PRIVACY POLICY

Last Updated: 20 April 2026

CHILLSPIN GAME LIMITED, (herein "we" or "us", "ours"), including its subsidiaries and affiliates, understands the importance of protecting your personal information (the "Personal Information"). We have adopted this privacy policy (the "Policy") to explain how we collect, use, process, store and share the Personal Information that provide to us or we collect when you use our website, software applications, games or any other products and services provided by us (the "Products and Services").

We collect, use, process, store and transfer your Personal Information in accordance with applicable data protection legislation, including but not limited to the (EU) General Data Protection Regulation ("GDPR") and applicable national data protection legislation ( together with GDPR, "Applicable Laws"). Wherever we talk about Personal Information below, we mean any information that can either by itself identify you as an individual or that can be connected to you indirectly by linking it to your Personal Information. We also collect, use, process, store and transfer anonymised data, whether aggregated or not, to analyse and generate reports related to usage patterns, spending habits, demographics of users, etc. As an individual is not or no longer identifiable from such anonymous data, the use of such data will not be governed by this Policy.

You agree that we will engage other third parties and may transfer your Personal Information to such third parties in order to fulfil our purposes and obligations as set out in this Policy. You acknowledge that some of these third parties may be located outside the country of your residence where there may not have as strict privacy legislation as yours. We will only transfer your Personal Information to such countries if we are allowed to do so, please see section D for more information.

By downloading, registering, accessing and/or using our Products and Services, you consent to our collection and use of your Personal Information in accordance with this Policy. IF YOU DO NOT AGREE TO THE POLICY, PLEASE DO NOT PROVIDE YOUR INFORMATION WHEN REQUESTED AND SHOULD REFRAIN FROM USING OUR PRODUCTS AND SERVICES.

A. COLLECTION OF YOUR PERSONAL INFORMATION

We collect Personal Information about you to provide you with our Products and Services.

Depending on the type of Products and Services you are using, we may collect the following types of information from you:

(i) Personal Information

This includes information you directly provide when creating an account, using social features, or contacting support:

· Identification information, including but not limited to your surname and first name, date of birth, nominated nickname, identification we import from your linked social media accounts, gender, age, country of residence, user ID and profile picture.

· Contact information, including but not limited to your email address and mobile phone number.

(ii) Data Collected Automatically

This includes information collected through your use of our Products and Services, facilitated by necessary device permissions as described below.

1. Device Identifiers and Connection Information

We collect Device IDs and other unique identifiers to facilitate core services, analytics, and security. This includes, but is not limited to:

.Device Unique Identifiers:device unique identifier, Android ID, IMEI (where permitted by law and platform policy).

.Advertising Identifiers: advertising ID, Google Advertising ID (GAID), Apple's Identifier for Advertisers (IDFA).

.Network and Hardware Identifiers: IP address, MAC address, BSSID, SSID.

.Technical Device Information: device brand, device name, device model, operating system, browser type, hardware information, language, device system type, device settings and version information.

.Sensor Information: data from device sensors where applicable for gameplay functionality.

.Network and Performance Data: Network connection status and type (e.g., Wi-Fi, cellular), strength, and related identifiers. Data necessary for core app functionality, such as maintaining network connections (enabled by the INTERNET permission), preventing sleep during gameplay (enabled by the WAKE_LOCK permission), providing haptic feedback (enabled by the VIBRATE permission), and running background services (enabled by the FOREGROUND_SERVICE permission).

2. Usage and Interaction Data

· Data about your use of our website, including but not limited to browsing time, click-activity, referring website, date/time stamp for your visit and/or data we collect with cookies and similar technologies (Please see Section B for further information), where applicable.

· Data about your use of the Products and Services, including but not limited to account history, game log, game character information, in-game chat history, communication records, sharing record, in-game item record, purchase record, purchase history, Account balance/credit, usage/session time, preferences, gameplay data, game progress, crashes or bugs data, social media sharing and interactions, purchase history and billing history, contacts, IOS/Android Software application version and name and Bundle ID, where applicable.

3. Advertising and Analytics Data

· Data about advertising identifier usage, Device ID, and other IDs: We and our advertising partners collect and use identifiers including:

- Advertising IDs: Google Advertising ID (GAID/AAID) and Apple's Identifier for Advertisers (IDFA).

- Device ID and other IDs: Such as Android ID, device unique identifier, device serial number, IMEI (where permitted by law and platform policy), and IP address. These identifiers are used to deliver relevant ads, measure campaign effectiveness (attribution), prevent ad fraud, and build custom audiences. You may manage your advertising preferences or reset your Advertising ID through your device settings. We may store the ad identification number and associated device information with your profile to track the success of our advertising if you interact with advertisements in our Services.

4. Security and Integrity Data

· Data required to be collected for ensuring security and detection, investigation and prevention of fraud, cheating, misuse of our Products and Services or other violations to our End User Agreement or Applicable Laws.

