BRAZIL PRIVACY POLICY FOR APPS

(Last update October 19, 2023)

INTEREST-BASED ADS

Before sharing any information with our advertising partners for the purposes of interest-based advertising, we will always ask for your consent. Based on your consent we share information we collect from you that can be used to personally identify your device, e.g., persistent identifiers such as advertising ID, IDFA, IP address with our advertising partners and they can use such data for interest-based advertising. For example, they may attach the information gathered from our App to information gathered from other apps, websites, or via other services, and then build profiles, show you an ad based on such profile (for example they might know that device with your advertising ID has clicked on a sports ad within other publisher's app and show to you a sports ad in our App). In addition, we may use and share such information with our advertising partners to target and optimize our advertising and promotions in our and other publisher's apps.

We allow our advertising partners to show interest-based ads to you only if you have consented to the sharing of your personal information for the purposes of interest-based advertising.

Our advertising partners use different technologies for the purposes of interest-based advertising that process your personal information in different ways, so please review their data processing practices before you provide your consent to sharing your persistent identifiers such as advertising ID, IDFA, IP address and other information that may be personal to you for the purpose of interest-based advertising.

WHO CAN SHOW INTEREST-BASED ADS TO ME?

Please see the following list of advertising providers that are allowed to show interest-based advertising and review their data processing practices, including the technologies they use for the purposes of interest-based advertising:

Outfit7 Limited: https://outfit7.com/privacy-brazil/en/List of ad partners: https://outfit7.com/privacy-brazil/en/#who-can-show-interest-based-ads-to-me

HOW CAN I TURN OFF INTEREST-BASED ADS?

You have an option to withdraw your consent to sharing your personal information for the purposes of interest-based advertising at all times. You can withdraw your consent by going to the app settings and clicking the interest-based ads button where you can manage your preferences by choosing to which advertising partner you allow to share your personal information for the purposes of interest-based advertising.

When you decide to withdraw your consent or if you do not provide your consent, you may still see the same number of ads on your mobile device; however, these ads may be less relevant because they won't be based on topics you like, your interest, behavior, demographics, etc. Our advertising partners may continue to show you ads based on the content of the application you are using.

ABOUT US AND THIS PRIVACY POLICY

Your privacy is very important for us, and we will always use your personal information only for the purposes as described in this Privacy Policy. As used in this Privacy Policy, "Outfit7 Neo", "we", "us" or "our", "ours" refers to Outfit7 Neo Limited and all of its subsidiaries.

This Privacy Policy covers how we collect, use, disclose, transfer and store information received about users from Brazil and/or information received about Brazil users' computing devices through their use of the Apps. You can always determine your country of residence in the app settings by clicking a "Country" button and selecting your country.

We receive and/or you may be asked to provide your information (including personal information) any time you are in contact with us or use the Applications. As described in greater detail below, we share your information (including personal information) with our affiliates and with third party partners (as defined below) and use it in ways consistent with this Privacy Policy. We may also use your information (including personal information) together with other information to provide and improve products, services, content, and advertising.

INFORMATION WE COLLECT FROM YOU

Most of the information that we collect about you comes directly from you when you play our Apps or interact with third party ads in our Apps or with our ads in other publisher's apps. In general, the information we collect about you relates to the type of device you are using, information that helps us identify your device, how you play our apps and may include information that you submit to us when you voluntarily contact us or which you allow us to access when you connect to your social network accounts through our Apps. We may also collect information from app store platforms and partners and other third parties such as information about your interests and in-app purchases (if we never receive your payment or credit card information).

1. Technical Information

We collect technical information about your device that are necessary for you to use our App and additional technical data that enables us to maintain and analyze the functioning of the App, to personalize the content of the App, and to display advertisements. Such information includes amongst others the type of device(s) you are using to play our Apps, persistent identifiers, such as IP address, device identifiers, ad identifiers, unique user ID specific for our Apps, and the country or region that you are playing in.

Persistent identifiers (such as IDFA, IDFV, Advertising ID, IP address) that are identifiers that do not identify you personally but may uniquely identify your device. Such online identifiers provided by end user devices, applications, tools and protocols are considered as personal information according to Brazil data protection legislation. Please check the rights you have under Brazil data protection legislation in Section "Your Rights".

We automatically collect certain information about your computing device, including:

IP address; Country or region;
IDFAs, IDFVs, Advertising IDs;
Language; Locale (specific location where a given language is spoken);
Time zone, session start/stop time,
Network status (Wi-Fi, etc.), browser plug-in types and versions;
User agent string (UA), platform, SDK version, timestamp;
Our apps installed;
Technical device information (e.g., device model and name, operating system name and version, CPU information, storage size, screen size, firmware, software, mobile phone carrier, Internet service provider, API key identifier for application, Android ID, Android Serial No);
Push notifications token (in order for us to be able to determine whether you are subscribed to push notifications);
Player identifier string (we collect player identifier string only upon your sign in to Google Play Games Services or Apple's Game Center).

