LINGOMASTER Privacy Policy

Our Privacy Policy was updated on Jan 1th, 2026.

Please take a moment to familiarize yourself with our privacy practices and let us know if you have any questions.

About us

LINGOMASTER is headquartered in Singapore as LIG EDUTECH PTE.LTD. ("we", "our", or "us"), from where we publish and distribute our services around the world. We recognise and value the privacy of people (“you” or user”) who use our services.

About this privacy policy

This Privacy Policy is designed with your needs in mind, and it is important that you have a comprehensive understanding of our personal information collection and usage practices, while ensuring that ultimately, you have control of your personal information provided to LINGOMASTER.Under this Privacy Policy, “personal information” means information that can be used to directly or indirectly identify an individual, either from that information alone or from that information combined with other information LINGOMASTER has access to about that individual, except as otherwise specifically provided by applicable laws in your region.

This Privacy Policy informs you of the following information:

· What Data We Collect and Process

· Why Do We Collect and Process Your Personal Data

· Legal Basis of our Data Collection and Processing

· Advertisements and Your Choices

· Cookies and Similar Technologies

· Information Sharing

· Data Retention

· Your Rights and Choices

· Securing Your Data

· Children’s Protection

· Changes to Privacy Policy

· Contact Us

· Supplemental Terms – Jurisdiction-Specific

Please read this entire privacy policy. You should also carefully review any other agreements that apply to the services you use, and confirm you understand and agree to them, before using those services.By accessing our websites or otherwise using our services you acknowledge that you have read, understood, and accepted this Privacy Policy. In the case you do not agree with any of the terms of this Privacy Policy, you may immediately stop using our services.

1. How We Collect and Use Your Personal Information

When you use our products or services, the scenarios in which you may be required or choose to authorize us to collect and use your personal information are as follows:

1.1. Provision of Core Functions

In order to provide you with the core functions of our products/services, you must authorize us to collect and use necessary information. If you refuse to provide such necessary information, you will be unable to use our products/services normally.

1.2. Provision of Additional Functions

To provide you with additional functions of our products/services, you may choose to authorize us to collect and use specific information. If you refuse to provide such information, you will be unable to use the relevant additional functions or achieve the intended functional effects; however, this will not affect your normal use of the core functions of our products/services.We adhere to the principles of lawfulness, legitimacy, and necessity. We collect and use your personal information for the purposes described in this Policy to provide the following functions:

1.2.1. When you register as a LINGOMASTER user, you must provide your mobile phone number and password to create an account. If you log in via third-party accounts such as FACEBOOK、X or INSTAGRAM, we will collect public information including your nickname, avatar, and city. We will obtain your authorization through the third-party account's authorization function before collecting such information. Please note: if you refuse to provide the aforementioned personal information, we will be unable to complete the registration process, and you will not be able to use any functions of Registration.

1.2.2. Word Learning and Reading Functions

If you wish to utilize our audio reading feature, you may choose to authorize us to access the microphone permissions of your device;If you wish to use features such as scanning QR codes on physical books via the camera to add study plans, customizing check-in covers, or saving images displayed by us and your screenshots, you may authorize us to access the camera and photo album permissions (or read and write permissions for external storage) of your device. Your refusal to provide the aforementioned permissions will result in the unavailability of the corresponding features, but will not affect your use of the basic word memorization functions.To better understand your usage of the Services and improve our service quality, we will record your word learning progress or reading status for the purposes of functional development and optimization.We will not provide the aforementioned information to any third party without obtaining your prior explicit authorization.

