PRIVACY AND DATA POLICY

1. INTRODUCTION AND GENERAL TERMS

These terms apply to the use of games and other products developed by STEVE MILLE INC PTE. LTD. (TS/ ‘we’ / ‘us’). Our registered office is at 3 Coleman Street, #03-24 Peninsula Shopping Complex, Singapore (569880).

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of all games, related online services (including online network play connectivity and interactivity) and other software and products made available by us (together the “Game(s)“), as well as any other online features relating to the Games including our website (the “Website”). Together the Game(s), and Website are referred to as the “Online Services”.

If you have any questions or comments about this Privacy Policy, please contact us at ceo@bravebitsglobal.com.

We are committed to protecting and respecting your privacy. The Privacy Policy explains the basis on which personal information we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through these Online Services is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.

Please read this Privacy Policy carefully as it contains important information about the following:

• What information we may collect about you;
• How we will use information we collect about you;
• Whether we will disclose your details to anyone else; and
• Your choices and rights regarding the personal information you have provided to us.

This Privacy Policy forms a part of and should be read in conjunction with our terms of use.

The Online Services may contain hyperlinks to services owned and operated by third parties. These third party services may have their own privacy policies and we recommend that you review them. They will govern the use of personal information that you submit or which is collected by cookies and other tracking technologies whilst using these services. We do not accept any responsibility or liability for the privacy practices of such third party services and your use of these is at your own risk.

We may make changes to this Privacy Policy in future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes. Where appropriate we may notify you of changes through the Games.

2. INFORMATION WE MAY COLLECT ABOUT YOU

We collect and process the following information which may include your personal data.

a) Information provided by you when using the Games (“Basic Information”)

We may collect the following information from you when you play our Games:

• your mobile device’s unique device ID (Device ID);
• your user preferences; and
• Core information related to your gameplay, such as your overall progression to a particular level or stage, your virtual currency stores or the completion of certain activities during your gameplay (for example, completing a tutorial, passing a level, making a purchase or viewing a video ad).

b) Information used for the purposes of serving advertisements (“Advertising Data”)

Through our third party advertising network partners, we may gather information about your devices when you install or play our Games, depending on the permissions you’ve granted. This may include:

• the make, model and operating system of your device;
• properties of your device, such as screen size and orientation, audio volume and battery;
• the mobile network operator linked to your device;
• the Games played;
• the country, time zone and locale settings on your device (i.e. country and preferred language);
• network connection type and speed;
• IP Address;
• MAC address;
• internet browser used to access the Games; and
• the advertiser ID, which is an identifier unique to you if you use an Apple or Android device, but which doesn’t reveal your name.

c) Information collected for the purposes of providing analytics (“Analytics”)

We may collect technical information about your use of the Online Services through the use of tracking technologies and analytics. Personal data we may collect includes the following:

• your Device ID;
• your user ID (which is generated by us and allocated to you when you first play our games);
• your device operating system & version;
• your device make and model;
• game play attempts, progression and results;
• session game time start, end and duration;
• purchase transaction types and spend you have made using virtual items in the Games;
• the country of your Device;
• the time, date and install source of your first download (e.g. from a clicked advertisement);
• advertisements viewed and clicked; and
• identification of crashes and defects.

d) Information about you collected from third parties (“Third Party Log In Information”)

When you access the Games via a third party social media provider such as Facebook, we may collect and store personal and non-personal information which is available on that third party social media provider, such as your Facebook name, your profile picture or its URL, your Facebook ID and other public data of your friends, provided that you have expressly agreed to the use of Facebook within the Games. We will also receive technical data in order to ensure the Games connect to the correct Facebook account.

e) Information collected through Publisher Provided Identifiers (PPID)

In order to improve advertising relevance and to help our advertising partners deliver, measure, and cap the frequency of ads, we may generate and assign a pseudonymous identifier (commonly referred to as a “Publisher Provided Identifier” or PPID) when you use our Online Services.

• The PPID is a first-party identifier controlled by us.
• It is created in a pseudonymous and hashed format and does not contain personally identifiable information such as your name, email address, or phone number.
• The PPID may be used within our network of websites and services to help advertising partners (including Google Ad Manager and Authorized Buyers) deliver ads, measure unique reach, and apply frequency capping in a privacy-safe manner.
• The PPID is not shared across unrelated third-party publishers.
• For users in regions that require consent (for example, the European Economic Area or the United Kingdom), we will only send the PPID to advertising partners if you have granted the appropriate consent through our consent management platform. If you decline consent, ads may still appear but will not use the PPID and will be served in a non-personalized manner.

3. WHY WE COLLECT INFORMATION ABOUT YOU

a) To provide our Games to you

We will use information about you (including Basic Information, Third Party Log In Information, Analytics and User Content) for delivering our Games to you under the terms of use agreed between us...

b) To help us improve the Online Services and fix any problems

We may process information about you (including Basic Information, User Content and Analytics) so that we can analyse and improve our Games and Online Services...

d) To acquire new users and engage current users

We may process information (including some Advertising Data and Analytics) to encourage engagement from our less active users...

e) To improve the monetisation of the Games via in-app purchases

We may process information (including Basic Information, User Content, Advertising Data and Analytics) to understand how users use our Games...

f) For advertising purposes

We may process Advertising Data to show you advertisements for third party services...

We work with the following third party advertising networks:

• Chartboost
• Adcolony
• Facebook
• Unity
• Google

g) To prevent fraud and illegal activity

We process personal data for our legitimate interests of ensuring that any use of the Online Services is lawful and non-fraudulent...

4. DATA SHARING

We will share your information with third parties only in the ways that are described in this Privacy Policy...

Group members, personnel, suppliers or subcontractors... Merger or acquisition... Required by law... Enforcement... Digital Content Stores...

5. AUTOMATED DECISION MAKING

We may use automated decision making methods which do not involve human involvement to process your information only in the ways that are described in this Privacy Policy...

6. CONSUMER CONTROL AND OPT-OUT OPTIONS

If you do not wish to be part of a lookalike campaign, receive notifications from us or be served with targeted advertisements you can opt-out by changing your advertising and notification settings on your device directly...

7. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU

You have the following rights over the way we process personal data relating to you...

• Ask for a copy of data we are processing about you and have inaccuracies corrected
• Object to us processing data about you
• Obtain a machine readable copy of your personal data...
• Make a complaint to a Supervisory Authority

To make a request, please let our Data Protection Officer know by submit request on my website.

8. DATA RETENTION

We will hold your personal information on our systems for as long as is necessary for the relevant service, or as otherwise described in this Privacy Policy.

9. CHILDREN

We do not use our Online Services to knowingly solicit information from or market to children under the age of 13...

10. SECURITY

We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information...