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PRIVACY POLICY

Privacy Policy Facebook Instant Games

JoyBorn respects and protects your personal data.

JoyBorn collects, processes or uses personal data exclusively within the applicable legal framework. Therefore, the high data protection level of the General Data Protection Regulation (GDPR) holds true.

Field of application

We develop games ("Facebook Instant Games") that are available on the social network Facebook, a platform provided by the Facebook Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland ("Facebook"). In this privacy policy we inform you on the collection, processing and use of data concerning the Facebook Instant Games.
Insofar as individual services of JoyBorn have different privacy policies, these apply.
The Facebook Instant Games can only be accessed via the Facebook network, which is operated solely by Facebook, and only if you have registered for the Facebook network and are logged in to your Facebook account. The processing of data by Facebook when you register your Facebook account and every time you access the Facebook network is excluded from the field of application of this privacy policy. Likewise, cookies that Facebook may use for statistical evaluations when you access the Facebook platform are not within this privacy policy's scope. Facebook organizes the aforementioned data processing independently and on its own responsibility, without us having any influence on this. For further information on this data processing by Facebook see the Facebook's privacy policy: https://www.facebook.com/privacy/explanation.

Data processed when accessing and using the Facebook Instant Game

When you first access one of our Facebook Instant Games, Facebook will assign you one unique ID per Facebook Instant Game (the "Facebook Instant Game ID"), which is linked to your personal information, and will disclose this ID to us. Facebook also provides us with the first name you have entered in your Facebook account, your profile picture, the language selected, and the country you are playing from. Further, Facebook checks which other Facebook users, with whom you are connected on Facebook (so-called Facebook friends), have already played the respective Facebook Instant Game and notifies us of the results. JoyBorn receives and uses the Facebook Instant Game ID and the other aforementioned data solely to create your player profile in the Facebook Instant Game to the extent necessary for using the game. Hence, the data processing in this context is carried out for the purpose of performing the contract with you on the use of the Facebook Instant Game pursuant to Art. 6 (1) (b) GDPR.

We would like to point out that JoyBorn does not receive any additional personal data from your Facebook user account. JoyBorn will not use the data to identify you or to create user profiles for purposes other than providing the Facebook Instant Games.

If you want to have the aforementioned data on you including the player profile deleted, you can, for example, send an email to wg@joyborn.com. In order to be able to identify the data concerning you for deletion, we need your Facebook Instant Game ID. Please note that it is not possible to use the Facebook Instant Games without such a player profile. If you use our Facebook Instant Games again after deletion of your player profile, a new player profile will be set up for you.

In order for you to access and play the respective Facebook Instant Game including all game functions, JoyBorn collects and processes data on the use of the Facebook Instant Game (data on game progress such as completed levels, owned skins and player aids used, high scores achieved, ongoing and paused game sessions). This data is linked to the Facebook Instant Game ID and added to your player profile by JoyBorn. The processing of this data for the use of the Facebook Instant Game is carried out for performance the contract with you on the use of the Facebook Instant Game pursuant to Art. 6 (1) (b) GDPR.
JoyBorn does not receive any further personal data of your Facebook account and is not able to identify you via the Facebook Instant Game ID. JoyBorn will not use this data to create user profiles for any other purpose than to provide the Facebook Instant Games.
Each time you access a Facebook Instant Game, Facebook automatically logs your gender, age and the country you are located in while playing. Facebook collects this information as part of an analytics function to provide JoyBorn with reports and analyses on the general use of the games, based on which JoyBorn can gain insights for possible improvements and further developments of the Facebook Instant Games. As JoyBorn only offers the Facebook Instant Games in the network operated by Facebook and therefore has no general access to the Facebook network, JoyBorn generally does not obtain any information on Facebook user accounts or other data that would allow conclusions to be drawn about the identity of individual players. The only exceptions to this are the data mentioned in Sect. 2.1, which JoyBorn only obtains and uses to create player profiles. Also, JoyBorn will not merge the data from the analytics function with other data about individual players, in particular not with the data mentioned in Sect. 2.1.
At the beginning and during a game, Facebook will also collect information about your game session, such as the respective Facebook Instant Game, the language used, the beginning and end of a game session, how you accessed and started the game, what elements and levels of the game you use, whether you successfully completed a level, and, if applicable, the number of other players. JoyBorn analyses this data and uses the insights from these evaluations to further develop and optimise the design of the Facebook Instant Games. However, JoyBorn only processes the Facebook Instant Game ID in connection with these evaluations of the game sessions and does not process any data from the player profiles which could provide information about the identity of individual players. It is therefore not possible for us to attribute the analysed data about the game sessions to individual persons. We also do not create profiles of individual players from these evaluations of game sessions, nor do we link these evaluations with data from the analytics function.
The data processing in connection with the above analyses of general game use and game sessions is based on our legitimate interest pursuant to Art. 6 (1) (f) GDPR, which consists in the continuous improvement of our games to ensure the best possible, entertaining gaming experience. For such adjustments based on user experience, we need to know the actual use of the games.
Furthermore, Facebook uses the aforementioned, recorded information independently and on its own responsibility for its own, individual purposes and also collects and processes additional data including information from your Facebook account for these purposes, without us being involved or having any influence on this. Details of this use of your personal data are explained in the Facebook privacy policy, which you can view under https://www.facebook.com/privacy/explanation.
We would like to point out that data processing by Facebook can also take place outside the EU or the European Economic Area, in particular on Facebook servers located in the United States. This can result in risks for the users, because, for example, the enforcement of the users' rights could become more difficult. In this particular case, Facebook and we guarantee that appropriate protection measures are in place in accordance with Article 44 et seq. GDPR. In particular, Facebook and we have agreed on the standard data protection clauses of the EU Commission as a precautionary measure which provide for appropriate protection measures for the specific case, such as encryption of the data, in accordance with Article 46 (2) lit. c) GDPR. The measures are also continuously developed and supplemented to the extent necessary to ensure an adequate level of data protection throughout.

