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Privacy Policy

PRIVACY AND DATA POLICY

ISSUED BY 321 Brasil

Last Updated: 2026-3-31

This Privacy Policy explains how your personal data is collected and processed. We update this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, depending on the specific changes, we will provide you with additional notice or require a renewed consent. We encourage you to review the Privacy Policy whenever you access the App or Game to stay informed about how we process your personal data and how you can protect your privacy.

1.     HOW WE COLLECT YOUR PERSONAL DATA

We acquire, utilize, and process your personal data through various means. In every instance, we are committed to safeguarding your personal data.

In the sections outlined below, we detail how we collect your personal data and how we handle that data.

PERSONAL DATA

When you access or use our applications or games, we may collect general information about you, including:

·         Log Information: IP Address, access time, device type, your name, email address and cover photos (if you have connected to Facebook or other social sites or platforms), and your general (city/country) location (in some cases both precise and approximate location (based on your Internet Protocol (“IP”) address)

·         Device Information: device manufacturer, device type, hardware type, device operating system, device time zone, and device language.

·         Device Identification Number: the online identification number of the device you use to access the Application, including IDFA, Google Ads ID, Google Device ID, Game Center ID, and Google Play account ID.

·         Usage Information: game progress, scores, achievements, and your interactions with other players.

·         Commercial Information: Purchase and usage history and preferences, the receipt of virtual goods in-game.

Some apps or games may request additional permissions, including access to the Advertising ID, the ability to run foreground services, control vibration, access the Google Play billing service, have full network access, view network connections, use the Play Install Referrer API, view Wi-Fi connections, receive data from the internet, install shortcuts, and read or write the contents of your shared storage.

2. HOW WE USE INFORMATION

We use information about you for the following purposes based on the legal basis for each type of personal data as described below:

·         Fulfill product orders and other requests, respond to your questions, and communicate with you

·         Provide services, enhance and personalize your experience on the services

·         Send you news, technical messages, updates, privacy warning and technical support

Our processing of your data for the purposes mentioned above is necessary to fulfill the contract you are a part of, support the operation of the Application, provide the products and services you request, and allow for the maintenance and updates of the Application. This is in accordance with Article 6(1)(b) of the GDPR, also known as the "balancing of interests" rule.

We may send you news and marketing communications based on your preferences and choices, including information about Scopely or third-party offerings that we think may interest you.

We aim to enhance and personalize your experience on the Services, while also maintaining your preferences and settings.

Additionally, we may review the use and performance of the Services, develop new products or services, and conduct analyses to improve our software, content, marketing, support, and overall Services.

Our processing for the above purposes is justified by our legitimate interest in providing advertisements and content that you are interested in as well as improving our services according to Article 6(1)(f) of the GDPR.

·         Deliver personalized advertising and marketing and relevant promotional information to users who agree to share their Advertising IDs with our ad network partner

Information from other sources that are being processed”

·         Fulfill product orders and other requests, respond to your questions, and communicate with you;

·         Understand your preferences, interests and provide you better, personalized services;

·         Deliver information and news about services, applications that you might be interested in;

Our action for the above purposes is justified by our legitimate interest in providing advertisements and content that you are interested in as well as improving our services according to Article 6(1)(f) of the GDPR.

3. DATA RETENTION

We'll keep your information for as long as necessary to provide you with the Services, fulfill our legal obligations, and/or exercise, defend or establish our rights. We may still retain some of your personal information in our files for a reasonable period of time to resolve disputes, enforce our terms and policies, administer our Services, comply with technical and legal requirements, and/or other constraints related to the security, integrity, and operation of our Services

We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service or we are legally obligated to retain this data for longer time periods.

4. SHARING OF INFORMATION

Subject to your legal rights, based on Article 6(1)(b), 6(1)(c) and 6(1)(f) GDPR, we may disclose the information we collect about you, and may enable you to share this information, with a variety of third parties in various ways, including:

·         Social media platforms, see more in “Social sharing” Feature;

·         Other third parties (e.g., for collaborative offerings, legal and safety purposes, in connection with the sale or transfer of a business or asset, and other purposes with your permission);

·         The authorities if we believe your actions are inconsistent with the spirit or language of our policies or if the disclosure is necessary to protect the rights, property and safety of us or others;

·         Other users, such as when you participate in open communities or events, or information published on leaderboards.

