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PLEASE NOTE THAT THIS PRIVACY POLICY APPLIES ONLY TO THOSE USERS OF THE SERVICES WHO ARE AGE 13 AND OLDER. SPECIAL PROCEDURES ARE USED WHEN COLLECTING INFORMATION FROM USERS UNDER THE AGE OF 13, WHICH ARE DISCUSSED IN THE “POLICIES REGARDING CHILDREN UNDER THE AGE OF 13” SECTION BELOW.

Privacy Policy Rare Gem Ventures Ltd designs, develops, and publishes various digital products. Rare Gem Ventures Ltd, its subsidiaries, parent companies, affiliates, joint ventures, and other corporate entities under common ownership (collectively, “we,” “our,” or “us”) take our users’ (“users” or “you”) privacy rights seriously. This Privacy Policy explains how we collect, use, store, disclose, and manage the personal information (“Personal Information”) you provide to us when using, or about to use, any of our applications, games, or software (collectively, the “Services”).

Whenever you access or use our website and domain name, and any of the Services, you agree to allow us to collect, use, store, disclose, and manage your Personal Information as explained in this Privacy Policy and accept this Privacy Policy in registration or game installation. We have the right to amend this Privacy Policy from time to time. Use of your information we collect now is subject to the Privacy Policy in effect at the time such info rmation is used. Whenever you use our sites or the Services, please check this Privacy Policy to make sure that you are aware of any amendments in our privacy practices. The date our Privacy Policy was last updated will be displayed therein. We will post a revised policy on our sites and/or mobile products to inform you and other users if we make any material revisions to this Privacy Policy. You understand that you accept the amendments to our Privacy Policy by continuously using our sites or the Services.

This Privacy Policy does not apply to information collected and stored by (1) web-based applications that are built from our mobile applications but published by other third parties, (2) or through websites and services provided by other third-party companies or entities to which our Services may link, or (3) mobile applications that we distribute on behalf of other third parties which mobile applications are hosted by such third parties, except otherwise as mentioned herein. IF YOU CHOOSE NOT TO ACCEPT THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT USE ANY OF OUR SITES, MOBILE PRODUCTS, OR SERVICES.

Personal Information and Non-Personal Information We collect both Personal Information and Non-Personal Information. “Personal Information” is information about you that can be used to identify or contact you online or offline, such as your name, birth date, home address, email address, credit card information, and phone number. “Personal information” may include your unique device or user identifier when the identifier is combined with your personal information. “Non-Personal Information” is information that, by itself, cannot be used to identify or contact you personally and can include gender, age, or interests and cannot be used to connect with you. This Privacy Policy does not restrict or limit our collection of aggregate information or Non-Personal Information. Personal information also does not include “aggregate information.” Aggregate information is data we collect about the characteristics and activities of the users and visitors of the Services and enhance our Services and our sites, from which any Personal Information has been removed. Such information may include demographic information, such as your unique user or user identifier (when not matched with or tied to your Personal Information), city of residence, information about your computer, software, platform, and Internet IP address. We collect aggregate information about the use of the Services to provide the best possible service and allow us to make certain recommendations and internal reports and share such information with our partners about how our customers use the Services so that our partners also understand how people use the Services and they can provide you with an optimal user experience.

We may combine Personal Information and Non-Personal Information to be used to improve your experience with or to aggregate it with information collected from other users to improve or analyze the Services.

How Personal Information Is Collected To assist us in personalizing and improving the Services, and allow our users to set up a user account and profile that can be used to personalize their experience in using the Services, Personal Information is collected from you. We may collect your Personal Information in a number of ways such as, during your (1) registration or log-in for games, games subscriptions or our websites, (2) creation of a personal profile, (3) customer support or technical service requests, (4) purchase of a license to use in-game virtual money or virtual items directly from us, any relevant billing and financial information necessary to process your charges will be collected by us, which may include your email address, (5) download and use of our mobile applications and web-based applications, (6) request for services from third party service providers on our websites or the Services (such as, your response to advertisements therein), (7) communications with other registered users on our websites or through the Services, and (8) participations in promotional or marketing activities, surveys, and other alerts. Depending on the activity in which you are involved, information that we collect from you will vary.

What about Cookies? – We collect certain technical information when you use the Services in order to (i) manage advertising; (ii) analyze the usage of our sites and services; and (iii) provide a more personalized experience. We and our service providers use tracking technologies to collect and analyze certain types of technical information, including cookies (cookies are small files applied to your browser to track movements within websites), platform type, IP addresses, device and identifiers, domain names, landing pages, the number of clicks, the amount of time spent on particular pages, pages viewed and the order of those pages, URLs, browser types and language, referring and exit pages, game state and the date and time of activity on our sites or games, and other similar information. For our internal use, we may also associate this information with your user ID number. However, please note that we do not combine the general information collected through cookies with your other Personal Information to inform us your identity or what your email address or screen name is.

Third-party advertising companies may be used by us to serve advertisements on our sites. This Privacy Policy covers only the use of our cookies and the respective privacy policies of other third party advertising companies govern the use of cookies by such advertisers. Our advertising partners, who may set cookies, may deliver advertisements appearing in the Services to users, and may also use other third-party advertising technology to target advertising in the Services. When we serve advertisements to you, a unique third-party cookie or cookies may be placed on your computer. These cookies are used by the advertisements server to identify your computer or other device each time an advertisement is served to you in order to gather information about you or others users who use your computer or device. Based on such information, advertisement networks will deliver targeted advertisements that will be of interest to you.

