PRIVACY POLICY

LAST UPDATED: April, 22nd, 2021

1. WHO WE ARE

1.1. We are TERRAFORM GAMES LIMITED, a legal entity located at Arch. Makariou III, 155, PROTEAS HOUSE, 5th floor, 3026 Limassol, Cyprus.

1.2. This Privacy Policy sets out how we collect and use your personal information when you use the Platform (hereinafter – the "Platform") offered by us and our subsidiaries, including website https://gameram.com and https://www.terraform.games (hereinafter – the "Site") and other Platform, and the choices available to you in connection with our use of your personal information.

1.3. This Privacy Policy should be read alongside, and in addition to our Terms of Use (hereinafter – the "Terms"), accessible online at https://terraform.games/tou. In case of any contradictions between this Privacy Policy and the Terms, this Privacy Policy will prevail. Any terms used with the capital letter which are not defined in the present Privacy Policy shall have meaning set forth in the Terms.

2. THIS PRIVACY POLICY

2.1. By making available the Platform we, acting reasonably and in good faith, believe that you:

(a) have all necessary rights to register on and use the Platform;

(b) provide true information about yourself to the extent necessary for use of the Platform;

(c) understand that by the posting your personal information, if there is such technical possibility in the Platform and where it is accessible by other users of the Platform, you have manifestly made this information public, and this information may become available to other Platform users and internet users, be copied and disseminated by them;

(d) are aware of and accept this Privacy Policy.

2.2. We do not check the user information received from you, except where such check is necessary in order for us to fulfill our obligations to you.

3. INFORMATION WE COLLECT ABOUT YOU

3.1. In order to implement the agreement between you and us, and provide you with access to the use of the Platform, we will improve, develop and implement new features to our Platform, and enhance the available Platform functionality. To achieve these objectives, and in compliance with applicable laws, we will collect, store, aggregate, organize, extract, compare, use, and supplement your data (hereinafter "processing"). We will also receive and pass this data, and our automatically processed analyses of this data to our affiliates and partners as set out in the table below and Section 4 of this Privacy Policy.

3.2. We set out in more detail the information we collect when you use our Platform, why we collect and process it and the legal bases below.

Information Collected Purpose Legal Basis 1 Data you provide for registering in the Platform such ase-mail, phone number We use this information in order to manage and administer the Platform provided to you. We use this data to enable us to fulfill our obligations to you as part of the Platform (e.g. in cases where you request restoration of your login). Legitimate interests Performance of our contract with you Consent 2 Additional data you provide when you edit your Account (inter alia any settings) including, if applicable, your first and last name, nickname, gender, date of birth, avatar picture and language preferences. We use this information in order to provide our Platform to you, to manage and administer Platform. Legitimate interests Performance of our contract with you Consent 3 Additional data received when you access the Platform, including information regarding technical devices, technical interaction with the Platform, such as your IP-address, time of registration in the Platform, device ids, IDFA, ADFV, country and language settings, device model and operating system used, your installed apps, type of a browser, your Internet provider and/or phone network operator, network type, screen resolution, RAM size. We use your data for internal review in order to constantly improve the content of our Platform and web pages, optimizing your user experience, to understand any errors you may encounter when using the Platform, to notify you of changes to the Platform and to personalize the use of our Platform. We may also use this data in order to tailor and improve the adverts that are presented to you to and measure the effectiveness of these advertisements. Legitimate Interests Performance of our contract with you 4 Information that is automatically received at the time of access to the Site with the use of cookies. Please see our cookies policy which sets out the types of cookies we use and what we use these cookies for. Information that is automatically received at the time of access to the Site with the use of cookies. 5 Information that is created by you while using the Platform (including information that you post in any Platform forums and/or chat rooms). Depending on the place of posting (chat room or forum) this information can be available to some or all other users of our Platform. We use this information in order to manage and administer the Platform, including providing our Platform to you. Legitimate interests, which inter alia, include the processing of manifestly made public by you data Performance of our contract with you 6 Information that is created by you while placing requests to our Platform support. We use this information in order to verify your identity and to fulfill your support request. We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service. Legitimate interests Performance of our contract with you 7 Information that is received as the result of your behavioral actions when using the Platform (including your Platform actions and achievements, badges). This information can be available to other users of our Platform. We use this information in order to manage and administer the Platform including providing our Platform to you. We may also use this data in order to tailor and improve the adverts that are presented to you to and measure the effectiveness of these advertisements. Legitimate interests, which, inter alia, include the processing of data manifestly made public by you, where it is accessible by other users of the Platform Performance of our contract with you 8 Information that is received about you as the result of other users' actions on the Platform (in particular, information posted in chat rooms and forums by other users). We use this information in order to manage and administer the Platform including providing our Platform to you. Legitimate interests 3.3. Our legitimate interests include (1) maintaining and administrating the Platform; (2) providing the Platform to you; (3) improving the content of the Platform and web pages; (4) processing of the data that was manifestly made public by you where it is accessible by other users of the Platform; (5) ensuring your account is adequately protected; and (6) compliance with any contractual, legal or regulatory obligations under any applicable law.

