PRIVACY POLICY

Last modified: November 13, 2021

1.Who We Are

1.1We are R Foundation, a company, located at 172 Lord lane, Failsworth, Manchester M35 0QS (“R Foundation” or “We”). We develop and

distribute our games throughout the world in cooperation with other companies operating pursuant to a contract with WEBREN LTD.

1.2This Privacy Policy sets out how we collect and use your personal information when you play our games or otherwise access any of our other products, services, content, crpgame.com, and other domains provided by R Foundation (“Services”) and the choices available to you in connection with our use of your personal information (the “Privacy Policy”).

This Privacy Policy should be read alongside, and in addition to, our Mobile Application End User License Agreement (“EULA”). In case of any contradictions between this Privacy Policy and the EULA, this Privacy Policy will prevail.

1.3This Privacy Policy describes:

a.what types of information we may collect or that you may provide;

b.how we process, store, and use the information and with whom we share it;

c.how you can access and update that information or request its deletion;

d.the choices you can make about how we collect, use, and share your information;

e.how we protect the information we store about you.

This Privacy Policy does not apply to any third party websites, services, or applications, even if they are accessible through any of our Services.

By downloading, accessing and/or playing our games, or interacting with our websites or other Services, you agree to the collection and use of your information in accordance with this Privacy Policy, including consenting to R Foundation’s and our advertising partners’ use of your data for targeted advertising purposes as described in the Marketing and Advertising sections of this Privacy Policy. If you

have any concerns about providing data to us or having it used in any manner permitted in this Privacy Policy, you should not use our Services. As set out in the EULA, you must be at least 13 years old to access and/or use our Services.

2.This Privacy Policy

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

a.have all necessary rights to register on and use the Services;

b.provide true information about yourself to the extent necessary for use of the Services;

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

d.are aware of and accept this Privacy Policy.

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

3.Information We Collect and How We Collect It

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

3.2Details about the information we collect when you use our Services, why we collect and process it, and the legal bases are set forth below.

Information Collected

 

 

 

Purpose

 

 

 

 

Legal Basis

Unique Player ID, which is

We use this information in order

to

Legitimate interests

automatically

created

for

you by

manage and

administer

the Services

Performance of our

our

game

server

when you

first

provided to you, identify your in-game

contract with you

start using the Services.

 

 

 

actions, track your progress, and

 

 

 

 

 

 

 

 

 

 

 

 

 

 

match your purchases to your account.

 

 

 

 

 

 

 

 

 

 

 

We use this data to enable us to fulfill

 

 

 

 

 

 

 

 

 

 

 

our obligations to you as part of the

 

 

 

 

 

 

 

 

 

 

 

Services (e.g. in cases where you

 

 

 

 

 

 

 

 

 

 

 

request restoration of your account

 

 

 

 

 

 

 

 

 

 

 

and progress or contact us to correct

 

 

 

 

 

 

 

 

 

 

 

errors with in-game purchases).

 

 

 

 

 

 

 

Your nickname if you choose to

We provide you with the option

to

Legitimate interests

create one.

 

 

 

 

 

 

 

create a nickname that is then matched

Performance of our

 

 

 

 

 

 

 

 

 

 

with your game profile for purposes of

 

 

 

 

 

 

 

 

 

 

contract with you

 

 

 

 

 

 

 

 

 

 

in-game competitions between players

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

and for leaderboards.

 

 

 

 

 

 

 

 

 

 

 

Additional

 

data

 

received

We use your data for internal review

Legitimate interests

automatically when you access the

and game analytics in order to

 

Services, whether on a mobile

constantly improve the content of our

 

device or on a computer, including

Services,

optimize

your

user

 

information

about

your

device,

experience, understand any errors you

 

such as your IP-address, device IDs

may encounter when using the

 

(MAC

Address,

Identifier

For

Services, prevent fraud, notify you of

 

Advertising

(IDFA),

Google

changes to the Services, and

 

Advertising

ID (GAID),

unique

personalize your use of our Services.

 

device

identifier

(UDID),

and/or

We

use this

information

in order

to

 

International

Mobile

Equipment

 

tailor and improve the advertisements

 

Identity (IMEI), and unique IDs for

 

that may be presented to you within

 

push

notifications),

country

and

 

the

Services and measure

 

the

 

language

settings,

 

device

model

 

 

 

effectiveness of these advertisements,

 

and

operating system

used,

your

 

as described in more detail below.

