PRIVACY POLICY

Last revised: [March 2021]

Welcome to MANAGENE GAMES. This Privacy Policy explains our privacy commitment to our players and users of our Services (hereinafter "Users"). This Privacy Policy is incorporated as part of the MANAGENE GAMES Terms of Use, accessible at [www.managames.hk].

At MANAGENE GAMES, we collect personal data to support our products and services, while respecting all applicable laws, including but not limited to the Personal Information Protection and Electronic Documents Act (PIPEDA), regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, directly applicable from May, 25th, 2018 (hereinafter, "General Data Protection Regulation", or "GDPR"), UK GDPR, Children's Online Privacy Protection Act of 1998(COPPA) in USA, or other applicable laws or regulations in your country. As defined in the GDPR, "personal data" means any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

By using MANAGENE GAMES’s services, ticking the checkboxes and clicking “Agree” button on the pop-up window, you authorize MANAGENE GAMES and its affiliated companies (collectively, "MANAGENE GAMES" or "we"), to process your personal data according to this Privacy Policy. If you do not accept the terms of this Privacy Policy, please refrain from using our online games or our games’ online functionalities, our websites, our mobile apps and any other online MANAGENE GAMES products and services (hereinafter "Services").

According to the GDPR, COPPA and other applicable laws and regulations, the minimum age for you to play our game services unsupervised is 13 (in US,JAPAN )/ 14(in UK、KOREA )/16(in Europe)/18(in most countries) years old. We will not knowingly collect personal data from children under this age without prior consent from their parents or legal representative. If you are a child under the age abovementioned, we will require parental consent before an account is created for you and personal data associated with it collected and use all reasonable efforts to verify that the consent was given by the child’s parents or legal representative, considering available technologies. We encourage parents to instruct their children to never give out personal data when online.

In the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, we will make an announcement in advance, disclose the details of the event and information about the successor, and with the express consent of you or your guardian in advance, your personal data may transfer to the successor of MANAGENE GAMES.

We may periodically modify, adjust, or revise the terms of this privacy policy. You are encouraged to check this page from time to time to ensure that you are informed of any changes. The updated terms especially material changes relating to your rights as a data subject will be announced to you before you use our service, in the form of a pop-up window with checkboxes or otherwise to obtain your consent again. You agree to check the new terms regularly.

1. WHAT PERSONAL INFORMATION DOES MANAGENE GAMES COLLECT?

1.1 When you use MANAGENE GAMES services

1.1.1 While Browsing MANAGENE GAMES websites

Cookies. MANAGENE GAMES uses cookies on the Services. A "cookie" is a small bit of record-keeping information that web sites often store on a user's computer. Cookies are not intended to include people's names, or other information that is directly identifiable; rather, they are typically used to quickly identify a user's device and to "remember" things about the user's visit. MANAGENE GAMES may set cookies for your web browser as you visit our websites, use our products, or visit a website where MANAGENE GAMES provides ads, content or analytics. For example, MANAGENE GAMES uses cookies to keep track of selected items in your shopping cart on our online store, and to remember your Account identifier. You can disable cookies or set your browser to alert you when cookies are being sent to your computer, although this may affect your ability to shop online or to access certain features of our Services. Each browser is different, so check the "Help" resources for your web browser to learn how to change your cookie preferences. In addition to MANAGENE GAMES using cookies on our network of websites, MANAGENE GAMES may allow certain partners to set and access their cookies on your computer. These companies’ use of cookies is subject to their own privacy policies, not the MANAGENE GAMES Privacy Policy. Please review them carefully.

IP addresses. MANAGENE GAMES also collects Internet Protocol (IP) addresses for safety and security reasons. An IP address is a number that is used by computers on the network to identify your computer every time you log on to the Internet.

Other passively collected information. While browsing our sites, MANAGENE GAMES may, on its own, or with the help of third-party tools, collect non-personally identifiable information concerning your gaming hardware, habits, behaviors and use of our Services. MANAGENE GAMES collects such information to better adapt our Services to users’ interests, and for a better quality of our Services. The information collected may contain the following, without limitation: device unique identity, including MAC address, mobile, unique identifier or other device identifiers and settings, internet provider, carrier, operating system, hardware information, localization information, date and time spent on the Services, game scores, game metrics, achievements, rankings, time played and statistics, feature usage, advertising conversion rates, monetization rate, purchase history and other similar information.