3.4. As part of maintaining and administrating the Platform we use the information to analyze user activity and ensure that rules and terms of use of the Platform are not violated.

3.5. Your personal information may also be processed if it is required by a law enforcement or regulatory authority, body or agency or in the defense or exercise of legal claims.We will not delete personal information if it is relevant to an investigation or a dispute.It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable/relevant law.

We will not delete personal information if it is relevant to an investigation or a dispute.

It will continue to be stored until those issues are fully resolved and/or during the term that is required and/or permissible under applicable/relevant law.

3.6. Please note, if you do not want us to process sensitive and special categories of data about you (including data relating to your health, racial or ethnic origin, political opinion, religious or philosophical beliefs, sex life, and your sexual orientation) you should take care not to post this information or share this data on the Platform.

Once you have provided this data it will be accessible by other Platform users and it becomes difficult for us to remove this data.

3.7. Please note, if you withdraw your consent to processing or you do not provide the data that we require in order to maintain and administer the Platform, you may not be able to access the Platform or register with the web pages.

3.8. If we intend to further process your data for any other purpose besides those set out in this Privacy Policy, we shall provide you with details of these purposes before we commence data processing.

3.9 We will use and store your personal information for the purpose of delivering our products and services and to analyze and enhance our operations. We will create statistical, agregated data relating to our users and the Platform for analytical purposes. Aggregated data includes data delivered from personal information and does not identify any individual. Subject to applicable laws and regulations, we use such aggregate information to understand our customers and to develop, improve and/or market our Platform. We may provide such aggregate information to third parties to tailor content and ads, provide social media features (e.g., features that allow you to share content directly to your preferred social media platform), track your preferences, analyze traffic, and provide similar services and content.

4. DATA SHARING

4.1. Publicly available data. Your username and other information that you provide or post while using the Platform can be available to all users of the Platform. We take technical and organizational measures to ensure that your data is safe. Please note, that by posting your personal information in publicly accessible areas (resources accessible by other users of the Platform), you have manifestly made this information public, and it may become available to other users of the Platform and Internet users and be copied and/ or disseminated by such users. Please keep in mind that once other users have gained access to or copied your data, neither you nor we are able to delete or remove such data from possession of those other users.

4.2. Sharing with third parties. We may share your personal information with third parties only in the ways that are described in this Privacy Policy. Sometimes we may need to provide your data to our affiliated entities, as well as our partners, in order to provide the Platform to you, to administer the Platform, for example, if you choose to share your data across other social media platforms, or to personalize, adjust and improve our Platform or in other cases described in this Privacy Policy and only subject to the purposes described in this Privacy Policy. We do not sell your personal information to third parties.

4.3. The transmissions of personal data with the recipients (whatever their legal status, subcontractor, processing manager or just recipient) are carried out in a secure manner and in application of an agreement between us and each recipient as may be necessary under applicable law. We undertake to ensure that each recipient knows the directive principles of personal data protection and submit to them in application of the law and/or of a particular contract.

4.4. Confidentiality obligations. In case we share your data with selected third parties, including our third party contractors and application developers, we always ensure that these third parties undertake confidentiality obligations regarding your personal data collected while you use the services or applications they offer. The developers use the information provided to them in order to provide you with additional Platform, including technical support, if applicable. We will not share your personal data outside the scope of purposes specified in this Privacy Policy without your prior consent.

