Privacy Policy LAST UPDATED: Nov. 21 2024

Please carefully review the terms of the {team_name} Privacy Policy ("Policy"). This Policy outlines how TaurusX International Pte. Ltd., the entity operating {team_name} ("{team_name}", "we", "us", or "our"), handles your personal data in relation to our websites, mobile and progressive web applications, content, features, digital events, referral programs, promotions, or products (collectively referred to as the "Services"). By using our Services, you ("User", "Users", or "you") agree to the practices described in this Policy, which is an integral part of the {team_name} Terms of Use ("Terms"). This Policy explains our practices regarding the collection, use, disclosure, and processing of your personal data. Unless otherwise defined in this Policy, capitalized terms have the meanings assigned to them in the Terms. "Personal data" or "personal information" refers to any information that can directly or indirectly identify you. This may include, but is not limited to, your name, email address, gender, age, device information, and usage data related to our Services. Please note, this Policy does not cover the use of third-party games accessed through our Services. Your data's handling by third-party game developers ("Game Partners") is subject to their privacy policies. We encourage you to review these policies before using their games and when you wish to exercise any rights under those policies.


Before delving into the types of information our Services collect, it's crucial to note that, according to some privacy and data protection laws, device-level data qualifies as "personal data", although solely at the device level and cannot, by itself, be used to identify a natural person in the real world.


Please note, if you are younger than 18, you are prohibited from registering for a {team_name} user account and use the Services.


Please check back on this page regularly for the latest version of our Policy. We reserve the right to update or amend the Policy to align with changes in our Services. Upon any modification, we will update the "Last Updated" timestamp and notify users of the change within the relevant Services. If you do not agree with the current Policy, kindly refrain from using our Services.


1. INFORMATION WE COLLECT ABOUT YOU

{team_name} acts as the Independent Data Controller, as defined by applicable laws, regarding the collection, processing, and utilization of personal data in relation to our Services, as detailed in this Policy. This signifies that {team_name} is accountable for determining the purposes and methods by which your personal data is utilized and processed. We collect various types of information about you, including:

We specify the personal data we collect for each purpose of processing, along with their applicable legal basis, in Annex B Table for Legal Processing Activities to this Policy.


2. USE OF PERSONAL DATA

{team_name} generally use personal data to:


The legal basis for {team_name}'s processing of your personal data, as outlined in this Policy, typically includes one or more of the following:

For additional information on the legal basis for specific processing activities, please refer to Annex B.


3. HOW WE SHARE PERSONAL INFORMATION ABOUT YOU

Username; Leaderboard.We may display your username, profile information, play progress and reward information, on leaderboards accessible to you or other Users on the {team_name} platform. Your username, play progression, and rewards progression may appear on your friend’s referral leaderboard if you joined {team_name} through your friend’s referral link. You have the option to opt out of leaderboards by reaching out to {team_name}'s customer service. You can update your username at any time through your {team_name} profile settings. To protect your privacy, we advise against using personal information in your username, as it will be visible to other users.

Corporate Affiliates and Transaction Parties.We may share your personal data with our subsidiaries or affiliates under common corporate control for the purposes described in this Policy. Additionally, we may share your personal data with counterparties as part of corporate transactions, such as mergers, sales of company assets, financing, or acquisitions, but only to the extent necessary to evaluate and complete such transactions and in accordance with applicable legal or contractual requirements.

Law Enforcement, Regulators and Other Parties for Legal and Security Reasons.We may disclose personal data when necessary to protect the legal rights of {team_name}, Users or third parties, in order to avoid fraud, manage risks, or comply with applicable laws, legal orders, or processes. This includes sharing information with authorities and security companies acting on our behalf. In these cases, where permitted by applicable laws, we disclose personal data to meet legal obligations or protect the legitimate interests of {team_name} or affected third parties, such as cooperating with government authorities in legal investigations.


When necessary, the categories of data disclosed to such third parties may include your identifiers, Internet or other similar network activity, inferences drawn from other personal information. Where required or permitted by law or regulation and reasonably practicable, we will attempt to notify you of such requirements.


Service Providers.We have agreements with various service providers to facilitate delivery of our Services, which include those we engage to operate the technical infrastructure needed to provide the Services, assist in providing you rewards and protecting and securing our systems and Services, and to help market {team_name} Services.

We specify the Service Providers we cooperate with in Annex D Service Providers to this Policy.