1.2.3. Marketing Services

When you choose to participate in activities organized by us, we may require you to provide information such as your mobile phone number and residential address to facilitate the delivery of physical items related to the activities.Please note that the aforementioned information may contain your Sensitive Personal Information. If you refuse to provide such information, we may be unable to deliver the relevant items to you.Furthermore, with respect to the contact information (telephone, email, and other contact methods) provided during your use of our products or services, we may, in the course of our operations, provide you with information regarding services, features, or activities of interest, as well as relevant commercial information, via SMS.To participate in relevant operational activities, it may be necessary to copy external passcodes. We may read or set the contents of your clipboard. If you are unwilling to have the aforementioned information read, please refrain from participating in operational activities that require the copying of passcodes.If you do not wish to receive commercial advertisements from us, you may unsubscribe or opt-out via the instructions provided in the SMS prompts or through other available methods.

1.2.4. Provision of Customer Service

When you contact our customer service, we may require you to provide necessary information to verify your identity and collect your contact information to facilitate timely communication once a solution is reached. Your communication records and contents with our customer service will also be preserved.

1.2.5. Use and Configuration of Smart Devices

When you use device binding, data transmission, and device configuration functions, we may collect your Wi-Fi information (including SSID, BSSID, Wi-Fi MAC address, and Wi-Fi password), device MAC address, and device Bluetooth MAC address. We will request Camera permissions to identify device QR codes and Bluetooth permissions to search for and connect to smart devices. Due to the operating mechanisms of mobile operating systems, the system's Bluetooth functionality mandatorily requires location permissions. Therefore, upon requesting Bluetooth access, we will request your location information (including approximate and precise location) to facilitate the connection to smart devices via Bluetooth.

1.2.6. Ensuring User Security and Service Improvement Plans

To ensure the continued provision of secure services and the ongoing optimization of your experience, we may collect information regarding your use of our services. Such information includes:When you use our services or access our platform’s web pages, we automatically receive and record information from your browser and computer, including but not limited to your IP address, browser type, language used, date and time of access, software and hardware characteristic information, and records of web pages requested. If you download or use client software from us or our affiliates, or access mobile web pages to use our platform services, we may read information related to your location and mobile device, including but not limited to device model, platform, manufacturer, brand, operating system, resolution, telecommunications carrier, and network information (such as IP address, Wi-Fi information, and base station information).Log Information refers to technical information that may be automatically collected by the system via Cookies or other methods when you use our services to determine your country and language preferences. This includes search or browsing information, such as web search terms, URLs of social media pages visited, and other details of information and content browsed or requested while using our services.To ensure you continue to enjoy the latest services, we may use your app version information and mobile phone model to provide app upgrade services. Additionally, we may collect information regarding the list and version numbers of smart devices you have connected to provide upgrade functions for those devices and ensure you have access to the latest service versions (including firmware versions). Operation records generated while using our services include, but are not limited to, course purchase history and browsing history.To collect the aforementioned basic personal device information, we will request permissions to access your device information. We collect this data to provide our basic services and core functions; please be advised that refusal to grant such permissions may result in your inability to use our products and services.

2. Indirect Collection and Authorized Sharing

Personal Information Collected via Indirect Methods: We may obtain relevant personal information that you have authorized for sharing from affiliates or third-party partners. Specifically, we may obtain account information (avatar, nickname, and login time) from third parties and, upon your consent to this Policy, bind your third-party account with your LINGOMASTER account to facilitate direct login. We will collect and use such personal information in accordance with applicable laws and regulations, based on agreements with affiliates or third-party partners, and only upon confirming that the source of the provided personal information is legitimate.

2.1. Exceptions to Prior Consent

You fully understand and agree that we may collect and use your personal information without your authorized consent under the following circumstances:

• Where necessary for the conclusion or performance of a contract to which you are a party;

• Where necessary for the fulfillment of statutory duties or legal obligations;

• Where necessary to respond to public health emergencies, or to protect the life, health, and property safety of natural persons in an emergency;

• Processing personal information within a reasonable scope for news reporting, public opinion supervision, and other such acts for the public interest;

• Processing personal information that you have disclosed yourself or that has otherwise been legally disclosed, within a reasonable scope in accordance with the law;

• Other circumstances stipulated by laws and regulations.

