(Last update October 2021)

INTEREST-BASED ADS

We promote our Apps and services in ours and other publisher's apps and

we also allow our partners to promote and advertise their goods and

services in our Apps. We may share information we collect from you to our

advertising partners, and they can reuse such data for targeted

advertising. We or our advertising partners may display interest-based,

or retargeted, ads (''IBA''), but only for the device IDs that have

passed the age gate and have not opted out of IBA. By using our Apps and

not choosing one of the opt-out options, you give us consent to transfer

your data as stated below.

We may pass information we collect from you such as technical

information, advertising and application usage information (for example

if a device has clicked on a sports ad within our Apps, for more

information please see Information and Data We Collect from You Section

of this Privacy Policy) as well as age & gender information to our

advertising partners and they can reuse such data for targeted

advertising. We allow our partners to serve targeted third party

advertisements or other content. They may attach the information gathered

from our App to info gathered from other apps, websites, or via other

services, and then build profiles and transfer the info to another

provider. For example, we pass advertising IDs to Facebook, and they

match it with your Facebook ID, aggregate it and delete the initial

identifier. By doing so the other provider may receive or gather

information about you and use the information for displaying targeted

ads. Advertisers may choose their audience by location, demographics,

likes, keywords, age & gender, interests, behaviors, connections and any

other information Facebook receives or infers about users. We cooperate

with several providers of IBA that are listed herein in subsection a) and

in Opt-Out Section of this Privacy Policy (''Third Parties''). When

allowing Third Parties to conduct IBA we adhere to the DAA Principles

available here http://www.digitaladvertisingalliance.org/principles/.

You have an option to opt out from sharing your information and data for

the purposes of interest-based advertising at all times. When you opt

out, you will not stop receiving ads, they just won't be based on topics

you like, your interest, behavior, demographics, etc. You can opt out by

choosing one of the following options (for more information please read

the ''Opt Out'' Section of our Privacy Policy):

a) Via third party IBA provider:

• MoPub http://www.mopub.com/optout/;

• Facebook Audience Network

https://www.facebook.com/about/privacy/update?ref=old_policy;

• Facebook Ad Campaigns

https://www.facebook.com/about/privacy/update?ref=old_policy

• InMobi http://www.inmobi.com/page/opt-out/;

• AppLovin https://www.applovin.com/optout;

• Google (Adx)

https://www.google.com/ads/preferences/html/mobile-about.html;

• Google (AdMob)

https://www.google.com/ads/preferences/html/mobile-about.html;

• My.Com https://target.my.com/privacy/;

• OpenX

http://openx.com/legal/privacypolicy/interestbasedadvertising/;

• Smaato https://www.smaato.com/privacy/#section4;

• Maiden Marketing PTE Ltd, dba Pokkt - Please see Section "10.

Your choices and opting-out" of Maiden Marketing PTE's privacy policy

available at https://www.pokkt.com/privacy;

• Vungle https://vungle.com/opt-out/;

• PubMatic https://pubmatic.com/legal/opt-out/#IBA;

• AdColony https://www.adcolony.com/privacy-

policy/#targetingchoices;

• Apple (Search Ads) https://support.apple.com/en-us/HT202074;

• Google (Ad Words)

https://support.google.com/ads/answer/2662922?hl=en;

• Chartboost www.chartboost.com/useroptout;

• Matomy Media Group Ltd., dba Mobfox

https://www.mobfox.com/privacy-policy/#opt-out;

• Click Tech Limited (dba Yeahmobi)

https://en.yeahmobi.com/html/privacypolicy/index.html;

• Gameloft S.E. – Please see Section "Limit Ad Tracking / Do

Not Track of Gameloft Cookie Policy available at

http://www.gameloft.com/en-gb/legal/showcase-cookie-policy;

• IQzone Inc. https://iqzone.com/about/privacy/#optout;

• Twitter https://help.twitter.com/en/safety-and-

security/privacy-controls-for-tailored-ads;

• Etermax S.A. http://www.etermax.com/en/privacy/#publicity-

analytics.

• Adverty AB https://www.adverty.com/privacy-policy#optout;

• Mintegral (Mobvista)

https://www.mintegral.com/en/privacy/#yourDataRights;

• ironSource https://developers.ironsrc.com/ironsource-

mobile/air/ironsource-mobile-privacy-policy/#how-to-control-your-info;

• Fyber Monetization Ltd. https://www.fyber.com/privacy-

policy/#user-choice;

• AdTiming Technology Company Limited

https://www.adtiming.com/privacy-policy.php#opt-out;

• A9.com, Inc. and Amazon Europe Core S.а.r.l

https://www.amazon.com/adprefs;

• The Rubicon Project, Inc

https://rubiconproject.com/privacy/consumer-online-profile-and-opt-out/;

