PRIVACY POLICY

Effective Date:  February 19, 2025

1.  Introduction

FUNFLY PTE. LTD. (the “Company”, “we”, “our”, or “us”), together with its partners, parent companies, subsidiaries, licensees, licensors and affiliates (collectively, the “Affiliates”) develop, publish, market and commercialize a variety of games for use on various platforms, including mobile devices (our “Applications”) through which we offer relating game play and gaming services, including the ability to make purchases through the Applications. We also operate networks and platforms related to our Applications (collectively “Networks”), web domains and subdomains (collectively “Sites”) and web forums or messaging boards related to our Applications and Sites (collectively “Forums”). Any and all of our Applications, Networks, Sites, Forums and any other related services provided by us are referred to herein as our “Services”.

To the extent permitted by applicable law, children under the age of 13 (or other age threshold required by local laws) are not allowed to use the Services. If you are 13 or older but considered a minor in your country (e.g. under 18 years old in some jurisdictions), you must have your parent or legal guardian read through this Privacy Policy with you and you represent that you have obtained the permission of your parent or guardian to use the Services.

If you are a parent or legal guardian of a minor in your country, please make sure that you have read this Privacy Policy before allowing your children to create their own accounts or to use the Services. You agree that you will be subject to this Privacy Policy and be responsible for your children’s activities while using the Services. You agree to supervise your children’s use of the Services and make sure that your children only view the contents that are age-appropriate to your children.

2. Contact Us

If you have questions regarding data protection or requests related to your personal data, we encourage you to reach out to us primarily through the support features available in our games, as this allows us to respond to you more promptly. Alternatively, you can contact us at:

l  privacy@firstfun.com

3. Notice

We recommend that you read this Privacy Policy in full to ensure you are completely informed about your personal information.

This Privacy Policy is intended to provide notice of the Company’s information practices, including the types of personal information gathered, how personal information is used and safeguarded, and how you may control the maintenance and sharing of your personal information. This Privacy Policy applies to personal information we collected through our Services and applies to all users of our Services globally. By clicking or checking “I agree”, “Accept” or similar statements on our Applications and Sites, or by accessing or using any part of our Applications, Sites and/or Services, you acknowledge that you have read and understood this Privacy Policy, and hereby agree and consent to our collection, use, disclosure and/or processing of your personal information as described in this Privacy Policy. If you do not agree with any terms of this Privacy Policy, please do not access or use our Services.

4. What Information We Collect About You

We may collect personal information about you in the following ways: (1) directly from you, (2) automatically through your use of our Services, or (3) from third parties. The personal information we receive depends on factors such as the Service you’re using, third parties we partner with or you integrate with, and your privacy settings.

4.1. Information that you provide directly

We collect personal information directly from you when you choose to provide us or our Affiliates with such personal information online and through your other interactions with us (such as data collected via social media and any surveys, customer service communications, competitions or other promotional programs in which you may participate). Certain parts of our Services may ask you to provide personal information when you engage in activities such as email association, contacting customer service and purchase or delivery of goods/services.

4.2. Information that we collect indirectly

We collect your personal information indirectly, including through automated means from your device when you use our Services. Some of the information we collect indirectly may be captured using tracking technologies, as explained further in the "Mobile IDs and Tracking Technologies" section below.

4.3.  Information from third parties

We may also collect your personal information from third party sources, for example:

Social Media and Third-Party Partners. We may collect any of the below categories of information from third-party applications, including social networks, that you choose to connect or interact with through our Services.

Service providers. Third parties collect or provide any of the below categories of information in connection with work they do on our behalf or in collaboration with us. For example, we use vendors to provide customer service communications in our Applications. They may collect the content of communications, your name, username, and contact information, and any other information you provide to them.

The table below describes the categories of personal information we collect from and about you through our Services. This information will be combined with other information contained in our systems.

For some websites, apps, or services provided by us, we may collect additional information beyond the above listed information. We will develop individual privacy notices to inform you how we process your personal data when you use the specific services. Such individual privacy notices will prevail in terms of the personal data processed for such individual services. When you are asked to provide personal information, you may decline. And you may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow our collection, use, disclosure or processing of personal information that is necessary for certain services or features, those services or features may not be available or fully functional.

5. Mobile IDs and Tracking Technologies

Mobile analytics and advertising IDs are generated by operating systems for mobile devices (iOS and Android) and can be accessed and used by Applications in much the same way that websites access data. Our apps contain software that enables our third-party analytics and advertising partners to access the mobile IDs.