Please be advised that, according to applicable laws, if we process personal information using technical and other necessary measures such that the data recipient cannot re-identify specific individuals and the process is irreversible, or if we conduct de-identified research, statistical analysis, and forecasting to support business decisions and improve our products and services (including using anonymous data for machine learning or model algorithm training), the use of such processed data does not require separate notification to you or your consent.If we cease operation of LINGOMASTER products or services, we will promptly stop collecting your personal information, notify you of the cessation through individual delivery or public announcement, and delete or anonymize the personal information we hold related to the discontinued business.

2.2. Legal Basis for Data Processing

Legal Basis for Data Collection and Processing: In accordance with certain applicable laws (including the General Data Protection Regulation (GDPR)), we must disclose the legal bases for processing your data. If such laws apply to you, we will collect and process your personal data based on the following:

• Contractual Necessity: Necessary for the performance of our service agreement.

• Consent: Processed based on your consent, especially where required by law (you may withdraw your consent at any time by emailing baicizhan@baicizhan.com.

• Legal Obligation: Necessary for the fulfillment of our statutory obligations.

• Vital Interests: Necessary to protect the vital interests of you or other natural persons (unless overridden by your rights).

• Legitimate Interests: Necessary for the legitimate interests of ourselves or third parties, including our right to provide innovative, direct marketing, and security services.

2.3. Cookies and other technologies

Technologies such as cookies, tags, and scripts are used by LINGOMASTER and our third party service providers to analyze trends, administer the site, track users’ movements around the website and to gather demographic information about our user base as a whole.Log files: We gather certain information and store it in log files, including IP addresses, browser type, ISP, referring/exit pages, operating system, date/time stamp, and/or clickstream data.Local storage – HTML5/Flash: We might use Local Storage Objects (LSO) such as HTML5 or Flash to store content and preferences.Do Not Track (DNT): Numerous web browsers are equipped with a "Do Not Track" feature that transmits a DNT signal to the websites a user visits. At present, major internet standards organizations have not yet established a standardized policy or regulation governing how websites should respond to such requests. However, if your browser has "Do Not Track" enabled, all of our websites will acknowledge and honor your preference.

3. How we share, transfer, and publicly disclose your personal information

3.1. Sharing, Transfer, and Public Disclosure

We will not share your personal information with any company, organization, or individual outside of our Company, except where your explicit consent has been obtained. The following circumstances are exempt from this restriction:Sharing with Explicit Consent：Upon obtaining your affirmative and explicit consent, we may share your personal information with third parties.Legal and Statutory Obligations：Provision of information as required by applicable laws and regulations, legal proceedings, or mandatory administrative or judicial requirements.Contractual and Regulatory Agreements：Provision of information as stipulated in relevant agreements signed with you (including electronic agreements and platform rules) or other binding legal documents.Sharing your personal information with our affiliates.Entrusted Processing：Providing your personal information to trusted partners to process such information on our behalf, in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures.

Currently, our authorized partners include the following categories:

Suppliers of Goods or Technical Services：

• We may share your personal information with third parties that support our platform's functionality.

• This support includes infrastructure technology services, logistics and delivery, payment processing, and data processing. To facilitate core functions of our products/services (e.g., sharing order details with logistics providers for delivery; sharing transaction amounts with payment institutions for settlement; or utilizing third-party survey platforms to collect feedback).Third-Party Software Development Kits: To ensure the realization of relevant functions and the secure, stable operation of LINGOMASTER, we may integrate SDKs provided by third-party providers.

(Example: Getui SDK):

• Provider: Mobi-Interactive Co., Ltd.

• Data Collected: Device identifiers (including IMEI, IDFA, Android ID, device MAC address, HarmonyOS OAID, IMSI), application lists, network information (IP address, Wi-Fi details such as SSID, BSSID, MAC, Wi-Fi password, and DHCP info), location-related data, and AP scan results.

• Purpose: To provide push notification services; collecting OAID and other identifiers to tag devices for precision delivery.

