Last Updated: ___________________.

365Games understands that your privacy is important to you and that you care about how your personal data is collected and used. We respect and value the privacy of all of our users who access and use our website, https://________________ (“Site”), and services provided through the Site (collectively the “Service”), and will only collect and use personal data in ways that are described in this Privacy Policy, and in a way that is consistent with our obligations and your rights under the applicable laws.

PLEASE READ THIS PRIVACY POLICY CAREFULLY AS IT BECOMES LEGALLY BINDING ON YOU WHEN YOU USE OUR SERVICE. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY YOU SHOULD IMMEDIATELY STOP USING OUR SERVICE. FURTHER, PLEASE REVISIT US REGULARLY TO KEEP TRACK OF ANY PRIVACY POLICY UPDATES.

Information About Us

365Games is owned and operated by UNIVERSAL GAMES TECHNOLOGIES, a limited liability company (LLC) registered and existing under the laws of the United Arab Emirates, with its registered address located at G2 Office, Al Nud, Sharjah, UAE. For the purposes of the applicable laws, 365Games is the data controller of your personal information.

What Does This Notice Cover?

This Privacy Policy explains how we collect your personal information, why we collect your personal information, how we keep it and who we share it with. It also explains what rights you have under the applicable laws relating to your personal data.

1. Personal Data We Collect

We collect personal data from you when you access and use our Service. Personal data is any data that can directly or indirectly identify a person such as a name, email address, or date of birth.

We collect the following personal information from you:

(a) Information directly provided by you

1. Registration. When you register for an account we collect the following personal information from you:

• Name
• Email
• Country
• Birthday
• In-Game Username

2. Account Information. If you make any changes to your account, you may be sharing personal information of yours with us. This may include:

• Photo (when you upload your own user avatar that identifies you)
• User Bio (your user bio written by you may contain your personal information)

3. Newsletter. When you subscribe to our newsletter we collect your email address. This is used to send you our newsletter on a regular basis to help you stay updated about our products and services.

4. Financial Information. When you purchase an In-Game Item (as defined in our Terms and Conditions), or when you withdraw your funds we ask you to provide your financial information which may include:

• Your Bank Card Information
• Other Financial Information (associated with other third-party payment processors)

5. Support Requests. You can create a support ticket in order to alert any error or failure in the Service, request assistance, or submit any other requests. We may collect personal information that you voluntarily share with us.

6. Social Media Interaction. When you contact us through our social media pages (including following us, or mentioning us in your posts) we see your personal information such as your name, user ID, profile photo, job title and any other information you choose to share with us in your communication with us. This information is stored with the appropriate social media platform and is subject to their applicable privacy policy and terms and conditions.

7. In-Game Data. We collect and process your information relating to your game performance. This may include:

• Games you play
• Achievements and awards
• Prizes
• Teams you have joined

8. Verification. In the event you won an award or a prize on our Service, we will use our verification system before we are able to transfer your money to you. As part of our verification procedure you may be requested to verify your identity by submitting the required documents.

(b) Information we collect automatically

When you use our Service we automatically collect the following from you (except for Cookies we first ask you for your consent). None of this information is capable of identifying you alone. However, when combined with other information, it may identify you. Please be aware that we do not knowingly attempt to identify you by combining information about you.

1. Automated Information. To make our Service more useful to you, our servers (hosted by a third party service provider) collect certain information from you. This includes, without limitation, your browser type, operating system, IP address and date/time stamp for your visit.

2. Log Data. When you visit our Site, view content provided by us, use our Service we automatically collect and store certain information in log files. This includes your IP address, URL, referral URL, exit URL, browser software, operating system, date/time, requests type to our Site and error responses returned by our Site.

3. Cookies. We use cookies and other similar tracking technologies (collectively “cookies”). These cookies are used by us for limited purposes with your consent (except for those that are strictly necessary for the functioning of our Service).

Purposes of Data Processing

When we collect any personal information, we will do our best to store and process it securely. We will comply with our obligations and safeguard your rights under the applicable laws at all times. We process your data for the following purposes.

1. Provision of our Service. To allow you access and use our Service - create user accounts, process transactions, send information about updates, notices, etc.

2. Diagnosis & Troubleshooting. To diagnose problems with our servers, to administer our Service.

3. Security. To prevent, detect and investigate illegal activities, breaches of any agreements entered into between you and us and threats to the security of the Service.

4. Enhance User Experience. To enhance our services and give you a better user experience when you access our Site and use our Service.

5. Statistics. To produce aggregate statistical information about users and their activities on our Site that does not identify any person.

6. Legal & Compliance. To investigate any claims or disputes concerning the use of our Service.

7. Research & Development. To improve and enhance the safety and security of our Service, as well as to design and develop new features and products relating to the Service.

