TERMS OF SERVICE

END USER LICENSE AGREEMENT
ISSUED BY FIRST TOUCH GAMES LIMITED (“FIRST TOUCH”, or “we” or “us”).

Last updated 16 January 2018
THIS END USER LICENSE AGREEMENT (“EULA”) APPLIES TO AND GOVERNS ALL USE OF SCORE! MATCH, DREAM LEAGUE SOCCER AND SCORE! HERO (EACH A “GAME” AND TOGETHER THE “GAMES”).

PLEASE READ THE FOLLOWING CAREFULLY BEFORE USING, DOWNLOADING, PURCHASING OR INSTALLING ANY OF THE GAMES (WHICH INCLUDES ANY VIRTUAL ITEMS AND THE RELATED ONLINE SERVICE). BY DOWNLOADING OR USING ANY OF THE GAMES YOU ARE AGREEING TO BE BOUND BY AND BECOME A PARTY TO THIS EULA AND OUR PRIVACY POLICY WHICH CAN BE FOUND ON OUR WEBSITE HERE. IF YOU DO NOT AGREE WITH THE TERMS OF THIS EULA, YOU MAY NOT USE, DOWNLOAD OR INSTALL ANY OF THE GAMES.

This EULA constitutes the entire agreement between First Touch and you in respect of the Games.

First Touch Games Limited is a company registered in England and Wales under company number 07638595 and with our registered office at 264 Banbury Road, Oxford, OX2 7DY. If you have any queries concerning this EULA you may contact us at support@ftgames.com.

SCORE! MATCH (“Score! Match”), DREAM LEAGUE SOCCER (“Dream League Soccer”) and SCORE! HERO (“Score! Hero”) are all games owned by First Touch. The terms “Score! Match”, “Dream League Soccer”, “Score! Hero” and the “Games” includes all the software and materials that are made available by First Touch in order for you to download, install or use the Games; any Online Service (defined below); and any Virtual Items (defined below).

Please note that the Games rely on internet connectivity and the availability of our Online Service (as explained further below) for much of its functionality. We will use our reasonable efforts to ensure that the Games and any Online Service will be available for at least 3 months from the date upon which you last make a purchase in connection with any of the Games.

You are responsible for ensuring that you have an internet connection and that the device you use has sufficient system requirements and memory in order to play and store the Games.

The Games comprise copyright works of First Touch and/or its licensors. The Games are licensed, not sold. Your license confers no title or ownership in the Games. The Games are solely for use by end users according to the terms of this EULA. Any use, reproduction or redistribution of the Games not in accordance with the terms of this EULA is expressly prohibited.

1. LIMITED USE LICENSE.
First Touch hereby grants a limited, non-exclusive right and license to download, install and use the Games for your personal, non-commercial use only on compatible devices that are owned by you, subject to the terms of this EULA. This EULA and your use of the Games do not give you any rights of ownership in any property whether tangible or intangible (including in any Virtual Item). Where a Game allows you to, this licence includes the right to use the Game to communicate with other users of that Game using the Online Service via pre-determined messages only.

2. END USER OBLIGATIONS.
2.1 You may use the Games for your own personal, non-commercial use as described in this EULA but you are not entitled to and must not do any of the following except to the extent expressly permitted by this EULA:
2.1.1 sell, copy, reproduce, translate, communicate, reverse engineer, publish, stream, distribute, rent, loan, sub-licence, derive source code from, modify, adapt, merge, disassemble, decompile, create derivative works based on or otherwise transfer or deal in copies or reproductions of the Games or any part or interest in it to other parties in any way except where a Game expressly permits you to do so through sharing content in that Game on social media;
2.1.2 engage in any act that First Touch deems to be in conflict with the spirit or intent of the Games and/or the Online Service including without limitation using cheats, exploits, automation software, bots, hacks, mods or any unauthorised third-party software designed to modify or interfere with the Games;
2.1.3 attempt to gain unauthorised access to the Online Service or to the computers, devices, servers, or networks connected to the Online Service by any means other than the user interface provided by First Touch; or
2.1.4 use the Games for any illegal or immoral purposes.

