XQGAMES PRIVACY POLICY

1. About this Privacy Policy

Our Privacy Policy applies to any user of our games and related services, applications and software.

We care about your privacy and we think it is important that you always know what information we obtain about you in the context of your use of the Smilegate Megaport games and what that information is used for. In the Privacy Policy below, we therefore aim to keep you fully informed as to the type, extent and purpose of the collection, storage, use and processing of personal data on our websites, PC games, Mobile platforms and products and/or services relating to the Smilegate Megaport games and related services and game support applications and software (the "Games") and any XQGAMES website on which this Privacy Policy is posted (the "Websites").

Personal data is all information relating to an identified or an identifiable natural person. A person is identified when the identity of a specific person can be deduced from the information itself. A person is identifiable when we can make a connection to a specific person using additional information available to us.

This Privacy Policy applies to the Games and Websites only. You can also see this Privacy Policy at the websites.

We recommend that you read the privacy policy of every other service provider you make use of, in particular before you make your personal data available to them.

Please read this Privacy Policy carefully to understand our practices regarding your personal data and how we will treat it.

IF YOU DO NOT AGREE WITH OUR POLICIES AND PRACTICES, DO NOT DOWNLOAD, REGISTER WITH, OR USE OUR GAMES OR VISIT OUR WEBSITES.

By downloading our games, visiting our Websites and using our products and services (including the Games), you acknowledge the terms of this Privacy Policy and the use and disclosure of your personal data as set out in this policy.

2. Who we are

We are a provider of games and related services and applications.

We are XQGAMES, located at 3F, 427-1, Nonhyeon-ro, Gangnam-gu, Seoul, Republic of Korea (hereinafter: "XQ" "XQGAMES" "we" or "us").

We are the provider of the Games and the Websites and the organization responsible for the personal data you provide as part of using the Games and the Websites within the meaning of applicable data protection and privacy laws.

3. How to contact us

You can contact our dedicated privacy contacts with any queries or complaints regarding your data.

If you have any questions about this Privacy Policy or our use of your personal data, if you need to report a problem, or if you would like to exercise one of your rights under this Privacy Policy you can contact us using the following contact details:

Title: Data Protection Officer

Email: privacy@xqgames.com

For the purposes of applicable EU data protection legislation, we also have a representative located within the European Union. The contact details of our EU representative are set out below:

Name: v. KEUSSLER Consulting GbR

Address: v. Keussler Consulting GbR, partnership, Schepp Allee 47, 64295 Darmstadt, Germany

Email: privacy_EU@xqgames.com

4. How we get information

We collect certain information about you via your STOVE membership or when you use a guest account.

We may collect the following types of information relating to you indirectly through XQGAMES

When you log into the Games using your STOVE account, a Guest account or third party social media platforms such as Facebook, Google or Twitter, Apple, Google Play Games, Apple Game Center

Membership number

Nickname or Name

connection record (connection IP, country/language/time zone/offset of subscription, login dates)

service use record

device information (device ID, country of settings, language of settings, model name, OS, OS version, whether routed, ADID); and

age

When you pay for the use of the Games we receive your payment records (payment amount, name of product, payment date, order number).

During your participation and progression in our Events, we may also collect certain personal data about you, such as name, email address, cellphone number, address for the prize delivery etc.

When you pre-register for the game, we may collect your country information mobile number or email address. If you 'check My PC Specs', we will collect your PC Specs information. Your PC spec information, that is collected, will not be used for any other purpose than game running, game installation and game-related trouble-shooting.

We log your visits and use of our Games using cookie technology

We also collect the following information automatically when you play the Games or visit the Websites:

Connection record (Connection IP, IP address, country/language/time zone/offset of subscription, login dates, detection and blocking history)

service use record; and

device information (device ID, Android ID, country of settings, language of settings, model name, OS, OS version, whether routed, ADID, UUID).

To do this we may use cookies or mobile cookies (pieces of data sent by a website to your computer and stored on its hard drive or a small file placed on your smartphone). We also use analytics, indicator and tracking analysis tools in our games that utilize cookies and similar mechanisms. See below for more information about how we use cookies.

