Privacy Policy

1. INTRODUCTION

1.1 Welcome to the Azrach Games Services operated by AzrachIT Pvt. Ltd. and its

affiliates and related corporations (collectively referred to as "Azrach Games," "we,"

"us," or "our"). This Privacy Policy governs the collection, use, maintenance, and

disclosure of information obtained from users of the game. This policy applies to the

Game and all related services provided by Azrach Games. Users refer to individuals

who register for an account or access the Services ("users," "you," or "your"). We

understand the significance of the personal data you entrust to us and believe it is our

responsibility to properly manage, protect, and process your personal data. This

and process the personal data you provide to us, whether now or in the future, and to

assist you in making an informed decision before sharing any of your personal data.

Terms capitalized in this Privacy Policy that are not defined otherwise have the

meanings ascribed to them in the Azrach Games Terms of Service.

1.2 "Personal Data" refers to data, whether accurate or not, that pertains to an

identifiable individual, either from that data alone or in combination with other

information accessible to or possessed by an organization. Examples of personal data

include names, identification numbers, and contact information.

1.3 By using the Services, registering for an account, or visiting our Site, you

acknowledge and agree to accept the practices, requirements, and policies outlined in

this Privacy Policy. Furthermore, you consent to our collection, use, disclosure, and

processing of your personal data as described herein. IF YOU DO NOT CONSENT

TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS

GAMES OR SITE. If we modify our Privacy Policy, we will notify you by posting

the changes or the revised Privacy Policy on the Site. We reserve the right to amend

this Privacy Policy at any time. To the maximum extent permitted by applicable law,

your continued use of the Services or Site, including making purchases or placing

orders, constitutes your acknowledgment and acceptance of the changes made to this

1.4 This Policy is to be read in conjunction with other notices, contractual clauses,

and consent clauses that apply to the collection, storage, use, disclosure, and

processing of your personal data by us. It is not intended to override those notices or

clauses unless expressly stated otherwise.

2. WHEN WILL AZRACH GAMES COLLECT PERSONAL DATA?

2.1 We will/may collect personal data about you:

• when you register and/or use our Services, Games or Site, or open an account with

us;

• when you submit any form, including, but not limited to, application forms or other

forms relating to any of our products and services, whether online or by way of a

physical form;

• when you enter into any agreement or provide other documentation or information

in respect of your interactions with us, or when you use our products and services;

• when you interact with us, such as via telephone calls (which may be recorded),

letters, fax, face-to-face meetings, social media platforms and emails, including when

you interact with our customer service agents;

• when you use our electronic services, or interact with us via our Games or Site or

use our Services. This includes, without limitation, through cookies which we may

deploy when you interact with our Games or Site;

• when you grant permissions on your device to share information with our mobile

application or Site;

• when you link your Azrach Games account with your Social Media Account

(defined below) or other external account or use other social media features, in

accordance with the provider’s policies;

• when you carry out transactions through our Games or Site (where applicable) or

with our authorized third-party payment service providers;

• when you provide us with feedback or complaints;

• when you register for a contest, for games or game specific events;

• during your gameplay; and

• when you submit your personal data to us for any reason.

The above does not purport to be exhaustive and sets out some common instances of

when personal data about you may be collected.

3. WHAT PERSONAL DATA WILL AZRACH GAMES COLLECT?

3.1 The personal data that Azrach Games may collect includes but is not limited to:

• name, username and user ID;

• contact information (including email address, telephone number, and/or address);

• transaction information, including bank account and payment information where

applicable and subject to applicable law;

• chat and other information about the people and accounts you interact with;

• gender, age, and/or date of birth;

• information sent by or associated with the device(s) used to access our Services;

• photographs or audio or video content that you submit via the Services;

• location related information, including IP address;

• government issued identification or other identification you share with us, where

applicable;

• marketing and communications data, such as your preferences in receiving

marketing materials, your communication preferences and history of communications

with us and our service providers;

• survey responses. competition, contest or tournament related information, and/or

other information you provide to us;

• any other information about you provided when you sign up or use the Services,

including information shared via any linked social media account (“Social Media

Account”); and

• usage and transaction data, including data on your activities, orders, use of the

Services and the advertising and other content you engage with.

