Lights of Fortune - App Social Gaming

1. Who We Are

1.1. The Data Controller of Your Personal Data is Drako Limited, a Maltese Company with registration number C 91369 and having its registered address at Level 5, 135 Spinola Bay, St. Julians STJ 3093, Malta (the “Company” “We” “Us” “Our”). The purpose of this Privacy Notice is to inform You of how the Company collects, processes, uses, stores and protects Your Personal Data as well as the rights You have with respect to the processing of Your Personal Data.

1.2. By visiting Lights of Fortune Application (the “App”) and using Our Services, You acknowledge reading and fully considering this Privacy Notice.

1.3. The Company acknowledges that in collecting Your Personal Data, We are bound by the laws of Malta and will process Your Personal Data in accordance with the GDPR. For any further request or query about how We use Your Personal Data, You may address Us/Our Data Protection Officer through the following email address: gdpr@drako.mt.

1.4. Any notice, demand, request, or other communication which You address to the Company shall either be sent by certified mail, return receipt requested, or by e-mail. All communication done by e-mail shall be deemed received on the business day following the day of transmission.

2. Definitions

Capitalised terms in this Notice shall have the meaning assigned to them under the GDPR and shall be construed accordingly. Furthermore, the following definitions shall apply:

2.1. Account – an account provided to You by the Company upon Your registration and acceptance of the Terms and Conditions for use of the Services.

2.2. GDPR – the General Data Protection Regulation (EU) 2016/679, of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of Personal Data and on the free movement of such data, and repealing Directive 95/46/EC, as amended, replaced or superseded and in force from time to time.

2.3. Services – the provision of social games provided by the Company through the App.

2.4 . User – any person who installs, visits, accesses, plays, registers an Account or otherwise uses the App (“You”, “Your”).

3. Subject Matter

3.1. This Privacy Notice sets out the terms and conditions which the Company follows in order to protect the privacy of Our Users. It describes the conditions under which We collect and process Your Personal Data and ensure security and confidentiality.

3.2. The Company reserves the right to amend and update this Privacy Notice, whenever it deems appropriate, and any changes thereof shall come in force and effect from the instance they appear online on the App. Any substantial modifications to this Privacy Notice will communicated to You.

4. Principles of Data Processing

4.1. We fully respect Your fundamental rights and consider the protection of Your Personal Data to be a priority. Accordingly, when processing Your Personal Data, We respect the following basic principles:

4.1.1. We submit Your Personal Data only to lawful and fair processing, and We maintain complete transparency vis-à-vis the way We handle Your Personal Data.

4.1.2. We collect and process Your Personal Data only for specified, explicit, and legitimate purposes as outlined in this Privacy Notice and We do not process it further in any manner incompatible with these purposes.

4.1.3. We process Your Personal Data only to the extent that it is necessary and appropriate to the purposes for which it is collected.

4.1.4. We make reasonable efforts to ensure that Your Personal Data is accurate and updated, taking all reasonable steps to immediately delete or correct it in case of inaccuracy.

4.1.5. We process Your Personal Data in a manner that guarantees its security by using appropriate technical and organizational measures.

4.2. In general, We comply with all applicable laws and statutory obligations as Data Controller of Your Personal Data.

5. Types of Personal Data We Process

5.1 The Company collects and processes the following types of Personal Data:

5.1.1 At the point You install, access and use of the App as a guest – “Technical Data”:

• End user device data;

• General communication data;

• Browsing data; and

• Information on user preferences regarding the App.

5.1.2 At the point of Your Account registration through social media – “Registration Data”:

• Name and Surname;

• E-mail address;

• Location;

• Language;

• Age;

• Profile picture; and

• List of friends.

5.1.3 Any other Personal Data directly provided by You during Your interaction with Us.

5.2 Please note that the Company is not responsible for processing of Your Personal Data by other organizations, such as Facebook, Google Play Store, App Store or any other social media platform provider, operating system provider, wireless service provider, or device manufacturer, including any Personal Data You, disclose to other organizations through or in connection with the Company’s APP. You should always read the privacy notices of any website that You access or social media page through which You share information carefully in order to understand their specific privacy and information usage practices.

6. Purposes and Legal Basis for Data Processing

6.1. The Company may process Your Personal Data to fulfill its obligations under the Terms and Conditions, for the following purposes:•Administration and development of the App and the Services;

• Enhancement of user experience, including the provision of personalized Services and improvement of the App and the Services;

• Development of new products, utilities and offerings;

• Management and organization of game events inside the APP and inviting You join;

• Identify the user in the ranking and manage, save and keep the record of the user’s performance, such as your points, level and your position in the rankings;

• Communicating with You in case You contact the Company or in case We need to provide You with important information or request Your feedback; and

• Verifying compliance with the Terms and Conditions of the App.

