1. Introduction

This Privacy Policy describes the measures that we take to preserve and safeguard your privacy when you visit our website located at "Website" or make use of our games, Website, online shop, forums, social media channels, customer and technical support and any other services we provide to you ("Services"). It also demonstrates how we may process data in accordance with the EU General Data Protection Regulation ("GDPR"). Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it.

For the purpose of the GDPR, the data controller is Unfrozen Ltd., registered office: 118 Agias Fylaxeos, Christabel House, 3087 Limassol, Cyprus, registration number HE421434 ("Unfrozen", "we" or "us") is committed to protecting the privacy of all individuals in respect of whom we hold personal data. If you do not agree with our policies and practices, your only recourse is not to use our Website or Services.

"Personal data" is information that identifies you or that can be used to contact you (online or offline). Personal data can include but not limited to your name, email address, physical address, Internet Protocol (IP) address, telephone number, birthdate, etc.

All capitalised terms used but not defined herein shall have the meaning given to them in the Terms of Use.

2. General Information

This Privacy Policy governs personal data and non-personal data, which we collect from you when you're using our Website and Services. We maintain reasonable and appropriate security safeguards designed to protect your information from loss, theft, misuse and unauthorised access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the information.

3. How We Use Your Data

We rely on the following grounds to legally collect and use your personal data:

• The data are necessary to provide our Services to you;
• We are using your personal information where it is in our legitimate interests to do so;
• We have a legal obligation to process your personal information;
• You have consented to the use of your personal information by us.

We will use your personal information for the following purposes:

• to provide the Services to You;
• to improve the quality of our Website and Services and to offer new features to you;
• to understand, improve, and research products, features, and services;
• to comply with the legal requirements set by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

Also, when we have your consent, we may process your personal data:

• to provide you with marketing information (including personalised and targeted marketing emails) regarding goods and services you request from us or which we feel may interest you;
• to target and personalise our marketing communications, offers and advertisements that we display on our Website and websites of third parties.

4. Personal Data We Collect

We may collect the following data:

• a. When setting up an Account, you may be asked to provide personal data including, but not limited to, your username, password and email address. You may also use your credentials from other services such as Google, Facebook, Twitter, Apple iCloud to create an account faster with us.
• b. When you provide feedback about our Services. These data include information that you post, comment, share content or like in any of our forums, social networks, and on the Website.
• c. We collect personal data whenever you contact us and provide us with information that we are able to identify you by. This includes information such as your name, email address, and phone number.
• d. In order to make a purchase on our Website, as well as for access to the personalised services, if applicable, we collect your data, which is necessary to fulfil obligations on the part of the Unfrozen.
• e. In order to fix crashes and other technical issues that may arise while you are using our Services, we collect, store and use information about the device you are using the Services on.
• f. When you access our services using your credentials from a social network or external platform we may process your social network IDs and details about your use of social networking services.
• g. When you participate in a game contest or survey organised by Unfrozen.
• h. In order to get in touch with you about features and offers relating to the Service that we think you would be interested in.

5. Non-Personal Information

We indirectly collect a variety of information through your interaction with and use of our Website and Services. This information may include, but is not limited to, anonymized browser and device information (both software and hardware), data collected through automated electronic interactions, application usage data, demographic information, geographic, geo-location information, statistical and aggregated information.

6. Processing Data as Data Processor

In some cases, we receive your personal data as a data processor, which means that the data are controlled by our partners and we use them only in accordance with their instructions and applicable laws. We use this data in order to fulfil our obligation to you, improve the Services, and when processing is required in order to comply with a legal obligation to which we are subject.

7. No Processing of Special Categories of Data

We do not collect or process any special categories of personal data. We do not undertake automated decision making or profiling on the data which are provided to us.

8. Cookies

We use cookies and similar technologies like web beacons, pixel tags, or local shared objects ("flash cookies"), to deliver, measure, and improve our Services in various ways. A cookie is a small text file that identifies your computer on our server. Cookies in themselves do not identify the individual user, only the computer being used.

Preferences and Features. Cookies or similar technologies can tell us which language you prefer and what your communications preferences are.

Marketing. We may use cookies or similar technologies to help us deliver marketing campaigns and track their performance.

Performance, Analytics and Research. Cookies or similar technologies help us learn how well our Websites and Services perform.

Third Party Analytics Providers. We may use third-party analytics providers software to allow us to better understand the functionality of our Website including but not limited to Google Analytics.

9. How We Share Your Information

For the performance of a contract with you, compliance with a legal obligation to which we are subject, and based on our legitimate interests, we may share your personal data with the following categories of third parties:

• Our Affiliates. Our affiliates may access your personal data to help us develop, maintain and provide our Services.
• Service Providers. Our service providers provide us support for our Services, including Website and application development, hosting, maintenance, backup, storage, payment processing, analysis and other services.
• Advertising and Advertising Measurement Partners. We may share your email, nickname, IP address and other information you provide to us in order to facilitate targeting, delivery, and measurement of online advertising.
• Professional Advisers. Our lawyers, accountants, bankers, auditors and insurers may need to review your personal data.
• Legal Authorities. We may disclose your personal data if we believe it is reasonably necessary to comply with a law, regulation, or order.
• Business Partners. We may share certain information such as your location, browser and cookie data and other data relating to your use of our Services with our business partners.
• Researchers. We may provide personal data to third parties under confidentiality obligations for research purposes.

10. Data Transfer

Our Service is global by nature and your data can therefore be transferred to anywhere in the world. We transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Services. Whenever we transfer your information, we take steps to protect it.

11. Your Rights

Depending on where you reside you may have rights to:

• Access your personal information — upon your request, we will provide you with a copy of your personal data in a structured, electronic format;
• Rectify — you can edit some of your personal data through your account, or ask us to change, update or fix your data;
• Erase — in certain territories you can ask us to erase or delete all or some of your personal data;
• Data portability — if you ask us to do so, we will pass on your personal information in a structured, usable format;
• Object to your personal information being used.

You can exercise these rights directly with us by submitting a request at info@unfrozen.studio.

If you believe that we have not processed your personal data in accordance with the applicable legislation, you may submit a complaint to the data protection authority through the website http://www.dataprotection.gov.cy/.

12. Opt-Out of Direct Marketing

We may also process information that constitutes your personal data for direct marketing purposes, provided that you have a right to object to our use of your personal data for this purpose. You can withdraw your consent at any time by following the 'unsubscribe' link that is provided in emails from us or contacting us by emailing to info@unfrozen.studio.

13. Response Time

We are obliged to respond to your requests without undue delay. In most instances, we will respond within one calendar month. If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests), we may extend this period by a further two calendar months.

14. Data Retention

We keep most of your personal data collected and processed for the purposes described in this Privacy Policy for as long as you continue to use our Services. After the retention period, your personal information will either be securely deleted or anonymized.

We will delete your personal data after you request to delete your Account and the grace period of 90 (ninety) calendar days expires. The process of erasing your personal data can take up to one month from expiry of the grace period.

15. Age Restriction

You may use the Services only if you are over the age of eighteen (18). We recognize the privacy interests of children and encourage parents and guardians to take an active role in their children's online activities and interests. If we learn that we've collected personal data from a child under the applicable age of consent, we will take reasonable steps to delete it. Parents who believe that we may have collected personal data from a child can submit a request at info@unfrozen.studio.

16. Amendments

We may change this Privacy Policy from time to time as laws, regulations and/or our business evolves. We will post the changes to this page and encourage you to review our Privacy Policy periodically to stay informed. If you have any questions about us, our Website, our Services or this Privacy Policy, please contact us by emailing to info@unfrozen.studio.