Privacy Policy

HOOPSLY PRIVACY POLICY

Last updated: July 23rd, 2021

Hoopsly FZE, Business Center, Al Shmookh Building, UAQ Free Trade Zone, Umm Al Quwain, U.A.E. (hereinafter collectively with its Affiliates “Hoopsly”, “we”, “us”) develops and publishes mobile applications (“Games”) that can be downloaded from the app stores of various providers.

“Affiliate” shall mean (i) an entity controlled by Hoopsly FZE, where control is denoted as having fifty percent (50%) or more of the voting power (or equivalent) of the applicable legal entity, or (ii) an entity controlled by Hoopsly FZE ‘s controlling shareholders, where control is denoted as having fifty percent (50%) or more of the voting power (or equivalent) of the applicable legal entity.

Hoopsly is committed to protecting your privacy. Whenever you use our Games, website and other products (“Services”) various personal data will be collected. Please carefully review this Privacy Policy to learn about how we collect, use, and protect any personal information you provide us and your choices for managing your personal information.

By accessing and using our Services you agree to be bound by this Privacy Policy and consent to our processing of information as specified herein.

If you have questions about data protection, or if you have any requests for resolving issues with your personal data you may contact us through the following email: privacy@hoopsly.com.

DATA WE COLLECT

The categories of personal data we collect depend on the Services you use, and the requirements of applicable law.

Information you provide to us: your name, email address, phone numbers or other contact information, profile information, your messages to the Services, other data you choose to give We will try to explain the reasons you are asked to provide certain personal data at the point you are asked for data provision.
Data we collect automatically: (a) Data about your account and game progress, including in most cases an automatically created internal account ID; (b) Your IP address and mobile device identifiers (such as your device or advertising ID); (c) Data about your device, such as device name and operating system, browser type and language, internet service provider, and mobile carrier; (d) Data we collect with cookies and similar technologies; (e) Approximate location data (as derived from IP address); (f) Data and analytics about your use of the Service, such as gameplay data and your interactions with other players inside the Services; (g) Information collected automatically through our website (or third-party services engaged in our website),
Data we collect from our partners (such as social networking sites, data analytics providers and advertising networks in order to supplement information we have about you): (a) Data we receive if you link a third party tool with the Services (such as Facebook, Google); (b) Demographic data (such as to determine the coarse location of your IP address); (c) Data to fight fraud (such as refund abuse in games or click fraud in advertising); (d) Data from platforms that the games run on (such as to verify payment); (e) Data for advertising and analytics

purposes, so we can provide you a better Services; (f) Data that you have made available to us from a third party service (such as Google or Facebook) via your privacy settings.

We do not request or intend to collect any “special categories of information” such as personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation.

DATA USE

We use the information we collect and store to provide a better gaming experience, but there are other uses as well. These uses may include:

To make the Services work. To perform the contract we process data necessary to create accounts and allow you to play our Games and use our Services, operate the Services; verify and confirm payments; provide and deliver products and services you request; send you Services-related
To make the Services more suitable for our players. We have a legitimate interest to collect and process necessary data to update and develop player profiles, develop and improve the Services and player experience, manage our relationship with you, provide social features as part of the Services, customize your Services experience; respond to your comments and questions and provide player support, provide you offers in the Services as well as in other websites and services, and by email, send you related information, such as updates, security alerts, and support messages; enable you to communicate with other
To show personalized We have a legitimate interest to process necessary data to track the content you access in connection with the Services and your online behavior; deliver, target and improve our advertising and the Services. For information on how to opt-out from personalized advertisements, see information below.
To keep the Service safe and We have a legitimate interest to process necessary

data to analyze and monitor use of the Services and its social features; moderate chats either automatically or manually; take action against fraudulent or misbehaving players.

Legal This covers information that is processed by us to comply with a legal

obligation, for instance, to maintain records for tax purposes.

To analyze, profile, and segment. In all of the above cases and purposes, we may analyze, profile and segment all collected
With your With your consent, we may process your data for additional purposes.

