PRIVACY AND DATA POLICY

ISSUED BY JETBLACK SOFTWARE LIMITED

Last Updated: 21 September 2018

1. INTRODUCTION AND GENERAL TERMS

These terms apply to the use of apps, games and other products developed by Jetblack Software Limited ('Jetblack' / 'we' / 'us'). Our registered office is at 165 Powis Avenue, Tipton, West Midlands, DY4 0RW. We are a company registered in England, with company number 07835536.

This privacy and data policy ("Privacy Policy") applies and has effect in respect of all apps, games, related online services (including online network play connectivity and interactivity) and other software and products made available by us (together the "App(s)"), as well as any other online features relating to the Apps including our website (https://www.jetblacksoftware.com/) (the "Website"), and user support Centre (support@jetblacksoftware.com) (the "Support Centre"). Together the App(s), the Website and the Support Centre are referred to as the "Online Services".

If you have any questions or comments about this Privacy Policy, please contact our Data Protection Officer at support@jetblacksoftware.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.

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 Apps.


2. INFORMATION WE MAY COLLECT ABOUT YOU

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


Information provided by you when using the Apps

("Basic Information")

We will collect the following information from you when you use our Apps:

▪ your mobile device's unique device ID (Device ID) (if applicable);

▪ your Google Play ID (if applicable); and

▪ your user preferences.


Information collected when you purchase any of the Apps online

("Purchase Information")

When you purchase any of the Apps online we may collect the following information from you:

▪ your name;

▪ your Order ID;

▪ your email address;

▪ your IP Address;

▪ the date of Purchase;

▪ the EU VAT country (if applicable); and

▪ a log of the download date/time of the purchased App.


Contact information provided by you when you contact us or use the Support Centre

("Contact Information")

We may ask you for, or you may submit, certain contact information to us whenever you contact us through the Support Centre or via support@jetblacksoftware.com.

This may include:

▪ your email address; and

▪ your name.


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:

▪ how many times you visit the Website;

▪ which pages you go to;

▪ traffic data;

▪ your IP and MAC address;

▪ your internet service provider;

▪ your Device ID;

▪ your user ID;

▪ your device operating system & version;

▪ your device make and model;

▪ app session time start, end and duration;

▪ the country of your device;

▪ A/B testing statistics; and

▪ identification of crashes and defects (including optional personal description of problem).

We use the following third party analytics providers:

▪ Google Analytics

Google may collect analytics data on our behalf and in accordance with our instructions, and their applicable privacy notice. If you would like to find out more about the way Google collect and process this information this is likely to be set out in their privacy policies and/or terms and conditions. Please refer to https://policies.google.com/privacy.


Information collected for the purposes of providing advertising

("Advertising")

Android Advertising ID

Some of our Apps are provided for free and supported by in-app advertising. These Apps make use of an Android Advertising ID.

We fully comply with Google's policy on its use:

▪ We use it only for advertising and user analytics.

▪ We do not associate it with any personally-identifiable information or other identifiers.

▪ If reset, we do not associate it with any previous advertising identifier or data derived from a previous advertising identifier.

▪ We respect the "Opt out of Interest-based Advertising" and "Opt out of Ads Personalisation" settings.

▪ Collection and use of the advertising identifier is transparently disclosed to users here in our privacy policy.

▪ We abide by the terms of use and use it only in accordance with these terms.



3. WHY WE COLLECT INFORMATION ABOUT YOU


To provide the Online Services to you

We will use information about you (including Basic Information and Analytics) for delivering our Apps 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 an App, and to ensure the Apps deliver the features promised and function properly, so that you have the best experience when using any one of our Apps and using the Online Services.


To help us improve the Online Services and fix any problems

We may process information about you (including Basic Information, Purchase Information, and Analytics) so that we can analyse and improve our Apps 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 using any of our App(s) and using the other Online Services; (ii) improving the quality of our Online Services, and providing a better experience to our users; and (iii) identifying and correcting any bugs in the Apps and Online Services.


To respond to your enquiries and requests for support and to enable you to use the Support Centre

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


To prevent fraud and illegal activity

We process personal data (including Purchase Information) 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.


4. COOKIES

A cookie is a text file placed onto your device when you access our Apps or Website. We use cookies and other online tracking devices such as web beacons, and flash object storage to deliver, improve and monitor our Website and Apps, including in the following ways:

Authentication: To log you into our Website and Apps and keep you logged in.

E-commerce: To keep track of items you have purchased in our Apps or which you are interested in, and to take you through the checkout process.

Preferences: To remember information about you such as your preferred language and configuration.

Analytics: To help us understand how you use our Apps and Website, and how often, so we can improve them to deliver a better experience for our users. To carry out research and statistical analysis to help improve our content, products and services.

Advertising: To deliver ads which are more relevant to your interests, and to measure their performance.


The information we obtain from our use of cookies will not usually contain your personal data. Although we may obtain information about your device such as your IP address, your browser and/or other internet log information, this will not usually identify you personally.

Our Website should display a notice alerting you to our use of cookies and other similar technologies and linking to this privacy policy. If you use our Website after this notice has been displayed to you we will assume that you consent to our use of cookies or similar technologies for the purposes described in this privacy policy.

Please note that if you choose to disable cookies, or similar technologies, on your device you may be unable to make full use of our Apps and Website.

We work with third parties who may also set cookies on our Website, for example Google Analytics, Google Adsense, Facebook, Twitter and YouTube, which we use to display video content, enable social networking functionality and sharing, to deliver ads, and to monitor how visitors use our Apps and Website. These third party suppliers are responsible for the cookies they set on your device.

If you want to learn about how to opt out of Google's use of cookies, please visit https://tools.google.com/dlpage/gaoptout/ or your Google Ads Settings (https://www.google.com/settings/u/0/ads/authenticated). The Google Analytics terms of service can be accessed here: www.google.co.uk/analytics/terms/us.html. For further information please visit the website of the relevant third party.


5. 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, you will be notified via, account message and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

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 Jetblack, our customers, or others.

Digital Content Stores: Where the Apps are downloaded through Google Play, we may disclose your personal information to Google for the purposes of facilitating any payments made through these platforms.


6. 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@jetblacksoftware.com.


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).


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 Jetblack 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.


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 a commonly used, machine-readable and interoperable format. Where it is technically feasible, you can ask us to send this information directly to another IT system provider if you prefer.


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.


7. 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.

Purchase Information is retained indefinitely.


8. 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@jetblacksoftware.com.


9. SECURITY

We will take all reasonable technical and organisational precautions to prevent the loss misuse or alteration of your personal information.

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.


10. INTERNATIONAL DATA TRANSFERS

It is possible that your personal information may be transferred outside of the EEA by Google. 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.

Our web server is hosted by Gandi.net located in Paris, France.

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@jetblacksoftware.com.


CONTACT INFORMATION

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

©2018 Jetblack Software Limited. All trade marks are the property of the relevant owners. All rights reserved.