(iii) Data that you may provide to us

· Data about your use of our Products and Services, including but not limited to messages, posts, comments, conversations transmitted or submitted through the Products and Services (such as chat logs and player support tickets).

· Data you choose to provide to us to request information or support from us or to purchase Products and Services or to participate in competitions or tournaments or respond to our questionnaires or surveys, including but not limited to personal data to identify a lost account, account number, email address, photographs, security questions and answers you created, contact information.

· Any other data that you provided to us as part of the Products and Services, or that we collected with your consent to provide you with the Products and Services or for specific purposes made known to you at the time of collection.

(iv) Data that may be provided to us by third parties

· Data about you from other third-parties who have obtained your consent or otherwise are permitted by Applicable Laws to share such data with us, including but not limited to your account information registered under other third-party applications (if you have linked such applications to our Products and Services or accessed such applications by using our social media features) and may include profile picture, email address, user name, gender, language, country, users ID and profile pictures of your followers, friends or contacts. The types of information we receive will depend on your settings with such third-party applications.

· Data which include attributes about you and your interests as further detailed in section B.

Unless expressly stated otherwise, we do not collection from you sensitive personal data which discloses your psychological, mental or physical health, or genetic, biometric, religious beliefs, political views, or criminal records.

B. Use of Data

Purposes of Collection and Use

We collect and may use your Personal Information for the purposes including but not limited to the following:

· to facilitate the setting up of your Account and enable you to log-in to and top-up your Account and use the Products;

· to provide you with and maintain our Products and Services, including but not limited to our games, websites and mobile applications;

· to evaluate, customise and improve the Products and Services and the user experience;

· to handle, process and execute any transactions related to the Products and Services;

· to provide you with our customer and/or technical support;

· to analyse the use and trends of the Products and Services;

· to seek your opinion about our Products and Services and conducting surveys on the Products and Services;

· to send or disseminate confirmation notices, updates, and security alerts;

· to manage any abusive, unlawful or dishonest uses of Products and Services or violation to our End User Agreement, such as managing player bans;

· to prepare and offer push ads, newsletters, promotions, rewards, and other types of content or features that match with your interests;

· to customise the Products and Services, in particular by providing features or ads which correspond to your interests and/or your preferences;

· to improve the safety and reliability of our Products and Services;

· to prevent malicious programs like viruses and trojans on your device when using our Service and Software;

· to research and develop other services; or any other purposes described in the Policy or for specific purposes made known to you at the time of collection.

Legal Basis

Under Applicable Laws such as the GDPR, our use of your Personal Information must be justified under one of a number of legal bases. Our principal legal basis that justifies our use of your Personal Information are:

· Contract Performance: where it is necessary for us to perform our contract with you in providing you with our Products and Services;

· Legitimate Interests: where we collect and use your Personal Information for legitimate interests, such as for the purposes of our compliance with Applicable Laws, to ensure information security, to prevent fraud, etc. When we rely on a legitimate interest, we shall ensure that our interests do not override your interests or fundamental rights and freedoms.

· Your Consent: where you have consented to our collection and use of your Personal Information, for example, by agreeing to this Policy. You may withdraw your consent at any time;

· Legal Requirement: where it is necessary for us to defend, prosecute or make a claim against you, us or a third party.

Analytics and Optimisation

We use internal analytics technologies and other automatic tracking and analytic technologies provided by third parties to collect information through automated means in order to adapt our content to your interests as well as to provide and manage the use of the Products and Services.

(i) Cookies

Cookies, or similar technologies such as cookies, web beacons, web server logs, scripts, eTags or other similar technologies ("Cookies"), are small computer files stored on your hard drive. Various types of Cookies may be used to enable us to provide certain features and functionalities and they are placed on our websites either by us or by other third parties permitted by us. The information collected by Cookies enables us to monitor site traffics and users' interactions with other services. We may also use certain cookies that can only collect generic information in relation to browser configurations and personalize the appearance of our websites. We also use anti-cheat technologies that also use Cookies as described below.

You have the option to permit installation of such Cookies or subsequently disable them. You may accept or decline or instruct to be notified of the storage of Cookies by changing the configurations of your web browser (in the case of websites) or the device (with respect to games or applications). However, if you decline to install Cookies, the Products and Services and/or certain features may not work properly as intended. For more information on cookies, please refer to the following website: http://www.allaboutcookies.org.

(ii) Third-party analytics tools

Third-party analytics tools may use cookies or visitor action pixels to track your behaviors while you are using our Service and Software. These tools may associate the information they collected in connection with the Service and Software with personal information that they had independently collected on other services, as governed by their respective privacy policies. We do not collect or access any data that may be independently collected by these third parties.

To the extent that the data we collect by Cookies or other third-party analytics tools is combined with personal information or otherwise such data can be used to identify an individual (whether directly or indirectly), we shall treat the combined data and such data as personal information in accordance with this Policy.

Direct Marketing and Advertising

If you choose to receive our direct marketing materials, newsletters and news releases, we will use your name and email to send you messages regarding new features, updates, contests and events concerning our Products and Services or to show you promotions, services or products that might be of interest to you in connection with the Products and Services. You may opt-out of receiving direct marketing materials from us at any time by contacting us At support@chillspingame.com.

