ASANTEE GAMES - PRIVACY POLICY

This privacy statement ("Privacy Statement") applies to the treatment of personally identifiable information submitted by, or otherwise obtained from, you in connection with the associated application ("Application"). The Application is provided by Asantee Games. By using or otherwise accessing the Application, you acknowledge that you accept the practices and policies outlined in this Privacy Statement.

DATA CONTROLLER INFORMATION

The data controller responsible for the collection and use of your personal information under this Privacy Policy is Asantee Games.

For any questions, concerns, or to exercise your data protection rights, you may contact our data controller using the following details:

• Name: Bruno Pereira
• Title: CEO
• Email: bruno@asanteegames.com
• Company: Asantee Games

DATA PROTECTION OFFICER (DPO)

To ensure compliance with data protection regulations and provide users with a dedicated contact for privacy-related concerns, Asantee Games has appointed a Data Protection Officer (DPO).

For any privacy concerns or questions, you may contact our DPO using the following details:

• Name: André Santee
• Title: CTO
• Email: andre@asanteegames.com

WHAT PERSONAL INFORMATION DOES ASANTEE GAMES COLLECT?

We collect the following types of information from our users:

Personal Information You Provide to Us:

We may receive and store any information you submit to the Application (or otherwise authorize us to obtain - such as, from your Google account or Apple Game Center account). The types of personal information collected may include your full name and email address to provide the Application services.

Personal Information Collected Automatically:

We receive and store certain types of usage-related information whenever you interact with the Application. This includes:

• Device ID: We collect and store device identifiers such as Device ID (Android ID) or other unique identifiers associated with your device. This data helps us ensure the security of our services and provides us with insights into how users interact with the Application.
• Usage Data: Information on how you interact with the Application, such as session duration, features used, and system logs, may be collected automatically.

Such information may be shared in aggregate (non-personally identifiable) form with our partners.

HOW DOES ASANTEE GAMES USE THE INFORMATION IT COLLECTS?

Asantee Games uses the information described in this Privacy Statement (i) internally, to analyze, develop, and improve its products and services, and (ii) as set forth below in the "Will Asantee Games Share any of the Personal Information it Collects" section below.

WILL ASANTEE GAMES SHARE ANY OF THE PERSONAL INFORMATION IT RECEIVES?

Personal information about our users is an integral part of our business. We neither rent nor sell your personal information to anyone (with the exception of sharing your information with an applicable Application Partner - see the "Application Partner Treatment" section above). We share your personal information only as described below.

• Application Partners: We will share your personal information with an applicable Application Partner (see the "Application Partner Treatment" section above).
• Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. Unless we tell you differently, Asantee Games agents do not have any right to use personal information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of personal information for the above purposes.
• Business Transfers: In some cases, we may choose to buy or sell assets. In these types of transactions, customer information is typically one of the business assets that are transferred. Moreover, if Asantee Games, or substantially all of its assets were acquired, or in the unlikely event that Asantee Games goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Asantee Games may continue to use your personal information as set forth in this policy.
• Protection of Asantee Games and Others: We may release personal information when we believe in good faith that release is necessary to comply with the law; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of Asantee Games, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
• With Your Consent: Except as set forth above, you will be notified when your personal information may be shared with third parties, and will be able to prevent the sharing of this information.

DATA RETENTION POLICY

We retain personal data for as long as necessary to fulfill the purposes for which it was collected, as outlined in this Privacy Policy, or as required by law. Specifically:

• User Account Information: We retain your account information (e.g., name, email) for as long as your account is active or as needed to provide services to you. If you request account deletion, we will delete your data in accordance with applicable laws, unless we are required to retain certain information for legal, regulatory, or administrative purposes.
• Device ID and Usage Data: Device identifiers and usage data are retained for as long as necessary to improve our services, ensure security, and for legal compliance.
• Legal Requirements: In certain circumstances, we may retain your data for longer periods if we are required to do so by legal obligations, or if we need to resolve disputes, enforce agreements, or protect our legal rights.
• Data Deletion Requests: You have the right to request the deletion of your personal data. To make such a request, please contact us at contato@asanteegames.com. We will process your request in accordance with applicable data protection laws, such as the GDPR or CCPA. Please note that some exceptions may apply, and we may be required to retain certain data for legal, regulatory, or administrative purposes.

YOUR RIGHTS UNDER THE CALIFORNIA CONSUMER PRIVACY ACT (CCPA)

If you are a resident of California, you have specific rights under the California Consumer Privacy Act (CCPA). These rights include:

• Right to Access: You have the right to request access to the personal information we collect about you, including the categories of information collected, the purposes for which the data was collected, and any third parties with whom the data was shared.
• Right to Deletion: You have the right to request the deletion of personal information we have collected about you, subject to certain exceptions (e.g., when retention is required for legal purposes).
• Right to Know: You have the right to know whether your personal information is sold or shared, and to whom.
• Right to Opt-Out: You have the right to opt-out of the sale of your personal information. If we engage in any practices that qualify as a sale of your personal data under the CCPA, we will provide you with a mechanism to opt-out.
• Right to Non-Discrimination: You have the right not to be discriminated against for exercising your CCPA rights.

