Reef Games Privacy policy

Last updated: Feb. 15, 2025

1. WHO WE ARE

1.1. Reef Games respects the privacy of users of its Services, as defined below, and complies with applicable laws for the protection of the privacy, including, without limitation, the European Union General Data Protection Regulation (“GDPR”), the California Consumer Privacy Act (“CCPA”), the UK GDPR, the Lei Geral de Proteção  de Dados (“LGPD”), consumer privacy laws of Virginia, California, Colorado,  Connecticut, Utah and other states and jurisdictions. We are Reef Games LTD.,  located at Griva Digeni, 51, ATHINAION COURT, Flat/Office 202, 8047, Paphos, Cyprus (“Reef Games”). Please, see section 12  for details of the Service Support. 

1.2. This Privacy Policy shall be read alongside, and in addition to, our Terms of Use (the “Cookie Policy”). 

1.3. This Privacy Policy sets out how we collect and use your personal information when you (i) use the services offered by Reef Games and its subsidiaries by visiting  our website; 

(ii) use Reef Games Ecosystem, Games, and the Website as 

defined in the Terms; and (iii) use the mobile, online, and downloadable products and services (the “Services”) offered by Reef Games and its affiliates on the Website and  the choices available to you in connection with our use of your personal information  (the “Privacy Policy”). 

1.4. It is reminded that information collected via the Reef Games Ecosystem,  including, without limitation, Games, and the Website offered by Reef Games LTD. and its affiliates is used by Reef Games LTD., responsible for its processing. 1.5. In case of any contradictions between this Privacy Policy and the Terms, this Privacy Policy will prevail. 

1.6. Please note that if you use other products and services that Reef Games suggests on the Reef Games Website and you register “extra” accounts, additional  privacy policies shall be applied and accepted by you. 



2. THIS PRIVACY POLICY

2.1. By making the Services available, we, acting reasonably and in good faith,  believe that you: 

(a) have all necessary rights to register on the Website and use the Services; (b) provide true information about yourself to the extent necessary for the use of the Services; 

(c) understand that, by posting your personal information, if there is such a technical possibility in the Services, and where it is accessible by other users of the Services,  you have manifestly made this information public, and this information may become available to other Website users and Internet users, be copied, and be disseminated  by them; 

(d) understand that some types of information transferred by you to other Service users cannot be deleted by you or by us; 

(e) are aware of and accept this Privacy Policy. 

2.2. We do not check the user information received from you, except where such a

check is necessary in order for us to fulfill our obligations to you.



3. INFORMATION WE COLLECT ABOUT YOU

3.1. In order to implement the agreement between you and us, and provide you with access to the use of the Services, we will improve, develop, and implement new features of our Services, and enhance the functionality of the available Services. To achieve these objectives, and in compliance with applicable laws, we will collect,  store, aggregate, organise, extract, compare, use, and supplement your data  (hereinafter “processing”). We will also receive and pass this data, and our  automatically processed analyses of this data, to our affiliates and partners as set  out in the table below and in section 4 of this Privacy Policy. 

3.2. We set out in more detail the information we collect when you use our Services, why we collect and process it, and the legal basis below. 

3.3. General clauses, which shall apply to your use of the Website and the Services related to online and downloadable products of Reef Games and its affiliates:

  1. Information Collected: Data you provide for registering in the  Services, including your e-mail and/or mobile phone number

    Purpose: We use this information in order to manage and administer the Services provided to you. We use this data to enable us to fulfil our obligations to you as part of the Services (e.g. in cases where you request restoration of your account). See section 8.3 of this Privacy Policy for more information. We also use this information in order to provide you with updates and information on our and selected third parties’ products and services we think you may be interested in. You can use unsubscribe button on you Profile page in the Service or in the email itself in case you are no longer interested in the receiving of the updates.

    Legal Basis: Legitimate  interests Performance of  our contract with you Consent

  2. Information Collected: Where necessary, a copy of your identity or  another document containing  your first name, surname, photograph, number  of the principal identity  document of you or your representative,  payment details, and other additional data that  you may provide us with, including through our Support Service. We may take  additional verification steps,  which we consider  reasonable in order to verify your account.

    Purpose: We use this data in order to identify you, verify your account, and prevent abuse and infringement of your or other persons’ rights. For example, we use this information to verify your identity if you lose your credentials and wish to access your account with us.

