Geniesoft Inc, a Korea corporation, with registered and business offices at 245, Geumnam-ro, Dong-gu, Gwangju, Republic of Korea, respects your privacy and provides you with this Privacy Policy (“Privacy Policy”) so that you may understand the ways in which we do and do not use the information you transmit when accessing and playing the Geniesoft, accessing and using websites, platforms, software services and related services (hereinafter the “Game”). Please note that your access and/or playing of the Game constitutes your acceptance of this Privacy Policy as well as our Terms of Use.

Where applicable, access and playing of certain basic Game versions, experience of certain basic content and games features may not require registering of an account with applicable platform/service providers that are providing the Game etc. to you. However, in order to access and play the complete Game, access certain premium game functions, levels, content and features you must register an account with the platform/service providers that are providing the Game etc. to you. You must then create an account with the platform/service providers’ platforms that hosts the Game to access such premium game functions, levels, content and features etc. To create an account you are required to provide certain mandatory information such as your name, your email address, account login etc. which is mandatory in order to be able to establish an account. Geniesoft and/or the platform/service providers (i.e. Apple App Store, Google Play, PlayStation (PSVR), Xbox etc.) collects financial information on the terms and conditions set out in this Privacy Policy and/or the platform/service providers’ own Privacy Policies, which can be found on the respective platforms. Geniesoft does not use financial information for any purpose other than processing payments. Further you may, but may not be required to, provide certain voluntary information such as date of birth, screen name, your personal profile in the Game, interests in and use of various games, products and services, and any other personal or preference information. Geniesoft may also collect and process other information when you interact with the Game online, such as the type of browser you are using, the type of operating system you are using; the IP address or other unique identifier such as a device identifier of any of your computer(s) or device(s) that are used to access the Game. Such information will be collected and processed irrespective of whether you only access the Game or if you actually play the Game. Geniesoft may also collect and process certain information when you as a user with a user account interact with the Game such as the information in your personal profile, the relationships you form in the Game, the messages you send, the groups you form, the events you set up, the applications you add and the information you transmit information through various channels.

Geniesoft may invite you share your email address with us for sales and marketing purposes. You may be invited to do this in the Game, related websites etc. as well as third party ad networks. By opting in to receive these emails on our website or from our ad partners, you are giving your consent to receive these types of sales and marketing emails, as well as us storing Personal Data related to such emails and related material in accordance with the terms and conditions of this agreement.

If you choose to use any invitation service to tell a friend about the Game, Geniesoft will ask you to provide Personal Data needed to send the invitation, such as your friends email address etc. Geniesoft will send your friend a one-time email or instant message inviting him or her to visit the Game. Geniesoft stores this Personal Data to send this one-time invitation, to register a friend connection if your invitation is accepted, and to track the success of our referral program. Your friend may contact Geniesoft at genie@geniesoft.io to request that Geniesoft remove this Personal Data from its database.

Geniesoft may also collect information about you from other sources, such as third party sites or platforms, newspapers, blogs, instant messaging services, and other End Users of the Game through the operation of the Game in order to provide you with more useful information and a more personalized experience.

Geniesoft will use information about you for the following purposes in accordance with applicable laws: Age identification

To identify your age for data protection purposes, for example to determine the legal requirements for processing of Personal Data. We request that anyone under the age of 18 not send any Personal Data about themselves over the Internet unless sent under the supervision of their parent or guardian. We do not knowingly collect Personal Data from children under 13 years old in the Game. We believe it is important to safeguard the privacy of children and encourage parents to regularly monitor their children’s use of online activities. If you are a parent and believe that your child under the age of 13 has accessed and/or played the Game and provided personally identifiable information to us, please contact us at privacy@resolutiongames.com or the mailing address at the end of this Privacy Policy and we will work to delete that account and any such personally identifiable information. This in compliance with Article 6(1)(c) of the GDPR. Information you provide or is collected from you in or in relation to the Game and information from other sources

Information is provided by you or collected in or in relation to the Game and/or collected from other sources in order to:

· provide, operate, improve and maintain the Game, game experience and services, your account(s);