Opt-Out of "Sale", "Sharing" and "Targeted Advertising" Practices

Depending on the site you are visiting or the app you are visiting and your relationship with us, you have the right to opt-out of certain information sharing practices with Third Parties who do not act as our Service Providers. In some states, like California, this information sharing may qualify as a "Share" or a "Sale," while in other states, this information sharing may qualify as "Targeted Advertising" (collectively, "personalized advertising"). If you wish to opt-out of personalized advertising associated with our games, please contacting us as set forth below.

If you are using our Products and/or Services to which this Policy applies from the Commonwealth of Virginia in the United States of America, the following terms will also apply to you. In the event of any inconsistency between any provision set out in this Section O and the rest of the Policy, the provisions hereunder in Section O will take precedence to the extent as permitted by Applicable Laws.

Your rights as a resident in Virginia include:

· To confirm whether we are processing your personal data and to access such personal data;

· To correct inaccuracies in your personal data;

· To delete personal data provided by or obtained about you;

· To obtain a copy of your personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format;

· To opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

How to Opt Out of "Sale", "Sharing" and "Targeted Advertising" Practices

Method 1: In-App Control

The fastest and most direct way to opt out is within the Domino Spin app by logging in, tapping the Settings icon, selecting "Privacy Controls", and turning the "Do Not Sell or Share My Personal Information" switch ON.

Enabling this switch signals our systems and relevant third-party partners to stop processing your data for targeted advertising and data sale/sharing purposes.

Method 2: Online Form

You may also submit a request via our online form: https://forms.gle/FdikYPBKcTd2wxK6A

Method 3: Email

You can contact us via email at support@chillspingame.com with the subject line "VCDPA Opt-Out Request". Please include your game account details for verification.

Alternative Opt-Out Method for Interest-Based Advertising

If you would prefer to opt out of having information about your mobile app usage used for interest-based advertising, you may also do so through your device settings such as ("Allow Apps to Request to Track" on iOS and "Opt Out of Ads Personalization" on Android).

Our Processing Commitment

Upon receiving your verified opt-out request form, we will process it within 45 days and notify you of the outcome via the email address you provided in your submission. If you have any questions about this process, please contact us at: support@chillspingame.com.

Important Notes

You acknowledge and agree that if you opt-out of or do not consent to receiving interest-based or targeted advertising, we may not conduct direct marketing to you and provide your Personal Information to others for direct marketing purposes. You may however still see advertising which may or may not be related to our Products and Services, but the relevant advertising will not be targeted using your Personal Information.

Ads Serving Technologies

Ads serving technologies, including interest-based ads, from our suppliers, involve the use of pixels and/or other similar technologies to collect data in order to determine what kinds of advertising you would prefer to see.

Data collected by these third parties may include, without limitation, (i) your age and/or sex, (ii) your IP address and/or country, (iii) the advertisements placed and their location in the Products and Services, (iv) the duration of visibility of an advertisement as well as the number of views, (v) the identifiers and settings of your device, (vi) your use of the Products and Services and/or other websites (including third party websites) you have viewed (as well as the date and the time of such viewing), and/or (vii) your responses to the advertisements, if any, to allow our suppliers to calculate the number of views of the advertisements or to present ads in a format that best suits your device. Advertisements may be tailored to your interests, for example, you could view an offer for a game or product that might interest you.

Third-party advertising service providers may associate Personal Information with data that they have collected independently from other services in accordance with their own privacy policies. We do not collect or access data that may be independently collected by these third parties. To learn more about some of these ad network practices, you can visit www.networkadvertising.org, www.aboutads.info/choices, or www.youronlinechoices.com.

The technologies deployed by us as described above are fundamental to our Products and Services. If you do not consent to the use of the abovementioned technologies, you should stop using or accessing our Products and Services.

Anti-cheating services

Some of our Services (including our games) may have incorporated or implemented mechanisms to identify and curb users from taking unfair advantage over other users of such Services (such acts will be referred to as "Cheating" and such mechanisms shall collectively referred to as the "Anti-Cheat Tools").

When you start a new game session, the Software may automatically load and install its latest version on your device. When using the game, the Anti-Cheating Tools may scan the game's binary files and the device's memory to detect and prevent cheating in the game (the "Objective"). By installing or accessing any of our games, you agree that the Anti-Cheat Products and Services may collect, store and disclose to us your Personal Information, account details, gameplay and any other unauthorised programs or techniques in Cheating for us to detect and manage Cheating behaviours and also to identify players who cheat in games and prohibit them from doing so. This Objective is necessary to pursue our legitimate interests and to ensure the safety of you and other users of our Products and Services.

The collection of data by such Anti-Cheat Service providers will be governed by their privacy policies. If you think that your access to our Products and Services has been blocked by mistake by the Anti-Cheating Tools, please contact us at support@chillspingame.com.

