IMPORTANT PRIVACY INFORMATION

hen you use the App we automatically collect from your device language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, Facebook ID, and other unique identifiers (such as IDFA and AAID). We need this data to provide our services, analyze how our customers use the App, to serve ads.

For improving the App and serving ads, we may share this data with third parties. Such parties include Apple, Google, Appsflyer, Amplitude, Applovin, Firebase, Facebook, Unity Analytics As a result of sharing this data with third parties we (1) analyze different interactions; (2) serve ads (and show them only to a particular group of users)

Please read our Privacy Policy below to know more about what we do with data (Section 3), what data privacy rights are available to you (Section 6), who will be the data controller (Section 1) and how to opt out or influence personalized advertising. If any questions will remain unanswered, please contact us at info@universeapps.limited

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PRIVACY POLICY

TABLE OF CONTENTS

1. PERSONAL DATA CONTROLLER
2. CATEGORIES OF PERSONAL DATA WE COLLECT
3. FOR WHAT PURPOSES WE PROCESS PERSONAL DATA
4. UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)
5. WITH WHOM WE SHARE YOUR PERSONAL DATA
6. HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS
7. AGE LIMITATION
8. INTERNATIONAL DATA TRANSFERS
9. CHANGES TO THIS PRIVACY POLICY
10. CALIFORNIA PRIVACY RIGHTS
11. DATA RETENTION
12. HOW “DO NOT TRACK” REQUESTS ARE HANDLED
13. CONTACT US

• 1.PERSONAL DATA CONTROLLER

GM UniverseApps Limited, a company incorporated under the laws of Cyprus, having its mailing address at 26 Stavrou Street, Strovolos 2034, Nicosia, Cyprus will be the controller of your personal data.

• 2.CATEGORIES OF PERSONAL DATA WE COLLECT

We collect data automatically (for example, your IP address, device type, etc.).

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1. Data provided to us by third parties

We may receive data about you from third parties (for example, when you sign in via Facebook).

When you decide to log in using Facebook, we get personal data from your Facebook account. This includes your profile image, name, and Facebook ID.

For more information, please refer to the Facebook Permissions Reference (describes the categories of information, which Facebook may share with third parties and the set of requirements) and to the Facebook Data policy. In addition, Facebook lets you control the choices you made when connecting your Facebook profile to the App on their Apps and Websites page.

2. Data we collect automatically:
1. Data about how you found us

We collect data about your referring app or URL (that is, the app or place on the Web where you were when you tapped on our ad).

2. Device and Location data

We collect data from your mobile device. Examples of such data include: language settings, IP address, time zone, type and model of a device, device settings, operating system, Internet service provider, mobile carrier, hardware ID, and Facebook ID.

3. Usage data

We record how you interact with our Service. For example, we log with what features and content you interact, how often you use the App, how long you are in the App, or what sections of the App you use.

4. Advertising IDs

We collect your Apple Identifier for Advertising (“IDFA”) or Google Advertising ID (“AAID”) (depending on the operating system of your device). You can typically reset these numbers through the settings of your device’s operating system (but we do not control this).

• 3.FOR WHAT PURPOSES WE PROCESS YOUR PERSONAL DATA

We process your personal data:

1. To provide our Service

This includes enabling you to use the Service in a seamless manner and preventing or addressing Service errors or technical issues.

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To host personal data and enable our App to operate and be distributed we use Amazon Web Services, which is a hosting and backend service provided by Amazon.

We use Firebase Performance Monitoring and Firebase Crash Reporting, which are monitoring services provided by Google. To learn more, please visit Google’s Privacy policy and Privacy and Security in Firebase .

2. To customize your experience

We process your personal data to adjust the content of the Service and make offers tailored to your personal preferences.

3. To manage your account and provide you with customer support

We process your personal data to respond to your requests for technical support, Service information or to any other communication you initiate. This includes accessing your account to address technical support requests. For this purpose, we may send you, for example, notifications about the performance of our Service, security, payment transactions, notices regarding our Terms and Conditions of Use  or this Privacy Policy.

4. To communicate with you regarding your use of our Service

We communicate with you, for example, by push notifications. These may include reminders or other information about the App. As a result, you may, for example, receive a push notification that a new feature or level has been deployed in the App. To opt out of receiving push notifications, you need to change the settings on your device.