1.1.2 Registering on a MANAGENE GAMES service

When you use our Services, you may give us information directly (like when you’re setting up your account). Some games or parts of our Services may also let you create a registration or account where you may be asked to give us information like: your username, password, email address, date of birth (or age) and country of origin.

1.1.3 Contacting MANAGENE GAMES

MANAGENE GAMES may ask for your first name, family name, e-mail address and your date of birth to answer your demands to the MANAGENE GAMES Customer Support, to confirm any information or transaction on your MANAGENE GAMES account, and to give you information regarding the Services (for instance, if you lose your password or if we make changes to the Terms of Use).

1.1.4 Participating to contests and sweepstakes

MANAGENE GAMES may offer you the opportunity to participate in online surveys, questionnaires. To participate, you may need to provide your first name, your family name, e-mail address, date of birth, your address and country of residence. If you choose to participate in surveys and questionnaires, your personal data may be processed to allow you to participate, and for internal statistical use.

1.1.5 Interacting on forums

Whenever you participate or interact with other users on a forum, MANAGENE GAMES collects the content of your communications, the time and the location of your activities, as well as your online ID and your IP address.

1.1.6 Advertisements

MANAGENE GAMES uses third party ad-serving technologies that may collect information to provide behavioral and non-behavioral advertisements within our Services. The information collected and used for the targeted advertising may contain the following, without limitation: age and gender, number of views of an advertisement, device unique identifier or other device identifiers and settings, information about your use of the products and Services, other sites (including third party web pages and mobile Internet sites) you have viewed (as well as date and time viewed), advertisement(s) served, the advertisement(s)’ in-game location and length, and your response to the advertisement(s) (if any). The analytics tools and ad serving technologies may use server log files, web beacons, cookies, tracking pixels and other technologies to collect this information, and may combine the information collected on other MANAGENE GAMES Services with information collected from other third-party websites, products and services and with demographic, advertisement, market and other analytics surveys. Standing alone, this information is not personal data; however, if MANAGENE GAMES combines any of this information with personal data, MANAGENE GAMES will treat this information as personal data pursuant to this Privacy Policy.

You have the right to withdraw your consent to the processing of your personal information for advertising purposes at any time by contacting us in the manner set out in section 8, or by turning off the corresponding permission in the privacy settings of your personal devices. We undertake not to process personal information of children or minors under the age of 13 (or the age of a minor or child as defined by law or other regulation in your country or region) for advertising purposes.

1.1.7 Social media and other third parties’ platforms

We collect the Data that you have agreed to share via the social media site or third-party platform in question when you sign into our Services with a social login or your credentials from a third-party platform (for example, Facebook, Google).

MANAGENE GAMES may also collect personal information on third party social networks, platforms or services. By playing a MANAGENE GAMES game through a social network or other third party platform, or by connecting to such a third party network, platform or service via one of our products and/or Services, you authorize MANAGENE GAMES to (1) collect, store, and use, in accordance with this Privacy Policy, any and all personal information that you agreed the social network or third party platform could provide to MANAGENE GAMES based on your settings on the social network or platform, and (2) share any and all of your personal information with the social network or other third party platform, through the social network/third party platform’s Application Programming Interface (API). You agree to this sharing when you connect with the third-party network, platform or service via our products and/or services, and/or when you connect with, "accept" or "allow" (or similar terms) one of our applications through a social network, or other third-party platform or service.

You acknowledge and agree that if you access our Services from a third-party application or connect our Services to a third-party application, the third-party application providers will be data controllers of some of your personal information, and we cannot guarantee that they will provide the same level of protection for your personal information as we do. therefore, we encourage you to read that third-party application’s terms of service and privacy policy before you using the third-party application.

If you become aware that a third party application provider is processing personal information about you or your child in a manner that causes you concern or anxiety, you may also contact us and we will do our best to assist you with the situation.

1.2 Whenever you play games of MANAGENE GAMES

1.2.1 Creation of user generated content

Some Services give you access to tools in order to allow you to create and/or share unique content. This User-Generated Content may be collected by MANAGENE GAMES; this content may also contain your personal information or the personal information of others (for instance, your name, or a picture of you). Please exercise caution: MANAGENE GAMES is not liable for any negative consequences linked to your disclosure of User-generated content.