    Legal Basis: Legitimate interests Performance of  our contract with you Processing is  necessary for compliance  with a legal obligation (e.g.  right of access granted by  GDPR).

  3. Information Collected: Additional data you  provide when you edit  your profile page or  your profile pages at  dedicated Services, including your first  name and surname,  nickname, gender,  date of birth, avatar picture, and language preferences.

    Purpose: We use this information in order to provide our Services to you, to manage and administer Services, and as additional information to verify your account to prevent abuse and infringement of your or other persons’ rights. We also use this information in order to provide you with updates and information on our and selected third parties’ products and services we think you may be interested in. We use this information in order to tailor and improve the advertisements that may be presented on the Website and in our other products and services that you may choose to use, and to measure the effectiveness of these advertisements.

    Legal Basis: Legitimate  interests Performance of  our contract with  you Consent

  4. Information Collected: Additional data  received when you access the Services, including information regarding technical devices, technical interaction  with the Service such  as your IP-address, time of registration in the  Service, device IDs, country  and language settings,  device model and operating system used, system information and  memory usage data, your  installed apps, type of  browser, your Internet provider  and/or phone network  operator, network type, screen resolution, RAM size,  and other identifiers characterizing theInformation that is automatically  received at the time of access to  the Services with the use  of cookies.

    Purpose: We use your data for internal review in order to constantly improve the content of our Services and web pages, to optimise your user experience, to understand any errors you may encounter when using the Services, to notify you of changes to the Services, and to personalise the use of our Services. We use this information in order to tailor and improve the advertisements that may be presented on the Website and in our other products and services that you may choose to use, and to measure the effectiveness of these advertisements.

    Legal Basis: Legitimate  interests Performance of  our contract with you Consent

  5. Information Collected: Information that is automatically  received at the time of access to  the Services with the use  of cookies.

    Purpose: Please see our cookies policy which sets out the types of cookies we use and what we use these cookies for. We use this information in order to tailor and improve the advertisements that may be presented on the Website and in our other products and services that you may choose to use, and to measure the effectiveness of these advertisements.

    Legal Basis: Consent

  6. Information Collected: Information that is  created by you while  using the Services (if  there is such a technical possibility  in the Services), including information that you  post in any game forums  and/or chat rooms.  Depending on the Services and  place of posting (chat room or forum), this  information can be available to  some or all other users of our Services.

    Purpose: We use this information in order to manage and administer the Services, including providing our services to you.

    Legal Basis: Legitimate  interests, which, inter alia, include  the processing of data manifestly made  public by you, where it is  accessible by other users of  the Services Performance of  our contract with you Consent

  7. Information Collected: Information obtained  as a result of your  behavioural actions when using Services, information obtained as a result  of your use of the payment features of Services  (for example, PAN(the  first and last four digits of  your bank card), cardholder's  name, service code, the card expiration date, email,  IPaddress), information about payments  (date, amount, payment  type, payment status), information about  goods and services  purchased (name, amount), information about the activation status of  goods and services  purchased, including information obtained by the  “Main” account from your  “extra” accounts in order to  match this data to your user account, etc.

    Purpose: We use this information in order to manage and administer the Services, including providing our services to you. We use this information in order to tailor and improve the advertisements that may be presented on the Website and in our other products and services that you may choose to use, and to measure the effectiveness of these advertisements. We process such information in full conformity with PCI DSS, being a globally recognized set of security standards designed to ensure the safe handling and protection of cardholder data.

    Legal Basis: Legitimate  interests, which, inter alia, include  the processing of data manifestly made  public by you, where it is  accessible by other users of  the Services Performance of  our contract with you

  8. Information Collected: Information that is  created by you while placing requests to our  Service Support.

    Purpose: We use this information in order to verify your identity and to fulfil your support request. We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service.

    Legal Basis: Legitimate  interests Performance of  our contract with you

  9. Information Collected: Data collected via  third parties, including your social network IDs, application store IDs, nickname, e-mail and friends list, when you register in our  Services via your social or  application store accounts  and/or connect your social account to our  Services (e.g. Facebook,  Twitter, Google, YouTube).

    Purpose: We use this information in order to manage and administer the Services provided to you. We use this information for certain social functions of our Services, such as to show you your friends who play the same game as you. We also use this information in order to provide you with updates and information on our and selected third parties’ products and services we think you may be interested in.

