PRIVACY POLICY

SIMPLIFIED PRIVACY & DATA POLICY FOR MINORS

PRIVACY AND DATA

POLICY
ISSUED BY FIRST TOUCH GAMES
LIMITED

Last Updated: 15 May 2024

1. INTRODUCTION AND
GENERAL TERMS
These terms apply to the use of
games and other products
developed by First Touch Games
Limited (‘FTG’ / ‘we’ / ‘us’). Our
registered o!ce is at 264 Banbury
Road, Oxford, OX2 7DY. We are a
company registered in England,
with company number 07638595.

This privacy and data policy

(“Privacy Policy”) applies and has
e"ect in respect of all games,
related online services (including
online network play connectivity
and interactivity) and other
software and products made
available by us (together the
"Game(s)"), as well as any other
online features relating to the
Games including our website (the
“Website”), our online forums (the
“Forums”) and User Support Centre
(the “Support Centre"). Together
the Game(s), the Website, the
Forums and Support Centre are
referred to as the “Online
Services”.

If you have any questions or

comments about this Privacy Policy,
please contact us at support@ftgam
es.com

We are committed to protecting

and respecting your privacy. The
Privacy Policy explains the basis on
which personal information we
collect from you will be processed
by us or on our behalf. Where we
decide the purpose or means for
which personal data you supply
through these Online Services is
processed, we are the “controller”.
We will comply with all applicable
data protection laws, including the
General Data Protection Regulation
2016/679 and California Consumer
Privacy Act 2018 (“CCPA”).

Please read this Privacy Policy

carefully as it contains important
information about the following:

What information we may

collect about you;
How we will use information
we collect about you;
Whether we will disclose your
details to anyone else; and
Your choices and rights
regarding the personal
information you have provided
to us.

This Privacy Policy forms a part of

and should be read in conjunction
with our terms of use. These are
linked below:

In respect of the Game(s):

In respect of the Support Centr
e:

The Online Services may contain

hyperlinks to services owned and
operated by third parties. These
third party services may have their
own privacy policies and we
recommend that you review them.
They will govern the use of personal
information that you submit or
which is collected by cookies and
other tracking technologies whilst
using these services. We do not
accept any responsibility or liability
for the privacy practices of such
third party services and your use of
these is at your own risk.

We may make changes to this

Privacy Policy in future, which will
be posted on this page. You should
check this page from time to time to
ensure you are aware of any
changes. Where appropriate we
may notify you of changes through
the Games.

2. INFORMATION WE
MAY COLLECT ABOUT
YOU
We collect and process the
following information which may
include your personal data.

a) Information provided by you

when using the Games

(“Basic Information”)

We will collect the following

information from you when you
play our Games:

your mobile device’s unique

device ID (Device ID) and
device name;
your user preferences; and
Core information related to
your gameplay, such as your
overall progression to a
particular level or stage, your
virtual currency stores or the
completion of certain activities
during your gameplay session
(for example, completing a
tutorial, passing a level, making
a purchase or viewing a video
ad) (“Gameplay Statistics”).

b) Contact information
provided by you when using
the Forums or Support
Centre

(“Contact Information”)

We may ask you for, or you

may submit, certain contact
information to us whenever
you contact us through the
Forums or Support Centre.

This may include:

your avatar/profile picture

(Forums only);
your username (Forums only);
your email address;
your name (Forums only), and
your password (Forums only).

c) Information used for the

purposes of serving
advertisements

(“Advertising Data”)

Through our third party advertising

network partners, we may gather
information about your devices
when you install or play our Games,
depending on the permissions
you’ve granted. This may include:

the make, model and

operating system of your
device;
properties of your device, such
as screen size and orientation,
audio volume and battery;
the mobile network operator
linked to your device;
the Games played;
the country, time zone and
locale settings on your device
(i.e. country and preferred
language);
network connection type and
speed;
IP Address;
internet browser used to
access the Games; and
the advertiser ID, which is an
identifier unique to you if you
use an Apple or Android
device, but which doesn’t
reveal your name, if you allow
it to be collected.

d) Information collected for the

purposes of providing analytics

(“Analytics”)

We may collect technical

information about your use of the
Online Services through the use of
tracking technologies and analytics.

