PRIVACY AND DATA POLICY ISSUED BY Powerful Spring Limited

1. INTRODUCTION AND GENERAL TERMS

These terms apply to the use of games and other products developed by Powerful Spring Limited (“we” / “us”). Our registered office is at Unit 1603, 16th Floor, The L. Plaza, 367-375 Queen’s Road Central, Sheung Wan, Hong Kong.

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of all games, related online services (including online network play connectivity and interactivity), and other software and products made available by us (together the “Game(s)”), as well as any other online features relating to the Games, including our website (the “Website”). Together, the Game(s) and Website are referred to as the “Online Services.”

If you have any questions or comments about this Privacy Policy, please contact us at ceo@everymanlimited.com.

We are committed to protecting and respecting your privacy. This Privacy Policy explains the basis on which personal information we collect from you will be processed by us or on our behalf. Where we decide the purpose or means for which personal data you supply through these Online Services is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.

Please read this Privacy Policy carefully as it contains important information about the following:

• What information we may collect about you;
• How we will use information we collect about you;
• Whether we will disclose your details to anyone else; and
• Your choices and rights regarding the personal information you have provided to us.

This Privacy Policy forms a part of and should be read in conjunction with our terms of use.

The Online Services may contain hyperlinks to services owned and operated by third parties. These third-party services may have their own privacy policies, and we recommend that you review them. They will govern the use of personal information that you submit or which is collected by cookies and other tracking technologies while using these services. We do not accept any responsibility or liability for the privacy practices of such third-party services, and your use of these is at your own risk.

We may make changes to this Privacy Policy in the future, which will be posted on this page. You should check this page from time to time to ensure you are aware of any changes. Where appropriate, we may notify you of changes through the Games.

2. INFORMATION WE MAY COLLECT ABOUT YOU

We collect and process the following information, which may include your personal data.

a) Information provided by you when using the Games (“Basic Information”)

We may collect the following information from you when you play our Games:

• Your mobile device’s unique device ID (Device ID);
• Your user preferences; and
• Core information related to your gameplay, such as your overall progression to a particular level or stage, your virtual currency stores, or the completion of certain activities during your gameplay (for example, completing a tutorial, passing a level, making a purchase, or viewing a video ad).

b) Information used for the purposes of serving advertisements (“Advertising Data”)

Through our third-party advertising network partners, we may gather information about your devices when you install or play our Games, depending on the permissions you’ve granted. This may include:

• The make, model, and operating system of your device;
• Properties of your device, such as screen size and orientation, audio volume, and battery;
• The mobile network operator linked to your device;
• The Games played;
• The country, time zone, and locale settings on your device (i.e., country and preferred language);
• Network connection type and speed;
• IP Address;
• MAC address;
• Internet browser used to access the Games; and
• The advertiser ID, which is an identifier unique to you if you use an Apple or Android device, but which doesn’t reveal your name.

c) Information collected for the purposes of providing analytics (“Analytics”)

We may collect technical information about your use of the Online Services through the use of tracking technologies and analytics. Personal data we may collect includes the following:

• Your Device ID;
• Your user ID (which is generated by us and allocated to you when you first play our games);
• Your device operating system & version;
• Your device make and model;
• Game play attempts, progression, and results;
• Session game time start, end, and duration;
• Purchase transaction types and spend you have made using virtual items in the Games;
• The country of your Device;
• The time, date, and install source of your first download (e.g., from a clicked advertisement);
• Advertisements viewed and clicked; and
• Identification of crashes and defects.

d) Information about you collected from third parties (“Third Party Log In Information”)

When you access the Games via a third-party social media provider such as Facebook, we may collect and store personal and non-personal information available on that third-party social media provider, such as your Facebook name, your profile picture or its URL, your Facebook ID, and other public data of your friends, provided that you have expressly agreed to the use of Facebook within the Games. We will also receive technical data in order to ensure the Games connect to the correct Facebook account.

3. WHY WE COLLECT INFORMATION ABOUT YOU

We collect information about you for the following reasons:

a) To provide our Games to you

We will use information about you (including Basic Information, Third Party Log In Information, Analytics, and User Content) to deliver our Games to you under the terms of use agreed between us. This is necessary for us to record your progress and current status within a Game, ensure the Games deliver the features promised, and function properly so that you have the best experience.

b) To help us improve the Online Services and fix any problems

We may process information about you to analyze and improve our Games and Online Services, ensuring they function properly, improving quality, identifying and correcting bugs, and understanding marketing effectiveness.

c) To acquire new users and engage current users

We may process information to encourage engagement from our less active users and notify them of new virtual items or promotions. We also use this information to improve the relevancy of our marketing and acquire new users.

d) To improve monetization via in-app purchases

We may process information to understand how users engage with our Games, compile reports, and improve revenue generation through dynamic pricing models.

e) For advertising purposes

We process Advertising Data to show you advertisements for third-party services, track ad performance, and reward users with benefits. Our advertising partners include:

• Chartboost – https://answers.chartboost.com/en-us/articles/115001489623
• Adcolony – https://www.adcolony.com/privacy-policy/
• Facebook – https://www.facebook.com/privacy/explanation
• Unity – https://unity3d.com/legal/privacy-policy
• Google – https://policies.google.com/technologies/ads

f) To prevent fraud and illegal activity

We process personal data to ensure lawful use of our Online Services, prevent fraudulent activity, and comply with legal obligations. If necessary, we may share your information with relevant authorities.

4. DATA SHARING

We will share your information with third parties only as described in this Privacy Policy.

For more details, please contact us at ceo@everymanlimited.com.