Effective from January 30, 2020

PRIVACY POLICY

This Privacy Policy (hereinafter – the “Policy”) describes the information collected by DICE ROLL SOLUTIONS LTD. (hereinafter - the “Owner”, “We”, “Our”, or “Us”, “Data Controller”), the owner and operator of Gold for tanks Application (“Gold4tanks App.” or “App.”), the information on how we collect, use, share and protect that information. The Policy also guarantees the protection of User personal data collected by the Application and/or with respect to in-app services offered (the “Services”). The User is hereinafter referred to as the “User” or “You”.

We always do our best to process your personal data in a manner to ensure appropriate security and confidentiality of the data collected. This Policy is drafted in strict compliance with data protection laws applicable in relevant jurisdiction and Regulation (EU) 2016/679 (General Data Protection Regulation), hereinafter referred to as the “GDPR”.

1. ACCEPTANCE OF THE POLICY TERMS

1.1 By using any of our Services or Applications, You expressly consent to the terms and conditions hereof. Your continued use of the Applications or Services indicates your express consent to the terms and conditions hereof as well and any amendments hereto.

1.2 If you have a complaint or question about this Policy, if you would like to make a request concerning your personal data as specified herein, withdraw your consent, you may at any time contact us at support@free4ga.me. We will aim to respond you within maximum 10 business days from receipt of request. Any correspondence received from you is classified as restricted-access information and may not be disclosed without your prior consent.

2. WHY DO WE NEED YOUR INFORMATION AND WHAT INFORMATION EXACTLY WE COLLECT

2.1 We collect the following information, both personal and non-identifiable:

2.1.1 Person identifiable information: full name; e-mail address, gender, birth date, Facebook or google profile photo; link to Facebook profile (if applicable); nickname; ID number of Facebook or google profile.

2.1.2 Technical information (the information about your mobile device or computer): Android version, system language, debugger identifier, device brand name and model, display width and height; device manufacturer; processor architecture (ARM, x86 etc.), gsm module, list of installed applications, applications black list information, bootloader version number, fingerprint, App. version.

Automatically collected information. Cookies. We use cookie-files and other similar technology, which are the text information located in a temporary file that we send via the web server to the User’s device in order to save the session on the User device, and to identify the User the next time he or she visits the Gold4tanks App. Cookies do not contain personal User data. You can manage the use of cookies and disable the sharing of data by blocking consent to cookies in the settings of your browser. If you do not wish to share your information collected with the use of cookies you may not consent in the pop-up alerts appeared.

2.1.3 Technical identifiers: IP address, network operator, sim country code, network country code.

2.2. To comply with the requirements of applicable laws and GDPR principles relating to processing of personal data we refer to the time of data collection, purpose and legal basis of data processing in this clause as follows.

2.2.1 The data indicated in clause 2.1 of this Policy are collected when you log in Gold4tanks App. and use it (launch, play the game, receive bonuses and rewards, end your game session etc.).

2.2.2 The information collected is processed for the following purposes: A) Person identifiable information is used for (i) access and use of Gold4tanks App., creation of personal App. account, delivery of Services to the User, (ii) communication with the User with respect to access, use of App. and Services, support requests, managing and submitting confirmations and important information about the User account, the App., in-app bonuses or rewards, settlement of any complaints and provision of efficient service; (iii) calculation of our consideration for the services provided to the third parties via the App. and settlement of any claims with regard to calculation of our consideration.

B) Technical information is used for (i) smooth running and integration of App. with the User device, (ii) calculation of our consideration for the services provided to the third parties via the App. and settlement of any claims with regard to calculation of our consideration, (iii) technical and statistical purposes (including, but not limited to, product updates, patches and fixes to assure correct operation of the Gold4tanks App.).

C) Technical identifiers are used for (i) verifying the geography of App. usage for statistics purpose, (ii) delivery of Services to the User, (iii) technical and statistical purposes (including, but not limited to, product updates, patches and fixes to assure correct operation of the Gold4tanks App.).

2.3 We will only collect and process personal information about you where we have legal basis.

2.3.1 We consider it is our legitimate interest to (i) collect the data specified in this Policy for collecting and verifying our consideration for ad services we provide to third parties through Application, for the establishment, exercise or defence of legal claims of our partners, and (ii) for the performance of the contract with you (our obligations in accordance with the End-User License Agreement (EULA) or any other similar documents in effect).

