Privacy Policy

Last updated: August 2, 2024

This Privacy Policy outlines our practices regarding the collection, use, and disclosure of your information when you utilize the Service, as well as your privacy rights and the protection provided by law.

By engaging with the Service, you consent to the collection and use of information in accordance with this Privacy Policy.

OVERVIEW OF PRIVACY POLICY

This Taiga Pte. Ltd. User Privacy Notice ("Policy") provides detailed information on how Taiga Pte. Ltd. ("Taiga Pte. Ltd.", "we", "us", or "our") handles personal data in connection with our websites, mobile applications, progressive web applications, content, features, digital events, or products (collectively, the "Services"). This Policy is an integral part of Taiga Pte. Ltd.'s Terms of Service ("Terms"). "Personal data" refers to information that can identify you either directly or indirectly. This includes details such as your name, phone number, email address, device data, and usage information. This Policy does not cover third-party games accessed via our Services. The privacy policy of the respective game developer ("Game Partners") will apply to their games.

If you are under 13 years old, you are not permitted to use Taiga Pte. Ltd.'s applications.

We encourage regular review of this Policy for the latest updates. Changes will be communicated within the affected Services, and the "Last Updated" date will be revised accordingly. If you do not accept the current Policy or any applicable addendums, please refrain from using the Services.

1. INFORMATION WE COLLECT ABOUT YOU

As the controller of your personal data, Taiga Pte. Ltd. is responsible for determining how it is used and processed. We collect your information directly (e.g., email or phone number when claiming rewards), indirectly (e.g., IP address when downloading our app), from public records, or from our partners or clients. The types of personal data we collect are detailed in Annex B, Table for Legal Processing Activities.

2. USE OF PERSONAL DATA

We may link or combine your personal data to provide a personalized experience. Our use of personal data includes:

• Delivering and improving our Services, including awarding Points

• Personalizing Services with game, feature, and event suggestions

• Marketing our Services on third-party platforms

• Organizing contests, sweepstakes, and digital events

• Fulfilling operational and business needs, such as billing and rewards delivery

• Verifying identity to prevent fraud

• Developing new products and updating Services

• Creating reports and insights with aggregated or anonymous data

• Communicating with you according to your preferences

• Troubleshooting and resolving issues

• Providing technical and customer support

The legal basis for processing your personal data may include:

• Performance of our agreement with Users

• Meeting legal and compliance obligations

• Our legitimate interests, such as service improvement and fraud prevention

• Consent, where required by law

For more details on specific legal bases for processing activities, refer to the regional notices.

3. HOW WE SHARE PERSONAL INFORMATION ABOUT YOU

We share data with third parties that assist us in delivering and analyzing the Services, including:

• Corporate affiliates and transaction parties during business transactions

• Law enforcement and regulators for legal and security reasons

• Service providers to help deliver and secure our Services and conduct marketing

• Advertising platforms and networks for campaign management

• Marketing vendors for campaign support and event organization

• Analytics providers for insights and trends

• Game Partners for personalized content and marketing

We may also disclose aggregated or anonymized data that cannot identify individuals or devices, except where limited by law.

4. HOW WE STORE, TRANSFER, AND SECURE PERSONAL INFORMATION ABOUT YOU

We store data on servers in Hong Kong and may transfer it to other jurisdictions. We implement safeguards to protect your data, though privacy laws in other jurisdictions may vary.

5. EXERCISING OF YOUR RIGHTS

You can update preferences and exercise rights under data protection laws by contacting us. Changes in preferences may affect your Service experience. If your personal data changes, please inform us.

Specific rights for residents of certain regions are detailed in the Region-Specific Notices.

6. OTHER IMPORTANT INFORMATION

6.1 Children's Privacy: We comply with laws protecting children's privacy. Contact us if you believe we have information about a child.

6.2 Data Retention: We retain personal data as required by law, for as long as you use the Services, or as necessary for its purposes. Your data may be deleted after prolonged inactivity or upon account deletion. For data held by Game Partners, contact them directly.

