Privacy Policy

Last Updated: 2021/01/19

Welcome to [Project:L] (the Game).The Game is provided, operated and controlled by big fat (Hong Kong) Limited, whose registered address is at Suite 1113A, 11/F., Ocean Centre, Harbour City, 5 Canton Rd, Tsim Sha Tsui, Kowloon, Hong Kong. (big fat, we or us).

You are reading the Privacy Policy, which explains how we collect, use and disclose your personal data when you download the Game from Apple App Store or Google Play, access the Game, and the rights you may have under applicable privacy laws. If you do not agree with this policy, you should not play the Game.

If you have any questions about how we use your personal data, please contact Lucia.cs.jp@gmail.com.

Below is a summary of key points in our Privacy Policy.

This privacy policy consists of a main body and a jurisdiction-specific section. The jurisdiction-specific section might include additional information required under local data protection laws and/or render certain aspects of the body policy to be inapplicable or amend them accordingly due to local data protection laws.

SUMMARY

  1. What data do we collect about you?

We collect and process your data when you create an account and play the Game, including your contact details, location data and other data you provide when you register for an account, create or share content via the Game,or play the Game. We also collect data you share with us from third parties (such as Facebook, Twitter, Instagram, Google, or Apple). if you choose to log in to the Game via your account with such third party networks, and technical and behavioral data about your use of the Game. We may also collect data about you automatically through your use of the Game.

  1. How and for what purpose will we use the data about you?**

We use your data to provide the Game to you and to improve and administer it. We may also use your data to, among other things, improve and develop the Game and ensure your safety. We may also use your personal data to serve you targeted advertising and promote the Game and other products and services (in each case, if required under applicable law, where we have your consent).

  1. Who else will access and collect your personal data and who do we share your data with?**

The third party developer of the Game will have access to your data. Your data may also be collected by/shared with other companies in the same group as the big fat, payment providers, and advertising service providers. Where required or permitted by law, we will share your data with law enforcement agencies or regulators and with third parties pursuant to a legally binding court order.

  1. Your Rights

In certain circumstances, you have rights in relation to your data such as the right to access and the right to correction. Depending on your jurisdiction, you may have additional rights - please see the jurisdiction-specific provision at the end of this Privacy Policy.

  1. How long do we keep hold of your data?

We retain your data for as long as it is necessary to provide you with the Game service so that we can fulfill our contractual obligations and rights in relation to the data involved. Where we do not need your data in order to provide the Game to you, we retain it only as long as we have a legitimate business purpose in keeping such data or where we are subject to a legal obligation to retain the data. We will also retain your data if necessary for the establishment, exercise or defense of legal claims.

  1. How will we notify you of any changes to this Privacy Policy?**

We will generally notify all users of any material changes to this policy through a notice within the Game when you log in. However, you should look at this policy regularly to check for any changes. We will also update the Last Updated date at the top of this policy, which reflects the effective date of such policy. By accessing the Game, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it.

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  1. The types of personal data we use

Unless otherwise stated in this policy, the personal data we collect from you or about you is required so that we can perform our contract with you to provide the Game to you as detailed in our Terms of

Service. The provision of certain data is mandatory for the purposes of your access to the Game, and if you do not provide your age data required by us for account set up purposes, we will not be able to grant you access to the Game. If you do not provide certain types of data, such as your location data, we may not be able to provide certain aspects of the Game service or certain functionalities may be lost. However, you have control over certain kinds of personal data that you can choose to share or to withhold from us, and still be able to access the Game, as detailed in this policy.

We collect and use the following data about you:

Data You Provide to Us, Including Your Profile Data. You give us data when you register an account to play the Game via the application directly or if you choose to register using your social network account details (e.g. Facebook, Facebook, Twitter, Instagram, Google, Apple, Kakao, Line, etc.), including your name, gender, username, age, language, and/or email address, data you disclose in your user profile, your photograph or profile photo as well as photos and videos you choose to upload from your device while using the Game, for which you grant us access to your camera and or your devices photo album, character name or nickname, age data to verify an account, in a limited manner and data you voluntarily elect to provide in order to customize game play, such as gender. If you choose to find other users through your social network account contacts, we will access and collect them and match that data against existing users of the Game. We link your data with your activity on our Game across all your devices, using your email or other log-in or device data.

We also collect data in correspondence you send to us.

Behavioral and Use Data.

Gameplay

We process data regarding your use of the Game including login history, purchase history, how you engage with the Game, the preferences you set (such as choice of language), the amount of time spent in the Game, your game play and activity, your Game progress, your interactions with other players in the Game, your interactions with other players inside the Game, share records, download records and other pieces of data in connection with your various activities within or through the Game or otherwise (including when you capture a screenshot in the Game) that are sent by your browser, device or computer system when you access the Game, which are automatically tracked and recorded by our servers. We also link your subscriber data with your activity on our Game across all your devices using your email, phone number, or similar data that you have provided. When you capture a screenshot, we will give you the option to share the screenshot through either an SMS, email, messaging app or social media platform.

Your participation in tournaments or other online gaming events is conditional upon you granting big fat permission to collect, use, store, transmit and publicly display statistical data, such as your scores, rankings and achievements, generated through your participation.

Surveys

We collect data through surveys, challenges and competitions in which you may participate including gender, likeness, age and preferences.We also infer your preferences, including your interests, gender and age for the purpose of serving personalized advertising (with your consent, if required under applicable law). We will also process your personal data in order to tell you about services and opportunities.

Messages

Where local laws allow us to, we collect and process, which includes scanning and analyzing, data you provide in the context of composing, sending, or receiving direct messages to and from other players, either directly on our websites and apps or to third party social media account and whether by words, audio, video or photos and your communications with us e.g.in the context of customer support including audio messages. That data includes the content of the message and data about when the message has been sent, received and/or read, as well as the participants of the communication.

We do this to prevent and block spam, prevent and detect crime, safeguard children (where this is in the substantial public interest) or to protect the interests of our users and other people.

Please also be aware that messages sent to other players will be accessible by those players and that we are not responsible for how those players use or disclose them.

Message Boards and Chat Rooms

We may also collect additional data you share about yourself such as on the Games message boards, chat rooms and in the Game, including comments, images, photos, links, stickers and emojis. Any actions you perform with other players are considered public and are solely at your discretion, and therefore you should have no expectation of privacy or confidentiality. You may choose to disclose data about yourself in the course of contributing user generated content to the Game or in its chat rooms, blogs, message boards, user profiles for public view, or in similar forums on its sites through mobile services and/or through third party sites or services. You should be aware that any personally identifiable data you submit in the course of these public activities can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages.

Feedback

We also collect data and content of messages you provide to us through your feedback such as product reviews you write, or questions and data you provide for customer support. In this case, we may collect and store your contact data that you give them (i.e. your name and email address), your social network or service user ID number. When you contact us, such as for customer support, phone conversations or chat sessions with our representatives may be monitored and recorded.

Data from Third Parties. You may choose to share certain data with us from third parties or through your use of the Game. We have set out further details on the data we receive from third parties below:

Social Networks

If you choose to register to use the Game using your social network account details (e.g. Facebook, Twitter, Instagram, Google or Apple), you will provide us or allow your social network to provide us with your username and public profile (including your name, profile picture, gender, networks, user IDs, list of friends, followers and accounts you follow, date of birth, email address, and any other data you have set to public on your account). We may also access posts in your news feeds, friend data or fan pages and any other data included in your social network or online profile including blacklists, likes given and received, even if you are not using the social network. Please note that if you allow big fat to have access to this data, then big fat will have access to data even if you have chosen not to make that data public.

Advertising Service Providers

We use the data collected from you and your interaction with the Game to infer your likely interests to provide you with more relevant advertising. If you provide your consent for us to do so (where required by applicable law). This data tells us about purchases you have made so that we can predict what else might interest you in the future and assess how effective the advertising on our Game is. We collect this data by the use of Cookies and similar technologies in our Game and from similar data received from third parties who advertise through our Game and whose sites you visit.