4.5. Advertising disclaimer. Our ad management and recommendation system is designed so that your information will not be shared directly with our third party advertisers. An advertiser or maker of a recommendation can only choose to target advertisements to groups of users falling within criteria such as age, gender, location (country, city), or other, or to target communities according to their types. If you fall within one of the target groups, you will receive an advertisement or recommendation of such third party partners or our affiliates. However, such third party advertisers or our affiliates may gather some of your information in case you interact in any way with the ads provided by such advertisers.

4.6. Integrated advertising and infrastructure solutions. Our Platform may contain software components operated by our selected advertising partners, which may collect and share some of your information with such partners in course of normal use of the Platform or, for example, after you interact with their advertisements provided within the Platform. In such a case the processing of your information will be governed by privacy terms of such partners. In case you use our Platformyou agree that some of your personal data, including personally identifiable information, pseudonymous identifiers and other personal data, may be collected and processed by such Partners on the terms accessible at their privacy policies.

Partner Legal Adjust Company: Adjust GmbH Address: 121 Menachem Begin Road, Azrieli Sarona Tower, Tel Aviv, Israel 6701318. Please refer to the Privacy Policy at https://www.adjust.com/terms/privacy-policy/ for the information about the collection and processing of such data and privacy practices of Adjust. Firebase Company: Google Ireland Limited Address: Gordon House, Barrow Street, Dublin 4, Ireland Please refer to https://policies.google.com/technologies/partner-sites and to Google's Privacy Policy at https://policies.google.com/privacy for the information about the collection and processing of such data and privacy practices of Google.

4.7. Retargeting disclaimer. An advertiser or maker of recommendations may also choose to upload a list of identifiers (e.g., e-mails, phone numbers) and identities to our systems so that we (but not the adviser or maker of recommendations) can check for user matches. They will see the number of matches but not the matches themselves.

4.8. Sharing in the general conduct of business. We may also share your data with our affiliates and keep some of your personal information in our business records for the accounting and compliance purposes. As such, we may also disclose your personal information to a third party if we decide to transfer a business to that third party, so you can continue to receive service and information in connection with that business with as little disruption as possible. Similarly, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, your personal information may be transferred to our successor or assignee.

4.9. Disclosure to tax authorities. We reserve the right to disclose your personal information to tax authorities in case it is necessary because of your participation in public tournaments or promotional activities.

4.10. Disclosure required by law. We reserve the right to disclose your personal information as required by law, by court order or in special cases when we have reason to believe that disclosing such information is necessary to identify, contact, or bring legal action if you or third parties are violating the Terms, any other terms of services provided by us or our affiliates or any applicable law, for the purpose of defense of our rights and interests. We also reserve the right to disclose your personal information if we have a good faith belief that it is necessary to prevent fraud or other illegal activities.

5. PRIVACY SETTINGS

5.1. The Platform may contain links to sites operated by third parties. We are not responsible for your data privacy when you access these links or engage with third party services and you should ensure you review the relevant third party's privacy statement which will govern your data privacy rights.

5.2. In case you intend to connect your Google account to the Platform using Google API, you may review and, if necessary, adjust your Google privacy settings before linking or connecting them to our website or Service. You can find more information on Google's privacy at https://policies.google.com/.

5.3. We bear no liability for the actions of third parties which, as the result of your use of the internet or the Platform, obtain access to your information in accordance with the confidentiality level selected by you.

5.4. We bear no liability for the consequences of use of the information which, due to the Platform nature, is available to any internet user. We ask you to take a responsible approach to the scope of their information posted on the Site or in the Platform.

6. INTERNATIONAL TRANSFERS

6.1. We may transfer and maintain on our servers or databases some of your personal information outside the European Economic Area (EEA) including in United States of America.

6.2. The countries to which we transfer your data may not have the same data protection laws as your jurisdiction. We take reasonable cyber security measures and/or put in place the Standard Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure your data is adequately protected.

7. RETENTION PERIODS

7.1. We will retain your personal information for as long as required to perform the purposes for which the data was collected depending on the legal basis for which that data was obtained and/or whether additional legal/regulatory obligations mandate that we retain your personal information during the term that is required and/or permissible under applicable/relevant law.

7.2. You may delete your personal data by removing the data from your Account; alternatively, you can delete your Account.

7.3. You may request to remove your account and data on our Platform by contacting the Platform support (see Section 11 for details).