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To communicate with you we also use Firebase Cloud Messaging and Firebase Notifications, which are message sending services provided by Google. Firebase Cloud Messaging allows us to send messages and notifications to users of our App across platforms such as Android and iOS. We integrate Firebase Notifications with Firebase Analytics to create analytics-based audiences and track opening and conversion events. As a result, we can, for example, send reminders only to users who used the App more frequently. Google's privacy policy.To communicate with you we also use Firebase Cloud Messaging and Firebase Notifications, which are message sending services provided by Google. Firebase Cloud Messaging allows us to send messages and notifications to users of our App across platforms such as Android and iOS. We integrate Firebase Notifications with Firebase Analytics to create analytics-based audiences and track opening and conversion events. As a result, we can, for example, send reminders only to users who used the App more frequently. Google's privacy policy.

We use Apple Push Notification service (“APNs”), that is a notifications service provided by Apple. APNs allows us to send information to iOS devices. Apple’s privacy policy.

5. To research and analyze your use of the Service

This helps us to better understand our business, analyze our operations, maintain, improve, innovate, plan, design, and develop the App and our new products. We also use such data for statistical analysis purposes, to test and improve our offers. This enables us to better understand what features and sections of the App our users like more, what categories of users use our App. As a consequence, we often decide how to improve the App based on the results obtained from this processing.

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To perform research and analysis about how users interact with our App we use Appsflyer. Appsflyer enables us to understand, in particular, how users find us (for example, who was the advertiser that delivered an ad to users, which led you to an app store with our App). Appsflyer also provides us with different analytics tools that enable us to research and analyze your use of the Service. Privacy Policy , Opt Out.

We use Facebook Analytics, which is a service provided by Facebook that allows us to use different analytical tools. On Facebook Analytics we get, in particular, aggregated demographics and insights on how many people launch our App, how often users make purchases, and other interactions. Lean more about Facebook’s approach to data from its Privacy Policy

To track and analyze behavior of our App’s users (in particular, how they react to changes of the App structure, text or any other component), we use Firebase Remote Config. Firebase Remote Config is an A/B testing and configuration service provided by Google, which also enables us to tailor the content that our App’s users see (for example, it allows us to show different onboarding screens to different users). Privacy Policy and Privacy and Security in Firebase.

Amplitude is an analytics service provided by Amplitude Inc. We use this tool to understand how customers use our Service. Amplitude collects various technical information, in particular, time zone, type of device (phone or tablet), unique identifiers (such as IDFA). Amplitude also allows us to track various interactions that occur in our App. As a result, Amplitude helps us to decide what features/languages we should we focus on. Amplitude is EU-US Privacy Shield certified. Amplitude provides more information on how they process data in its Privacy Policy.

We also use Firebase Analytics, which is an analytics service provided by Google. In order to understand Google's use of data, consult Google's partner policy. Firebase Privacy information . Google’s Privacy Policy.

Unity Analytics is another analytical tool designed specifically for games and analyzing players’ in-game behavior. For more information, please see Unity Analytics Privacy Policy.

6. To send you marketing communications

We process your personal data for our marketing campaigns. As a result, you will receive information about our products, such as for example, special offers. We may show you advertisements in our App, and send you push notifications for marketing purposes. To opt out of receiving push notifications, you need to change the settings on your device.

7. To personalize our ads

We and our partners, including Applovin, Facebook and Google, use your personal data to tailor ads and possibly even show them to you at the relevant time. For example, if you have installed our App, you might see ads of our products, for example, in your Facebook’s feed.

How to opt out or influence personalized advertising

iOS: On your iPhone or iPad, go to “Settings,” then “Privacy” and tap “Advertising” to select “Limit Ad Track”. In addition, you can reset your advertising identifier (this also may help you to see less of personalized ads) in the same section.

Android: To opt-out of ads on an Android device, simply open the Google Settings app on your mobile phone, tap “Ads” and enable “Opt out of interest-based ads”. In addition, you can reset your advertising identifier in the same section (this also may help you to see less of personalized ads).

To learn even more about how to affect advertising choices on various devices, please look at the information available here.

