Thank you for playing a Charlie Studios, LLC (“Charlie Studios”, “we”, or “us”) game. Your privacy is important to us and we take our responsibility of caring for it seriously. This Privacy Policy describes what information Charlie Studios collects when you use our products. By using our products, you consent to this policy. This policy may change from time to time, so please review it frequently. Your continued use of Charlie Studios’ products signifies your acceptance of changes to this Privacy Policy.

1. INFORMATION WE COLLECT

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The information we collect depends on what products you use and how you use them. The controller of the personal information collected is:

Charlie Studios LLC

2201 Menaul Boulevard NE

Suite A, Albuquerque, NM 87107 USA

A. Information You Give Us Directly

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We collect information you provide us, including information you provide when seeking help from us, such as your name, email address, and records of the issues you experience.

When you participate in social features through a Social Media Site, the information you disclose is public information. We may store and access it, and it may be read, copied, collected, or used by other users without your consent. Please make sure your privacy settings on the Social Media Sites you use reflect your preferences.

B. Other Information We Collect When You Use Our Products

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We collect other information automatically when you use our products, including:

• IP address;

• Mobile and other hardware or device identifiers or the advertising identifier;

• Browser information, including your browser type and the language you prefer;

• Referring and exit pages, including landing pages and pages viewed;

• Platform type;

• Your location, down to the resolution of city;

• Information about your media, device, hardware and software, such as your hardware settings and components;

• Details about what Charlie Studios products you use and your use of them; and

• Device event information, including crash reports, request and referral URLs and system activity details (e.g. whether you encountered an error playing our games or lost Internet access).

We may also collect and store information locally on your device, using mechanisms like cookies, browser web storage and application data caches.

To comply with local laws, we may need to collect your IP address to help us determine your country of residence. In that case, your IP address may be sent to a server that we control, for evaluation purposes, but will not be stored or further processed. We also use your device settings to determine the country where you are located as a way to respect privacy laws specific to your location. We do not collect your precise location, at a level more granular than your city, without your explicit consent.

C. Information Provided to Us by Third Parties

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If you play or purchase our games or in-app purchases on your mobile device and/or tablet, we receive information about you from the app stores and other mobile platform providers. This information may include your username and/or device identification number and the fact that you made a purchase, for instance, but does not include any sensitive or financial information. Some of our mobile platforms also may send information to us that you authorize them to provide, through systems such as Google Play Services or Apple Game Center.

We may receive information from third parties, like Facebook or other Social Media Sites, when you use these services in connection with our products. We also may receive information from third parties to supplement the information we receive from you. A representative list of these types of third parties can be found below. We also may use information from third parties, for instance, to help us understand your approximate geolocation via your IP address for tax purposes, or to customize certain services to your location, and for fraud and/or abuse prevention purposes.

2. HOW WE COLLECT INFORMATION

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We collect some information from you when you provide it to us directly, such as via an online form or when you communicate with our customer support team. We and third parties also use certain technologies, described below, to deliver positive customer experiences.

Our products change over time and those changes are reflected in new versions that are available to download from the Apple App Store, Google Play Store, and other official stores. Charlie Studios recommends that you always use the latest version of our products to guarantee you have the most secure, privacy-oriented, and engaging experience possible.

Charlie Studios cannot guarantee the integrity of versions of products that are installed from unofficial channels and does not support, provide customer support, or provide privacy guarantees for those unofficial versions. If you are using a version of one of our products that was installed from an unofficial channel or is no longer supported, we encourage you to remove it from your device as soon as possible and install an officially distributed version.

A. Cookies and Similar Technologies

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We use cookies and similar technologies to help us understand things like what web pages, features, or ads you view and what games you play. This information helps us measure the effectiveness of our advertising, make sure you don’t see the same ad repeatedly and otherwise enhance your user experience. We use other technologies for similar purposes as a cookie, such as web beacons, pixels and other similar technologies. Your Internet web browser enables you to opt out of tracking with cookies. Please visit http://www.allaboutcookies.org or the documentation for your individual web browser if you would like to learn more about managing your cookie preferences.

We use Internet log files (which contain technical data such as your IP address) to monitor traffic on our products, troubleshoot technical problems, detect and prevent fraud, and to enforce our Privacy Policy. Our legal basis for this collection and processing is to protect our legitimate business interests and therefore we do not seek consent to collect your information for these purposes. You may contact us if you have additional questions about these use cases.

B. Analytics Technologies

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We use our own game servers and internal and third party analytic technologies to collect information about how you use our products, your computer or device and the health of our products.

