WinWing Privacy Policy

1.Introduction

Hello! Welcome to the Ivymobileinternational Privacy Policy. This policy describes how Ivymobileinternational and, its other group companies (collectively described as “Ivymobileinternational”, “we”, “us” or “our”) and its third party marketing and advertising partners collect, use, process and share information about you.

Your privacy and trust are important to Ivymobileinternational. It is important that you check back regularly for updates to this Policy. If we make changes we consider to be important, we will let you know by placing a notice on the relevant Services and/or contact you using other methods.

2. Information and Data We Collect from You and How We Collect It

For purposes of this Privacy Policy, “personal data” means personally identifiable information that specifically identifies you as an individual.

a)Account Information

When you use our Apps or Services, you may register an account with us to track your progress and to sync your activity across devices. To register an account, you may be asked to provide certain personal information to us, including your name, email address, and password. You are solely responsible for ensuring your account information is correct and up-to-date.

b)Information From Social Media Platforms

Personal information collected by Ivymobileinternational is information voluntarily provided to us by you when you create your account or change your account information. The information includes your Facebook Id, name, gender, location and your friends’ id on Facebook. Ivymobileinternational also stores your game checking, likes, dislikes, recommendations and messages.

c)Activity and Usage Data

Ivymobileinternational may use collected personal data for purposes of analyzing usage of the Services, providing customer and technical support, managing and providing Services (including managing advertisement serving) and to further develop the Services and other Ivymobileinternational services and products. Ivymobileinternational may combine non-personal data with personal data.

d)non-personal information (Analytical Data)

We collect and use non-personal information (Analytical Data) during the use of our apps:

1. Are there any errors in the app? Where and when do they occur?

2. How long do users use our apps?

3. How do our users use our apps, which features are most popular and which ones are used less.

This helps us to gain a better understanding of our users, to draw conclusions for future concepts, and, ultimately, to develop better apps. In order to collect this information, we use Google Analytics.

The privacy policies for these services are available here:

http://www.google.com/analytics/terms/us.html

Please note that certain features of the Services may be able to connect to your social networking sites to obtain additional information about you. In such cases, Ivymobileinternational may be able to collect certain information from your social networking profile when your social networking site permits it, and when you consent to allow your social networking site to make that information available to Ivymobileinternational. This information may include, but is not limited to, your name, profile picture, gender, user ID, email address, your country, your language, your time zone, the organizations and links on your profile page, the names and profile pictures of your social networking site friends and other information you have included in your social networking site profile. Ivymobileinternational may associate and/or combine as well as use information collected by Ivymobileinternational and/or obtained through such social networking sites in accordance with this Privacy Policy.

3. How We Use Your Personal Information

We will only use your personal information as described in this Policy or as disclosed to you prior to such processing taking place. The purposes for which we may use your personal information include:

1)To Provide Our Services

We use your personal information to provide you with the Apps and any other services, purchases or requests in connection with the Services you request. This may include processing transactions, providing you with the requested features, syncing your data across your devices logged into your account, customer service, etc.

2)To Personalize Your Experience

We may process your information to personalize the Services for you. For example, we use your language preferences and country location to display the correct language and time zone in the Services. We also use certain information about your device (such as operating system version and screen resolution information) to optimize the display of pictures on your screen.

3)To Send You Service-Related Communications

We will use your information (such as contact information) to send you communications about your account, requested transactions, and changes in our policies. Please note that you may not opt out of such communications, which are necessary to keep you informed about important updates about your account and the Services.

4)To Conduct Analytics and Other Internal Purposes

We may use your personal information to conduct analytics. This can be used for quality control, internal auditing, and to measure how our Apps, Services, and ad campaigns are performing. We also use your personal information to accumulate and report aggregate, statistical information in connection with the Apps, Services and user activity, in order to help us operate, enhance and improve our Services.

5)To Ensure Security of our Services

While we are offering services, it is used for the purposes of identity verification, customer service, security protection, combatting spam, malware, and malicious activity, fraud monitoring, archiving and backups, ensuring the security of the products and services that we provide to you.

3.Who We Share Your Information With

We share your Information with selected third parties, including:

1)Other players and users: Because social features are a core component of our Games, other players and users may see your profile information and in-game activities, as well as any other information you choose to share with them, such as chat data.

2)Vendors and service providers we rely on for the provision of the Games, for example:

3)Cloud service providers who we rely on for data storage, including Amazon Web Services who are based in the U.S.

4)App Stores to allow you to make purchases via Google Play, IOS App Store, and maintain a record of such purchases. The information we are provided with includes your device ID and the in app purchase activity to enable us to provide you with the items you purchase from such App Stores.

5)Player support solution providers, who help us manage and respond to our player questions and complaints. This includes HelpShift, Inc. who is based in the U.S. and who hosts our player support function;

6)Analytics providers: We work with a number of analytics, segmentation and mobile measurement service providers who help us understand our userbase. This includes AppsFlyer and Firebase, who are based in the United States, and other analytics.

7)Social media: Should you play our Games via Facebook, social media interaction tools may be utilized to enhance social media features in the game such as accessing your friends list and displaying your profile picture;

8)User acquisition: We work with a variety of user acquisition partners to help us report on the success of our marketing campaigns. We may use some of your personal information to participate in Custom Audience and Lookalike Audience programmes, which enable us to display adverts to both existing and prospective players when they visit one of our partners’ websites.

9)Advertising partners: Our Games are supported by ads. Subject to your settings, we provide certain Information to advertisers who will use them to serve you with ads in our Games, and we measure who sees and clicks on their ads. We also share advertising identifiers, along with the interests or other characteristics of a device or the person using it, to help partners decide whether to serve an ad to that device or to enable them to conduct marketing, brand analysis, interest-based advertising, or similar activities.

10)Law enforcement agencies, public authorities or other judicial bodies and organisations: We disclose Information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection).

11)Change of corporate ownership. If we are involved in a merger, acquisition, bankruptcy, reorganisation, partnership, asset sale or other transaction, we may disclose your Information as part of that transaction.

3.Where We Process Your Information

Our service is global by nature and your Information can be collected from players anywhere in the world. Currently your Information is processed by our employees and service providers in the European Economic Area (“EEA”), the UK, Israel and the USA. Israel and the UK are countries which the European Commission has decided offer an adequate level of data protection. Because countries outside of the EEA may have different data protection laws, we take steps to ensure that all transfers are protected by adequate safeguards, including the use of standard contractual clauses approved by the European Commission.

4.Opt-Out

You can opt-out of interest-based advertising in our Games by checking the privacy settings of your Android or iOS device and selecting "limit ad tracking" (Apple iOS) or "opt-out of interest-based ads" (Android). For more information, For personalized in-Game offers opt-out, you can use the options provided in the Game settings.

4.How Do We Protect Your Information

a)Security Safeguards: In order to help ensure a secure and safe player experience, we are continuously developing and implementing organisational, technical and physical security measures to protect your Information from unauthorized access or against loss, misuse or alteration. These measures include hashing of Information, segregating and limiting access to Information and requiring two factor authentication to access Information.

B)Retention: We retain your Information for as long as needed to provide you the Games and up to three (3) years from the date on which you stop interacting with the Games.

5. Data Retention & Right to deletion.

Ivymobileinternational retains your personal data for as long as needed to provide you Services, unless we are required by law to delete or if Ivymobileinternational accepts your request to delete the information. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Right to deletion. Subject to certain exceptions set out below, on receipt of a verified request from you, we will:

• Delete your personal information from our records; and

• Direct any service providers to delete your personal information from their records.Please note that we may not delete your personal information if it is necessary to:

• Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;

• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;

• Debug to identify and repair errors that impair existing intended functionality;

• Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;

• Comply with the California Electronic Communications Privacy Act;

• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;

• Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;

• Comply with an existing legal obligation; or

• Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

To exercise these rights, you can submit a request to exercise your rights in the Ivymobileinternational Privacy Portal or through the Privacy category in the Support page within the game you play. You have the right to not be discriminated against for exercising any of your rights. Please understand that, if the exercise of your rights limits our ability to process personal data (such as a deletion request), we may no longer be able to provide you with the Service.

5.Advertising

Our games may include advertising for third party products and services.

Ivymobileinternational and our advertising partners collect and use information about you to improve advertising, targeting and measurement systems so that we can show you relevant third party ads in our games. To provide our games, Websites and interest-based advertising, we use ad identifiers, cookies and similar technologies. This section describes our use of these technologies and how you can manage your preferences.

6.Security

Ivymobileinternational takes reasonable measures to protect your information from unauthorized access or against loss, misuse or alteration by third parties. Although we make good faith efforts to store the information collected on the Services in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third-party “hackers” from illegally obtaining access to this information. We do not warrant or represent that your information will be protected against, loss, misuse, or alteration by third parties. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

7.Children

You must be over a certain age to play our games and use our Services, depending on where you live. For the full list of age restrictions by country, please see below. We do not knowingly collect or solicit personal information from or direct or target interest based advertising to anyone under the ages set out below, or knowingly allow such persons to use our Services. If you believe that we might have any information from or about a child under the age set out below, please Contact Us.

8.Your rights

You have certain rights in connection with your personal information and how we handle it. You can exercise these rights at any time by contacting us via any of the methods set out in the Contact Us section below.

9.Contact us

To communicate with us and/or use your rights specified under this Privacy Policy please contact us at: help@ivymobile.com