PRIVACY NOTICE FOR THE USERS OF MOBILE APP

This notice is being shared with you in order to describe how RTB House processes your personal data with regard to the use of the App as well as to follow transparency obligations arising from personal data laws specifically art 13 and/or 14 of the General Data Protection Regulation (‘GDPR’).

When we refer to the “App” it means one of the following mobile applications:

• Foxy Match - available only on Android;
• Triple Find 3D - available on Android and iOS;
• Used Car Dealer - available on Android and iOS;

DATA CONTROLLER

The controller of your personal data is RTB Marketing & Tech Services Ltd. with its registered seat in Nicosia Cyprus at Kyriakou Matsi 18 2nd Floor Egkomi Nicosia 2408 hereinafter: “we” “us” or “RTB House”.

Data Protection Officer (DPO) - Katarzyna Kamińska dpo@rtbhouse.com

CONTACT DETAILS

You can contact us in the following manner: (1) by mail at Nicosia Cyprus at Kyriakou Matsi 18 2nd Floor Egkomi Nicosia 2408; (2) by e-mail at contact@bestgames.ai; or (3) by our DPO’s e-mail at dpo@rtbhouse.com.

CATEGORIES OF COLLECTED DATA AND PURPOSES FOR THE PROCESSING

We process the following categories of personal data:

• IP addresses;
• Device characteristics;
• Device identifiers;
• Probabilistic identifiers;
• Authentication-derived identifiers;
• Browsing and interaction data;
• User-provided data;
• Non-precise location data;
• Privacy choices.

We process the personal data for the following purposes:

• Using the App (on the basis of contractual obligations) - We process your data which is necessary to ensure the proper functionality of the App.
• Store and/or access information on a device (on the basis of your consent) - Cookies, device or similar online identifiers (e.g. login-based identifiers, randomly assigned identifiers, network-based identifiers) together with other information (e.g. browser type and information, language, screen size, supported technologies, etc.) can be stored or read on your device to recognise it each time it connects to an app or to a website for one or several of the purposes presented here.
• Use limited data to select advertising (on the basis of your consent) - Advertising presented to you on this service can be based on limited data such as the website or app you are using, your non-precise location, your device type, or which content you are (or have been) interacting with (for example, to limit the number of times an ad is presented to you).
• Create profiles for personalised advertising (on the basis of your consent) - Information about your activity on this service (such as forms you submit, content you look at) can be stored and combined with other information about you (for example, information from your previous activity on this service and other websites or apps) or similar users. This is then used to build or improve a profile about you (that might include possible interests and personal aspects). Your profile can be used (also later) to present advertising that appears more relevant based on your possible interests by this and other entities.
• Use profiles to select personalised advertising (on the basis of your consent) - Advertising presented to you on this service can be based on your advertising profiles, which can reflect your activity on this service or other websites or apps (like the forms you submit, content you look at), possible interests, and personal aspects.
• Create profiles to personalise content (on the basis of your consent) - Information about your activity on this service (for instance, forms you submit, non-advertising content you look at) can be stored and combined with other information about you (such as your previous activity on this service or other websites or apps) or similar users. This is then used to build or improve a profile about you (which might, for example, include possible interests and personal aspects). Your profile can be used (also later) to present content that appears more relevant based on your possible interests, such as by adapting the order in which content is shown to you so that it is even easier for you to find content that matches your interests.