For example, Charlie Studios may collect and store data from your device when you use our products. This information includes technical and related information about your computer or device and operating system (such as IP address and device ID), information about your feature usage, gameplay and usage statistics and system interactions. If you play a game offline, this data will be stored on your device and may be transmitted to Charlie Studios when your device connects to the Internet. If you participate in online components of our games, such as leaderboards, Charlie Studios may also collect, use, store, transmit, and publicly display statistical data regarding game scores and achievements.

Third party analytics services integrated into our products may combine the information they collect in connection with Charlie Studios’ services with information they have independently collected over time and across different websites and applications. Many of these companies collect and use information under their own privacy policies. A list of the third party analytics companies that operate in our products can be found in the Appendix below.

C. Fraud Prevention Technologies

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When you use a Charlie Studios product, we or third parties may use cookies and similar technologies, or collect data about your machine or device, for fraud prevention, security, and authentication purposes. Our legal basis for collecting and processing your information for these purposes, without your consent, is that we consider them vital to protecting our legitimate business interests.

3. HOW WE USE YOUR INFORMATION

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We use your personal and non-personal information, both individually and in aggregate, in the following ways:

To operate our business and to enhance and personalize your game experience, including to:

• Operate, improve, and develop our games and services;

• Help you find your friends or tell your friends about a Charlie Studios product;

• Facilitate sharing on social networks;

• Serve and measure the effectiveness of advertising;

• Measure the health of our services;

• Provide game experiences customized to your preferences;

• Facilitate your gameplay on multiple devices, when available;

• Identify, fix, and troubleshoot bugs and service errors;

• Provide software updates;

• Save game progress and stats;

• Adhere to your preferences and to deliver dynamic content; and

• Help keep our services safe and fair, resolve disputes, investigate and help curb fraud and illegal behavior, comply with the law, and to enforce our agreements and policies.

To provide you support, including to:

• Help identify and troubleshoot problems with your account or games;

• To survey your opinions through surveys or questionnaires;

• Communicate with you and respond to your specific requests or questions; and

• Manage and send you confirmations and important information about your products.

To personalize our communications with you, including to:

• Present offers or information relating to games you might like;

• Make recommendations to you; and

• Personalize advertising for you and deliver targeted marketing, service updates and promotional offers.

4. HOW WE PROCESS YOUR INFORMATION

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Charlie Studios uses analytics services to understand how users engage with our products. Our analysis relies on your consistent device identifier, or identifier for vendor (IDFV) on Apple devices, so that we can track your behavior over time and develop an understanding of how you prefer to interact with our products. If you have more than one Charlie Studios product installed on your device, those products may share the same identifier value. This enables us to develop an understanding of how you engage with all of the Charlie Studios products you have installed. The identifier value is provided to Charlie Studios through the operating system on your device. In the course of processing your data, we may do any of the following:

• Analyze your behavior in our products over time;

• Analyze your behavior in aggregate;

• Combine your information with the information of other players to create anonymized aggregate reports that allow us to understand large-scale behavior trends;

• Analyze your information to understand how well our products perform on your device or to investigate bugs, crashes, and other technical issues;

• Combine your information with the information of other players to create customer segments based on behavior in our products or location-based behavior;

• Use analysis of your behavior in our products to provide you with customized gameplay experiences;

• Use your device identifier to enroll you in an A/B test. An A/B test is a type of simple behavioral experiment wherein groups of users are provided with slightly different experiences in our products so that we can research and analyze which of the experiences is the most compelling to users of our products; and

• Analyze your behavior in the context of an A/B test.

European Economic Area (EEA) Only:

Per requirements under the EU’s General Data Protection Regulation (GDPR), we log your consent state for compliance purposes. This information is stored on servers hosted in the EU and is used solely for GDPR compliance. Your device identifier is stored along with your consent status. If you consent to personalized advertising, your device advertising identifier also is stored in case we need to be able to access it to assist you with data portability or erasure requests. Your device advertising identifier is not stored in our consent logging database if you do not consent to personalized advertising.

5. INFORMATION WE SHARE WITH THIRD PARTIES

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We do not share personal information that directly identifies you (such as your name, email, or postal address) with independent third parties without your consent, unless it is required by law or we determine that disclosure is critical to protect our rights, property, or operations or to protect our players or third parties. We may share anonymous (including pseudonymous identifiers) or aggregated information, or other data that does not directly identify you, with third parties, for instance your persona on leaderboards or to show trends about use of our products.

If you contact us, your message will be processed through Google’s G Suite email service.

We employ third parties located in and outside of your country of residence (including outside of the European Economic Area (EEA)) to collect or process personal information on our behalf for various reasons, such as conducting market surveys or analyzing gameplay event data. When our third party agents or service providers collect or receive personal information, we require that they use the data only on our behalf and for purposes consistent with this policy.