Where processing is necessary for us to carry out our legal obligations

we have legal obligations that we need to comply with, and we are allowed to collect your personal data when we need to comply with those legal obligations.

IF YOU DO NOT WANT US TO COLLECT ANY OF THE INFORMATION DESCRIBED IN THIS link, DO NOT USE OUR WEBSITES, DOWNLOAD OUR GAMES OR DELETE THEM FROM YOUR DEVICE.

5. Linking to third party websites

Other websites and applications may use your data differently and have their own privacy policies. You should always read those policies.

Within the Games, you may be provided with the option to link through to other websites or gaming communities. These other domains, apps and websites are subject to their own privacy practices and we encourage you to read the privacy policies of each and every website and application with which you interact. You visit these other websites or applications at your own risk.

You should be aware that personal data that you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your data and by using such services, you assume the risk that the personal data you provide may be viewed and used by third parties for any number of purposes.

6. Why we collect, process and use your information

We use your data to provide you with our Games.

We collect, process and use your personal data for the following purposes:

To provide services and comply with the service contract

for the purposes of providing and organising game services and game events

for the purposes of analysing and tracking game data

settling fees, provide contents, purchase and fee payments, delivery of goods (prizes from events, etc.)

To manage our members

for customers services purposes

to distinguish between the members using the member service, to prevent unlawful and unauthorized use by rogue members, to check if they want to join, to deal with civil complaints including resolving dissatisfaction and customer advice, to preserve records for any disputes mediation and to give notifications

We use your data to help deal with complaints.

To manage our guests

to deal with civil complaints including resolving dissatisfaction arising from service use and customer advice

We use your data to provide you with details of our new products and services.

For marketing and promotion purposes

for specialization or development of new services (products), to deliver promotional information such as events and to provide services based on demographic information, statistics related to access frequency and the members' use of the service

7. How long we keep your information for

We don't keep your data forever.

We will not keep your personal data for longer than the term that is necessary for the purposes for which we collect it unless we believe that the law or

other regulation requires us to preserve it (for example, because of a request by a tax authority or in connection with any anticipated litigation)

When it is no longer necessary the retain your data, we will delete the personal data that we hold about you from our systems.

After a request to unsubscribe, we may immediately delete or store your personal data for a maximum of 30 days depending on the individual operational policy of the Game you play, after a request to unsubscribe for the purposes resolving unwanted customer complaints or disputes, etc., such as unwanted deregistration, etc. caused by personal data piracy, etc.

If you agree to receive marketing emails, you may withdraw your consent to receive marketing email messages from us by following the unsubscribe instructions provided in our emails. Your email address will be stored until you withdraw your consent.

8. Your rights

You have a number of rights regarding your data. These may vary depending on your location.

You have various rights in relation to the data which we hold about you. To get in touch with us about any of your rights under applicable data protection laws, please use the contact details set out above. We will seek to deal with your request without undue delay, and in any event within any time limits provided for in applicable data protection law (subject to any extensions to which we are lawfully entitled). Please note that we may keep a record of your communications to help us resolve any issues which you raise.

In addition, for users located in the EU only, the European General Data Protection Regulation (the "GDPR") gives you the following rights in relation to your personal data:

Right to object

This right enables you to object to us processing your personal data where we do so for one of the following reasons:

because it is in our legitimate interests to do so (for further information please see the link on our legal bases for processing below);

to enable us to perform a task in the public int

erest or exercise official authority;

to send you direct marketing materials; or

for scientific, historical, research, or statistical purposes.

Right to withdraw consent

Where we have obtained your consent to process your personal data for certain activities (for example, for marketing), you may withdraw this consent at any time and we will cease to use your data for that purpose unless we consider that there is an alternative legal basis to justify our continued processing of your data for this purpose, in which case we will inform you of this condition.

Data Subject Access Requests

You may ask us for a copy of the information we hold about you at any time, and request us to modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this unless permitted by law. If you request further copies of this information from us, we may charge you a reasonable administrative cost. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.