6. How We Use, Disclose or Process Your Information

We may use, disclose or process the personal information we collect for purposes described in this Privacy Policy or for purposes that we explain to you at the time we collect your information. Where we process the personal information of EU and UK users, depending on our purpose for collecting your personal information, we rely on one of the following legal bases:

Contract – we require certain personal information in order to provide and support the Services you purchase or request from us;

Consent – in certain circumstances, we may ask for your consent (separately from any contract between us) before we collect, use, or disclose your personal information, in which case you can voluntarily choose to give or deny your consent without any negative consequences to you;

Legitimate interests – we will use or disclose your personal information for the legitimate business interests of either us or a third party, but only when we are confident that your privacy rights will remain appropriately protected. If we rely on our (or a third party's) legitimate interests, these interests will normally be to: operate, provide and improve our business, including our Services; communicate with you and respond to your questions; improve our Services or use the insights to improve or develop marketing activities and promote our products and services; detect or prevent illegal activities (for example, fraud); and/or to manage the security of our IT infrastructure, and the safety and security of our employees, customers and vendors. Where we require your data to pursue our legitimate interests or the legitimate interests of a third party, it will be in a way which is reasonable for you to expect as part of the running of our business and which does not materially affect your rights and freedoms. We have identified below what our legitimate interests are; or

Legal obligation – there may be instances where we must process and retain your personal information to comply with laws or to fulfil certain legal obligations.

The following table provides more details on our purposes for processing your personal information and the related legal bases. The legal basis under which your personal information is processed will depend on the data concerned and the specific context in which we use it.

For the purposes set forth above, our affiliates may be authorized to process your information, provided that such affiliates comply with the terms in this Privacy Policy.

We combine information we collect from different sources for these purposes and to give you a more seamless, consistent, and personalized experience.

7. Who May Access Your Personal Data

In addition to the Company and/or its affiliates, other parties may also access your personal data in the following situations. You acknowledge that you have foreseen the occurrence of such disclosure when you provide your personal data.

l  Public information: Some of your profile information can be seen by other players in the games such as your profile name (either the default name or a name that profile name of your choosing), your profile image (the default image, an image you select, or the profile photo associated with a linked account)，your comments and the level of the game you are playing. You may select options available to edit your name and/or profile name, change your profile picture, and certain other information. Any data you post to any communication area is publicly viewable. We strongly recommend that all users avoid posting personal or sensitive data at any time on or through our Services.

l  Third party social media platforms: Only at your direction, we will share information including your profile name, your player ID, your profile picture and certain in-game content (such as the level of game you are playing, screenshots of your gameplay) to your accounts with third party social media platforms.

l  Service providers: We may provide personal information to third party vendors, service providers, contractors or agents who perform functions on our behalf for the purposes described in this Privacy Policy. For example, this includes companies we hired to provide customer services support and game play analysts.

l  Financial services and payment processing:  
When you provide payment information,for example to make a purchase, such payment and transactional data will be used by the banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, analytics, or other related financial services.

l  Affiliates: We enable access to personal information across our subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access helps us to provide our Services and operate our business.

l  Corporate transactions: We may disclose personal information as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.

l  Legal and law enforcement: We will access, disclose, and preserve personal information when we believe that doing so is necessary to comply with applicable law, a judicial proceeding, court order, or other valid legal process, including from law enforcement or other government agencies, whether within or outside Singapore.

l  Security, safety, and protecting rights: We will disclose personal information if we believe it is necessary to: to protect us, our users, and others, for example to prevent spam or attempts to commit fraud, or to help prevent the loss of life or serious injury of anyone; to operate and maintain the security of our Services, including to prevent or stop an attack on our computer systems or networks; or to protect the rights or property of ourselves or others, including to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, enforce our agreements, terms, and policies, or as support or evidence in any dispute or litigation in which we are involved.

Third party analytics and advertising companies may also collect personal information through our Services, including identifiers and device information (such as device IDs, MAIDs, and IP address), IP address, usage data, and inferences based on and associated with that data. Some of the disclosures to these third parties may be considered a “sale” or “sharing” of personal information as defined under the laws of California and other U.S. states. Please see the “What Choices Do You Have” and relevant subsection in the “Supplemental Terms – Jurisdiction-Specific” section below for more details.

Please note that some of our Services also include integrations, references, or links to services provided by third parties whose privacy practices differ from ours. If you provide personal information to any of those third parties, link or bind your accounts, or allow us to share personal information with them, that data is governed by their privacy statements.

8. What Choices Do You Have

We provide a variety of ways for you to control the personal information we hold about you, including choices about how we use that information. In some jurisdictions, these controls and choices may be enforceable as rights under applicable law. If you are a resident in the UK, EEA or Switzerland, or if you are a resident in the California, please see the respective subsections in the Supplemental Terms – Jurisdiction-Specific section below.