By using our Services, you acknowledge the practices and policies outlined in this Privacy Policy.

7. CONTACT US

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If you have questions that do not relate to this Policy or data privacy, please write to our customer support team and Submit a Request. To exercise applicable data protection rights or comment about this Policy and our privacy practices to the extent you may enjoy any data subject rights as per privacy laws applicable to you, you may reach out to our data protection office at:

Taiga Pte. Ltd.

727 CLEMENTI WEST STREET 2#01-280 SINGAPORE (120727) or via email at [email protected]

ANNEX A: REGION-SPECIFIC NOTICES

We may choose or be required by law to provide different or additional disclosures relating to the processing of personal data about residents of certain countries, regions or states.

Europe and United Kingdom Notice

1.SPECIFIC RIGHTS FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA, SWITZERLAND AND THE UNITED KINGDOM (“EEA, SUI & UK”)

This Europe and United Kingdom Notice  provides additional information for users in the EEA, SUI and UK. Unless otherwise set forth in this Europe and United Kingdom Notice  all other terms and principles in Taiga Pte. Ltd.’s Global Privacy Policy continue to apply.

Users in the EEA and UK have certain privacy rights as specified under applicable law, including the General Data Protection Regulations (“GDPR”), SUI Article 13 of the Swiss Constitution and Federal Act on Data Protection (DPA) and UK Data Protection Act 2018. The Policy and the privacy controls we offer to all users are in line with these laws. As a resident of the EEA, SUI & UK, you also have certain specific rights regarding your personal data. You are free to exercise any of these rights by contacting us or as specified herein:

• Access. You have the right to request a copy of the personal data that we process about you. However, there are exceptions to this right, so that access may be denied if, for example, making the information available to you would adversely affect the rights and freedoms of another person, or if we are legally prevented from disclosing such information.

• Accuracy. We aim to keep your personal data accurate and complete. We encourage you to keep us informed about changes that you would like reflected in our records.

• Objecting. In certain circumstances, you have the right to object to processing of your personal data. You may ask us to block, erase or limit the use or other processing of your personal data.

• Rectification. You have the right to request the rectification of inaccurate personal data and, taking into account the purposes of the processing, to complete your personal data.

• Data Portability. Provided further legal requirements are fulfilled, you have the right to request that some of your personal data is provided to you, or, where technically feasible, to have your personal data transmitted to another provider should you wish to stop using our Services in favor of another, in a structured, commonly used and machine-readable format.

• Erasure. You have the right to erase or request that we erase your personal data as far as legal requirements for erasure are fulfilled, such as when your personal data is no longer necessary for the purposes for which it was collected.

• Automated Decision-Making. You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you as far as further legal requirements are fulfilled.

• Complaints. You have the right to issue a complaint with the applicable data protection authority

• For France, you also have the right to provide guidelines relating to the retention, deletion and communication of your personal data after your death

The specific further legal requirements for the exercise of these rights depend on the applicable statutory data protection laws. For your protection, we only fulfill requests for the personal data associated with the email address that you identify in your request, and we may need to verify your identity before fulfilling certain requests. As an EEA, SUI or UK data subject, you may access your rights with respect to Taiga Pte. Ltd. by communicating as directed in the Contact Us section of the Policy

1. SUBMITTING COMPLAINTS

If you are resident in the EEA, you have the right to make a complaint at any time to the regulator in your jurisdiction. To find out how to contact your local regulator, please visit https://edpb.europa.eu/about-edpb/about-edpb/members_en.

If you reside in the UK, you have the right to make a complaint at any time to the Information Commissioner’s Office (“ICO“), the UK regulator for data protection issues. You can make a complaint via the ICO’s website (https://ico.org.uk/make-a-complaint/). This website also provides additional contact details for the ICO.

2. TRANSFERS OF PERSONAL DATA

For EEA, SUI & UK based users, your personal data may be transferred outsidae of the EEA for example to countries where we have facilities or engage service providers, such as to the United States where our corporate affiliate and our hosting provider, are located.  By consenting to the transfer of your personal data outside of your country of residence, you acknowledge that your personal information may be transferred to recipients in the United States and other countries that may not offer the same level of privacy protection as the laws in your country of residence or citizenship.