· personalize the Game, content, loyalty programs and related services to you;

· send technical notices, updates, security alerts,

· for support and troubleshooting reasons;

· send support and administrative messages

· provide news and information about the Game and/or about our games and products;

· monitor the end users playing of the Game and activities in the Game;

· facilitate sharing on social networks;

· provide adults with advertising in accordance with given consent and/or permissible laws;

· provide children reasonable contextual advertisements in the Game accordance with permissible laws;

· identify, fix, and troubleshoot bugs and service errors, provide software updates etc;

· resolve disputes, investigate and help curb fraud and illegal behavior, comply with the law, and to enforce our agreements and policies;

· survey end users opinions about the game and related matters through surveys or questionnaires;

· communication reasons related to the Game and related matters;

· to store, process and use User Created Content in accordance with our Terms of Use;

· to comply with applicable laws or respond to legal process (like requests from law enforcement or other public or government authorities);

· to administer, process and examine claims of copyright infringements, or other violations of our Terms of Use;

· manage the Game and send you confirmations and important information about your account, products, purchases, subscriptions, and warranties;

· present offers and/or information relating to the Games and other games that you might like;

· make recommendations to you; and

· personalize advertising for you and deliver targeted marketing, service updates and promotional offers.

Processing of this information is necessary for the purpose of performance of a contract to which you are a party, in order to support the operation of the Game, facilitate the delivery of requested products and services, enable maintenance and update of the Game under Article 6(1)(b) of the GDPR, and purposes justified by our legitimate interests in providing advertisements and content of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR (“the balancing-of-interest rule”). Disclosure of your advertising ID to third parties for the purposes of behavioral advertising is based on your consent in accordance with Article 6(1)(a) of the GDPR. We only process your information to the extent that is necessary to achieve the purposes for which the information has been collected.

With respect to processing of Personal Data Resolution Games is Data Controller. Geniesoft shall (i) Not keep the Personal Data for longer than is necessary for the purposes of performing the Agreement unless further storage is required in order to establish, exercise or defend a legal claim or to comply with applicable law, including accounting rules; (ii) Store, process and use the Personal Data for the sole purpose of performing the Agreement; and (iii) Ensure that their employees and employees of their affiliates and subcontractors involved in the performance of the Agreement comply with the provisions of this agreement (iv) Implement all reasonable technical and organizational measures to protect your Personal Data against any accidental or unlawful destruction, accidental loss, unauthorized alteration, communication or access, (v) Where applicable report to you, upon its occurrence, any unauthorized access, disclosure, use, modification or destruction of your Personal Data, (vi) Refrain from exporting or transferring your Personal Data to any Third Country, and from collecting, using or Processing Personal Data within any Third Country, unless prior to the transfer we have ensured that an adequate level of protection of the Personal Data has been implemented in accordance with the terms and conditions stated in section 9 of this Agreement (International Data Transfers). Personal Data are deleted or anonymized as soon as it no longer serves one of the above mentioned purposes and in any event no later than three (3) years after your interaction with us has ended.

As a general rule we will not share Personal Data that directly identifies you (such as your name, e-mail or postal address etc.) with independent third parties without your consent, unless it is either required by law or we determine that disclosure is reasonably necessary to enforce our rights, property or operations or to protect our players or third parties. We may share anonymous 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. Notwithstanding the forgoing, we may share information about you with certain third parties based on the legal basis in Articles 6(1)(b), 6(1)(c) and 6(1)(f) of the GDPR as follows:

We may share information about you with third party agents and contractors in order to provide the Game to you, for ongoing development, for analytical purposes etc. We will only provide information to such third party agents and contractors for their performances of their specific assignments for us and consistent with this Privacy Policy, and for no other purposes and provided that such third party agents and contractors have ensured an adequate level of protection of the Personal Data in accordance with all Applicable Data Protection Legislation and/or though agreements with us.

Where the Game and related services are accessed and/or provided through social networks.

When required by applicable law, rule, regulation, legal process, in the process of negotiations of, any mergers and acquisitions, sale of company assets, financing or acquisition of all or a portion of our business by another company where personally identifiable information submitted to us may be transferred to the acquiring entity.

