Privacy Policy of Be a Pro - Football

1. INTRODUCTION

1.1 Studio Trois Private Limited and its affiliates and related

corporations (individually and collectively, "Studio Trois Private Limited", "we",

"us" or "our"). Studio Trois Private Limited takes its responsibilities

under applicable privacy laws and regulations ("Privacy Laws")

seriously and is committed to respecting the privacy rights and concerns of all

users of our Studio Trois Private Limited

website (the "Site") (we refer to the Site and the services we

provide as described in our Site collectively as the "Services"). We

recognize the importance of the personal data you have entrusted to us and

believe that it is our responsibility to properly manage, protect and process

your personal data. This Privacy Policy (“Privacy Policy” or “Policy”) is designed to assist you in

understanding how we collect, use, disclose and/or process the personal data

you have provided to us and/or possess about you, whether now or in the future,

as well as to assist you in making an informed decision before providing us

with any of your personal data. Please read this Privacy Policy carefully. If

you have any questions regarding this information or our privacy practices,

please see the section entitled "Questions, Concerns or Complaints?

Contact Us" at the end of this Privacy Policy.

1.2 "Personal Data"

or "personal data" means data, whether true or not, about an

individual who can be identified from that data, or from that data and other

information to which an organization has or is likely to have access. Common

examples of personal data could include name, identification number and contact

information.

1.3 By using the Services,

registering for an account with us or visiting our Site, you acknowledge and

agree that you accept the practices, requirements, and/or policies outlined in

this Privacy Policy, and you hereby consent to us collecting, using, disclosing

and/or processing your personal data as described herein.

1.4 IF YOU DO NOT CONSENT TO

THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY,

PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR GAMES OR SITE. If we change our

Privacy Policy, we will post those changes or the amended Privacy Policy on the

Site. We reserve the right to amend this Privacy Policy at any time.

2. WHEN WILL STUDIO Trois PRIVATE LIMITED COLLECT PERSONAL DATA?

2.1 We will/may collect

personal data about you:

• when you register and/or use

our Services, Games or Site, or open an account with us;

• when you submit any form,

including, but not limited to, application forms or other forms relating to any

of our products and services, whether online or by way of a physical form;

• when you enter into any

agreement or provide other documentation or information in respect of your

interactions with us, or when you use our products and services;

• when you interact with us,

such as via telephone calls (which may be recorded), letters, fax, face-to-face

meetings, social media platforms and emails;

• when you use our electronic

services, or interact with us via our Games or Site or use our Services. This

includes, without limitation, through cookies which we may deploy when you

interact with our Games or Site;

• when you carry out

transactions through our Games or Site;

• when you provide us with

feedback or complaints;

• when you register for a

contest, for games or game specific events;

• during your gameplay; and

• when you submit your personal

data to us for any reason.

The above does not purport to

be exhaustive and sets out some common instances of when personal data about

you may be collected.

3. WHAT PERSONAL DATA WILL

STUDIO Trois PRIVATE LIMITED COLLECT?

3.1 The personal data that

Studio Trois Private Limited may collect

includes but is not limited to:

• name;

• email address;

• date of birth;

• billing address;

• bank account and payment

information;

• telephone number;

• gender;

• information sent by or

associated with the device(s) used to access our Services;

• any other information about

the user when the user signs up to use our Services, and when the user uses the

Services, as well as information related to how the user uses our Services; and

• aggregate data on content the

user engages with.

3.2 You agree not to submit

any information to us which is inaccurate or misleading, and you agree to

inform us of any inacuracies or changes to such information. We reserve the

right at our sole discretion to require further documentation to verify the

information provided by you.

3.3 If you sign up to be a

user of our Services using your social media account (“Social

Media Account”), link your account to your Social Media

Account or use any Studio Trois Private

Limited social media features, we may access information about you which you

have voluntarily provided to your Social Media Account provider in accordance

with such provider's policies, and we will manage and use such personal data in

accordance with this Policy at all times.