3. OWNERSHIP.
3.1 All right, title, interest and ownership rights in the Games and any copyright, design right, database right, patents and any rights to inventions, know-how, trade and business names, trade secrets and trade marks (whether registered or unregistered) and any applications therefor and other intellectual property rights (“Intellectual Property Rights”), in or connected with the Games and each part thereof (including by way of example only any titles, code, themes, objects, concepts, artworks, animations, audio-visual effects and methods of operation) and any copies, translations, modifications, adaptations and any other derivative based on the Games are owned by, belong to and vest in First Touch or its licensors.
3.2 The Games may contain certain licensed materials. All trade marks are the property of their respective owners.

4. TERMINATION.
4.1 This EULA and the licence granted by it are effective until terminated.
4.2 You may terminate this EULA at any time and for any reason by deleting and removing the Games from your device.
4.3 First Touch may terminate this EULA if you fail to abide by any of the terms and conditions of this EULA at any time and for any reason or we reasonably suspect that you have failed to abide by any of the terms and conditions of this EULA. First Touch may take any action it deems reasonable in its sole discretion against users who do not comply with the terms of this EULA, which may include banning users from any of the Games. First Touch reserves the right to determine what conduct it considers to be in violation of, or otherwise outside the intent or spirit of, this EULA and/or the Games and/or Online Service. However, if what you have done can be put right we will give you a reasonable opportunity to do so.
4.4 Following termination, you will no longer be permitted to use any of the Games and you will be required to delete the Games from your device.

5. WARRANTY AND LIMITATION OF LIABILITY.
5.1 FIRST TOUCH WARRANTS THAT IT HAS USED AND WILL USE REASONABLE EFFORTS TO ENSURE THAT:
5.1.1 IT IS ENTITLED TO GRANT THE RIGHTS AND LICENCES GRANTED HEREUNDER; AND
5.1.2 THE GAMES (INCLUDING ANY VIRTUAL ITEMS) WILL BE OF SATISFACTORY QUALITY.
5.2 EXCEPT AS SPECIFICALLY PROVIDED IN THIS EULA AND TO THE MAXIMUM EXTENT PERMITTED BY LAW:
5.2.1 THE GAMES ARE PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS WITHOUT WARRANTY OR GUARANTEE OF ANY KIND (EXPRESS OR IMPLIED) OTHER THAN THOSE SET OUT IN THIS EULA;
5.2.2 FIRST TOUCH ONLY ACCEPTS LIABILITY FOR DIRECT LOSS AS A RESULT OF ITS BREACH OF ITS WARRANTIES IN CLAUSE 5.1 ABOVE UNLESS OTHERWISE SET OUT IN THIS EULA;
5.2.3 FIRST TOUCH AND ITS LICENSORS’ MAXIMUM LIABILITY WILL BE LIMITED TO £100;
5.2.4 FIRST TOUCH AND ITS LICENSORS WILL NOT IN ANY EVENT BE LIABLE IN ANY WAY FOR ANY CONSEQUENTIAL OR INDIRECT LOSS OR DAMAGE (SAVE TO THE EXTENT THAT DAMAGE TO YOUR DEVICE OR OTHER DIGITAL CONTENT WHICH YOU OWN IS CAUSED BY THE GAMES AS A RESULT OF OUR FAILURE TO USE REASONABLE CARE AND SKILL IN WHICH CASE YOU MAY BE ENTITLED TO COMPENSATION OR WE MAY BE OBLIGED TO REPAIR YOUR DEVICE);
5.2.5 FIRST TOUCH DOES NOT GUARANTEE THAT THE OPERATION OF THE GAMES WILL BE UNINTERRUPTED OR ERROR FREE OR THAT ERRORS CAN OR WILL BE CORRECTED, OR THAT THE GAMES OR THE ONLINE SERVICE ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS;
5.2.6 YOU INSTALL AND USE THE GAMES AT YOUR OWN RISK.
5.3 THIS EULA SHALL NOT LIMIT ANY RIGHTS YOU MIGHT HAVE AS A CONSUMER THAT MAY NOT BE EXCLUDED UNDER APPLICABLE LAW NOR SHALL IT EXCLUDE OR LIMIT ANY LIABILITY FOR FRAUD, FRAUDULENT MISREPRESENTATION, OR DEATH OR PERSONAL INJURY CAUSED BY FIRST TOUCH’S NEGLIGENCE.

6. SEVERABILITY.
In the event that any provision of this EULA (including, without limitation, any restriction) shall be held by a court or other tribunal of competent jurisdiction to be unenforceable, such provision will be enforced to the maximum extent permissible and the remaining portions of this EULA shall remain in full force and effect.