Personal data we may collect

includes the following:

your Device ID;

your user ID (which is
generated by us and allocated
to you when you first play our
games);
your device operating system
& version;
your device make and model;
game play attempts,
progression and results;
session game time start, end
and duration;
purchase transaction types
and spend you have made
using virtual items in the
Games;
the coarse location of your
Device when playing our
Games;
the local time zone of your
Device when playing our
Games;
the time, date and install
source of your first download
(e.g. from a clicked
advertisement);
advertisements viewed and
clicked; and
identification of crashes and
defects.

For the small number of users that

continue to play some of our legacy
games which are no longer
available for sale, the management
of the Analytics is provided by
Amazon Pinpoint, part of Amazon
Web Services. If you would like to
find out more about the way
Amazon Web Services collects and
processes this information this is
likely to be set out in their privacy
policies and/or terms and
conditions. Please refer to https://a
ws.amazon.com/legal/

e) Information about you

collected from third parties

(“Third Party Log In Information”)

When you access the Games via a

third party social media provider
such as Facebook, we may collect
and store personal and non-
personal information which is
available on that third party social
media provider, such as your
Facebook name, your profile
picture or its URL, your Facebook ID
and other public data of your
friends, provided that you have
expressly agreed to the use of
Facebook within the Games. We will
also receive technical data in order
to ensure the Games connect to the
correct Facebook account.

f) Content created by our users

which we host and display on the
Forums and in the Support
Centre

(“User Content”)

When users submit their own User

Content to the Forums or Support
Centre, this content may contain
personal and non-personal
information. This could include
information in or about the User
Content, such as the location of a
photo or the date a file was created,
or anything else a user decides to
communicate using these parts of
our Online Services.

3. COOKIES
The collection of this information
may include the use of cookies and
similar technologies (for example,
which are used on the Website). A
cookie is a string of information
that a website stores on a visitor’s
computer, and that the visitor’s
browser provides to the website
each time the visitor returns.
Cookies are widely used in order to
make websites work, to provide
functionality, to make them more
e!cient and to provide website
owners with information about how
the website is being used and who's
using it. We use a limited number of
cookies on our website.

The following cookies are used on

our Website:

Cookie

Twitter cookies(including cookies named: __ncuid

Google / YouTube cookies (including cookies nam

Most web browsers allow you to

control cookies through your
browser settings. To find out more
about cookies generally and how to
manage or delete them, you can
visit here

Find out how to manage cookies on

popular browsers:

Google Chrome (here)

Microsoft Edge (here)
Mozilla Firefox (here)
Microsoft Internet Explorer (here)
Opera (here)
Apple Safari (here)
To find information relating to other
browsers, visit the browser
developer's website.

4. WHY WE COLLECT
INFORMATION ABOUT
YOU
a) To provide our Online Services
to you

We will use information about you

(including Basic Information, Third
Party Log In Information, Analytics
and User Content) for delivering our
Games to you under the terms of
use agreed between us. The
processing of information in this
way is necessary for us to record
your progress and current status
within a Game, and to ensure the
Games deliver the features
promised and function properly, so
that you have the best experience
when playing any one of our
Games.

We will use information about you

(including your Contact Information,
User Content and Third Party Log In
Information) to provide you with
the Forums under the terms of use
agreed between us. The processing
of information in this way is
necessary for us to provide you
with the Forums’ functionality and
to ensure that you have the best
experience when using the Forums.

