Effective Date: 25th May, 2018

99Games Online Private Ltd., hereinafter referred as “99Games”, “We”, “Us” is a “Data Controller”, which means we are responsible for deciding how we hold and use Personal Data about you. We Thank you for playing our games. Your privacy is most significant to us, and we deem it as our duty to care for it seriously; therefore, we conduct our business in compliance with applicable laws on data privacy protection and data security. We hope the policy outlined below will help you understand what data 99Games may collect, how 99Games uses and safeguards that data and with whom we may share it. We at 99Games publish games on the iOS, Android, Windows, Facebook Gameroom and Mac platforms, which include Star Chef, Star Chef 2, Fantastic Chefs, Dhoom:3 The Game, Fan: The Game, Dream Star, Sultan: The Game, Words Worth etc. 99Games is committed to respect the privacy of all visitors/users of its Website, mobile applications and other online products and services (collectively, the "Services").

PRIVACY QUESTIONS, ACCESSING AND UPDATING YOUR INFORMATION

If you have questions about data protection, or if you have any requests for resolving issues with your personal data, we encourage you to primarily contact us through the game so we can reply to you more quickly. If you wish to access, update, or delete your PII, please reach out to us at privacy@99games.in. We may ask you to verify your identity before we can act on your request. In some cases, we may have to keep that information for legitimate business or legal purposes.
If you have questions pertaining to In-App Purchases, requesting a refund or Reporting a problem and issues regarding to the same in Android platform you are advised to contact 99Games through game or email within 48hrs of the cause of action, details refer AUTO RENEWABLE SUBSCRIPTIONS sub header below.
email: privacy@99games.in

COLLECTION OF PERSONAL / NON-PERSONAL INFORMATION

Data you provide us

• Contact information (such as name and email address through which you have logged in)
• Your messages to the Service (such as chat logs etc)
• Whichever you have disclosed through support mail.

Data we collect automatically

• Data about your account and game progress
• Your IP address and mobile device identifiers such as your device ID, advertising ID (also called Ad ID, GAID or IDFA), MAC address.
• Data about your device, such as device name and operating system, browser type and language
• Data we collect with cookies and similar technologies (see more below)
• Data about your use of the Service, such as gameplay data and your interactions with other players inside the Service
• Data about Crash Logs and Diagnostics to ensure our apps run optimally on a vast range of devices. We collect Diagnostics Information about the performance of the app on the device - For example, battery life, loading time, latency, framerate, or any technical diagnostics.

In all cases, we also create a Unique ID and Encrypted ID for you when you use the Service.

Data we collect from our partners

• Data we receive if you link a third-party tool with the Service (such as Facebook, Google etc)
• Data from platforms that the games run on (such as to verify payment)
• Data for advertising and analytics purposes, so we can provide you a better Service

WHY WE COLLECT PERSONAL / NON-PERSONAL INFORMATION

To make the Service work

To perform the contract, we process data necessary to

• Create accounts and allow you to play our games and use our Service
• Verify and confirm payments
• Provide and deliver the products and services you request

To make the Service more suitable for our players

To provide a great Service to our players, we have a legitimate interest to collect and process necessary data to

• Develop and improve the Service and player experience
• Update and develop player profiles
• Manage our relationship with you
• Provide social features as part of the Service
• Respond to your comments and questions and provide player support
• Enable you to communicate with other players

To show personalized ( targeted ) advertisements

To show you personalized ( targeted ) advertisements in the Service as well as in other websites and services we have a legitimate interest to process necessary data to

• Track the content you access in connection with the Service and your online behaviour
• Deliver, target and improve our advertising and the Service

For information on how to opt-out from personalized ( targeted ) advertisements, see section 'Your rights and options' below.

If you live in the USA (United States) , Canada or Europe, you can also opt-out from the collection of your data by our advertising partners who participate in the Digital Advertising Alliance, by visiting https://aboutads.info/choices (for United States users), https://youradchoices.ca/choices (for Canadian users), https://youronlinechoices.eu(for European users).

To keep the Service safe and fair

Ensuring a level playing field in the Service is a top priority for us. For more information on our acceptable use policy, see the 99Games Terms of Service. In order to keep the Service and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to

• Analyse and monitor use of the Service and its social features
• Moderate chats either automatically or manually
• Take action against fraudulent or misbehaving players

To analyse, profile, and segment

In all of the above cases and purposes, we may analyse, profile and segment all collected data.