When ordered or requested by courts, legal authorities etc. and required in order for us to abide by applicable laws, or to protect our rights, in defense in law suits, property or safety of Resolution Games, the Game, end users etc.

In order to provide certain Game features.

For advertising purposes. We may share your advertising ID with advertising partners in order to serving behavioral advertisements to you within the Game if you have given consent in accordance with Article 6(1)(a) of the GDPR. Where applicable certain third parties’ use of Personal Data will not be covered by this Privacy Policy. In such instances you must review such third parties’ privacy policies.

In order to access the complete Game, certain premium game functions, levels, content and features etc. you are required to pay certain fees. When purchasing such features and functions etc. you may be asked by the platform/service providers to provide certain personally identifiable information, such as full name, billing address, email address, phone number and credit card number/expiration date etc. Please note that you must be the age of 18 or older to make purchases in the Game, however children over thirteen but under eighteen may access and play the game under the supervision of a legal guardian. Once End Users have successfully entered valid credit card information etc. and completed the order process, a purchasing account will be created and maintained for them. The platform/service providers will use the information provided to process the End User’s order and to send order confirmations via email, as well as to make future purchases easier for the End User. Geniesoft does not sell, transfer or share customer information with third parties, except where applicable the information is transferred, disclosed and shared with its third-party agent(s) who uses the information solely to handle and deliver certain online activities necessary to operate Geniesoft’ business (e.g. processing orders and payments).

Geniesoft has taken reasonable steps to ensure that the personally identifiable information it collects is secure and we have taken reasonable measures to protect the confidentiality, security, and integrity of the Personal Data collected from our Game’s End Users. Personal Data is stored in secure operating environments that are not available to the public and that are only accessible to authorized employees and contractors. We also have security measures in place to protect the loss, misuse, and alteration of the information under our control. However, there is no such thing as perfect security. As a result, although we strive to protect personally identifying information, we cannot ensure or warrant the security of any information transmitted to us through or in connection with the Game, that we store on our systems or that is stored on our service providers' systems. Please note that Geniesoft may provide links to other games and websites that are operated and hosted by third parties who may have their own information collection practices. Those other games and websites are governed by their own privacy policies, which may be substantially different from Geniesoft’ policies. Visitors to other games and websites are encouraged to review the privacy policies and information collection practices of those websites. Any improper collection or misuse of User Created Content or information provided in the Game is a violation of the Terms of Use and should be reported to Geniesoft at genie@geniesoft.io

We may transfer and share your information to third parties (including service providers operating on our behalf) which may be located in countries outside the European Union (“EU”) and/or the European Economic Area (“EEA”) which may not have the same level of data protection laws as those in the country where you are located. Where your data is sent to a country outside the EU/EEA that is not subject to an adequacy decision by the EU Commission, the transfers will only occur based on the following safeguards: i) If the entity is certified to comply with the principles for data protection under the US-EU Privacy Shield Framework ("Privacy Shield") (see Privacy Shield at www.privacyshield.gov), or ii) If we have entered into EU Commission approved standard contractual clauses with the entity, which is deemed to offer sufficient safeguards with respect to the protection of the privacy and fundamental rights and freedoms of individuals.

You have the following rights regarding your Personal Data:

In accordance to Chapter III, Article 15 of the GDPR a Data Subject may request access to processed Personal Data. This includes confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:

· the purposes of the processing;

· the categories of Personal Data concerned;

· the recipients or categories of recipient to whom the Personal Data have been or will be disclosed, in particular recipients in third countries or international organizations;

· where possible, the envisaged period for which the personal data will be stored or, if not possible, the criteria used to determine that period;

· the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;

· the right to lodge a complaint with a supervisory authority;

· where the Personal Data are not collected from you, any available information as to the source;

· Right of correction and erasurethe existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

Where Personal Data are transferred to a third country or to an international organization, you have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer. You shall be provided a copy of the Personal Data undergoing processing. For any further copies requested, we may charge a reasonable fee based on administrative costs. Where you make the request by electronic means, and unless otherwise requested by you, the information shall be provided in a commonly used electronic form. The right to obtain a copy shall not adversely affect the rights and freedoms of others. Please note that the access may be restricted due to intellectual property rights or trade secrets.