    Legal Basis: Legitimate  interests Performance of  our contract with you

  10. Information Collected: Information that is received as the result  of your behavioural  actions when using the  Services (including your game actions and  achievements, badges). This  information may be available to  other users of our Services  (e.g. on leader boards).

    Purpose: We use this information in order to manage and administer the Services, including providing our Services to you. We may also use this data in order to tailor and improve the advertisements that are presented to you to and to measure the effectiveness of these advertisements.

    Legal Basis: Legitimate  interests

  11. Information Collected: Information that is received about you as  the result of other users’ actions on the  Services (in particular,  information posted in chat rooms  and forums by other  users).

    Purpose: We use this information in order to manage and administer the Services, including providing our Services to you. We use this information in order to verify your identity, manage, and administer the  Services, including providing our Services to fulfil your support request. We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service.

    Legal Basis: Legitimate  interests Performance of  our contract with you

    3.4. In the case that you use the mobile Services of Reef Games and its affiliates, the clauses below shall apply in addition to the clauses above:

  12. Information Collected: IData obtained via third parties, including your social network IDs, application store IDs, social network  nickname, e-mail and friends  list, when you connect your social account (e.g. Facebook, Google, YouTube, or Apple  Game Center) to our  Services.

    Purpose: We import this information into your profile. We use this information in order to manage and administer the Services provided to you. We use this information for certain social functions of our Services, such as to show you your friends who play the same game as you, or to provide you with the ability to post your achievements into your social account. We also use this information to retain the data about your usage of our Services (such as game progress and achievements) across your different mobile devices, which are connected to the same social account.

    Legal Basis: Legitimate  interests Performance of  our contract with you

  13. Information Collected: Information that is received as the result  of your use of the  payment functionality of the Services (for  example, PIN (first and last four  digits of your bank card  number), cardholder's name,  service code, the card  expiration date, email, IP address, that are required in  order to match these details  with your account).

    Purpose: We use this information in order to manage and administer the Services, including providing our Services to you. We may also use this data in order to investigate any complaints on your behalf and to provide you with a more efficient service. We process such information in full conformity with PCI DSS, being a globally recognized set of security standards designed to ensure the safe handling and protection of cardholder data.

    Legal Basis: Legitimate  interests Performance of  our contract with you

  14. Information Collected:Information about purchases or  transactions you have made. 

    Purpose: We may also use this data in order to tailor and improve the advertisements that are presented to you to and to measure the effectiveness of these advertisements.

    Legal Basis: Legitimate  interests Performance of  our contract with you

  15. Information Collected: Additional data received when you access the Services, including information regarding technical devices, 

    technical interaction  with the Service, such as  your IP-address, time of registration in the  Service, device IDs, country  and language settings,  general and/or precise  location data, device model  and 

    operating system  used, crash data from the  app, information about the performance of the  app on the device, information about the apps installed on your device, type of browser, your Internet provider and/or phone network operator,  network type, screen  resolution, or RAM size, manufacturer, processor model, number of processor cores; manufacturer, model,  video card identifier; video memory size; DirectX version, dxdiag, and  other identifiers  characterizing the Internet service provider.

    Purpose: We use your data for internal review in order to constantly improve the content of our Services and web pages, to optimise your user experience, to understand any errors you may encounter when using the Services, to notify you of changes to the Services, and to personalise the use of our Services. We may also use this data in order to tailor and improve the advertisements that are presented to you to and to measure the effectiveness of these advertisements.

    Legal Basis: Legitimate  interests. Performance of  our contract with you

  16. Information Collected: Information that is  created by you while using  the Services (if there is  such a technical possibility  in the Services), including information that you  post in any game forums  and/or chat rooms, inter alia, information about  your files or documents,  your photos and/or videos,  your voice, such as a  voicemail or a sound recording  data. Depending on the  Services and place of posting  (chat room or forum), this information can be available to some or  all other users of our  Services.

    Purpose: We use this information in order to manage and administer the Services, including providing our services to you.

    Legal Basis: Legitimate  interests, which, inter alia, include  the processing of data manifestly made  public by you, where it is  accessible by other users of  the Services Performance of our contract with you

    3.5. In case you choose to use the games which are part of our downloadable  Services that include our anti-cheat system, we may also undertake certain actions to prevent fraudulent activity in our Services, improve our Services  and provide you with better user experience, such as automatic collection and  processing of screenshots of your screen during the time when the game is launched and the game's window is not minimized to ensure users’ compliance with the Terms of Use  of the relevant Service. Please be aware that such collection and processing of the screenshots complies at any time with this Privacy Policy and no decisions are  based solely on automated processing. 