3.4 If you do not want us to

collect the aforementioned information/personal data, you may opt out at any

time by notifying our Data Protection Officer in writing. Further information

on opting out can be found in the section below entitled "How can you

withdraw consent, remove, request access to or modify information you have

provided to us?". Note, however, that opting out or withdrawing your

consent for us to collect, use or process your personal data may affect your

use of the Services. For example, opting out of the collection of location

information will cause its location-based features to be disabled.

3.5 If you want us to

delete your personal data from our database, you can send an email to beaprofootball@gmail.com to provide your identity id and request that we delete your personal data from our database.

4. COLLECTION OF OTHER DATA

4.1 As with most websites and

mobile applications, your device sends information which may include data about

you that gets logged by a web server when you use our Services. This typically

includes without limitation your device’s Internet Protocol (IP) address,

computer/mobile device operating system and browser type, type of mobile

device, the characteristics of the mobile device, the unique device identifier

(UDID) or mobile equipment identifier (MEID) for your mobile device, the

address of a referring web site (if any), the pages you visit on our website

and mobile applications and the times of visit, and sometimes a

"cookie" (which can be disabled using your browser preferences) to

help the site remember your last visit. If you are logged in, this information

is associated with your personal account. The information is also included in

anonymous statistics to allow us to understand how visitors use our Games and

Site.

4.2 Our mobile applications

may collect precise information about the location of your mobile device using

technologies such as GPS, Wi-Fi, etc. We collect, use, disclose and/or process

this information for one or more purposes including, without limitation,

location-based services that you request or to deliver relevant content to you

based on your location or to allow you to share your location to other Users as

part of the services under our mobile applications. For most mobile devices,

you are able to withdraw your permission for us to acquire this information on

your location through your device settings. If you have questions about how to

disable your mobile device's location services, please contact your mobile

device service provider or the device manufacturer.

5. COOKIES

5.1 We may from time to time

implement "cookies" or other features to allow us or third parties to

collect or share information that will help us improve our Site, Games and the

Services we offer, or help us offer new services and features. “Cookies” are identifiers we transfer to your computer or mobile device that

allow us to recognize your computer or device and tell us how and when the Services

or website are used or visited, by how many people and to track activity within

our Site and Games. We may link cookie information to personal data. Cookies

also link to information regarding what items you have selected for purchase

pages you have viewed, or games you have played. This information is used to

keep track of your shopping cart, for example. Cookies are also used to deliver

content specific to your interest and to monitor usage of the Services.

5.2 You may refuse the use of

cookies by selecting the appropriate settings on your browser. However, please

note that if you do this you may not be able to use the full functionality of

our Site, Games or the Services.

6. HOW DO WE USE THE

INFORMATION YOU PROVIDE US?

6.1 We may collect, use,

disclose and/or process your personal data for one or more of the following

purposes:

(a) to consider and/or

process your application/transaction with us or your transactions or

communications with third parties via the Services;

(b) to manage, operate,

provide and/or administer your use of and/or access to our Services, Site and

Games (including, without limitation, your preferences), as well as your

relationship and user account with us;

(c) to respond to, process,

deal with or complete a transaction and/or to fulfil your requests for certain

products and services and notify you of service issues and unusual account

actions;

(d) to enforce our Terms of

Service or any applicable end user license agreements;

(e) to protect personal

safety and the rights, property or safety of others;

(f) for identification and/or

verification;

(g) to maintain and

administer any software updates and/or other updates and support that may be

required from time to time to ensure the smooth running of our Services;

(h) to deal with or

facilitate customer service, carry out your instructions, deal with or respond

to any enquiries given by (or purported to be given by) you or on your behalf;