• Vdopia Inc DBA Chocolate https://chocolateplatform.com/opt-

out/

• Verve GmbH (ex PubNative GmbH) https://pubnative.net/privacy-

notice/#opt-out

• My.com B.V https://target.my.com/optout/

• Tappcelerator Media, S.L https://www.tappx.com/privacy-

policy/#opt-out

• Snap Inc. https://support.snapchat.com/en-GB/a/advertising-

preferences

• AppicPlay Co., Ltd. https://www.appicad.com/privacy.html

• ScaleMonkInc., https://www.scalemonk.com/opt-out/index.html

• Liftoff Mobile, Inc., https://liftoff.io/opt-out/

• Huawei (Aspiegel SE),

https://consumer.huawei.com/minisite/cloudservice/ads/privacy-

statement.htm?country=EU&language=en-eu

• Bidmachine Inc. (Stack), https://bidmachine.io/privacy-

policy/

• Verve Inc., https://verve.com/product-privacy-policies/

If you choose to opt out by following one of the third party IBA

provider's opt out mechanism, you should stop receiving interest-based

and targeted ads via the selected IBA provider, but you may continue to

receive interest-based or targeted ads through other IBA providers. For

opting out from receiving interest-based or targeted ads through all IBA

providers, please see opt out options b) and c) below.

b) Via "Do Not Track Settings" in mobile phone:

Turn on "Limit Ad Tracking" on your iOS device or "Opt Out of Interest-

Based Ads" on your Android device.

c) Via our Apps:

Choose "Opt Out of IBA" within the settings of our Apps (where

available).

ABOUT US AND THIS PRIVACY POLICY

As used in this Privacy Policy, "Mika Spin", "we", "us" or "our", "ours"

refers to Mika Spin, registered at 1st Moskow Russia, with business

address at , and all of its subsidiaries.

This Privacy Policy is part of and incorporated by reference into the End

User License Agreement (the "EULA") governing the use of all "Mika Spin"

branded software applications (the "App/s"), which may operate on any

type of computing device (including without limitation, a mobile device),

and applies to your use of the App. This Privacy Policy covers how we

collect, use, disclose, transfer and store information received about you

and/or information received about your computing device through your use

of the Apps.

By using our Apps you specifically consent to the collection, use and

disclosure of your information (including personal information) in

accordance with this Privacy Policy. We may receive and/or you may be

asked to provide your information (including personal information) any

time you are in contact with us or use the Applications. As described in

greater detail below, we may share this information (including personal

information) with our affiliates and with third party partners (as

defined below) and use it in ways consistent with this Privacy Policy. We

may also use your information (including personal information) together

with other information to provide and improve products, services,

content, and advertising.

For general information please feel free to contact us via

bmiryuk@gmail.com and for privacy questions via bmiryuk@gmail.com or call

us on our toll-free telephone number: (914) 0407388.

INFORMATION AND DATA WE COLLECT FROM YOU

1. Technical Information and Data

We collect technical data necessary for you to use our App and additional

technical data that enables us to maintain and analyze the functioning of

the App, to personalize the content of the App, and to display

advertisements.

We automatically obtain certain information about your computing device,

including:

• IP address; Country code;

• IDFAs, IDFVs, Advertising IDs;

• Language; Locale (specific location where a given language is

spoken);

• Time zone, session start/stop time;

• Network status (WiFi, etc.), browser plug-in types and

versions;

• User agent string (UA), platform, SDK version, timestamp;

• All Mika Spin apps installed;

• Technical device information (e.g., device model and name,

operating system name and version, CPU information, storage size, screen

size, firmware, software, mobile phone carrier, Internet service

provider, API key identifier for application, International Mobile

Equipment Identity (IMEI) on Android, Android ID, Android Serial No);

• Push notifications token;

• Player identifier string (we collect player identifier string

only upon your sign into Google Play Games Services or Apple's Game

Center).

Additionally, for playing video advertisements through a video platform

provider, we may collect additional information about your device, such

as:

• "do not track" flag;

• page URL;

• Iso code of the country set on device;

• device date;

• whether Limit Ad is enabled or disabled;

• type of device (tablet or not).

In addition, for users of Android devices we create a unique user ID and

for users of iOS devices we use IDFVs to track your use of our Apps.

Older versions of our Apps may still obtain information such as UDID

number and IMEI number on iOS. If you wish to prevent this, please update

the App with the latest version available on App Store.

2. Advertising and Application Usage Information and Data

When you use our Apps, we may collect additional information by using

device identifiers that permit identification of your device. Such

information is used for advertising and analytics purposes.

The information collected includes:

• Which advertisements are shown;

• Length of time an advertisement is visible and the size of

the advertisement;

• Advertisement response (if any), including clicks on ads;

• Angle of view;

• Application usage information, (how often you use the app,

for how long you use the app, the events that occur within the app, in-

app progress, in-app purchases you make and their value, aggregated

usage, performance data, lifetime value of user etc.).