• Method: Local collection via SDK

We conduct rigorous security audits of third parties and stipulate data protection measures by agreement. For details, please refer to our "List of Personal Information Shared with Third Parties."

3.2. Public Disclosure

We will only publicly disclose your personal information under the following circumstances:

• Upon obtaining your explicit consent;

• Legally mandated disclosure: When required by law, legal proceedings, litigation, or mandatory requests from competent government authorities.

3.3. Exceptions to Consent Requirement

Prior authorized consent is not required for the sharing, transfer, or public disclosure of your personal information in the following situations:

• Related to national security or national defense;

• Related to public safety, public health, or significant public interests;

• Related to criminal investigation, prosecution, trial, and enforcement of judgments;

• To protect life, property, or other significant legal rights of yours or others where obtaining consent is impractical;

• Personal information already disclosed to the public by yourself;

• Information collected from legal and public channels (e.g., legitimate news reports or government information disclosures).

Please be advised: In accordance with applicable laws, if personal information is processed using technical and other necessary measures such that the recipient cannot re-identify specific individuals and the process is irreversible, the sharing, transfer, or public disclosure of such processed data shall not require separate notification to or consent from you.

4. How we store and protect your personal information

4.1.Security safeguards

We are committed to keeping your personal information secure. We have put in place all legally required physical, electronic and managerial procedures to safeguard and secure the information. All your personal information is stored on secure servers and protected in controlled facilities.

4.2.Retention policy

Generally, we will retain your personal information only for the minimum period necessary to achieve the purposes of providing the Services to you, except in the following circumstances:

• To comply with applicable laws, regulations, or other relevant statutory provisions;

• To comply with court judgments, rulings, or the requirements of other legal proceedings;

• To comply with the law enforcement requirements of relevant government authorities.

In the event of a cessation of operation of our products and/or services, we will notify you through methods such as push notifications or public announcements. Furthermore, we will delete or anonymize your personal information within a reasonable period, unless otherwise mandated by applicable laws and regulations.

4.3.How your personal information is transferred globally

Our headquarters are located in Singapore. For the purposes of achieving unified global management and providing services, we will transfer the aforementioned personal information collected from you—which is necessary for the provision of services—to our headquarters, LIG EDUTECH PTE.LTD., located in Singapore (please note that the App will not transmit your national identification number across borders). You may contact us via baicizhan@baicizhan.com to exercise your rights as a data subject. Your personal information may also be transferred to other countries providing processing services to us in accordance with our instructions.Regardless of where your personal information is transferred, we will obtain your separate consent and inform you of the relevant details regarding the processing of your personal information (for details, please refer to the Cross-border Data Transfer Statement). If we need to transfer personal information out of your jurisdiction, we will comply with relevant applicable laws and ensure that such transfers meet local legal requirements by implementing unified safeguards.The internet environment is not entirely secure. We will endeavor to ensure and warrant the security of any information you transmit to us. You acknowledge and understand that the systems and communication networks utilized to access our Services may experience issues due to factors beyond our reasonable control. Accordingly, you should take proactive measures to protect the security of your personal information. We strongly recommend that you refrain from disclosing personal information contained within the Product to third parties (including other websites or products linked hereto) to prevent data leakage. Please utilize complex passwords and refrain from disclosing your account credentials or relevant personal information to others to assist us in maintaining your account security.In the unfortunate event of a personal information security incident, we will, in accordance with the requirements of applicable laws and regulations, promptly inform you of: the basic circumstances and potential impact of the security incident, the disposal measures we have taken or intend to take, suggestions for your independent prevention and risk reduction, and available remedial measures. We will promptly notify you of the incident details via email, mail, telephone, push notification, or other similar methods. Where it is difficult to notify each personal information subject individually, we will issue a public announcement in a reasonable and effective manner. Simultaneously, we will proactively report the handling and status of the personal information security incident to regulatory authorities as required.

5. Your rights

5.1. Controlling settings

You may restrict the collection, use, disclosure or processing of your personal information and control your privacy settings, such as signing in or out of the LINGOMASTER Account.