With your consent

With your consent, we may process your data for explicit additional purposes. One example for this is using Read_External_Storage and Write_External_Storage permissions for requesting screenshots (photos) and screen recordings (videos) from players that Contact us for Support via the HelpShift Tool. Another example is using the Read_Phone_State within Contacts Data Category - our Advertising partner(Applovin) uses this to detect if a call is received while a player is watching a Rewarded Video, and to mute the video in such situation to allow user to take the call. We or Applovin do not collect or share your Phone Number in any situation.

DISCLOSURE OF PERSONAL/NON-PERSONAL INFORMATION

Apart from 99Games, your data can be accessed by others in the following situations:

Other players and users

Social features are a core component of our games. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted.

Partners working for 99Games

99Games has partners to perform services for us. These partners process your data only at and according to 99Games instructions to provide the Service, such as hosting, player support, advertising, analytics and fraud prevention.

Other companies and public authorities

In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests. We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.

Advertising and Social Media partners

The Service includes features from our partners, such as social media interaction tools and in-game advertising. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.

GDPR CLASSIFICATIONS

Many types of data we process qualify for multiple legal bases for processing under the General Data Protection Regulation (GDPR). Below is the primary legal basis for each type of data that we process:

• We have a legitimate interest in conducting analytics, measurement of usage and conversions, and game telemetric to improve our services. We and our processors have multiple measures in place to minimize the privacy impact.
• We have a legitimate interest in storing users’ purchase history for the purpose of providing users help in fixing purchase and payment issues.
• We have a legitimate interest in enabling third party ads and data collection on our sites and apps to help provide a more customized ad experience for our users and site visitors. Our reputable partners provide opt outs and numerous other privacy measures to minimize the privacy impact of online ads.
• We have a legitimate interest in periodic email and direct marketing, to inform registered users of updates and offers. We make clear disclosures when users sign up and offer opt outs for anyone not interested.

It is contractually necessary to process your username, email, password, cookie data, IP address, game network IDs, game information and similar information to fulfil our obligations in the terms of service to provide you with high quality games and a social game network from ourselves and our partners.

INTERNATIONAL DATA TRANSFERS

Our Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy.

DATA RETENTION

We will process your personal data only for as long as necessary for the purposes for which it was collected in connection with your business relationship with us, unless we are legally required or entitled to retain the data for a longer period, or if it is necessary for establishing, exercising, or defending legal claims.

Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and are free to securely delete it for any reason and at any time, with or without notice to you.

In some circumstances, we may anonymize your Personal Data so that it can no longer be associated with you, in which case we may use such information without further notice to you and it is no longer considered Personal Data within the meaning of this Privacy Policy.

YOUR RIGHTS AND OPTIONS

Opt-out of targeted advertising

You can opt-out of interest-based advertising on mobile applications by writing to us on privacy@99games.in checking the privacy settings of your Android or iOS device and selecting "limit ad tracking" (Apple iOS) or "opt-out of interest-based ads" (Android).

We do not carry out any decision-making based solely on automated processing, including profiling.

We do not collect sensitive personal information.

Access the personal data we hold about you

You have a right to know what information we hold about you and, in some cases, to have the information communicated to you. If you wish to exercise this right please contact us letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information, and the law permits us to charge a fee for exercising this right of access. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will endeavour to tell you why. We will try to respond to any request for a right of access as soon as possible, but we will always do so within 40 days of receipt of your request, evidence of ID and any applicable fee.

Right to correct personal information

We try to keep the information that we hold about you accurate and up to date. Should you realise that any of the information that we hold about you is incorrect, please let us know at privacy@99games.in and we will correct it as soon as we can.

Data deletion

In some circumstances you have a right to have some of the personal information that we hold about you deleted. Should you wish to have any information about you deleted, please contact us using the information below. Please note that to ensure that we do not collect any further information you should also delete our games from your mobile devices and clear our cookies from any device where you have played our games in a web browser. Where we delete personal information about you, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity. We may also retain your information in an anonymised form.

Account deactivation

If you have created an account with us, you can ask us to deactivate that account by contacting us using the information above. We may ask you for other information before we are able to deactivate your account. That information might include information about your mobile device. Other steps you should take should you wish to completely deactivate your account include disassociating your Facebook account from our mobile games and deleting our games from your mobile devices. Please note that if you completely deactivate your account all your progress in our games and any unspent virtual items, will be lost and we may not be able to restore them in the future.