Right to erasure

You have the right to request that we "erase" your personal data in certain circumstances. Normally, this right exists where:

The data are no longer necessary;

You have withdrawn your consent to us using your data, and there is no other valid reason for us to continue;

The data has been processed unlawfully;

It is necessary for the data to be erased in order for us to comply with our obligations under law; or

You object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.

We would only be entitled to refuse to comply with your request for erasure in limited circumstances and we will always tell you our reason for doing so. When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.

Right to restrict processing

You have the right to request that we restrict our processing of your personal data in certain circumstances, for example if you dispute the accuracy of the personal data that we hold about you or you object to our processing of your personal data for our legitimate interests. If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.

Right to rectification

You have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. You may also request details of the third parties that we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.

Right of data portability

If you wish, you have the right to transfer your personal data between service providers. In effect, this means that you are able to transfer the details we hold on you to another third party. To allow you to do so, we will provide you with your data in a commonly used machine-readable format so that you can transfer the data. Alternatively, we may directly transfer the data for you.

Right to complain

You also have the right to complain to your applicable data protection authority. Contact details for data protection authorities in the EU are available at: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080

9. Sharing your information

We may need to share your data with limited third parties (e.g. to help us provide the Games).

In general, your data is processed exclusively by us and we do not pass on any personal user data to third parties unless we need to do so in order to offer you certain Games services. Where we do share your personal data, we do so with the following categories of recipients:

Service Providers

In order to provide the Games services we work with service providers (e.g. payment service providers, platform providers, Solution providers, Customer Support service providers and survey providers) who may, in the course of providing the respective services, receive and process personal data on our instruction and on the basis of a commissioned data processing agreement. In addition, we use certain software tools, including in relation to anti-cheat and fraud prevention analytics, which may allow the software provider to collect certain information for the purposes of providing the relevant services.

In particular, we share your personal data with SurveyMonkey who provide us with the ability to survey our players. For further information regarding SurveyMonkey and their processing of personal data, please see their privacy policy, available at: https://www.surveymonkey.com/mp/legal/privacy-policy/

Regulatory bodies

We may disclose your personal data:

to data protection regulatory authorities;

in response to an enquiry from a government agency; and

to other regulatory authorities with jurisdiction over our activities.

Professional advisors and Auditors

We may disclose your personal data to professional advisors (such as legal advisors and accountants) or auditors for the purpose of providing professional services to us.

Replacement providers

In the event that we sell or buy any business assets, we may disclose your personal data to the prospective seller or buyer of such business or assets. If XQGAMES or substantially all of its assets are acquired by a third party, personal data held by us about our clients will be one of the transferred assets.

Indicator and tracking analysis tools

We share your personal data with certain entities which provide us with indicator and tracking analysis tools in the Games. Other companies that place advertising on our Games or websites may collect information about you when you view or click on advertisements In particular, we share your personal data with:

Google: We use Google Analytics and AdMob. For details of how Google uses your data, please visit https://policies.google.com/technologies/partner-sites?hl=en&gl=en; and

Singular: We use Singular's analytics platform. For details of how Singular uses your data, please visit https://www.singular.net/privacy-policy.

Adjust: We use Adjust's analytics platform. For details of how Adjust uses your data, please visit https://www.adjust.com/terms/privacy-policy.

Unity: We use Unity Ads. For details of how Unity uses your data, please visit https://unity3d.com/legal/privacy-policy.

Vungle: We use Vungle Ad Services. For details of how Vungle uses your data, please visit https://vungle.com/privacy .

Pangle: We use Pangle advertising platform. For details of how Pangle uses your data, please visit https://www.pangleglobal.com/privacy/enduser-en .

AppLovin: We use AppLovin Advertising Services. For details of how AppLovin uses your data, please visit https://www.applovin.com/privacy .

ironSource: We use ironSource platform. For details of how ironSource uses your data, please visit https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy .

Please see the "Cookies" link, below for further information on the cookies which are used as part of the indicator and tracking analysis tools in the Games.

At your option

In certain circumstances, you have the option of sharing information with others yourself as part of the Games (e.g. if you give out personal data in a publically accessible player or forum profile). However, we do not transfer such data to other third parties.

