Hello, our dear friends and players!

Welcome to OPTIFLOW LUDUS LABS LTD. (that's "us" from here on out). When you explore the wondrous worlds we create, build your dream home, or share joy with fellow members of our community, you give us the most precious gift of all—your trust. This "Privacy Promise" is our response to that trust.

We know that your personal information is a part of your "secret garden"—sacred and private. It is our core belief and undeniable responsibility to protect your secret garden. This promise will explain, in the most candid and clear way possible, how, why, and under what circumstances we carefully interact with some of the information from your garden. This is not a cold legal document, but a sincere dialogue between us about respect and protection.

Please take some time to read this promise carefully. Understanding how we protect your data is an important right you have as a member of our community. When you use any of our games, websites, or services (collectively, "Our Services"), you signify that you have understood and agreed to the practices described in this promise.

This promise is a vital part of "Our Pact" with you (our Terms of Use). They complement each other and together form the foundation upon which our harmonious community operates.

1. Our Guiding Principles for Protection

Before diving into the details, we want to share the four golden rules we follow when handling your information. These four principles are the starting point and code of conduct for all our privacy work:

Principle One: Purposeful and Minimal. We do not collect information arbitrarily. For every piece of data we collect, there is a clear and reasonable purpose behind it—to make your gaming experience smoother, more fun, and more secure. We only acquire the minimum amount of information necessary to achieve these purposes.

Principle Two: Experience First, Service to You. The ultimate reason we use your information is to provide you with a better service. Whether it's saving your game progress, fixing annoying bugs, or recommending activities you might be interested in, our goal is always to enhance your happiness.

Principle Three: Security is Paramount. We treat your data security as our lifeline. We employ industry-standard technical and administrative measures, like building high walls and posting sentinels around your secret garden, to do everything in our power to prevent unauthorized access, disclosure, alteration, or loss.

Principle Four: You are the Master. Your data, your rules. We believe in the power of transparency and provide you with clear paths to access, correct, and delete your information, as well as manage your privacy preferences. You are, and always will be, the master of your own secret garden.

2. The Information We Interact With

To keep our magical worlds running, we need to interact with a few types of information. Below, we'll explain what they are and why we need them.

2.1 The Little Notes You Hand Us (Information You Provide Directly)

When you interact with Our Services, some information is shared with us by you, directly.

Account Creation Information: When you create your "Explorer's Account," you will choose a unique nickname (username) and set a password. We may also ask for an email address.

·Why do we need this? Your nickname is your identity in our worlds, allowing other players to recognize you. The password (which is encrypted) is the key to protecting your account. The email address is very important; it's the channel for you to reset your password if you forget it, and it's how we send you important service notifications (like updates to our terms) or, with your consent, community newsletters.

Communication Information: When you contact our "Community Guards" (customer support team) for help, whether to report a problem or offer a suggestion, you will provide us with your account information and a detailed description of the issue. All correspondence between you and us (including emails or in-app support tickets) may be saved.

·Why do we need this? This helps us to accurately understand the problem you're facing, track its resolution, and ensure your issue is resolved to your satisfaction. These records also help us identify potential problems with Our Services so we can improve them.

Community Interaction Information: Any content you post on our forums, in chat channels, or on our social media pages, such as your game guides, replies to other players, or screenshots you share.

·Why do we need this? This is part of the community ecosystem, allowing players to communicate and share. But please remember, this information is public, so please do not share any of your private, sensitive information here.

Other Information You Voluntarily Provide: Sometimes, we may invite you to participate in surveys or market research to understand your opinions about our games. Participation is completely voluntary.

·Why do we need this? Your feedback is crucial to us. It directly helps us design game features and events that are more popular with everyone.

2.2 The "Travel Log" We Automatically Collect During Your Adventures (Information We Collect Automatically)

As you immerse yourself in our games, our systems automatically record some technical and behavioral information. Think of it as an automatically generated travel log that documents your adventures.

Device Information: We collect information about the device you use, such as the device model, operating system version, unique device identifiers (like IDFA or Android Advertising ID), language settings, and approximate geographic location (usually based on your IP address and only precise to the country or city level).

·Why do we need this? This is critically important. Understanding your device helps us optimize game performance and ensure the graphics are perfectly adapted to your screen. It also helps us locate and fix bugs that only appear on specific devices or systems. Approximate location helps us provide localized content (like events for local holidays) and comply with regional laws.

In-Game Behavioral Data: We record your actions within the game, such as your game progress, level, achievements earned, how often you interact with certain game features, the in-game treasures (virtual items) you possess, the time you spend on specific levels, and in-game crash logs.

·Why do we need this? This is the core basis for our game improvements. By analyzing this anonymized and aggregated data, we can understand which levels are too hard or too easy and which features are most popular, allowing us to make balance adjustments and content updates. Crash logs help our engineers quickly locate and fix the "gremlins" that cause the game to crash.