Game Partners. The main purpose of the {team_name} loyalty program is to promote and advertise the games of our Game Partners in the {team_name} platform. In order to enable the loyalty program and reward you for your engagement, (a) we must allow tracking and collection of certain personal data by applicable Game Partners and their analytics providers, such as your game installs or survey answers, for purposes of reporting, attribution, and billing of the Game Partners; and (b) you direct {team_name} to collect Gameplay Data from Game Partners, including your in-game purchases and advertising views, in order for {team_name} to reward you, provide you with personalized content, market new games of interest to you, to develop our AI and algorithms for predictive modeling, grow our business and community of users, and for development of new products, features, and services. If you choose to access or install a game recommended through our Services, you acknowledge that Game Partner and its analytics partner will collect your personal data from {team_name}.


{team_name} may also disclose aggregated information about Users along with information that does not and cannot identify any individual or device, except where limited by applicable laws. For example, we may use anonymized user ratings, review of apps and aggregated information for statistical and machine learning purposes, to provide insights into developing or enhancing Services, for marketing and advertising and for other legally permissible purposes such as testing our IT systems and features.

For more information regarding the sharing of data with third parties please review the applicable sections below and notices within Annex A and Annex B.


4. HOW WE STORE, TRANSFER AND SECURE PERSONAL INFORMATION ABOUT YOU

We implement robust administrative, technical, and physical measures to protect your personal data in compliance with the legal standards of the region where the data was collected. These safeguards are designed to prevent unauthorized or unlawful access, use, alteration, disclosure, destruction, or loss of the personal information we collect and process.


5. EXERCISING OF YOUR RIGHTS

You have the right to update your preferences and assert your rights under applicable data protection laws by reaching out to us as specified. Please note that changes to your preferences, opting out, or withdrawing consent may affect your experience with our Services, potentially limiting access to certain features, such as Units and the Rewards Program outlined in our Terms.


For detailed information on specific rights related to your personal information for residents of certain European countries, staes of California and Virginia, refer to Annex A for Region-Specific Notices. We will address your requests in compliance with relevant laws, including response times, identity verification, and content. If we are unable to fulfill your request, we will explain the reasons, barring any legal or regulatory constraints.


Depending on your jurisdiction, your rights may include:


6. OTHER IMPORTANT INFORMATION

6.1 CHILDREN’S PRIVACY

In accordance with the Terms, you may not use the Service if you are under 18 years old. {team_name} is committed to complying with laws protecting children, within the meaning of applicable law. If you believe we might have any information from or about a child, please contact us.

6.2 DATA RETENTION

{team_name} will retain your personal data only for the duration mandated by law, while you continue to use our Services, or until it serves the original purpose of collection. For instance, personal data obtained from facial scans is retained for 24 months to prevent fraudulent activities. Account balances and earned rewards must be retained post-termination to facilitate processes like billing and tax reporting. If you cease interaction with our Services for 6 months, we will either destroy your personal information or store it separately.

Please be aware that if you remain inactive for at least of 180 days, your account may be terminated, and any unredeemed Units may expire, leading to the deletion of personal data.

You have the option to request the deletion of your {team_name} Account. However, doing so will result in the loss of any unredeemed Units. If {team_name} decides to retain or utilize de-identified information, as allowed by law, we will continue to do so without attempting to re-identify you. For the removal of personal data held by Game Partners, please follow the instructions provided in their privacy policy independently.


7. CONTACT US

If you have questions that do not relate to this Policy or data privacy, please write to our customer support team and Submit a Request. To exercise applicable data protection rights or comment about this Policy and our privacy practices, you may reach out to our {team_name} teamemail at .




ANNEX A: REGION-SPECIFIC NOTICES


EEA

If you are in the EEA, you have a right to (subject to a limited number of exceptions as permitted by GDPR):

(i) request access to and rectification or erasure of your personal information;

(ii) obtain restriction of processing or to object to processing of your personal information; and

(iii) ask for a copy of your personal information to be provided to them, or a third party, in a digital format. You also have the right to lodge a complaint about the processing of your personal information with your local data protection authority in the EEA.


State of California

If you are residents of the State of California in the United States, you can request the following information about how we have collected and used your personal information during the past 6 months:


Your CCPA Rights: Under the California Consumer Privacy Act (CCPA), California residents are entitled to the following rights regarding their personal data:


You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA. You may

(i) submit requests to exercise your California privacy rights described above by writing to us at ;

(iii) submit requests to restrict the use of your sensitive Personal Information by writing to us at: .