For example, within the Games and the Websites, you may be provided with the option to link through to other websites or gaming communities. These other domains, apps and websites are subject to their own privacy practices and we encourage you to read the privacy policies of each and every website and application with which you interact. You visit these other websites or applications at your own risk.

Otherwise, your data will only be passed on in special exceptional cases, where we are obligated or entitled to do so by statute or upon binding order from a public authority.

10. Changes to this Privacy Policy

Changes to this Privacy Policy apply to your use of our Games after the “effective date.”

We will review this Privacy Policy periodically, and reserve the right to modify and update it at any time. You acknowledge that we may make changes to this Privacy Policy and it is your responsibility to check back to this page from time to time to review the Privacy Policy.Provided,

however, that if such changes are significant and it is required by applicable laws, we will endeavour to post notice or acquire your consent

regading such significant changes to this Privacy Policy.Changes to this Privacy Policy will come into effect immediately upon such changes being uploaded in the Games or to our Websites.

11. Children's privacy

The Games are only intended for persons: (i) in Europe aged 16 or older,(ii) in U.S aged 13 or olderl; or (iii) reached applicable age elsewhere

The Games are primarily intended for persons: (i) in Europe aged 16 or older; or (ii) in U.S aged 13 or older, or (iii) outside of Europe and

U.S, reached applicable age otherwise defined in your country of residence("applicable age")or older than such applicable age.

We therefore do not knowingly collect any personal data from: (i) children under 16 in Europe; or (ii) children under 13 in U.S or (iii) under

applicable age. Any person who provides their personal data to us through the Games represents that he or she is of an applicable age. If we learn that personal data of persons under these age restrictions has been collected, then we will take the appropriate steps to delete this information.

If you are a parent or legal guardian and discover that your child under these age restrictions has obtained an account with us or otherwise has provided personal data to us, you may contact us using the contact details set out above and request that we delete your child's personal data and account.

12. Your California privacy rights and "Do Not Track"

If you are located in California, you have certain additional rights.

California Civil Code link 1798.83 permits users who are California residents to request certain information identifying any third party to whom XQGAMES may have disclosed, within the past year, personal data pertaining to such user and such user's family for that third party's direct marketing purposes, as well as a description of the personal data disclosed. To request such information, you may contact us using the contact details set out above. Any written inquiry must include "California Privacy Rights Request" in the first line of the description. Please note that we are only required to respond to one request per user each year.

If the california Consumer Privacy Act(CCPA) applies to your information, you can exercise your rights to receive information about our data practices, as well as to request access to and deletion of your information. See the 'Your rights'section above for more information.

In addition, California residents under the age of 18 who are registered users of any of online sites, services or applications where this Privacy Policy is posted may under California law request and obtain removal of content or information they have publicly posted. To make such a request, you may contact us using the contact details set out above. Your request should include a detailed description of the specific content or information to be removed. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

California law permits our users who are California residents to be informed as to how we respond to web browser "Do Not Track" settings. We do not respond to "Do Not Track" settings at this time, whether that signal is received on a computer or on a mobile device.

13. Cookies

We use cookie technology to provide a personalised service to you.

We use cookies (access data files) which save the user's personal information in order to provide a specialized service that is customized and personalized to our users, as well as for analytics and tracking purposes. Cookies are small pieces of data (text files) that are sent by the website server to the user's browser or app and saved on the user's computer and other devices. With respect to its operation, our cookies distinguish between the users' computer or mobile phones but do not differentiate the individual users.

You have a right to choose whether the cookies are installed or not. You may choose to refuse all cookies, confirm each time a cookie is saved, or permit all cookies by going to [Tools]>[Internet Option]>[Security]>[Custom Setting], or by using the Settings or Options function on mobile devices. However, if you refuse all cookies, you cannot use our services that use cookies.

Google Analytics

The Websites use Google Analytics, a web analytics service provided by Google, Inc. ("Google").

Google Analytics uses "cookies", which are text files placed on your computer, to help us analyse how users use the Websites. These cookies do not collect any personally identifiable information and are only used for the statistical collection of data such as visits and page hits. Google Analytics’ cookies store IP addresses but we cannot link those addresses to any individual or path through the Websites. Google uses the cookies to read information and evaluate visitors’ use of the Websites in the form of statistical reports that we can access. The information generated by the cookie about your use of the Websites (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 the Websites, compiling reports on website activity 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.