To exercise any of these rights under the CCPA, you can contact us at contato@asanteegames.com. We will respond to your request in accordance with the requirements of the CCPA.

YOUR RIGHTS UNDER THE VIRGINIA CONSUMER DATA PROTECTION ACT (VCDPA)

If you are a resident of Virginia, the Virginia Consumer Data Protection Act (VCDPA) provides you with specific rights regarding your personal information. These rights include:

• Right to Access: You have the right to confirm whether we are processing your personal data and to request access to the data.
• Right to Correction: You have the right to request the correction of inaccurate personal data that we hold about you.
• Right to Deletion: You have the right to request the deletion of your personal data that we have collected, subject to certain exceptions (e.g., when retention is required for legal purposes).
• Right to Opt-Out: You have the right to opt-out of the processing of your personal data for purposes such as targeted advertising, the sale of personal data, or profiling that has legal or significant consequences.
• Right to Data Portability: You have the right to obtain a copy of the personal data you have provided to us in a portable and easily accessible format.

To exercise your rights under the VCDPA, you can contact us at contato@asanteegames.com. We will respond to your request in accordance with the requirements of the VCDPA.

HOW USERS CAN OPT-OUT OF DATA SHARING, SALE, TARGETED ADVERTISING, AND PROFILING

Under the VCDPA, CCPA, and other applicable laws, you have the right to opt-out of:

• Sharing or Selling of Personal Data: You may opt-out of having your personal data shared or sold to third parties.
• Targeted Advertising: You may opt-out of having your data used for targeted advertising purposes.
• Profiling: You may opt-out of profiling that affects decisions with legal or significant consequences.

How to Exercise Your Opt-Out Rights:

To opt-out of the sharing, sale, targeted advertising, or profiling of your personal data, you can submit your request by contacting us at contato@asanteegames.com.

Once we receive your opt-out request, we will stop processing your personal data for the specified purposes as required by law. We will also refrain from sharing, selling, or using your data for targeted advertising or profiling activities that have legal consequences.

YOUR RIGHTS UNDER OTHER DATA PROTECTION LAWS

In addition to the CCPA and VCDPA, other jurisdictions may grant you additional rights over your personal data. For example:

• GDPR (General Data Protection Regulation): If you are a resident of the European Union, you have the right to access, correct, or delete your personal data, as well as other rights provided by the GDPR.

If you are a resident of a jurisdiction that grants additional data protection rights, you may contact us at contato@asanteegames.com to exercise those rights.

CONDITIONS OF USE

If you decide to use or otherwise access the Application, your use/access and any possible dispute over privacy is subject to this Privacy Statement and our Terms of Use, including limitations on damages, arbitration of disputes, and application of California state law.

THIRD-PARTY APPLICATIONS/WEBSITES

The Application may permit you to link to other applications or websites. Such third-party applications/websites are not under Asantee Games control, and such links do not constitute an endorsement by Asantee Games of those other applications/websites or the services offered through them. The privacy and security practices of such third-party application/websites linked to the Application are not covered by this Privacy Statement, and Asantee Games is not responsible for the privacy or security practices or the content of such websites.

WHAT PERSONAL INFORMATION CAN I ACCESS?

Asantee Games allows you to access the following information about you for the purpose of viewing, and in certain situations, updating that information. This list may change in the event the Application changes:

• Account and user profile information
• User e-mail address, if applicable
• Google profile information, if applicable
• Apple Game Center information, if applicable
• Device ID and usage data
• User preferences
• Application specific data

CAN CHILDREN USE THE APPLICATION?

Our site and the services available through Asantee Games are intended for all audiences. Asantee Games does not knowingly or specifically collect information about children under the age of 13 and believes that children of any age should get their parents' consent before giving out any personal information. We encourage you to participate in your child's web experience.

CHANGES TO THIS PRIVACY STATEMENT

Asantee Games may amend this Privacy Statement from time to time. Use of information we collect now is subject to the Privacy Statement in effect at the time such information is used. If we make changes in the way we use personal information, we will notify you by posting an announcement on our Site or sending you an email. Users are bound by any changes to the Privacy Statement when they use or otherwise access the Application after such changes have been first posted.

QUESTIONS OR CONCERNS

If you have any questions or concerns regarding privacy on our Website, please send us a detailed message at contato@asanteegames.com. We will make every effort to resolve your concerns.

Effective Date: October 24, 2024.