5.2. Your rights to your personal information

Subject to the applicable laws and regulations, you may have the following data protection rights as a user of our services and to withdraw your consent. You also have the right to complain to the local authorities.To exercise any applicable rights below or to exercise any other statutory data subject rights you may enjoy under applicable laws and regulations, you may contact us using the contact details under the “Contact Us” heading below.To protect the security of your account and your personal data, we may ask you to provide certain additional information before we respond to your requests. Under some circumstances, we may refuse to comply with your request as permitted by applicable laws and regulations. We may also charge a reasonable fee for complying with your request in accordance with applicable law (e.g. if your request is clearly repetitive or excessive).

5.2.1. Right to Know about Personal Data Collected or Disclosed

You may have the right to access your personal data that we hold about you, such as

• information whether your personal data is collected or disclosed,

• categories of your personal data which has been collected or disclosed,

• categories of sources from which your personal data is collected, and (iv) business or commercial purpose for collecting or disclosing your personal data (if any).

You may have the right to require us to provide a duplicate of your processed personal data, subject to submitting a verifiable request to us using the contact information in section “Contact Us” below. You may also be able to exercise the right to access some of your personal data through the privacy setting available in the services (e.g. profile/personal page or privacy dashboard), where applicable.

5.2.2. Right to Rectify / Right to Correct

If we process your personal data, we endeavour to ensure by implementing suitable measures that your personal data is accurate and up to date for the purposes for which it was collected. If your personal data is inaccurate or incomplete, you may have the right to request for rectification of your inaccurate personal data according to applicable laws and regulations and you may be able to modify the information in the privacy setting of the services (if available).

5.2.3. Right to Request Deletion of Personal Data

You may have the right to request the deletion of your personal data, if the purpose(s) for processing as stated in Section 2 and Section 13 of this Privacy Policy does not exist anymore, or if there is another legal ground for its deletion, subject to submitting a verifiable request to the contact details under the “Contact Us” below.You acknowledge and agree that as a result of deleting your account, you will lose access to services, including the account information, subscriptions and information linked to such account, and lose the possibility to access other services through the account.

5.2.4. Right to Opt-out of Marketing Communications

You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing messages we send you.

5.2.5. Right to Complain

You may have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority where applicable.

5.2.6. Right to Withdraw Your Consent

If we have collected and processed your personal data based on your consent, you can withdraw your consent in accordance with applicable laws. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted in reliance on lawful processing grounds other than consent. In many circumstances, we need to use your personal data in order for us to provide you with our services which you require. If you do not provide us with the required personal data, or if you withdraw your consent to our use and/or disclosure of your personal data for these purposes, it may not be possible for us to continue to serve you or provide you with the services that you require.Please be aware that advertisers or websites with links to and/or from our websites may collect personal data about you. This Privacy Policy does not apply to such third party services, and cannot control the activities of, those other advertisers or websites. We highly recommend that you read the privacy policy of such third-party websites which you may be directed to before providing any personal data.

6. Children’s Privacy and Protection of Minors

Pursuant to relevant laws and regulations, if you are a child under the age of 13, you shall, in accordance with the registration and usage procedures, obtain the prior consent of your parent or legal guardian. Furthermore, your parent or legal guardian shall assist you in completing the registration process for the Services to facilitate your use of the Services provided by us. If you are the guardian of a minor under the age of 13, you shall read and agree to this Privacy Policy on behalf of your ward before utilizing the Services.We protect the personal information of minors in accordance with the provisions of relevant national laws and regulations. We will only collect, use, or disclose the personal information of minors where permitted by law, with the explicit consent of the parents or other guardians, or where necessary for the protection of the minor. If we discover that we have collected the personal information of a minor without obtaining prior verifiable parental or guardian consent, we will endeavor to delete the relevant information as promptly as possible.