3.2 You agree not to submit any information to us which is inaccurate or misleading,

and you agree to inform us of any inaccuracies or changes to such information.

Subject to applicable law, we reserve the right at our sole discretion to require further

documentation to verify the information provided by you.

3.3 If you sign up to be a user of our Services using your Social Media Account, link

your account to your Social Media Account or use any Azrach Games social media

features, we may access information about you which you have voluntarily provided

to your Social Media Account provider in accordance with such provider's policies,

and we will manage and use such personal data in accordance with this Privacy Policy

at all times.

3.4 If you do not want us to collect the aforementioned information/personal data, you

may opt out at any time by notifying our Data Protection Officer in writing. Further

information on opting out can be found in the section below entitled "How can you

withdraw consent, remove, request access to or modify information you have

provided to us?". Note, however, that opting out or withdrawing your consent for us

to collect, use or process your personal data may affect your use of the Services.

4. COLLECTION OF OTHER DATA

4.1 As with most websites and mobile applications, your device sends information

which may include data about you that gets logged by a web server when you use our

Services. This typically includes without limitation your device’s Internet Protocol

(IP) address, computer/mobile device operating system and browser type, type of

mobile device, the characteristics of the mobile device, the unique device identifier

(UDID) or mobile equipment identifier (MEID) for your mobile device, the address of

a referring web site (if any), the pages you visit on our website and mobile

applications and the times of visit, and sometimes a "cookie" (which can be disabled

using your browser preferences) to help the site remember your last visit. If you are

logged in, this information is associated with your personal account. The information

is also included in anonymous statistics to allow us to understand how visitors use our

Games and Site.

4.2 Our mobile applications may collect precise information about the location of

your mobile device using technologies such as GPS, Wi-Fi, etc. We collect, use,

disclose and/or process this information for one or more purposes including, without

limitation, location-based services that you request or to deliver relevant content to

you based on your location or to allow you to share your location to other Users as

part of the services under our mobile applications. For most mobile devices, you are

able to withdraw your permission for us to acquire this information on your location

through your device settings. If you have questions about how to disable your mobile

device's location services, please contact your mobile device service provider or the

device manufacturer.

4.3 As when you view pages or content on our Site or mobile application, most of the

same information is sent to us (including, without limitation, IP Address, information

about your operating system, etc.); but, instead of page views, your device sends us

information on the content, advertisement viewed and/or software installed and time.

5. COOKIES

5.1 We or our authorized service providers and advertising partners may from time to

time implement "cookies" or other features to allow us or third parties to collect or

share information in connection with your use of the Services. These features help us

improve our Site, Games and the Services we offer, help us offer new services and

features, and/or enable us and our advertising partners serve more relevant content to

you, including through remarketing, subject to applicable law. “Cookies” are

identifiers we transfer to your computer or mobile device that record data about your

computer or device, how and when the Services or websites are used or visited, by

how many people and other activity within our Site and Games. We may link cookie

information to personal data. Cookies may also link to information regarding what

items you have selected for purchase, pages you have viewed, or games you have

played. Depending on the relevant Services, this information may be used to keep

track of your shopping cart, to deliver content specific to your interests, to enable us

or our third party advertising partners to serve advertisements through the Services or

on sites across the internet, and to monitor usage of the Services.

5.2 You may refuse the use of cookies or web beacons by selecting the appropriate

settings or adjusting your preferences on your browser or device. However, please

note that if you do this you may not be able to use the full functionality of our Site,

Games or the Services.

5.3 You may also be able to opt out of personalized advertisements on some mobile

applications by following the instructions for Android and iOS.

6. HOW DO WE USE THE INFORMATION YOU PROVIDE US?

6.1 We may collect, use, disclose and/or process your personal data for one or more of

the following purposes:

(a) to consider and/or process your application/transaction with us or your

transactions or communications with third parties via the Services;

(b) to manage, operate, provide and/or administer your use of and/or access to our

Services, Site and Games (including, without limitation, your preferences), as well as

your relationship and user account with us;

requests for certain products and services and notify you of service issues and unusual

account actions;

(d) to enforce our Terms of Service or any applicable end user license agreements;

(e) to protect personal safety and the rights, property or safety of others;

(f) for identification and/or verification;

(g) to maintain and administer and improve any software updates and/or other

updates, to support the Services, including to troubleshoot, report, or address any

issues (e.g., to respond to errors or crash reports) that may be required from time to

time to ensure the smooth running of the Games and/or our Services;

(h) to deal with or facilitate customer service, carry out your instructions, deal with or

respond to any enquiries given by (or purported to be given by) you or on your behalf;

(i) to contact you or communicate with you via voice call, text message and/or fax

message, email and/or postal mail or otherwise for the purposes of administering

and/or managing your relationship with us or your use of our Services, such as but not

limited to communicating administrative information to you relating to our Services.