(i) to contact you or

communicate with you via voice call, text message and/or fax message, email

and/or postal mail or otherwise for the purposes of administering and/or

managing your relationship with us or your use of our Services, such as but not

limited to communicating administrative information to you relating to our

Services. You acknowledge and agree that such communication by us could be by

way of the mailing of correspondence, documents or notices to you, which could

involve disclosure of certain personal data about you to bring about delivery

of the same as well as on the external cover of envelopes/mail packages;

(j) to inform you when

another user has sent you a private message or posted a comment for you on the

Games or Site;

(k) to conduct research,

analysis and development activities (including, but not limited to, data

analytics, surveys, product and service development and/or profiling), to

analyze how you use our Services, to improve our Services or products and/or to

enhance your customer experience;

(l) to allow for advertising

and other audits and surveys to, among other things, validate the size and

composition of our target audience, and understand their experience with Studio

Trois Private Limited’s Services;

(m) for marketing and, in

this regard, to send you by various modes of communication marketing and promotional

information and materials relating to products and/or services (including,

without limitation, products and/or services of third parties whom Studio Trois Private Limited may collaborate or tie up

with) that Studio Trois Private Limited

(and/or its affiliates or related corporations) may be selling, marketing or

promoting, whether such products or services exist now or are created in the

future. You can unsubscribe from receiving marketing information at any time by

using the unsubscribe function within the electronic marketing material. We may

use your contact information to send newsletters from us and from our related

companies;

(n) to respond to legal

processes or to comply with or as required by any applicable law, governmental

or regulatory requirements of any relevant jurisdiction, including, without

limitation, meeting the requirements to make disclosure under the requirements

of any law binding on Studio Trois Private

Limited or on its related corporations or affiliates;

(o) to produce statistics and

research for internal and statutory reporting and/or record-keeping

requirements;

(p) to carry out due

diligence or other screening activities (including, without limitation,

background checks) in accordance with legal or regulatory obligations or our

risk management procedures that may be required by law or that may have been

put in place by us;

(q) to audit our Services or

Studio Trois Private Limited’s business;

(r) to prevent or investigate

any fraud, unlawful activity, omission or misconduct, whether relating to your

use of our Services or any other matter arising from your relationship with us,

and whether or not there is any suspicion of the aforementioned;

(s) to store, host, back up

(whether for disaster recovery or otherwise) of your personal data, whether

within or outside of your jurisdiction;

(t) to deal with and/or

facilitate a business asset transaction or a potential business asset

transaction, where such transaction involves Studio Trois Private Limited as a participant or involves

only a related corporation or affiliate of Studio Trois Private Limited as a participant or involves

Studio Trois Private Limited and/or any one or

more of Studio Trois Private Limited's related

corporations or affiliates as participant(s), and there may be other third

party organizations who are participants in such transaction. A “business

asset transaction” refers to the purchase, sale, lease,

merger, amalgamation or any other acquisition, disposal or financing of an

organization or a portion of an organization or of any of the business or

assets of an organization; and/or

(u) any other purposes which

we notify you of at the time of obtaining your consent.

(collectively, the “Purposes”).

6.2 As the purposes for which

we will/may collect, use, disclose or process your personal data depend on the

circumstances at hand, such purpose may not appear above. However, we will

notify you of such other purpose at the time of obtaining your consent, unless

processing of the applicable data without your consent is permitted by the

Privacy Laws.

7. HOW DOES STUDIO Trois PRIVATE LIMITED PROTECT CUSTOMER INFORMATION?

7.1 We implement a variety of

security measures to ensure the security of your personal data on our systems.

User personal data is contained behind secured networks and is only accessible

by a limited number of employees who have special access rights to such

systems. We will retain personal data in accordance with the Privacy Laws

and/or other applicable laws. That is, we will destroy or anonymize your

personal data when we have reasonably determined that (i) the purpose for which

that personal data was collected is no longer being served by the retention of

such personal data; (ii) retention is no longer necessary for any legal or

business purposes; and (iii) no other legitimate interest warrant further

retention of such personal data. If you cease using our Services, or your

permission to use the Site, Games and/or the Services is terminated, we may

continue storing, using and/or disclosing your personal data in accordance with

this Privacy Policy and our obligations under the Privacy Laws. Subject to

applicable law, we may securely dispose of your personal data without prior

notice to you.