6.1. Countries where we operate an Age-Gate

In certain countries, such as the United States, we may be required by law to operate an age-gate, where, when a user indicates that they are a child, we do not collect or process their personal data until they are no longer a child as defined above or until their parent or guardian provides consent and/or enables access to particular features. In these circumstances, the personal data we collect may include:

· Date of birth and country to determine age and apply appropriate settings

· Persistent identifiers like IP address, UIDs, necessary website tracking technologies, and device identifiers in order to provide and maintain our services (including analytics to improve them), protect the security and integrity of users and ensure legal and regulatory compliance.

For clarity, the data indicated above (including persistent identifiers) will be collected and processed prior to obtaining parent or guardian consent, for the purposes stated and to support internal operations, for example, to trigger the age-gate and other internal operational purposes.

7. How we update this privacy policy

We review and update this Privacy Policy periodically. If we make material changes, we will notify you via registered contact information or a notice on the website.

8. Contact us

If you have any comments or questions about this Privacy Policy, please contact：

LIG EDUTECH PTE.LTD.

60 PAYA LEBAR ROAD, #11-53, PAYA LEBAR SQUARE, SINGAPORE 409051

[email address]：baicizhan@baicizhan.com

[number]：+6531588866

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Additional Information for US Residents

1.1. General

Why We Collect and Process Your Personal Data

In order to provide our services to you, we collect and process the following categories of personal data described in more detail in Section 1, for one or multiple purposes described below, and for any other purposes for which we provide specific notice at the time the information is collected.

1.1.1. Data Retention

Where your data is required to be deleted in accordance with your request or where we are legally required to do so under applicable law or otherwise, we may retain certain personal information where permitted or required under law. For example, we may retain persistent identifiers such as device ID, device FP, IP address and other device information that was collected prior to obtaining verifiable parental consent, for the purpose of supporting internal operations.

1.1.2. Your Rights and Choices

If you submit a request to us and you receive a response from us informing you that we have declined your request, in whole or in part, where provided by applicable law, you may appeal that decision by submitting your appeal using the contact method described in this Privacy Policy.

1.1.3. Right to Opt-out of Targeted Advertising and Data “Sales”

Some privacy laws define “sale” broadly to include some of the data disclosures described in Section 6 above – in particular certain sharing with third party providers for targeted advertising purposes. To opt-out from targeted advertising and any related data “sales,” you have several options.

You can use browser or device-level controls as follows:

• Cookie controls. Please see (AboutCookies.org) for details on how you can control cookies. Note that if you choose to refuse or delete cookies, this could affect certain features, settings and preferences controlled by those cookies including advertising preferences which may be deleted and may need to be recreated.

• Do Not Track. Some browsers include a "Do Not Track" (DNT) setting that can send a signal to the websites you visit indicating you do not wish to be tracked. Our websites do not respond to browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the advertising controls described above.

• Mobile advertising ID controls. iOS and Android operating systems provide options to limit tracking and/or reset the advertising IDs.

• Email web beacon controls. Most email clients have settings that allow you to prevent the automatic downloading of images, including web beacons, and the automatic connection to the web servers that host those images.

These choices are specific to the device or browser you are using. If you access our services from other devices or browsers, take these actions from those devices or browsers to ensure your choices apply to the data collected when you use them.

1.2. Additional terms for California Residents

Additional terms for California Residents California Consumer Privacy Act. The CCPA requires us to provide our users who reside in California with the additional notice below. For the purposes of this notice, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).

Personal Information does not include information that is:

• Lawfully made available from government records.

• Deidentified or aggregated.

• Otherwise excluded from the scope of the CCPA.

We collect and disclose the categories of personal information as set out in Section 1.1 above, for the business purposes also set out in Section 1.1.If you are a California resident, and the processing of personal information about you is subject to the CCPA, you have certain rights with respect to that information:

• Notice at Collection. At or before the time of collection, you have a right to receive notice of our practices, including the categories of personal information and sensitive personal information to be collected [Section 1], the purposes for which such information is collected or used [Section1], whether such information is sold or shared[Section3], and how long such information is retained [Section 4]. You can find those details in this Privacy Policy by referring to this and the above-referenced sections.