Other technologies may also be used by us, which include: (i) flash cookies (which help us in preventing fraud, remembering your in-game preferences and speeding up load times); (ii) tracking pixels (which permit us to advertise more efficiently by (a) not serving certain promotional messages to our current users, (b) identifying the source of a new installation or (c) delivering advertisements to you on other websites); and (iii) device identifiers (which allow us to track your computer or device when you play games). In addition, we may use mobile analytic software to allow us to understand the functionality of our mobile software on your device. Our third-party service providers may also use mobile analytic tools to collect information from you. Moreover, our advertisers and third-party marketing partners may also collect information about your use of other websites and services, and may combine such information with other information about you in order to provide you with advertising targeted to meet your interests and preferences and to understand better the usage of our sites and services. We may also use Facebook Pixel to measure the effectiveness of our Facebook advertising.

Device Permissions – We may require your permission to access certain services on your mobile device (such as location services, camera, and microphone). If you deny access, you may be unable to access certain features or the Services altogether, and we may not be able to provide you with the corresponding services.


How We Use Your Personal Information – By accessing our websites or using the Services, you expressly allow us to use your information, including your personal information. We use your personal information to do things like (1) create your account, (2) provide, personalize, and improve your experience with the Services, (3) carry out your requested transactions, (4) provide technical support, (5) tailor advertisements to your interests, and (6) communicate with you about our new products, services, promotions, (7) send important notices, such as communications about purchases, and changes to our terms, conditions, and policies. In addition, we may use your personal information for the following purposes:

• to respond to your inquiries and fulfill your requests;
• to send you important information regarding our relationship with you or regarding the Services, changes to our terms, conditions, and policies and/or other administrative information;
• to send you surveys and marketing communications that we believe may be of interest to you;
• to personalize your experience on the Services by presenting content, products, and offers tailored to you;
• to allow you to participate in sweepstakes, contests, and similar promotions and to administer these activities. Some of these activities have additional rules, which could contain additional information about how we use and disclose your personal information. We suggest that you read any such rules carefully;
• to allow you to send messages to a friend through the Services. By using this functionality, you are telling us that you are entitled to use and provide us with your friend’s name and email address. We will not store this information except for the sole purpose of sending this one-time email and tracking the success of our referral program. Please ensure that you only send emails to friends who have given you permission to do so;
• for our business purposes, such as quality assessment, data analysis, audits, developing new products, enhancing the Services, improving our Services, identifying usage trends, determining the effectiveness of our promotional campaigns, and operating and expanding our business activities; and
• as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations; (f) to protect our rights, privacy, safety, or property, and/or that of you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

How We Share Your Personal Information – Except as described in this Privacy Policy, we will not disclose your personal information that we collect to third parties without your consent. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:

• Service Providers: We may share your information with third parties who perform services on our behalf, such as payment processing, data analysis, email delivery, hosting services, customer service, and marketing assistance.
• Business Transfers: We may share your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Protection of Rights: We may disclose information if we believe that it is necessary to comply with a court order, governmental request, or other legal process, to protect our rights or the rights of others, to enforce our terms of use, or to respond to claims of violation of the rights of third parties.
• With Your Consent: We may share your information in other circumstances with your consent.

Policies Regarding Children Under the Age of 13 - We do not knowingly collect or solicit personal information from anyone under the age of 13. If you are under 13, please do not send any personal information about yourself to us. In the event that we learn that we have collected personal information from a child under age 13 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at [contact email address].

Security - We use reasonable security measures to protect the security of your personal information that we collect and store. However, no security system is impenetrable, and we cannot guarantee the security of our servers or databases, nor can we guarantee that the information that you supply will not be intercepted during transmission to us over the Internet.


Your Choices Regarding Your Personal Information - You have several choices regarding the use of information on our Services:

• Email Communications: If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt-out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or services you have requested.
• Mobile Device Settings: You can manage the sharing of certain personal information when you register with us through your device settings.
• Cookies: Most browsers allow you to turn off cookies. To do this, look at the "help" menu on your browser. Switching off cookies may restrict your use of the Services.
• Google Analytics: We use Google Analytics to help analyze how users use our sites. Google Analytics uses cookies to collect standard Internet log information and visitor behavior information in an anonymous form. The information generated by the cookie about your use of our sites (including IP address) is transmitted to Google. This information is then used to evaluate visitors’ use of our sites and to compile statistical reports on site activity for us. We will never (and will not allow any third party to) use the statistical analytics tool to track or to collect any Personally Identifiable Information of visitors to our sites. Google will not associate your IP address with any other data held by Google. For more information about Google Analytics, or to opt-out of Google Analytics, please go to: https://tools.google.com/dlpage/gaoptout.

Changes to Privacy Policy – This Privacy Policy is subject to occasional changes at our discretion. If we make changes to this Privacy Policy, we will post those changes on this page. Please check this page periodically for changes. Your continued use of the Services following the posting of changes to this Privacy Policy will be considered your consent to those changes.

Contact Information – If you have any questions or concerns about our Privacy Policy, you may contact us by emailing us at support@raregem.ventures.