8. DOES STUDIO Trois PRIVATE LIMITED DISCLOSE THE INFORMATION IT

COLLECTS FROM ITS VISITORS TO OUTSIDE PARTIES?

8.1 In conducting our

business, we will/may need to disclose your personal data to our third party

service providers, agents and/or our affiliates or related corporations, and/or

other third parties, whether sited in Singapore or outside of Singapore, for

one or more of the above-stated Purposes. Such third party service providers,

agents and/or affiliates or related corporations and/or other third parties

would be processing your personal data either on our behalf or otherwise, for

one or more of the above-stated Purposes. Such third parties include, without

limitation:

• our subsidiaries, affiliates

and related corporations;

• contractors, agents, service

providers and other third parties we use to support our business. These include

but are not limited to those which provide administrative or other services to

us such as mailing houses, telecommunication companies, information technology

companies and data centres;

• a buyer or other successor in

the event of a merger, divestiture, restructuring, reorganization, dissolution

or other sale or transfer of some or all of Studio Trois Private Limited’s

assets, whether as a going concern or as part of bankruptcy, liquidation or

similar proceeding, in which personal data held by Studio Trois Private Limited about our users is among the

assets transferred; or to a counterparty in a business asset transaction that

Studio Trois Private Limited or any of its

affiliates or related corporations is involved in; and

• third parties to whom

disclosure by us is for one or more of the Purposes and such third parties

would in turn be collecting and processing your personal data for one or more

of the Purposes.

8.2 This may require, among

other things, disclosing your gaming history and/or disclosing records showing

which games were viewed by which IP addresses. We will also share statistical

and demographic information about our users and their use of the Services with

suppliers of advertisements and programming. This would not include anything

that could be used to identify you specifically or to discover individual

information about you.

8.3 Additionally, you may

elect to export your user activity feeds as RSS feeds which may be subscribed

to by other users, which may include information regarding your game play,

installation of games, connections with other users and other information about

your account activity which is published as a feed on the Site or Games.

8.4 For the avoidance of

doubt, in the event that Privacy Laws or other applicable laws permit an

organization such as us to collect, use or disclose your personal data without

your consent, such permission granted by the laws shall continue to apply.

8.5 Third parties may

unlawfully intercept or access personal data transmitted to or contained on the

site, technologies may malfunction or not work as anticipated, or someone might

access, abuse or misuse information through no fault of ours. We will

nevertheless deploy reasonable security arrangements to protect your personal

data as required by the Privacy Laws; however, there can inevitably be no

guarantee of absolute security such as but not limited to when unauthorized

disclosure arises from malicious and sophisticated hacking by malcontents

through no fault of ours.

9. INFORMATION ON CHILDREN

9.1 The Services are not

intended for children under the age of 10. We do not knowingly collect or

maintain any personal data or non-personally-identifiable information from

anyone under the age of 10 nor is any part of our Site, Games or other Services

directed to children under the age of 10. We will close any accounts used

exclusively by such children and will remove and/or delete any personal data we

believe was submitted by any child under the age of 10.

10. INFORMATION COLLECTED BY

THIRD PARTIES

10.1 Our Site and Games use

Google Analytics, a web analytics service provided by Google, Inc.

("Google"). Google Analytics uses cookies, which are text files

placed on your device, to help the website analyze how users use our Services.

The information generated by the cookie about your use of the Services or

device (including your IP address) will be transmitted to and stored by Google

on servers in the United States. Google will use this information for the

purpose of evaluating your use of our Services, compiling reports on website

activity for website operators and providing other services relating to website

activity and Internet usage. Google may also transfer this information to third

parties where required to do so by law, or where such third parties process the

information on Google's behalf. Google will not associate your IP address with

any other data held by Google.