    3.5.1. If you decide to use the Games that are part of our downloadable Services including the anti-cheat system, we may also process the information obtained through the anti-cheat system, including: sections of computer RAM used by you simultaneously with the launch and/or operation of the Game, as well as the following data: (a) system procedures, including threads, hotkeys and timer  processes, (b) network filters, including Windows firewall rules and visited DNS, (c) performance counter and performance monitoring interrupt events, (d) User account information, including account ID and server information, (e) access to graphics library methods (such as Direct3D) such as setting of rendering state and drawing, (e) User  equipment information (device information, software information (including OS and drivers), processing information including icon hash and timestamps, system information including display settings). This information is processed in order to prevent  fraudulent activities in our Services, improve our Services and provide you with a better user experience. 

    3.6. Our legitimate interests include (1) maintaining and administrating the Services; (2) providing the Services to you; (3) improving the content of the Services and web pages; (4) processing of the data that was manifestly made public by you where it is accessible by other users of the Services; (5) ensuring your account is adequately protected; and (6) complying with any contractual, legal, or egulatory obligations  under any applicable law. 

    3.7. As part of maintaining and administrating the Services, we use the information  to analyse user activity and to ensure that the rules and Terms of Use of the Services  are not violated. 

    3.8. Your personal information may also be processed if it is required by a law enforcement or regulatory authority, body, or agency, or in the defence or exercise of legal claims. We will not delete personal information if it is relevant to an investigation or a  dispute. It will continue to be stored until those issues are fully resolved and/or during the  term that is required and/or permissible under applicable/relevant law.

    3.9. In case you provided us with a consent to the sending of marketing information, you may withdraw your consent to the sending of marketing information to you by amending your privacy settings in your account. An option to unsubscribe will also  be 

    included in every SMS or e-mail sent to you by us or our selected third party partners. 3.10. Please note, that if you do not want us to process sensitive and special categories of data about you (including data relating to your health, racial or ethnic origin, political opinion, religious or philosophical beliefs, sex life, and/or your sexual orientation), you have to take care not to post this information or share this data on  the Website and/or Services. Once you have provided this data, it will be accessible by other Website users and it becomes difficult for us to remove this data. 3.11. Please note, that if you withdraw your consent to data processing or you do not provide the data that we require in order to maintain and administer the Services, you may not be able to access the Services or register with the web pages of the  Website. 

    3.12. If we intend to further process your data for any other purpose besides those  set out in this Privacy Policy, we shall provide you with details of these purposes before  we commence data processing. 

4. DATA SHARING

4.1. Publicly available data. Your username and other information that you provide or post while using the Services can be available to all users of the Services. We take technical and organisational measures to ensure that your data is safe. Please note, that by posting your personal information in publicly accessible areas (resources accessible by other users of the Services), you have manifestly made this  information 

public, and it may become available to other users of the Services and Internet users and be copied and/ or disseminated by such users. Please keep in mind that once  other users have gained access to or copied your data, neither you nor we are able to  delete or remove such data from possession of those other users. 

4.2. Sharing with third parties. We may share your personal information with third parties only in the ways that are described in this Privacy Policy. Sometimes we may need to provide your data to our affiliated entities, as well as our partners, in order to provide you with the Services offered by Reef Games and its affiliates, to administer  the Services, for example, if you choose to share your data across other social media platforms, to administer the billing services or to personalize, adjust and improve our Services or in other cases described in this Privacy Policy and only subject to the purposes described in this Privacy Policy. We do not sell your personal information  to third parties.

The transmissions of personal data with the recipients (whatever their legal status, subcontractor, processing manager or just recipient) are carried out in a secure  manner and in application of an agreement between us and each recipient as may be necessary under applicable law. We undertake to ensure that each recipient knows  the directive principles of personal data protection and submit to them in application  of the law and/or of a particular contract. 

4.3. Confidentiality obligations. In case we share your data with selected third  parties, including our third party contractors and application developers, we always  ensure that these third parties undertake confidentiality obligations regarding your  personal data collected while you use of the services or applications they offer. The developers use the information provided to them in order to provide you with additional services, including technical support, if applicable. We will not share your personal data  outside the scope of purposes specified in this Privacy Policy without your prior consent.