7.4. We may remove your Account, or the information you post as provided by the Terms.

8. YOUR RIGHTS

8.1. You have the following rights, in certain circumstances, in relation to your personal information:

(a) Right to access your personal information;

(b) Right to rectify your personal information: you can request that we update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or no longer relevant for the purpose of processing;

(c) Right to restrict the use of your personal information;

(d) Right to request that your personal information is erased if:

- it is no longer required in relation to the purposes for which it was gathered or processed in another way;

- you withdraw your consent concerning processing subject to consent;

- you are justifiably opposed to the processing;

- it has been subject to illicit processing; or

- it is imposed by law.

(e) Right to object to processing of your personal information;

(f) Right to data portability (in certain specific circumstances);

(g) Right not to be subject to an automated decision;

(h) Right to lodge a complaint with a supervisory authority;

(i) For processing based upon your consent, the right withdraw that consent at any time;

(j) You may have other rights under your legislation of your country of residence, including right to define the instructions relative to the outcome of your personal data after your death.

8.2. You also have a right to independently remove personal information on your account and make changes and corrections to your information, provided that such changes and corrections contain up-to-date and true information. You can also view an overview of the information we hold about you. If you reside in France you have the right to register on the list of opposition to telephone canvassing on www.bloctel.fr.

8.3. If you would like to exercise these rights, please contact support at [email protected] or send your request to us, in writing to Arch. Makariou III, 155, PROTEAS HOUSE, 5th floor, 3026 Limassol, Cyprus (TERRAFORM GAMES LIMITED). We will aim to respond to you within 30 days from the date of receipt of your request. We will need to verify your identity before we are able to disclose any personal data to you.

8.4. In case you provided the Platform with the access to your Google account (for example if you registered on the Platform using Google account) you can revoke that the access of the Platform to your Google account via the Google security settings page at https://security.google.com/settings/security/permissions.

9. YOUR CALIFORNIA PRIVACY RIGHTS

9.1. This notice to California residents is provided under California law, including the California Consumer Privacy Act ("CCPA"), Cal. Civ. Code 1798.100, et seq. This notice supplements our Privacy Policy by explaining your California privacy rights if you are a California resident, and provides certain mandated disclosures about our treatment of California residents' information, both online and offline.

9.2. If you are a California resident you have the following rights in relation to your personal information:

(a) Right to Access. If you are a California resident, you have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, and sell. (b) Right to Delete. If you are a California resident, you have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions. (c) Process to Make a CCPA Request. To make an access or deletion request, please contact [email protected]. Before completing your request, we may need to verify your identity or the identity of your authorized representative. We will then take action to verify your email address and may request additional documentation or information solely for the purpose of verifying your identity. (d) Right to Opt Out of Sale of Personal Information. If you are a California resident, you have the right to "opt out" of the "sale" of your "personal information" to "third parties" (as those terms are defined in the CCPA). You can exercise this right by clicking here or emailing [email protected]. Our Privacy Policy describes the limited circumstances in which we may share your information with third parties. Our Privacy Policy also provides you with certain controls and choices regarding our collection, use, and sharing of your information. (e) Right to Non-Discrimination: You have the right not to receive discriminatory treatment for the exercise of your privacy rights conferred by the CCPA. (f) Shine the Light Act. If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your personal information by us and our affiliates to third parties for the third parties' direct marketing purposes. We are dedicated to treating your personal information with care and respect. For inquiries regarding our disclosure policy, you may send an email to [CCPA-email], send your enquiries to Platform support at [email protected] or send your request to us in writing to Arch. Makariou III, 155, PROTEAS HOUSE, 5th floor, 3026 Limassol, Cyprus (TERRAFORM GAMES LIMITED). (g) Authorized Agents. If you would like to designate an authorized agent to make a request on your behalf, please be sure the agent can (i) demonstrate you have provided written permission for the agent to submit the request on your behalf, and (ii) provide proof of his or her own identity. If the agent does not satisfy these requirements, we will deny the request. (h) Privacy Rights for California Minors. If you are a California resident under the age of 18, California Business and Professions Code Section 22581 permits you to view, correct and request the removal of content or information you have posted to the Site, message boards, or forums. You may exercise this right you may send an email to [CCPA-email], send your enquiries to Platform support at [email protected] or send your request to us in writing to Arch. Makariou III, 155, PROTEAS HOUSE, 5th floor, 3026 Limassol, Cyprus (TERRAFORM GAMES LIMITED). Note that any information posted to the message boards or forums is publicly viewable. We strongly recommend that all users avoid posting personal or sensitive information. Residual copies of content and/or information that have been deleted may remain on our backup servers. We do not have to remove posted content or information if it has been rendered anonymous. We may retain your information to resolve disputes, enforce our user agreements, or comply with legal requirements; in this case, your personal information will be blocked from use for any other purpose. Additionally, we do not have control over third parties (e.g., other users) who may have copied or reposted the content or information. 9.3. Mandatory Disclosures. In addition to the information provided elsewhere in our Privacy Policy, we make the following disclosures for purposes of compliance with the CCPA:

· We collected the following categories of personal information in the last 12 months: IP addresses, Identifiers/Contact Information, demographic information (like gender and age), commercial information (such as information about services you have accessed), Internet or other electronic network activity information, electronic information, and inferences drawn from the above.

· The sources of personal information that we collected are: our users, directly, third party sites or platforms that you link with your registration account, analytics tools, social networks, advertising networks, and trusted sources who update or supplement information we hold about you.

· The business or commercial purposes of collecting personal information are described in the "INFORMATION WE COLLECT ABOUT YOU" Section of this Privacy Policy.

· We disclosed the following categories of personal information for a business purpose in the last 12 months: IP addresses, Identifiers/Contact Information, , commercial information (such as information about services you have accessed), Internet or other electronic network activity information, , and inferences drawn from the above. We disclose these categories outside only as described in the "DATA SHARING" Section of this Privacy Policy.

· Although we do not sell personal information for monetary consideration, some of our partners may collect and process information when you interact with our Platform, including IP addresses, digital identifiers, information about your web browsing, and how you interact with our advertising properties and ads in order to provide you with relevant ads across the Internet and for other analytics purposes, and such partners may "sell" that information to other businesses for advertising and other purposes under the definition of "sale" in the CCPA.

· As the term is defined by the CCPA, we "sold" the following categories of personal information in the last 12 months: IP addresses, Identifiers/Contact Information, Internet or other electronic network activity information, including information about your web browsing, and inferences drawn from the above. We "sold" each category to advertising networks, data analytics providers and our infrastructure service providers.

· The business or commercial purposes of "selling" personal information is for third party companies to perform services on our behalf, like marketing, advertising, performance and audience measurement.

· We do not "sell" personal information of known minors under 16 years of age.

9.4. Online Tracking/Do Not Track. We and our third party service providers may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites. California Business and Professions Code Section 22575(b) (as amended effective January 1, 2014) permits our users who are California residents to be informed as to how we respond to Web browser "Do Not Track" settings. As Do Not Track is a standard that is currently being developed, we do not take actions to respond to Do Not Track settings, and instead we adhere to the standards set out in this Privacy Policy.

10. SECURITY MEASURES

10.1. We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data are protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination.

10.2. Access to the Platform is authorized using your login (e-mail address or mobile phone number) and password. You are responsible for keeping this information confidential. You should not share your credentials with third parties and we recommend you take measures to ensure this information is kept confidential.

10.3. If you forget your login details, you can request us to send you an email, which will contain a restoration code.

10.4. To reduce the probability of third parties gaining unauthorized access, if you login to your account from an unusual place or after several failed attempts to provide valid login details, we may block entry to your Account. You will then need to contact Platform support and provide certain additional information to verify your credentials and gain access to your Account.

11. CHANGES TO THIS POLICY

From time to time, we may change and/or update this Privacy Policy. If this Privacy Policy changes in any way, we will post an updated version on this page. We will store the previous versions of this Privacy Policy in our documentation achieve. We recommend you regularly review this page to ensure that you are always aware of our information practices and any changes to such.

12. CONTACT US

12.1. If you have any questions, please send your inquiries to Service support at [email protected] or in writing to Arch. Makariou III, 155, PROTEAS HOUSE, 5th floor, 3026 Limassol, Cyprus (TERRAFORM GAMES LIMITED). So we can deal with your enquiry effectively, please quote this Privacy Policy. We will aim to respond to you within 30 days from receipt of request.

12.2. All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.