1.2.2 In-game data collection

Whenever you use the Services, MANAGENE GAMES may collect, store and process your in-game data, including but not limited to: your game scores, game metrics, achievements, rankings, time played and statistics, feature usage, advertising conversion rates, monetization rate, purchase history and other similar information. MANAGENE GAMES will use this information to improve the Services, to personalize them to your interests, and otherwise upgrade your gaming experience. Any information collected by MANAGENE GAMES in accordance with Article 1 of this Privacy Policy may also be used in an aggregated form to identify specific patterns regarding the use of our Services.

1.3 Online payment

For some Services, you may make purchases, whether you shop on MANAGENE GAMES websites or directly in-game.

When you do this, you agree that MANAGENE GAMES may share your personal data with third parties, companies, or organizations, which may collect and process your personal data in order to effectuate online transactions, delivery, discounts, and promotional gifts.

When you play MANAGENE GAMES’s games or access any of our other Services on connected third-party applications or platforms (like Apple, Google), any purchases you make will be processed by that third-party application and subject to that third-party application’s terms of service and privacy policy. For these purchases, MANAGENE GAMES does not receive your financial information, but may receive non-financial information related to your purchases, like the items purchased.

2. HOW DOES MANAGENE GAMES USE YOUR PERSONAL DATA?

The information you submit to our Services is collected and used by MANAGENE GAMES as set out in this Privacy Policy. MANAGENE GAMES collects and processes your personal information at different times when you interact with our Services. Generally, personal information is collected when:

a. you use a Service,

b. you create an Account,

c. you make a purchase within our Services,

d. you create user generated content,

e. you watch advertisements within our Services,

f. you sign up for a newsletter,

g. you contact MANAGENE GAMES customer service and during technical support sessions,

h. you chat with other users of the Services,

i. you participate in a beta or otherwise download a patch or a demo, or

j. you share or otherwise contribute to our social media channels or other community websites.

In addition, MANAGENE GAMES may use the submitted information to answer your demands, to send your order confirmations and other information regarding your MANAGENE GAMES Account, to send you (non-child or minors only) advertising or promotional materials, including information about special rebates, promotional offers and other events of interest, based on your preferences.

We also may use your personal information for our internal marketing and demographic studies, so we can constantly improve the Services we provide you and to better meet your needs.

MANAGENE GAMES processes your personal data, wherever necessary:

- To provide you with the Services (creation of your MANAGENE GAMES account, bug detection, fighting fraud, online payment, etc.)

- To offer the best possible experience to users, and improve the Services (in-game data analytics, etc). It is in MANAGENE GAMES’s legitimate interest to process your data for these purposes.

- To provide you with supplementary services (custom content, etc.). In such case, MANAGENE GAMES will ask for your consent before processing your personal data for this purpose.

Whatever the activity may be, we will only collect personal information to the extent necessary to provide you with the Services and fulfil your requests.

3.Security of Your DATA

We take your privacy and the security of your personal information very seriously. To protect your personal information, MANAGENE GAMES maintains appropriate safeguards to ensure the security, integrity and privacy of the information you have provided. We use robust security measures to protect personal information from loss, misuse and alteration. We use industry-standard practices such as encrypted communications, physically secured rooms, firewalls and password protection systems to safeguard the confidentiality of your personal information. In addition, we take reasonable steps to assure that third parties who collect personal information on our behalf provide sufficient protection of personal information. Please note, we will make every effort to protect your personal information to the maximum extent possible using the security solutions allowed by available technology and notify Users of a data breach pursuant to applicable law.

If your MANAGENE GAMES accounts and personal data are protected by a password, you are responsible for ensuring this password’s confidentiality. Please do not disclose this password. If you share a computer with other people, please consider disconnecting from your accounts before allowing others to use your computer. Services may contain links leading to third party websites, such as but not limited to social media sites. Whenever you click on a link leading to a third party’s website, you agree to leave MANAGENE GAMES Services as governed by this Privacy Policy, and you understand and agree that MANAGENE GAMES does not control such third party’s website. MANAGENE GAMES cannot guarantee that third parties’ websites will be governed by the same security and confidentiality obligations. MANAGENE GAMES is not liable for the use of your personal data by these third parties. Please consider checking privacy policies of any service provider you transfer your personal data to.

