Last Updated: Dec 23, 2025

At Coin Combo Ltd. (referred to as "we," "us," or "our" in this policy), we are deeply committed to protecting your privacy and securing your personal information. This Privacy Policy details how we collect, utilize, manage, and safeguard your personal data when you visit our website (the "Site") or engage with Developer Games—games published by independent developers that leverage our infrastructure and services (collectively the "Services").

By accessing the Site, registering for an account, or using any of our Services, you acknowledge that you have read, understood, and agreed to the practices outlined in this Privacy Policy. We reserve the right to update this policy from time to time, with changes taking effect upon posting the revised version on the Site. Your continued use of the Services after updates constitutes acceptance of the modified terms.

1. Collection of Personal Information

1.1 Categories of Collected Information

When you interact with our Services (including Developer Games), we may gather the following types of personal information, based on your usage and consent:

• Contact Information: Full name (first and last), valid email address, residential address, and mobile or other phone numbers provided during registration or communication.

• Account & Profile Data: Gender, date of birth or age range, profile photos, custom avatars, and account credentials (username, encrypted password, and security question responses).

• Communication Records: Content of messages exchanged via email, in-app chat, postal mail, or other official communication channels, as well as records of communication timelines and topics.

• Third-Party Sourced Data: Information obtained from trusted external platforms or websites (with your explicit consent) that relates to your interaction with or interest in our Services, such as linked social media profile data.

• Location-Related Data: Geolocation information derived from mobile device GPS (when enabled by you) or approximate location inferred from IP address, collected only where permitted by applicable law and necessary for service delivery.

• Technical & Usage Data: Details about your interaction with the Site and Services, including visit frequency, gameplay duration, feature usage patterns, hardware model, device type, unique device identifiers (e.g., IMEI, UUID), operating system version, browser type, IP address, and system performance metrics.

• Government-Issued Identifiers: Passport numbers, driver's license numbers, or social security numbers, collected solely to comply with legal requirements (e.g., age verification, anti-money laundering checks) and never for non-essential purposes.

• Sensitive Personal Information: Biometric authentication data (e.g., fingerprint, facial recognition), precise geolocation, driver's license details, and financial information (e.g., payment card numbers), collected only when mandated by law or regulatory obligations, with enhanced security measures applied.

1.2 Purposes for Using Your Information

We use your personal information solely for legitimate business purposes, as outlined below, and will not use it for unstated purposes without your prior consent:

• Account Registration & Authentication: To facilitate account creation, verify your identity, enable secure login, and maintain your user profile (including updates to personal details).

• Eligibility & Geographic Verification: To confirm that you meet legal requirements (e.g., age, location) to access and play Developer Games, in compliance with jurisdiction-specific regulations.

• Player Connection & Matching: To help you discover, connect with, and interact with other players (e.g., multiplayer game lobbies, friend requests) based on your preferences and gameplay activity.

• Payment Processing: To securely handle in-game purchases, process transactions, update account balances, and maintain accurate transaction records for billing and refund purposes.

• Service & Feature Provision: To deliver core game functionalities, including in-app messaging, chat services, gameplay history tracking, achievement unlocks, and profile customization options.

• Customer Support & Issue Resolution: To respond to your inquiries, address technical issues, resolve complaints, and provide personalized assistance related to the Services.

• Service Improvement & Innovation: To analyze usage patterns, monitor service performance, identify technical glitches, and develop new features, enhancements, or game offerings that align with user needs.

• Advertising & Promotion Optimization: To evaluate the effectiveness of marketing campaigns, tailor promotional content to your preferences, and deliver relevant game updates or special offers (with opt-out options available).

• Service Communications: To send essential updates, such as game maintenance notices, account security alerts, policy changes, and responses to your feedback or questions.

• Security & Fraud Prevention: To detect and prevent unauthorized access, account misuse, fraud, cheating, or other malicious activities, and to strengthen our security infrastructure.

• Legal & Regulatory Compliance: To fulfill legal obligations, including tax reporting, regulatory inquiries, and compliance with data protection laws and industry standards.

• Enforcement of Agreements: To monitor compliance with our Terms of Service, Developer Agreements, and other applicable policies, and to enforce our rights when necessary.

2. Sharing of Personal Information

We prioritize the confidentiality of your personal information and will never sell it to third parties for marketing purposes. We may share your information only in the limited scenarios outlined below, with strict safeguards to ensure data protection:

2.1 Permitted Information Sharing

• Legal & Regulatory Obligations: We may disclose your information if required by law, such as in response to valid court orders, subpoenas, search warrants, or requests from government agencies or regulatory bodies.

• Business Transitions: In the event of a merger, acquisition, asset sale, or other corporate restructuring, your personal information may be transferred as part of the business assets, with the acquiring party bound by the terms of this Privacy Policy.

• Third-Party Service Providers: We may share information with trusted affiliated companies and third-party vendors who perform services on our behalf (e.g., cloud storage, payment processing, customer support, analytics). These providers are authorized to use your information only to fulfill their assigned services and are contractually obligated to maintain its confidentiality and security.