Social Media Features

You may be able to use our social media features for logging into our Products and Services, find out if your friends play our games, and invite them to join you in these games. If you choose to use social media features in some of our Products and Services or to create an account with us using your account with a certain social media platform, the social media platform will provide us with some of your Personal Information, such as your social media platform user ID, your profile picture (to create your avatar in certain games) and the user IDs and profile pictures of your followers, friends or contacts on such social media platform. You may determine the scope and extent of Personal Information that will be provided to us by modifying your sharing settings.

Public data, including user-generated content, online forums, blogs, chat and profiles.

You may communicate Personal Information when you provide or otherwise create content by using or accessing our Products and Services, whether as part of games, online forums, blogs, discussion platforms, public user profiles or other similar forums available as part of our Products and Services (collectively, the "Forums"). Any Personal Information you disclose in the Forums would become public data and may be read or used by other users without your consent. If you decide to disclose Personal Information on the Forums, you will do so at your own risk and we shall not be responsible for held liable for any unauthorised use of such Personal Information by any third parties.

You may choose not to provide certain Personal Information. However, you may not be able to use certain or all features of our Products and Services.

C. Personal Data Shared with Third Parties

We use and share your information to provide you with our Products and Services and to operate our business. As described below, we may share your information with our subsidiaries and with trusted third-party service providers for the following purposes.

1. Providing You with Games and Support

We use the information we collect to develop, deliver, operate, and improve our Products and Services. This includes providing game updates, fixing bugs and crashes, and offering timely customer support.

· Associated Permissions: INTERNET, FOREGROUND_SERVICE, WAKE_LOCK, VIBRATE, READ_LOGS.

· Recipients of your data:

i.Cloud and Infrastructure Providers: We store data on servers operated by providers such as Alibaba Cloud to host our Services globally.

ii.Customer Support Tools: We use integrated support systems (such as live chat) to communicate with you and respond to inquiries within our apps.

2. Analytics and Performance Optimization

We use your information to understand how our Services are used, analyze trends, gather demographic insights, and improve performance and security. Data used for analytics is typically aggregated and does not directly identify you.

· Associated Permissions: ACCESS_NETWORK_STATE, ACCESS_WIFI_STATE.

· Recipients of your data:

i.Analytics Platforms: Such as  Google Firebase Analytics (via firebaselogging.googleapis.com), to measure game performance, diagnose crashes, and understand user engagement.

ii.Crash Reporting: We use services like Google Firebase Analytics to collect crash reports and monitor application stability.

3. Advertising and Attribution

We offer free or low-cost access to our Services supported by advertising. To deliver and measure relevant ads, our app utilizes specific advertising and attribution services. This functionality involves new permissions detected in this app version, including: ACCESS_ADSERVICES_AD_ID, ACCESS_ADSERVICES_ATTRIBUTION, ACCESS_ADSERVICES_CUSTOM_AUDIENCE, and com.google.android.gms.permission.AD_ID: These permissions enable our partners to access your device's Advertising ID for ad personalization, campaign measurement (attribution), building custom audiences, and fraud prevention.

· Recipients of your data:

i.Advertising Networks: Such as Meta (Facebook) (via graph.facebook.com), to deliver personalized (interest-based) and contextual ads.

ii.Attribution and Measurement Providers: Such as Adjust (via app.adjust.com), to analyze campaign performance and attribution.

4. Installation Attribution and System Functionality

To understand how users discover our app and to ensure core system features work correctly, we process related data.

· Associated Permissions: BIND_GET_INSTALL_REFERRER_SERVICE, RECEIVE_BOOT_COMPLETED, DYNAMIC_RECEIVER_NOT_EXPORTED_PERMISSION, com.google.android.c2dm.permission.RECEIVE.

·Recipients of your data:

i.Attribution Partners: Such as Adjust (via app.adjust.com) and platform services, to understand referral sources.

5. Notifications and User Communication

We send you relevant game updates and news with your consent.

·Associated Permissions: POST_NOTIFICATIONS.

·Recipients of your data:

i.Push Notification Services: We use cloud messaging services (e.g., Firebase Cloud Messaging via firebaselogging.googleapis.com) to deliver notifications.

6. In-App Purchases

All transactions are processed securely through official platforms.

·Associated Permissions: com.android.vending.BILLING.

·Recipients of your data:

i.Payment Processors: Transactions are handled directly by Apple App Store or Google Play Store. We do not receive or store your full payment card information.

7. Security, Anti-Cheat, and Fraud Prevention

We use your information to maintain a fair and secure gaming environment.

·Recipients of your data:

i.Security and Anti-Cheat Providers: Specialized third-party services that help us identify and mitigate unauthorized activities. This may include sharing with providers associated with endpoints such as us-fp.apitd.net for fraud prevention and security purposes.

Legal and Compliance

We may disclose your information where reasonably necessary to comply with laws, regulations, legal processes, or to protect rights, property, or safety. This may include sharing with regulators, law enforcement, or in connection with a business transfer (e.g., merger or acquisition).