Data security

JoyBorn has taken appropriate technical and organisational measures to protect personal data against accidental loss, damage, unauthorised access or unauthorised changes. In particular, JoyBorn will transmit data only in encrypted form. However, JoyBorn points out that privacy and data security cannot be guaranteed for transmissions outside JoyBorn's sphere of influence.
The classification of Platform Data is PRIVATE DATA, we will follow the Data Handling Guidelines to process/access that data.
- Storage of platform data on organizational and removable devices is only allowed when there is a clear and actionable business purpose.
- Platform data held on organizational devices and removable devices is deleted once the business purpose for storing them no longer exists.

About Meta access tokens
- Must not be written such that another user or process could read it.
- Process or store Meta access tokens on server side:
  - Must be protected using a data vault with separate key management service (KMS) and where access to the decryption key is limited to the application.
  - Must not be written to log files.
About Meta App Secret
- JoyBorn never expose the app secret outside of a secured server environment (e.g., it is never returned by a network call to a browser or mobile app and the secret is not embedded into code that’s distributed to mobile or native/desktop clients).
About Vulnerabilities and Security Issues
- JoyBorn test the app and systems for vulnerabilities and security issues at least every 12 months.
- JoyBorn will resolve all critical and high severity vulnerabilities related to server before released to production.
- JoyBorn will test the cloud configuration for security issue related to server host before released to production.

