PRIVACY POLICY GOFRA GAMES, S.L.

Gofra Games, S.L. (hereinafter, "Gofra", "we", "our" and "us") hereby inform you on how we compile, use and protect your personal information and personal details. It also describes your rights and how you can access and update such information.

This Privacy Policy applies to the personal information and personal details provided by our visitors and/or users (hereinafter, “you” or “User”) through (i) our website www.gofragames.com (hereinafter, "Site"); (ii) through any Gofra's online games accessible through any platform, applications or software (hereinafter the "Game") or through any other services we can provide you, collectively referred as our "Services"; or, (iii) through any other means in which we may be collecting your personal information and personal details with reference to this Privacy Policy (all referred as “Means of Collection”)

Gofra respects the legislation on the protection of personal data, the Users’ privacy and the confidentiality and security of personal data. All our Users' data will be processed in accordance with the principles of legality, loyalty and transparency, purpose limitation and time limits for storage of personal data, data minimization, accuracy, integrity and confidentiality, among others, as well as respecting the all obligations and guarantees set forth in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, (GDPR) and Ley Orgánica 3/2018 of 5 December (LOPDGDD) by adopting for said purposes all necessary technical and organisational measures in order to prevent the loss, misuse, alteration, unauthorised access and theft of the personal data provided, given the state of technology, the nature of the data and the risks to which they are exposed.

1. Data controller

Identity:                      Gofra Games, S.L.

ID Company:              B67603068.

Postal Address:       Calle D’Olivella número 17, Planta 1ª Puerta 2ª, 08870 Sitges (Spain)

                                       Registered in the Mercantile Chamber of Barcelona, sheet 181, book 47.315, sheet number                                        B-548.305

Site:                             www.gofragames.com

Email Address:        hello@gofragames.com

                                      gdpr@gofragames.com (to exercise your rights set out in section 9)

2. Personal data we collect about you

Personal data consists of information that identifies or makes it possible to identify individual persons such as name, email address, IP Address, etc.

We collect information you provide directly via (i) our website www.gofragames.com (hereinafter, "Site"); (ii) through any Gofra's online games accessible through any platform, applications or software (hereinafter the "Game") or through any other services we can provide you, collectively referred as our "Services"; or, (iii) through any other means in which we may be collecting your personal information and personal details (all referred as “Means of Collection”)

The information we collect includes personally identifiable information, which is any information that concerns you individually and would permit someone to identify you.

a. Information you provide upon registration to the Game

When you register to the Game to create your own personal account, we collect and process the following data:

    • Contact information. On registering or requesting to receive information from Gofra’s Services and updates,     promotions and/or marketing information we collect your nickname and email address and demographic information     including your country.

    • Account Registration. To register an account with us, you will be required to fill out a registration form on the Game     application. On registering to our Services, we collect your selected or designated nickname, email address and     demographic information including your country. You may also provide payment data and profile data such as a profile     photo. Please note you must have all rights over the photo you upload and you cannot upload in any event a photo of a     third party without their consent.

    • Credentials. We collect passwords, password hints, and other information for authentication and account access.

    • Payment Data. We may temporarily collect certain data necessary to process your payment on behalf of our     payment service providers. However, we do not collect or retain credit card information.

    • Other Unique Identifying information. It may include information you provide in-person, online or by phone or mail     when you interact with customer service; your written, voice or video responses to customer surveys or contests; the     usernames of your social network accounts; or, any additional information you have provided to us to facilitate delivery     of Gofra Services and to respond to your inquiries.

If you choose not to register to the Game you will be able to use the Service. You will not be required to share with us your personal data, but some functionalities, such as purchasing the virtual gems and coins or participating in a competition may be limited. In this case, we still collect the information collected automatically set out in section 2b.

b. Information Collected Automatically

When you access or use the Site and/or our Services, we automatically collect information about your device and how your device interacts with our Site and /or Services.

We collect automatically and process the following data:

    • Cookies. The Site server’s, the Service' servers, or the servers of third parties that are used to operate the Site and/or     the Services, may place a "cookie" on your device, store data in your device’s browser or access pre-existing removable     tracking features on your device in order to allow you to use the Services and to personalize your experience. A "cookie"     is a small piece of data that can be sent by a web server to your device, which then may be stored by your browser on     your device’s hard drive. This technology allow us to recognize your device while you are using our Site and/or Services     and help customize your online experience. To learn more about how we use cookies, please visit our Cookie Policy.

    • In-game and device information. Information about the device you use to access the Site or the Services and     information on how you use and interact with our Services. For example, information about how and when you play our     Game or visit our Site, what device you use to access our services, the country from which you access to the game, the     virtual gems and coins you have in your account, your position in the rankings, information on how you interact with     the ads displayed in the Game, a specific player identifier, statistical data of the Service, the number of sessions and     length, store your Game sessions. We only collect this information when you are using the Game.

At any moment, you can disable the information that is collected automatically through settings in your device; however, if you choose not to share the information, in some cases we will not be able to provide you the Game or respond effectively for any queries you may have.

c. Additional data.