Additionally, for playing video advertisements through a video platform provider, we may collect additional information about your device, such as:

● "do not track" flag;

● page URL;

● Iso code of the country set on device;

● device date;

● whether Limit Ad is enabled or disabled;

● type of device (tablet or not).

_In addition, for users of Android devices we create a unique user ID and for users of iOS devices we use IDFVs to track your use of our Apps. _

Older versions of our Apps may still obtain information such as UDID number and IMEI number. If you wish to prevent this, please update the App with the latest version available on the App Store.

2. Advertising and Application Usage Information

When you use our Apps, we collect additional information from you by using persistent identifiers that permit identification of your device. We collect information about how you play our Apps, how you interact with our ads in other publisher's apps and how you interact with third party ads that are shown to you in our Apps. Such information is used for delivering and improving our service, advertising, cross-promotion and analytics purposes.

We collect information, including log information, that lets us know:

Which advertisements are shown to you;
How long an advertisement is visible to you, the size of the advertisement and the angle of view;
How you interact with our ads in other publisher's apps and how you interact with third party ads that are shown to you in our Apps (if any), including clicks on ads;
How you play our Apps (how often you play the app, for how long you use the app, the events that occur within the app, in-app progress, in-app purchases you make and their value, aggregated usage, performance data, life time value of user etc.);
Whether you use chat feature, and if you do, the content of messages sent using our chat system, provided that this is only used for operating the service;
If you connect to Third Party Social Network, information we collect from you when you connect to such Third Party Social Network as described in "Third Party Social Networks" Section.

3. Classical Personal Information

We do not collect classical personal information through our Apps (such as your name, address, email or phone number) and you can use our Apps without providing us with your classical personal information. We will receive your classical personal information (such as your name, address, email or phone number) only when you contact us directly and will use such information only to respond to your inquiry.

For some of our Apps we collect information about the nickname you choose and your rating of the Application (if any). Please do not use your real name.

HOW WE USE YOUR INFORMATION

1. In General

We use the information we collect about you/your device to deliver services and our Apps to you and to operate our business. We use it also for improving our services and Apps, for enhancing security and for analytics and research purposes to make sure we provide you with the best experience. In addition, we use your information to promote our services and Apps in our apps and in other publisher's apps and to display third party advertisements to you. We use your information also for attribution and fraud prevention for advertising purposes and for complying with our legal obligations.

We use your information for the following purposes:

Delivering and improving our services: We use your information for developing, delivering and improving our Apps and other products, services, and content, tailoring our products and services, providing App updates, technical troubleshooting, understanding and analyzing trends in connection with usage of the Apps, and administering the Apps.
Displaying advertisements: We use your information for showing advertisements for our Apps in other publisher's apps and for displaying third party advertisements in our Apps. Please see more in the Advertising Section of this Privacy Policy.
Cross-promotion: We use your information for cross promoting our Apps and services, meaning to promote one of our Apps while you are playing a different App of ours.
Attribution and fraud prevention for advertising purposes: We use your information for attribution how our advertising campaigns perform, and for identifying and preventing fraud for our advertising campaigns. We also use your information for the purposes of attribution performance, ad visibility and privacy compliance of third-party advertising campaigns in our Apps.
Analytics and research: We use your information for understanding and analyzing trends in connection with the usage of the Apps, gathering demographic information about our user base, data about where the App was downloaded from. We may also create reports and analysis for the purposes of research or business intelligence, for example to track potential problems or trends with our Apps and services, or to test our new game features and content.
Security: We use your information for enhancing the safety and security of our Apps, products and services.
Customer Support: We use your information for providing customer support to you and to respond to your inquiries.
Our legal obligations: We use your information when we are required to do so by law, for example we use your country or region for tax reporting purposes.

2. Game Notifications

We have two types of notifications in our Apps - local and push notifications. Local notifications are contextual and sent from the device, whereas push notifications are sent from the server. ** ** We use such notifications to remind you about your activities within the App. You will receive such notifications only if you are subscribed to such notifications in the App. You can always unsubscribe from push notifications, please use the instructions provided below.