Legal Bases of Data Processing

Under the applicable laws we are required to have valid legal bases in order to lawfully collect and process any personal information. The following are the legal bases that we rely on when we collect, use and process your personal information:

(a) Consent

In order to collect and use certain information about you, we rely on your consent. This is where you have actively agreed to our collection and use of your personal information. For example, when you accept our use of cookies to collect and process certain information about your experience with us.

(b) Performance of a Contract

As a user of our Service you agree to our Terms and Conditions in order to access and use the Service. We will process your personal information on the legal basis that it is necessary for us to provide you with our Service.

(c) Legal Compliance

We may have to process and share your personal data in order to comply with our legal obligations, or to protect our rights or the rights of others. For example, we may be required to comply with a subpoena, court order, or a similar legal procedure.

(d) Legitimate interests

In some situations we rely on our legitimate business interests in order to collect and process your personal data. Before using your data for our legitimate interests, we always carry out a balancing test to carefully consider the impact of the processing on your interests, rights and freedoms. We only process your personal data if we are satisfied there is no negative impact on you. Particularly, we rely on legitimate interests for the following activities:

• providing, maintaining, improving and developing our Service;
• analyzing the use of our Service;
• using aggregated (non-personally identifiable) statistical and analysis data to identify usage trends;
• dealing with user queries and complaints;
• personalizing your experience on our Site;
• identifying fraudulent behavior and ensuring our Site and systems are safe and secure.

Sharing of Your Personal Information

When we provide our Service we share personal information with other parties. When we share your personal information, we do our best to ensure that your personal data is stored and handled as securely as it is with us. We may share your personal information with the following categories of recipients:

Service Providers. We use third party service providers to provide our services to you which have access to your data. We ensure that these service providers do not make use of your personal data for any secondary purposes other than our express written instructions. The following are the categories of such service providers:

• Hosting Service Providers - to host our Site, database and media files.
• Email Management Provider - to send marketing emails
• Web Analytics Service Provider - to obtain statistical information about the Service usage
• SMS Management Provider - to send SMS
• Games APIs - to calculate the points for the players
• Social Media Tool - to monitor our account

Business Transfers. If we sell, transfer, or merge parts of our business or assets, your data may be transferred to a third party. Any new owner of our business may continue to use your data in the same way that we have used it, as specified in this Privacy Policy (i.e. to communicate with you).

Law Enforcement. In some limited circumstances, we may be legally required to share certain data, which may rarely include your personal data, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

Staff. We may share some personal information about you, we may share some personal information about you with our employees, or independant contracts. We ensure that they handle your personal data according to this Privacy Policy, applicable laws and our internal policies.

In-Game Sharing. Some information about you is publicly visible to other users of our Service. This information may also include your ranking, achievements, awards and prizes you won on the Service.

Your Rights

You have got the following rights in relation to our collection, use and processing of your personal information.

• The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more.
• The right to access the personal data we hold about you.
• The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete.
• The right to deletion, i.e. the right to ask us to delete or otherwise dispose of any of your personal data that we hold.
• The right to restrict (i.e. prevent) the processing of your personal data.
• The right to object to us using your personal data for a particular purpose or purposes.
• The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
• The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
• Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about how we use your personal data or how to exercise your rights, please contact us by writing an email to _____________.

Where is Your Data Stored?

We use service providers (e.g. email management, website and database hosting and web analytics) located in different countries and regions (including the USA and EU) to carry out certain operations during the normal course of business. Consequently, your personal information may be transferred to another country where it would be subject to the laws of that country. In order to ensure the security of your personal data we sign binding data processing agreements with these service providers and require them to have certain technical and organizational measures in place to ensure the confidentiality and security of your personal information. These agreements also ensure that your personal information is not used for purposes other than those for which it was collected.

Data Retention Period

We will keep your personal information only as long as is reasonably necessary for the purposes described in this Privacy Policy, or for a longer period as may be required by applicable laws. You can always request that we suspend or remove your personal data by writing to _________.

Security Measures

We use Secure Sockets Layer (SSL) to encrypt the information you enter on the Service in order to protect its security during transmission to and from the Service. When storing personal information, we protect its security by encryption and pseudonymization of data. We also apply a two factor authentication (2FA) for account creation verification, and for other critical activities you carry out with our Service.

We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal information. We also apply access restrictions to your personal data by our employees. Furthermore, we ensure to educate and train our employees about the importance of privacy and data protection on a continuous basis.

Despite the fact that we take all these measures to maintain the safety and security of your personal information, you should be aware that no transmission over the Internet can ever be guaranteed to be secure. Therefore, we cannot fully guarantee the security of any personal information that you transfer over the Internet to us.