It is possible that from time to time we ask you for your consent to collect additional data from you or your device: for instance, (i) access to your contacts to invite them to participate; (ii) access to your GPS to know your locations; (iii) access to your camara and/or microphone to register your image and/or voice. In each case, we will inform you what information we would like to collect, the purpose for collecting and your rights.

3. Purpose of data processing

a. We collect, process and use your data for the following business purposes:

Purpose Information you provide upon registration Information collected automatically Additional data or information from third parties

To manage your relationship with Gofra and conduct ordinary business operations Yes Yes

To provide our Services to you Yes Yes

To communicate with you on Gofra’s Services Yes. Please note we may communicate with you even if the Game is in in a secondary plane or deactivated. At any moment, you can disable the communications you receive through settings in your device.

Transaction, process payment and purchase verification

  This information is collected and processed by Distribution Platform and Payment Service Providers. See below Section 5

Customer support

 Yes This information is collected and processed by Distribution Platform and Payment Service Providers. See below Section 5

Analytics and optimisation purposes Yes This information is also collected by Third Party Analytic Tools. See below Section 5

Create an in-game profile Yes

Personalisation of in-game offers Yes In-game advertising. Please note the game contains in-game advertising managed by the Distribution Platform. See below Section 5.

Fraud prevention Payment information is collected and processed by Distribution Platform and Payment Service Providers. See below Section 5

Marketing purposes Yes. See below section 3.b.

  In-game advertising. Please note the game contains in-game advertising managed by the Distribution Platform. See below Section 5.

Competitions Yes. Please note your profile can be shared when you enter in competitions. See below section 3.c. and 5.

b. Further purposes of processing: marketing and advertising purposes

With the free and optional User’s consent, some User’s personal data (name, surname and electronic mail) may be processed by Gofra also for marketing purposes.

Giving consent to personal data processing for such purpose is free and optional and, in the event such consent is missing, the possibility to use the Services is not prevented in any manner whatsoever. In the event that such consent has been granted, the relevant User may revoke the same without retroactive effects at any time whatsoever upon request to Gofra following the methods specified under the section entitled “Contact Us”. Once revoked the consent Gofra will send to the User an electronic mail message in order to confirm that the consent has been actually revoked.

c. Competitions

If you choose to participate in an in-game competition, we may use your data to manage your participation in the in-game competition. In that case, we will inform you clearly of the data collected, how this will be used, the purposes and your rights. Please note that participation in in-game competition may entail the publication of your nickname, photo, country, position within the game, statistical data of the game and score of the participants. That information will be processed in accordance with this Privacy Policy.

4. Legal basis of data processing

Contractual necessity and legitimate interest. The legal basis for the processing of your data is the fulfilment of the Service. The Game includes in-game offers and is in development; therefore, to provide the Service and based in the legitimate interest of the controller, considering the reasonable expectations of the user, we will also process your data for activities such as advertising, analytics, research and optimisation of our Game and other Services.

Consent. Your download and/or use of our Services constitutes your agreement and acceptance of this Privacy Policy and your consent to the practices it describes. If you have questions or comments about our Privacy Policy, please contact us as set forth in the section entitled “Contact Us” below.

You are not required to share the personal data that may be requested at any point; however, if you choose not to share the information, in some cases we will not be able to provide you the Services or respond effectively for any queries you may have.

When the User provide personal data electronically, the User guarantees that is older than 16 years old and the information given is precise and truthful. User agrees and acknowledges that he/she is responsible of the accuracy of the data provided and that she/she will provided the data up to date, being responsible of any false, incorrect or inexact data that he/she may have provided, as well as any direct or indirect damages that may arise.

Gofra has the commitment to collect the User express and verifiable consent to process their personal data for one or several specific purposes.

5. Sharing your data

We will only share your personal data as provided herein and, when applicable, only with the appropriate contractual obligations in place.

Your data can be transferred to service providers and partners that are essential for the correct execution of the Services or to correctly manage our relationship with you.

- Service providers. In particular, but not limited to, we inform you that we use the following service providers: Azure Microsoft.

- Distribution platforms. We collaborate with third party distribution platforms to distribute the Game, such as App Store or Google Play (“Distribution Platforms”). These Distribution Platforms provide you access to download the Game, act as payment service providers (see below) and may manage and personalise your experience within the in-game advertising. The exchange of personal data with these distribution platforms will be regulated by their user agreement and privacy policy. We advise you to consult your agreements with them and the settings in your device to understand the information these Distribution Platforms are processing as controllers.

- Account management providers. We collaborate with third party account management providers, such as App Store or Google Play (“Account Managers”). These Account Managers facilitate your registration to the Game using your account with them. By logging using Account Manager Providers, you may permit Gofra to access information related to your account with that Account Manager Providers, and the Account Manager Providers may be able to access information concerning your actions in the Game. The exchange of personal data with these Account Managers will be regulated by their user agreement and privacy policy. We advise you to consult your agreements with them.