Technical Data we collect about you. We automatically collect certain data from you when you use the Game. Such data includes your IP address, time zone settings,browser type, language, data regarding the device or hardware you are using to access the Game such as the model of your device, mobile devices unique identifier (UDID) or serial number, cellular information, WiFi network, identifier for vendor (IDFV), source of user (where you use your account on a third party platform to log in), IMEI number (only for games launched in China), device screen resolution, mobile carrier, software, platform, incident data, network type, device ID, operating system, a list of installed packages and running apps or processes, file names and types, Android ID, Google Advertising ID, and other third-party apps you have on your device, as well as other types of data sent by your browser or device when you access the Game, domain names, landing pages, pages viewed and the order of those pages, amount of time spent on particular pages, referring pages, exit pages and URLs, number of clicks, and the date and time of this activity which are automatically tracked and recorded by our servers. Where you log-in from multiple devices, we will be able to use your profile data to identify your activity across devices.

Location. We use the Region; you select in Settings to customize your Game experience. When you play the Game on a mobile device, we will collect data about your location, including your country, zip code, area code and geolocation. In certain jurisdictions, with your permission, we will collect Global Positioning System (GPS) data and mobile device location data based on your SIM card. If you do not wish to share your precise location with us, you can switch off location services via the settings on your mobile device.

Find other users and invite your friends. you can choose whether to find other users of the Game among your contacts in your preferred social networks who have a Game account. The Game supports and often encourages you to interact with other players. If you choose to find other users through your social network contacts, we will collect your public profile data as well as names and profiles of your social contacts. If you play through a social network or register through asocial network, your social network friends will see your name, profile photo and descriptions of your Game activity. Similarly, other players, regardless of whether they are your social network friends or not, will be able to see descriptions of your Game activity and view your Game profile, which may include your name or a game name and your profile photo. Other players may also be able to send you Game requests or even friend requests. You can also use this function to invite your contacts to join you in playing the Game. We will use the contact data you have for that person, from Facebook friends (or other similar social network) list and give you the option to send them either an SMS, email or third party message (such as WhatsApp, Facebook (including Facebook Messenger), Instagram, Google, Twitter, Kakao or Line) inviting them to play the Game.

Buy virtual items. If you buy virtual items and advantages via in-app purchases, we collect

your transaction record including how much you spent in the game and items purchased OR your purchase will be made via your Apple iTunes or Google Play account. When you play the Game or access any of our other services on connected third-party applications or platforms (like Facebook, Apple, Google, etc), any purchases you make will be processed by that third-party application and subject to that third-party applications terms of service and privacy policy. We do not collect any financial or billing data from you in relation to such a transaction but may receive non-financial data related to your purchase, like your name and approximate physical location, the fact that you have an Apple Pay or Google Pay account, and the items purchased. Please review the relevant app stores terms and notices in respect of the handling of such data. So that we can credit your account with the correct value in virtual items, we keep a record of the virtual assets/items you own, purchases you make, the time at which you make those purchases and the amount spent.

Other. big fat may also receive either non-personal or public data from third parties in connection with market and demographic studies and/or data that big fat may use to supplement personal data provided directly by you. big fat may ask some third-party service providers to supplement the personal data that you provide to big fat for its own marketing and demographic studies, so that big fat can consistently improve its services and related advertising to better meet its visitors needs and preferences. To enrich its understanding of individual customers, big fat may tie this data to the data you provide to it.

2. Cookies

We, our vendors and service providers use cookies and other similar technologies (e.g. pixels, web beacons etc.) (collectively, Cookies) to enhance your experience using the Game. We will obtain your consent to the use of Cookies where required under applicable law.

a) What is a Cookie?

Cookies are used to collect data, including personal data, from you. Cookies are small files which, when placed on your device, enable the Game to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as pixel tags or clear GIFs, that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar data from your computer or device.

Cookies are stored on your browser by website or apps that you visit. When you return to that website or app (or visit websites or apps that use the same cookies) these platforms recognize the Cookies and your browsing device.

We also use pixels. Pixels are small portions of code which we use in the Game. We use pixels to learn whether you have clicked on certain content and help us to optimize our ad campaigns.This helps us measure and improve our services and personalize your experience.

b) Categories of Cookies

Cookies do many different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. Cookies can tell us, for example, whether you have visited the Game before or whether you are a new player. They can also help to ensure that adverts you see online are more relevant to you and your interests.

There are different categories of Cookies, including:

· First-party Cookies: First-party Cookies are small amounts of text which are served by us directly to your device.

· Third-party Cookies: Third-party Cookies, which are served by a third party on our behalf. We use third party Cookies for essential, functionality, analytic and performance, targeting or advertising and social media purposes.

Cookies can remain on your computer or mobile device for different periods of time. Some Cookies are session cookies, meaning that they exist only while your browser is open and are deleted automatically once you close your browser. Other Cookies are permanent cookies, meaning that they survive after your browser is closed. They can be used by the platform to recognize your computer when you open your browser and browse the Internet again.

c) What types of Cookies do we use and how do we use them?

The types of Cookies and similar technologies used by us and our partners in connection with the Game can be classified into one of five categories, namely essential Game Cookies, functionality Cookies, analytics and performance Cookies, targeting and advertising Cookies, and social media Cookies. Cookies do a lot of different tasks to ensure you enjoy your use of the Game, for example, they are used to remember your preferences on sites you visit, to help you navigate between pages more efficiently and to make sure the adverts you see on our Game are relevant to you and your interests. We have set out some further information about each category, and the purposes of the Cookies we and third parties set in the following table.

Cookies that are necessary for essential purposes

These Cookies are essential to provide you with the Game and to use some of its features, such as to enable you to log in. Without these Cookies, we would not be able to provide you with a secure log in account. We use Cookies to uniquely identify you. Each time you log in to the Game, a Cookie containing a unique identifier that is tied to your account is placed on your browser. These Cookies allow us to uniquely identify you when you are logged into the Game and to process your online transactions and requests.

Functionality Cookies

Functionality Cookies record information you have entered or choices you have made. These Cookies also enable you to optimize your use of the Game after logging in so that we can personalize our content for you, greet you by name and remember your preference. These Cookies can also be used to remember settings you have applied, such as insert settings applicable to game e.g. layout and text size. These Cookies mean that when you continue to use or come back to the Game, we can enable you to start the Game from where you left off.

Analytics and Performance Cookies

We use performance/analytics Cookies to analyze how you use the Game, including your level in the Game, which tutorials you view, measure any errors that occur and test different design ideas. The information is used to report and evaluate your activities and patterns as a user of the Game to provide services in accordance with these activities. These Cookies do not collect information that individually identifies you and all information these Cookies collect is aggregated and anonymous. We also use third-party analytics tools to help us measure traffic and usage trends for the Game (with your consent if required under applicable law).

Targeting or Advertising Cookies

Analytics: As you use the Game, you will notice that it features advertising. We allow third party companies, including advertising companies, to place Cookies in the Game to track the performance of our advertisements (with your consent if required under applicable law). As an example, these Cookies remember which users have used the Game. The information provided to third parties does not include personal information but it may be associated with personal information after we receive it.

Marketing: We may also (with your permission, where required under applicable law) contract with third-party advertising networks that collect IP addresses and other information from the Game, from third party websites and apps. Ad networks follow your online activities and collect information through automated means (such as through the use of Cookies, again, with your consent, if required under applicable law). Ad networks use this information, mainly to serve adverts about products and services that are likely to interest you. We may also partner with third parties to provide certain features in the Game or display advertising based on your web browsing activity. We may also use information from one device to help personalize your experience on another device. For advertising purposes, we may collect your Google Ad ID, Android Ad ID or (where applicable) your IDFA (IDFA stake the place of Cookies in mobile advertising delivered to iOS devices).

Social Media Cookies

Third parties whose applications are connected to the Game by you will set their own Cookies in order to customize their applications for you. Because of how Cookies work, we cannot access these Cookies, nor can the third parties access the data in Cookies used by us. If you are logged in to your account with the third party, the third party will be able to link information about you with your actions via Cookies.

  1. How and for what purpose we use your personal data

We may use the data we collect about you in the following ways:

• In order to comply with our legal obligations, we may use your data to

• In accordance with our legitimate interests to provide an enjoyable and

  1. Who else will access your personal data and how we share your data

Third Party Game Developer

We work with third party game developers, and the third party developer of the Game will have access to your technical data and other data.

Social Networks

If you choose to register to use the Game using your social network account details (e.g. Facebook, Twitter, Instagram, Google, Line or Kakao, etc), you will provide us or allow your social network to provide us with your user name and public profile (including your name, profile picture, gender, networks, user IDs, list of friends, date of birth, email address, and any other data you have set to public on your account).