• Use profiles to select personalised content (on the basis of your consent) - Content presented to you on this service can be based on your content personalisation profiles, which can reflect your activity on this or other services (for instance, the forms you submit, content you look at), possible interests, and personal aspects. This can, for example, be used to adapt the order in which content is shown to you so that it is even easier for you to find (non-advertising) content that matches your interests.
• Measure advertising performance (on the basis of your consent) - Information regarding which advertising is presented to you and how you interact with it can be used to determine how well an advert has worked for you or other users and whether the goals of the advertising were reached. For instance, whether you saw an ad, whether you clicked on it, whether it led you to buy a product or visit a website, etc. This is very helpful to understand the relevance of advertising campaigns.
• Measure content performance (on the basis of your consent) - Information regarding which content is presented to you and how you interact with it can be used to determine whether the (non-advertising) content, e.g. reached its intended audience and matched your interests. For instance, whether you read an article, watch a video, listen to a podcast, or look at a product description, how long you spent on this service and the web pages you visit, etc. This is very helpful to understand the relevance of (non-advertising) content that is shown to you.
• Understand audiences through statistics or combinations of data from different sources (on the basis of your consent) - Reports can be generated based on the combination of data sets (like user profiles, statistics, market research, analytics data) regarding your interactions and those of other users with advertising or (non-advertising) content to identify common characteristics (for instance, to determine which target audiences are more receptive to an ad campaign or to certain contents).
• Develop and improve services (on the basis of your consent) - Information about your activity on this service, such as your interaction with ads or content, can be very helpful to improve products and services and to build new products and services based on user interactions, the type of audience, etc. This specific purpose does not include the development or improvement of user profiles and identifiers.
• Use limited data to select content (on the basis of your consent) - Content presented to you on this service can be based on limited data such as the website or app you are using, your non-precise location, your device type, or which content you are (or have been) interacting with (for example, to limit the number of times a video or an article is presented to you).
• Ensure security, prevent and detect fraud, and fix errors (on the basis of our legitimate interest) - Your data can be used to monitor for and prevent unusual and possibly fraudulent activity (for example, regarding advertising, ad clicks by bots) and ensure systems and processes work properly and securely. It can also be used to correct any problems you, the publisher, or the advertiser may encounter in the delivery of content and ads and in your interaction with them.
• Deliver and present advertising and content (on the basis of our legitimate interest) - Certain information (like an IP address or device capabilities) is used to ensure the technical compatibility of the content or advertising and to facilitate the transmission of the content or ad to your device.
• Save and communicate privacy choices (on the basis of our legitimate interest) The choices you make regarding the purposes and entities listed in this notice are saved and made available to those entities in the form of digital signals (such as a string of characters). This is necessary in order to enable both this service and those entities to respect such choices.
• Defend our rights or pursue claims (on the basis of our legitimate interest) - This may happen, e.g., if you file a complaint regarding the operation of the App or in case we discover an external attack in our App;
• Answer your queries (on the basis of our legitimate interest or legal obligations) - For this purpose, we use the data you provide us voluntarily. For example, if you send us a message via a contact form available on our App or in a direct message via e-mail, we will process your contact data and the content of such message to handle your query, provide you with relevant information and remember what the query was about.