Cookies & Tracking

(a) What are Cookies?

We use cookies and other tracking technologies (collectively “Cookies”) on our Site. Cookies are small textual files that may be stored on your device (i.e. computer, mobile phone or other device) when you visit a website. They are generally used to facilitate browsing on the website, keep track of actions within the website, measure how well the website is doing, remember your preferences and login details, etc.

(b) Why do we use Cookies?

These technologies allow us to deliver our Service to you and enhance your experience with us. We do not place any cookies on your device before obtaining your consent (except for the strictly necessary cookies which allow our Site/Service to function).

The category of cookies are presented to you when we ask your consent to install cookies on your device. You can always change your cookie preferences.

(c) How to delete cookies?

It is you who decides whether we can set cookies on your device. You are also able to configure your browser to accept or reject cookies by default through your browser setting. You can refer to official information provided by your browser software provider on how you can deactivate and delete cookies.

In the event that you set your browser to reject all cookies or delete our cookies, that may lead to the unavailability to access to some or all of the Service provided by us and that your experience when you use our Service may be less satisfactory.

Notice to EU/UK Residents

The General Data Protection Regulation of the EU and the UK (collectively the “GDPR”) gives the residents of the EU/UK certain rights when their personal data is being collected and processed. At 365Games, we are committed to comply with the GDPR.

This Privacy Policy, in its entirety, conforms with the information disclosure obligations set out under the GDPR. Therefore, EU/UK residents should read the entire Privacy Policy to find out how we handle their personal information.

(a) Data Subjects Rights

As a EU/UK resident you have the rights accorded to you under the Chapter 3 of the GDPR, and we always work to uphold these rights. These rights correspond to your rights accorded to you under the relevant section of this Privacy Policy. In order to obtain more information about your rights and how to exercise your rights, please contact us at _______________.

(b) International Transfer of Data

If you are a resident of the EU/UK, you should be aware that when you access our Site and use our Service your personal information will be transferred to countries located outside the EU/UK.

Notice to California residents

Residents of California have additional rights accorded to them under the California Consumer Privacy Act (CCPA).

(a) Your CCPA Rights

If you are a California resident, you may request that we disclose to you the following information covering the 12 months preceding your request:

• The categories of personal information that we have collected about you and the categories of sources from which we collected such personal information
• The business or commercial purposes for collecting such personal information
• The categories of personal information about you that we have disclosed to third parties for a business purpose and the categories of third parties to whom we have disclosed such personal information

You, as a resident of California may contact us by writing to _________________ to obtain copies of any personal information that may have been collected or stored about you, and request its correction or deletion as may be required and permitted by law. That said, you should also be aware that there may exist legal or other reasons that 365Games may have to decline to honor your request. For example, in cases if we cannot verify your identity or confirm that the personal information that we maintain relates to you, or if we cannot verify that you have the authority to make a request on behalf of another individual.

As a California resident, you have the right to empower an authorized agent to submit requests on your behalf. We will need your authorized agent to confirm his/her authority by a written authorization.

(b) Sale of Personal Information

We do not and will never sell or trade any personal information collected from you for monetary value. Therefore, you do not need to opt out in order to prevent the sale or trading of personal data.

(c) “Do Not Track” Requests & Behavioral Tracking

Please be advised that currently we do not respond to “Do Not Track” requests. You should be aware that we allow third party behavioral tracking on our Site.

Notice to Canada Residents

(a) Fair Information Principles

According to the Personal Information Protection and Electronic Documents Act of Canada (“PIPEDA”) all organizations collecting, using and processing personal information of Canadian residents must adhere to 10 fair information principles set out under the PIPEDA. These principles are:

• Accountability
• Identifying purposes
• Consent
• Limiting Collection
• Limiting Use, Disclosure, and Retention
• Accuracy
• Safeguards
• Openness
• Individual Access
• Challenging Compliance

This Privacy Policy sets out all the information about how we fulfill the requirements of these principles. We recommend you to read this Privacy Policy in its entirety to find out answers to your questions.

(b) Appointment of a Responsible Person

The principle of accountability under PIPEDA obliges organizations to appoint an individual whose duty is to ensure compliance with PIPEDA. At 365Games, we have appointed such a person who you can reach out to by writing an email to ___________.

Changes to Privacy Policy

This Privacy Policy may be amended by us from time to time. This may be done out of necessity (e.g., in order to reflect changes in the applicable laws), or if we change our business in a way that affects personal data protection.

Any changes will immediately be posted on our Site and you will be deemed to have accepted the terms of the updated Privacy Policy on your first use of our Site/Service following the amendments. Therefore, we strongly recommend you to revisit this page and check our Privacy Policy regularly in order to keep up-to-date.