For iOS: You will be asked to accept or refuse push notifications after an Application is downloaded. If you do not accept, you will not receive push notifications. Please note that if you accept, some mobile phones will allow you to disable push notifications later on by using the settings on your mobile phone. To manage push notifications on your mobile phone please follow these instructions: Open your Settings menu and tap "Notifications"; Find the App; Tap on the icon of App; Manage the "Notifications" option by sliding it OFF or ON.
For Android and Windows: After an App is downloaded, you will automatically receive push notifications. You can manage push notifications on your mobile phone by entering the "info screen" on the homepage of the App and choosing the "Settings" option. Here, push notifications can be disabled by unchecking the "Notification" option within the App.

When you decide to unsubscribe from push notifications, such push notification tokens will be deleted from our database.

3. Survey

We are conducting surveys to improve our services and you may freely decide whether you would like to help us or not. We will always ask for your consent before conducting a survey.

From time to time, we may conduct an in-app survey and collect demographic and usage information for the purposes of internal analysis, marketing and brand development. Participating in a survey is completely voluntary. We will use the information to make our services more appealing to users. Collected information shall be anonymized and aggregated. We might collect the following information: age and gender of the user of an app, whether another person uses the app, the age and gender of the people regularly using the app, assessment of popularity of the main character, which of the characters are known to the user, which app is most commonly used, the gender of users playing the app, different ways of using the app, an assessment of the features of an app, the time period of using the app, which apps the user has, which Products have been bought or have been considered, what would make the app more appealing, and other information needed for the purposes of internal analysis, marketing and brand development.

We may use third party providers for the in-app surveys, and they may place their tags within an App to collect non-personally identifiable data from the device ("Tag Data") solely for the purposes of conducting the survey, such as to collect cross device information in order to enable the deduplication of audiences across devices. These providers may use the data collected from the survey and Tag Data on an anonymized and aggregated basis together with the data from other partners ("Unified Data") to publish syndicated reports on internet behavior and trends. If you wish to opt out from conducting an in-app survey, do not click on the survey button or deny answering the survey questions.

4. In-App Purchases

Our Apps enable in-app purchases. We do not process payments for in-app purchases nor have access to your credit card information.

Payment transactions for in-app purchases are completed through the app store via your app store account. Any post-purchase processes are controlled by the app store and are subject to specific terms of such app store. Please review the privacy policy and terms of service of your app store. For more information on in-app purchases in our Apps please see In-App Purchases Section of the End User License Agreement available at https://outfit7neo.com/eula.

We cannot provide all services necessary for the successful operation of the Apps by ourselves. We must therefore share collected information with third parties, including analytics providers, attribution and fraud prevention providers, cloud service providers, third party advertising providers and their attribution and fraud prevention providers and other third party service providers that develop and support the Apps (collectively referred to as "Partners"). We share information that can be used to personally identify your device (e.g., persistent identifiers such as IDFA, IDFV, advertising ID and IP address) for the purposes of developing and delivering our services, displaying advertisements, conducting analysis and research and for measuring our and our Partners' advertising campaign performance. We also reserve the right to disclose your information (including personally identifiable information) when we are legally required to do so, to disclose your information in an anonymous and aggregated manner, meaning you could not be personally identified from it.

We may share such information to:

Our affiliate, Outfit7 Limited, who provides several services for us, such as tracking and fraud prevention, analytics, advertising, and is partnered with third party service providers for provisions of such services. For third party service providers of Outfit7 Limited, please check this link: https://outfit7.com/privacy-brazil/en/#how-we-share-your-information

We may contract with additional Partners or change existing Partners in the future to perform any services in connection with the Apps. These changes shall be updated twice a year or promptly in case of material changes in our data processing practices.

We reserve the right to disclose your information (including personally identifiable information) in response to law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations, users or user experience. Additionally, in the event of a reorganization, merger or sale we may transfer any and all information (including personally identifiable information) we collect to the relevant third party.

For any additional questions about third party information collection please refer to [email protected].

ADVERTISING

We offer our Apps for free or at low cost and in order to do that we need to share information we collect from you with our third party advertising partners that assist us in delivering advertisements to you. When you use our Apps we rely on our legitimate interest to show contextual advertisements to you. Before sharing any information with our advertising partners for the purposes of interest-based advertising, we will always ask for your consent.

When you use our Apps we show contextual advertisements to you. In order to enable advertising, we allow our advertising partners to collect advertising identifiers (such as advertising ID on Android and IDFA on iOS) that are considered as personal information under Brazil data protection legislations, but they should use it solely for the purposes of contextual advertising. For any other purposes they should use the information solely on an anonymized and aggregated basis, this means in a way that cannot be tracked back to your device.