You acknowledge and agree that such communication by us could be by way of the

mailing of correspondence, documents or notices to you, which could involve

disclosure of certain personal data about you to bring about delivery of the same as

well as on the external cover of envelopes/mail packages;

(j) to allow other users to interact, communicate, or connect with you, including to

inform you when another user has sent you a private message or posted a comment

for you via the Games or Site;

(k) to conduct research, analysis and development activities (including, but not

limited to, data analytics, surveys, product and service development and/or profiling),

to analyse how you use our Services, to improve our Services or products and/or to

enhance your customer experience;

(l) to allow for advertising and other audits and surveys (via offline and online

surveys, including on third parties platforms (e.g. Google Forms), among other things,

validate the size and composition of our target audience, and understand their

experience with Azrach Games’s Services;

(m) for marketing and advertising for any marketing activities where permissible

under applicable law, and in this regard, to recommend products and/or services

relevant to your interests, to send you by various mediums and modes (including

email or SMS) of communication marketing and promotional information and

materials relating to products and/or services (including, without limitation, products

and/or services of third parties whom Azrach Games may collaborate or tie up with)

that Azrach Games (and/or its affiliates or related corporations) may be selling,

marketing or promoting, whether such products or services exist now or are created in

the future. You can unsubscribe from receiving marketing information at any time by

using the unsubscribe function within the electronic marketing material. We may use

your contact information to send newsletters or marketing materials from us and from

our related companies;

(n) to respond to legal processes or to comply with or as required by any applicable

law, governmental or regulatory requirements of any relevant jurisdiction, including,

without limitation, meeting the requirements to make disclosure under the

requirements of any law binding on Azrach Games or on its related corporations or

affiliates;

(o) to produce statistics and research for internal and statutory reporting and/or

record-keeping requirements;

(p) to carry out due diligence or other screening activities (including, without

limitation, background checks) in accordance with legal or regulatory obligations or

our risk management procedures that may be required by law or that may have been

put in place by us;

(q) to audit our Services or Azrach Games's business;

(r) to prevent or investigate any actual or suspected violations of our Terms of

Service, fraud, unlawful activity, omission or misconduct, whether relating to your

use of our Services or any other matter arising from your relationship with us;

(s) to store, host, back up (whether for disaster recovery or otherwise) of your

personal data, whether within or outside of your jurisdiction;

(t) to deal with and/or facilitate a business asset transaction or a potential business

asset transaction, where such transaction involves Azrach Games as a participant or

involves only a related corporation or affiliate of Azrach Games as a participant or

involves Azrach Games and/or any one or more of Azrach Games's related

corporations or affiliates as participant(s), and there may be other third party

organisations who are participants in such transaction. A “business asset transaction”

refers to the purchase, sale, lease, merger, amalgamation or any other acquisition,

disposal, transfer of or financing of an organisation or a portion of an organisation or

of a portion of or all of any of the business, business activities, or assets of an

organisation; and/or

(u) to verify your qualification and/or to submit your application/request when you

give you rewards where applicable; and

(v) other purposes which are permissible under applicable law and which we notify

you of at the time of obtaining your consent.

(collectively, the “Purposes”).

6.2 You acknowledge, consent and agree that Azrach Games may access, preserve

and disclose your Account information and Content if required to do so by law or

pursuant to an order of a court or by any governmental or regulatory authority having

jurisdiction over Azrach Games or in a good faith belief that such access preservation

or disclosure is reasonably necessary to: (a) comply with legal process; (b) comply

with a request from any governmental or regulatory authority having jurisdiction over

Azrach Games, (c) enforce the Azrach Games Terms of Service or this Privacy

Policy; (d) respond to any threatened or actual claims asserted against Azrach Games

or other claim that any Content violates the rights of third parties; (e) respond to your

requests for customer service; or (f) protect the rights, property or personal safety of

Azrach Games, its users and/or the public.