- Payment service providers. Our payment service providers will provide us with information about your purchases so that we know if a purchase has been successful. When you purchase items via our mobile apps (such as those you can purchase in the App Store, on Facebook or on Google Play) we do not collect or store any payment information from you.

    • Your data can also be disclosed to the tax authorities and financial institutions.

    • Your data can also be disclosed when required by law.

- Third party analytic tools. We also use third party analytics tools to collect information about how you use the Services, such as Firebase and AppMetrica.

- Public profile. In case you choose to participate in a competition or in leagues, your nickname, photo, country, position within the game, statistical data of the game and score may be published and accessible by other participants of the competition or leagues, as well as by any other users of the Game.

We do not transfer personal data to third countries or international organisations outside the European Economic Area (EEA).

6. External Links

The Game may contain links, login interfaces and other connections to third party websites, applications and Platforms. Such third party services are provided solely as a convenience to You, and we shall not be deemed to endorse the content of third party services nor be made responsible for the content. Use of third party services may require you to accept additional terms. We are not responsible for examining or evaluating, and do not warrant the offerings of, any third party services, and you agree to use them at your sole risk. The user license agreement, terms of use, privacy policy and any other terms designated by the third party service will govern your use of that third party service. If you have any questions, concerns or complaints about a third party service, please contact the support or contact personnel of that third party service.

You understand and agree that all third party content that you may visualise or receive when using the Game and/or our Services, whether publicly posted or privately sent, including but not limited to advertising or links to different sites, is the sole responsibility of the person that sent the third party content.

We do not control third party content posted on our Services by other people and therefore we do not guarantee the accuracy, integrity or quality of that Content. You understand that when using our Services, you may be exposed to Content that you may consider offensive, indecent or objectionable. Under no circumstances will we be liable in any way for any Content, including, but not limited to, any errors or omissions in any Content, or any losses or harm of any kind resulting from the use of any Content posted, emailed, transmitted or otherwise made available via our Services.

7. Data Retention period

We retain your personal data during the necessary time to provide you the services, fulfil with any existing contractual obligation between the parties and or correctly manage the relationship with you, with legitimate and essential business purpose for which it has been collected. At the moment of collecting the data for specific purposes, we will inform the User about the retention period for such data and, when this is not possible, the criteria to determine such period.

We will retain personal data collected to contact you as potential user of our Services or to respond to any request you may have addressed to us a maximum of 1 year from the collection of the data. After that period, the data will be deleted unless there is no contractual obligation between the parties.

We will retain the personal data submitted through registration and collected during the course of your use of the Services until deactivation of your Account either by you or us. Once such personal data is no longer used for the purpose mentioned above, it will be deleted.

Note that we will retain the data collected from you in an anonymised and aggregated format.

We may retain personal data beyond the aforementioned periods for legal or administrative reasons, such as defending our responsibility and complying with mandatory legal obligations, subject to applicable law.

8. Security Measures

We implement security measures and personal data protection schemes as required by law to maintain the confidentiality and integrity of your data and protection against unauthorised access, modification or destruction.

9. Your Rights

You have rights under data protection laws in relation to your personal data. You have the right to:

    - Access to your personal data in order to know which data are being processed, as well as to request the     rectification of inaccurate data or, where appropriate, to request erasure of your personal data when, among other     reasons, the data is no longer necessary for the purposes for which it was collected.

    - In certain circumstances, you may request the limitation of the processing of your data, in which case we will only     retain the data for the purpose of exercising or defending claims.

    - In accordance with current legislation, you may request to restrict the processing of your data when (i) you have     exercised the rights of rectification or opposition and we are in the process of dealing with your request; (ii) the     processing is unlawful, which would result in the data being deleted, but you object to this; (iii) the data is no longer     necessary for processing and should be erased but we need it to exercise or defend claims.

    - You may object to the processing of your data, in which case we will stop processing your data, except for     compelling legitimate reasons or for the defence of possible claims.

    - You also have the right to request the transfer of your data you have provided us to another controller (portability).     In this case, the data will be transferred to another controller or to you in a structured, commonly used and machine-    readable format.

    - If you have given us consent for a specific purpose, you have the right to withdraw this consent at any time.

 The aforementioned rights may be effective by sending a letter or e-mail to Gofra (contact data available in section 1)  and specify which right you intend to exercise. We will respond to your request within 30 days.

In any case, you also have the right to file a complaint to the competent authority: Spanish Data Protection Agency (Agencia Española de Protección de Datos). Address: Calle Jorge Juan, 6, 28001 Madrid (Spain). Phone Nr.: +34 901 100 099 / +34 91 266 35 17. Web site: www.agpd.es" www.agpd.es

10. Changes to this Privacy Policy

We reserve the right to amend, modify or supplement this Privacy Policy at any time. We will notify you by providing a clear notice of these changes by email or on our Services, and a link to the new Privacy Policy. If you continue to use our Services after such update, you will be deemed to accept the new terms. If you do not accept the update, please notify us and we will terminate your Account and remove any of your personal data (except as required to be maintained for legal purposes), and you will not be able to continue to use our Services.

Last updated on 07th March 2022