7. APPLICABLE LAW AND JURISDICTION.
7.1 This EULA and any dispute or claim arising out of or in connection with it or its subject matter or formation shall be governed by and construed in accordance with the law of England and Wales and the courts of England and Wales shall have exclusive jurisdiction to settle any dispute or claim.

8. ONLINE SERVICE.
8.1 First Touch provides and maintains certain online functionality, online network play connectivity and interactivity and other online features relating to the Games (“Online Service“) subject to the terms and conditions of this EULA.

Age Restrictions.
8.2 First Touch does not target the Games to users under 13 years of age. To use the Online Service you must be over the age of 13 years or have your parent’s or guardian’s explicit consent to do so on these terms. By using the Online Service you therefore confirm that you are over 13 years of age and, where you are between the ages of 13 and 17, you confirm that you have your parent’s or guardian’s consent (and that your parent or guardian has read and agreed to these terms).

User Rules.
8.3 You further agree that you will not in any way conduct yourself in a manner which is unlawful or which gives rise to civil or criminal liability or which might call into disrepute First Touch or the Games.
8.4 Where a Game allows you to share pre-determined messages with other users, First Touch shall be entitled to remove, restrict, suspend or alter that ability for any reason in its sole and absolute discretion.
8.5 You will cooperate fully with First Touch to investigate any suspected unlawful, fraudulent or improper activity.
8.6 If you feel that the behaviour of another user breaches this EULA then please let First Touch know by sending an email to support@ftgames.com with details of the potential breach and/or the user responsible. First Touch will take reasonable steps to deal with any breach.

9. VIRTUAL ITEMS.
9.1 As part of and to enhance your use and enjoyment of the Games you may be able to obtain additional features that form part of the experience of the Games (“Virtual Items”).
9.2 Virtual Items include (without limitation):
9.2.1 Gems, which can be purchased as described in the payment section of Score! Match or obtained for free as a reward for your playing Score! Match (including watching incentivised video adverts);
9.2.2 Bux, which can be purchased as described in the payment section of Score! Hero or obtained for free as a reward for your playing Score! Hero or Score! Match (including watching incentivised video adverts), or by exchanging Gems that you have purchased in Score! Match;
9.2.3 Coins, which can be purchased as described in the payment section of Dream League Soccer or obtained free of charge as part of and as a result of your playing Dream League Soccer (including watching incentivised video adverts); and
9.2.4 Any other additional features contained in the Games such as power ups which can be obtained free of charge as part of and as a result of your playing the Games or by exchanging Gems and/or Bux and/or Coins.
9.3 Virtual Items are gameplay features of the Games, they have no cash or real world value, they are not redeemable or exchangeable for anything with a real world value and they can be used as part of the Games only, in accordance with this EULA.
9.4 Purchases of Virtual Items are subject to this EULA and the terms of any third party app distribution platform through which your purchase is made. Purchases are made via Apple, Google or Amazon and not via First Touch. To the extent that this EULA conflicts with such agreement between you and the relevant third party in respect of any purchase of Virtual Items, the terms of your agreement with the third party app distribution platform shall prevail.
9.5 To cancel a purchase of any Virtual Items (such as Gems or Coins) you should contact the platform through which you made that purchase. If you cannot use Gems or Coins due to an error or fault, you may still be charged. If this happens, please contact First Touch as set out below and we will endeavour to rectify the issue and if we are unable to do so you may be entitled to a refund via the platform through which you made that purchase (i.e. Google, Apple or Amazon).
9.6 Virtual Items that may be purchased (either through Google, Apple or Amazon) are advertised for sale in the Game so that you may offer to purchase them for the price stated in the manner described below.
9.7 It is a condition and fundamental term of this EULA and your use of the Games that you may not and must not buy, sell, barter, swap, exchange, trade, lend, rent or otherwise deal in any way with any aspect of the Games (including any third party account you use in relation to the Games) or any Virtual Item (including Gems and Coins) outside of the Games or in any way other than as expressly provided above, namely that certain Virtual Items may only be exchanged for certain other designated Virtual Items in and as part of the Games only.
9.8 First Touch may manage, vary, regulate, control, modify or eliminate Virtual Items in its sole discretion, with or without notice (including not supplying Virtual Items if it is reasonable to do so). First Touch shall have no liability to you or any third party in the event that First Touch exercises such rights.
9.9 When you submit, or anyone using your device submits, a request to purchase Virtual Items you are offering to purchase them for the price stated and our acceptance of that offer shall only occur once we make the Virtual Items available to you, prior to which your order may be declined for any reason.
9.10 Please notify First Touch immediately if you dispute a transaction involving Virtual Items or believe that any transaction is unauthorised.
9.11 Your statutory rights are unaffected by this EULA.