 

 

 

installed apps, type of browser,

 

 

 

 

 

 

 

 

 

 

your Internet provider and/or phone

 

 

 

 

 

 

 

network

operator,

network

type,

 

 

 

 

 

 

 

screen resolution, RAM size and

 

 

 

 

 

 

 

your browsing behavior.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

2

Details about your usage of the

 

We use your data for game analytics

 

Legitimate interests

Services, such as the date and time

 

and in order to constantly improve the

 

 

 

you installed our game or Service,

 

content of our Services, optimize your

 

Performance of our

the date and time you accessed our

 

user experience, understand any errors

 

game or Service, your game

 

you may encounter when using the

 

contract with you

progress and various in-game

 

Services, prevent fraud, notify you of

 

 

 

activities, such as, for example,

 

changes to the Services and

 

 

 

spending in-game currencies, and

 

personalize the use of our Services.

 

 

 

system and game error reports.

 

 

 

We also use your data to provide you

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

with customer support should you

 

 

 

 

 

 

 

 

 

 

 

 

encounter any problems with our

 

 

 

 

 

 

 

 

 

 

 

 

Services.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Additional

information

that

you

 

We use your data for game analytics

 

Legitimate interests

provide

to

us

when you enter

a

 

and in order to constantly improve the

 

Performance of our

promotion or

contest or

report

an

 

content of

our

Services,

optimizing

 

 

 

contract with you

issue with the Services to us.

 

 

 

your user experience, and to

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

understand any errors you may

 

 

 

 

 

 

 

 

 

 

 

 

encounter when using the Services.

 

 

 

 

 

 

 

 

 

 

 

 

 

Information

that is

automatically

 

crpgame.com

and

Game-

 

Consent

 

received at the time of access to the

 

crpgame.com use cookies solely to save

 

 

 

Services with the use of cookies.

 

 

your language preference and do not

 

 

 

 

 

 

 

 

 

 

 

 

use any type of third-party cookies or

 

 

 

 

 

 

 

 

 

 

 

analytics.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Limited

payment

information

if

 

We use this information to resolve any

Legitimate interests

you make

 

in-game

purchases

 

errors that

may

occur with payment

Performance of our

within our Services, such as unique

 

processing

through the

appropriate

 

contract with you

transaction ID, date and time of

 

store or platform to ensure that your

 

 

 

payment, and the payment amount.

 

purchase can be applied to your

 

 

We do not receive or store any

 

account.

 

 

 

 

 

 

billing

and

payment information

 

 

 

 

 

 

 

 

that you provide when your

 

 

 

 

 

 

 

 

purchase is processed by a mobile

 

 

 

 

 

 

 

 

app store (such as Apple or

 

 

 

 

 

 

 

 

Google) or by a social network

 

 

 

 

 

 

 

 

(such as Facebook).

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Information that is created by you

 

We use this information in order to

Legitimate interests, which

while using the Services (if there is

 

manage and administer the Services

inter alia,

include the

such technical possibility in the

 

including providing our services to

processing of data that you

Services). This information can be

 

you.

 

 

 

 

expressly

made public

available to some or all other users

 

 

 

 

 

 

where it is accessible by

of our Services.

 

 

 

 

 

 

 

 

 

 

other users of the Services.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Performance of our

 

 

 

 

 

 

 

 

 

 

 

 

 

 

contract with you

 

 

 

 

 

 

 

 

 

Information

submitted

by

you

 

We use this information

in order to

Legitimate interests

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

3

while

requesting assistance

from

verify your identity and to fulfill your

Performance of our

our customer support, such as your

support request.

 

 

 

 

 

contract with you

name

and

e-mail address,

data

We may also use this data in order to

 

about your game play and activity

 

investigate any

complaints

on

your

 

on our Services, your player and/or

 

behalf and to provide you with a more

 

social

network

ID

number,

and

 

efficient service.

 

 

 

 

 

 

other information that may be

 

 

 

 

 

 

We will also store all your

 

requested by our customer support

 

team in order to assist you, such as

communications

with

our

customer

 

screenshots or payment transaction

service team and any information in

 

IDs.

 

 

 

 

 

 

those communications in order to

 

 

 

 

 

 

 

 

provide support.

 

 

 

 

 

 

 

 

 

 

 

 

 

For your convenience, we provide the

 

 

 

 

 

 

 

 

option of contacting our customer

 

 

 

 

 

 

 

 

support from the mobile applications

 

 

 

 

 

 

 

 

and the desktop Services. If you

 

 

 

 

 

 

 

 

choose to use our in-Service interface,

 

 

 

 

 

 

 

 

some information will be added to

 

 

 

 

 

 

 

 

your support ticket automatically, such

 

 

 

 

 

 

 

 

as your unique player ID assigned to

 

 

 

 

 

 

 

 

you when you downloaded the game,

 

 

 

 

 

 

 

 

platform, and information about your

 

 

 

 

 

 

 

 

operating system, your device or

 

 

 

 

 

 

 

 

desktop computer, and your screen

 

 

 

 

 

 

 

 

size.