Some of the non-EEA countries are recognized by the European Commission as providing an adequate level of data protection according to EEA standards. For transfers from the EEA to countries not recognized by the European Commission as offering an adequate level of data protection, we have put in place adequate measures, such as standard contractual clauses adopted by the European Commission to protect your personal data. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in countries outside the EEA may be entitled to access your personal data. If you would like to receive a copy of our implemented safeguards (where possible) you can contact us as directed in the Policy.

Specific Notice for Residents of the United States

1.ADDITIONAL DISCLOSURES FOR RESIDENTS OF CALIFORNIA, USA

This section applies to the personal information of residents of California and supplements the other sections of Taiga Pte. Ltd.’s Global Privacy Policy, which continue to apply

Collection and Use of Personal Information: We have collected the following categories of personal information about you in the past 12 months:

Please note that we use and disclose sensitive personal information only for purposes expressly permitted under California law. For your information, personal data does not include publicly available information from government records and de-identified or aggregated consumer information.

Disclosure of Personal Information: We may disclose your personal information to third parties for the business purposes outlined in the chart above.  In the past 12 months, we may have disclosed your personal information for a business purpose or at your direction.  For more details on third parties we share data with see the How We Share Personal Information About You section of this Policy. Although we do not “sell” personal information in exchange for money, some of our sharing of personal information as part of our Services may be classified as a “sale” under applicable California laws. We do not knowingly sell or share the personal information of anyone under the age of 16.

Retention of Your Data: Taiga Pte. Ltd. will only retain personal data for as long as you use the Services, as required by law or for as long as it is required to meet the purposes for which it was collected.  For example, Taiga Pte. Ltd. account balances or rewards earned as of termination must be preserved for some period to allow for such matters as billing and tax reporting. Note, under the Terms, if a user does not use the Service for at least one hundred eighty days, the user’s inactive account may be terminated, units earned may automatically expire, subject to the Terms of Use and the user’s personal data may be destroyed.

Notice of Financial Incentive: Under California law, the Rewards Program enables you to earn Units and may be considered a financial incentive provided in exchange for the collection and retention of personal information. While Taiga Pte. Ltd. does not assign a monetary value to the data that we collect, based on our reasonable estimate, the value received from the insights and the Rewards Program is reasonably equal to or greater than the value Taiga Pte. Ltd. receives from the use of this information. Taiga Pte. Ltd. uses the information to better understand how you use our Services, to improve our products and Services and to further enhance our user analytics. Note that participation in the Rewards Program is completely voluntary and you can withdraw at any time.  For further details of the Rewards Programs and its terms, including how to withdraw or terminate your participation, please refer to Terms.

Your CCPA Rights: The California Consumer Privacy Act (CCPA) grants California consumers the following rights with respect to their personal information:

• Right to Know. You have the right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information that we have collected about you.

• Right to Delete. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.

• Right to Correct. You have the right request that we correct inaccurate personal information that we maintain about you.

• Right to Opt Out of Sales and Sharing. You have the right to opt out of sales of your personal information to third parties and to opt out of the disclosure of your personal information to third parties for cross-context behavioral advertising, if applicable.

• Right to Limit Use or Disclosure of Sensitive Personal Information. You have the right to limit the use and disclosure of your sensitive personal information to certain specific business purposes.

• Right to Non-discrimination. You have the right not to receive discriminatory treatment for exercising any of your CCPA rights.

Exercising Your Rights:

You may opt out of sales and/or sharing or  exercise your right to limit the use/disclosure of your sensitive personal information by sending a request to [email protected]. We also honor requests to opt-out submitted via privacy preference signals, such as Global Privacy Control (GPC). (For more information on the GPC and how to use a browser or browser extension incorporating the GPC signal, see https://globalprivacycontrol.org/)

You may submit requests to know, delete, or correct by contacting us as directed in the Policy. To make such a request, please include the phrase “Personal Information Privacy Request” in the subject line, the Service you are inquiring about, along with your name, address, and email address. If we receive a request to delete your data, we will ask you if you want your personal information to be removed entirely or if you want to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise). We cannot keep a record of individuals whose personal information we have deleted so you may be contacted again by us, should we come into possession of your personal information at a later date. Requests to know and requests to delete will be honored within 45 days; if more time is needed to respond, Taiga Pte. Ltd. will notify you.