If you have consented to sharing of your personal information for the purposes of interest-based advertising, the advertisements you see are more relevant to you and are based on your app and device usage, online behavior and interests (this is commonly referred to as online behavioral or interest-based advertising). Learn more about sharing of your personal information for the purposes of interest-based advertising in the "Interest-based Advertising" Section of this Privacy Policy.

Your privacy is important to us, so we follow not only applicable legislation, but also accepted market practices, such as respecting your privacy preferences on your device. You can choose to opt out of interest-based advertising via "Limit Ad Tracking" on your iOS device or "Opt Out of Interest-Based Ads" on your Android device and all advertising providers are bound to comply with such a setting, but we cannot provide any guarantees on their behalf. If you choose to withdraw your consent available via our Apps, we will not share your advertising ID with advertisers for the purposes of interest-based advertising.

You can find the setting for your mobile device by following the directions below or contact your device provider.

IOS DEVICE

iOS 7 or Higher

Go to your Settings \> Select Privacy \> Select Advertising \> Enable the "Limit Ad Tracking" setting

iOS 6

Go to your Settings \> Select General \> Select About \> Select Advertising \> Enable the "Limit Ads Tracking" setting

_More information about the iOS setting can be found here: _https://support.apple.com/en-us/HT202074

ANDROID DEVICE

For Android devices with OS 2.2 and up and Google Play Services version 4.0 and up:

Open your Settings app \> Google \> Ads \> Enable "Opt Out of Interest-Based Advertising"

Some of our Apps enable you to connect to third party social networks, to share the content you created within the Apps on such third party social networks or to participate in leader boards or multiplayer apps. If you connect to a third party social network, such as Google Play Games Service or Apple Game Center, you will be able to use your account to log in on multiple devices and to synchronize progress across those devices. If you connect to a third party social network, such as Facebook, you may be able to interact, compete and connect with your friends (please see more in "Special Privacy Features In Some Of Our Apps"). Some of our Apps enable you also to share the content you created within the App on third party social network, such as Facebook, YouTube, Twitter or Vkontakte. When you log in to your social network account or by using the App to share content on social network, we will receive some of the information you have on such social network account (please see more below).

Some of our Apps use third parties' services such as Google Play Games Service, Apple Game Center, Facebook, YouTube, Twitter or Vkontakte ("Third Party Social Network/s"). Such Apps enable you to log in to your Third Party Social Network account to connect to our App by using the "Log in with" or "Connect to" feature in our App. You may also share the content you created within the App on Third Party Social Networks. Please note, Third Party Social Networks are governed by their own privacy policies, terms and end user agreements and we are not responsible for, and have no control over, the sharing practices or policies of the third parties that operate those sites. For additional questions you can contact us at [email protected].

The information you allow us to access varies by App, and it is affected by the privacy settings you and your friends establish on those Third Party Social Networks. You can control and find out more about these settings at the Third Party Social Network in question. When you use the "Log in with" or "Connect to" feature we may access and store some or all of the following information, as allowed by you, Third Party Social Networks and your preferences: (i) your basic information from your public profile, such as your name, surname, profile picture, age range, gender, and other public information; (ii) email address, login ID and/or player identifier string (iii) list of your friends; (iv) any other information which is detailed and displayed to you in the notice which appears during the "Log in with" or "Connect to" process. We may share your name, profile picture and your game data (such as moves, App progress and scores) with respect to the applicable App, with your friends who have also used the "Log in with" or "Connect to" feature in connection with such App or with your contacts in applicable Third Party Social Media Network account.

The App may further ask you to allow us to post on such Third Party Social Networks on your behalf (e.g. photos, e-cards, videos and status updates). Please keep in mind that we will only do that if specifically allowed by you and we will store ID and your full name for the purposes of user identification. Other information will be merely stored within the App on your device so that the App will be able to communicate with Third Party Social Network directly; Voice recordings from Apps are also only being collected and stored within the Apps solely upon your request.

If you use Third Party Social Networks to participate in game related activities, such as in leader boards and multi-player games, you share your information with other players and Third Party Social Networks (for example scores, rankings and achievements).

THIRD PARTY TERMS AND CONDITIONS

Our Apps may contain links to third party websites, products, or services. For example, the Apps may feature offers from third party advertisers or the ability to engage in transactions with such entities. Please note that while using such third party offerings, you are using sites, products, and services developed and administered by people or companies not affiliated with or controlled by us. We cannot control the actions of those people or companies, the content of their sites, products or services, the use of information you provide to them, or any products or services they may offer. Our link to such third parties does not constitute our sponsorship of, or affiliation with, those people or companies. Nor is such linking an endorsement of such third party's privacy or information security policies or practices or their compliance with laws. Information collected by third parties, which may include such things as location information or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of third parties with which you interact.