3. Classical Personal Information

We do not collect any personal information about you through our Apps,

with the sole exception of persistent identifiers (such as IDFA, IDFV,

Advertising ID, IP address). Persistent identifiers are identifiers that

do not identify you personally but may uniquely identify your device.

Some legislation (such as US) may treat such information that uniquely

identifies your device as personal information.

We may ask you to submit and we may process other non-personally

identifiable information that may be personal to you such as your age

range, year of birth and gender, provided that year of birth and gender

information is collected solely for users who have passed the age gate in

our Apps. We will use such information to personalize the content of the

App, and for users who passed the age gate and have not opted out from

behavioral advertising we may use such information to display targeted

ads. You can opt out from receiving targeted ads by choosing one of the

options described in the ''Opt Out'' Section of our Privacy Policy.

When you voluntarily contact us directly, we may collect information

about you that you provide us (such as your name and surname, email

address). We will use such contact information only for the purpose for

which you provided it to us. We will not share this information with

third parties.

If you wish to delete your contact information that we received from you

when you contacted us, please send an e-mail to privacy@mikaspin.com and

your contact information will be deleted from our database.

For the App we also collect the information about the name you give to

and your rating of the Application (if any) and for the App we collect

information about the nickname you choose. Please do not use your real

name.

HOW WE USE YOUR INFORMATION

1. In General

We use the information we collect about you/your device to deliver

services to you and to operate our business. Such use by us and by our

Partners may include:

• Delivering our services: developing, delivering and improving

our products, services, and content, tailoring our products and services,

providing software updates and product support, understanding and

analyzing trends in connection with usage of the Apps, administering the

Apps, and customer communications.

• Displaying advertisements: displaying third party

advertisements in our Apps and showing advertisements for our Apps in

other publisher's apps. Please see more in Advertising Section of this

• Cross-promotion: cross promoting our Apps and services,

meaning we may promote one of our Apps while you are playing a different

App of ours.

• Tracking and fraud prevention for advertising purposes: for

some of our Apps we use third party services for tracking and fraud

prevention for advertising purposes and for privacy compliance purposes.

Please see more in Tracking Section of this Privacy Policy.

• Analytics and research: understanding and analyzing trends in

connection with the usage of the Apps, gathering demographic information

about our user base, data about where the App was downloaded from. We may

also create reports and analysis for the purposes of research or business

intelligence, for example to track potential problems or trends with our

Apps and services, or to test our new game features and content. We use

the data we receive from Third Party Social Network only for internal

analytics. For opting out from analytics please visit Opt-Out Section of

this Privacy Policy.

2. Game Notifications

We have two types of notifications in our Apps - local and push

notifications. Local notifications are contextual and sent from the

device, whereas push notifications are sent from the server. Push

notifications are never sent to users who identified themselves as under

13. We use such notifications to remind you about your activities within

the App. You will receive push notifications only if you are subscribed

to such notifications in the App. To unsubscribe, please use the

instructions provided below:

• For iOS: You will be asked to accept or refuse push

notifications after an Application is downloaded. If you do not accept,

you will not receive push notifications. Please note that if you accept,

some mobile phones will allow you to disable push notifications later on

by using the settings on your mobile phone. To manage push notifications

on your mobile phone please follow these instructions: Open your Settings

menu and tap "Notifications"; Find the App; Tap on the icon of App;

Manage the "Notifications" option by sliding it OFF or ON.

• For Android and Windows: After an App is downloaded, you will

automatically receive push notifications. You can manage push

notifications on your mobile phone by entering the "info screen" on the

homepage of the App and choosing the "Settings" option. Here, push

notifications can be disabled by unchecking the "Notification" option

within the App.

We collect push notification tokens for us to be able to determine

whether you are subscribed to push notifications. When you decide to

unsubscribe from push notifications, such push notification tokens will

be deleted from our database.

For the restriction on the usage of information please see 'Children's

Privacy' Section of this Privacy Policy.

3. Survey

We are conducting surveys to improve our services and you may freely

decide whether you would like to help us or not.

From time to time, we may conduct an in-app survey and collect

demographic and usage information for the purposes of internal analysis,

marketing and brand development. Participating in a survey is completely

voluntary. We will use the information to make our services more

appealing to users. Collected information shall be anonymized and

aggregated. We might collect the following information: age and gender of

the user of an app, whether another person uses the app, the age and

gender of the people regularly using the app, assessment of popularity of

the main character, which of the characters are known to the user, which

app is most commonly used, whether children under the age of 13 use the

app on their own or with an adult, the gender of users playing the app,

different ways of using the app, an assessment of the features of an app,

the time period of using the app, which apps the user has, which and

Friends Products have been bought or have been considered, what would

make the app more appealing, and other information needed for the

purposes of internal analysis, marketing and brand development.