The CCPA enables California users to appoint an authorized agent to act on their behalf to submit disclosure requests and or deletion requests under the CCPA. We will honor a request from an authorized agent provided that: i) you provide written authorization to the authorized agent to act on your behalf and we can verify your identity, and ii) the agent submits proof of authorization.

Browser “Do Not Track” Signals.  Most browsers contain a “do-not-track” setting.  In general, when a “do-not-track” setting is active, the user’s browser notifies other websites that the user does not want their personal information and online behavior to be tracked and used, for example, for interest-based advertising.  As required by California law, we are required to inform you that, as is the case with most websites, we do not honor or alter our behavior when a user to one of our Websites has activated the “do-not-track” setting on her/his browser.

1. ADDITIONAL DISCLOSURES FOR RESIDENTS OF COLORADO, CONNECTICUT AND VIRGINIA, USA

This section applies to the personal data of residents of Colorado, Connecticut and Virginia and supplements the other sections of this Policy.

For information on the categories of personal data that we collect, the purposes for which we process that personal data, and how we disclose that personal data, please refer to the Information We Collect About You, Use of Personal Data and Legal Basis for Processing, and How We Share Personal Information About You sections above, as well as Table for Legal Processing Activities below. For an explanation of the types of information we share with third parties, please refer to the Disclosures of Personal Information section in the Additional Disclosures for Residents of California notice above.

In some cases we may share your information with third parties who may use your information for their own purposes, including for purposes of marketing and advertising. These disclosures may be considered “sales” or “targeted advertising” under applicable privacy laws. For more information about the categories of personal data that we may sell to or share with third parties, and the categories of such third parties, see the Disclosure of Personal Information subsection in the Additional Disclosures for Residents of California, USA section above.

Depending on where you reside, and subject to certain exceptions, you may have the following rights with respect to your personal data:

• Access. You may have the right to request that we confirm whether we process your personal data and that we provide you access to such personal data.

• Data Portability. You may have the right to request that we provide a copy of your personal data in a portable and, to the extent technically feasible, readily usable format.

• Correction. You may have the right to request that we correct inaccuracies in the personal data that we process.

• Deletion. You may have the right to request deletion of your personal data.

• Opt Out of Sales and Targeted Advertising. You may have the right to request that we not process your personal data for the purposes of targeted advertising, sales, or profiling in furtherance of decisions that produce legal or similarly significant effects, as those terms are defined by applicable state law.

• Opt Out of Profiling. You may have the right to request that we not process your personal data for the purpose of profiling in furtherance of decisions that produce legal or similarly significant effects.

You may opt out of sales and/or targeted advertising using information as directed in the Policy. Where required, we also honor requests to opt-out submitted via privacy preference signals recognized under applicable local law, such as the GPC.

You may submit requests to exercise your other rights as directed in the Policy. Please include the phrase “Personal Information Privacy Request” in the subject line, the Service you are inquiring about, along with your name, address, and email address. If we receive a request to delete your personal data, we will ask you if you want your personal data to be removed entirely or if you want to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise). We cannot keep a record of individuals whose personal data we have deleted, so you may be contacted again by us, should we come into possession of your personal data at a later date.

You may also have the right to appeal a refusal to take action on your request as directed in the Policy.

Depending on where you reside, you may also use an authorized agent to act on your behalf to submit requests to exercise your rights. We will honor a request from an authorized agent provided that: i) you provide written authorization to the authorized agent to act on your behalf and we can verify your identity, and ii) the agent submits proof of authorization.

ANNEX B: TABLE FOR LEGAL PROCESSING ACTIVITIES