4. FOR HOW LONG DOES MANAGENE GAMES KEEP YOUR PERSONAL DATA?

Unless relevant legal provisions mandate a different data retention period, MANAGENE GAMES will store your personal data only as long as necessary to process it according to this Privacy Policy. For instance, we may retain certain information after you close your account for a period of time needed to protect MANAGENE GAMES from legal claims. In this case, we will archive your personal data during the relevant statutory period of limitations.

5. WITH WHOM DOES MANAGENE GAMES SHARE YOUR PERSONAL DATA?

MANAGENE GAMES does not disclose your personal data to any third party other than our affiliates and partner suppliers without your prior consent, except in cases where disclosure is expressly required by applicable laws or regulations.

5.1 Sharing your personal data with MANAGENE GAMES affiliated companies

MANAGENE GAMES may share your personal information among the MANAGENE GAMES group of companies. To the extent that our corporate affiliates and/or technical partners have access to your information, they will follow practices that are at least as restrictive as the practices described in this Privacy Policy.

5.2 Sharing your personal data with third parties

While browsing on MANAGENE GAMES websites, or while using MANAGENE GAMES Services, external providers may collect your personal data for and on behalf of MANAGENE GAMES, and MANAGENE GAMES may share some of your personal data with these partners to allow the functioning of the Services (such as Facebook, Google, Twitter, AppsFlyer, Firebase). For example, these third parties may help deliver your purchases, provide discounts or offer products, promote the Services, perform electronic payment processing, and any other service that may be required by MANAGENE GAMES. These external providers will share your personal data with no one other than MANAGENE GAMES, and they may not use your data for their own independent marketing purposes, unless you consent to their privacy policy and terms directly.

the list of the third parties collecting your information on our behalf is as followed:

Name of the SDK provider: [Facebook]

purpose of data collection: [Login, analytics]

Privacy Policy: [https://www.facebook.com/about/privacy]

Name of the SDK provider: [AppsFlyer]

purpose of data collection: [Configuring media sources]

Privacy Policy: [https://www.appsflyer.com/privacy-policy/]

Name of the SDK provider: [Firebase]

purpose of data collection: [Configuring media sources, analytics, push notification]

Privacy Policy: [https://policies.google.com/u/1/privacy]

5.3 Sharing your personal data with government authorities

In accordance with relevant laws, MANAGENE GAMES may have to disclose your personal data to a judiciary or administrative entity, whenever such disclosure is deemed necessary for protecting or enforcing the legal rights of MANAGENE GAMES, its Users, or third parties. Unless required by law, MANAGENE GAMES will not be required to notify you of any such disclosure.

5.4 Transfers of personal data to third countries or outside the European Union

The user data we collected above is stored and encrypted in our servers located in East Virginia, United States of America (“USA”). And you are aware and agree that your personal information may be transferred to, stored in, and processed by affiliated companies, subcontractors and/or MANAGENE GAMES partners, located in third countries/outside the country where you live or work. Because different countries may have different data protection laws than your own country and they may not provide you with protection of the same level to your personal information as the data protection law in the country where you live or work, in which case, we will take steps according to applicable laws and regulations in your country to ensure that your personal information is adequately protected within the data process location.

5.5 Friends and Other MANAGENE GAMES Players

MANAGENE GAMES Services may offer a public profile feature ("Public Profile") that allows you to publish information, including personal information, to the public Internet. Those aspects of the Public Profile that are designated as "public" will be visible to everyone, potentially including people not registered within the MANAGENE GAMES environment, and may be indexed and displayed through public search engines when someone searches for you. If you post your personal information to a Public Profile, including a video, image or photo, you should be aware that these may be viewed, collected, copied and/or used by other users without your consent.

We are not responsible for disclosure by other users of your Personal Information, including without limitation, videos, images or photos that you choose to make public on the MANAGENE GAMES Services. Also, please remember that the Personal Information you provide to us as part of your Public Profile may reveal or allow others to identify aspects of your life that you may not choose to state on your Public Profile directly (for example, your picture may reveal your gender).