(1) Access, portability, correction, and deletion. In some jurisdictions, you have the right to access, receive a copy of, correct, and delete your personal information. If you reside in one of these jurisdictions, and you wish to access, receive a copy of, correct, or delete personal information about you that we hold, you may make your request by emailing privacy@firstfun.com. We may need you to provide some personal information so that we may verify your request and locate your personal information to fulfill your request.

Please note that certain records, for example those relating to payments or customer service matters, will be held for legal and accounting purposes. If you have previously receive push notifications through your device, you can stop receiving push notifications by visiting your mobile device's settings for the relevant Application or in some cases, through the Application itself.

You acknowledge and agree that as a result of deleting your account, you will lose access to game related services, including the account information and game-related information linked to such account and lose the possibility to access other services through the account.

(2) Withdrawal of consent. If we have collected and processed your personal data with 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.

(3) Communications preferences. If any promotional communication has been made to you, you may opt-out of promotional communications by following the opt-out instructions contained in the promotional communications, or by contacting us as described in the “Contact Us” section below. Please note that it may take some time for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you e-mails about your account or any Services you have requested or received from us.

(4) Data sales. Some privacy laws define “sale” broadly to include some of the disclosures described in the “Who May Access Your Personal Data” section above. To opt-out from such data “sales”, visit our Do Not Sell or Share My Personal Information section below, use the Global Privacy Control as described below, or email your request to privacy@firstfun.com.

(5) Browser or platform controls.

Cookie controls. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our Sites. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may also be deleted and may need to be recreated.

Global Privacy Control. Some browsers and browser extensions support the “Global Privacy Control” (GPC) or similar controls that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales and/or targeted advertising, as specified by applicable law. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting or similar control that is recognized by regulation or otherwise widely acknowledged as a valid opt-out preference signal.

Do Not Track. Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our Sites do not currently respond to browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described above.

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

(6) Email web beacons. Most email clients have settings which allow you to prevent the automatic downloading of images, including web beacons, which prevents the automatic connection to the web servers that host those images.

Except for the automated controls described above, if you send us a request to exercise your rights or these choices, to the extent permitted by applicable law, we may decline requests in certain cases. For example, we may decline requests where granting the request would be prohibited by law, could adversely affect the privacy or other rights of another person, would reveal a trade secret or other confidential information, or would interfere with a legal or business obligation that requires retention or use of the data. Further we may decline a request where we are unable to authenticate you as the person to whom the data relates, the request is unreasonable or excessive, or where otherwise permitted by applicable law. If you receive a response from us informing you that we have declined your request, in whole or in part, you may appeal that decision by submitting your appeal using the contact methods described at the beginning of this Privacy Policy.

9. Third Party Partners

Our partners use technologies to enhance and customize your experience, analyze usage, and prevent fraud. Please be aware that our partners may have their own privacy policies governing their use of these technologies (as illustrated in the examples below). When specific third parties are involved in collecting data and information, please refer directly to their privacy policies on their official websites and learn more about their data processing practices.

10. Retention of Personal Information

We retain personal information for as long as necessary to provide the Services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs vary for different information types in the context of different services, actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the data, the availability of automated controls that enable users to delete data, and our legal or contractual obligations.

Details of retention periods for different aspects of your personal information are available from us on request by contacting us using the contact details provided under the “Contact Us” heading above.

In the case you request to remove or delete your personal data, we will retain your data as long as necessary for applicable laws and regulations, such as to comply with our legal obligations, resolve disputes, and/or enforce the agreements between you and us. Please note that the removal or deletion of any of your data may result in the termination of some of our applicable Services.

11. Location and International Transfer of Personal Information

The personal information we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, partners, or service providers process data. The storage locations are chosen to operate efficiently and improve performance. We take steps with the intent of processing and protecting personal information as described in this Privacy Policy, wherever the personal information is located.

To the maximum extent permitted by the applicable laws and regulations, we may transfer information that we collect about you to our affiliated entities, partners, service providers, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, and we take appropriate steps to ensure adequate safeguards are in place to enable transfer of information and the use and disclosure of information about you, including personal information, as described in this Privacy Policy.

12. Security of Your Personal Information

We have implemented commercially reasonable precautions designed to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Unfortunately, the transmission of information via the internet is not completely secure. While we strive to protect your personal data, we also remind you to be aware of hacking, cyber-attacks, and other risks on the Internet.

Therefore, we strongly urge you to take every possible precaution to protect your personal data when using our Services, including but not limited to using a secure browser and/or taking other possible security measures.

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.