If you access third-party services, such as Facebook, Instagram, Google, Apple, or Twitter, to login to the Game or to share data about your usage of the Game with others, these third-party services may be able to collect data about you, including data about your activity on the Game, and they may notify your connections on the third-party services about your use of the Game, in accordance with their privacy policies.

To manage the data big fat receives about you from a third-party application, such as Facebook, you will need to follow the instructions for the third-party application for updating your data and changing your privacy settings. To review and update data associated with the game profile in certain games, visit the settings page in that game.You can also manage some aspects of data collection and use by visiting the settings page of your mobile device and reviewing the permissions of each application or app. Once big fat receives your data from a third-party application or your mobile device, that data is stored and used by big fat in accordance with this Privacy Policy. You may access and update that data as described herein.

Payment Provider

If you choose to buy virtual items, we will share data with the relevant payment provider to facilitate this transaction. We share a transaction ID to enable us to identify you and credit your account with the correct value in virtual items once you have made the payment.

Advertising Service Providers

We may share data with advertisers and third party measurement companies may collect some of your personal data, for example to show how many and which users of the Game have viewed or clicked on an advertisement. We will also share and/or they may collect non-personal and personal data e.g. IDFA, IP address, time zone settings, browser type, language, operating system, network connection type and speed, and data regarding the device or hardware you are using to access the Game such as the model and make of your device, you may refer to the advertisers privacy policy for more information.

Please note, after clicking on a third party advertisement, you may no longer be on a site hosted by big fat or the social network through which you are playing the Game. If you no longer want to receive tailored in-Game advertisements from third parties, you may adjust your privacy settings.

Our third-party analytics providers use this data to help us serve targeted adverts which may be of interest to you (if you have chosen to receive personalized advertising from us and/or our partners). For more data about how our analytics providers collect data from the Game, please see the above section on Cookies.

Service Providers

We provide data and content to service providers who support our business, including but not limited to cloud service and data storage providers, maintenance service providers, customer service providers, and technical support providers who enhance game operations, improve the Game experience, conduct debugging, analytics and provide general support services. We contractually require these third party service providers to maintain the confidentiality of the data we share with them, and we require them not use your data for anything other than to provide services on our behalf.

Our Corporate Group

We may also share your data with other members, subsidiaries, or affiliates of our corporate group, to provide the Game including improving and optimizing the Game, preventing illegal use, and supporting users.

Law Enforcement

We may share your data with law enforcement agencies, public authorities or other organizations if legally required or permitted to do so, or based on our legitimate business interests if such use is reasonably necessary to:

Social Features of the Game

If you choose to engage in the social features of the Game (e.g. sending messages to others), you should be aware that any data you share may be read, collected, or used by other users. You should use caution in disclosing personal data while engaging. We are not responsible for the data you choose to share with other players.

Sale or Merger

We will also disclose your data to third parties:

5. International data transfers

The personal data that we collect from you may be transferred to, and stored at, or otherwise processed in a destination outside of your jurisdiction of residence. Please see the jurisdiction-specific terms at the end of this privacy policy for further information relevant to your jurisdiction.

  1. Your Rights

You may have the following rights under applicable laws:

Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

Depending on your jurisdiction, you may have additional rights. Please see the jurisdiction-specific provisions at the end of this Privacy Policy.

Please send an e-mail to Lucia.cs.jp@gmail.com if you would like to exercise any of your rights. We will respond to your request consistent with applicable law and subject to proper verification.

In addition:

  1. The security of your personal data

We take steps to ensure that your data is treated securely and in accordance with this policy. Unfortunately, the transmission of data via the internet is not completely secure. Although we will do our best to protect your personal data, for example, by encryption, we cannot guarantee the security of your data transmitted via the Game; any transmission is at your own risk.

We will, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Because big fat cannot control the activities of third parties, it cannot accept responsibility for any use of your personal data by such third parties, and it cannot guarantee that they will adhere to the same privacy and security practices as big fat. Please check these policies before you submit any data to these websites.

  1. How long do we keep your personal data

We retain your data for as long as it is necessary to provide you with the service so that we can fulfill our contractual obligations and rights in relation to the data involved. However, there are occasions where we are likely to keep this data for longer in accordance with our legal obligations or where it is necessary for the establishment, exercise or defense of legal claims.

  1. Data relating to children

The Game is not directed at children under the age of 13 and we do not knowingly collect or solicit personal data from children under 13. If you believe that we have personal data about or collected from a child under the relevant age, please contact us at Lucia.cs.jp@gmail.com and we will ensure that it is deleted.

  1. Complaints

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at Lucia.cs.jp@gmail.com and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the relevant data protection authority.

  1. Changes

We will generally notify all users of any material changes to this policy, through a notice provided via the Game and providing any other notice required by applicable law. However, you should look at this policy regularly to check for any changes. We will also update the Last Updated date at the top of this policy, which reflects the effective date of such policy. Your continued access to or use of the Game after the date of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Game.

  1. Translations

In the event of any conflict or inconsistency between the terms in the English and any translation thereof in any other language, the English version shall prevail.

  1. Contact

Questions, comments and requests regarding this policy should be addressed to Lucia.cs.jp@gmail.com.

Supplemental Terms - Jurisdiction-Specific

In the event of a conflict between the provisions of the Supplemental Terms - Jurisdiction - Specific that are relevant to your jurisdiction from which you access or use the Services, and the rest of policy, the relevant jurisdictions Supplemental Terms - Jurisdiction - Specific will supersede and control.

EUROPEAN JURISDICTIONS

Germany

Questions, comments and requests regarding this policy should be addressed to Lucia.cs.jp@gmail.com.

In the Summary, under How will we notify you of any changes to this Privacy Policy?, the following sentence shall be deleted:

By accessing the Game, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it.

Section 11 (Changes) is modified to delete the sentence:

Your continued access to or use of the Game after the date of the updated policy constitutes your acceptance of the updated policy.

EEA, UK and Switzerland

In Section 2 (Cookies), the following shall be added:

We will only make use of Cookies to obtain and share your data if you provide your express consent. You may withdraw your consent at any time and such withdrawal shall not affect the lawfulness of the processing based on consent before its withdrawal.

In Section 3 (How we use your data), the following shall be added:

• With your consent, we will use your data (including ad identifiers, age, region, gender, language, data related to your use of the Game and interactions with others, messages including content of the message and data about when the message has been sent, received and/or read, as well as the participants of the communication, username and public profile) to:

○ conduct surveys as outlined in the body section of this privacy policy including telling you about services and opportunities;

○ collect and process, which includes scanning and analyzing, data you provide in the context of composing, sending, or receiving messages through the Game messaging functionality. That data includes the content of the message and data about when the message has been sent, received and/or read, as well as the participants of the communication;

○ monitor and record customer support communication, phone conversations or chat sessions with our representatives;

○ access posts to your social media walls, posts in your news feed and access your social network data at any time, including any of your favorite websites, friend data or fan pages and any other data included in your application, social network or online profile, even if you are not using the social network or you chose not to make that data public;

○ provide you with personalized advertising. Please see the section entitled Advertising Service Providers for more information. You can manage Personalized Ads via your Game settings;

○ collect and process certain technical data, namely list of installed packages and running apps or processes and third-party apps you have on your device;

○ collect data about your location. In certain jurisdictions, with your permission, we will collect Global Positioning System (GPS) data and mobile device location data based on your SIM card;

○ find other users and invite your friends in your preferred social networks as outlined in the body section of this privacy policy and to show descriptions of your game activity and game profile to other players on the social network, regardless of whether they are your social network friends or not;

○ supplement personal data provided directly by you with either non-personal or public data from third parties in connection with market and demographic studies and/or data that big fatmay use, or to ask third-party service providers to supplement the personal data that you provide to big fat for its own marketing and demographic studies, and to tie individual customer data to data you provide to big fat.

○ to send you direct marketing via email or SMS; and

○ use cookies as outlined under section 2.

You may withdraw your consent at any time and such withdrawal shall not affect the lawfulness of the processing based on consent before its withdrawal.

The following shall be added to section 5 - International data transfers:

The personal data that we collect from you will be transferred to, and stored at, a destination outside of the European Economic Area (EEA).