In-App Purchases. Please note: We do not process payments for in-app purchases nor have access to your credit card information. Payment transactions for in-app purchases are completed through the app store via your app store account (payment service providers). We are not involved in the collection and processing of such information. Any post-purchase

processes are controlled by the app stores and are subject to specific terms of such stores, which you are advised to review periodically.

DATA SHARING

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

Our analytics providers. We use third-party analytics for the purposes of delivering our services, conducting analysis, and The device data we share with such providers are encoded. The providers may assign a random ID to these data and they are not able to match it back to you. We can aggregate the data for benchmarking feature.
Our cloud service We store information we collect from you on servers provided by our third-party cloud service providers.
Our tracking and fraud prevention providers. For some of our Games we use tracking and fraud prevention providers for the purposes of measuring performance and optimizing our advertising campaigns, displaying advertisements, conducting analysis to improve our services and for fraud prevention purposes. Such providers may use APIs, and SDKs in our Games to enable them to collect and analyze user and device-related data and information, such as impressions, clicks, installs or other advertising campaign performance indicators and post-install in-app
Third-party advertising partners. We have contracted with certain third-party advertising networks that assist us in delivering advertising to you that allows us to continue offering the Games for free or at low
Advertising partner’s third-party tracking provider. We allow our advertising partners to track impressions, clicks, installs or other advertising campaign performance indicators through their tracking providers for the purposes of measuring their advertising campaign They may use their own third-party tracking providers.
Other third-party service providers. For our Games, we use Unity Software to develop such For the data processing by Unity please see Unity’s privacy policy available at https://unity3d.com/legal/privacy-policy. For some Games, we partner with third-party development studios to develop such Games. Such third-party development studios do not have access to your personal information, they can only access aggregated data that they cannot trace back to you.

A list of the partners is available below in this document. 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.

We reserve the right to disclose your personal data in response to law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations, users or user experience. Additionally, in the event of a reorganization, merger or sale we may transfer any and all personal data we collect to the relevant third party.

CROSS BORDER DATA TRANSFERS

Our Services are global by nature and your data can therefore be transferred to anywhere in the world. Different countries may have different data protection laws than your own country, in this regard we take steps to ensure adequate safeguards are in place to protect your data as explained in this document. Adequate safeguards that we may use include standard contractual clauses approved by applicable lawful safeguards.

YOUR RIGHTS AND OPTIONS

Opt-out of marketing emails and other direct marketing. You may opt-out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications, or by changing your in-game settings. The updated settings may not be effective immediately. Note that you may still continue to receive non-promotional emails from us, such as communications regarding the Services or updates to our Terms and Conditions or this Privacy
Push Notifications. We may send you push notifications through our mobile applications. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile
Opt-out of targeted advertising. You can opt-out of interest-based advertising on mobile applications by 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). You can also opt out from personalized in-game offers through the options provided in the game
Access the personal data we hold about If you request, we will provide you a copy of your personal data in an electronic format.
Your other You also have the right to to withdraw your consent; to access your

data; to correct your data; to have your data deleted; to restrict processing of your personal information; to take your data with you; to object how your data is handled; to send complaints to the supervisory authority.

You can exercise these rights at any time by sending us relevant requests to our contact email stipulated in this document. We will respond to all requests within a reasonable timeframe and in accordance with applicable laws. You may also contact your local data protection authority within the European Economic Area, Switzerland or UK for unresolved complaints.

To protect your privacy, we may also take additional steps to verify your identity before fulfilling your request, such as by requesting you provide us a purchase receipt or other account information, asking you to link your email address with your game account, or asking you to answer questions regarding your activities on our Services.

DATA PROTECTION

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 Services. We may for example periodically de-identify unused game accounts, and we may 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.