Our Commitments in Data Sharing

·All third-party service providers are contractually obligated to protect your information and use it only to perform the services we have requested.

·Transparency on New Permissions: The new permissions requested in this app version are primarily for advertising, attribution, and core app functionality (as listed above). We do not request permissions to access your location (ACCESS_FINE_LOCATION, ACCESS_COARSE_LOCATION) or contacts (READ_CONTACTS).

·Sharing with advertising partners for personalized ads may be considered a "sale" or "share" under laws like the CCPA. You have the right to opt-out as described in the "Opt-Out of ‘Sale', ‘Sharing' and ‘Targeted Advertising' Practices" section.

D.Location and Transfer of Your Personal Information

The Personal Information may be hosted and processed, for the purposes of the Policy, on servers operated by trusted partners that may or may not be located where you live. Our support, developers and other team members are located in different parts of the world and they may have access to your Personal Information from outside of where you live in order to provide timely support to constantly maintain our Products and Services. The servers of our games are located in Singapore, or otherwise specified. These locations are either a jurisdiction with an adequate level of protection recognized by the European Commission or such transfers subject to appropriate safeguards as required by the Applicable Laws.

Some of our subcontractors described in Section C may be located in other countries, including outside the European Economic Area. By using the Products and Services and the games, you agree that your Personal Information may be processed by such subcontractors in countries that may not offer the same degree of data protection as your country. We will, however, only transfer the Personal Data in compliance with Applicable Laws.

We have taken reasonable contractual measures to ensure that our subcontractors would process your Personal Information in accordance with our directions and for our purposes as set forth in this Policy. Our subcontractors are prohibited from using your Personal Information for any other purposes without your consent.

E. Retention Period of Personal Information

We keep your Personal Information for a period not exceeding what is required for the purposes for which the Personal Information is collected and in accordance with Applicable Laws.

Your data will be kept in our active database:

· for the time as long as necessary to provide the Products and Services; or

· for the duration necessary to solve your technical problems or your request; or

· for the time needed to compile game statistics; and

· for 30 days for IP addresses and logs.

At the end of this period, your Personal Information will be deleted or anonymized by us, or archived in an intermediate database, if necessary, for legal, operational, or legitimate reasons, and for the legally prescribed period. The retention period may be changed upon your cancellation of or re-enrollment in the Products and Services, or in accordance with Applicable Laws.

F. Safeguards of your Personal Information

We take different measures to secure your Personal Information. We follow generally accepted rules in the video game industry, as well as Applicable Laws, to protect any loss, destruction, alteration, or unauthorized, unlawful or abusive use of Personal Information. We strive to use appropriate organizational and technical means to protect your Personal Information. For example, we will use encryption technologies (such as TLS, SSL), firewalls, anonymization, restrictions on unauthorized access, de-identification and other means to protect your personal information. We consistently enhance software security capabilities, such as locally encrypting specific information on the device to strengthen secure transmission. Furthermore, we analyze information about applications installed on your device and running processes to prevent malicious programs like viruses and trojans.

We have established a specialized management, process and organization system to ensure information security. For example, we strictly restrict the scope of personnel who can access information and require them to comply with their contractual confidentiality obligations and be subject to regular audits. In the event of a data breach or other security incident of Personal Information, we will activate an emergency response plan to prevent the expansion of such security incident and notify you in the form of push notifications, public announcements, etc.

However, you acknowledge that no security measures are 100% effective. To the extent permitted by Applicable Laws, we shall not be held liable for any direct or indirect loss, damages or costs sustained or incurred by you in the event of a data breach or if the Personal Information is subject to unauthorized use or access.

If you have any questions regarding the security of your Personal Information, please contact us by email at support@chillspingame.com.

G.Your Rights and Choices on Your Personal Information

You enjoy the below rights with respect to your Personal Information that is in our possession or under our control under Applicable Laws. Nothing under this section shall restrict your entitlement to the rights granted under the Applicable Laws in your relevant jurisdiction.

The right to know about data sharing

You have the right to request that we disclose to you, for the 12-month period preceding your request, specific information about our collection, use, sale, sharing (as defined under the CCPA), and disclosure of your Personal Information. This includes the right to know:

· Whether we have sold or shared your Personal Information.

· The categories of Personal Information we collected.

· The categories of sources from which we collected that Personal Information.

· Our business or commercial purposes for collecting, selling, or sharing that Personal Information.

· The categories of third parties to whom we have disclosed your Personal Information, specifying whether each disclosure was for a business purpose or constituted a sale or share.

· The specific pieces of Personal Information we have collected about you.

For details on how we have handled these categories of activities over the past twelve (12) months, please refer to Section N (Jurisdiction specific provisions - California) below.

We strongly suggest you review this Policy carefully before using our Products and Services.

The right of access

You have the right to access and know about the Personal Information that we have collected, used, disclosed, or sold/shared (where applicable). Under laws such as the CCPA and VCDPA, this includes:

The right to request disclosure of the specific pieces of Personal Information we have collected about you.