 

 

 

 

 

 

 

 

 

 

 

 

Data collected via third parties,

We use this information in

order to

Legitimate interests

including your social network IDs,

manage and

administer the Services

Performance of our

application store IDs, first and last

provided to you and to allow you to

contract with you

name, photo, nickname, friends list,

synchronize

your

game

progress

 

when you choose to log into our

across multiple devices.

 

 

 

 

Services

via

your

social

or

We use

this

information for certain

 

application

store

accounts

(Apple

 

social functions of our Services, such

 

Game Center, Google Play Game

 

as to show you your friends who play

 

Services, or Amazon Game Circle)

 

the same

game(s)

as

you

and

their

 

and/or connect your social account

 

progress

and

to

allow

you

to

invite

 

to our

Services

(e.g. Facebook,

 

friends to play or send them in-game

 

Twitter). We will

also

receive

 

gifts.

 

 

 

 

 

 

 

 

access to your e-mail address, if the

 

 

 

 

 

 

 

 

We also use this information in order

 

social media platform shares it, but

 

we will not store it.

 

 

 

to provide you with updates and

 

 

 

 

 

 

 

 

information on our and selected third

 

 

 

 

 

 

 

 

parties’ products and services in which

 

 

 

 

 

 

 

 

we think you may be interested.

 

 

 

 

 

 

 

 

 

You can control what information is

 

 

 

 

 

 

 

 

shared with us from your social media

 

 

 

 

 

 

 

 

account by reviewing the privacy

 

 

 

 

 

 

 

 

controls on the appropriate third party

 

 

 

 

 

 

 

 

network. We recommend that you

 

 

 

 

 

 

 

 

review the social

network’s privacy

 

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policy to learn more about the information they share with us and other developers and the choices you can make to limit the accessible information.

3.3Our legitimate interests include the following: (1) maintaining and administering the Services;

(2)providing the Services to you; (3) improving the content of the Services and our web pages;

(4)processing the data that you expressly made public; (5) ensuring your account is adequately protected; and (6) compliance with any contractual, legal, or regulatory obligations under any applicable law.

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

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

3.7Please note, if you do not want us to process sensitive and special categories of data about you (including data relating to your health, racial or ethnic origin, political opinion, religious or philosophical beliefs, sex life, and your sexual orientation) you should take care not to post this information or share this data within our Services. Once you have provided this data it may be accessible by other users and it becomes difficult for us to remove this data.

3.8Please note, if you withdraw your consent to processing or you do not provide the data that we require in order to maintain and administer the Services, you may not be able to access the Services.

3.9If we intend to further process your data for any purpose other than the purposes set out in this Privacy Policy, we shall provide you with details of this further purpose before we commence processing.

3.10Marketing and Advertising

Our games and Services may include advertising for third party products and services, and we, or

our third party partners, may send you marketing communications about other R Foundation games and related services based on your interests. For example, we may serve ads within our games and Services or place ads on third party websites or apps. Unless you opt out as explained below, you consent to us and our advertising partners collecting and using information about you to improve marketing and advertising so that we can show you relevant third party ads in our games or Services.

We and our third party partners use ad identifiers, such as ID for Advertisers (IDFA), Google Advertising ID (GAID), or unique device identifier (UDID), and other information collected from your devices, social networks, and provided by you to offer you ads that may be relevant to you within our games and Services.

When you play our games or use our Services, the ad identifiers and other information from your device is collected and shared with advertising partners to enable the delivery of ads to your device. Our marketing and advertising partners may combine such information with data they collected from you elsewhere (for example when you used their services) and use it to serve you more relevant ads or to improve the accuracy of their targeting and measuring systems.

By playing our games and using our Services, you consent to the collection and use of your data for targeted advertising purposes by our partners as set forth in this Privacy Policy and our partners’

policies, including, but not limited to the following: Facebook, Google Ads, Firebase, Adjust. You

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can refuse or withdraw your consent to such use at any time by preventing your device’s ad identifier being used for interest-based advertising by updating your device’s settings.