LEGAL BASIS FOR THE PROCESSING

The legal basis for processing your personal data is:

• Necessity for the performance of a contract to which you are subject when using the App (“contractual obligations”);
• Necessity to comply with legal obligations to which the controller is subject within the scope of the duties and responsibilities arising from provisions of law (“legal obligations”);
• Legitimate interests pursued by the controller (“legitimate interest”), specifically the legitimate interest to defend our rights and if required pursue claims; or
• Your consent given to us via the Consent Management Platform (CMP) within the App (“consent”). CMP is a tool that helps us to collect and manage your consent that is required for processing of your personal data.

RECIPIENTS OF PERSONAL DATA

RTB House may disclose your personal data to other entities such as its clients, business partners, or subcontractors. Sometimes we will also share your data with other companies from the RTB House corporate group (e.g., for administrative purposes). We may share your data with the following categories of third parties within our Apps:

• ironSource Mobile Ltd. (ironSource) - Role of processing: Processor. Purpose of processing: Advertising services (mediation platform). Location of personal data processing: European Economic Area, Israel, United States, United Kingdom, Switzerland. Link to the ironSource privacy policy. Applicable to the following Apps: i) Triple Find 3D; ii) Used Car Dealer; iii) Foxy Match. Processed personal data: Please see the ironSource’s privacy policy.
• GameAnalytics ApS (Game Analytics) - Role of processing: Processor. Purpose of processing: Analytics, AB testing. Location of personal data processing: European Economic Area, United States, United Kingdom, Switzerland. Link to the Game Analytics privacy policy. Applicable to the following Apps: i) Triple Find 3D; ii) Used Car Dealer; iii) Foxy Match. Processed personal data: device characteristics, device identifiers, non-precise location data. For all categories of processed personal data please see Game Analytics’ privacy policy.
• AppsFlyer Ltd. and its affiliates (AppsFlyer) - Role of processing: Processor. Purpose of processing: Analytics. Location of personal data processing: European Union. Link to the AppsFlyer privacy policy. Applicable to the following Apps: i) Triple Find 3D; ii) Used Car Dealer; iii) Foxy Match. Processed personal data: Please see AppsFlyer’s privacy policy.
• PlayFab Inc. (Playfab) - Role of processing: Processor. Purpose of processing: Social services (via Azure plug-in), Analytics. Location of personal data processing: European Economic Area, United States. Link to the Playfab privacy policy. Applicable to the following Apps: i) Triple Find 3D; ii) Used Car Dealer; iii) Foxy Match. Processed personal data: IP addresses, device characteristics, device identifiers, probabilistic identifiers, authentication-derived identifiers, browsing and interaction data, user-provided data. For all categories of processed personal data please see Playfab’s privacy policy.
• Meta Platforms Inc. (Facebook) - Role of processing: Processor. Purpose of processing: Friends Avatar. Location of personal data processing: European Economic Area, United States. Link to the Facebook privacy policy. Applicable to the following Apps: i) Triple Find 3D; ii) Used Car Dealer; iii) Foxy Match. Processed personal data: Please see Facebook's privacy policy.
• Google LLC (Crashlytics - Firebase service) - Role of processing: Processor. Purpose of processing: Collecting information about the bugs and crashes. Location of personal data processing: European Economic Area, United States. Link to the Crashlytics privacy policy. Applicable to the following Apps: i) Triple Find 3D; ii) Used Car Dealer; iii) Foxy Match. Processed personal data: Please see Crashlytics' privacy policy.

In cases where it is necessary or required by law, we may also share your personal data with law enforcement agencies, supervisory authorities, or in court proceedings.

TRANSFERS TO OTHER COUNTRIES

RTB House may occasionally transfer your data to a country outside of incorporation of RTB House, including outside the European Economic Area (EEA). In such cases, we will take measures to ensure the transfer is in compliance with applicable laws. Specifically, the transfer can be allowed if one of the following is applicable:

• The country has been declared as offering an adequate level of protection through a European Commission adequacy decision;
• Binding Corporate Rules (BCR) are in place (for inter-company transfers);
• Standard Contractual Clauses (EU model-clauses) are used; or
• The entity complies with the Data Privacy Framework.

RETENTION PERIOD

RTB House will store your personal data until the purposes for its collection are fulfilled. After its termination, we will keep the data until the lapse of the period of limitation of claims under applicable laws. If a dispute arises between you and RTB House, we will store your personal data until it is resolved (including enforcement of claims). Please be advised that our business partners may have different data retention rules. For more information, please consult their privacy policies (linked in section RECIPIENTS OF PERSONAL DATA).

DATA SUBJECT’S RIGHTS

You have the right to know about the data processing we conduct and what personal data we have about you. If your personal data is wrong or incorrect, you can tell us and we will fix it. Until that happens, you have the right to restrict the processing and it will be limited to storage only for that time. If you no longer wish to have your personal data processed, you can also exercise your right to object or ask for its erasure. In certain situations, we may still keep some of your personal data even after your request. This may happen due to the legal obligation imposed on us or in order to meet our business needs.

If we process your personal data by automated means and on the basis of consent or of fulfilling a contract, you have a right to receive personal data that you have provided to us in a machine-readable format. You can also ask us to have this personal data transmitted directly from us to another controller where technically feasible. When we process you on the basis of consent, you have the right to withdraw it at any time. Withdrawal of consent does not affect the legality of the processing done up to that point. To know more about your data protection rights and how to exercise them, you can contact our data protection officer at: dpo@rtbhouse.com

AUTOMATED DECISION-MAKING

Within the scope of processing that we undertake as a data controller, we conduct activities that may be deemed “profiling” of your personal data only to a very limited extent (i.e., analysis of data regarding your interactions with our App). In any case, the profiling does not produce any legal effects on you or similarly significantly affect you. We will not use your data for automated decision-making.

SOURCE OF PERSONAL DATA

We obtain your personal data directly from you or through your interactions with our App.

OBLIGATION TO DISCLOSE PERSONAL DATA

You need to provide us with your personal data because it is necessary to enter into a contract with you. If you don’t provide your personal data to us despite the above, you may face the following possible consequences: not being able to use the App.

RIGHT TO LODGE A COMPLAINT

You have the right to file a complaint with the authority that oversees data protection for RTB House or for the country where you live. You can find the contact information for these authorities on this website.