2.3.2 We do not collect or process any sensitive data, that is also prohibited by Art. 9 GDPR, unless it is required by applicable law of jurisdiction, for example, in the event of court order. Under most circumstances, the types of data listed below will not be processed: - Race or ethnic origin, - Political opinions, - Religious or philosophical beliefs, - Trade union memberships, - Genetic or biometric data, - Health or mortality, - Sex life or sexual orientation.

3. THIRD PARTIES

3.1 In some cases, we need to pass some of your information to third parties and collect some of your personal data from third parties as well. We do our best to share minimum information and comply with the provisions of applicable laws and GDPR when sharing and collecting your personal data. . For more understanding of how we collect information from third parties and who can receive your personal data please refer to the below:

3.1.1 Person identifiable data is collected from your Facebook and Google account. The purpose, time of collection and legal basis of such data processing are specified in section 2 hereof.

3.1.2 Application contains some elements developed by third parties for advertising function of the Application (“Third Parties SDK”). To our best knowledge, such third parties through Third Parties SDK collect and process personal data on a legal basis and with responsible approach to personal data protection. Moreover, in any case they are well known companies with respected reputation and we always negotiate the necessity to process your personal data. However, we do not make decisions about the information processed by these third parties and purposes of processing. Therefore, we do not include information on exact actions and purposes of personal data collection of mentioned third parties.

3.1.3 In the list below you can find the information about third parties mentioned in clauses 3.1.1 and 3.1.2 and direct links to texts of privacy policies developed by such third parties (if applicable):

*Google Analytics places permanent cookie-files to your web browser to identify you as a unique user the next time you visit the App. These cookie-files do not collect personal identifiable information. The information collected using cookies will be transmitted to Google, Inc. Processing of personal data by Google, Inc. is regulated by the Privacy Policy of this company indicated in the table above. We want to underline that we use the information obtained through Google Analytics only to exercise our obligations under the EULA entered into with the User and improve our App. and in-app service delivery to the User under the EULA. We do not combine the non-identifiable information received through Google Analytics with personal identifiable information we collect. You can disable Google Analytics to recognize you when you return to the App. by the following means: 1) for disabling Google Analytics - by (i) opting out Google Analytics cookies in your browser, or (ii) you can use Google Analytics Blocker.

4. SHARING YOUR INFORMATION

4.1 We may be required to disclose your personal information in accordance with applicable laws of jurisdiction, any legal process, or court proceedings, and/or on the basis of government authority requests in or outside the country where you are located. In the event of the reorganization, merger, or sale of the company, we may transfer any or all of the personal information we have collected to the successor of the company.

4.2 We do not sell or in any way provide personal information of our users to third parties, except as sharing the information collected as follows:

4.2.1 Our Users. Your username and any information that you post, including, without limitation, reviews, comments, scores, participation in the game, and text will be available to, and searchable by, all other our users.

4.2.2 Our Partners, including advertising contractors and payment gateway contractors. We may share certain information, such as ID number of your Facebook or google profile, game nickname, some non-identifiable information, such as IP address, country code, with the said partners. The partners will use this information solely for the purpose of determining your eligibility for the bonus or reward in the App. Any information that you submit to a third party will be governed by that third party’s website privacy policy and not this Policy. We do not share your personal information with our partners or other third parties for their direct marketing purposes.

4.2.3 Our group companies and employees. All parties receiving information about You are required to comply with current data protection legislation and ensure the privacy of Your information to the same extent to which we are bound by this Policy, applicable laws and GDPR provisions.

4.3 We share your data only for the following purposes (i) collecting and verifying our consideration for ad services we provide to the partners through the Application, for the establishment, exercise or defence of legal claims of our partners, and (ii) for the performance of the contract with you (our obligations in accordance with the End-User License Agreement or any other similar documents in effect).

5. USER RIGHTS

5.1 Among other and under the Chapter 3 GDPR, you have the following rights in relation to your personal information:

• Right to access your personal information: at any time, you may request personal data we process, purpose of processing, means of processing etc. You may request a copy of the personal data we process as well. For these requests please send us an email at support@free4ga.me. headed "Subject Access Request";

• Right to rectify your personal information: at any time, you may request to update, block or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received or there is no need to proceed processing anymore;

• Right to erasure: at any time, you may request to delete all personal data that we have– it is your right to be forgotten, like if we have never met before. We will also deactivate your account. If you do so, you will no longer have access to the Applications associated with your account;

• Right to restrict the use of your personal information: for example, if you think, that your personal data is not accurate and we need time to check it, we can make a pause in processing your personal data during the check time. If you do not request deletion, then it is possible to request reactivation of your account if it was accidentally or wrongfully deactivated. Please, note, that we cannot restore permanently deleted accounts;

• Right to object to processing of your personal information: at any time, you request to cease data processing and we will no longer process your personal data, but we may retain them if there are legal grounds for that;

• Right to data portability (in certain specific circumstances): if you wish, you may request to download (export) the personal data we have and share them with someone indicated by you or ask us to transfer them your data directly;

• Right not to be subject to an automated decision: if we process your personal data automatically and we take some decisions in respect of your data, so that it affects you seriously, you may contest such decision. But it’s not the subject of our processing;

• Right to lodge a complaint with a supervisory authority: you are always entitled to complain about the way we process your personal data to competent authorities.

