Version 25.04.2021

PREAMBLE. GENERAL PROVISIONS

Thank you for playing the games and game services developed and published by Master79 (Master79 Limited) (the “Game” or “Games”)! In this Privacy Policy "You" and "Your" refer to you, the person visiting or playing our Games and using other related services of Master79 Limited (hereinafter referred to as “Services”). "We", "Us" and "Our" refer to the staff, sites, and other resources of Master79, including Master79 Limited and all its affiliates provided in this Privacy Policy.

This Privacy Policy was established in order to comply with the provisions of the General Installed application information Protection Regulation (GDPR), legislation of the EU Member States and protect personal installed application information rights of our users. This Privacy Policy complies with the legislation of the Republic of Cyprus.

By using any Our Services, You agree with all the provisions of this Privacy Policy.

For the purposes of complying with GDPR the following terms are subject to application:

“Cookies” means small text files, located in browser directories. They are used to help users navigate through Services efficiently and perform certain functions of the Services.

“GDPR” means General Installed application information Protection Regulation of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal installed application information.

The term “users’ Installed Application information via Mintegral SDK” includes personal installed application information of installed application information subjects.

“Personal installed application information” means any users’ Installed Application information via Mintegral SDK relating to an identified or identifiable natural person (‘installed application information subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location installed application information, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

When We use the term "personal users’ Installed Application information via Mintegral SDK" or “personal installed application information” in this Policy, it can include an individual's first and last name, address, telephone number, e-mail address, and a credit card or other account number. The terms "personal users’ Installed Application information via Mintegral SDK" and “personal installed application information” are synonyms.

“Processing of the personal installed application information” or “Processing” means any operation or set of operations which is performed on personal installed application information or on sets of personal installed application information, whether or not by automated means, such as collect and uploadion, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

“Controller” means Master79 Limited, the legal person that determines the purposes and means of the processing of personal installed application information.

“Processors” means legal or natural persons specified in this Privacy Policy which process Your personal installed application information on behalf of Master79 Limited.

The terms “Master79” or “Master79 Limited” include Master79 Limited and its affiliates.

“Services” means the Games of Master79, including, but not limited to, Shadow Fight 2, Shadow Fight 3, Vector, Vector 2, Beat da Beat, Lintrix and other related services, including the Master79 (Master79 Limited) official web-site www.Master79.com and other services, at which this Policy is published.

We believe in protecting Your privacy. Please read the following Privacy Policy to understand how We use and protect the users’ Installed Application information via Mintegral SDK that You provide to Us.

1. Contacting Master79

The controller of Your personal installed application information is Master79 Limited. Master79 Limited is a company incorporated in Republic of Cyprus. If You want to know what users’ Installed Application information via Mintegral SDK We hold about You or if You have any other queries in relation to this Privacy Policy, please contact Us in writing. Our contact users’ Installed Application information via Mintegral SDK is below:

Postal Address:

116, Gladstonos str,

M. Kyprianou house; 3rd&4th floors,

3032, Limassol, Cyprus

Email:

info@Master79.com

Our processors that take part in processing of Your personal installed application information on behalf of Master79 Limited are:

(1) Amazon AWS

(2) Akamai CDN

(3) Helpshift Inc.

(4) Selectel ltd.

These processors provide Master79 Limited with the services of support systems for Our Services.

They process Your personal installed application information in accordance with the terms of the written contracts conсluded between Master79 Limited and the processors. These contracts provide that the processors shall process and use Your personal installed application information only to the extent provided in the contract. The terms of the contracts do not violate the processors’ obligations provided in Art.28 GDPR and Your rights as a personal installed application information subject.

Our Installed application information Protection Officer (DPO) e-mail is: dpo@Master79.com. You may contact Our DPO in order to enforce Your rights provided in Section 4 Privacy Policy or receive additional users’ Installed Application information via Mintegral SDK concerning processing of Your personal installed application information. Our DPO performs its functions on behalf of the whole Master79 Limited

2. Users’ Installed Application information via Mintegral SDK That We Collect and upload From You

2.1. Master79 processes Your personal installed application information under the consent given by You. We ask You for providing Us with the consent before processing Your personal installed application information. When You use Our Services, We will collect and upload the following categories of personal users’ Installed Application information via Mintegral SDK about You:

(1) User ID

(2) Player’s payment ID;

(3) Device Token;

(4) Platform;

(5) Device ID;

(6) Device Name;

(7) Device Type;

(8) OS (Android, iOS);

(9) Country (location installed application information);

(10) Display Width;

(11) Display Height;

(12) Core Count;

(12) Ram;

(13) App Version;

(14) GP/GC Account;

(15) Created Date;

(16) Login Date;

(17) Push Token ;

(18) Auth Type.