The right to know the categories of Personal Information collected, the purposes for collection, the categories of sources from which it was collected, and the categories of third parties with whom we have shared, sold, or disclosed your Personal Information.

The right to know whether your Personal Information has been sold or shared (as defined under the CCPA) and the categories of information and recipients involved.

For Products and Services where you have created an account, you may access and update certain Personal Information at any time by logging in and adjusting your account settings. For other information or to submit a formal request, please contact us using the methods described in Section N (for California residents) or Section Q below.

The right of rectification

You have the right to rectify any of your Personal Information that is in our possession or under our control. Similar to the above, you may revise or supplement any of your Personal Information at any time by logging into the relevant Products and Services and adjusting your account settings.

The right to erasure and the right to restrict processing to storage

You have the right to request us to delete your account, to remove your Personal Information or to restrict the processing of your Personal Information where there are no compelling reasons for any continued processing. To submit such a request, you may log in to your account in the relevant Products and Services, contact us through the in-game support system, or reach us using the contact methods listed in Section Q of this Policy.

The right to erasure is however subject to our legitimate rights afforded under Applicable Laws to retain Personal Information for our legitimate purposes. An example is for enforcement of our legal rights.

If you require us to restrict the processing of your Personal Information other than for storage purposes, please note that we may use such Personal Information again if there are valid reasons under Applicable Laws for us to do so.

The right to data portability

If you reside in the European Economic Area, you have the right to receive a copy of the Personal Information we process about you. You may also request us to transfer it to another party, except under certain exceptions.

The right to object

You have the right to object to our processing or use of your Personal Information at any time. In particular, you can object to our use of your Personal Information for direct marketing purposes.

We will only use your [list of types of personal information] for direct marketing purposes upon your explicit consent. Our direct marketing materials may include, but are not limited to, [types of direct marketing e.g: sending you marketing materials by post or online (including by email or through your mobile device or via online banner advertisement)]. If you prefer not to receive any direct marketing materials, you may withdraw your consent at any time by contact us at support@chillspingame.com.

If you wish to contact us regarding the processing of your Personal Information, or to have access to it in an electronic format, correct it, erase it, change how we process it (if applicable), or withdraw your consent (if applicable), or transfer them to another online provider (where technically possible), you may email us at support@chillspingame.com. Please note that the withdrawal of your consent shall not affect the lawfulness of how we have used or processed your Personal Information before your withdrawal.

In the case of an email request, you agree to provide us with your contact information, the subject of the request and the Personal Information in question for our further action. We reserve the right to ask you for any information about you to confirm your identity.

Please note that if you choose to delete your Personal Information, you will no longer have access to the Products and Services associated with your internal and/or external identifier.

We reserve the right to reject deletion requests if there is a legal obligation on us to retain the Personal Information due to legal claims or as required by any Applicable Laws.

Your request will be processed within thirty (30) days of receipt, with the understanding that we reserve the right as permitted by Applicable Laws to extend this period to two (2) months due to the complexity and number of requests. We reserve the right to impose a reasonable administration fee for complying with a data access request.

You may also contact your local data protection authority for any questions relating to the collection and use of your Personal Information.

The right to lodge a complaint

You have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the country of your habitual residence, place of work, or place of the alleged infringement, if you believe that our processing of your personal information violates applicable data protection laws.

H. Children

Most of our Products and Services (including some of our games) are not directed to Children ("Controlled Products and Services"). WE DO NOT KNOWINGLY COLLECT, SOLICIT, MARKET TO OR REQUIRE THE PERSONAL INFORMATION BELONGING TO CHILDREN. IF YOU ARE BELOW THE MINIMUM APPLICABLE AGE IN YOUR COUNTRY, DO NOT SEND YOUR PERSONAL INFORMATION TO US AND DO NOT USE SUCH CONTROLLED SERVICES. If we obtain actual knowledge that we have collected data from Children, we will promptly delete it, unless we are legally obligated to retain such data.

For the purpose of this Section, by Children, we mean users under the age of 18 years old, or in the case of a country where the minimum age for processing Personal Information differs such different ages. The table below sets out the minimum relevant age specified in Applicable Laws:

We require the parents' and/or legal guardians' personal information to create any user accounts for their Children to access our Controlled Products and Services. Such information may include full name and email address. We may also require the parent's and/or legal guardian's separate consent and acknowledgement to this Policy before allowing the creation of an account and/or access to our Controlled Products and Services.

Parents or legal guardians who are concerned about our use of data are welcome to contact us at support@chillspingame.com.

I.Third party services

Our Products and Services may contain advertisements or links to third-party websites such as X (Formerly known as Twitter), Facebook and/or YouTube. The presence of these links on our Products and Services does not constitute an endorsement, authorization or affiliation with the websites in question. If you click on these links or use the services of a third party, you will leave our Products and Services and you must consult the privacy policy of the website in question before sharing your Personal Information.