Before we process any request, we may ask you for certain information in order to verify your identity. Where permitted by local law, we may reject requests that are unreasonable or impractical. We will respond your requests in reasonable time.

6. CHILDREN

Our Services are not designed for persons under 18 (or the minimum legal age to consent to the collection and processing of personal data if different under applicable law of relevant jurisdiction). While GDPR specifies that different countries may provide by law for a lower age provided that such lower age is not below 13 years, we do not knowingly collect information from children under 13 as well. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.

7. WHERE WE HOLD YOUR INFORMATION

Personal information we collect may be stored and processed for the purposes set out herein in any country in which we operate and your personal information may be transferred, stored and processed by recipients in various countries around the world where other users or our partners are located. We do our best to make sure all recipients or your personal data understand the necessity to process personal data only on a legal basis taking into account any and all applicable legislation. Aiming the appropriate security and protection of data collected we located our servers with personal data of our users in Germany, the member state of EU, recognized by the European Commission as the country providing adequate measures on protection of personal data information in accordance with GDPR.

8. HOW LONG WE STORE YOUR PERSONAL INFORMATION

8.1 We retain personal information for as long as necessary to fulfil purposes described in this Policy, subject to our own legal and regulatory obligations (no longer than it is necessary for the purposes for which your personal data is processed). We will retain basic account information and information about performed transactions for at least 10 years after an account is closed.

8.2 If you submit a request to be forgotten, as it is specified in GDPR, we will anonymize your personal data unless we have a legal obligation to continue to store the personal data, or for the establishment, exercise or defense of a legal claim. For example, if you have redeemed a reward within any of our Application we may store your personal data for as long the statute of limitations for making a claim relating to that redemption. If you have indicated in any way that you believe you have a dispute with us, we may store your personal data at least until that dispute is resolved.

8.3 We may store anonymized data indefinitely. We maintain this type of data to compare performance of our Applications and our Services over past periods, to analyze current performance, to measure player activity over time, and for other business issues.

9. DELETION OF AN ACCOUNT RECORD ON THE Gold4tanks App.

9.1 Users may change or delete information about themselves in the User Account Record on the Gold4tanks App. by sending a message to the Support Service at support@free4ga.me. Your account will be deleted and your personal data will be de-personalized within 30 days of receiving your request.

9.2 We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse or enforce our EULA. We will retain the data de-personalized after your account has been deleted.

10. PROTECTION OF PERSONAL INFORMATION

10.1 We employ a variety of measures to safeguard the collection, transmission and storage of the information we collect. These measures vary based on the sensitivity of the information that we collect, process and store and the current state of technology. Even so, no security measure is 100% perfect. Therefore, while we strive to employ reasonable protections for your information that are appropriate to its sensitivity, we cannot guarantee the security of your information and do not assume any responsibility for the unauthorized use or access to your information under our control.

10.2 The personal information you post on social networks, on forums, or in chat rooms is visible to other users and may be read, collected, or used by them. You are responsible for the personal information that you prefer to provide in such cases.

10.3 You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity. To change your social net’s password, you must go to the social net’s site and follow its procedures for changing your password.

11. AMENDMENTS TO THE PRIVACY POLICY

We reserve the right to amend this Privacy Policy at any time. Amendments to the Privacy Policy shall come into force immediately after they are posted on the Gold4tanks App., and will be accessible on the Gold4tanks App.’s page in Google play.

12. APPLICABLE LAW

When processing your personal data, we rigorously try to comply with the regulations of English Common Law, including the Data Protection Act 1998 and Regulation (EU) 2016/679 (General Data Protection Regulation).

13. ABOUT US

DICE ROLL SOLUTIONS LTD.

Company registered number: 341088

Registered address: Arch. Makariou III, 155 PROTEAS HOUSE, 5th floor 3026, Limassol, Cyprus

Most recent update to the Privacy Policy: January 30, 2020