13. Age Limits and Children Protection

You represent that you are not a child under the age of 13. Children under the age of 13 (or other age threshold required by local laws) are not allowed to use the Services, to the extent permitted by applicable law. If you are 13 or older but considered a minor in your country (e.g. under 18 years old in some jurisdictions), you must have your parent or legal guardian read through this Privacy Policy with you and you represent that you have obtained the permission of your parent or guardian to use the Services.

If you are a parent or legal guardian of a minor in your country, please make sure that you have read this Privacy Policy before allowing your children to create their own accounts or to use the Services. You agree that you will be subject to this Privacy Policy and be responsible for your children’s activities while using the Services. You agree to supervise your children’s use of the Services and make sure that your children only view the contents that are age-appropriate to your children.

Notwithstanding the foregoing, we recognize that we have a special obligation to protect children in regard to the collection and processing of personal data. We strongly urge parents and guardians to instruct their children to never disclose or give out their personal data when using our Services without the prior permission of their parent/guardian. If we learn that we have collected personal data about a child under the age of 13, we will take steps to delete that data as quickly as possible. Also, if you believe that we might have any data from or about a child, please contact us using the contact details under the “Contact Us” above.

14. Supplemental Terms – Jurisdiction-Specific

(1) Additional Information for the UK, EEA or Swiss residents

If the processing of personal information about you is subject to UK or European Economic Area (EEA) or Swiss data protection law, you have certain rights with respect to that data:

l You can request access to, and rectification or erasure of, personal information;

l If any automated processing of personal information is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal information in a usable and portable format;

l If the processing of personal information is based on your consent, you can withdraw consent at any time for future processing using the contact details provided under the “Contact Us” heading above. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data conducted in reliance on lawful processing grounds other than consent;

l You can object to, or obtain a restriction of, the processing of personal information under certain circumstances;

l You have the right to opt-out of marketing communications if we send you any of them any time. You can usually exercise this right by following the opt-out instructions contained in the marketing communications we send you. You can also contact us using the contact details provided under the “Contact Us” heading. If you choose to opt out of marketing communications, we will still send you non-promotional emails, such as emails about your account or our ongoing business relations;

l You have the right to complain to a supervisory authority about our collection and use of your personal data. For more information, please contact your local supervisory authority. Certain supervisory authorities require that you exhaust our own internal complaints process before looking into your complaint; and

l For residents of France, you can send us specific instructions regarding the use of your personal information after your death.

To make such requests, contact us at privacy@firstfun.com.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

(2) Additional Information for California Residents

If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (“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, the purposes for which such information is collected or used, whether such information is sold or shared, and how long such information is retained.

Right to Know. You have a right to request that we disclose to you the personal information we have collected about you. 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” by contacting us at privacy@firstfun.com.

Right to Request Deletion. You also have a right to request that we delete personal information under certain circumstances, subject to a number of exceptions. To make a request to delete, you may email us at privacy@firstfun.com.

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 (if any) as those terms are defined by the CCPA.

Note that the CCPA defines “sell” and “personal information” very broadly, and some of our data sharing described in this Privacy Policy may be considered a “sale” under those definitions. To opt-out from “sales” or “sharing” of personal information, please use the Global Privacy Control as described herein, or email your request to privacy@firstfun.com. 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. We collect and process the contents of your communications on our Services for the purpose of facilitating those communications, to provide customer service and respond to user complaints regarding violations of our Terms of Service. If you have any questions regarding our use of such sensitive personal information, please contact us using the contact information provided at the beginning of this Privacy Policy.

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 it 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 by asking you to send your request or confirm your request from the email address associated with your account or requiring you to provide information necessary to verify your account.

Finally, you have a right not to be discriminated against for exercising these rights set out in the CCPA.

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. In general, if the business has made such a disclosure of personal information, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom personal information was disclosed in the preceding calendar year, as well as a list of the categories of personal information that were disclosed. California Customers may request further information about our compliance with this law by e-mailing privacy@firstfun.com. 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 request that we remove content or information you have publicly posted, email us at privacy@firstfun.com. 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.

15. Effective Date; Policy Changes

Each time you use our Services, the current version of the Privacy Policy will apply. Accordingly, when you use our Services, you should check the date of this Privacy Policy (which appears at the top of the Privacy Policy) and review any changes since the last version.

This Privacy Policy is subject to change from time to time. Unless stated otherwise, our current Privacy Policy applies to all personal information that we have about you. If we make material changes to the Privacy Policy, we will provide notice or obtain consent regarding such changes as may be required by law. Your continued access to or use of our Services after such notice had been given and such revised Privacy Policy had come into effect shall constitute your acceptance of the revised Privacy Policy.