In relation to certain Games, we will

use your Gameplay Statistics to
enable you to: (i) access certain
statistics and information relating
to your gameplay performance and
the gameplay performance of other
users; and (ii) share statistics and
information relating to your
gameplay performance with other
users (the “Gameplay Statistics
Service”). The processing of
information in this way is necessary
for us to provide you with the
Gameplay Statistics Service in
accordance with the terms of use
agreed between us.

b) To help us improve the Online

Services and fix any problems

We may process information about

you (including Basic Information,
User Content and Analytics) so that
we can analyse and improve our
Online Services.

This processing is also necessary for

us to pursue our legitimate
interests of (i) ensuring that our
Online Services function properly so
that you and other users have the
best experience when playing any
of our Game(s) and using the other
Online Services; (ii) improving the
quality of our Online Services, and
providing a better experience to our
users; (iii) identifying and correcting
any bugs in the Online Services; and
iv) understanding the e"ectiveness
of our marketing to attract new
users and re-engage our current
users at an aggregated level.

c) To respond to your enquiries

and requests for support

We may process Contact

Information and Analytics so that
we are able to properly respond to
your enquiries and support
requests either via the Support
Centre or Forums or through suppo
[email protected]

d) To acquire new users

We use various forms of marketing

to acquire new users, working with
a variety of third party user
acquisition partners to deliver our
marketing campaigns on external
websites and apps. As part of this
we may process your Basic
Information, Analytics and
Advertising Data to pursue our
legitimate interest to o"er you
relevant marketing and acquire new
users for our Games. Your
Advertiser ID and Analytics may be
shared with our 3rd party
marketing analytics partner called
‘Adjust’ and with our 3rd party user
acquisition partners to improve our
marketing e"ectiveness.

Adjust and our user acquisition

partners may collect analytics and
advertising data on our behalf and
in accordance with our instructions,
and its applicable privacy notice.

We work with the following

approved third party User
Acquisition partners:

Facebook (https://www.facebo
ok.com/privacy/explanation)
Google (https://policies.google.
com/technologies/partner-site
s))
Snapchat (https://www.snap.co
m/en-GB/privacy/privacy-policy
/)
Unity (https://unity3d.com/lega
l/privacy-policy)
Applovin (https://www.applovi
n.com/privacy/)
TikTok (https://www.tiktok.com
/legal/privacy-policy)

If you would like to find out more

about the way these third parties
collect and process your
information please refer to their
respective privacy policies and/or
terms and conditions by clicking on
the links provided above.

If you would like to find out more

about the way Adjust collects and
processes this information this is
likely to be set out in their privacy
policies and/or terms and
conditions. Please refer to (https://
www.adjust.com/terms/) and (http
s://www.adjust.com/privacy-policy/).

e) To improve the monetisation

of the Games via in-app
purchases

We may process information

(including Basic Information, User
Content, Advertising Data and
Analytics) to understand how users
use our Games, and to compile
statistical reports regarding that
activity, as well as understanding
how users progress, and their
current status within a Game. This
processing is necessary for us to
pursue our legitimate interests of
improving the Games and
increasing the amount of revenue
generated via in-app purchases.
This may include segmenting and
analysing users according to
various relevant factors, such as
geography, gameplay progression
and playing behaviour so that we
can o"er personalised and
temporary promotional discounts
and o"ers.

We do not segment users who have

confirmed to us as under the age of
16.

f) For advertising purposes

We may process Advertising Data to

show you advertisements for third
party services; including advertising
that may reward you with benefits
during your use of the Games.

The information we collect about

you may be used to understand
how advertisements placed in our
Games have performed or how
many people have viewed certain
advertisements. We aggregate this
information so that it does not
personally identify you or permit
you to be treated individually.

We may also use this information to

reward users with benefits that can
be used for further enjoyment of
the Games from the viewing of
certain advertising placed in our
Games.

We will not pass or process your

information for the purposes of
marketing by third parties unless
you give your consent should we
ask for it. After you have given your
consent, you may withdraw it at any
time.

We may use the information we

collect about you to serve you