You have the right to object to the Personal Data processing on grounds relating to your particular situation when the data are processed based on the balancing-of-interest rule in Article 6(1)(f) of the GDPR, see Article 21 of the GDPR. In this case, we will cease the processing unless there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or if the processing is necessary for the establishment, exercise or defense of legal claims. You have the right to object to our processing of your Personal Data for direct marketing purposes at any time. We will cease the processing of your Personal Data for this purpose after the objection. Please note that if you exercise this right, your user license to use the Game and related services will cease automatically.

You have the right to have inaccurate Personal Data rectified, in accordance with Article 16 of the GDPR. You have the right to have your Personal Data erased where one of the following grounds applies, see Article 17 of the GDPR:

· The Personal Data is no longer necessary in relation to the purposes for which it was collected or otherwise processed,

· if you have withdrawn your consent and there are no other legal grounds for the processing,

· if you have objected to the processing and there are no overriding legitimate grounds for the processing, the Personal Data have to be erased for compliance with a legal obligation in Union or Member State law,

· the Personal Data have been unlawfully processed or

· the Personal Data have been collected in relation to the offer of information society services.

Please note that your right to erasure may be limited if the data are necessary for compliance with a legal obligation or for the establishment, exercise or defense of legal claims.

You have the right to obtain restriction of processing in certain circumstances, in accordance with Article 18 of the GDPR. If you have the right to restriction, we will only process your Personal Data with your consent or for the establishment, exercise or defense of a legal claim or to protect a person or important grounds of public interest.

If we have asked for your consent to our processing of your Personal Data, you have the right to withdraw your consent at any time, in accordance with Article 7 of the GDPR. You may at any time opt out of and/or unsubscribe from emails from Resolution Games and our service providers, or withdraw consent to Personal Data storage, either via the unsubscribe link included in the emails, or by emailing privacy@resolutiongames.com. If you withdraw your consent, we will cease processing of the Personal Data for which you have withdrawn consent, unless we have a legal obligation to keep some or parts of your data. Please note that if you withdraw your consent, your right to play the Game and related services will cease automatically. The withdrawal of your consent does not affect the lawfulness of processing based on your consent before its withdrawal.

You have the right to receive your Personal Data that you have provided to us in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hinderance if the processing is based on consent or contract performance, sin accordance with Article 20 of the GDPR.

Access and control over most Personal Data in the Game is readily available through the profile editing tools on your account with the applicable platform/service provider that you are accessing the game through. End Users may modify or delete any or all of their profile information at any time by logging into their accounts. Information will be updated as soon as possible. End Users who wish to deactivate their Game account may do so in their accounts with the applicable platform/service provider that you are accessing the game through. Removed information may persist in backup copies for a reasonable period of time but will not be generally available to other End Users or visitors of the Game. You cannot however remove communications made in any communication features in the Game, which might have been shared with other End Users (for example sending personal messages to another End Users).

If you wish to invoke any of the rights described above, you may contact us at any time by emailing us at genie@geniesoft.io. We will process and answer your requests without undue delay and in any event within one month of our receipt of the request unless a longer period is required due to the complexity of the request. In this case, our response time can be up to three months in total as permitted by Article 12 of the GDPR.