6.3 As the purposes for which we will/may collect, use, disclose or process your

personal data depend on the circumstances at hand, such purpose may not appear

above. However, we will notify you of such other purpose at the time of obtaining

your consent, unless processing of the applicable data without your consent is

permitted by the Privacy Laws.

7. HOW DOES AZRACH GAMES PROTECT AND RETAIN CUSTOMER

INFORMATION?

7.1 We implement a variety of security measures and operational controls, and we

strive to ensure the security of your personal data on our systems. User personal data

is contained behind secured networks and is only accessible by a limited number of

employees who have special access rights to such systems. However, there can

inevitably be no guarantee of absolute security.

7.2 We will retain personal data in accordance with the Privacy Laws and/or other

applicable laws. That is, we will destroy or anonymize your personal data when we

have reasonably determined that (i) the purpose for which that personal data was

collected is no longer being served by the retention of such personal data; (ii)

retention is no longer necessary for any legal or business purposes; and (iii) no other

legitimate interest warrant further retention of such personal data. If you cease using

our Services, or your permission to use the Site, Games and/or the Services is

terminated or withdrawn, we may continue storing, using and/or disclosing your

personal data in accordance with this Privacy Policy and our obligations under the

Privacy Laws. Subject to applicable law, we may securely dispose of your personal

data without prior notice to you.

8. DOES AZRACH GAMES DISCLOSE THE INFORMATION IT COLLECTS

FROM ITS VISITORS TO OUTSIDE PARTIES?

8.1 In conducting our business, we will/may need to disclose your personal data to our

third party service providers, agents and/or our affiliates or related corporations,

and/or other third parties, whether sited in Singapore or outside of Singapore, for one

or more of the above-stated Purposes. Such third party service providers, agents

and/or affiliates or related corporations and/or other third parties would be processing

your personal data either on our behalf or otherwise, for one or more of the above-

stated Purposes. Such third parties include, without limitation:

• our subsidiaries, affiliates and related corporations;

• other users of our Services in connection with your use of the Services and for one

or more of the above-stated Purposes;

• contractors, agents, service providers and other third parties we use to support our

business. These include but are not limited to those which provide administrative or

other services to us such as mailing houses, our game development partners, payment

or financial services providers, advertising and marketing partners,

telecommunication companies, game development partners, information technology

companies, and data centres;

• governmental or regulatory authorities having jurisdiction over Azrach Games or as

otherwise permitted under Section 6.2;

• a buyer or other successor in the event of a merger, divestiture, restructuring,

reorganisation, dissolution or other sale or transfer of some or all of Azrach Games’s

assets, whether as a going concern or as part of bankruptcy, liquidation or similar

proceeding, or transition of any of our Services, in which personal data held by

Azrach Games about our users is among the assets transferred; or to a counterparty in

a business asset transaction that Azrach Games or any of its affiliates or related

corporations is involved in, including any entity which succeeds or to which we

transfer the operation of any of our Services; and

• third parties to whom disclosure by us is for one or more of the Purposes and such

third parties would in turn be collecting and processing your personal data for one or

more of the Purposes.

8.2 We may, among other things, disclose your gaming history and/or disclosing

records showing which games were viewed or accessed by which IP addresses. We

may also share statistical and demographic information about our users and their use

of the Services with advertising partners and third party suppliers of advertisements,

remarketing, and other programming subject to applicable law.

8.3 Additionally, you may elect to export your user activity feeds as RSS feeds which

may be subscribed to by other users, which may include information regarding your

game play, installation of games, connections with other users and other information

about your account activity which is published as a feed on the Site or Games.

8.4 For the avoidance of doubt, in the event that Privacy Laws or other applicable

laws permit an organisation such as us to collect, use or disclose your personal data

without your consent, such permission granted by the laws shall continue to apply.

8.5 Third parties may unlawfully intercept or access personal data transmitted to or

contained on the site, technologies may malfunction or not work as anticipated, or

someone might access, abuse or misuse information through no fault of ours. We will

nevertheless deploy reasonable security arrangements to protect your personal data as

required by the Privacy Laws; however there can inevitably be no guarantee of

absolute security such as but not limited to when unauthorised disclosure arises from

malicious and sophisticated hacking by malcontents through no fault of ours.