CHILDREN

Our Serviceы do not address anyone under the age of 16 (“Children”). When we collect personal information, we do not know the age of our users. We do not knowingly collect personally identifiable information from children under 16. If you are a parent or guardian and wish to review personal data collected from your child, or have that information modified or deleted, you may contact us as described above. If we become aware that a child has provided us with personal data contrary to the above, we will delete any personal data we have collected, unless we have a legal obligation to keep it, and terminate the child’s account and/or revert them to the underage experience, as applicable.

Although the graphical content of the Games may be suitable for younger audiences, there are multiple reasons for responsible developers to apply a minimum age of 16. Some of these reasons are in-app purchases and privacy.

COOKIES AND SIMILAR TECHNOLOGIES

We and our partners use cookies and similar technologies to provide and personalize the Services, analyse use, target advertisements and prevent fraud. Cookies and similar technologies allow us and our partners to store their preferences and track your activities within the Services. Note that our partners may operate under their own privacy policies.

We and our partners collect and store information about users’ interactions with unaffiliated websites and applications that use our technologies, including cookies and similar tracking technologies. This allows us to infer the presence of a common user or household behind multiple devices or browsers, for instance, and then link those browsers and devices into a device graph. We do so in order to:

detect and prevent fraud;
allow users to use the Services on one device and pick up seamlessly where they left off on another device;
analytics, personalization and attribution;
limit the number of times a user is shown the same advertisement, across all known or inferred devices; and/or
provide personalized advertising on each device that is inferred from the browsing patterns on all of the

You can disable cookies in your browser settings, but some parts of the Services may then not function properly.

SUPPLEMENTAL TERMS FOR CERTAIN REGIONS

The following section applies only to residents of California.

Data collection, data use, as well as your rights under California law are described in relevant Sections “Data we collect”, “Data use” and “Your rights and options” of our Privacy Policy.

Data disclosure and/or sale. We do not sell your personal data to third parties. However, we may share your cookie information and advertising identifiers with our third-party advertising platforms to deliver interest-based advertisements, attribute installs and optimize campaign performance. To the extent that practice is considered a “sale” under the CCPA, you may opt out of said sharing by following the steps described in “Opt-out of targeted advertising” of our Privacy Policy.

We do not have actual knowledge of any sale of personal data of minors under 16 years of age, as the term “sale” is defined under the CCPA. In the preceding 12 months, we have disclosed the following categories of personal data as part of our Services:

Identifiers: to other players, service providers, business partners, advertising networks;
Name or telephone number: to service providers;
Age: to service providers, advertising networks;
Commercial information (purchase data): to service providers, advertising networks;
Internet or other electronic network activity: to service providers, advertising networks;
Profile reflecting a consumer’s preferences, characteristics and behavior: to service

In addition to the sharing described above, we may share any information we collect about you with our affiliates, to protect us or others, or in the event of a merger, sale, or other asset transfer.

OPT-OUT OF TARGETED ADVERTISING

Should you desire to limit behaviourally targeted advertising, you can do so by limiting ad tracking in your device settings. Opt-outs are specific to each browser and device and it may take extra time before your opt-out will take effect, which please note.

For mobile advertising in apps, you can reset your Advertising Identifier and depending on your device, select to opt out of interest-based ads (Android) or turn on the Limit Ad Tracking setting

(iOS). For display advertising on the Web, you can also adjust your browser settings to limit certain tracking by means of cookies.

We also use partners to perform services for us as processors, such as attribution providers. These partners do not use your data for additional purposes and your opt-outs can also affect these partners.

LIST OF PARTNERS

PARTNER NAME	LINK TO PRIVACY POLICY
AppsFlyer Ltd.	https://www.appsflyer.com/privacy-policy/
AppLovin Corporation	https://www.applovin.com/privacy/
Facebook, Inc. (Facebook Analytics, Facebook Ads)	https://web.facebook.com/about/privacy/update?ref=old_policy
Google LLC (Google Cloud Platform)	https://cloud.google.com/security/privacy/
Google LLC (Firebase)	https://firebase.google.com/support/privacy/
Google LLC (Google Cloud Platform)	https://cloud.google.com/security/privacy/
Adjust GmbH	https://www.adjust.com/terms/privacy-policy/