10. CONSUMER RIGHTS.
10.1 These terms above shall not limit any rights you might have as a consumer that may not be excluded under applicable law.
10.2 Alternative dispute resolution is a process where an independent body considers the facts of a dispute and seeks to resolve it, without you having to go to court. If you are not happy with how we have handled any complaint, you may want to consider an alternative dispute resolution provider. In addition, please note that disputes may be submitted for online resolution to the European Commission Online Dispute Resolution platform.

11. APPLE DEVELOPER TERMS
11.1 The following terms of this clause are the terms which First Touch is required by Apple to notify you of and obtain your consent in respect of using the iOS version of the Games (Apple iPad, iPhone and iPod etc.):
11.2 You and First Touch acknowledge that this EULA is concluded between you and First Touch only, and not with Apple Inc., nor any subsidiary or affiliate company of Apple Inc., (“Apple”). You also acknowledge that First Touch is solely responsible for the Games and the content thereof.
11.3 Subject to your compliance with all conditions of this EULA First Touch grants you a non-exclusive, personal, revocable, non-transferable license to use the Games on an iOS Product which you own or control, and as permitted by the Usage Rules set forth in the App Store Terms of Service (https://www.apple.com/uk/legal/sales-support).
11.4 First Touch is solely responsible for providing support and maintenance for the Games. You and First Touch acknowledge that Apple has no obligation whatsoever to furnish any maintenance and support services with respect to the Games.
11.5 You acknowledge that First Touch, and not Apple, is responsible for addressing any claims you may have relating to the Games or your possession and/or use of the Games, including but not limited to:
11.5.1 product liability claims;
11.5.2 any claim that the Games fail to confirm to any applicable legal or regulatory requirement; and
11.5.3 claims arising under consumer protection or similar legislation.
11.6 You acknowledge that in the event of a third party claim that the Games or your possession and use of the Games infringes that third party’s intellectual property rights, then First Touch shall be solely responsible for the investigation, defence, settlement and discharge of any such intellectual property right infringement claim, and not Apple.
11.7 You confirm that:
11.7.1 you are not located in a country that is subject to a US Government embargo, or that has been designated by the US Government as a “terrorist supporting” country; and
11.7.2 you are not listed on any US Government list of prohibited or restricted parties.
11.8 You acknowledge and agree that Apple are third party beneficiaries of this EULA, and that when you accept the terms and conditions of this EULA, Apple will have the right (and will be deemed to have accepted the right) to enforce this EULA against you as a third party beneficiary thereof.
11.9 First Touch uses third party software and services provided in the Games (explained above). Use of the Games is therefore subject also to your acceptance and compliance of these third party terms and you agree to comply with the applicable third party terms and conditions when using the Games. More information about this can be found in our Privacy and Data Policy.

12. ADVERTS
12.1 Although First Touch is responsible for the advertisements that are placed in the Games or on the Online Service, we do not control the specific content of those adverts. We do, however, have control over the general types of advertisements that are placed in the Games to ensure that the Games do not contain any inappropriate advertisements.
12.2 Please report any advert that you find offensive or inappropriate to support@ftgames.com.
12.3 If you click on any advert you will be dealing with external companies responsible for that advert. First Touch does not control the actions of these companies or the content of their websites.

13. INDEMNITY AND REMEDIES.
13.1 You hereby indemnify (agree to compensate), defend and hold harmless First Touch and First Touch’s affiliates, officers, directors, owners, licensors, service providers, partners, contractors, employees, agents and licensees (collectively, the “Indemnified Parties“) harmless from and against any and all any liabilities, claims, costs and expenses (including legal expenses and lawyers’ fees) incurred by the Indemnified Parties in connection with any claim arising out of any breach by you of this EULA or claims arising directly or indirectly from your use or misuse of the Games (which includes Virtual Items and the Online Service), and any negligent or improper use of your device, password and username; and / or any use otherwise than in accordance with the terms of this EULA. You shall fully cooperate with First Touch in the defence of any such claim and First Touch reserves the right, at our own expense, to assume the exclusive defence and control of any matter otherwise subject to indemnification by you.
13.2 You further agree that the subject matter of this EULA is of a unique character with special value and that First Touch would be irreparably damaged if the terms of this EULA were not specifically enforced, and therefore you agree that First Touch shall be entitled, without bond, other security, or proof of damages, to appropriate equitable remedies (including injunctive relief) with respect to breaches of this EULA, in addition to such other remedies as First Touch may otherwise have available to it under applicable laws.
13.3 First Touch’s licensors shall be third-party beneficiaries under this EULA and shall have the express right to enforce its provisions and to enjoy the benefits of its protections.