6.2. The Company may process Your Personal Data only with Your lawful consent for the following purposes:

• Commercial communication, marketing and advertising of Our Services.You have the right to withdraw Your consent at any time in writing to Our contact details mentioned in this Notice. Withdrawal of Your consent does not affect the lawfulness of the treatment of Your data prior to its revocation.

6.3. The Company may process Your Personal Data based on its legitimate interest for the following purpose:

• Defending the Company against any legal claims.

7. Data Recipients

7.1. For the execution of the purposes mentioned in this Privacy Notice, We may provide access or transmit Your Personal Data to the following recipients (“Data Processors”):

• Our internet and data hosting providers for hosting purposes; and

• Third-party providers for the smooth operation of App and Our information and communication systems.

7.2. The processing of Your Personal Data by Our Data Processors is done under a contract compelling Data Processors to the same level of data protection provided under this Privacy Notice.

7.3. In case your Personal Data is transferred with any third parties outside of the European Union, We will take all reasonable steps possible such as entering into the Standard Contractual Clauses issued by the European Commission to ensure that Your data is treated as securely as it is within the European Union and in accordance with this Privacy Notice and applicable legislation.

7.4. In the event that We are required by a court or other administrative authority, pursuant to an investigation relating to unlawful activities and in any other case that We are legally bound to do so, the Company may transfer Your Personal Data to public authorities to the extent specified by law.

8. Data Security and Confidentiality

8.1. In order to ensure the proper use and integrity of Your Personal Data and to prevent unauthorised or accidental access, processing, deletion, alteration or other use, the Company applies internal policies and takes all appropriate organizational, technical and procedural security measures, as well as technical standards, in accordance with applicable laws and regulations.

8.2. The processing of Your Personal Data by the Company is conducted in a manner that ensures confidentiality and security, taking into account the latest developments, implementation costs and the nature, scope, context and purposes of the processing, as well as the risks for Your rights and freedoms, which are applicable in each circumstance.

8.3. Your Personal Data is processed solely by authorised personnel of the Company, bound by strict obligations of confidentiality.

9. Retention of Personal Data

9.1. We retain Your Personal Data for as long as is necessary to fulfill the relevant purposes of processing explained in this Notice, in accordance with the Data Minimisation and Storage Limitation principles.

9.2. Furthermore, the Company may retain Your Personal Data after the expiration of the relevant processing purposes based on Our legitimate interest to defend the Company against any potential legal claims, before any competent court or public authority.

9.3. After the period of retention, Your Personal Data is erased from Our databases and systems. For more information about data retention terms in relation to specific Personal Data, please contact Us at gdpr@drako.mt.

10. Your Rights

10.1. You have the right:

• To request access to Your Personal Data and information related to its processing and obtain a copy thereof.

• To request for the rectification of any inaccuracies or any missing Personal Data of Yours.

• To request the erasure of Your Personal Data.

• To request the restriction of the processing of Your Personal Data in cases explicitly provided for by law.

• To request the portability of Your Personal Data to another Data Controller in a structured, commonly used and machine-readable format.

• To object to the processing of Your Personal Data in cases explicitly provided for by law.

• To object to a decision taken solely based on automated processing, including profiling, which has an impact on You or significantly affects You.

10.2. Any requests relevant to the above Section 10.1 must be addressed in writing to gdpr@drako.mt

10.3. If You feel that Your rights are infringed, You have the right to file a complaint with the Malta Office of the Information and Data Protection Commissioner at the following website https://idpc.org.mt/en/Pages/contact/complaints.aspx.

11. Your Obligations

11.1. By using Our App and by providing Your Personal Data, You acknowledge that You are required to provide Your actual, accurate, and complete data as requested by the Company. Furthermore, You must inform Us of any changes to Your information so as to ensure it is kept up-to-date and accurate.

11.2. If You are found to be in breach of Your obligations or if We have reasonable suspicion that the information You provide is false or incomplete or in any way contrary to applicable law or this Privacy Notice, We retain the right to reject Your application for registration or suspend or terminate Your Account immediately without notice. In such case, You have no right to any compensation due to the rejection of Your application or the suspension or termination of Your Account.12.Cookies12.1.Our App uses cookies. For more information please review Our Cookie Notice.