When you submit a request we will verify your request by the information you provide (e.g. device ID, account information) according to our internal guidelines. You may designate an authorized agent to make a request to know or a request to delete your personal information by providing the authorized agent written permission to do so; and by verifying your own identity with us directly. We will deny any requests from agents that do not submit proof of authorization.


State of Virginia

If you are a resident of the State of Virginia in the United States, effective January 1, 2023, you may exercise the following personal information rights with us.

As set forth in the VCDPA you have the right to exercise the above rights without discrimination.

You may exercise your rights to personal information as described above by sending email to to refuse personalized advertising, refuse the sale of your personal information, and refuse user profiles that have a significant legal or similar impact on you. If you fail to provide valid information for our effective feedback, etc. when exercising your rights as described above, we may deny your right to exercise your rights. If you have any dispute on such denial, you may raise such dispute by sending email to .


You can contact us via and request your data rights.


ANNEX B: TABLE FOR LEGAL PROCESSING ACTIVITIES

Processing Purpose Categories of Data used Legal Basis for Processing
Account creation and editing, and to provide access to and deliver our Services

First and last name, age,gender, email, phone number, account preferences and other communication when you set upyour account with {team_name} and data related to community features you use (“Account Data”).

In accordance with your privacy settings on a social network, the third-party profile (e.g., Facebook, Google) you provide for sign-up, including the first name and last name displayed and information you provided on such profiles (including information in your posts), as well as the email address and profile ID for these platforms (“Personal Data from Third-Party Social Networks”). Where offered and as required by applicable laws, you may choose to register for and sign in to your {team_name} account using your email address or phone number.

Processing is necessary for the performance of a contract with the User (i.e. the account creation). Without this information,we will not be able to provide the service you have requested.

Ensuring compliance with our statutory retention obligations under commercial and tax law as well as other legal obligations of {team_name}.

User consent when actively deciding to sign up via social networks profile. Then, the processing will be necessary for the performance of a contract with the User (i.e. account creation).

Without this information, we will not be able to provide the service you have requested.
To maintain and improve the Services

Account Data

Usage Data (Defined in Section 1of the Notice)

Gameplay Data (Defined in Section 1of the Notice)

IP address (including approximate location andcountry), exact geolocation data (including longitude and latitude), mobiledevice identifier, advertising identifier (e.g. Google advertising ID) or otherunique identifiers, data about your operating system, device model and devicelanguage, log data (e.g. network connection type, applications connected to theplatform including the site you came from, go to next, and the web page(s) youaccess during your session in the platform), data on apps already installed onyour device (“Device Data”).

It is in our legitimate interest to maintain and improve our Services by better understanding your preferences, the use of Services, and to avoid bugs or similar errors in order to ultimately provide you with the best possible Service.

This basis also applies for the EU.

Where required by applicable laws we will obtain your consent.
Enabling you to redeem rewards earned in our Services or to engage in and claim prizes on our Promotions

Account Data

Gameplay Data

Device Data (mainly location)

Fitness and Health Info

Loyalty Rewards Tier status

Participation in community features including data sharing with other Users, certain Gameplay Data, image and/or User name

Gameplay Data

Device Data (with precise geolocation)

Usage Data

Processing is necessary for the performance of a contract with the User (i.e. display rewards selection available in your country and providing you with the reward or prize from Promotions we run). Without this information, we will not be able to provide the service you have requested.

Processing is necessary for {team_name} to enable you to redeem rewards and to prevent abuse of Reward Program. This basis also applies for the EU.

Where required by applicable laws, we will rely on User consent.
Personalization of Services,including content on the {team_name} platform, game ads, and promotions; and building user profiles

Account Data

Device Data

Gameplay Data

Usage Data

It is in our legitimate interest to show you game recommendation advertisements and promotions that are tailored to your interests.

Where required by applicable laws and in the EU, we will obtain your consent. Where User freely decides not to grant or to withdrawn the consent, access to a generic newsletter will alternatively be accessed as this personalization, even if voluntary, is essential for the purposes of due development of the Services.

Usage Data including information on device installed apps is used in the context of profiling user preferences.
Law Enforcement, Regulators and Other Parties for Legal and Security Reasons

Account Data

Device Data

Gameplay Data

Usage Data

It is in our legitimate interest to protect our rights and the App.

Compliance with due EU laws where we are required to cooperate with due and competent authorities and courts.
Marketing and advertising of the {team_name} Services (including data sharing with third-party platforms)

Device Data (limited to advertising ID and IP address)

Gameplay Data

It is in our legitimate interest to acquire new users and build the {team_name} community.