14. CHANGES TO THIS EULA
14.1 We may update the terms of this EULA from time to time for any reason by posting the updated version HERE. Every time you launch any of the Games on your device you are deemed to have accepted the terms of the EULA in place at that time. Accordingly, we suggest you check HERE for any updates to the EULA each time you launch any of the Games on your device.

PRIVACY AND DATA POLICY
ISSUED BY FIRST TOUCH GAMES LIMITED

Last Updated: 17 May 2018

1. INTRODUCTION AND GENERAL TERMS

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

This privacy and data policy (“Privacy Policy”) applies and has effect in respect of all games, related online services (including online network play connectivity and interactivity) and other software and products made available by us (together the “Game(s)“), as well as any other online features relating to the Games including our website (the “Website”), our online forums (the “Forums”) and User Support Centre (the “Support Centre“). Together the Game(s), the Website, the Forums and Support Centre are referred to as the “Online Services”.
If you have any questions or comments about this Privacy Policy, please contact us at support@ftgames.com

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

Please read this Privacy Policy carefully as it contains important information about the following:

 What information we may collect about you;

 How we will use information we collect about you;

 Whether we will disclose your details to anyone else; and

 Your choices and rights regarding the personal information you have provided to us.

This Privacy Policy forms a part of and should be read in conjunction with our terms of use. These are linked below:

 In respect of the Game(s):

 In respect of the Support Centre:

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

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

2. INFORMATION WE MAY COLLECT ABOUT YOU

We collect and process the following information which may include your personal data.

a) Information provided by you when using the Games
(“Basic Information”)

We will collect the following information from you when you play our Games:

 your mobile device’s unique device ID (Device ID) and device name;

 your user preferences; and

 Core information related to your gameplay, such as your overall progression to a particular level or stage, your virtual currency stores or the completion of certain activities during your gameplay (for example, completing a tutorial, passing a level, making a purchase or viewing a video ad).

b) Contact information provided by you when using the Forums or Support Centre
(“Contact Information”)

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

This may include:

• your email address;

• your name (Forums only), and

• your password (Forums only).

c) Information used for the purposes of serving advertisements
(“Advertising Data”)

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

• the make, model and operating system of your device;

• properties of your device, such as screen size and orientation, audio volume and battery;

• the mobile network operator linked to your device;

• the Games played;

• the country, time zone and locale settings on your device (i.e. country and preferred language);

• network connection type and speed;

• IP Address;

• MAC address;

• internet browser used to access the Games; and

• the advertiser ID, which is an identifier unique to you if you use an Apple or Android device, but which doesn’t reveal your name.

d) Information collected for the purposes of providing analytics
(“Analytics”)

We may collect technical information about your use of the Online Services through the use of tracking technologies and analytics.
Personal data we may collect includes the following:

• your Device ID;

• your user ID (which is generated by us and allocated to you when you first play our games);

• your device operating system & version;

• your device make and model;

• game play attempts, progression and results;

• session game time start, end and duration;

• purchase transaction types and spend you have made using virtual items in the Games;

• the country of your Device;

• the time, date and install source of your first download (e.g. from a clicked advertisement);

• advertisements viewed and clicked; and

• identification of crashes and defects.

We use a third party analytics provider called Adjust when conducting our analysis on our marketing campaigns.

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

If you would like to find out more about the way Adjust collects and processes this information this is likely to be set out in their privacy policies and/or terms and conditions. Please refer to https://www.adjust.com/terms/ and https://www.adjust.com/privacy-policy/.

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

e) Information about you collected from third parties
(“Third Party Log In Information”)

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

f) Content created by our users which we host and display on the Forums and in the Support Centre
(“User Content”)

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

3. WHY WE COLLECT INFORMATION ABOUT YOU

a) To provide our Games to you

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

b) To help us improve the Online Services and fix any problems

We may process information about you (including Basic Information, User Content and Analytics) so that we can analyse and improve our Games and Online Services.