10.2 We, and third parties,

may from time to time make software applications downloads available for your

use on or through the Services. These applications may separately access, and

allow a third party to view, your identifiable information, such as your name,

your User ID, your device’s IP Address or other information such as what

game you are playing during any given session, and any cookies that you may

previously have installed or that were installed for you by a third party

software application or website. Additionally, these applications may ask you

to provide additional information directly to third parties. Third party

products or services provided through these applications are not owned or

controlled by Studio Trois Private Limited.

You are encouraged to read the terms and other policies published by such third

parties on their websites or otherwise.

11. DISCLAIMER REGARDING

SECURITY AND THIRD PARTY SITES

11.1 WE DO NOT GUARANTEE THE

SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD

PARTY SITES. We do implement a variety of security measures to maintain the

safety of your personal data that is in our possession or under our control.

Your personal data is contained behind secured networks and is only accessible

by a limited number of persons who have special access rights to such systems,

and are required to keep the personal data confidential. When you place orders

or access your personal data, we offer the use of a secure server. All personal

data or sensitive information you supply is encrypted into our databases to be

only accessed as stated above.

11.2 In an attempt to provide

you with increased value, we may choose various third party websites to link

to, and frame within, the Site or Games. We may also participate in co-branding

and other relationships to offer e-commerce and other services and features to

our visitors. These linked sites have separate and independent privacy policies

as well as security arrangements. Even if the third party is affiliated with

us, we have no control over these linked sites, each of which has separate

privacy and data collection practices independent of us. Data collected by our

co-brand partners or third party web sites (even if offered on or through our

Site or Games) may not be received by us.

11.3 We therefore have no

responsibility or liability for the content, security arrangements (or lack

thereof) and activities of these linked sites. These linked sites are only for

your convenience and you therefore access them at your own risk. Nonetheless,

we seek to protect the integrity of our Site and Games and the links placed

upon each of them and therefore welcome any feedback about these linked sites

(including, without limitation, if a specific link does not work).

12. HOW CAN YOU WITHDRAW

CONSENT, REQUEST ACCESS TO OR CORRECT INFORMATION YOU HAVE PROVIDED TO US?

Withdrawing Consent

12.1 You may withdraw your

consent for the collection, use and/or disclosure of your personal data in our

possession or under our control by sending an email to our Personal Data

Protection Officer at studio 123456@gmail.com.

12.2 However, your withdrawal

of consent may mean that we will not be able to continue providing the Services

to you, and we may need to terminate your existing relationship and/or the

contract you have with us.

Requesting Access to, or

Correction of Personal Data

12.3 If you have an account

with us, you may personally access and/or correct your personal data currently

in our possession or control through the Account Settings page or tab on the

Site or Games. If you do not have an account with us, you may request to access

and/or correct your personal data currently in our possession or control by

submitting a written request to us. We will need enough information from you in

order to ascertain your identity as well as the nature of your request so as to

be able to deal with your request. Hence, please submit your written request by

sending an email to our Personal Data Protection Officer at studio 123456@gmail.com.

12.4 We may charge you a

reasonable fee for the handling and processing of your requests to access your

personal data. If we so choose to charge, we will provide you with a written

estimate of the fee we will be charging. Please note that we are not required

to respond to or deal with your access request unless you have agreed to pay

the fee.

12.5 We reserve the right to

refuse to correct your personal data in accordance with the provisions as set

out in Privacy Laws, where they require and/or entitle an organization to

refuse to correct personal data in stated circumstances.

13. QUESTIONS, CONCERNS OR

COMPLAINTS? CONTACT US

13.1 If you have any

questions, concerns or complaints about our privacy practices, please contact

us at beaprofootball@gmail.com.