In addition, you may get useful information and opt out of some interest-based advertising, by visiting the following links:

• Network Advertising Initiative –http://optout.networkadvertising.org/
• Digital Advertising Alliance – http://optout.aboutads.info/
• Digital Advertising Alliance (Canada) –http://youradchoices.ca/choices
• Digital Advertising Alliance (EU) –http://www.youronlinechoices.com/
• DAA AppChoices page –http://www.aboutads.info/appchoices

We value your right to influence the ads that you see, thus we are letting you know what service providers we use for this purpose and how some of them allow you to control your ad preferences.

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We use Facebook Ads Manager together with Facebook Custom Audience, which allows us to choose audiences that will see our ads on Facebook or other Facebook’s products (for example, Instagram). Through Facebook Custom Audience we may create a list of users with certain sets of data, such as an IDFA, choose users that have completed certain actions in the App (for example, installed it). As a result, we may ask Facebook to show some ads to a particular list of users. As a result, more of our ads may show up while you are using Facebook or other Facebook’s products (for example, Instagram). You may learn how to opt out of advertising provided to you through Facebook Custom Audience here.

Facebook also allows its users to influence the types of ads they see on Facebook. To find how to control the ads you see on Facebook, please go here or adjust your ads settings on Facebook.

Google Ads is an ad delivery service provided by Google that can deliver ads to users. In particular, Google allows us to tailor the ads in a way that they will appear, for example, only to users that have conducted certain actions with our App (for example, show our ads to users who have purchased a subscription). Some other examples of events that may be used for tailoring ads include, in particular, installing our App, finishing a free trial. Google allows its users to opt out of Google’s personalized ads and to prevent their data from being used by Google Analytics.

Applovin is a mobile marketing platform which allows showing mobile application users more relevant advertising that is based on users’ interest in applications. To see more details, please see Applovin Privacy Policy.

8. To enforce our Terms and Conditions of Use and to prevent and combat fraud

We use personal data to enforce our agreements and contractual commitments, to detect, prevent, and combat fraud. As a result of such processing, we may share your information with others, including law enforcement agencies (in particular, if a dispute arises in connection with our Terms and Conditions of Use ).

9. To comply with legal obligations

We may process, use, or share your data when the law requires it, in particular, if a law enforcement agency requests your data by available legal means.

• 4.UNDER WHAT LEGAL BASES WE PROCESS YOUR PERSONAL DATA (Applies only to EEA-based users)

In this section, we are letting you know what legal basis we use for each particular purpose of processing. For more information on a particular purpose, please refer to Section 2. This section applies only to EEA-based users.

We process your personal data under the following legal bases:

1. your consent;

Under this legal basis we obtain your personal data from third parties, for example, when you decide to login using Facebook you may give consent to share your email address.

2. to perform our contract with you;

Under this legal basis we:

• Provide our Service (in accordance with our Terms and Conditions of Use
• Customize your experience
• Manage your account and provide you with customer support
• Communicate with you regarding your use of our Service

3. for our (or others') legitimate interests, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data;

We rely on legitimate interests:

• to communicate with you regarding your use of our Service

This includes, for example, sending you push notifications about new features. The legitimate interest we rely on for this purpose is our interest to encourage you to use our Service more often.

• to research and analyze your use of the Service

Our legitimate interest for this purpose is our interest in improving our Service so that we understand users’ preferences and are able to provide you with a better experience (for example, to make the use of the App easier and more enjoyable, or to introduce and test new features).

• to send you marketing communications

The legitimate interest we rely on for this processing is our interest to promote our Service in a measured and appropriate way.

• to personalize our ads

The legitimate interest we rely on for this processing is our interest to promote our Service in a reasonably targeted way.

• to enforce our Terms and Conditions of Use and to prevent and combat fraud

Our legitimate interests for this purpose are enforcing our legal rights, preventing and addressing fraud and unauthorised use of the Service, non-compliance with our Terms and Conditions of Use .

4. to comply with legal obligations.