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

c) To respond to your enquiries and requests for support and to enable you to use the Forums

We may process Contact Information so that we are able to properly respond to your enquiries and support requests either via the Support Centre or Forums or through support@ftgames.com and so you are able to use the Forums, in accordance with the terms of use agreed between us.

d) To acquire new users and engage current users

We may process information (including some Advertising Data and Analytics) to encourage engagement from our less active users and to notify them with new virtual items or other promotions on offer.

We may also process this information to pursue our legitimate interests of acquiring new users for our Games.

We use various forms of marketing to acquire new users. The information we collect about you may be used to improve the relevancy of our marketing, including the creation of ‘lookalike’ audiences. This allows us to offer more relevant marketing to potential new service users without using information that personally identifies you.

e) To improve the monetisation of the Games via in-app purchases

We may process information (including Basic Information, User Content, Advertising Data and Analytics) to understand how users use our Games, and to compile statistical reports regarding that activity, as well as understanding how users progress, and their current status within a Game. This processing is necessary for us to pursue our legitimate interests of improving the Games and increasing the amount of revenue generated via in-app purchases. This may include the implementation of dynamic pricing models, so that in-app purchases are priced according to relevant factors, such as geography and gameplay progression so that we can offer temporary promotional discounts.

We will not pass your information to third parties for the purposes of dynamic pricing unless you give your consent should we ask for it. After you have given your consent, you may withdraw it at any time.

f) For advertising purposes

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

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

We may also use this information to reward users with benefits that can be used for further enjoyment of the Games from the viewing of certain advertising placed in our Games.
We will not pass or process your information for the purposes of marketing by third parties unless you give your consent should we ask for it. After you have given your consent, you may withdraw it at any time.

We may use the information we collect about you to serve you targeted advertisements in our Games. We do this to provide you with more relevant advertising content. We work with the following third party advertising networks :

 Applovin – https://www.applovin.com/privacy

 Chartboost – https://answers.chartboost.com/en-us/articles/115001489623

 Adcolony – https://www.adcolony.com/privacy-policy/

 Facebook – https://www.facebook.com/privacy/explanation

 Unity – https://unity3d.com/legal/privacy-policy

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

g) To prevent fraud and illegal activity

We process personal data for our legitimate interests of ensuring that any use of the Online Services is lawful and non-fraudulent, does not disrupt the operation of our services, does not harass our staff or other individuals, to enforce our legal rights and to comply with our legal obligations.

Where we reasonably believe that you are or may be in breach of any applicable laws or our terms of use, we may use your personal information to inform relevant third parties such as your law enforcement agencies about the content.

We reserve the right to disclose your identity to any third party who is claiming that any User Content posted by you constitutes a violation of their intellectual property rights, or of their right to privacy. You may not copy, download, or embed any User Content without the express written permission of the content owner. You may not use any User Content for any commercial purposes, or any public performances.

We work with Apple and Google to assist us with fraud prevention and the detection of any illegal activity (e.g. to verify in-app purchases made through iTunes and Google Play).

4. DATA SHARING

We will share your information with third parties only in the ways that are described in this Privacy Policy

Group members, personnel, suppliers or subcontractors: We keep your information confidential, but may disclose it to any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in section 1159 of the Companies Act 2006), our personnel, suppliers or subcontractors insofar as it is reasonably necessary for the purposes set out in this Privacy Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it.

Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of its assets, any third party to which we sell or transfer our assets to will have the right to continue to use the personal and other information that you provide us in the manner set out in this Privacy Policy.

Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

Enforcement: We may also disclose your personal information to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect the rights, property or safety of FTG, our customers, or others.

Digital Content Stores: Where the Games are downloaded though Google Play, iTunes and/or Amazon Appstore, we may disclose your personal information to Google, Apple and/or Amazon respectively for the purposes of facilitating any in-Game payments made through these platforms.

Support Centre: We use a third party platform provider called Zendesk to manage any support requests, queries and issues raised by users via the Support Centre or sent to support@ftgames.com. Further details about the way in which Zendesk may collect and process your information can be found in their terms here.

5. AUTOMATED DECISION MAKING

We use automated decision making methods which do not involve human involvement to process your information only in the ways that are described in this Privacy Policy

We process your personal information via automated decision making methods in order to identify users who are suspected of cheating in the Games. Our automated decision making methods are designed to detect cheating by looking out for (i) excessive currency stores against actual completed gameplay; and (ii) excessive content against actual purchases made and completed gameplay.