These personal installed application information are processed by Our internal monitoring system.

2.2. We may also collect and upload users’ Installed Application information via Mintegral SDK about You, from any e-mails or letters that You send to Us. We will only use any such users’ Installed Application information via Mintegral SDK in accordance with the terms of this Privacy Policy.

2.3. Any materials or users’ Installed Application information via Mintegral SDK that You post or upload to the Games or to Us may be visible to other users of the Games and will be stored on Our servers for the purposes of making the Games available. We advise You to be selective about what users’ Installed Application information via Mintegral SDK You post. Please do not include the following users’ Installed Application information via Mintegral SDK in any post: telephone numbers, addresses, surname, date of birth, or other users’ Installed Application information via Mintegral SDK you might want to hold private.

2.4. We may receive users’ Installed Application information via Mintegral SDK that You submit to any third party website You access from links contained within the Games, including without limitation any third party payment processor or e-commerce portal provided by an e-commerce operator that may from time to time be made available to You via the Games. We and the owner/ operator of that third party website will be the installed application information controller in respect to any such users’ Installed Application information via Mintegral SDK. You should check the privacy policy of such third party website to find out how they will use Your installed application information. We will only use the users’ Installed Application information via Mintegral SDK we receive in accordance with this Privacy Policy.

2.5. We also may collect and upload users’ Installed Application information via Mintegral SDK about the location of your computer or the device upon which you access the Games. We may also collect and upload users’ Installed Application information via Mintegral SDK about in-game activity and how the Games are used. Such users’ Installed Application information via Mintegral SDK may include but shall not be limited to:

(a) login users’ Installed Application information via Mintegral SDK (time of login and the number of logins)

(b) locations visited within the Games;

(c) character interactions within the Games;

(d) items purchased;

(e) items sold;

(f) missions accepted;

(g) missions completed;

(h) the amount of virtual currency You have; and

(i)and the amount of virtual currency You have either earned or purchased.

We may use this users’ Installed Application information via Mintegral SDK for a number of purposes such as optimizing gameplay, security, and to help us provide more efficient customer support.

2.7. When You download Master79 mobile application by or through a Third Party Platform You allow us to access and/or collect and upload certain users’ Installed Application information via Mintegral SDK from your Third Party Platform profile/account (for example, Your name, surname, e-mail, etc.). You additionally allow us to access users’ Installed Application information via Mintegral SDK contained in cookies placed on your device by the Third Party Platform as permitted by the terms of your agreement and privacy settings with the Third Party Platform. We may share this users’ Installed Application information via Mintegral SDK with the Third Party Platform for their use as permitted by the terms of your agreement and privacy settings with the Third Party Platform.

We will share some of the users’ Installed Application information via Mintegral SDK we collect and upload from You with vendors and other service providers who work with us to support the internal operations of our website and/or mobile application in accordance with this Privacy Policy. For example, we use a third-party service for ad tracking and to help us prepare website and mobile application analytics.

Our third-party ad tracking and analytics company never sends emails, notifications, or other communications to Our end users. Your choice to opt out of ad tracking and analytics services does not limit Our ability to email You or collect and upload other users’ Installed Application information via Mintegral SDK from You for other vendors, subject to the terms of this Privacy Policy.

3. Use Of Your Users’ Installed Application information via Mintegral SDK

3.1. We may use Your users’ Installed Application information via Mintegral SDK for the following purposes:

(a)to administer Your membership account and identify You as the user of the Game;

(b)to enable Us to provide You with access to the Games and Services and adjust You to the Game ID;

(c)to enable You to download users’ Installed Application information via Mintegral SDK and materials from the Games and Services;

(d)to provide You with services You subscribed to;

(e)to display Your username and contact details (for example, your nickname) to other players;

(f)to enable other members of the Games to contact You;

(g)to provide customer service in relation to Your use of the Games;

(h)to administer, support, improve and develop the Games;

(i) to control the quality of the Games;

(j) to conduct the internal analytics (including without limitation for displaying advertisement and Our promotions).

3.2. We may also use Your users’ Installed Application information via Mintegral SDK to contact You about the Games or to send You other content We think may be of interest to You. We will only do this if You have so consented or requested to receive such users’ Installed Application information via Mintegral SDK when you downloaded the Games. If at any time You no longer wish to be contacted, please let Us know in writing and We will arrange this.