4.4. Advertising disclaimer. Our ad management and recommendation system is designed so that your information will not be shared directly with our third party advertisers. An advertiser or maker of a recommendation can only choose to target advertisements to groups of users falling within criteria such as gender, general location (country, city), or other, or to target communities according to their types. If you fall within one of the target groups, you will receive an advertisement or recommendation of such third party partners or our affiliates. However, such third  party advertisers or our affiliates may gather some of your information in case you interact  in any way with the ads provided by such advertisers. 

4.5. Integrated advertising, analytics and transfer of data to partners. We may share your personal information with analytical systems for the purposes of performance measurement of our Website and our Services, and we may also provide such information to third parties such as advertisement networks and our partners  engaged in operation of the Services. By using our Services, you agree that we may transfer your data to such third parties and accept that your data will be processed in accordance with privacy terms of such third parties. The current list of integrated  third party systems used by us and other cases of data transfer is provided in analytics systems list 

4.6. In some cases, we will rely on your consent to provide your personal information  to the third-party advertisement networks in order to serve you with a personalized ads experience. The purpose of showing personalized ads is to improve our game  services and your experience therein and to provide you with content relevant to you. You  have 

the option to withdraw your consent for personalized advertising at all times by changing your choice in the App settings through Privacy Setting (in some cases it might be named Privacy) button. 

Once you withdraw your consent you still might see a number of ads while using services, that might be less relevant to your interests and they will not be based on topics you like. The advertisement will be based on the content you using, i.e. contextual advertisement. 

4.7. Retargeting disclaimer. An advertiser or maker of recommendations may also choose to upload a list of identifiers (e.g., e-mails, phone numbers) and identities to  our systems so that we (but not the adviser or maker of recommendations) can check  for user matches. They will see the number of matches but not the matches  themselves. 

4.8. Sharing in the general conduct of business. We may also share your data with  our affiliates and keep some of your personal information in our business records for the accounting and compliance purposes. As such, you hereby consent that we may  also transfer your personal information to a third party if we decide to transfer or sale of  all or substantially all of our business to which this Privacy Policy relates to, whether by merger, sale of stock, sale of assets, or otherwise, if permitted by and done in accordance with applicable law, so you can continue to receive service and  information in connection with that business with as little disruption as possible. Similarly, you hereby consent that in that case your personal data will be processed by our  successor or assignee in accordance with this Privacy Policy. 

4.9. Disclosure to tax authorities. We reserve the right to disclose your personal information to tax authorities in case it is necessary because of your participation in public tournaments. We may also publish your data as part of the tournament score tables on our and third party Websites. 

4.10. Disclosure required by law. We reserve the right to disclose your personal information as required by law, by court order or in special cases when we have  reason to believe that disclosing such information is necessary to identify, contact, or bring legal action if you or third parties are violating the Terms, any other terms of services provided by us or our affiliates or any applicable law, for the purpose of defence of  our 

rights and interests. We also reserve the right to disclose your personal information  if we have a good faith belief that it is necessary to prevent fraud or other illegal activities. 

5. PRIVACY SETTINGS

5.1. The Services may contain links to Websites operated by third parties. We are not responsible for your data privacy when you access these links or engage with third party services, and you shall ensure that you review the relevant third party’s privacy statement, which will govern your data privacy rights. 

5.2. In case you intend to connect your YouTube or Google account to the Reef  Games Ecosystem using YouTube API Services, you may review and, if necessary, adjust  your YouTube privacy settings at Google security settings page at

https:// security.google.com/settings/security/permissions before linking or connecting  them to our Website or Service. You can find more information on YouTube and Google’s privacy at https://policies.google.com/ and Google Privacy Policy at Google Privacy Policy at http://www.google.com/policies/privacy. 

5.3. We bear no liability for the actions of third parties, which, as the result of your  use of the Internet or the Services, obtain access to your information in accordance with the confidentiality level selected by you. 

5.4. We bear no liability for the consequences of the use of the information that, due  to the nature of the Services, is available to any Internet user. We ask you to take a responsible approach to the scope of the information posted on the Website.

6. INTERNATIONAL TRANSFERS

6.1. Sometimes, when it is reasonably necessary, we may transfer and maintain  some of your personal information on our servers or databases outside the European Economic Area (EEA), including in CIS. 