Facebook Audience Network

Our Facebook Instant Games implement the so-called Facebook Audience Network, a service of Facebook for serving advertisements. This service is used by Facebook to display advertisements in our Facebook Instant Games. When an advertisement is to be displayed in a Facebook Instant Game or clicked on, Facebook will record notably your interaction with the advertisement, your IP address and, if applicable, your further usage behaviour after the click on the advertisement. Facebook processes this information in order to measure the success of the respective advertising and to provide us with excerpts of the results. However, Facebook only provides JoyBorn with access to aggregated data on the results of the advertising feed, which JoyBorn cannot trace back to individual persons. Besides, JoyBorn only receives excerpts of data in the context of the advertisements that cannot be attributed to individual persons. In particular, JoyBorn in does not receive and process any IP addresses or cookies from user devices or other data that allow conclusions to be drawn about the identity of individual users.
Facebook autonomously decides on the specific advertisements that are displayed in each case and on the processing of your personal data in the context of selecting and playing these advertisements. JoyBorn can only exclude certain categories, in particular sensitive categories (such as depictions of violence, politics, religion) by choosing between default settings. Facebook uses this information to display the advertisements: which specific Facebook Instant Game you are playing, information about your usage behaviour in the Facebook social network and your interaction with other content in the Facebook network, as well as information that you have entered in your Facebook account. Facebook also uses cookies for this purpose. Further information on the data processing by Facebook regarding the Facebook Audience Network can be found at https://www.facebook.com/ads/about/?entry_product=ad_preferences and is explained in the Facebook privacy policy: https://www.facebook.com/privacy/explanation.
You will only receive personalised advertising via Facebook Audience Network if you have consented to this in your Facebook settings. The legal basis is therefore Art. 6 (1) (a) GDPR. Of course, you can withdraw your consent at any time for the future by changing your Facebook settings under the following link: https://www.facebook.com/ads/preferences. Please note that we can only provide the Facebook Instant Games free-of-charge with advertise funding. This means that even if you do not consent to receive personalised advertising, you will still see ads in Facebook Instant Games, but they will not be personalised, i.e., they will not be tailored to your personal interests. We have a legitimate interest in displaying advertisements in our Facebook Instant Games in order to generate revenue and thereby offer our games to you for free. There is also no indication apparent that your interest in not receiving advertising through Facebook Audience Network is prevailing when you voluntarily play our Facebook Instant Games for free. The associated data processing is therefore justified in accordance with Art. 6 (1) (f) GDPR.
The data processed within the Facebook Audience Network can be transferred to Facebook servers, which are also located in the United States. We have concluded the standard data protection clauses adopted by the EU Commission with Facebook for transferring data by the Facebook Audience Network, having included the implementation of appropriate protective measures. Facebook and we also regularly review the need for possible additions and, if necessary, the implementation of additional appropriate protection measures within the meaning of Article 44 et seq. GDPR, to the extent as this is necessary to continuously grant a suitable level of data protection.

Usage analysis via Firebase

The Instant Game implements functions of the Firebase service, which is provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google").
Data on the general use of the Instant Game are collected and evaluated via the Firebase service (so-called Google Analytics for Firebase). For these purposes, information on whether and how you use certain parts of the Facebook Instant Games is collected together with the IP address, a hash of your Facebook Instant Game ID and other technical data on your device and the configurations assigned to it (hereinafter "Device-Related Data"), such as the manufacturer and model of the device, the language setting and the advertising ID as well as the country from which you use the Instant Game. At no time will personal data from your player profile, such as your username and Facebook Instant Game ID, be transmitted to Google in clear text.
Google evaluates such data on our behalf and compiles aggregated reports for us. We use these reports to gain insight into the general use of the Instant Game, in order to use this information to improve the content and functions of the Instant Game and, in particular, to eliminate existing errors and problems. In addition to this we also get access to the in-game activity of individual users through Google, based on an anonymized user-id. Nevertheless, it is not relevant for JoyBorn which User used the respective Instant Game and to what extent. It is therefore not a matter of creating user profiles for JoyBorn but rather of providing functional Instant Games through the analysis of aggregated reports from Google. Google may also transfer these data to servers operated by Google LLC in the USA and analyse them there. However, in member states of the European Union or in other states that are party to the Agreement on the European Economic Area your IP address will be shortened and thus made anonymous before it is transmitted to a Google server in the USA.
Google also processes the aforementioned data collected via the Firebase service to the extent covered by its own privacy policy which you can find at https://policies.google.com/privacy. There you will also find additional information on Google's handling of personal data.
We would like to point out that the transmission of data to servers in the USA used by Google LLC may involve additional risks, for instance the enforcement of your rights to these data may be more difficult. In order to counter these risks, we have concluded the standard data protection clauses by the EU Commission with Google LLC for this data transfer and also stipulated appropriate protective measures therein, which, depending on the need for protection of the data, also include data encryption and can be improved in accordance with the legal and technical conditions for appropriate protection of the data. If data is transferred to Google LLC in the USA, such transfer is based on Article 46 (2) lit. c) GDPR.
We only use Firebase for the data analysing purposes described above, if you consent to it via your Facebook settings. In these cases, the legal basis for the processing of your data is Article 6 (1) sentence 1 lit. a) GDPR. You may revoke an already granted consent for data processing at any time with effect for the future. We have further concluded a data processing agreement with Google in accordance with Article 28 GDPR on data processing in the context of error analysis. Accordingly, Google will only process the data collected in this context in accordance with our instructions for this purpose. This forwarding of data to Google is therefore based on Article 28 GDPR.