9. INFORMATION ON CHILDREN

9.1 The Services are not intended for children under the age of 13. We do not

knowingly collect or maintain any personal data or non-personally-identifiable

information from anyone under the age of 13 nor is any part of our Site, Games or

other Services directed to them. As a parent or legal guardian, please do not allow

such children under your care to submit personal data to Azrach Games and please

also consult Azrach Games’s Terms of Service for more information. In the event that

personal data of a child under the age of 13 in your care is disclosed to Azrach

Games, you hereby consent to the processing of the child’s personal data and your

acceptance and agreement to be bound by the terms of this Privacy Policy on behalf

of such child. In the event you do not in fact consent to the processing of the personal

data of a child under the age of 13 in your care, please contact our Data Protection

Officer. We will close any accounts used exclusively by such children and remove

and/or delete any personal data that was submitted without parental consent by such

child or as otherwise required by applicable law.

10. INFORMATION COLLECTED BY THIRD PARTIES

10.1 Our Site and Games use Google Analytics, a web analytics service provided by

Google, Inc. ("Google"). Google Analytics uses cookies, which are text files placed

on your device, to help the website analyse how users use our Services. The

information generated by the cookie about your use of the Services or device

(including your IP address) will be transmitted to and stored by Google on servers in

the United States. Google will use this information for the purpose of evaluating your

use of our Services, compiling reports on website activity for website operators and

providing other services relating to website activity and Internet usage. Google may

also transfer this information to third parties where required to do so by law, or where

such third parties process the information on Google's behalf. Google will not

associate your IP address with any other data held by Google.

10.2 We, and third parties, may from time to time make software applications

downloads available for your use on or through the Services. These applications may

separately access, and allow a third party to view, your identifiable information, such

as your name, your User ID, your device’s IP Address or other information such as

what game you are playing during any given session, and any cookies that you may

previously have installed or that were installed for you by a third party software

application or website. Additionally, these applications may ask you to provide

additional information directly to third parties. Third party products or services

provided through these applications are not owned or controlled by Azrach Games.

You are encouraged to read the terms and other policies published by such third

parties on their websites or otherwise.

11. DISCLAIMER REGARDING SECURITY AND THIRD PARTY SITES

11.1 WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA

AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY

SITES. We do implement a variety of security measures to maintain the safety of your

personal data that is in our possession or under our control. Your personal data is

contained behind secured networks and is only accessible by a limited number of

persons who have special access rights to such systems, and are required to keep the

personal data confidential. When you place orders or access your personal data, we

offer the use of a secure server. All personal data or sensitive information you supply

is encrypted into our databases to be only accessed as stated above.

11.2 In an attempt to provide you with increased value, we may choose various third

party websites to link to, and frame within, the Site or Games. We may also

participate in co-branding and other relationships to offer e-commerce and other

services and features to our visitors. These linked sites have separate and independent

privacy policies as well as security arrangements. Even if the third party is affiliated

with us, we have no control over these linked sites, each of which has separate

privacy and data collection practices independent of us. Data collected by our co-

brand partners or third party web sites (even if offered on or through our Site or

Games) may not be received by us.

11.3 We therefore have no responsibility or liability for the content, security

arrangements (or lack thereof) and activities of these linked sites. These linked sites

are only for your convenience and you therefore access them at your own risk.

Nonetheless, we seek to protect the integrity of our Site and Games and the links

placed upon each of them and therefore welcome any feedback about these linked

sites (including, without limitation, if a specific link does not work).

12. WILL AZRACH GAMES TRANSFER YOUR INFORMATION

OVERSEAS?

12.1 Your personal data and/or information may be transferred to, stored or processed

outside of your country. Azrach Games will only transfer your information overseas

in accordance with Privacy Laws and this Policy. By accepting this Policy, you agree

to the cross-border transfer of your information to any country where our affiliates,

developers, servers and/or databases are located. In most cases, your personal data

will be processed in Singapore, where our central database and servers are operated.

Because different jurisdictions may have different data protection requirements, we

take steps to implement adequate safeguards to protect your data.

