PRIVACY POLICY

Last update: October 28th, 2024

Welcome to the privacy policy of Speedax Limit!

First of all, thank you for playing our games!

This document describes how and why Speedax Limit collects and processes your personal data (the "Data") when you interact with our mobile games (the "Games") or our speedaxglobal.net website (the "Website"). Hereinafter, we refer to both the Games and the Website as the "Services".

We act as a data controller for the processing of personal data under applicable privacy laws, including the General Data Protection Regulation ("GDPR").

Please note that this policy only applies to information collected and/or processed received by Speedax Limit through your use of the Services.

Please note you must be over a certain age to play our Games and use our Services, depending on where you live. If you are under the legal age in your country, please do not play our Games or use our Services.

If you have any questions, feel free to contact us at jumpingtorch@outlook.com.

1. Who we are

Speedax Limit and its affiliated companies ("Speedax Limit", "we", "our", "us") develop and publish mobile games and operate related websites and services (collectively, the "Services").

Speedax Limit is a Nigeria company and having its main place of business located at ST THERESA Catholic Church ABOR, UDI - 401114.

2. Our Games

2.1 Why do we collect or use your Data

When you install and play Speedax Limit's Games, we can collect and process some of your Data based on your express consent or for different purposes.

In cases in which Speedax Limit is a data "controller" (meaning, when Speedax Limit is the main decision-maker, exercising overall control over the purposes and means of the processing of your Data), Speedax Limit only uses your Data with a legal basis for doing so, such as:

- for the performance of our contract with you;

- where you have given your consent for a specific purpose;

- to comply with our own legal and regulatory obligations;

- for our legitimate interests or those of a third party.

A legitimate interest happens when we have a business or commercial reason to use your personal information and includes our own interests or the interests of third parties, and can cover commercial interests (e.g. sustain our free-to-play model), so long as this is not overridden by your own rights and interests.

In cases we are required under law or regulation to obtain your consent for the processing of your personal information, we will ask for your consent.

Here's why Speedax Limit may collect your personal information and the legal basis we rely on in each case :

• To provide and operate our Games: Contractual Necessity
• To show personalized ads, based on your preferences and interests : Consent
• To gather and provide third-party analytics, i.e. data collected through our applications may be shared with third-party partners that provide Speedax Limit's with analytics services : Consent
• To gather first party analytics, i.e. Data collected through our applications may be used for the purposes of Speedax Limit's internal analytics tool to understand how users interact with our applications to continuously improve them. This Data is not shared with third party partners : Legitimate interest
• Attribution, i.e. match an advertisement of one of our Games you may have seen in another application with the install of such Game : Legitimate interest
• To ensure the functionalities of our applications (for instance, debug, maintain the apps) : Legitimate interest

For all data processing activities that rely on users' consent, you can always change your preferences and withdraw your consent in the privacy settings of any of our applications.

Note that, if you opt-out, you will still be able to see ads in our applications and some of our partners may still serve ads to you.

2.2. Data we collect

When you use any of Speedax Limit's applications on a mobile platform and, for the above specific purposes, we may collect and process (store, share with our partners, process for analytics purposes) the following Data strictly for the purposes identified above:

Data collected automatically by Speedax Limit

• Data about your player account, game progress, which includes a unique internal ID;
• Data pertaining to your activities in game and the way you interact with our apps (for instance, gameplay data, how and when you use our applications...);
• Identifiers, such as your mobile device identifiers, advertising ID ...;
• Your location at a city/region level (based on your Internet Protocol - "IP" - address);
• Technical information about the device you use and your connection (for instance, the operating system, device model, type of connection, language, timezone);
• Technical data pertaining to the app you're using (for instance, the app version you've installed);
• Data pertaining to the advertising served in our applications (for instance, number of ads you've clicked on).

2.3. How is your Data collected

Most of the personal information we process via our Games comes directly from you.

In addition, we may also collect personal information:

• from our business partners SDK's, as outlined below;
• from any other third party to whom you have given your consent.

2.4. With whom may we share your Data

When you consent to the collection of Data for advertising and third party analytics purposes, we may share the data listed above with the following categories of recipients.

2.5. How long do we keep your Data

We keep the Data collected and processed for the purposes described in this policy only as long as necessary.