Network and Connection Information: We collect your IP address and network type (e.g., WiFi or cellular).

·Why do we need this? Your IP address helps us determine your approximate geographic location and is used for security purposes (like identifying unusual login activity). Knowing your network type helps us optimize data transfer and reduce your data consumption when you're on a mobile network.

2.3 "Messenger Intelligence" from Our Partners (Information We Receive from Third Parties)

Sometimes, we also receive some information about you from our partners.

Third-Party Platform Login Information: If you choose to use a third-party service (like Apple Game Center, Google Play Games, or Facebook) to log into our games, that platform will share some of your basic public profile information with us, according to your authorization, such as your nickname and a unique platform ID.

·Why do we need this? This provides you with a convenient way to log in without having to remember an extra set of credentials. It also helps you easily sync your game progress across different devices. We will never receive your password for these third-party platforms.

Payment Processing Information: When you make a purchase in our games, you are transacting directly with a third-party payment platform (like the Apple App Store or Google Play Store). We do not collect or store any of your financial information, such as credit card numbers or bank accounts. The payment platform only sends us a confirmation notice that a purchase of a specific amount has been successfully completed, so we can deliver the corresponding in-game treasures to your account.

·Why do we need this? This is to fulfill your purchase request and to keep a necessary record of the transaction in case you have inquiries or need after-sales support.

Advertising and Analytics Partner Information: We work with partners who help us promote our games elsewhere or analyze the effectiveness of our own advertising. They may share some aggregated, non-personally identifiable information with us, such as how many game downloads a particular ad generated.

·Why do we need this? This helps us evaluate whether our marketing campaigns are effective and allows us to invest our resources in channels that our players are genuinely interested in.

2.4 "Memory Crystals" and Similar Technologies (Cookies & Similar Technologies)

Our websites and some of Our Services may use Cookies (small text files stored in your browser) and similar technologies (like pixel tags or web beacons). You can think of a Cookie as a "memory crystal."

What do they do?

·Essential Crystals: These are fundamental to the operation of a website. For example, when you log into our forum, a crystal remembers your login status so you don't have to log in again on every page.

·Performance Crystals: These help us understand how our website is being used. For example, they tell us which pages are visited most and how long users stay on them. This information is anonymous and helps us optimize the site's structure and performance.

·Functionality Crystals: These remember your preferences, like the language you've selected, to provide you with a more personalized experience.

·Advertising Crystals: We and our advertising partners may use these crystals to show you ads related to our games that may be of interest to you when you visit other websites. They work by identifying your browser, but they do not store your direct personal information.

How to manage these crystals? Most browsers allow you to view, manage, delete, and block Cookies. Please note that if you disable all Cookies, especially essential ones, some features of our website may not function correctly.

3. How We Use This Information to Work Our "Magic"

The ultimate purpose of collecting information is to work the "magic" that makes your experience better. Specifically, this includes:

Operating and Maintaining Our Services:

·Creating and managing your account.

·Syncing your game progress across your different devices.

·Providing the game features and content you request.

·Processing your purchase transactions.

Improving and Optimizing Your Experience:

·Analyzing player behavior to improve game design, balance, and fun.

·Fixing technical issues, bugs, and game crashes.

·Developing new games, features, and events.

·Providing you with more personalized content and recommendations (with your consent).

Providing You with Support and Protection:

·Responding to your questions and requests and providing customer service.

·Sending you important service-related notifications (such as security alerts or changes to our terms).

·Maintaining the safety and fairness of our community by detecting and combating cheating, fraud, and violations of our Community Covenant.

Staying in Touch with You (with Your Consent):

·Sending you community news, event information, and special offers that may interest you. You can unsubscribe at any time via the link in the emails.

·Managing and delivering personalized advertising to support the operation of our free-to-play games. We will provide you with options to opt out of personalized ads.

4. Our Sharing Principles: Who Might See Your Information?

We solemnly promise that we will never sell your personal information. We will only share information with our trusted partners in the following limited and necessary circumstances, or as required by law.

Service-Providing Partners: We work with top-tier third-party service providers who give us the technical support we need to operate.

·Cloud Storage and Server Providers (e.g., Amazon Web Services, Google Cloud): Your game data is securely stored on their servers.

·Data Analytics Providers (e.g., Google Analytics for Firebase): They help us process and analyze anonymous gameplay data.

·Customer Support Platforms (e.g., Zendesk): Their tools help us efficiently manage and respond to your support requests.

We have strict data processing agreements with all these partners, requiring them to use your information only for the purpose of providing services to us and to implement security measures no less stringent than our own to protect your data.

Other Players: Part of the fun of gaming is social interaction. Therefore, your public information, such as your game nickname, avatar, guild information, leaderboard rankings, and messages in public chats, will be visible to other players in the community.

Advertising Partners: To keep our free-to-play games running, we may work with ad networks to show you ads in the game. We typically share your advertising identifier (IDFA/Android Ad ID) and some technical information (like device type and language) with them so they can serve you more relevant ads. We will provide you with the option to opt out of personalized advertising.