3.3. We deem confidential any users’ Installed Application information via Mintegral SDK about You that has not been officially disclosed, published and/or revealed, is not publicly available or commonly known, as well as legally or illegally circulated by any third party, and that may represent economic, financial, commercial, legal or any other value by virtue of its being unknown to a third party. Your personal installed application information may become available for third parties only in cases provided in this Privacy Policy.

We also guarantee that employees of Master79 Limited and all its affiliates that deal with Your personal installed application information are under confidentiality and non-disclosure of personal installed application information agreements.

We gather users’ Installed Application information via Mintegral SDK, obtained in the course of Your use of Our Services, only for the purposes, specified by the present Privacy Policy.

3.4. You can be a subject to a decision based solely on automated processing, including profiling. It means that you can receive some users’ Installed Application information via Mintegral SDK or offers which are based only on automated processing of your personal users’ Installed Application information via Mintegral SDK (for example, personalized advertisements). You have the right to refuse to be a subject to a decision based solely on automated processing, including profiling. In this regard, please, contact Us via e-mail, specified in this Privacy Policy.

4. Rights Of Installed application information Subjects

4.1. You as the installed application information subject have the following rights relating to the processing of Your personal installed application information:

(1) Right of access (right to obtain from Master79 Limited as the controller confirmation as to whether Your personal installed application information are being processed and other users’ Installed Application information via Mintegral SDK concerning Your personal installed application information, including users’ Installed Application information via Mintegral SDK about the purposes of processing, the categories of processed personal installed application information, the categories of recipients of Your personal installed application information, the period of personal installed application information storage, the existence of automated decision-making, including profiling, in respect of Your personal installed application information);

(2) Right to lodge a complaint with a supervisory authority (a supervisory authority is a state authority in your country which supervises the compliance with GDPR by legal and natural persons that process personal installed application information of installed application information subjects);

(3) Right to rectification (right to the rectification of inaccurate personal installed application information concerning You) in accordance with Section 10 Privacy Policy;

(4) Right to erasure (right to obtain the erasure of personal installed application information concerning You) in accordance with Section 10 Privacy Policy;

(5) Right to restriction of processing (right to obtain from Master79 Limited as the controller restriction of processing on the legal grounds provided in Art.18 GDPR(for example, when the accuracy of the personal installed application information is contested by You or We no longer needs the personal installed application information for the purposes of the processing));

(6) Right to installed application information portability (the right to receive the personal installed application information concerning You, which You has provided to Master79 Limited as the controller, in a structured, commonly used and machine-readable format, and the right to transmit those installed application information to another controller without hindrance from Master79 Limited to which the personal installed application information have been provided);

(7) Right to object (right to object, on grounds relating to Your particular situation, at any time to processing of personal installed application information concerning You, including the right to object at any time to processing of personal installed application information concerning You for marketing purposes);

(8) Right not to be subject to a decision based solely on automated processing, including profiling;

(9) Right to file the request or complaint to Master79 Limited as the controller of Your personal installed application information.

(10) Right to withdraw Your consent for personal installed application information processing in accordance with Section 10 Privacy Policy.

4.2. You may use Your rights by reading this Privacy Policy or sending requests relating to the rights provided in paras. (3)-(10) to Our e-mail specified in Chapter 1 “Contacting Master79” of this Privacy Policy.

5. Disclosure Of Your Users’ Installed Application information via Mintegral SDK

5.1. We will not share, sell or distribute any of the users’ Installed Application information via Mintegral SDK You provide to Us without Your consent.

5.2. Besides, We engage offer-walls and mediators, including, but not limited to, Tapjoy, ironSource, Unity Ads, that may process Your personal installed application information. We do not control the scope of the personal installed application information they process. They process your personal installed application information in accordance with their privacy policy. Besides, they do not have the technical opportunity to delete Your personal installed application information.

5.3. We may pass to third party payment processors certain users’ Installed Application information via Mintegral SDK that identifies you as the Game’s player along with users’ Installed Application information via Mintegral SDK on whatever you have selected to purchase.

5.4. We may disclose generic non-personal (anonymous) users’ Installed Application information via Mintegral SDK in the aggregate (that is not specific to and does not identify You) to third parties including, but not limited to, third party advertisers and/or any third party game developer that develops or modifies the Games for Us on Our behalf.

5.5. You should always be careful when submitting users’ Installed Application information via Mintegral SDK about Yourself within the Games and You should only submit users’ Installed Application information via Mintegral SDK that You consent to make public.