For further information regarding the way in which Google Analytics uses cookies please see "How Google uses data when you use our partners' sites or apps", (located at www.google.com/policies/privacy/partners/). You can also stop being tracked by Google Analytics across all websites by going to Google's site at: http://tools.google.com/dlpage/gaoptout.

14. Security

We take security seriously and put in place measures to protect your information

We have in place appropriate technical and organizational security measures to protect your personal data, including:

In order to protect the unauthorized disclosure of users' personal data from hacking or any external break-ins, we currently use an equipment that blocks any external break-ins, which protects the data from any hacking, attacks, or unauthorized access, and we also use encryption, etc., so that personal data may be transferred safely. In particular, the server containing users' personal data is managed separately so that is not directly linked to the external internet line.

In preparation for any unexpected emergencies, we have a policy to back-up the system and data. We are taking protective measures to try and minimize damages caused by computer viruses by using vaccines that are regularly updated. Only the minimum number of people have right of access to the users' personal data. We regularly train our staff who handle personal data on new security technology and personal data protection obligations. Further, through an internal designated personal data protection unit, etc., we try and correct any errors immediately upon detection by checking the company's personal data processing procedure implementation and the relevant personnel's compliance with the personal data protection policies.

15. Where your information is transferred and stored

We may store, transfer and use your data outside your country.

In general, your data will be stored in Japan, the United States of America and the Republic of Korea, where our servers are located.

In the event that we transfer your personal data to another country and where the country or territory in question does not maintain adequate data protection standards, we will take all reasonable steps to ensure that any such transfers is undertaken in accordance with applicable data protection and privacy laws and that your data is treated securely and in accordance with this Privacy Policy. However, please note that where personal data is stored in another country, it may be accessible to law enforcement agencies in accordance with domestic laws.

16. Legal bases for processing your information

We rely on certain lawful bases to collect, use and share data about you if you are in the EU.

For users located in the EU only, the GDPR requires us to inform you of the different legal bases that we rely on to legitimize our processing of your personal data. We have described these below.

Where you give us your consent to process your personal data

We are allowed to use your personal data where you have specifically consented. In order for your consent to be valid:

It has to be given freely, without us putting you under any type of pressure;

You have to know what you are consenting to – so we'll make sure we give you enough information;

You should only be asked to consent to one thing at a time – we therefore avoid "bundling" consents together so that you don't know exactly what you're agreeing to; and

You need to take positive and affirmative action in giving us your consent – for example, we could provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion.

We currently seek your consent for marketing and advertisement purposes.

Before giving your consent you should make sure that you read any accompanying information provided by us so that you understand exactly what you are consenting to.

You have the right to withdraw your consent at any time, and details can be found in the "Right to withdraw consent" paragraph in the link on your rights above.

Where processing your information is within our legitimate interests

We are allowed to use your personal data where it is in our interests to do so, and those interests aren't outweighed by any potential prejudice to you.

We believe that our use of your personal data is within a number of our legitimate interests, including but not limited to:

To handle customer complaints;

To verify your identity;

To ensure that our systems run smoothly;

To protect against improper use or unauthorized use of our Games; and

To market our Games.

We don't think that any of the activities set out above will prejudice you in any way. However, you do have the right to object to us processing your personal data on this basis. We have set out details regarding how you can go about doing this in the link on your rights above.

Where processing your personal data is necessary for us to carry out our obligations under our contract with you

We are allowed to use your personal data when it is necessary to do so for the performance of our contract with you. For example, we need to process certain personal data about you in order to be able to provide you with the Games and related services (including Games branded websites) which you have requested from us and in order to govern the relationship between you and XQGAMES.

Where processing is necessary for us to carry out our legal obligations

As well as our obligations to you under any contract, we also have other legal obligations that we need to comply with, and we are allowed to use your personal data when we need to comply with those other legal obligations.

This Privacy Policy should come into effect from June. 10, 2020