• Right to Know. The right to request a copy of the personal information that we have collected about you in the prior 12 months. You also have a right to request additional information about our collection, use, disclosure, or sale of such personal information. Note that we have provided much of this information in this Privacy Policy. You may make such a “request to know” as described in Section 8 of this Privacy Policy.

• Rights to Request Correction or Deletion. You also have rights to request that we correct inaccurate personal information and that we delete personal information under certain circumstances, subject to a number of exceptions. To make a request to correct or delete, please do so using our account information functionality or email us using the contact information in Section 12 of this Privacy Policy.

• Right to Opt-Out / “Do Not Sell or Share My Personal Information”. You have a right to opt-out from future “sales” or “sharing” of personal information as those terms are defined by the CCPA.

Note that the CCPA defines “sell,” “share,” and “personal information” very broadly, and some of our data disclosures described in this Privacy Policy may be considered a “sale” or “sharing” under those definitions. In particular, we let advertising and analytics providers collect identifiers (IP addresses, cookie IDs, and mobile IDs), activity data (browsing, clicks, app usage), and device data through our sites and apps when you use our online services, but do not “sell” or “share” any other types of personal information. If you do not wish for us or our partners to “sell” or “share” personal information relating to your visits to our sites for advertising purposes, you can make your request by emailing us using the contact information in Section 12 of this Privacy Policy. If you opt-out using these choices, we will not disclose or make available such personal information in ways that are considered a “sale” or “sharing” under the CCPA. However, we will continue to make available to our partners (acting as our service providers) some personal information to help us perform advertising-related functions. Further, using these choices will not opt you out of the use of previously “sold” or “shared” personal information or stop all interest-based advertising.We do not knowingly sell the personal information of minors under 16 years of age.

· Right to Limit Use and Disclosure of Sensitive Personal Information. You have a right to limit our use of sensitive personal information for any purposes other than to provide the services or goods you request or as otherwise permitted by law. Note that we do not use sensitive personal information for any such additional purposes.

You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.Further, to provide, correct, or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We will verify your request through common market practices, including by asking you to send it from the email address associated with your account or requiring you to provide information necessary to verify your account.

You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.Additionally, under California Civil Code section 1798.83, also known as the “Shine the Light” law, California residents who have provided personal information to a business with which the individual has established a business relationship for personal, family, or household purposes (“California Customers”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes.Please be aware that we do not disclose personal information to any third parties for their direct marketing purposes as defined by this law.California Customers may request further information about our compliance with this law by emailing the address provided in the "Contact Us" section above. Please note that businesses are required to respond to one request per California Customer each year and may not be required to respond to requests made by means other than through the designated email address.California residents under the age of 18 who are registered users of online sites, services, or applications have a right under California Business and Professions Code section 22581 to remove, or request and obtain removal of, content or information they have publicly posted. To remove content or information you have publicly posted, or to request that we remove such content or information, please send us a detailed description of the specific content or information you wish to have removed using the details provided in the "Contact Us" section above. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.An authorized agent may submit an access or deletion request on your behalf by sending a written authorization signed by you using the contact information in the “Contact Us” section. We may still require you to directly verify your identity and confirm that you provided the authorized agent permission to submit the request.

2. Additional Information for the EEA and UK residents

If you are in the European Economic Area (EEA) or the United Kingdom (UK), the following additional information applies to you in addition to the Privacy Policy set out above.

2.1. Data Subject Rights

• In addition to the information set out in the "Your rights and choices" section in the Privacy Policy above, you have the right to:

• ·ask us to restrict the processing of your personal data,

• data portability,

• to object to the processing of personal data.