When you agree with the information in Article 6(1)(1) GDPR, we will share your Device identifiers to advertising network companies. This will help to serve you personalized advertisements. We use or may user the following advertising network:

·         Applovin Corporation: https://www.applovin.com/privacy/

·         Facebook, Inc.: https://www.facebook.com/about/privacy/

·         Google LLC: https://policies.google.com/privacy

·         Google Admob: https://support.google.com/admob/

·         Unity Technologies: https://unity3d.com/legal/privacy-policy

·         Vungle, Inc.: https://vungle.com/privacy/

·         Pangle:  https://www.pangleglobal.com/privacy/partner

·         Mintegral: https://www.mintegral.com/privacy

The recipients' use of the disclosed information will not be covered by this Privacy Policy. If you have questions concerning the processing carried out by such third parties, you should review their privacy policy.

In connection with our processing, we use following data processors such as server hosting providers, technical service providers for supporting internal operations, user login services and analytics service providers:

·         Facebook Analytics (Facebook, Inc.) https://www.facebook.com/about/privacy/

·         Firebase (Google LLC) https://firebase.google.com/support/privacy

5. CHILDREN

These Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13 years of age. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do the necessary actions.

6. SECURITY

We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

7. PUSH NOTIFICATIONS

We send push notifications or alerts to your mobile device to provide game-related information, service updates, promotional communications and other related messages, if you have agreed to such notifications. You can deactivate these notifications by changing your notification settings on your device.

8. YOUR RIGHTS

Rights of EEU residents

We process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total as permitted by Article 12 of the GDPR.

Right to request access

You have the right to request access into the data that we are processing on you, see Article 15 of the GDPR, including information about:

·         The purposes of the processing;

·         The categories of personal data concerned;

·         The recipients or categories of recipient to whom the personal data have been or will be disclosed;

·         The envisaged period for which the personal data will be stored.

Furthermore, you have the right to obtain a copy of the personal data undergoing processing. Please note that the access may be restricted due to intellectual property or trade secrets.

The right to object

You have the right to object to our processing of your personal data on grounds relating to your particular situation when the data are processed based on the balancing-of- interest rule in Section 6(1)(f) of the GDPR, see Article 21 of the GDPR. In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims.

You have the right to object to our processing of your personal data for direct marketing purposes at any time. We will cease the processing of your personal data for this purpose after the objection.

Right to rectification

You have the right to have inaccurate personal data rectified, see Article 16 of the GDPR.

The right to restriction

You have the right to obtain restriction of processing in certain circumstances, see Article 18 of the GDPR. If you have the right to restriction, we will only process your data with your consent or for the establishment, exercise or defense of a legal claim or to protect a person or important grounds of public interest.

The right to withdraw consent

If we have asked for your consent to our processing of your data, you have the right to withdraw your consent at any time, see Article 7 of the GDPR.

If you withdraw your consent, we will cease processing of the data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data.

The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.

The right to data portability

You have the right to receive the personal data you have provided us with which we process in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller if the processing is based on consent or contract performance, see Article 20 of the GDPR.

Rights of California residents

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal data that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

Right to opt out

Under CCPA each California resident can request any business stop selling personal information to third parties.

Right to be informed

You have a right to be informed about what categories of personal data we are collecting, including the purpose of the collection. You can freely find this information in our Privacy Policy. We update our Privacy Policy at least once every 12 months.

Right to disclosure

You can request us to disclose what personal data we have collected on you in the past 12 months.

We can assure you that our Privacy Policy is a relevant document where you can find information about what personal data we have collected about you over the past 12 months and intend to collect, sources of your personal data and how we use your personal data.

You also have a right to get a free copy of your personal information disclosed in a readily usable and readable format (right of access). You can make this request for free, twice per year.

When providing information under the right of access, we will provide you with the following information:

·         The categories of personal data we are collecting about you,

·         The categories of sources of the personal data,

·         The purpose for collecting your personal data,

·         The categories of any third parties with whom we share your personal data,

·         The specific pieces of personal data collected about you.

Right to deletion

You can request us to delete the personal data we have collected on you in the past 12 months.

We fully recognize your right to deletion, however, we would like to note that in some cases we are obliged to keep your personal data for a certain period of time. For instance, if we need to provide services to you, detect or resolve security or functionality-related issues, comply with the law, conduct research in the public interest, safeguard the right to free speech or carry out any actions for internal purposes that you might reasonably expect. If we do not have obligations to perform any of the above actions, we can delete your personal information at your request.

9. DATA DELETION

You may request us to erase without undue delay your personal data when it is no longer necessary for us to retain such data.

In order for your data to be erased you can contact us by 321financas@gmail.com with request.

10. Contact & Complaints

If you have questions

regarding this Privacy Policy, please contact us and we will endeavor to

respond to your request within a reasonable period of time. You may also submit

questions or comments using the email address listed below.

321financas@gmail.com