Where we transfer your personal data to countries outside the EEA, we do so under the Commissions model contracts for the transfer of personal data to third countries

(i.e. standard contractual clauses) pursuant to 2004/915/EC or 2010/87/EU (as appropriate). For a copy of these Standard Contractual Clauses, please contact us at Lucia.cs.jp@gmail.com.

The following shall amend section 6 - Your Rights:

• Right to request access to your personal data: You have the right to obtain from us confirmation as to whether or not personal data concerning you is processed, and, where that is the case, to request access to the personal data. The access information includes - inter alia - the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipient to whom the personal data have been or will be disclosed. However, this is not an absolute right and the interests of other individuals may restrict your right of access.

You have the right to obtain a copy of the personal data undergoing processing free of charge. For further copies requested by you, we may charge a reasonable fee based on administrative costs.

• Right to request rectification: You have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

• Right to request erasure (right to be forgotten): You have the right to obtain from us the erasure of personal data concerning you and we may be obliged to erase such personal data.

• Right to request restriction of processing: You have the right to obtain from us that we restrict the processing of your personal data. In this case, the respective data will be marked and may only be processed by us for certain purposes.

• Right to data portability: Where processing of your personal data is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, you have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format or to have your personal data transmitted directly to another company, where technically feasible;

• Right to withdraw consent: Where the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time without impact to data processing activities that have taken place before such withdrawal;

• Automatic decision making: You have the right not to be subject to any automatic individual decisions, including profiling, which produces legal effects on you or similarly significantly affects you unless we have your consent, this is authorized by EU or EU Member State law or this is necessary for the performance of a contract;

• Right to Object: You have the right to object to processing if we are processing your personal data on the basis of our legitimate interest unless we can demonstrate compelling legitimate grounds which may override your right. If you object to such processing, we ask you to state the grounds of your objection in order for us to examine the processing of your personal data and to balance our legitimate interest in processing and your objection to this processing; and

• Right to complaint: You have the right to lodge complaints before the competent data protection authority.

These rights might be limited under applicable national data protection law.

Please send an e-mail to Lucia.cs.jp@gmail.com if you would like to exercise any of your rights. We will respond to your request consistent with applicable law and subject to proper verification.

Section 8 (How long we keep your personal data) is modified to add:

Where we do not need your data in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose or other valid legal basis for keeping such data.

Section 9 (Information relating to children) shall be replaced with the following:

The Game is not directed at children under the age of 16 and we do not knowingly collect or solicit personal data from children under 16. If you believe that we have personal data about or collected from a child under the relevant age, please contact us at Lucia.cs.jp@gmail.com and we will ensure that it is deleted.

ASIA-PACIFIC JURISDICTIONS

Australia

The following definition shall apply to the Privacy Policy:

Personal data means personal information as defined in the Privacy Act 1988 (Cth), i.e., information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable.

The following shall be added to Section 5 - International data transfers:

The personal data that we collect from you will be transferred to, and stored at, a destination outside of Australia, in particular in Singapore and the United States of America.

The following shall replace Section 12 - Contact:

If you have any questions about the Privacy Policy, or would like to complain about a breach of the Australian Privacy Principles, or are concerned about the handling of your personal data, please contact the privacy officer at Lucia.cs.jp@gmail.com. You have the right to access your personal data and seek correction of it. Please contact the privacy officer on the details provided in this Privacy Policy if you wish to access your personal data and/or seek correction of your personal data. If you are not satisfied with the response or do not receive a response within a reasonable time frame, you may have the right to take your complaint to the Office of the Australian Information Commissioner (OAIC). Current contact details for the OAIC are available on the OAICs website at www.oaic.gov.au.

New Zealand

The following sentence should be added to the end of Section 5 (International Data Transfers):

Where we send your personal data to a jurisdiction outside of New Zealand, we will ensure that your personal data will be protected by security safeguards comparable to New Zealand law while in that foreign jurisdiction. If your personal information will not be protected by security safeguards comparable to New Zealand law while in that foreign jurisdiction, we will inform you that this is the case, and only transfer your personal information with your consent.

Hong Kong

Section 3 (How we use your personal data) is modified to add:

We intend to use your personal data (name and email address) for promotional marketing purposes, namely to send you messages concerning new products, features, enhancements, special offers, upgrade opportunities, contests and events of interest in relation to the Game. We require your express consent (for use) and written consent (for transfer) before we do so.

We will not transfer your personal data to other parties for gain.

Japan

The following shall be added to Section 5 - International data transfers:

The personal data that we collect from you will be transferred to, and stored at, a destination outside of Japan, in particular in Singapore and the United States of America.

Macau

In Section 1 (The types of personal data we use), the first sentence of the second paragraph is modified to read: You expressly consent that we will collect and use the following data about you:.

In Section 3 (How and for what purpose we use your personal data), the first sentence is modified to read: You expressly consent that we may use the data we collect about you in the following ways:.

In Section 4 (How we share your personal data), the first sentence is modified to read: You expressly consent that we will share your data with the following selected third parties:.

Section 5 (International data transfers) shall be modified as follows:

You expressly consent that the personal data that we collect from you may be transferred to, and stored at, or otherwise processed in a destination outside of your jurisdiction of residence. These jurisdictions include Singapore and the United States of America. The list of jurisdictions may be supplemented from time to time in accordance with Section 11 of this Policy.

In Section 6 (Your rights), the following sentence: The right to object to processing your personal data for the purposes of sending you promotional messages shall be deleted and replaced with the following:

• The right to object prior to and during our usage of your personal data for direct marketing purposes.

South Korea

Section 3 (How we use your personal data) is modified as follows:

We intend to use your personal data (name and email address) to send you promotional messages concerning new products, features, enhancements, special offers, upgrade opportunities, contests and events of interest in relation to the Game. We require your express consent before we do so.

Section 4 (How we share your personal data) shall be modified as follows:

We share your data with the following selected third parties:

Service Providers

We provide data and content to service providers who support our business, such as cloud service and data storage providers, and technical support providers who enhance game operations, improve the Game experience,conduct debugging, and provide general support services. Details of the service providers are as follows:

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Section 8 (How long we keep your personal data) shall be replaced with the following:

In principle, we will promptly destroy your personal data in our possession once we achieve the purpose of collection and use of your personal data.

Procedure and Method for Destruction of Personal Data

In principle, we will promptly destroy your personal data in our possession once we achieve the purpose of collection and use of your personal data.

Your personal data will be destroyed after storage for a certain period pursuant to our internal policy or applicable laws and regulations (please refer to the provisions on retention and use period). Personal data stored in electronic file format will be deleted by using technical means that will not allow data recovery.

Section 9 (Data relating to children) shall be replaced with the following:

The Game is not directed at children under the age of 14 and we do not knowingly collect or solicit personal data from children under 14. If you believe that we have personal data about or collected from a child under the relevant age, please contact us at Lucia.cs.jp@gmail.com and we will ensure that it is deleted.

For children under the age of 14, their legal guardians have the right to exercise the rights of their children with respect to data protection.

Taiwan

Section 5 (International data transfers) shall be modified as follows:

The personal data that we collect from you may be transferred to, and stored at, or otherwise processed in destination outside of your jurisdiction of residence, including Singapore and the United States.

The following wording shall be added to Section 6 - Your rights:

• The right to request the cessation of the collection, processing or use of your personal data.

Thailand

The first paragraph of section 6 (Your Rights) shall be replaced with the following:

You may have the following rights under applicable laws:

• Right to request access to your personal data: You have the right to request access to and obtain a copy of the personal data we have about you, including to request from us information regarding how we acquired personal data which we obtained without your consent.

• Right to data portability: Where processing of your personal data is either based on your consent or necessary for the performance of a contract with you, in a structured, commonly used machine-readable format and processing is carried out by automated means, you have the right to receive a copy of the personal data concerning you in such format, or to have your personal data transmitted directly to another party;

• Right to object: You have the right to object to processing in certain cases, including when we use your personal data for direct marketing purposes;

• Right to request erasure (right to be forgotten): You have the right to obtain from us the erasure of personal data concerning you and we may be obliged to erase such personal data.

• Right to request restriction of processing: You have the right to restrict the collection, use and disclosure of your personal data. This enables you to ask us to suspend the collection, use and disclosure of your personal data in certain cases;

• Right to request rectification: You have the right to rectify personal data we hold about you which are inaccurate, outdated, incomplete, and misleading.