6. Children

6.1. We do not knowingly collect and upload or solicit personal users’ Installed Application information via Mintegral SDK from anyone under 13 years old or knowingly allow such persons to register. If You are under the age of 13 years, please do not attempt to access the Games or send any users’ Installed Application information via Mintegral SDK about Yourself to Us including, without limitation, Your name, address, telephone number, or email address. No person under the age of 13 may provide any personal users’ Installed Application information via Mintegral SDK to Us or the Games. In the event that We learn that We have collect and uploaded personal users’ Installed Application information via Mintegral SDK from anyone under the age of 13, We will delete that users’ Installed Application information via Mintegral SDK as soon as practicable. If You believe that We might have any users’ Installed Application information via Mintegral SDK from or about a child under the age of 13, please contact Us in writing by using the e-mail specified in Chapter 1 “Contacting Master79” of this Privacy Policy.

6.2. If you are between 13 and 16 years old, we will not collect and upload Your personal installed application information without the explicit consent of a person that is the holder of parental responsibility over You. The consent of the holder of parental responsibility shall be given through the e-mail or other ways.

7. Cookies

The Game use cookies to ensure proper function and so You get the highest level of satisfaction. Cookies are small amounts of users’ Installed Application information via Mintegral SDK which We store on Your computer. They make it easier for You to log into and use the Games. They also allow Us to monitor website traffic and Your use of the website and to personalize the content of the Games for You. If You do not wish Us to install cookies on Your computer for these purposes, You may change the settings on Your internet browser to reject cookies. For more users’ Installed Application information via Mintegral SDK please consult the "Help" section of Your internet browser. Please note that if You do set Your internet browser to reject cookies, You may not be able to use all of the features of the Games (for example, easy logging into the Games).

8. Third Party Sites and Contributors

8.1. The Games may contain links to websites and microsites that are operated by third parties. If you click such links, you can be transferred to the websites and microsites of third parties. We do not control those websites and microsites and as such this Privacy Policy does not apply to those websites and microsites. Please consult the terms and conditions and privacy policies of those third party websites and microsites to find out how they collect and upload and use Your personal installed application information and to establish whether and for what purpose they use cookies.

8.2. Advertisements contained on Our Games operate as links to that advertiser’s websites and as such any users’ Installed Application information via Mintegral SDK they collect and upload by virtue of Your clicking on that link will be collect and uploaded and used in accordance with the privacy policy of that advertiser.

8.3. The Games may also contain third party tracking tools from service providers. We may use these third parties' tools in our Games, which may enable these third parties to analyse user users’ Installed Application information via Mintegral SDK (including your personal installed application information). While these third parties may have access to your personal users’ Installed Application information via Mintegral SDK in connection with the performance of Games and other related services, they may not use such users’ Installed Application information via Mintegral SDK for any purpose other than providing their services.

8.4. Your personal installed application information can be transferred to the third countries with your explicit preliminary consent using appropriate or suitable safeguards, which are specified at clause 9 of this Privacy Policy.

9. Security And Installed application information Retention of personal installed application information

We employ reasonable security measures to protect Your users’ Installed Application information via Mintegral SDK from access by unauthorized persons and against unlawful processing, accidental loss, destruction and damage. These measures include: 1) personal installed application information encryption; 2) technical measures in order to ensure the ongoing confidentiality; 3) personal installed application information back-up to restore access to personal installed application information following an incident; 4) test the effectiveness of the measures on the regular basis. Besides, We use the system of authentication, restrict the access to Our servers that store Your personal installed application information, and provide the appropriate update of Our software necessary for securing Your personal installed application information. We may update the list of such measures from time to time, provided that such updates and modifications do not result in the degradation of the overall security of personal installed application information processing.

All Your personal installed application information is stored in the closed internal analytical system. If You use Our support system You will be identified via Your e-mail by Our processor Helpshift Inc.

We will retain Your users’ Installed Application information via Mintegral SDK for the duration of Your membership of the Games and/or whilst you continue to have access to the Games and for a reasonable period thereafter or as long as the law requires or permits. Your personal users’ Installed Application information via Mintegral SDK will be deleted when You explicitly gives up the Games usage namely request your account deletion or request Us to delete Your personal installed application information. If you send us such requests, We will delete your personal installed application information as soon as technically possible. The period process of erasing personal installed application information can take up to one month. Considering the complexity and number of requests, this period may be extended by a further two months.