Lodge Complaint

Without prejudice to any other administrative or judicial remedy, every data subject shall have the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, place of work or place of the alleged infringement if the data subject considers that the processing of personal data relating to him or her infringes this Regulation. The supervisory authority with which the complaint has been lodged shall inform the complainant on the progress and the outcome of the complaint including the possibility of a judicial remedy pursuant to Article 78.

Additional Information for the United States Residents

In this section, we provide additional information about how we handle personal data about California, Virginia, Utah, Colorado and Connecticut residents as required by the privacy laws of those states including the California Consumer Privacy Act as amended by the California Privacy Rights Act (CPRA) (collectively “CCPA”), the Virginia Consumer Data Protection Act (VCDPA), the Minnesota Consumer Data Privacy Act (MCDPA), the Texas Data Privacy and Security Act (TDPSA), the Oregon Data Privacy Law (OCDPA), the Utah Consumer Privacy Act (UCPA), the Colorado Privacy Act (CPA) and Connecticut Personal Data Privacy and Online Monitoring Act (COMA). This section does not address or apply to our handling of publicly available information lawfully made available by state or federal government records or other personal information that is exempt under the mentioned acts.

In general, the residents of California, Virginia, Minnesota, Texas, Oregon, Utah, Colorado and Connecticut have the following rights with respect to their personal data:

• Do-not-sell (opt-out): to opt-out of our sale of your personal data. While we may “sell” personal data as defined by the applicable laws, we do not sell personal data about our consumers who we know are younger than 16 years old.
• Right to delete: to request deletion of the personal data that we have collected about you and to have such personal data deleted (without charge), subject to certain exceptions.
• Right to correct: to request correction of any inaccurate personal information that we hold about you.
• Right to non-discrimination: the right not to be subject to discriminatory treatment for exercising your rights.

Additional Rights of California Residents.

Right to know: to require that we disclose the following to you:

• Categories of personal data collected;
• Categories of sources of personal data;
• Categories of personal data about you we have disclosed for a business purpose or sold;
• Categories of third parties to whom we have sold or disclosed for a business purpose your personal data;
• the business or commercial purposes for collecting or selling personal data; and
• a copy of the specific pieces of personal data we have collected about you.

Right to access information and opt-out of automated decision-making technology: we do not carry out any decision-making based solely on automated processing, including profiling. Right to limit use and disclosure of sensitive personal information: we do not collect sensitive personal information.

Additional Rights of Virginia, Utah, Colorado and Connecticut Residents

• Right to opt-out of the processing of personal data for targeted advertising and profiling, subject to certain exceptions.
• Right of access: to confirm whether we process your data.
• Right to data portability: to request a copy of your data in a format that is easy to move from one service provider to another, subject to certain exemptions. You can make this request up to two times per year.

Submitting Requests. California, Utah, Virginia Colorado and Connecticut residents may exercise their right by emailing us at privacy@99games.in When you submit any request, we will take steps to verify your request by asking you some questions about the in-game experience (such as current level, the name of the virtual items added etc) and matching the information provided by you with the information we have in our records. You must answer the questions to verify your request. In some cases, we may request additional information in order to verify your request or when necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents may initiate a request on behalf of another individual by contacting us at privacy@99games.in. Authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

Additional Rights of Brazil Residents.

We comply with the requirements of the Lei Geral de Proteção de Dados (LGPD) as detailed here - https://www.lgpdbrasil.com.br/wp-content/uploads/2019/06/LGPD-english-version.pdf. You can exercise these rights by contacting us at privacy@99games.in.

Additional Rights of South Korea Residents.

We comply with the requirements of the Personal Information Protection Act (PIPA, Korean: 개인정보 보호법) as detailed here - https://www.pipc.go.kr/eng/index.do. You can exercise these rights by contacting us at privacy@99games.in.

Additional Rights of South Africa Residents.

We comply with the requirements of the Protection of Personal Information Act (POPIA) as detailed here - https://popia.co.za/. You can exercise these rights by contacting us at privacy@99games.in.

Additional Rights of Japan Residents.

We comply with the requirements of the Protection of Personal Information (APPI, Act No. 57 of 2003) as detailed here - https://www.cas.go.jp/jp/seisaku/hourei/data/APPI.pdf. You can exercise these rights by contacting us at privacy@99games.in.

Additional Rights of India Residents.

We comply with the requirements of the India Digital Personal Data Protection Act 2023 (DPDPA) as detailed here - https://www.meity.gov.in/writereaddata/files/Digital%20Personal%20Data%20Protection%20Act%202023.pdf. You can exercise these rights by contacting us at privacy@99games.in.