• 5.WITH WHOM WE SHARE YOUR PERSONAL DATA

We share information with third parties that help us operate, provide, improve, integrate, customize, support, and market our Service. We may share some sets of personal data, in particular, for purposes and with parties indicated in Section 2 of this Privacy Policy. The types of third parties we share information with include, in particular:

1. Service providers

We share personal data with third parties that we hire to provide services or perform business functions on our behalf, based on our instructions. We may share your personal information with the following types of service providers:

• cloud storage providers ( Amazon)
• data analytics providers (Facebook, Appsflyer, Firebase, Amplitude, Unity Analytics)
• marketing partners (Facebook, Google)
2. Law enforcement agencies and other public authorities

We may use and disclose personal data to enforce our Terms and Conditions of Use , to protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others, and to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, or in other cases provided for by law.

3. Third parties as part of a merger or acquisition

As we develop our business, we may buy or sell assets or business offerings. Customers’ information is generally one of the transferred business assets in these types of transactions. We may also share such information with any affiliated entity (e.g. parent company or subsidiary) and may transfer such information in the course of a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

• 6.HOW YOU CAN EXERCISE YOUR PRIVACY RIGHTS

To be in control of your personal data, you have the following rights:

Accessing / reviewing / updating / correcting your personal data. You may request a copy of your personal data collected during your use of the App at info@universeapps.limited .

Deleting your personal data. You can request erasure of your personal data by sending us an email at info@universeapps.limited.

When you request deletion of your personal data, we will use reasonable efforts to honor your request. In some cases we may be legally required to keep some of the data for a certain time; in such event, we will fulfill your request after we have complied with our obligations.

Objecting to or restricting the use of your personal data. You can ask us to stop using all or some of your personal data or limit our use thereof by sending a request at info@universeapps.limited.

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If you are based in the EEA, you have the following rights in addition to the above:

The right to lodge a complaint with supervisory authority. We would love you to contact us directly, so we could address your concerns. Nevertheless, you have the right to lodge a complaint with a competent data protection supervisory authority, in particular in the EU Member State where you reside, work or where the alleged infringement has taken place.

The right to data portability. If you wish to receive your personal data in a machine-readable format, you can send respective request at info@universeapps.limited.

• 7.AGE LIMITATION

We do not knowingly process personal data from persons under 16 years of age. If you learn that anyone younger than 16 has provided us with personal data, please contact us at info@universeapps.limited.

• 8.INTERNATIONAL DATA TRANSFERS

We may transfer personal data to countries other than the country in which the data was originally collected in order to provide the Service set forth in the Terms and Conditions of Use and for purposes indicated in this Privacy Policy. If these countries do not have the same data protection laws as the country in which you initially provided the information, we deploy special safeguards.

In particular, if we transfer personal data originating from the EEA to countries with not adequate level of data protection, we use one of the following legal bases: (i) Standard Contractual Clauses approved by the European Commission (details available here), or (ii) the EU-U.S. Privacy Shield Framework (details available here), or (iii) the European Commission adequacy decisions about certain countries (details available here).

• 9.CHANGES TO THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time. If we decide to make material changes to this Privacy Policy, you will be notified through our Service or by other available means and will have an opportunity to review the revised Privacy Policy. By continuing to access or use the Service after those changes become effective, you agree to be bound by the revised Privacy Policy.

• 10.CALIFORNIA PRIVACY RIGHTS

California’s Shine the Light law gives California residents the right to ask companies once a year what personal information they share with third parties for those third parties' direct marketing purposes. Learn more about what is considered to be personal information under the statute .

To obtain this information from us, please send an email message to info@universeapps.limited which includes “Request for California Privacy Information” on the subject line and your state of residence and email address in the body of your message. If you are a California resident, we will provide the requested information to you at your email address in response.

• 11.DATA RETENTION

We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing the Service to you), which includes (but is not limited to) the period during which you have an account with the App. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

• 12.HOW “DO NOT TRACK” REQUESTS ARE HANDLED

Except as otherwise stipulated in this Privacy Policy, this App does not support “Do Not Track” requests. To determine whether any of the third-party services it uses honor the “Do Not Track” requests, please read their privacy policies.

• 13.CONTACT US

You may contact us at any time for details regarding this Privacy Policy and its previous versions. For any questions concerning your account or your personal data please contact us at info@universeapps.limited.

Effective as of: December 2021