OUR GOAL IS TO RESOLVE DISPUTES FAIRLY AND QUICKLY. FOR ALL DISPUTES AGAINST RESOLUTION GAMES, YOU AGREE TO FIRST CONTACT RESOLUTION GAMES AND TRY TO RESOLVE THE DISPUTE INFORMALLY BY SENDING A WRITTEN NOTICE OF THE CLAIM ("NOTICE") TO RESOLUTION GAMES. THE NOTICE TO RESOLUTION GAMES MUST BE SENT VIA REGISTERED LETTER TO THE ADDRESS LISTED IN SECTION 17 BELOW OR BY EMAIL WITH CONFIRMATION OF RECEIPT. THE NOTICE MUST (A) INCLUDE YOUR NAME, YOUR RESIDENTIAL ADDRESS AND E-MAIL ADDRESS AND / OR MOBILE PHONE NUMBER ASSOCIATED WITH YOUR ACCOUNT REGISTERED WITH RESOLUTION GAMES AND/OR THE PLATFORM/SERVICE PROVIDER; (B) DESCRIBE THE TYPE AND REASON FOR THE CLAIM; AND (C) SPECIFY THE SPECIFIC COMPENSATION SOUGHT, IF ANY. IF YOU AND RESOLUTION GAMES CANNOT AGREE ON A SOLUTION TO THE DISPUTE WITHIN 60 DAYS OF RECEIVING SUCH A NOTICE, EITHER PARTY MAY INITIATE LEGAL PROCEEDINGS IN ACCORDANCE WITH SECTIONS 12-15 BELOW.

If you are located within the United States of America, the following applies to you: Any claim (excluding claims for injunctive or other equitable relief) where the total amount of the award sought by either party is less than $10,000 shall be resolved via binding non-appearance-based arbitration initiated through the American Arbitration Association (“AAA”). The AAA Rules are available online at www.adr.org or by calling the AAA at 1-800-778-7879. In any such arbitration, the parties and AAA must comply with the following rules: (a) the arbitration shall be conducted by telephone, online and/or be solely based on written submissions, the specific manner shall be chosen by the party initiating the arbitration; (b) the arbitration shall not involve any personal appearance by the parties or witnesses unless otherwise mutually agreed by the parties; (c) the arbitrator may award injunctive or declaratory relief only in favor of the individual party seeking relief and only to the extent necessary to provide relief warranted by that party’s individual claim; and (d) any judgment on the award rendered by the arbitrator may be entered in any court of competent jurisdiction. Nothing in this Agreement shall prevent either party from seeking remedies in small claims court of competent jurisdiction. The right to refrain from arbitration. You may choose to waive this arbitration term. Then neither you nor Geniesoft can demand that the other party take part in arbitration proceedings. In order to refrain, you must inform Geniesoft in writing about this within 30 days of obtaining notice of this Arbitration section. You must provide the name and address, the e-mail address associated with your Game account (if you have one) and a clear wording that you want to waive the arbitration terms. All requests to refrain from arbitration must be sent to: Geniesoft, 245, Geumnam-ro, Dong-gu, Gwangju, Republic of Korea and marked “Waiver of Arbitration”. If you do not waive this arbitration section it will continue to apply to you.

YOU AGREE THAT ANY AND ALL CLAIMS MUST BE MADE IN YOUR INDIVIDUAL CAPACITY, AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING.

YOU AND GENIESOFT AGREE THAT ANY CAUSE OF ACTION ARISING OUT OF OR RELATED TO THE TERMS OF USE OR THIS PRIVACY POLICY MUST COMMENCE WITHIN ONE (1) YEAR AFTER THE CAUSE OF ACTION ACCRUES. OTHERWISE, SUCH CAUSE OF ACTION IS PERMANENTLY BARRED.

This Privacy Policy applies to all information collected by us or provided to us on and after the Effective Date. This Privacy Policy is subject to change and we may make any changes to this Privacy Policy as we see fit. Geniesoft will notify you of material changes by posting them on applicable game/app stores, and/or on the websites etc. You are encouraged to check back and review this Privacy Policy from time to time so that you will always know what information is collected how it is used and to whom it is disclosed. Your continued use of our services and playing of the Game subject to this Privacy Policy will signify your acceptance of Privacy Policy changes.

If you have any questions, complaints or comments regarding our Privacy Policy, please contact Geniesoft at:

Geniesoft Inc.

245, Geumnam-ro, Dong-gu,

Gwangju, Republic of Korea

Email: genie@geniesoft.io

You may also contact the Korea Consumer Agency(Korea Consumer Agency, KCA) Data Protection Authority if you have any complaint regarding Geniesoft’ processing of your Personal Data. Phone: +82-043-880-5500

(27738)

54, Yongdu-ro, Maengdong-myeon, Eumseong-gun, Chungcheongbuk-do, Republic of Korea