COOKIES AND SIMILAR TECHNOLOGIES

Like most online services, we and our partners use cookies and similar technologies to provide and personalize the Service, analyse use, target advertisements and prevent fraud. You can disable cookies in your browser settings, but some parts of the Service may then not function properly.

HOW DO WE PROTECT YOUR DATA

Security Safeguards

In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.

Data retention

We retain your data for as long as your account is active or as needed to provide you the Service. We will for example periodically de-identify unused game accounts and we regularly review and de-identify unnecessary data.
Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

LINKS TO NON-99GAMES WEBSITES

We may also provide you with general links to non-99Games websites. Your use of these links is subject to the third parties' privacy policies, and you should become familiar with the third-party sites' privacy policies before using the links. 99Games is not responsible for the privacy practices or the content of those other websites.

AGE LIMITS

We do not knowingly collect or solicit personal data about or direct or target interest-based advertising to children or knowingly allow such persons to use our Services. 99Games will not knowingly collect personal data from children without insisting that they seek prior parental consent if required by applicable law. We will only use or disclose personal data about a child to the extent permitted by law, to seek parental consent pursuant to local law and regulations or to protect a child. The definition of "child" or "children" should take into account applicable laws as well as national and regional cultural customs.

AUTO-RENEWABLE SUBSCRIPTIONS

99Games outlines an auto-renewable subscription as one that allows a user to purchase dynamic content for a set period of time. Once that set period of time ends, the subscription renews again for the same amount of time. This continues until the user cancels the subscription. These subscriptions services allow users to choose their plan and the frequency of renewal. After the user makes a choice of a subscription, 99Games requests the user to approve it. When the subscription starts, it is recorded under the user’s ID. Respectively subscription displays the date of renewal and the term. After listed, cancellation is easy. All a user needs to do is open up the particular subscription under manage subscription and hit “cancel subscription”.
In case of any queries relating to the requesting a refund or Reporting a problem relating to auto renewable subscriptions in Android platform, he is being strictly advised to contact 99Games within 48hours of the issue/query, delaying to which the user may be refunded with only in-game virtual items not the money/amount.
For further more details, explanation and clarity on the same the user is advised to refer https://support.google.com/googleplay/answer/2479637

LOCATION

Geolocation information (location at City, State or Country level only), collected from you and our analytics and advertising partners, will be shared with our service providers for the purpose of aggregated Analysis, Personalized In-Game offers and In-App Advertising. We collect general location information about a particular individual or device and do not collect or process precise geolocation data.

LEGAL USES

We may use your data as required or permitted by any applicable law. As a specific example, if you live in the European Union, this would include for the purpose of providing VAT invoices where we are required to do so by law or where requested by you.

GRIEVANCE REDRESSAL MECHANISM

Any complaints or request or concerns with regards to use, processing or disclosure of information provided by you or breach of these terms may be taken up with the designated grievance redressal officer as mentioned below via post or by sending an email to privacy@99games.in

Grievance Redressal Officer (DPO):

Any complaints, abuse or concerns with regards to content and or comment or breach of these terms shall be immediately informed to the designated Grievance Officer ( Data Protection Officer ) as mentioned below via in writing or through email signed with the electronic signature to.
Name: Gururaja Bhat
Email: privacy@99games.in
99Games Online Private Limited
1st Floor, Mahalakshmi Towers, Court Road
Udupi- 576101, Karnataka, India.
Phone: +91 820 2583800

99Games request you to please provide the following information in your complaint:
a) Identification of the information provided by you.
b) Clear statement as to whether the information is personal information or sensitive personal information.
c) Your address, telephone number or e-mail address.
d) A statement that you have a good-faith belief that use of the information has been processed incorrectly or disclosed without authorization.
e) A statement, that the information in the notice is accurate, and that you are authorized to act on behalf of the owner of the right that is allegedly infringed.
99Games may reach out to you to confirm or discuss certain details about your complaint and issues raised, 99Games shall not be responsible for any communication, if addressed, to any non-designated person in this regard.

UPDATES TO THIS PRIVACY STATEMENT

99Games may update this policy from time to time, so please review it frequently. We'll notify you of material changes via a notice on our home page (99games.in). Your continued use of our products means you accept the changes. Once you accept this policy, we will not enforce future changes we deem in good faith to be material absent your express agreement to the changed terms.

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