Certain products and/or services are offered to you as part of our Products and Services in partnership with third parties and you may be required to provide Personal Information to them in order to register and access their products or services. The identity of these third parties will be indicated at the time of registration. If you choose to register, you will transmit your Personal Information to these third parties and their use of your Personal Information will be subject to their privacy policies.

We are not responsible for the use of your Personal Information by such third parties and we cannot guarantee that they have the same level of data protection policy as us.

J. Conditions of use of our Products and Services

The terms of this Policy are incorporated into our End User Agreement which you may refer to at the following link: https://static.chillspingame.com/agreement.html

K.Changes to the Policy

We are committed to protecting your privacy and being transparent about our data practices. To ensure our Policy accurately reflects how we collect, use, and protect your information, as well as our compliance with evolving privacy laws, we commit to reviewing this Policy at least annually, even if no material changes have occurred.

We reserve the right to change the Policy at any time. If we change the Policy, we will communicate the changes to you through the landing page or other similar page under the Products and Services, or any other appropriate means, for example, by email or with a pop-up notice in our games or on your account page, so that you will be fully informed of such changes. Any changes to the Policy will take effect thirty (30) days after such changes have been communicated to you. Your continued use of our Products and Services will be deemed as an acceptance of the changes to the Policy.

L.Severance

If any part or provision of this Policy is prohibited or deemed to be void or unenforceable, that part or provision shall be ineffective to the extent of such prohibition or unenforceability without invalidating the remaining provisions hereof.

M.Governing Law

This Policy shall be governed by, and construed in accordance with, the laws of Hong Kong Special Administrative Region ("Hong Kong"). Any dispute, controversy, difference or claim arising out of or relating to these Terms and Conditions, including the existence, validity, interpretation, performance, breach or termination thereof or any dispute regarding non-contractual obligations arising out of or relating to it shall be referred to and finally resolved by arbitration administered by the Hong Kong International Arbitration Centre (HKIAC) under the HKIAC Administered Arbitration Rules in force when the Notice of Arbitration is submitted. The seat of arbitration shall be Hong Kong. The number of arbitrators shall be one. The arbitration proceedings shall be conducted in English.

The United Nations Convention on Contracts for the International Sale of Goods do not apply to this Policy.

N. Jurisdiction specific provisions (California, United States of America)

If you are using our Products and/or Services to which this Policy applies from the State of California in the United States of America, the following terms will also apply to you. In the event of any inconsistency between any provision set out in this Section N and the rest of the Policy, the provisions hereunder in Section N will take precedence to the extent as permitted by Applicable Laws.

For the purposes of this section, "personal information" and "sensitive personal information" have the same meanings given in the California Consumer Privacy Act of 2018 ("CCPA").

For detailed information on what categories of Personal Information from or about you or your devices that we collect and disclose over the past twelve (12) months, see section A of this Policy. We collect and disclose your Personal Information for the business and legal purposes as set out in section B of this Policy.

In the past twelve (12) months, we have not sold or shared Personal Information of residents in California within the meaning of "sold" and "shared" in the CCPA, nor do we have any knowledge of any sale or sharing of Personal Information of Users under sixteen (16) years of age.

We do not use or disclose sensitive personal information for any purpose other than to deliver the services reasonably anticipated by the typical consumer who makes a request for those services. In the past twelve (12) months, the following category of sensitive personal information may have been collected from you: in-game chat data.

Your rights as a resident in California include:

· Requesting disclosure, free of charge, of the following information in the past twelve (12) months:

▪ categories of Personal Information that we collect about you;

▪ the business and/or legal purpose for collection;

▪ the categories of sources from which the Personal Information was collected;

▪ the categories of third parties to which we disclose such Personal Information;

· Subject to certain exemptions under the CCPA, requesting the deletion or erasure of the Personal Information collected about you;

· Requesting the correction of inaccurate personal information retained by us about you;

· Be free from unlawful discrimination for exercising your rights under the CPPA.

Pursuant to the requirements of the CCPA, we aim to fulfil all valid requests within forty-five (45) calendar days from the date of receipt of such request.

To exercise your rights under the CCPA, you must provide your notice of request to us via our customer service email address at support@chillspingame.com with a clear statement setting out your request, with details of your name, Account ID, postal address and where applicable, your telephone number, fax number and email address linked to your Account. We may take steps to verify your identity before complying with your request and may decline to fulfil your request if your identity cannot be verified. If you choose to designate an agent to make such requests on your behalf, you must provide us with a proof of written permission. We may require the agent to verify their own identity and to confirm that they have duly obtained your authorization to make the request on your behalf.

O. Jurisdiction specific provisions (Virginia, United States of America)

If you are using our Products and/or Services to which this Policy applies from the Commonwealth of Virginia in the United States of America, the following terms will also apply to you. In the event of any inconsistency between any provision set out in this Section O and the rest of the Policy, the provisions hereunder in Section O will take precedence to the extent as permitted by Applicable Laws.

For the purposes of this section, "personal data" has the same meaning given in the Virginia Consumer Data Protection Act ("VCDPA").