6.2. Some of the countries to which we transfer your data may not have the same  data protection laws as your jurisdiction. In such case, we will take reasonable cyber security measures and/or put in place where required the Standard Contractual Clauses (e.g. Model Clauses, Data Processing Agreement/Addendum) to ensure  your 

data is adequately protected. 

7. RETENTION PERIODS

7.1. We will retain your personal information for as long as required to perform the purposes for which the data was collected, depending on the legal basis for which  that data was obtained and/or whether additional legal/regulatory obligations mandate  that we retain your personal information during the term that is required and/or  permissible 

under applicable/relevant law. 

7.2. You may delete your personal data by removing the data from your account; alternatively, you can delete your account. 

7.3. You may request to remove your account and data on our Services by contacting the Service Support (see section 12 for details). 

7.4. We may remove your account or the information you post, as provided by the Terms. 

8. YOUR RIGHTS

8.1. You have the following rights, in certain circumstances, in relation to your  personal information: 

(a) Right to access your personal information. 

(b) Right to rectify your personal information: you can request that we update, block,  or delete your personal data, if the data is incomplete, outdated, incorrect, unlawfully received, or no longer relevant for the purpose of processing. 

(c) Right to restrict the use of your personal information. 

(d) Right to request that your personal information is erased if: 

it is no longer required in relation to the purposes for which it was gathered or processed in another way; 

you withdraw your consent concerning processing subject to consent; you are justifiably opposed to the processing; it has been subject to illicit processing; or it is imposed by law. 

(e) Right to object to processing of your personal information. 

(f) Right to data portability (in certain specific circumstances). 

(g) Right not to be subject to an automated decision. 

(h) Right to lodge a complaint with a supervisory authority.

(i) For processing based upon your consent, the right withdraw that consent at any time. 

(j) You may have other rights under your legislation of your country of residence, including right to define the instructions relative to the outcome of your personal  data 

after your death. 

(k) You may, subject to the limitations indicated below, set one of the following confidentiality levels for your Reef Games account: 

information available to any Internet user; 

information available to the users of the Services having the status of your friends on the Services; information available only to You and no one else. The following information is always available to any Internet user: your nickname  and avatar picture, link to your Reef Games account, last login date, time spent on the Reef Games Ecosystem and/or on any part thereof. Despite of the confidentiality level for your Reef Games account change, information indicated in the sixth table line of Clause 3.3 shall remain available on the Reef  Games Ecosystem. 

Please be aware that Internet users, who have accessed your personal information in accordance with the confidentiality level selected by You, may disclose such information to others. In case of removal of your information from your account or removal of your account from the Services, your information copied by other persons  or 

stored on other persons’ pages may remain available on the Reef Games Ecosystem.

8.2. You also have the right to independently remove personal information on your account and make changes and corrections to your information, provided that such changes and corrections contain up-to-date and true information. You can also view  an 

overview of the information we hold about you. If you reside in France you have the right to register on the list of opposition to telephone canvassing on www.bloctel.gouv.fr. 

8.3. If you would like to exercise these rights, please contact Service Support writing  to Griva Digeni, 51, ATHINAION COURT, Flat/Office 202, 8047, Paphos, Cyprus (“Reef Games”). We will aim to respond to you  within 30 days from the date of receipt of your request. We will need to verify your  identity before we are able to disclose any personal data to you. 8.4. In case you provided the access of the GAMES Ecosystem to your YouTube account (for example if you registered on the GAMES Ecosystem using YouTube  social network account) you can revoke that the access of the GAMES Ecosystem to your YouTube account via the Google security settings page at  

https://security.google.com/ 

settings/security/permissions. 

9. YOUR CALIFORNIA PRIVACY RIGHTS

9.1. This notice to California residents is provided under California law, including the California Consumer Privacy Act (“CCPA”), Cal. Civ. Code 1798.100, et seq. This  notice supplements our Privacy Policy by explaining your California privacy rights if  you are a California resident, and provides certain mandated disclosures about our  treatment of California residents’ information, both online and offline.

9.2. If you are a California resident you have the following rights in relation to your personal information: 

(a) Right to Access. If you are a California resident, you have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, and sell. 

(b) Right to Delete. If you are a California resident, you have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions. 

(c) Process to Make a CCPA Request. To make an access or deletion request, please send your enquiries to Service Support  

writing to Griva Digeni, 51, ATHINAION COURT, Flat/Office 202, 8047, Paphos, Cyprus (“Reef Games”) 

(d) Before completing your request, we may need to verify your identity or the identity of your authorized representative. We will then take action to verify your  email address and may request additional documentation or information solely for the purpose of verifying your identity. 