• Right to withdraw consent: Where the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time without impact to data processing activities that have taken place before such withdrawal;

• Right to complaint: You have the right to lodge complaints before the competent data protection authority.

The following shall be added to Section 5 (International data transfers):

Some of the recipients we may share your personal data with may be located outside Thailand, where the data protection standards in those destination countries may or may not be equivalent to Thailand. In such case, we take necessary steps to ensure the appropriate safeguards are in place, and oblige the recipients to protect your personal data in accordance with this policy. We will separately obtain your consent for international data transfer, where consent is required under applicable law.

The following shall be added to section 9 (Data relating to children):

For individuals under 20 years of age, we do not offer targeted and personalized ads to you and you will not receive direct marketing communications about third party products and services.

Indonesia

In the Summary, under _ How will we notify you of any changes to this Privacy Policy? _, the following sentences shall be deleted: However, you should look at this policy regularly to check for any changes. By accessing the Game, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it.

The following clause shall be added to Section 1 (The types of personal data we use): When you provide us with your personal data, we will send a verification link to the email address you provided in our service to ensure the accuracy of personal data.

The first sentence in Section 3 (How and for what purpose we use your personal data) shall be replaced with: Upon obtaining your expressed consent, we may use the data we collect about you in the following ways: …

The first sentence in Section 4 (How we share your personal data) shall be replaced with: We share your data that is disclosed to and given consent by you, with the following selected third parties:…

Section 5 (International data transfers) shall be replaced with the following:

The personal data which you provide to us may be stored, processed, transferred between, and accessed in a destination outside of Indonesia which have laws and regulations that may not guarantee the same level of protection of personal data as Indonesia. However, we will take reasonable steps to ensure that your personal data is handled in accordance with this Privacy Policy, regardless of where your personal data is stored or accessed from.

Section 9 (Data relating to children) shall be replaced with the following:

The Game is directed toward and designed for use by persons aged 21 or older. We do not intend to collect personal data from children under 21 years of age, except on some sites specifically directed to children. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 21, you hereby declare that such user is above the age of 13 and that you have read and acknowledged big fat Privacy Policy and Terms of Use and agree to the use by your child of the game and registration for an account. Further, if you believe that we have personal data about or collected from a child under the relevant age, please contact us at Lucia.cs.jp@gmail.com and we will ensure that it is deleted.

The following sentences under Section 11 (Changes) should be deleted: However, you should look at this policy regularly to check for any changes. Your continued access to or use of the Game after the date of the updated policy constitutes your acceptance of the updated policy.

The following to be added to the end of the Privacy Policy:

If you agree for us to use your personal data as elaborated in this Privacy Policy, please confirm by checking the box.

Singapore

The following shall be added to Section 5 (International data transfers):

We shall ensure that any personal data transferred to a jurisdiction outside of Singapore will be provided a standard of protection to personal data so transferred that is comparable with the protection under the Personal Data Protection Act 2012.

Section 6 (Your Rights) shall be deleted and replaced as follows:

You may have the following rights under applicable laws:

• The right to request (i) confirmation of whether we process your personal data and (ii) access to a copy of the personal data retained for a reasonable fee;

• The right to request proper rectification of your personal data;

• The right to withdraw consent to processing of your personal data, including the use of your personal data for the purposes of sending you promotional messages. We may continue to process your personal data if we are permitted to do so without your consent under applicable law.

Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

Please send an e-mail to Lucia.cs.jp@gmail.com if you would like to exercise any of your rights. We will respond to your request consistent with applicable law and subject to proper verification.

Malaysia

The following sentence shall be added in the second paragraph of the Privacy Policy before If you do not agree with this policy, you should not play the Game:

By accessing the Game or providing us with your personal information, you consent to your personal data being collected, stored, used, processed and disclosed asset out in this policy, including the transfer of your personal data outside of Malaysia.

The following shall be added to Section 5 (International data transfers):

You hereby expressly consent that the personal data that we collect from you may be transferred to, and stored at, a destination outside of Malaysia. For the places where the personal data is transmitted, retained or processed outside of Malaysia, we will take reasonable measures to protect that personal data.

The first paragraph of Section 6 (Your rights) before Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details shall be deleted in its entirety and replaced with the following:

You may have the following rights under applicable laws:

• The right to request free of charge (i) confirmation of whether we process your personal data and (ii) access to a copy of the personal data retained;

• The right to request proper rectification or removal of your personal data or restriction of the processing of your personal data, including personal data relating to other persons who may be identified from that personal data; and

• The right to object to processing your personal data for the purposes of sending you promotional messages.

Section 12 (Contact) shall be deleted in its entirety and replaced with the following:

Questions, comments and requests regarding this policy should be addressed to Lucia.cs.jp@gmail.com.

Philippines

The following is added to the Summary:

The following is added to Section 6 (Your Rights):

The following shall replace Section 12 (Contact):

If you have any questions about the Privacy Policy, or would like to complain about a violation of the Data Privacy Act of 2012, or are concerned about the handling of your personal data, please contact the data protection officer (DPO) at Lucia.cs.jp@gmail.com. You have the right to access your personal data and seek correction of it. Please contact the DPO on the details provided in this Privacy Policy if you wish to access your personal data and/or seek correction of your personal data. If you are not satisfied with the response or do not receive a response within a reasonable time frame, you have the file a complaint with the National Privacy Commission (NPC). Current contact details for the NPC are available on the NPCs website at www.privacy.gov.ph.

Vietnam

Section 3 (How we use your personal data) is modified to add:

We intend to use your personal data for promotional marketing purposes, including to send you promotional messages concerning new products, features, enhancements, special offers, upgrade opportunities, contests and events of interest in relation to the Game. We require your express consent to do so.

Section 4 (How we share your personal data), the first sentence is modified to read: You expressly consent that we may share your data with the following selected third parties:

The Law Enforcement in this Section shall be replaced with:

We may share your data with law enforcement agencies, governmental, public and regulatory authorities or other organizations (whether in Singapore or another jurisdiction) if legally required or permitted to do so under applicable laws, or pursuant to any court order, or based on our legitimate business interests if such use is reasonably necessary to:

• comply with a legal obligation, process or request by any law enforcement agencies, governmental, public and regulatory authorities (whether in Singapore or another jurisdiction) or any court order, subpoena or search warrant (big fat is not required to question or contest the validity of any legal process, search warrant, subpoena or other similar governmental request that it may receive);

• enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;

• detect, prevent or otherwise address security, fraud or technical issues;

• or protect and defend the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging data with other companies and organizations for the purposes of fraud protection, anti-money laundering prevention, know your client checks and credit risk reduction).

Section 5 (International data transfers), the first sentence is modified to read: You expressly consent that the personal data we collect from you may be transferred to, and stored at, or otherwise processed in a destination outside of your jurisdiction or residence.

Section 6 (Your Rights), the following shall be added:

Section 9 (Data relating to children) shall be replaced with the following:

The Game is not directed at children under the age of 16 and we do not knowingly collect or solicit personal data from children under 16. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 16, you hereby declare that such user is above the age of 13 and that you have read and acknowledged big fat Privacy Policy and Terms of Use and agree to the use by your child of the game and registration for an account. Further, if you believe that we have personal data about or collected from a child under the relevant age, please contact us at Lucia.cs.jp@gmail.com and we will ensure that it is deleted..

THE AMERICAS

Canada

The following shall be added to Section 5 - International data transfers:

The personal data that we collect from you will be transferred to, and stored at, a destination outside of Canada, in particular in Singapore and the United States of America for the purposes stated under this Privacy Policy. We may disclose your personal data to foreign law enforcement and national security authorities in such jurisdictions in accordance with this Privacy Policy.

The following shall replace Section 12:

Contact

If you have any questions, comments and requests regarding this policy, or would like to obtain written information about the organizations policies and practices with respect to service providers outside of Canada, please contact Lucia.cs.jp@gmail.com.

The data protection officer for us can be contacted as follows: Lucia.cs.jp@gmail.com.

USA

Data relating to children

Section 9 (Data relating to children) is modified to add:

big fat respects the privacy of parents and children, and is committed to complying with the Childrens Online Privacy Protection Act (COPPA). If a parent believes that his or her child under the age of 13 has submitted personal data to big fat, he or she can contact us via email: Lucia.cs.jp@gmail.com.

Supplemental California Disclosures

In this section, we disclose information about our data processing practices as required by the California Consumer Privacy Act of 2018 (CCPA). These disclosures are addressed only to residents of the State of California. These disclosures do not reflect our collection, use or disclosure of California residents personal information where an exception under the CCPA applies.

For the purpose of these supplemental disclosures, personal data as used in the Privacy Policy, shall have the same meaning as personal information under the CCPA.

A. Right to Know about Personal Information Collected, Disclosed or Sold

You have the right to request that we disclose what personal information we collect, use, disclose and sell about you specifically (right to know). To submit a request to exercise the right to know, please submit an email request to Lucia.cs.jp@gmail.com and include California Request to Know in the subject line. Please specify in your request the details you would like to know, including any specific pieces of personal information you would like to access.

We will ask that you provide certain information to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. We will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.

B. Our Personal Information Handling Practices over the Past 12 Months

We have set out below categories of personal information we have collected about California residents in the preceding 12 months. For each category of personal information we have collected, we have included the reference to the enumerated category or categories of personal information in California Civil Code § 1798.140(o)(1) that most closely describe such personal information.

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We collect such information from you or your device. If you choose to provide us with information through your social network account, we also collect information about you from the provider of that social network. We may also collect information about your interests, preferences and characteristics from advertising networks and publicly available sources for the purposes of targeting advertising at you. We use your personal information for the purposes set forth in Section 3 of the Privacy Policy above.

In the past 12 months, we disclosed the above categories of personal information to our affiliated and unaffiliated service providers for the purposes listed in our Privacy Policy. If you direct us to share your personal information with other specified third parties, we may disclose information about you with these third parties for the purposes described in your directions. We may also disclose personal information to the recipients described in Section 4 of the Privacy Policy above.

We do not sell, and in the preceding 12 months did not sell, California residents personal information. We do not have actual knowledge that we sell the personal information of minors under 16 years of age.

C. Right to Request Deletion of Personal Information

You have a right to request the deletion of personal information that we collect or maintain about you. To submit a request to delete personal information, please submit an email request to Lucia.cs.jp@gmail.com and include California Request to Delete in the subject line. Please specify in your request the personal information about you that you would like to have deleted, which can be all of your personal information as required by the CCPA.

We will ask that you provide certain information to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. Once confirmed, we will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.

D. Right to Non-Discrimination for the Exercise of CCPA Rights

You may not be discriminated against because you exercise any of your rights under the CCPA in violation of California Civil Code § 1798.125.

E. Right to Information about Direct Marketing Disclosures

Once a calendar year, you may be entitled to obtain information about personal information that we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information, as well as the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. To request a notice, please submit your request to Lucia.cs.jp@gmail.com.

F. Authorized Agent

You can designate an authorized agent to make a request under the CCPA on your behalf if:

• The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and

• You sign a written declaration that you authorize the authorized agent to act on your behalf.

If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please have the authorized agent take the following steps in addition to the steps described in subsections A, C and D above:

• Mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf to Suite 1113A, 11/F., Ocean Centre, Harbour City, 5 Canton Rd, Tsim Sha Tsui, Kowloon, Hong Kong; and

• Provide any information we request in our response to your email to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps, and we will respond to any request from such authorized agent in accordance with the CCPA.

Uruguay

In the Summary, the paragraph under _ How and for what purpose will we use the data about you? _should be amended as follows:

We use your data to provide the Game to you and to improve and administer it. We may also use your data to, among other things, improve and develop the Game and ensure your safety. You agree that we may also use your personal data to serve you targeted advertising and promote the Game and other products and services. You will be able to withdraw your consent at any time.

In Section 1 (The types of personal data we use), the paragraph under Surveys in ehavioral and Use Data, the following sentence will be added:

You will be able to exercise the right to block your personal data regarding advertising activities and withdraw your consent.

Under Section 6 (Your rights), the first paragraph is supplemented with the following additional rights:

You may have the following rights under applicable laws:

· Block right: You have the right to block your data from being processed for publicity or data profiling purposes, if we use your personal information for targeting, marketing,analytics and in general for advertising activities.

· The right to obtain from us the deletion of personal data concerning you and we maybe obliged to delete such personal data in case of harming the legitimate interests of third parties, manifest mistake and breach of a legal obligation;

Section 9 (Data relating to children) is amended as follows:

The Game is not directed at children under the age of 18 and we do not knowingly collect or solicit personal data from children under 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged big fat Privacy Policy and Terms of Use and agree to the use by your child of the game and registration for an account. Further, if you believe that we have personal data about or collected from a child under the relevant age, please contact us at Lucia.cs.jp@gmail.com and we will ensure that it is deleted.

Colombia

The introduction shall be amended as follows:

The following definitions shall be taken into account for Colombia:

a. Data Base: Organized set of personal data that is processed.

b. Personal Data: Any information linked or that can be associated to one or more determined or determinable persons.

c. Data Subject: all the individuals whose personal information is processed.

d. Sensitive Personal Data: Personal data that may affect Data Subjects privacy or give rise to discrimination, such as personal data associated with racial or ethnic origin, political orientation, religious or philosophical beliefs, membership of trade unions, social organizations, human rights or that promote the interests of any political party or that guarantee the rights and guarantees of opposition political parties, as well as data concerning health, sex life, and biometric data.

E. Consent: Prior, express and informed authorization granted by the Data Subject to carry out the processing of personal data.

F. Applicable Law: Law 1581 of 2012, Decree 1377 of 2013, Law 1266 of 2008 and other regulations that modify, add or repeal them.

g. Transfer: The transfer of data takes place when the Data Controller in charge of the processing of personal data, located in Colombia, sends the information or personal data to a recipient, who in turn is also a Data Controller for the processing of personal data and is inside or outside the country.

H. Transmission: Processing of personal data that implies the communication of the same within or outside the territory of the Republic of Colombia when the purpose is to carry out processing by a Data Processor on behalf of the Data Controller.

i. Processing: Any operation or set of operations on personal data, such as collection, storage, use, transmission, transfer or deletion.

J. Children or adolescent: person under the age of 18.

k. Data Access Request: Consults or Requests as mentioned in the Applicable Law.

The following shall be added to Section 1 (The types of personal data we use):

Sensitive Personal Data. We may collect your sensitive personal data (as defined), if you choose to register using your social network account details (e.g. Facebook, Twitter, Instagram, Google or Apple) and in the context of composing, sending, or receiving direct messages to and from other players, either directly on our websites and apps or to third party social media account and whether by words, voice, video or photos and your communications with us. Please note that according to Colombian law you may or may not consent to the processing of your sensitive personal data. However if you decide not to consent to the processing of your sensitive personal data big fat will not be able to fulfill the purposes described in Section 3 (How and for what purpose we use your personal data).

The following shall be deleted from Section 1 (The types of personal data we use) under the heading Message Boards and Chat Rooms

Any actions you perform with other players are considered public, and are solely at your discretion and you should have no expectation of privacy or confidentiality.

You should be aware that any personally identifiable data you submit in the course of these public activities can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages.

The following shall be added to Section 2 (Cookies):

We will only make use of Cookies to obtain and share your data if you provide your express consent. You may withdraw your consent at any time and such withdrawal shall not affect the lawfulness of the processing based on consent before its withdrawal.

The first paragraph of Section 6 (Your rights) shall be supplemented with the following rights under the Colombian Data Privacy Regime:

• The right to request for proof of the consent given for the processing of your personal data;

• The right to be informed, upon request, of the use that has been made of your personal data;

• The right to revoke your consent and/or request the deletion of the data when the processing does not respect the constitutional and legal principles, rights and guarantees; and

• All other rights established under applicable law.

The following shall be added to Section 6 (Your rights):

For Data Access Requests, we will have ten (10) business days from the business day following receipt of the Data Access Request to provide an answer. If big fat is unable to respond to your Data Access Request within that time period, big fat will advise you as Data Subject of the situation and explain the reason for the delay. In any event, we will respond to your Data Access Request within five (5) business days of the expiration of the first initial ten (10) day period.

In the case of complaints, we will answer them within fifteen (15) business days from the date the request or inquiry is received. The complaint shall be formulated by means of a request addressed to the Company, and shall include the identification of the Data Subject, description of the facts that give rise to the complaint, your address and supporting documents as attachments. If the complaint is incomplete, we may request that you supplement information as required within five (5) days of our receipt of the claim. After two (2) months from the date of the request, without your submitting the required information, your complaint will be deemed as withdrawn.

If it is not possible for us to respond to the complaint within the above-mentioned time limit, we will inform you of this situation and explain the reason for the delay. In any case, big fat will respond to you within eight (8) business days after the expiration of the initial fifteen (15) business days.

The following shall be added to Section 9 (Data relating to children):

The Game is not directed at children under the age of 18 and we do not knowingly collect or solicit personal data from children under 18. Nevertheless, in the case of children or adolescents above 14 but under the age of 18, parents or legal guardians must consent to the processing of personal data on their behalf. The processing of personal data of children and adolescents over the age of 14 will be carried out taking into account the rights described in Section 6 (Your rights) and respecting the rights established in the Colombian Constitution. Further, if you believe that we have personal data about or collected from a child under the relevant age, please contact us at Lucia.cs.jp@gmail.com and we will ensure that it is deleted.

The following shall be added to Section 10 (Complaints):

Complaints will be resolved following the same procedure established in Section 6 (Your rights).

Section 11(Changes) shall be amended as follows:

We will generally notify all users of any material changes to this policy, through a notice provided via the Game and providing any other notice required by applicable law. However, you should look at this privacy policy regularly to check for any changes. We will also update the Last Updated date at the top of this policy, which reflects the effective date of such policy. By accessing the Game, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it. Your continued access to or use of the Game after our notification to users of the updated policy constitutes your acceptance of the updated policy. If you do not agree to the updated policy, you must stop accessing or using the Game.

Argentina

The following sentence should be added to Section 1 (The types of personal data we use):

Personal data shall have the meaning set forth by the Argentina Data Protection Law No. 25,326, as amended (Law). The personal data we collect and process may include sensitive data, as defined by the Law, when permitted by applicable regulations. By accepting this Privacy Policy, you grant your consent for the collection and processing of sensitive data.

The following paragraphs should be inserted under Section 6 (Your rights):

big fat is responsible for the database where your personal data will be stored, domiciled at Singapore and the United States of America.

The Agencia de Acceso a la Información Pública (i.e. the Argentine Data Protection Authority) is the enforcement authority of the Law in Argentina.

The following sentence should be added to Section 8 (How long do we keep your personal data):

Your personal data will be destroyed or anonymized after the reasons to retain your personal data as referred to above no longer exist, and in accordance with this Privacy Policy or applicable laws.

Brazil

In the Summary under How will we notify you of any changes to this Privacy Policy?, the following sentence shall be deleted:

By accessing the Game, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it.

The following shall be added to Section 3 (How and for what purpose we use your personal data):

With your consent, we will use your data (including ad identifiers, age, region, gender, language, data related to your use of the Game and interactions with others, messages including content of the message and data about when the message has been sent, received and/or read, as well as the participants of the communication, username and public profile) to:

· Conduct surveys as outlined in the body section of this privacy policy including telling you about services and opportunities;

· Collect and process, which includes scanning and analyzing, data you provide in the context of composing, sending, or receiving messages through the Game messaging functionality. That data includes the content of the message and data about when the message has been sent, received and/or read, as well as the participants of the communication;

· Access posts to your social media walls, posts in your news feed and access your social network data at any time, including any of your favorite websites, friend data or fan pages and any other data included in your application, social network or online profile, even if you are not using the social network or you chose not to make that data public;

·Collect and process certain technical data, namely a list of installed packages and running apps or processes and third-party apps you have on your device; and

· Collect data about your location. In certain jurisdictions, with your permission, we will collect Global Positioning System (GPS) data and mobile device location data based on your SIM card;

·Find other users and invite your friends in your preferred social networks as outlined in the body section of this privacy policy and to show descriptions of your game activity and game profile to other players on the social network, regardless of whether they are your social network friends or not.

You may withdraw your consent at any time and such withdrawal shall not affect the lawfulness of the processing based on consent before its withdrawal.

In Section 6 (Your rights), the first paragraph is supplemented with the following additional rights:

You may have the following rights under applicable laws:

· The right to request anonymization, restriction of processing or erasure of personal data we process about you that is unnecessary, excessive or processed contrary to applicable law;

· The right to portability of your personal data to another service provider;

· The right to request erasure of personal data that we process based on your consent;

· The right to receive information about the public and private entities with which we share your personal data;

· The right to be advised about your choice not to give consent and the corresponding consequences;

· The right to revoke your consent;

· The right to lodge a complaint with the Brazilian Data Protection Authority;

· The right to oppose to processing of personal data that is not based on your consent in the event processing fails to comply with applicable law.

Section 9 (Data relating to children) is amended as follows:

The Game is not directed at children under the age of 16 and we do not knowingly collect or solicit personal data from children under 16. If you are 16 years of age or above but below the age of 18, you declare that you had the consent or assistance of your parent or legal guardian to use the Services and to agree to the big fat Privacy Policy and Terms of Use. Further, if you believe that we have personal data about or collected from a child under the relevant age, please contact us at Lucia.cs.jp@gmail.com and we will ensure that it is deleted.

In Section 11 (Changes), the following sentence shall be deleted:

By accessing the Game, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it.

Section 12 (Contact) is amended as follows:

The data protection officer for us can be contacted for questions, comments and requests regarding this policy as follows: Lucia.cs.jp@gmail.com.

MIDDLE EAST JURISDICTIONS

Bahrain

The following shall amend the first paragraph of Section 6 (Your Rights):

You may have the following rights under applicable laws:

· Right to request access to your personal data: You have the right to obtain from us confirmation as to whether or not personal data concerning you is processed, and, where that is the case, to request access to the personal data. The access information includes - inter alia - the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipient to whom the personal data have been or will be disclosed.

· You have the right to obtain a copy of the personal data undergoing processing free of charge.

· Right to request rectification: You have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

· Right to request erasure (right to be forgotten): You have the right to obtain from us the erasure of personal data concerning you and we may be obliged to erase such personal data.

· Right to request restriction of processing: You have the right to obtain from us that we restrict the processing of your personal data. In this case, the respective data will be marked and may only be processed by us for certain purposes.

· Right to data portability: Where processing of your personal data is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, you have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format or to have your personal data transmitted directly to another company, where technically feasible;

·Right to withdraw consent: Where the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time without impact to data processing activities that have taken place before such withdrawal;

·Automatic decision making: You have the right not to be subject to any automatic individual decisions, including profiling, which produces legal effects on you or similarly significantly affects you.

·Right to Object: You have the right to object to processing if we are processing your personal data on the basis of our legitimate interest unless we can demonstrate compelling legitimate grounds which may override your right. If you object to such processing, we ask you to state the grounds of your objection in order for us to examine the processing of your personal data and to balance our legitimate interest in processing and your objection to this processing; and

·Right to complaint: You have the right to lodge complaints before the competent data protection authority.

Section 9 (Information relating to children) shall be replaced with the following:

The Game is not directed at children under the age of 18 and we do not knowingly collect or solicit personal data from children under 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged big fat Privacy Policy and Terms of Use and agree to the use by your child of the game and registration for an account. Further, if you believe that we have personal data about or collected from a child under the relevant age, please contact us at Lucia.cs.jp@gmail.com and we will ensure that it is deleted.

Israel

In the Summary, under How will we notify you of any changes to this Privacy Policy?, the sentence …you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it, shall be deleted, and replaced inits entirely with the following:

…you agree to the terms of this privacy policy

In Section 1 (The types of personal data we use), the first paragraph (before the words We collect and use…) shall be amended in its entirely, as follows:

Unless otherwise stated in this policy, the personal data we collect from you or about you is required so that we can perform our contract with you to provide the Game to you as detailed in our Terms of Service. While you are not legally obliged to provide us with your personal data, the provision of certain data is mandatory for the purposes of your access to the Game. Therefore, should you choose to refrain from providing us with certain categories of personal data, as we may require, we may not be able to grant you access to the Game, and/or you may not be able to set-up an account and/or, we will not be able to provide certain aspects of the Game or certain functionalities may be lost. For example, if you do not provide your age data for account set up purposes, we will not be able to grant you access to the Game. If you do not provide your location data, we may not be able to provide certain aspects of the Game service or certain functionalities may be lost. However, you have control over certain kinds of personal data that you can choose to share or to withhold from us, and still be able access the Game, as detailed in this policy. In any event, if you choose to provide us with any categories of personal data, you do so of your own free will and consent

In Section 1 (Data You Provide to Us, Including Your Profile Data), the following sentence shall be added after the first paragraph:

Whenever you provide us personal data pertaining your friends, social contacts or any other third party, for any purpose (including, without limitation, when you interact with other players, invite a friend to play the Game, etc.), you are obliged to obtain all necessary and applicable consents from your friends, social contacts or such other third parties, for the transfer of their personal data to us.

In Section 3, (How and for what purpose we use your data), the following shall be added:

With your consent, we will use your data (including ad identifiers, age, religion, gender, language, data related to your use of the Game and interactions with others, messages including content of the message and data about when the message has been sent, received and/or read, as well as the participants of the communication, username and public profile) to:

In Section 5 (International data transfers), after the sentence The personal data that we collect from you may be transferred to, and stored at, or otherwise processed in a destination outside of your jurisdiction of residence, the following shall be added:

…, including in jurisdictions which provide a different level of data security and protection than as provided under Israeli law.

In Section 6 (Your Rights), the first paragraph (before the words Before we can respond to a request to exercise one or more of the rights listed above …) shall be amended as follows:

Please note that an Israeli data subject, may have the following rights regarding his/her personal data under Israeli law:

(i) The right to request access to the personal data we hold about you, subject to Israeli law;

(ii) The right to request to rectify or delete your personal data where it is inaccurate, incomplete, unclear or outdated; and

(iii) The right to object to our use of your personal data for direct mailing purposes (this is applicable when we engage and advertise to you with content based on your belonging to a group of the population that is determined by one or more characteristics, or to restrict the use of your personal data for direct mailing services).

Section 9 (Data relating to children) shall be replaced with the following:

We not do not knowingly collect or solicit personal data from children under 18 for prohibited purposes under applicable Israeli law. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged big fat Privacy Policy and Terms of Use and agree to the use by your child of the game and registration for an account. Further, if you believe that we have personal data about or collected from a child under the relevant age, please contact us at Lucia.cs.jp@gmail.com and we will ensure that it is deleted.

Qatar

The following shall replace the first paragraph of Section 6 (Your Rights):

You have the right at any time to access your personal data and, in particular to:

1- Have us notify you of the processing of your personal data and the purposes for which such processing is conducted and to notify you of any disclosure of inaccurate personal data, subject in each case to any restriction which arises in the relevant circumstances under the applicable law;

2- Obtain a copy of your personal data held by us upon payment of the service fee;

3- Withdraw your consent to the processing of your personal data subject to any overriding requirement of applicable law and provided that such withdrawal shall not affect the lawfulness of the processing based on consent before its withdrawal;

4- Object to the processing of your personal data if that is found to be unnecessary to achieve the purposes for which it was collected or if it is in excess of the requirements, discriminatory, unfair or against the law;

5- Request the deletion or erasure of your personal data in cases 3 and 4 referred to above or upon the achieving of the purpose for which it was processed or if there is no reason for us to keep it; and

6- Request the correction of your personal data, subject to you providing us with reasonable evidence as to the validity of your request.

Section 9 (Information relating to children) shall be replaced with the following:

We do not knowingly collect or solicit personal data from children under 18. If you believe that we have received personal data about or collected personal data from your child, please contact us at Lucia.cs.jp@gmail.com and we will ensure that it is deleted.

Section 10 (Complaints) shall be replaced as follows:

In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at Lucia.cs.jp@gmail.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the relevant data protection authority.

Turkey

Section 2 (Cookies) shall include the following:

We will only make use of non-essential Cookies to obtain and share your data if you provide your explicit consent. You may withdraw your consent at any time and such withdrawal shall not affect the lawfulness of the processing based on consent before its withdrawal.

Section 3 (How we use your data) shall include the following:

Based on Article 5(1) of the Turkish Data Protection Law, with your consent, we will use your data (including ad identifiers, age, region, gender, language, data related to your use of the Game and interactions with others, messages including content of the message and data about when the message has been sent, received and/or read, as well as the participants of the communication, username and public profile) to:

You may withdraw your consent at any time and such withdrawal shall not affect the lawfulness of the processing based on consent before its withdrawal.

References in this policy to the performance of contract as a legal basis refers to the legal basis under Article 5(2)(c) of the Turkish Data Protection Law, where the processing of your personal data is necessary for and directly related to the establishment and/or performance of our contract with you.

References in this policy to our legal obligations or legal requirements as a legal basis refers to the legal basis under Article 5(2)(ç) of the Turkish Data Protection Law, where the processing of your personal data is mandatory for compliance with our legal obligations under applicable laws; and/or Article 5(2)(a) of the Turkish Data Protection Law, where the processing is expressly laid down in laws.

References in this policy to our legitimate interests or legitimate business purposesas a legal basis refers to the legal basis under Article 5(2)(f) of the Turkish Data Protection Law, where the processing of your personal data is mandatory for our legitimate interests, provided that it does not violate your fundamental rights and freedoms.

References in this policy to the establishment, exercise or defense of legal claims refers to the legal basis under Article 5(2)(e) of the Turkish Data Protection Law, where the processing of your personal data is mandatory for the establishment, exercise or defense of a legal claim.

Section 6 (Your rights) shall be amended as follows:

You have the following rights with respect to your personal data:

Please send an e-mail toLucia.cs.jp@gmail.com if you would like to exercise any of your rights. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

We will respond to your request as soon as possible according to the nature of your request and within thirty days at the latest, free of charge. However, if your request incurs additional cost to us, then you may be charged over the tariff fee determined by the Turkish Personal Data Protection Board.

Section 9 (Data relating to children) shall be replaced with the following:

The Game is not directed at children under the age of 18 and we do not knowingly collect or solicit personal data from children under 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged big fat Privacy Policy and Terms of Use and agree to the use by your child of the game and registration for an account. Further, if you believe that we have personal data about or collected from a child under the relevant age, please contact us at Lucia.cs.jp@gmail.com and we will ensure that it is deleted.

Section 11 (Changes) is modified to delete the sentence:

Your continued access to or use of the Game after the date of the updated policy constitutes your acceptance of the updated policy.

United Arab Emirates

In the Summary under _ How and for what purpose will we use the data about you? _, amend the last sentence as follows:

We may also use your personal data to serve you targeted advertising and promote the Game and other products and services (in each case, if required under applicable law or where we otherwise deem it to be necessary, where we have your consent).

Under the heading Surveys in Section 1 (The types of personal data we use), amend the paragraph as follows:

We collect data through surveys, challenges and competitions in which you may participate including gender, likeness, age and preferences.We also infer your preferences, including your interests, gender and age for the purpose of serving personalized advertising (with your consent, if required under applicable law or where we otherwise deem it to be necessary). We will also process your personal data in order to tell you about services and opportunities.

Under heading Analytics and Performance Cookies in Section 2 (Cookies), amend the last sentence of the paragraph as follows:

We also use third-party analytics tools to help us measure traffic and usage trends for the Services (with your consent if required under applicable law or where we otherwise deem it to be necessary).

Under heading Targeting or Advertising Cookies in Section 2 (Cookies), amend the paragraphs as follows:

Analytics: As you use the Game, you will notice that it features advertising. We allow third party companies, including advertising companies, to place Cookies in the Game to track the performance of our advertisements (with your consent if required under applicable law or where we otherwise deem it to be necessary). As an example, these Cookies remember which users have used the Game. The information provided to third parties does not include personal information but it may be associated with personal information after we receive it.

Marketing: We may also (with your permission, where required under applicable law) contract with third-party advertising networks that collect IP addresses and other information from the Game, from third party websites and apps. Ad networks follow your online activities and collect information through automated means (such as through the use of Cookies, again, with your consent, if required under applicable law or where we otherwise deem it to be necessary). Ad networks use this information, mainly to serve adverts about products and services that are likely to interest you. We may also partner with third parties to provide certain features in the Game or display advertising based on your web browsing activity. We may also use information from one device to help personalize your experience on another device. For advertising purposes, we may collect your Google Ad ID, Android Ad ID or (where applicable) your IDFA (IDFAs take the place of Cookies in mobile advertising delivered to iOS devices).