Legal Requirements and Corporate Restructuring:

·Compliance with Legal Obligations: If we receive a legally binding request (such as a subpoena or an order from a government agency), we may disclose your information to the extent required by law.

·Protection of Legitimate Interests: We may also share information when necessary to protect the rights, property, or safety of us, our users, or the public.

·Corporate Transactions: If we undergo a major corporate transaction in the future, such as a merger, acquisition, restructuring, or sale of assets, your information may be transferred as part of that transaction to the new corporate entity. In such a case, we will notify you via an announcement or other means and ensure that the new entity continues to abide by this promise or provides you with a new privacy policy to review.

5. Your Rights: You are the Master of Your Secret Garden

We firmly believe that your control over your own information is paramount. Depending on the laws of your region, you may have one or more of the following rights:

The Right to Access: You have the right to request a copy of the personal information we hold about you.

The Right to Rectification: If you find that the information we hold about you is inaccurate or incomplete, you have the right to ask us to correct it.

The Right to Erasure ("Right to be Forgotten"): In certain circumstances (for example, if you decide to close your account), you have the right to request that we delete your personal information. Please note that we may need to retain archived copies of some information for legal or compliance reasons.

The Right to Restrict Processing: Under specific conditions, you have the right to request that we temporarily halt the processing of your personal information.

The Right to Object: You have the right to object to our processing of your personal information that is based on our legitimate interests. You also always have the right to object to our use of your information for direct marketing purposes.

The Right to Data Portability: Where technically feasible, you have the right to request that we provide some of your data to you in a structured, commonly used, and machine-readable format, or to transmit it directly to another service provider.

How to exercise your rights?

The most direct way to exercise these rights is to contact our "Community Guards" (customer support team) at [email protected]. To protect your account, we may need to verify your identity before processing your request. We will do our best to respond to all legitimate requests within a reasonable timeframe.

6. Our Protective Measures: How Do We Guard Your Garden?

We employ a range of industry-standard security measures to protect your information from unauthorized access, loss, or misuse.

Technical Measures: We use encryption technologies (like SSL/TLS) to protect data during transmission. For sensitive information stored at rest (like passwords), we use hashing and encryption.

Organizational Measures: We have established strict internal data access control policies. Only employees who need to access this information for their job duties are granted limited access, and they have all received training on data security and privacy protection.

Risk Acknowledgment: Despite our immense efforts, please understand that no network transmission or storage system is 100% secure. We cannot absolutely guarantee that your information will never be breached. However, we promise that in the event of any data security incident, we will immediately activate our emergency response plan and, as required by law, promptly inform you and report to the relevant regulatory authorities.

7. Data Retention: How Long Do We Keep Watch?

We will only retain your personal information for as long as necessary to fulfill the purposes described in this promise, unless a longer retention period is required or permitted by law. Generally, as long as your account is active, we will retain your account information and game data to provide you with continuous service.

When you delete your account or when we no longer need your information to provide services, we will take steps to securely delete your information or anonymize it so that it can no longer be associated with you personally.

8. A Special Note for Young Explorers: Children's Privacy

We care deeply about the well-being of our younger players. Our Services are not directed to children under the age of legal consent (for example, 13 in some regions, 16 in others). We do not knowingly collect personal information from these children.

If you are a parent or guardian and you discover that your child has provided us with personal information without your consent, please contact us immediately at [email protected]. Upon verification, we will take immediate steps to delete the relevant information.

9. A Journey Across Mountains and Seas: International Data Transfers

We are a global company, and our services and partners are located all over the world. This means your information may be transferred to, processed, and stored in regions outside of your home country, where the data protection laws may differ from those in your country.

Rest assured, no matter where your information is transferred, we will ensure it receives an equivalent level of protection. We rely on legally recognized mechanisms, such as entering into data processing agreements with our partners that include Standard Contractual Clauses, to ensure your data remains secure during cross-border transfers.

10. Updates to Our Promise

As Our Services evolve or as laws and regulations change, we may occasionally update this Privacy Promise. When we make significant changes, we will notify you in advance by posting an announcement on our website, sending an in-game notification, or sending you an email. We will also update the "Last Updated" date at the top of this promise.

We encourage you to check this promise periodically to stay informed about our latest privacy practices.

11. How to Contact Us

If you have any questions, comments, or concerns about this Privacy Promise, or if you wish to exercise any of your privacy rights, please do not hesitate to contact our dedicated privacy team at:

OPTIFLOW LUDUS LABS LTD.

41 DEVONSHIRE STREET GROUND FLOOR OFFICE 1 LONDON UNITED KINGDOM W1G 7AJ

[email protected]

Thank you for patiently reading this promise. Your trust is the greatest motivation for our journey forward. Now, let's get back to the game and continue having a wonderful, carefree time.