However, in the event of a reorganization, divestiture, merger, sale or bankruptcy, we may transfer all information we collect to the relevant third party and will obtain your consent to do so if required by law.

We do not control information sent from your browser to third parties, such as advertising networks and analytics companies that receive information in the normal course of your Internet activity. When third party technologies or social tools are integrated into our products, those third parties may collect information when you use our products. An example is the Facebook “Like” button.

European Economic Area (EEA) Only:

• We use your device settings and SIM card registered country to determine whether we believe you are located in the EEA. That processing is done on your device.

• If your device indicates that you are located in the EEA:

• We prompt you for your age to determine whether you are old enough to lawfully consent to tracking of your device identifier and advertising identifier; and

• If you are of legal age to consent in your country of residence, we prompt you for consent to serve personalized advertising.

6. INTERNATIONAL TRANSFER

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Personal information we collect may be stored and processed for the purposes set out in this Privacy Policy in the United States or any other country in which Charlie Studios, its business partners, or third party agents operate. By using our products, you consent 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.

7. HOW WE PROTECT YOUR PERSONAL INFORMATION

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We have put in place reasonable controls designed to help safeguard the personal information we collect via our products. However, no security measures are perfect and we cannot assure you that personal information that we collect will never be accessed or used in an unauthorized way.

8. AGE GUIDELINES AND CHILDREN’S PRIVACY

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Protecting children’s privacy is extremely important to us. We also encourage parents and/or guardians to play an active role in their children’s online experiences at all times.

Charlie Studios’ products are not intended for children under the age of 13 and we do not knowingly collect any personal information from children under the age of 13. If you are a resident of the European Economic Area (EEA) under 16 years of age or a minor in your country of residence, please ask your legal guardian’s permission to use or access Charlie Studios’ products. Additional age-based privacy information specific to California residents is set forth below in the Privacy Notice for California residents. If you believe Charlie Studios has inadvertently collected information about your child, please contact us so we can promptly remove the information.

9. DATA RETENTION

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Charlie Studios has a policy of retaining information we collect for a period of up to 180 days. During the period when we hold Information, we may transform and aggregate it such that it no longer is personally identifiable. We may retain the de-identified aggregate data products for more than the retention period to support business critical needs.

Uninstalling Charlie Studios applications from your devices does not cause the data that we possess to be deleted. It remains subject to the same data retention and expiration policies.

10. LEGAL BASIS FOR PROCESSING (EUROPEAN ECONOMIC AREA ONLY)

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If you are a resident of the European Economic Area (EEA), our legal basis for collecting and using the personal information will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where: (i) we have your consent to do so, (ii) where we need the personal information to perform a contract with you (e.g. to deliver a service you have requested), or (iii) where the processing is in our legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms). In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.

If we ask you to provide personal information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interests which are not already described in this Privacy Policy, we will make clear to you at the relevant time what those legitimate interests are.

A. Technical and usage Information

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Charlie Studios may collect in-game technical or usage data or gameplay analytics for players. Note that Google Play Services, Apple Game Center, and other platform-level services may also collect gameplay analytics if you are located within the EEA. Please see your device-level settings for more information about how to disable those services. Charlie Studios considers any data specific to your use of our apps that is collected or processed by Charlie Studios or through Google Play Services or Apple Game Center to be in our legitimate business interests.

B. Right to erasure

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Under the GDPR you have a right to have Charlie Studios and our third party partners erase the personal information we have collected from you without undue delay.

C. Right to portability

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Under the GDPR you have a right to request a copy of the personal data Charlie Studios and our third party partners have collected from you.

D. Right to withdraw consent

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Where we rely on your consent to process the personal information, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal. To change your consent status, please contact us or send us a letter at Charlie Studios LLC, 2201 Menaul Boulevard NE, Suite A, Albuquerque, NM 87107 USA.

E. Right to object

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Under the GDPR, you have the right to object to the processing of your data. If you wish to object to the processing of your data, please contact us or send us a letter at Charlie Studios LLC, 2201 Menaul Boulevard NE, Suite A, Albuquerque, NM 87107 USA.

11. PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

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This Privacy Notice for California Residents applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). We may use reasonable proxies, such as time zone or other data where we do not know the state of residence of a person, to determine whether a user is a California Resident – we do not ask users of our games for their address or state of residence. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Notice.

Where noted in this Notice, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some its requirements.

A. Information We Collect

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We collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”).

Personal information does not include:

• publicly available information from government records or

• deidentified or aggregated consumer information.

In particular, we have collected the following categories of personal information from consumers within the last 12 months: