PRIVACY POLICY

PRIVACY AND DATA POLICY

ISSUED BY 3DevTech

Last Updated: November 2023

INTRODUCTION AND GENERAL TERMS

These terms apply to the use of apps and other products developed by 3DevTech (‘we’ / ‘us’).

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of all apps, related online

services (including online network play connectivity and interactivity) and other software and products

made available by us, as well as any other online features relating to the apps including our website (the

“Website”). Together the App(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

threedevtech@gmail.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 Apps.

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 Applications

(“Basic Information”)

We may collect the following information from you when you use our Applications:

your mobile device’s unique device ID (Device ID);

Photos/Media/Files

read the contents of your USB storage

modify or delete the contents of your USB storage

Storage

read the contents of your USB storage

modify or delete the contents of your USB storage

Wi-Fi connection information

full network access

view network connections

your user preferences; and

Core information related to your app usage, such as your overall progression to a particular level or

stage, your virtual currency stores or the completion of certain activities during your usage (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 use our Apps, 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 apps used;

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 Apps; 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 use our apps);

your device operating system & version;

your device make and model;

app usage attempts, progression and results;

session app time start, end and duration;

purchase transaction types and spend you have made using virtual items in the Apps;

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 Apps via a third party social media provider such as Facebook, twitter or any other

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 Apps. We will also receive technical data in order to ensure the Apps connect to the correct

Facebook account.

WHY WE COLLECT INFORMATION ABOUT YOU

a) To provide our Apps to you

We will use information about you (including Basic Information, Third Party Log In Information, Analytics

and User Content) for delivering our Apps to you under the terms of use agreed between us. The

processing of information in this way is necessary for us to record your progress and current status within

an App, and to ensure the Apps deliver the features promised and function properly, so that you have the

best experience when playing any one of our Apps.

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 Apps and Online Services.

This processing is also necessary for us to pursue our legitimate interests of (i) ensuring that our Online

Services function properly so that you and other users have the best experience when using any of our

App(s) and using the other Online Services; (ii) improving the quality of our Online Services, and

providing a better experience to our users; (iii) identifying and correcting any bugs in the Apps and Online

Services and iv) understanding the effectiveness of our marketing to attract new users and re-engage our

current users at an aggregated level.

c) 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 and to notify them with new virtual items or other promotions on offer.

We may also process this information to pursue our legitimate interests of acquiring new users for our

Apps.

We use various forms of marketing to acquire new users. The information we collect about you may be

used to improve the relevancy of our marketing, including the creation of ‘lookalike’ audiences. This

allows us to offer more relevant marketing to potential new service users without using information that

personally identifies you.

d) To improve the monetisation of the Apps via in-app purchases

We may process information (including Basic Information, User Content, Advertising Data and Analytics)

to understand how users use our Apps, and to compile statistical reports regarding that activity, as well

as understanding how users progress, and their current status within an App. This processing is

necessary for us to pursue our legitimate interests of improving the Apps and increasing the amount of

revenue generated via in-app purchases. This may include the implementation of dynamic pricing

models, so that in-app purchases are priced according to relevant factors, such as geography and app

usage progression so that we can offer temporary promotional discounts.

e) For advertising purposes

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

advertising that may reward you with benefits during your use of the Apps.

The information we collect about you may be used to understand how advertisements placed in our Apps

have performed or how many people have viewed certain advertisements. We aggregate this information

so that it does not personally identify you or permit you to be treated individually.

We may also use this information to reward users with benefits that can be used for further enjoyment of

the Apps from the viewing of certain advertising placed in our Apps.

We will not pass or process your information for the purposes of marketing by third parties unless you

give your consent should we ask for it. After you have given your consent, you may withdraw it at any

time.

We may use the information we collect about you to serve you targeted advertisements in our Apps. We

do this to provide you with more relevant advertising content.

If you would like to find out more about the way these third parties collect and process your information

please refer to their respective privacy policies and/or terms and conditions.

f) 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, does not disrupt the operation of our services, does not harass our staff or

other individuals, to enforce our legal rights and to comply with our legal obligations.

Where we reasonably believe that you are or may be in breach of any applicable laws or our terms of

use, we may use your personal information to inform relevant third parties such as your law enforcement

agencies about the content.

We reserve the right to disclose your identity to any third party who is claiming that any User Content

posted by you constitutes a violation of their intellectual property rights, or of their right to privacy. You

may not copy, download or embed any User Content without the express written permission of the

content owner. You may not use any User Content for any commercial purposes, or any public

performances.

We work with Apple and Google to assist us with fraud prevention and the detection of any illegal activity

(e.g. to verify in-app purchases made through iTunes and Google Play).

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: We keep your information confidential, but may

disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and

its subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, suppliers or

subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy.

However, this is on the basis that they do not make independent use of the information, and have agreed

to safeguard it.

Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of its assets,

any third party to which we sell or transfer our assets to will have the right to continue to use the personal

and other information that you provide us in the manner set out in this Privacy Policy.

Required by law: In addition, we may disclose your information to the extent that we are required to do so

by law (which may include to government bodies and law enforcement agencies); in connection with any

legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our

legal rights (including providing information to others for the purposes of fraud prevention).

Enforcement: We may also disclose your personal information to third parties in order to enforce or apply

the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of

3DevTech, our customers/users, or others.

Digital Content Stores: Where the Apps are downloaded through Google Play, iTunes and/or Amazon

Appstore, we may disclose your personal information to Google, Apple and/or Amazon respectively for

the purposes of facilitating any in-app payments made through these platforms.

Additional information for users in Europe

This section of the policy applies to the users that are located in the European Economic Area (EEA),

Switzerland or United Kingdom (UK). 3DevTech processes your personal data in accordance with

European laws and regulations, such as the General Data Protection Regulation (GDPR) and UK

General Data Protection Regulation (UK GDPR).

(a) Controller's details

For the purposes of the GDPR and UK GDPR, 3DevTech is the controller of your personal data, and we

can be contacted using the details provided.

In certain circumstances, we process personal data as a processor on behalf of our customer. 3DevTech

these cases, it is the 3DevTech customer that is responsible for the processing of your personal data and

processing will be governed by the terms of the Data Processing Addendum it has entered with the

customer. If you have questions or concerns about how your personal data is handled by one of our

customers, you should contact the relevant customer that is using our Service and refer to their separate

privacy policies.

(b) Legal bases for processing

If you are located in the EEA, Switzerland or UK, we need a lawful basis to collect, use and disclose your

personal data as a controller. Our lawful basis will depend on the information concerned and the context

in which it is processed.

Generally, 3DevTech will collect and use your information as follows:

Contractual necessity: We need it to provide the Service to you and fulfil our obligations to you under our

may experience with the Service, obtaining payment for our Services and providing you with access to

your designs.

Legitimate interests: It is necessary for our legitimate interests for example, providing a useful and

customized Service, sending you relevant marketing messages, displaying advertising and tracking its

effectiveness, using information we collect about you (like your spending, platform usage, occupation and

employer) so that we can make more informed predictions, decisions and offers for our users, helping

users connect with team members and their employer's and enhancing our Service via research and

development, data analytics, data labelling, machine learning and predictive analytics relating to your

usage data. We do not rely on this lawful basis where our legitimate interests are overridden by your

rights and interests.

Consent: You consent to us, and our third party partners, using your information in a certain way – for

example, to hear about new features or offers, and for machine learning and predictive analysis relating

to your User Content.

Legal obligations: It is necessary for compliance with our legal obligations – for example, to disclose your

information in response to law enforcement requests and to retain your information for our record

keeping purposes.

If you consented to our use of your information, you can withdraw that consent at any time. Depending

on the situation you can either withdraw your consent by emailing threedevtech@gmail.com.

Where we use your information for our legitimate interest, you have the right to object to that use by

contacting threedevtech@gmail.com. However, if you do, it may diminish the quality of the Service you receive or

prevent you from using the Service.

By signing up, you understand and agree that 3DevTech will receive and process your personal data. We

may transfer your personal data to other countries where our affiliates and service providers are located.

Please note that some of these countries may have data protection laws that are different from your

country (and, in some cases, may not be as protective). For users in the EEA, Switzerland or UK, where

we transfer your information to a third-party service provider that is not located in Europe, and is not in a

country that benefits from an adequacy decision by the European Commission, UK or Swiss authorities,

we will require those third party providers to enter into an agreement that provides appropriate

safeguards for your information, including by using the EU Model Clauses and the UK International Data

Transfer Addendum.

Summary: If you are accessing our Service from Europe, 3DevTech is the controller of your personal

data. In some cases, though, we may only be processing your information on behalf of a Team as a

processor. We only process your data if we have a lawful basis. We may transfer your information

outside of Europe subject to appropriate safeguards.

12. Additional information for users in the United States

This section of the policy applies to 3DevTech users that are located in the United States. In certain U.S.

states, 3DevTech users have additional rights afforded to them under applicable state privacy laws,

including the California Consumer Privacy Act as amended by the California Privacy Rights Act, the

Virginia Consumer Data Protection Act, the Colorado Privacy Act, and the Connecticut Data Privacy Act.

(a) Categories of personal information collected by 3DEvTech

For more details about the personal information 3DevTech has collected in the past year, please see

“Information we collect”. For details on how we use that information, who we share it with, and how long

we keep it, please see relevant section on this page.

(b) Rights in respect of your personal information

These state privacy laws give resident users various rights with respect to the personal information we

collect, including the right to (subject to applicable law and certain limitations):

Request access to the personal information 3DevTech has collected about you;

Request that 3DevTech delete your personal information;

Request that 3DevTech correct inaccurate personal information;

Opt out from the "sale" of your personal information;

Opt out of the "sharing" of your personal information for cross-context behavioral advertising;

Appeal decisions where we deny your rights request.

You may make a request by contacting us at threedevtech@gmail.com. We will authenticate your request using

the email address associated with your account and if necessary, proof of residency. Depending

on applicable state law, you may also appeal a refusal to take action on a request by contacting us at

threedevtech@gmail.com.

You may opt out of the “selling or sharing” of your personal information, which may include us sharing

your information with third party advertising partners as described in relevant section "Advertising" or

providing your employer with information confirming whether or not you use our apps using their email

domain. You can opt out by following the instructions on the “Do not sell or share my personal

information” banner, or by emailing threedevtech@gmail.com.

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

We may process your personal information via automated decision making methods in order to identify

users who are suspected of cheating in the Apps. Our automated decision making methods are designed

to detect cheating by looking out for (i) excessive currency stores against actual completed app usage;

and (ii) excessive content against actual purchases made and completed app usage.

If users are determined to be or suspected of cheating the following actions may be taken and which will

be unknown to the user:

an increase in the number of advertisements displayed within the Apps; and

an increase in the frequency of suspected cheats using against other suspected cheats.

We may block users from the Apps and/or the Online Services who are determined to be cheating

following an automated decision process. In this scenario the user will be notified of the outcome and will

have the right to obtain human intervention to express his or her point of view and to contest the decision

to block access to the App and/or the Online Services.

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.

You can withdraw your consent to targeted advertising by changing your advertising settings on your

device at any time.

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, as set out in the

table below. We aim to comply without undue delay, and within one month at the latest.

To make a request, please let us know by sending an email to threedevtech@gmail.com.

a) Ask for a copy of data we are processing about you and have inaccuracies corrected

You have the right to request a copy of the personal information we hold about you and to have any

inaccuracies corrected.

We will use reasonable efforts to the extent required by law to supply, correct or delete personal

information held about you on our files (and with any third parties to whom it has been disclosed to).

b) Object to us processing data about you

You can ask us to restrict, stop processing, or to delete your personal data if:

you consented to our processing the personal data, and have withdrawn that consent;

we no longer need to process that personal data for the reason it was collected;

we are processing that personal data because it is in the public interest or it is in order to pursue a

legitimate interest of 3DevTech or a third party, you don’t agree with that processing, and there is no

overriding legitimate interest for us to continue processing it;

the personal data was unlawfully processed;

you need the personal data to be deleted in order to comply with legal obligations;

the personal data is processed in relation to the offer of a service to a child.

c) Obtain a machine readable copy of your personal data, which you can use with another service

provider

If we are processing data in order to perform our obligations to you, or because you consented, or if that

processing is carried out by automated means, we will help you to move, copy or transfer your personal

data to other IT systems.

If you request, we will supply you with the relevant personal data in digital format. Where it is technically

feasible, you can ask us to send this information directly to another IT system provider if you prefer.

d) Make a complaint to a Supervisory Authority

If you are unhappy with the way we are processing your personal data, please let us know by contacting

us via the email.

If you do not agree with the way we have processed your data or responded to your concerns, an

alternative is to submit a complaint to a Data Protection Supervisory Authority.

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.

CHILDREN

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

age of 13. Our terms of use prohibit users aged under 13 years from accessing our Online Services. In

the event that we learn that we have collected personal information from a child under 13 years of age

we will delete that information as quickly as possible. If you believe that we might have any information

from or about a child under 13 years of age please contact us at threedevtech@gmail.com.

SECURITY

We will take all reasonable technical and organisational precautions to prevent the loss misuse or

alteration of your personal information. For example, our databases are password protected and limited

to essential employees only (such as 3DevTech management or employees whose main role requires

system access).

Please be aware that, although we endeavor to provide reasonable security for information we process

and maintain, no security system can prevent all potential security breaches.

CONTACT INFORMATION

All questions, comments or inquiries should be directed to 3DevTech at threedevtech@gmail.com. We

will endeavor to respond to any query or questions within business days.