Opting out of interest based advertising and marketing will not prevent you from being able to play our games or use our Services and will not disable the advertising within the games or Services, but such ads will no longer be targeted based on the information that we hold about you. The ads may still be based on the game you are playing or the Service you are using or the region in which your device is located.

4.Data Sharing

4.1We take technical and organizational measures to ensure that your data is safe. Please note that by posting your personal information (if there is such technical possibility in the Services) you have expressly made this information public, and it may become available to other Service users and Internet users and be copied and disseminated by them.

4.2We may share your data with our affiliates, contractors, and service providers, who are subject to contractual confidentiality obligations no less restrictive than our obligations to you under this Policy. Sometimes we may also need to share your data with a third party in order to provide our Services to you or to administer the Services, for example if you choose to share your data across other social media platforms.

4.3Our Services, games or their purchase pages may display an “offer wall” that is hosted by an offer wall provider. The offer wall allows third party advertisers to provide virtual currency to you as a player in exchange for interacting with an advertisement or completing a marketing offer that may include signing up for an account with one of those advertisers. These offers are not made by us. These offers may be made available to you based on certain technical information, like your geographic area or de- identified demographic information. To properly credit your player account and to prevent fraud, a unique

identifier, in some cases your social network ID or player ID, will be shared with the offer

wall provider.

5.Privacy Settings

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

5.2We will not be liable for the actions of third parties who may obtain access to your information as the result of your use of the Internet or the Services and in accordance with the confidentiality level selected by you.

5.3We will not be liable for the consequences of use of the information which, due to the nature of the Services, is available to any Internet user. We ask you to take a responsible approach to the amount of information you choose to share publicly through our Services.

6.International Transfers

We may transfer and maintain on our servers or databases some of your personal information in

different countries worldwide, including outside of the European Union and take

reasonable cyber security measures to ensure your data is adequately protected.

7.Retention Periods

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

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so long as your account is active, and we deem an account to be active for a period of 60 months from the last interaction with our games or Services.

7.2We may remove your account, or the information you post as provided by the EULA.

8.Your Rights

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

a.Right to access your personal information;

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

c.Right to restrict the use of your personal information;

d.Right to request that your personal information is erased;

e.Right to object to processing of your personal information;

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

g.Right not to be subject to an automated decision;

h.Right to lodge a complaint with a supervisory authority.

8.2We strive to provide you with choices regarding the personal information you provide to us. Here are some of the mechanisms we provide for you to control certain uses and disclosures of over your information:

a.Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Services may then be inaccessible or not function properly.

b.Information from Social Networks. To manage the information R Foundation receives about you from a social network, like Facebook, where you play our games or with which you link a game on your mobile device, you will need to follow the instructions on that site for updating your information and changing your privacy settings.

c.Information from Your Mobile Device. You can manage some aspects of information collection and use by visiting the “settings” menu of your mobile device and reviewing the permissions for each application or “app.”

8.3If you want to review, delete, or change the information R Foundation has about you or have additional questions, e-mail us at info@crpgame.com. We will aim to respond to you within period established by applicable law. We will need to verify your identity before we are able to disclose any

personal data to you. Please note that certain records, for example those related to customer service matters, will be held for legal and accounting purposes.

9.Security Measures

9.1We take technical, organizational and legal measures, including, where suitable, encryption, to ensure that your personal data is protected from unauthorized or accidental access, deletion, modification, blocking, copying and dissemination. We will take reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy by us and our suppliers who process personal information on our behalf.

9.2Unfortunately, the transmission of information via the Internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee

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the security of your personal information transmitted through our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

10.Our Policies Concerning Children

Our Services and websites are not intended for children under 13 years of age, and we do not knowingly collect personal information from children under 13. Children under 13 should not use our websites or games at any time. If we learn we have inadvertently collected or received personal information from a child under 13, we will take reasonable measures to promptly remove that information from our records. If you believe we might have any information from or about a child under 13, please

contact us at info@crpgame.com.

11.Changes to this Policy

11.1From time to time, we may change and update this Privacy Policy. If this Privacy Policy changes

in any way, we will post an updated version on this page. We will store the previous versions of this Privacy Policy in our documentation archive. We recommend you regularly review this page to ensure

that you are always aware of our information practices and any changes in our practices.

11.2Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

12.Contact Us

12.1 If you have any questions, please send your inquiries to Service support at info@crpgame.com

. So we can deal with your enquiry effectively, please quote this Privacy Policy. We will aim to respond to you within period established by applicable law.

12.2All correspondence received by us from you (written or electronic inquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data

and other information about you may not be used without your consent for any purpose other than for response to the inquiry, except as expressly provided by law.

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