(e) Right to Opt Out of Sale of Personal Information. If you are a California resident, you have the right to “opt out” of the “sale” of your “personal information” to “third parties” (as those terms are defined in the CCPA). You can exercise this right by clicking here. Our Privacy Policy describes the limited circumstances in which we  may share your information with third parties. Our Privacy Policy also provides you with certain controls and choices regarding our collection, use, and sharing of your information. 

(f) Right to Non-Discrimination: You have the right not to receive discriminatory treatment for the exercise of your privacy rights conferred by the CCPA. (g) Shine the Light Act. If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your  personal information by us and our affiliates to third parties for the third parties’ direct marketing purposes. We are dedicated to treating your personal information with  care 

and respect. For inquiries regarding our disclosure policy, you may send your  enquiries writing to Griva Digeni, 51, ATHINAION COURT, Flat/Office 202, 8047, Paphos, Cyprus (“Reef Games”). (h) Authorized Agents. If you would like to designate an authorized agent to make a request on your behalf, please be sure the agent can (i) demonstrate you have  provided 

written permission for the agent to submit the request on your behalf, and (ii) provide proof of his or her own identity. If the agent does not satisfy these requirements, we  will deny the request. 

(i) Privacy Rights for California Minors. If you are a California resident under the age of 18, California Business and Professions Code Section 22581 permits you to view, correct and request the removal of content or information you have posted to the  Site, message boards, or forums. You may exercise this right you may send your enquiries  writing to Griva Digeni, 51, ATHINAION COURT, Flat/Office 202, 8047, Paphos, Cyprus (“Reef Games”). Note that any information posted to the message boards or forums is publicly viewable. We  strongly recommend that all users avoid posting personal or sensitive information. Residual copies of content and/or information that have been deleted may remain on our backup servers. We do not have to remove posted content or information if it has been rendered anonymous. We may retain your information to resolve disputes,  enforce our user agreements, or comply with legal requirements; in this case, your personal information will be blocked from use for any other purpose. Additionally, we do not have control over third parties (e.g., other users) who may have copied or reposted  the 

content or information. 

9.3. Mandatory Disclosures. In addition to the information provided elsewhere in our Privacy Policy, we make the following disclosures for purposes of compliance  with 

the CCPA: 

• We collected the following categories of personal information in the last 12 months: Identifiers, contact Information, demographic information, payment information associated with you, commercial information (such as information  about goods and services you have purchased), Internet or other electronic network activity information, including information obtained from third parties, general location data (country, city), electronic information, and inferences drawn from the above. For detailed information please refer to “INFORMATION WE COLLECT ABOUT YOU” Section of this Privacy Policy. 

• The sources of personal information that we collected are: our users, directly, third party sites or platforms that you link with your registration account, analytics tools, social networks, advertising networks, and trusted sources who update or supplement information we hold about you. 

• The business or commercial purposes of collecting personal information are described in the “INFORMATION WE COLLECT ABOUT YOU” Section of this Privacy. • We disclosed the following categories of personal information for a business purpose in the last 12 months: IP addresses, Identifiers, , information about your web browsing and app usage, demographic information, payment information associated with you, commercial information, Internet or other electronic network activity information, including information obtained from authorisation services of third  parties, general location data (country, city), electronic information, and inferences drawn  from the above. We disclose these categories outside only as described in the “DATA SHARING” Section of this Privacy Policy. 

• Although we do not sell personal information for monetary consideration, some of our partners may collect and process information when you interact with our Services, including IP addresses, digital identifiers, information about your web browsing and app usage, and how you interact with our advertising properties and  ads 

in order to provide you with relevant ads across the Internet and for other analytics purposes, and such partners may “sell” that information to other businesses for advertising and other purposes under the definition of “sale” in the CCPA. • As the term is defined by the CCPA, we “sold” the following categories of personal information in the last 12 months: IP addresses, Identifiers/Contact Information, Internet or other electronic network activity information, including information about your web browsing and app usage, and inferences drawn from the above. We “sold” each category to social networks (for the authorization purposes), advertising networks, data analytics providers and our infrastructure service  providers. 

• The business or commercial purposes of “selling” personal information is for third party companies to perform services on our behalf, like marketing, advertising, performance and audience measurement. 