Storage period and erasure of data

We process your personal data as long as it is necessary to achieve the purposes of the processing, or is prescribed by a legal obligation to store the data. Subsequently, the data is deleted in accordance with statutory laws.
Data that we store for legal reasons, however, is stored for as long as this is required by law. After expiry of a statutory retention period, the data will be deleted without undue delay, unless there are other reasons within the meaning of Art. 17 (3) GDPR opposing the deletion.

Data security

JoyBorn has taken appropriate technical and organisational measures to protect personal data against accidental loss, damage, unauthorised access or unauthorised changes. In particular, JoyBorn will transmit data only in encrypted form. However, JoyBorn points out that privacy and data security cannot be guaranteed for transmissions outside JoyBorn's sphere of influence.

Transmission to Third Parties

Personal data will only be passed on to third parties - unless otherwise set out elsewhere in this privacy policy - without the express consent of the user, if this is necessary for the provision of JoyBorn's services or for contract execution with the user (e.g. for the technical provision of the offer, see Sect. 7.2). Accordingly, the data are transmitted to such service providers (such as technical service providers) in our legitimate interests pursuant to Art. 6 (1) (f) GDPR, namely to provide access to our Facebook Instant Games. Of course, before passing on the user's personal data, JoyBorn ensures that the relevant service provider has taken appropriate technical and organizational measures to ensure the security of the data.
We store the data collected by us in the context of access and use of the Facebook Instant Games (i.e. data of the player profile including Facebook Instant Game ID, first name, profile picture, language, country, friends who also play the game, and data on the use of the game such as game progress and completed levels, used skins and player aids and achieved high scores) via third party services. We use the Alibaba Cloud service, provided by Alibaba Web Services ("Aliyun"), and the Google Cloud and Google Firebase services, both provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland ("Google"). These services also record the IP address of your device when you use the Facebook Instant Games and store it for a maximum of 30 days. However, JoyBorn does not receive the IP addresses directly and only exceptionally obtains insight into IP addresses recorded by these services and only if a valid legal basis exists, in particular if this is necessary to protect the legitimate interests of JoyBorn. Aliyun and Google also transfer the collected data to their servers in the United States. We use these services to provide the aforementioned data for playing the Facebook Instant Games efficiently and with the lowest possible susceptibility to errors, thus ensuring the smooth use of the game functions. The legal basis for the associated data processing is Art. 6 (1) (f) GDPR, whereby our legitimate interest is an optimal, technically flawless provision of the Facebook Instant Games. We have concluded the standard data protection clauses adopted by the EU Commission with Google and Aliyun to safeguard the transfer of data to the USA. We have also concluded a data processing agreement with Google and Aliyun. The forwarding of personal data to Google and Aliyun in connection with the aforementioned services is therefore based on Article 46 (2) lit. c) and 28 GDPR.
Otherwise, JoyBorn will not pass on the user's personal data to third parties unless the user has expressly consented to the transfer (Art. 6 (1) (a) GDPR), or JoyBorn is entitled or obliged to do so by legal provisions or court orders. In the latter case, the transmission is carried out by JoyBorn to fulfil a legal obligation pursuant to Art. 6 (1) (c) GDPR.

Access Lifecycle Management Standard

1. Purpose

1.1 This standard provides detailed guidance and requirements for securely managing the access account lifecycle for personnel accessing Information Systems.

2.Scope and Applicability

2.1. Scope
- 2.1.1 All Information Systems are in scope for this standard.
2.2. Applicability
- 2.2.1 All personnel are required to comply with this policy

3.Roles & Responsibilities

4.Access Provisioning, Authentication and Authorization

4.1 JoyBorn must confirm the identity of any personnel before submitting requests for account creation and enrolling the personnel in a secure system.
4.2 Only authorized personnel may perform account enrollment and access provisioning
4.3 JoyBorn must consider at least one of the following factors before providing access to Information Systems.
- 4.3.1 Business Need/Job Responsibilities: Access shall be granted based on valid business justification or requirements for the particular role/job.
- 4.3.2 Personnel Type: Access shall be provisioned considering the type of personnel (e.g., full time employee or collaborator).
- 4.3.3 Data Sensitivity: Access shall be provisioned considering the classification of Data the qiven Information System will process or store. Access to sensitive data shall be provisioned using approved access methods(e.g., security groups access models). For information on data classification, refer to the Data Classification Standard.
4.4 In order to access the production system and related tools, personnel must have a Google Cloud Identity account provisioned.
4.5 Only authorized personnel may beprovided access to Information Systems in the production network At a minimum the following logical access measures must be in place:
- 4.5.1 personnel must have an active user account.
- 4.5.2 personnel must have avalid business justification in order to request access to the production network.
- 4.5.3 personnel must use multi-factor authentication.
- 4.5.4 personnel must authenticate to the VPN with authorized credentials before gaining access to the Production Network.
4.6 Requests for Elevated Access must be approved by the requestor's manaqer and/or the Asset Owner the dedicated Securityteam managing access to the system, or other authorized personnel.