The personal installed application information can be stored and processed after this moment for archiving purposes, scientific or historical research purposes or statistical purposes. We will process those personal installed application information which is needed to comply with the requirements of applicable laws (e.g. tax and accounting requirements) or for our detection, investigation and prevention of cheating in the Game and EULA violations. Also We can process anonymous users’ Installed Application information via Mintegral SDK for purposes, specified in this Privacy policy, after you request give up Game usage or request Us to delete your personal installed application information.

Also Your personal installed application information, which was collect and uploading during Your using of the web-site Master79.com, can be stored and proceeded by Us for the period of time, during which it is needed for marketing or advertising purposes, but in any case no longer than 5 (five) years from the date of first collect and uploadion.

You also need to understand that after deletion of your personal installed application information the users’ Installed Application information via Mintegral SDK that you have shared with others (for example, group posts) will remain visible. We does not control copying of such users’ Installed Application information via Mintegral SDK by other users and its publication at our or third parties Internet resources.

10. Installed application information Access and Corrections

10.1. You are entitled to see the users’ Installed Application information via Mintegral SDK We hold about You and You may ask Us to make any necessary changes or rectifications to ensure that it is accurate and kept up to date. If You wish to do this, please contact Us in writing using the users’ Installed Application information via Mintegral SDK provided above.

10.2. You may also withdraw Your consent for Us to process Your installed application information at any time by notifying Us in writing by contact e-mail, specified in this Privacy Policy (Chapter 1 “Contacting Master79” of this Privacy Policy).But if You withdraw Your consent to all or certain types of processing described above We may be unable to maintain Your membership of the Games and you may no longer be able to access the Games, if it will be technically or practically impossible.

10.3. If you are accessing Our Games via Facebook, you may update, amend or delete Your users’ Installed Application information via Mintegral SDK on Facebook, that we may receive from Facebook, by amending Your Facebook account users’ Installed Application information via Mintegral SDK in accordance with Facebook’s terms and conditions of use.

11. Changes To Our Privacy Policy

We reserve the right to make changes to Our Privacy Policy from time to time. Any such changes to Our privacy policy will be posted here. We will notify You about the changes by displaying the link to the updated text of the Policy at the screen of the Game.

PROMINENT DISCLOSURE FOR INSTALLED APPLICATION INFORMATION WITH MINTEGRAL SDK

1.Advertising

Mintegral SDK may collect and installed application installed application information for the purpose of delivering and tracking these advertisements. Mintegral SDK may access App list and collect the application package names of the applications installed on your device. Mintegral SDK use the above information to better count, track and provide advertisements based on suitability, language, geography.

2. How And Why Mintegral SDK Collect and Uploading Installed Application Information

Depending on the nature of a User’s interaction, Mintegral SDK may collect and upload installed application information. The reasons and purposes for Mintegral SDK to collect installed application information are for displaying ads on Users’ device, including building profile about Users in order to serve interest-based ads based on installed application information Mintegral SDK collect; monitoring traffic and measuring the performance and effectiveness of ads including preventing any fraud; understanding and analyzing Users’ usage trends and preferences; improving Mintegral SDK service. Mintegral SDK may collect installed application version and characteristic of the app used by you when you interact with Mintegral SDK Service. When Mintegral SDK collect installed application information, the purpose is to provide better advertisement service.

3. How Mintegral SDK Use and Upload Installed Application Information

Mintegral SDK use installed application information to display ads on your applications. Ads may be shown to you based on the content you’re viewing, the app you’re using. Mintegral SDK may build profile about you and your interest and to show you personalized ads or behavioral ads which are relevant to you and customized to your inferred interests, preferences and other features based on profile about installed application information.

4. Disclosure of Installed Application Information

We disclose the installed application information to our users (i) to measure the performance and effectiveness of ads that you see or interact with, including measuring the traffic quality in order to perform Mintegral SDK contractual obligations to Mintegral business partners; (ii) to understand and analyze your usage trends and preferences, improve Mintegral SDK Service, and to develop new products; (iii) for purpose of monitoring and preventing fraudulent activity. Mintegral SDK is uploading and use installed application information to measure Users’ ad/site interaction and evaluate the performance and effectiveness of ads that User see or interact with, identify Users’ interest areas, better understand the app traffic usage or User behavior in order to improve Mintegral SDK services. The usage of the installed application information that we disclose will be governed by privacy policies.

5. Security of Installed Application Information

The security of uploading installed application information is our utmost priority, and Mintegral SDK take strict measures in order to protect data from unauthorized access, use, disclosure or destruction of data. Mintegral SDK have implemented physical, technical and administrative security measures for the Services that comply with applicable laws and industry standards.