• We do not “sell” personal information of known minors under 16 years of age. 9.4 Online Tracking/Do Not Track. We and our third party service providers may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites. California Business and Professions Code Section 22575(b) (as amended effective January 1, 2014) permits our users who are California residents to be informed as to how we respond to Web browser "Do Not Track" settings. As Do Not Track is a standard that is currently  being 

developed, we do not take actions to respond to Do Not Track settings, and instead  we adhere to the standards set out in this Privacy Policy.

10. SECURITY MEASURES

10.1. We take technical, organisational, and legal measures, including, where  suitable, encryption, to ensure that your personal data is protected from unauthorised or accidental access, deletion, modification, blocking, copying, and dissemination.

10.2. Access to the Services is authorised using your login (e-mail address or mobile phone number) and password. You are responsible for keeping this information confidential. You shall not share your credentials with third parties and we  recommend you take measures to ensure this information is kept confidential.

10.3. If you forget your login details, you can request us to send you an SMS or e mail, which will contain a restoration code. 

10.4. To reduce the probability of third parties gaining unauthorised access, if you  login to your account from an unusual place or after several failed attempts to provide  valid login details, we may block entry to your account. You will then need to contact  Service Support and provide certain additional information to verify your credentials and gain access to your account. 

11. CHANGES TO THIS POLICY

11.1. From time to time, we may change and/or update this Privacy Policy. If this Privacy Policy changes in any way, we will post an updated version on this page. We will store the previous versions of this Privacy Policy in our documentation archive.  We recommend you regularly review this page to ensure that you are always aware of  our information practices and any changes to them.

12. CONTACT US

12.1. If you have any questions, please send your enquiries writing to Griva Digeni, 51, ATHINAION COURT, Flat/Office 202, 8047, Paphos, Cyprus (“Reef Games”). Please quote this Privacy Policy so we can deal with your enquiry efficiently. We will aim to respond to you within 30 days from receipt of your request. 

12.2. All correspondence received by us from you (written or electronic enquiries) is classified as restricted-access information and may not be disclosed without your written consent. The personal data and other information about you may not be used without your consent for any purpose other than for responding to the enquiry,  except 

as expressly provided by law. 

12.3. If you have any questions about your personal data processing, enforceability  of this privacy policy or any other privacy concern, contact us marketing@reefgames.team

13. PRIVACY NOTICE FOR PARENTS/LEGAL  GUARDIANS

13.1. The Services are intended to be appropriate for general audiences and are not specifically aimed at children (the exact age is determined depending on the  applicable law). Reef Games does not intentionally collect personal information from children obtaining necessary parental approval in accordance with applicable legislation,  such as the U.S. Children’s Online Privacy Protection Act and the UK Age appropriate  design code. Authorized child accounts are treated like other accounts unless otherwise is required by applicable law. Children can get access to the Services with a suitable  age restriction and can exercise rights available to other Users. For additional details  about what personal information Reef Games collects from children, how Reef Games uses 

that personal information and information regarding Reef Games disclosure  practices for such information, please see “the “INFORMATION WE COLLECT ABOUT YOU” and “DATA SHARING” Section of this Privacy Policy. Please, note that during the use of  the Service children as the other Users may make their personal information publicly available by posting their personal information in publicly accessible areas  (resources 

accessible by other users of the Services). We encourage parents to discuss with  their children the importance of personal data protection. 

13.2. We will not require a child to provide more information than is reasonably necessary in order to use the Services. 

13.3. If under applicable law a parental consent is required, children can use the Services and register account on the Reef Games Ecosystem only with the parental consent. For the purpose of parental consent, when setting up an account, a child  must provide email address of his/her parent/ legal guardian. We use that email address  to contact the child’s parent/legal guardian to ask for his/her consent for child’s registration on the Reef Games Ecosystem and our use of the child’s personal data  in 

respect thereof. Information on the parental consent (with email address of parent/ legal guardian) shall remain available on the Reef Games Ecosystem. We will use  email address of parent/ legal guardian solely for parental consent purposes.

13.4. At any time, parents/legal guardians shall have the right to review their child’s personal information, the right to refuse to permit us to further collect or use of their child’s personal information , and the right to request the deletion of their child'spersonal information. Parents/legal guardians can exercise any right indicated  herein by sending a corresponding request via marketing@reefgames.team

13.5. For the matters related to children’s personal data collecting parents/legal guardians can contract us at marketing@reefgames.team