For detailed information on what categories of personal data from or about you or your devices that we collect and disclose, see section A of this Policy. We collect and disclose your personal data for the business and legal purposes as set out in section B of this Policy.

In the past twelve (12) months, we have not sold personal data of residents in Virginia within the meaning of "sale" in the VCDPA, nor do we process personal data for targeted advertising as defined under the VCDPA.

We do not process sensitive data concerning a consumer without obtaining the consumer's consent, or, in the case of the processing of sensitive data concerning a known child, without processing such data in accordance with the federal Children's Online Privacy Protection Act.

Your rights as a resident in Virginia include:

· To confirm whether we are processing your personal data and to access such personal data;

· To correct inaccuracies in your personal data;

· To delete personal data provided by or obtained about you;

· To obtain a copy of your personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format;

· To opt out of the processing of your personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

We aim to respond to your request without undue delay, but in all cases within forty-five (45) days of receipt of such request. That period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day period, together with the reason for the extension.

If we decline to take action regarding your request, we will inform you of our justification for declining to take action and provide instructions on how to appeal the decision. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, along with a written explanation of the reasons for the decisions.

To exercise your rights under the VCDPA, you must provide your notice of request to us via our customer service email address at support@chillspingame.com with a clear statement setting out your request, with details of your name, Account ID, and where applicable, your email address linked to your Account. We may take steps to verify your identity before complying with your request and may decline to fulfil your request if your identity cannot be verified. If you choose to designate an agent to make such requests on your behalf, you must provide us with a proof of written permission. We may require the agent to verify their own identity and to confirm that they have duly obtained your authorization to make the request on your behalf.

P. Jurisdiction specific provisions (Brazil)

If you are using our Products and/or Services from Brazil, the following terms will also apply to you. In the event of any inconsistency between any provision set out in this Section P and the rest of the Policy, the provisions hereunder in Section P will take precedence to the extent as permitted by Applicable Laws, including Brazil's General Data Protection Law (Lei Geral de Proteção de Dados, "LGPD").

For the purposes of this section, "personal data", "sensitive personal data", "processing", "controller", "processor", "anonymized data", and other defined terms have the meanings given in the LGPD. We act as the controller (controlador) of your personal data.

Legal Basis for Processing

We process your personal data in accordance with the LGPD based on one or more of the following legal grounds, as applicable:

1. With your free, informed, and unambiguous consent (consentimento) for specific purposes.

2. For the performance of a contract or preliminary procedures at your request.

3. To comply with a legal or regulatory obligation.

4. For the regular exercise of our rights in judicial, administrative, or arbitration proceedings.

5. To protect your or a third party's life or physical safety.

6. To protect health, exclusively in procedures carried out by health professionals.

7. For our legitimate interests (interesses legítimos), except when your fundamental rights and freedoms prevail.

8. For credit protection purposes.

The specific legal basis for each processing activity is described in Section B of this Policy.

Your Rights as a Data Subject under the LGPD

As a data subject (titular), you have the following rights regarding your personal data:

· Confirmation and Access: To confirm the existence of processing and to access your personal data.

· Correction: To request the correction of incomplete, inaccurate, or outdated data.

· Anonymization, Blocking, or Deletion: To request the anonymization, blocking, or deletion of unnecessary, excessive, or unlawfully processed data.

· Portability: To request the portability of your personal data to another service or product provider, where applicable and technically feasible.

· Deletion of Consent-Based Data: To request the deletion of personal data processed with your consent, subject to legal retention exceptions.

· Information about Sharing: To obtain information about the public and private entities with which we have shared your data.

· Information on Consent Consequences: To be informed about the possibility of denying consent and its consequences.

· Revocation of Consent: To revoke your consent at any time through a facilitated procedure.

· Review of Automated Decisions: To request a review of decisions made solely based on automated processing that affect your interests.

Exercising Your Rights and Our Response

To exercise any of your LGPD rights, you may submit a verifiable request to us via email at support@chillspingame.com. We will respond to your request without undue delay and within the timeframe required by applicable law. We may request information necessary to confirm your identity.

The exercise of your rights is free of charge, except in cases of manifestly unfounded or excessive requests.

Q. Communicate with Us

"Data Controller" means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Data is, or will be, processed. For the purpose of this Policy, we are a Data Controller of your data. For the purpose of establishing the Personal Data protection in a better and more efficient way, we, as the Data Controller, designate a Data Protection Officer (in short, "DPO") who is responsible for the oversight and implementation of the Personal Data protection strategy and ensures our processing of Personal Data is in compliance with necessary legal requirements stipulated in the applicable laws. If you have any comments, questions or concerns with respect to our Privacy Policy or Personal Data protection practices, please contact our DPO Chloe at support@chillspingame.com.

Name: CHILLSPIN GAME LIMITED

Address: Rm WS-8(E7) 11/F WALNUT 9 9 WALNUT ST Tai Kok Tsui, Kowloon Hong Kong

Tel: +852 56352895

Email: support@chillspingame.com