Where required by applicable laws and in the EU, we will obtain your consent.
Monitor and analyze usage and activity trends, including measuring the effectiveness of our Services to clients, creating operational reports and developing insights about our business with aggregate data

Account Data

Device Data

Gameplay Data

Usage Data

It is in our legitimate interest to monitor and analyze the use and effectiveness of our Services in order to improve our Services. This basis also applies for the EU.

Where required by applicable laws we will obtain your consent.
Send marketing communications, surveys and participating in User testing

Account Data

Other voluntary data you may provide when you are participating in our surveys or User testing phases. This can include income range, occupation, preference for games and other choices.

It is in our legitimate interest to keep you updated on our existing and new Services by sending you relevant marketing communications and surveys, and by processing the data that we collect in this respect or via User testing.

Where required by applicable laws and in the EU, we will obtain your consent

Customer service, including when contacting us by phone, email or otherwise

Account Data

Device Data

Gameplay Data

Usage Data

It is for performance of the contract to provide you with customer support,ensuring efficient and user-friendly communication and processing of your request.

Where required by applicable laws we will obtain your consent
Security and fraud detection prevention including sharing of information with, and collection of information by, fraud detection and identify verification vendors

Account Data

Personal Data from Third Party Social Networks

Device Data

Gameplay Data

Usage Data

Biometric Information

This processing is necessary for the performance of a contract with the User (i.e. the account creation). Without this activity, we will not be able to provide the service you have requested.

This includes determining if user is real or synthetic (i.e.a bot) or has other Apps on the relevant device that could be used to conduct fraudulent activities (such us wrongfully acquire units or gift cards).

Where required by applicable law, we will obtain your consent or rely on our legitimate interest in providing a secure Service

Training our machine learning and AI models to provide you with personalized content and user experience.

Improve and develop new products and features in our Services.

Account Data

Device Data

Gameplay Data

Usage Data

 It is in our legitimate interest to optimize and provide better Services to our Users.

ANNEX C: Biometric Information Processing

What is Biometric Information?

Biometric Information is any information, however generated, stored or shared, that is basedon an individual’s biometric identifier, and used to identify thatindividual.

In case of the {team_name}, only face geometry by utilizing facial recognition technology isused as a biometric identifier through facial recognition technology.

We require you undergo a facial recognition scan before we are able to pay out collected coins.

Collection of Biometric Information

We collect and process the following Biometric Information through the camera of your mobile or handheld during your verification within our payout process

Prior to using your Biometric Information for the first time, we will require you to consent to this Policy.

Purpose of Collection

We collect and use biometric data solely for the following purposes:

Storage and Protection of Biometric Data

Your Biometric Information will solely be stored in our rented server space onthe servers of AWS (please see our general privacy policy in this regard). We implement robust security measures, including encryption and secure storage, to protect your biometric information from unauthorized access, disclosure, or misuse.

Biometric data is stored for 24 months to fulfil the purposes outlined in this Policy or as required by law. After this period, the data is securely deleted.

Sharing of Biometric Data

In general, we do not disclose or share your Biometric Information with any third party, but do so only under the following circumstances：

Your Rights

You have the following rights regarding your biometric data:

How to Exercise Your Right

To exercise any of your rights or if you have any questions about this Policy,please contact us at:

Changes to This Policy

We may update this Policy from time to time to reflect changes in our practices or legal requirements. We will notify you of any significant changes by posting the new Policy on our website or through other communication channels. Your continued use of FaceTec after such changes constitutes your acceptance of the revised Policy.

For any inquiries and additional questions about processing personal data please contact us via . Our contact details may also be found above or in the imprint under the App’s settings menu.


Annex D: Services Providers

Services Providers Privacy Policy Links Purpose of Data Transfer and Processing
Adjust https://­www.adjust.com­/terms­/privacy-policy Data analysis
Amazon https://­aws.amazon.com­/privacy Face Liveness
AppsFlyer https://­www.appsflyer.com­/legal­/privacy-policy Data analysis
BytePlus https://­docs.byteplus.com­/en­/docs­/legal­/docs-privacy-policy Data analysis
Facebook https://­www.facebook.com­/about­/privacy­/update Third Login
Firebase https://­firebase.google.com­/terms Data analysis
Google https://­www.google.com/analytics­/terms­/us.html Third Login
OneSignal https://­documentation.onesignal.com­/docs­/data-security Notification
Digital Union https://­www.shuzilm.cn­/privacy_en Data analysis