6. WHAT ARE YOUR RIGHTS AS DATA SUBJECT?

You can access and update the contact information you gave us during registration (that is, your e-mail address or any other information that would directly enable us to contact you), by logging in and clicking the Edit Profile section. Additionally, according to the applicable laws and regulations in the country or region where you live or work, you may have a right to access, rectify, erase, object, or restrict processing for all your personal data processed by MANAGENE GAMES, as well as the right of data portability. You can exercise these rights or terminate your MANAGENE GAMES account by writing to MANAGENE GAMES customer support, via the following website: [www.managames.hk] or send an e-mail to [user.support@managames.hk]. MANAGENE GAMES will answer your request within a month following the receipt of your demand and the completion of the verification process. MANAGENE GAMES reserves the right to extend this delay up to three months if it necessary regarding the complexity of your demand, or based on the number of demands we receive. In such case, we will inform you of this extension within a month following the receipt of your demand. For any data processing activity requiring your consent (cookies, behavioral advertising, etc), you may withdraw your consent at any time. This withdrawal does not affect the lawfulness of any previous processing. You can also adjust your browser settings to understand when these Cookies are stored on your device or to disable the Cookies by consulting your browser’s “Help” menu. Please note that these settings may affect your ability to access certain features of our Services whenever these Cookies are needed for the operation of our Services.

Opting Out of Third-Party Behavioral Advertising

If you are interested in more information about behavioral advertising and your choices to prevent behavioral web and mobile web advertising from third parties, you may visit the following websites:

• Network Advertising Initiative Consumer Opt-Out Page or the Digital Advertising Alliance Opt-Out Page for U.S.-based advertising

• If you do not want to receive behavioral in-application advertisements from third parties that relate to your interests on your mobile device, you may adjust the ad tracking settings on your device (such as turning on “Limit Ad Tracking”). You can also reset the “Advertising Identifier” (such as an IDFA) from your mobile device’s settings page, which will prevent continued use of existing behavioral data tied to your previous “Advertising Identifier.”

All of the opt-out tools described in this subsection are provided by third parties, not by MANAGENE GAMES. MANAGENE GAMES does not control or operate these tools or the choices that advertisers and others provide through these tools.

Please note that you may still receive third-party advertisements in MANAGENE GAMES’s Services after using these opt-out tools, but the advertising you see may be less relevant to your interests.

Opting Out of Promotional Communications from MANAGENE GAMES

You can unsubscribe from promotional emails by by following the unsubscribe instructions included in these emails. You can opt out of mobile push notifications in your device’s settings page. You can opt out of SMS text communications by texting STOP. You also may contact us at [user.support@managames.hk].

Please note that if you opt out of receiving promotional communications from us, we may still communicate with you from time to time if we need to provide you with information about the Services you are using from us, if we need to request information from you with respect to a transaction initiated by you, or for other legitimate non-marketing reasons, for example, if we are required under applicable laws to notify you of updates to this Privacy Policy or our Terms of Service.

* If there are special provisions provided by applicable laws (including but not limited to GDPR, UK GDPR, CCPA, COPPA, PIPEDA etc.) and regulations in the country where you live or work, we will process your personal data in accordance with applicable laws.

7. PRIVACY POLICY CHANGES

MANAGENE GAMES reserves the right to modify this Privacy Policy at any time. As a result, please consider checking this Privacy Policy from time to time. Your use of the Services after MANAGENE GAMES changed this Privacy Policy shall signify that you agree with these changes unless there are significant changes regarding to your rights, in which case we will notify you in advance and acquire your consent when you entering our game service next time in the form of a pop-up window. If you do not accept changes made to this Privacy Policy, please refrain from using the Services.

8. CONTACTS

For any question related to your personal data processing and this Privacy Policy, please contact MANAGENE GAMES data protection officer at the following address: [user.support@managames.hk].

You can also write to us at the following address: [Rm 2701 27/F CENTRAL PLZ,18 HARBOUR RD,WANCHAI,HONG KONG]

Please be assured that any Personal Information that you provide in communications to the above email and postal mail addresses will not be used to send you promotional materials, unless you request it.

According to applicable laws, you may also have the right to lodge a complaint to data protection authorities in the country where you live or work.