• Partnership Collaborations: We may share non-identifiable or aggregated data with advertising platforms, game developers, or other partners to improve campaign performance or service offerings. Personal information will only be shared with such partners if you have provided explicit consent.

2.2 Data Security & Retention

• Security Measures: We implement industry-leading security technologies and administrative procedures to protect your personal information from unauthorized access, disclosure, modification, or destruction. These include encryption of data in transit (TLS 1.3) and at rest (AES-256), access controls restricted to authorized personnel, regular security audits, and vulnerability assessments.

• Data Retention: We retain your personal information only for as long as necessary to fulfill the purposes for which it was collected, or to comply with legal, regulatory, or accounting requirements. Once no longer needed, data is securely deleted or anonymized to prevent identification.

• Security Limitations: While we strive to protect your data, no internet or electronic storage system is 100% secure. We cannot guarantee absolute security, and you acknowledge and accept the inherent risks of data transmission over the internet.

• Data Deletion Rules:

o If you uninstall our software or cease using the Services, all your personal data will be permanently deleted within three (3) months, unless legal obligations require longer retention.

o If you initiate data deletion through in-app settings or official channels, local data stored on your device will be erased immediately, and all related data on our servers will be deleted within one (1) month.

3. Advertising Preferences & Opt-Out Rights

• If you do not wish to receive personalized marketing communications or have your data used for advertising optimization, you may opt out by adjusting your account settings, using the unsubscribe link in marketing emails, or contacting our privacy team.

• Opting out of advertising-related data use will not affect the collection or use of your information for essential operational purposes (e.g., security, fraud prevention, service delivery).

• Opt-out requests are device and browser-specific. You will need to submit separate opt-outs for each device or browser you use to access the Services.

4. Confidentiality & Service Access

We respect the confidentiality of your personal information and expect you to use our software and Services in compliance with applicable laws and this Privacy Policy. If we have reasonable grounds to believe that you have violated any laws, our Terms of Service, or this Privacy Policy, we reserve the right to suspend or terminate your access to the Services, and to disclose your information as necessary to enforce our rights or comply with legal obligations.

5. Protection of Children's Privacy

Our Services are not intended for individuals under the age of 18 ("Minors"), and we do not knowingly collect, use, or store personal information from Minors. If we become aware that we have inadvertently collected personal information from a Minor, we will immediately suspend processing of such data and take steps to permanently delete it within a reasonable timeframe, without prior notice. Parents or guardians who believe their child has provided personal information to us may contact our privacy team to request deletion.

6. Jurisdiction-Specific Privacy Rights

6.1 Rights for California Residents (CCPA/CPRA)

If you are a resident of California, you have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to Know: The right to request disclosure of the categories and specific pieces of personal information we have collected about you, the sources of such information, the purposes for collection, and the categories of third parties with whom we have shared it.

• Right to Delete: The right to request the deletion of your personal information, subject to exceptions allowed by law (e.g., legal retention requirements).

• Right to Opt-Out of Sale/Sharing: The right to opt out of the sale or sharing of your personal information (we do not sell personal information, but this right applies to certain types of data sharing for advertising purposes).

• Right to Non-Discrimination: The right to be free from discrimination for exercising your privacy rights (e.g., no denial of services or increased fees).

To exercise these rights, please contact our privacy team using the details provided below. We may require verification of your identity before processing your request.

6.2 Rights for EEA Residents (GDPR)

If you are located in the European Economic Area (EEA), you have the following rights under the General Data Protection Regulation (GDPR):

• Right to Withdraw Consent: The right to withdraw your consent to data processing at any time (where processing is based on consent), without affecting the lawfulness of processing based on prior consent.

• Right of Access: The right to request access to your personal information and obtain a copy of the data we hold about you.

• Right to Rectification: The right to request correction of inaccurate or incomplete personal information.

• Right to Erasure ("Right to be Forgotten"): The right to request the deletion of your personal information in certain circumstances (e.g., if the data is no longer needed for the stated purpose, or if you withdraw consent).

• Right to Restriction of Processing: The right to request that we restrict processing of your personal information (e.g., while we verify the accuracy of the data or investigate a complaint).

• Right to Object to Processing: The right to object to processing of your personal information for direct marketing, or for purposes based on legitimate interests (we will cease processing unless we can demonstrate compelling legitimate grounds).

• Right to Data Portability: The right to receive your personal information in a structured, machine-readable format, or to have it transferred to another data controller (where technically feasible).

• Right to Lodge a Complaint: The right to file a complaint with a supervisory authority in your jurisdiction if you believe we have violated your privacy rights.

To exercise these rights, please contact our data protection officer (DPO) using the details provided below. We will respond to your request within one month (extendable by two months for complex requests) and will not charge a fee for standard requests.

7. Contact Information

If you have questions about this Privacy Policy, wish to exercise your privacy rights, or report a privacy concern, please contact us:

• Email: [email protected]

• Response Timeframe: We will acknowledge your inquiry within 2-3 business days and provide a detailed response within 30 days, unless extended by law.