We will also retain and use your information for as long as is required in order to comply with our legal obligations.

2.6. Our policy regarding children

You must be over a certain age to play our Games and use our Services, depending on where you live. For the list of age restrictions by country, you can refer to this page published by the European Union Agency for Fundamental Rights.

We do not knowingly or willingly collect or solicit personal information from anyone under the applicable age, or knowingly allow such persons to use our Services.

If you are under the legal age in your country, please do not play our Games or use our Services.

In the event that we learn that we have collected personal information from children under the legal age, we will delete that information as quickly as possible. If you believe that we might have any information from or about children under the legal age please contact us at jumpingtorch@outlook.com.

2.7. Data storage and International transfers

We store our Data on servers located in Europe via Amazon Web Services or Google Cloud Platform.

To deliver Services to you, it is sometimes necessary for us to share your Data outside of your country or region, e.g.:

- with our offices and group companies;
- with our service providers.

We may therefore transfer information that we collect about you to our third-party partners across borders, including outside of the European Economic Area (the "EEA").

Please note that these countries outside of the EEA may not have the same data protection laws as your own jurisdiction. We take steps to ensure that there are adequate safeguards and mechanisms in place (including the use of EU Standard Contractual Clauses) to allow the transfer of your information outside of the EEA.

We also make sure any third parties we share information with have an adequate transfer mechanism in place, as well.

2.8. Security

We take appropriate security and technical measures to protect your information from unauthorised access, loss and misuse.

In addition, we request that our suppliers who process personal information on our behalf take a range of security measures designed to help protect your personal information and maintain an appropriate level of security.

3. Your choices and rights

Under data protection law, you have certain rights in connection with your personal information and how we handle it. You can exercise these rights at any time by contacting us at jumpingtorch@outlook.com :

- Right of access. You have the right to know what information we hold about you and in some cases to have the information communicated to you. If you wish to exercise this right please contact us letting us know that you wish to exercise your right of access and what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information.
- Right to rectification. You have the right to ask us to rectify personal information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- Right to erasure. You have the right to ask us to erase your personal information in certain circumstances.
You can contact us, as indicated in the "Contact" section below, in order to have the data previously collected by Speedax Limit on you and/or your device permanently erased.
In addition, in order for your data not to be collected anymore (for the future), you can, in the following order:

• Activate "Limit Ad Tracking" (LAT) in your device settings to opt-out of having an ID for Advertisers and don't see specific ads targeted at you; and
• Desinstall our Games; and
• Reinstall our Games.

Where we delete personal information about you, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights. We may also retain your information in an anonymised form.
- Right to restrict processing. In some cases, you may have the right to request a restriction of the processing of your personal data, such as when you are disputing the accuracy of your data held by us.
- Right to data portability. When the processing of your personal data is based on consent or contract, you may have the right to request that personal data that you have provided to us is provided to another data controller of your choice in a portable format.
- Right to object to processing. You have the right to object to the processing of personal data about you which is processed on the grounds of legitimate interests.

You are not required to pay any charge for exercising your rights. If you make a request, we have one month to respond to you.
Please contact us at jumpingtorch@outlook.com.

If you're a user under CCPA or other US state laws

In order to comply with CCPA or other US state laws, this paragraph aims at disclosing the mandatory information.

Sharing and Selling of Personal Data

We may share your data with third-party service providers such as:

• Advertising networks
• Analytics providers
• Attribution platforms

Under the CCPA, "selling" includes disclosing personal data for monetary or other valuable consideration. While we do not sell your personal data in the traditional sense, some of our ad partners may process data in a way that qualifies as a "sale" under the CCPA.

We share data with our partners for advertising and analytics, subject to appropriate safeguards. You have the right to opt-out of such selling and sharing.

4. Contact Information

You may exercise your rights in the Games or by contacting us at:

Email: jumpingtorch@outlook.com

Postal Address:

ST THERESA

Catholic Church

ABOR, UDI - 401114

Nigeria (NG)

California and Virginia residents may also opt-out of the sale/sharing of data via our in-game settings or use an authorized agent to make a request on their behalf.

If you have any questions about this Privacy Policy, please contact us at jumpingtorch@outlook.com.