If users are determined to be or suspected of cheating the following actions may be taken and which will be unknown to the user:

 an increase in the number of advertisements displayed within the Games; and

 an increase in the frequency of suspected cheats playing against other suspected cheats.

We may block users from the Games and/or the Online Services who are determined to be cheating following an automated decision process. In this scenario the user will be notified of the outcome and will have the right to obtain human intervention to express his or her point of view and to contest the decision to block access to the Games and/or the Online Services.

6. CONSUMER CONTROL AND OPT-OUT OPTIONS

If you do not wish to be part of a lookalike campaign, receive notifications from us or be served with targeted advertisements you can opt-out by changing your advertising and notification settings on your device directly. You can opt-out from analytics performed by Adjust here.

You can withdraw your consent to targeted advertising by changing your advertising settings on your device at any time.

7. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU

You have the following rights over the way we process personal data relating to you, as set out in the table below. We aim to comply without undue delay, and within one month at the latest.

To make a request, please let our Data Protection Officer know by sending an email to support@ftgames.com.

a) Ask for a copy of data we are processing about you and have inaccuracies corrected

You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected.

We will use reasonable efforts to the extent required by law to supply, correct or delete personal information held about you on our files (and with any third parties to whom it has been disclosed to).

b) Object to us processing data about you

You can ask us to restrict, stop processing, or to delete your personal data if:

 you consented to our processing the personal data, and have withdrawn that consent;

 we no longer need to process that personal data for the reason it was collected;

 we are processing that personal data because it is in the public interest or it is in order to pursue a legitimate interest of FTG or a third party, you don’t agree with that processing, and there is no overriding legitimate interest for us to continue processing it;

 the personal data was unlawfully processed;

 you need the personal data to be deleted in order to comply with legal obligations;

 the personal data is processed in relation to the offer of a service to a child.

c) Obtain a machine readable copy of your personal data, which you can use with another service provider

 If we are processing data in order to perform our obligations to you, or because you consented, or if that processing is carried out by automated means, we will help you to move, copy or transfer your personal data to other IT systems.

 If you request, we will supply you with the relevant personal data in CSV format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.

d) Make a complaint to a Supervisory Authority

 If you are unhappy with the way we are processing your personal data, please let us know by contacting us via the support services.

 If you do not agree with the way we have processed your data or responded to your concerns, an alternative is to submit a complaint to a Data Protection Supervisory Authority.

8. DATA RETENTION

We will hold your personal information on our systems for as long as is necessary for the relevant service, or as otherwise described in this Privacy Policy.

9. CHILDREN

We do not use our Online Services to knowingly solicit information from or market to children under the age of 13. Our terms of use prohibit users aged under 13 years from accessing our Online Services. In the event that we learn that we have collected personal information from a child under 13 years of age we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13 years of age please contact us at support@ftgames.com.

10. SECURITY

We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information. For example, our databases are password protected and limited to essential employees only (such as FTG management or employees whose main role requires system access).

Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.

11. INTERNATIONAL DATA TRANSFERS

Where you make in-Game purchases via iTunes or Google’s Play store, the confirmation that your purchase is valid as required by Apple or Google for such purchases will be processed using servers hosted in Singapore in the event that there is a problem with the servers hosted in Ireland. The servers we use for this purpose are hosted by Amazon Web Services.

Basic Information used for Matchmaking services, where users may play against other users, may be processed using servers based in Singapore or US in addition to Ireland and Germany, reflecting the global player base of the Games. The servers we use for this purpose are hosted by Amazon Web Services.

It is possible that your personal information may be transferred outside of the EEA by Ad Networks, Adjust, or Zendesk. We recommend that you refer to the privacy policies and/or terms and conditions of these third parties if you are concerned about your data being transferred outside the EEA.

Where we transfer your information outside of the EEA, we have agreements in place with those parties which include standard data protection clauses adopted by a data protection regulator and approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data. If you would like to find out more about these safeguards, please let us know by writing to support@ftgames.com.

CONTACT INFORMATION
All questions, comments or enquiries should be directed to FTG at support@ftgames.com. We will endeavour to respond to any query or questions within three business days.

© 2018 First Touch Games Limited. All trade marks are the property of the relevant owners. All rights reserved.

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