CHILDREN'S PRIVACY

We do not knowingly collect personal information from children under the age of digital consent according to Brazil data protection legislation. If we learn that we have collected personal information of a child under the age of digital consent according to Brazil data protection legislation, we will take all reasonable steps to delete the information as soon as possible. If you become aware that your child has provided us with personal information without your consent, please contact us at [email protected].

YOUR RIGHTS

You have certain rights in connection with your personal information and how we handle it, including but not limited to a right to obtain information about whether we hold and process personal information about you, to access personal information we hold about you, to obtain the correction, update, amendment or deletion of your personal information, to portability, and to turn to supervisory authority. Some of these rights may be subject to some exceptions or limitations. You can exercise these rights at any time by sending your requests regarding your personal information to [email protected].

GENERAL

Your privacy and security of your information is important to us, and we always pay special attention to ensure that we process your information lawfully in accordance with one of the legal bases set out under Brazil data protection laws that apply to Brazil users. You can always determine your country of residence in the app settings by clicking a "Country" button and selecting your country. We store your information for as long as needed to provide you with our services. We may store information longer, but only in a way that it cannot be tracked back to you. We operate globally and we share your information with our Partners as for the purposes described above in "How We Share Your Information" Section, which may include a transfer of your personal information outside of Brazil. Please check https://outfit7neo.com/privacy regularly for changes to our Privacy Policy.

LEGAL BASES

In each case where we process your information, we do so lawfully in accordance with one of the legal bases set out under Brazil data protection law.

The legal bases that we rely upon are the following:

Contractual Necessity. This covers information that is processed by us in order to provide you with service that you have requested - and that we have agreed - to provide to you, that is to deliver and improve our services, to provide customer support, to deliver special features in our Apps (such as in-app chat feature, multiplayer feature, leaderboards and other third party social network features), to deliver content of the in-app purchase you make.
Legitimate Interests. This covers information that is processed by us for the purposes that can be reasonably expected within the context of your use of our services to pursue our legitimate interests in order to ensure you have the best experience when playing our apps, to make sure your information is secure and to provide to you our Apps free of charge or at a low cost. We pay special attention to your data protection rights making sure that your data protection rights are not overridden by our legitimate interests. We rely on our legitimate interests for data processing for analytics, attribution and fraud prevention, push-notifications, cross-promotion, and contextual advertising purposes.
Consent. Where we ask for your consent to use your data for a particular purpose, we will make this clear at the point of collection and we will also make clear how you can withdraw your consent. We will ask for your consent before sharing any information with our advertising partners for the purposes of interest-based advertising and before conducting any surveys.
Legal or Regulatory Obligation. This covers information that is processed by us to comply with a legal or regulatory obligation, for instance is to maintain records for tax purposes.

SECURITY

We have implemented appropriate technical and organizational measures to protect the confidentiality, security and integrity of the collected information, and to prevent unauthorized access and the use of information contrary to this Privacy Policy. Although we use commercially reasonable efforts to assure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.

INTERNATIONAL TRANSFER

We operate globally, so we need to transfer your personal information to our affiliated entities and/or to other third party service providers across border and from your country to other countries around the world. Please note that not all of these countries have the same data protection laws as your own country, but we will always take appropriate steps to safeguard the privacy of your personal information.

RETENTION

We store your information for as long as needed to provide you with our services. We may store information longer, but only in a way that it cannot be tracked back to you. We delete the information as soon as we do not need it for the purposes as described in this Privacy Policy and in any event no later than five (5) years after your interaction with all of our Apps has ceased.

When required by law, we will retain your information for as long as we are legally obligated to do so. If you request us to delete your data, we will delete your data as described above in "Your Rights" Section.

CHANGES TO OUR PRIVACY POLICY

We will occasionally update this Privacy Policy as necessary to protect our users, furnish current information, and respond to legal and technical changes. The most current version of the Privacy Policy will govern our use of your information and will be available at https://outfit7neo.com/privacy.

For previous versions of this Privacy Policy please contact us via [email protected].

CONTACT US

If you have questions or concerns about Outfit7 Neo's Privacy Policy, please contact us through one of the following ways:

For privacy questions and exercising your rights via our privacy email: [email protected];
Our data protection officer: [email protected];
For general information please feel free to contact us via our customer service page: https://outfit7neo.com/contact.

For information collected under this Privacy Policy, the data controller is Outfit7 Neo, a company with a registered and business address at Christaki Kranou 20, 1st Floor, 4041 Limassol, Cyprus.

OUTFIT7 NEO BRAZIL PRIVACY POLICY FOR APPS, v 1.0, updated October 19, 2023