12.2 If you are a user in India, your personal data will be processed and stored in our

servers in India or Singapore. Azrach Games will only transfer your information

overseas in accordance with Privacy Laws, and you hereby consent to such transfer

and processing.

12.3 More information about the transfer out of the EU, of personal data and/or

information relating to users who are located in the EU, can be found in the section

titled "Additional Provisions for EU Users Only".

13. HOW CAN YOU WITHDRAW CONSENT, REQUEST ACCESS TO OR

CORRECT INFORMATION YOU HAVE PROVIDED TO US?

13.1 Withdrawing Consent

13.1.1 You may withdraw your consent for the collection, use and/or disclosure

and/or request deletion of your personal data in our possession or under our control by

sending an email to our Data Protection Officer at admin@azrachit.com . We will

process such requests in accordance with this Privacy Policy and our obligations

under applicable Privacy Laws and other applicable law.

13.1.2 However, your withdrawal of consent and/or request to delete personal data in

our possession or control may mean that we will not be able to continue providing the

Services to you, and we may need to terminate your existing relationship and/or the

contract you have with us.

13.2 Requesting Access to, or Correction of Personal Data

13.2.1 If you have an account with us, you may personally access and/or correct your

personal data currently in our possession or control through the Account Settings page

or tab on the Site or Games. If you do not have an account with us, you may request

to access and/or correct your personal data currently in our possession or control by

submitting a written request to us. We will need enough information from you in

order to ascertain your identity as well as the nature of your request so as to be able to

deal with your request. Please submit your written request by sending an email to our

Data Protection Officer. In addition, where required by law, we will take steps to

inform any third parties who have received or used your Personal Data of such

correction.

13.2.2 Where permitted under applicable law, we reserve the right to reject certain

requests and/or may charge you a reasonable fee for the handling and processing of

your requests to access your personal data. In such cases, we will inform you and will

provide you with a written estimate of any applicable fees. Subject to applicable law,

will provide you the requested personal data within a reasonable time after you pay

the applicable fees.

13.2.3 Please submit your written request by sending an email to our Data Protection

Officer. Subject to applicable law, we reserve the right to only respond to data subject

requests submitted in accordance with this Policy.

14. OTHER USER RIGHTS

14.1 Additional Provisions for EU USERS ONLY

14.1.1 The provisions in this Section only apply if you are a user who is located in the

EU. These provisions take precedence over any inconsistent provisions in the

remainder of this Privacy Policy.

14.1.2 Portability

You have the right to obtain from us the Personal Data that you have previously

provided to us, and which we process on the basis of your consent in a structured,

commonly used and machine-readable format and a right to request that we transfer

such Personal Data to another party. If you wish for us to transfer the Personal Data to

another party, please ensure you detail that party and note that we can only do so

where it is technically feasible. We are not responsible for the security of the Personal

Data or its processing once received by the third party. We also may not provide you

with certain Personal Data if providing it would interfere with another’s rights (e.g.

where providing the Personal Data we hold about you would reveal information about

another person).

14.1.3 Erasure

You have the right to request that we erase the Personal Data we hold about you in the

following circumstances:

(a) you believe that it is no longer necessary for us to hold the Personal Data we hold

about you;

(b) we are processing the Personal Data we hold about you on the basis of your

consent, and you wish to withdraw your consent and there is no other ground under

which we can process the Personal Data;

legitimate interest and you object to such processing. Please provide us with detail as

to your reasoning so that we can assess whether there is an overriding interest for us

to process and retain such Personal Data;

(d) you no longer wish us to use the Personal Data we hold about you in order to send

you promotions, special offers, marketing and lucky draws; and/or

(e) you believe the Personal Data we hold about you is being unlawfully processed by

us.

Please provide as much detail as possible on your reasons for the request to assist us

in determining whether you have a valid basis for erasure. However, we may retain

the Personal Data if there are valid grounds under applicable law for us to do so (e.g.,

for the exercise or defense of legal claims, where we have a legal obligation or right

to retain certain information, freedom of expression, etc.) but we will let you know if

that is the case. Please note that after deleting the Personal Data, we may not be able

to provide the same level of servicing to you as we will not be aware of your

preferences and in some cases, our services may no longer be available to you.