5.Access Review

5.1 JoyBorn must perform access reviews (manual or automated) as per applicable requlatory requirements to validate the appropriateness of active access based on personnel's job duties and employment status.
- 5.1.1 Personnel who have access to repositories/vaults that store root credentials for production servers and secure cages must be reviewed annually.
- 5.1.2 Personnel with Elevated Access must be reviewed annually.

6.Access Modification

6.1 The level of access granted to particular JoyBorn personnel may be modified for a valid reason which may include:
- 6.1.1 Change of roles or teams or current job requirements.
- 6.1.2 Failure to access an Information System for a predefined period of time(e.g90+days);
- 6.1.3 Valid business justifications

7. Access Revocation

7.1 For full time employees, JoyBorn must revoke access to Information Systems upon termination of employment.
7.2 For other personnel with Gooale Cloud Identity account, JoyBorn must revoke access to Information Systems at the end of employment or contract with JoyBorn.

9.Enforcement

9.1 personnel are required to familiarize themselves with this standard. Violations of this standard may result in disciplinary action up to and including denial of access, termination, and leqal penalties in accordance with the Code of Conduct the Termination, Discipline, and Rules of Conduct and applicable national, federal, state and local laws or reaulations.

10.Standard Exceptions

10.1 To request an exception to this standard, complete the Exception Request Form, explaining the business need for the exception. Based on the submission, the request will be routed to the appropriate JoyBorn team, which will review the request against relevant security legal,or other considerations and determine whether to approve or deny the request.
10.2 In order for an Affiliate to obtain an exception to this standard. the Affiliate must reauest approval for the exception through appropriate channels, identifying the specific elements of the standard from which an exception is sought and any compensating controls that the Affiliate has or plans to have in place. Any approved exception must be documented.

User rights

1. Right to object

The user has the right to object at any time to data processing based on Art. 6 (1) (e) or (f) GDPR for reasons arising from his particular situation, unless JoyBorn can prove compelling reasons worthy of protection, which outweigh the interests of the user, or the processing serves to assert, exercise or defend legal claims. The user can object to data processing for the purpose of direct advertising at any time without special reasons being required.

2. Right to information

The user has the right to obtain free of charge from JoyBorn the personal data stored by JoyBorn concerning him or her, the processing purposes, their origin, which transfer to which recipients or categories of recipients took place, the storage period and the rights of the data subjects available to him or her.

3. Right to correction, deletion and/or restriction of data processing

Furthermore, the user has the right to request at any time the correction of incorrect data, the deletion and/or restriction of the processing of personal data stored about him or her, insofar as there is no legal obligation for JoyBorn to keep records or other reasons in the sense of Art. 17 (3) GDPR which prevent deletion. Insofar as this includes personal data that is necessary for the provision of services to the user, the deletion or restriction of the processing of this data can only take place when the user no longer uses JoyBorn's services.

4. Right to data portability

If the user provides data relating to him or her and JoyBorn processes such data on the basis of the user's consent or in order to fulfil the contract, the user may request that he/she receives such data in a structured, current and machine-readable format from JoyBorn or that JoyBorn transmits such data to another controller, insofar as this is technically possible (so-called right to data portability).

5. Right to revoke consent

Any consent given by the user to the use of personal data can be freely revoked by the user at any time with effect for the future.

6. Right to complain to a supervisory authority

The user may also lodge a complaint with a supervisory authority against data processing which he or she considers to be in breach of the statutory provisions.

Changes to the Privacy Policy

JoyBorn reserves the right to change this privacy policy at any time, while JoyBorn will always comply with the legal requirements of data protection. Therefore, JoyBorn recommends that users regularly take note of the applicable privacy policy. JoyBorn will inform users in advance of any further use of data, for example via in-game notification or so-called push notifications in your browser, if you allow such push notifications.

Contact us

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

In relation to the Facebook Instant Game:

Data Protection Officer, responsible for the management and safety of your personal information
wg@joyborn.com

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