of the individual entrepreneur Marat Aidarovich Gilyazov

(PSRNSP 318784700056531)

(hereinafter – the “Developer”)

“21” December 2019

This Privacy Policy (hereinafter – the “Policy”) applies to all information shared in the games of the Developer (hereinafter separately referred to as the “Game” or collectively the “Games”) which the Developer or the third parties specified further in this Policy may get about the user of the Game in the course of its use.

The use of the Game implies the unconditional consent of the User to this Policy and the conditions for processing their personal information specified in it; in case of disagreement with these conditions, the User shall refrain from using the Games.

1. GENERAL PROVISIONS

1.1. Within the framework of this Policy, the personal information of the User means:

1.1.1. Personal information provided by the User when registering (creating an account) or in the process of using the Game, including the personal data of the User. Mandatory information is marked in a special way. Other information is provided by the User at their discretion.

1.1.2. Data that are automatically transferred to the third-party software in the Game in the process of using the Game utilizing the software installed in the Game, including the IP address, cookie data, information about the User’s device and the software installed on it (or another program enabling access to the game), date and time of access to the Game and other similar information. The following are links to the privacy policies of the third-party software installed in the Game, including, among others, the Users’ rights regarding the personal data collected about them and the composition of such personal data:

A) Facebook Analytics, Facebook Audience Network - https://www.facebook.com/policy.php

B) Gameanalytics - https://gameanalytics.com/privacy

C) Google AdMob - https://policies.google.com/privacy

D) Applovin - https://www.applovin.com/privacy/

E) Unity Ads - https://unity3d.com/legal/privacy-policy

F) Vungle - https://vungle.com/privacy/

G) Enhance - https://enhance.co/about/privacy-policy

The User has the right to contact such third parties directly with a request to clarify, forget, delete their personal data, as well as to exercise other rights granted to the User by law.

1.2. This Privacy Policy applies only to the Games of the Developer. The Developer does not control and is not responsible for third-party sites which the User can access through the links available in the Game, including by being directed to such sites from advertisements displayed in the Game.

1.3. Currently, the Developer does not collect or store Users’ personal data. The following sections, so far as they are applicable to the collected personal data, will relate to the rights and obligations of the User and the Developer from the moment the Developer begins to process the personal data of the User.

2. PURPOSES OF PROCESSING USERS’ PERSONAL INFORMATION

2.1. The Developer collects and stores only the personal information that is necessary for the provision and use of the Games or the execution of agreements and contracts with the User, except for cases when the law provides for the mandatory storage of personal information for a period specified by law.

2.2. The Developer processes the User’s personal information for the following purposes:

2.2.1. Identification of the User registered in the Game for the purpose of providing the functions and services of the Game.

2.2.2. Granting the User access to the activated and non-activated functions of the Game.

2.2.3. Establishing feedback with the User, including sending notifications, requests regarding the use of the Game, the processing of requests and queries from the User.

2.2.4. Determining the location of the User in order to ensure security, fraud prevention.

2.2.5. Confirming the accuracy and completeness of personal data provided by the User.

2.2.6. Creating an account to provide the User with access to the activated and non-activated functions of the Game if the User has agreed to create an account.

2.2.7. Notifying the User of the Game about in-game events, game updates, news about the development of other Developer’s Games.

2.2.8. Providing the User with effective customer and technical support in case of problems associated with the use of the Game.

2.2.9. Implementation of promotional activities with the consent of the User.

3. TERMS OF PROCESSING OF THE USER’S PERSONAL INFORMATION

AND ITS TRANSFER TO THIRD PARTIES

3.1. The Developer stores the Users’ personal information following the internal regulations that comply with the laws of the Russian Federation.

3.2. The confidentiality of the User’s personal information is maintained except for cases when the User voluntarily provides information about themselves for general access to an unlimited number of people. When using certain services, the User agrees that a certain part of their personal information becomes publicly available.

3.3. The developer has the right to transfer the personal information of the User to third parties in the following cases:

3.3.1. The User has agreed to such actions.

3.3.2. The transfer is necessary for the use of the Game by the User or execution of a specific agreement or contract with the User.

3.3.4. The transfer is provided for by Russian or other applicable legislation under the procedure established by the law.

3.3.5. In the case, if the rights to the Game are to be sold, all obligations to comply with the terms of this Policy regarding the personal information received by them shall be transferred to the purchaser.

3.4. Processing of User’s personal data is carried out within the period necessary for processing by any legal means, including in personal data information systems using automation tools or without using such tools. Processing of User’s personal data is carried out under Federal Law No. 152-FZ “On Personal Data” dated 07/27/2006.

3.5. In the event of loss or disclosure of personal data, the Developer shall inform the User about the loss or disclosure of personal data.

3.6. The Developer shall take the necessary organizational and technical measures to protect the personal information of the User from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, as well as from other illegal actions of third parties.

3.7. The Developer along with the User shall take all the necessary measures to prevent losses or other negative consequences caused by the loss or disclosure of the personal data of the User.

4. OBLIGATIONS OF THE PARTIES

4.1. The User shall:

4.1.1. Provide information about the personal data required to use the Game.

4.1.2. Update, supplement the provided information regarding personal data in case of a change of that information.

4.2. The Developer shall:

4.2.1. Use the information received solely for the purposes specified in this Privacy Policy.

4.2.2. Ensure the storage of confidential information in secret, not disclose it without the prior written permission of the User, as well as not sell, exchange, publish or disclose the transferred personal data of the User in any other possible way except as provided for in this Privacy Policy.

4.2.3. Take precautions in order to protect the User’s personal data confidentiality following the procedure normally used to protect this type of information in existing business transactions.

4.2.4. Block personal data related to the relevant User from the moment of contacting or requesting the User or their legal representative or authorized body for the protection of the rights of personal data subjects for the period of verification in case of revealing inaccurate personal data or illegal actions.

5. RESPONSIBILITY OF THE PARTIES

5.1. The Developer is responsible for the unlawful use of personal data in accordance with the legislation of the Russian Federation.

5.2. In the event of loss or disclosure of confidential information, the Developer shall not be liable if this confidential information:

5.2.1. Became public prior to its loss or disclosure.

5.2.2. Was received from a third party prior to it being received by the Developer.

5.2.3. Was disclosed with the consent of the User.

6. DISPUTE RESOLUTION

6.1. Prior to filing a dispute lawsuit arising due to the relationship between the User and the Developer, it is mandatory to submit a claim (a written proposal for the voluntary settlement of the dispute).

6.2. The recipient of the claim shall notify the claimant in writing of the results of the claim consideration within 20 calendar days from the date of receipt of the claim.

6.3. If an agreement is not reached, the dispute will be referred to the court in accordance with the current legislation of the Russian Federation.

6.4. The current legislation of the Russian Federation governs this Privacy Policy and the relationship between the User and the Developer.

7. ADDITIONAL TERMS

7.1. The Developer has the right to make changes to this Privacy Policy without the consent of the User.

7.2. The new Privacy Policy comes into force from the moment it is posted, unless otherwise provided for by the new version of the Privacy Policy.

7.3. All suggestions or questions regarding this Privacy Policy should be directed to the Developer at the e-mail address: support@anvil-games.com.

7.4. The current Privacy Policy is available at: www.anvil-games.com.

7.5. This Privacy Policy is an integral part of the agreement to use the Game posted at: www.anvil-games.com.