2.2. Legal basis for processing your personal data

Our legal basis for collecting and using the information described in section 1 for the purposes in section 2 of our Privacy Policy above is:

• To establish and perform our contract with you (i.e. our Terms of Service) and to provide our services;

• For our or our partners’ legitimate interests, where those interests are not overridden by your data protection interests of fundamental rights and freedoms, e.g. to protect our legal rights, to pursue or defend legal claims, to improve our services;

• Consent, where obtained separately;

• For compliance with our legal obligations under applicable laws and regulations;

• To protect our or your vital interests or those of another person (for example, another player), e.g. against fraud and violations of our terms;

• While we typically do not collect sensitive or special category personal information, where we do this, it will be on the grounds of explicit consent or other applicable lawful basis.Where we rely on a legitimate interest for the processing of your data, we have performed a legitimate interest assessment to determine whether your interests outweigh our interests in the processing taking place. You can obtain more information about this balancing test by using the contact details under ‘Contact Us’.If you have questions, need further information about the legal bases for processing your personal information, or want to withdraw your consent, please see section 12 “Contact Us” in the Privacy Policy above.

2.3. Cross-border data transfer

As a global company, we may transfer your personal data to our affiliates, third party service providers and partners that operate around the world, which are located in countries other than the country in which you are resident (e.g. Singapore/China). These countries may have data protection laws that are different to the laws of your country.Where we transfer your personal information to countries and territories outside of the European Economic Area and the UK, which have been formally recognised as providing an adequate level of protection for personal information, we rely on the relevant “adequacy decisions” from the European Commission, where applicable.Where the transfer is not subject to an adequacy decision, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy. The safeguards we use are the European Commission’s Standard Contractual Clauses as issued on 4 June 2021, including the UK Addendum, and/or the UK International Data Transfer Agreement permitted under Article 46 of the UK GDPR. This is how transfers of personal information between us and other companies will be safeguarded. All companies are required to protect personal information that they process from Europe in accordance with European Union data protection law. Transferred personal information includes basic information such as your name or contact information such as your email address.

2.4. Children's Notice

We protect the personal information of minors in accordance with the provisions of relevant national laws and regulations. We will only collect, use, or disclose the personal information of minors where permitted by law, with the explicit consent of the parents or other guardians, or where necessary for the protection of the minor. If we discover that we have collected the personal information of a minor without obtaining prior verifiable parental or guardian consent, we will endeavor to delete the relevant information as promptly as possible.

Data Protection Supervisory Authority To lodge a complaint with your national or regional data protection supervisory authority, please contact the competent authority.

3. Additional Information for Residents of Japan

If you are located in Japan, please see the information below with regard to international data transfers as described in Section 1.1.1 (Data Retention), in accordance with Article 28(2) of the Japanese Act on the Protection of Personal Information.

3.1. the name of the countries where the data recipients are located (headquartered)

Singapore

China

United States of America

3.2. the personal information protection systems of such foreign countries

See the link below

3.3. the measures to be taken by the data recipients

We will ensure that third parties in foreign countries to which we transfer your personal data take all measures corresponding to the eight principles of the OECD privacy guidelines.

4. Additional Information for residents of South Korea

If you are in South Korea, the following additional information applies to you in addition to the Privacy Policy set out above.

Destruction of Your Personal Data.If we determine that your personal data is no longer needed, we will destroy it under the supervision of our chief privacy officer and in accordance with applicable law and the Privacy Policy. Personal data in the form of electronic files will be securely deleted using technical methods to prevent recovery and reproduction, and printouts will be destroyed by shredding or incineration.Data Subjects Rights.In addition to the information set out in the "Your rights and choices" section in the Privacy Policy above, you have the following rights:

4.1. Right to Request the Suspension of Processing

You may have the right to request the suspension of processing of your personal data that we have collected and processed. However, such a request may be denied under applicable laws or regulations.In many circumstances, we need to process your personal data in order to provide you with the services you require. If you do not provide the necessary personal data, or if you request the suspension of its processing for these purposes, we may be unable to continue providing you with the services you require.

Location of Servers

The servers for the services we provide are located as follows:

United States of America

Singapore

China