14.1.4 Retention of Personal Data

We may retain your Personal Data as long as needed to provide services or products

to you, or as required or permitted by applicable laws, such as tax and accounting

laws or for the exercise or defense of legal claims. If you make a request for erasure

of your Personal Data and we determine that there is a valid basis for your request, we

will endeavour to erase the Personal Data within 30 days of your request, or inform

you if it will take longer.

14.1.5 Objection against Profiling and Targeted Marketing

At any time you have the right to object to our processing of Personal Data about you

in order to send you promotions, special offers and marketing messages, including

where we build profiles for such purposes and we will stop processing the Personal

Data for that purpose. Please provide as much detail as possible on your reasons for

the request to assist us in determining whether you have a valid basis for objection.

However, we may retain the Personal Data if there are valid grounds under law for us

to do so.

14.1.6 Restriction of Processing to Storage Only

You have a right to request that we restrict the processing of the Personal Data we

hold about you to storage purposes only, where:

(a) you believe the Personal Data is not accurate, for the period it takes for us to verify

whether the Personal Data is accurate;

(b) we wish to erase the Personal Data but you want us to just store it instead;

but you require it to be stored for the establishment, exercise or defense of legal

claims; or

(d) you have objected to us processing Personal Data we hold about you on the basis

of our legitimate interest and you wish us to stop processing the Personal Data whilst

we determine whether there is an overriding interest in us processing and retaining

such Personal Data.

14.1.7 Transfer of Personal Data outside the EU

Your Personal Data may be transferred outside of the EU. We take appropriate steps

to ensure that recipients of your Personal Data are bound to duties of confidentiality

and we implement measures such as appropriate contractual clauses to ensure that the

recipients of such transfer protect and treat your Personal Data in accordance with all

applicable personal data protection laws.

14.1.8 Information on Children

The Services are not intended for children under the age of 16 who are located in the

EU. We do not knowingly collect or maintain any personal data or non-personally-

identifiable information from anyone under the age of 16 who is located in the EU,

nor is any part of our Site, Games or other Services directed to children under the age

of 16 who are located in the EU. We will close any accounts used exclusively by such

children and will remove and/or delete any personal data we believe was submitted by

any child under the age of 16 who is located in the EU.

14.2 Additional Notice for Users Whose Data is Subject to California Law

14.2.1. For purposes of the California Consumer Privacy Act (“CCPA”), we do not

“sell” personal information and in the past twelve months prior to the effective date of

this Policy not sold any personal information of our users, as defined under the

CCPA. The California “Shine the Light” law also gives residents of California the

right under certain circumstances to opt out of the sharing of certain categories of

personal information (as defined in the Shine the Light law) with third parties for their

direct marketing purposes. We do not share your personal information with third

parties for their own direct marketing purposes.

14.2.2 The personal information that Azrach Games collects, uses and/or discloses

and has collected, used, and/or disclosed from users as set forth above in the twelve

months prior to the effective date of this Policy, may include personal information as

defined under the CCPA, depending on how you have accessed the Site and interacted

with us.

14.2.3 In accordance with the CCPA or other applicable law, you may have the right

to: (i) request confirmation of whether we are processing your personal information;

(ii) obtain access to or a copy of your personal information; (iii) receive an electronic

copy of your personal information or ask us to send that information to another

company; (iv) restrict our uses of your personal information, including the right to opt

in or opt out of the sale of your personal information to third parties, depending on

applicable law; (v) seek correction or amendment of inaccurate, untrue, incomplete, or

improperly processed personal information; and (vi) request erasure of personal

information held about you by Azrach Games, subject to certain exceptions prescribed

by law.

14.2.4 If you would like to exercise any of these rights, please contact us as set forth

below by sending an email to our Personal Data Protection Officer. We will process

such requests in accordance with applicable laws. To protect your privacy, we may

need to take steps to verify your identity before fulfilling your request. If you are a

California resident, you have the right not to receive discriminatory treatment by us

for the exercise of your rights conferred by the CCPA.

15. QUESTIONS, CONCERNS OR COMPLAINTS? CONTACT US

15.1 If you have any questions or concerns about this Privacy Policy

or our privacy practices, please contact us at admin@azrachit.com

By using the Game, you signify your acceptance of this Privacy Policy. If you do not

agree to this policy, please refrain from using the Game.

Last modified: 27-06-2023

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