We may use third party providers for the in-app surveys, and they may

place their tags within an App to collect non-personally identifiable

data from the device ("Tag Data") solely for the purposes of conducting

the survey, such as to collect cross device information to enable the

deduplication of audiences across devices. These providers may use the

data collected from the survey and Tag Data on anonymized and aggregated

basis together with the data from other partners ("Unified Data") to

publish syndicated reports on internet behavior and trends. If you wish

to opt out from conducting an in-app survey, do not click on the survey

button or deny answering the survey questions.

HOW WE MAY SHARE YOUR INFORMATION TO THIRD PARTIES

We cannot provide all services necessary for the successful operation of

the Apps by ourselves. We must therefore share collected information with

third parties, including analytics providers, tracking providers, third

party advertising providers and other third party service providers that

support the Apps (collectively referred to as "Partners"). We may share

information that can be used to personally identify your device (e.g.,

persistent identifiers such as IDFA, IDFV, advertising ID and IP address)

for the purposes of delivering our services, displaying advertisements,

conducting analysis and research and for measuring our and our Partners'

advertising campaign performance. We may share such information to:

• Our analytics providers: For some Apps we use third party

analytics such as BigQuery, and Firebase Analytics for the purposes of

delivering our services, conducting analysis and research. To get more

information about how your data is being collected and processed you can

visit the site "How Google uses data when you use our partners' sites or

apps" located at www.google.com/policies/privacy/partners/. Additionally,

we have also integrated Google Play Developer Console data like

Impressions, Downloads, and Traffic Sources into a Google Analytics

account to see how many times people viewed or downloaded our apps from

Google Play. The device data we share with such providers are encoded.

The providers may assign a random ID to these data, and they are not able

to match it back to You. Third party analytics providers have the right

to process the data in accordance with their privacy policies

(http://www.google.com/intl/en/policies/privacy/#nosharing) and such

collection and processing is limited to the disclosure in aggregated

manner, for the purposes of showing trends about the use of their

services, for advertising services and marketing purposes. We can

aggregate the data for benchmarking feature.

• Our cloud service providers: We store information we collect

from you on servers provided by our third party cloud service providers

such as Google Cloud Platform and Google's Android Backup Service.

• Our tracking and fraud prevention providers: For some of our

Apps we use third party services for tracking of our advertising

campaigns, for fraud prevention and privacy compliance purposes. Please

see more in Tracking Section of this Privacy Policy.

• Third party advertising partners: We have contracted with

certain third party advertising networks that assist us in delivering

advertising to you that allows us to continue offering the Apps for free

or at low cost. Such third party advertising partners include but are not

limited to advertising providers listed at http://mikaspin.com/third-

party-ad-providers/. Please see more in Advertising Section of this

• Advertising partner's third party tracking provider: For some

Apps we may allow our advertising partners to track impressions, clicks,

installs or other advertising campaign performance indicators through

their tracking providers for the purposes of measuring their advertising

campaign performance. Please see more in Tracking Section of this Privacy

Policy.

• Built-in customer support tool: In some of our Apps we offer

an in-app customer support tool, which allows users to get answers faster

and easier. The tool provides answers to the FAQ, and also enables users

to contact us within the App. The in-app customer support tool is

provided by Freshworks through their solution Freshdesk, for the data

processing by them, please see Fretworks' privacy policy available at

https://www.freshworks.com/privacy/.

• Video hosting provider: In some of our Apps we use a third

party video hosting provider, JW Player, that assists us in delivering

video content to you. You can read more about their data processing

practices in their privacy policy available at

https://www.jwplayer.com/privacy/.

•

• Other third party service providers: For some Apps we use

Unity Software to develop such Apps. For the data processing by Unity

please see Unity's privacy policy available at

https://unity3d.com/legal/privacy-policy.

We may contract with additional Partners or change existing Partners in

the future to perform any services in connection with the Apps. These

changes shall be updated twice a year or promptly in case of material

changes in our data processing practices.

We reserve the right to disclose your information (including personally

identifiable information) in response to law, legal process, litigation,

and/or requests from public and governmental authorities within or

outside your country of residence. We may also disclose information about

you if we determine that for purposes of national security, law

enforcement, or other issues of public importance, disclosure is

necessary or appropriate. We may also disclose information about you if

we determine that disclosure is reasonably necessary to enforce our terms

and conditions or to protect our operations, users or user experience.

Additionally, in the event of a reorganization, merger or sale we may

transfer any and all information (including personally identifiable

information) we collect to the relevant third party.

For any additional questions about third party information collection

please refer to privacy@mikaspin.com.

HOW OUR PARTNERS MAY USE YOUR INFORMATION

We strive to adhere to the generally accepted industry practices

regarding the collection and the usage of information by our Partners and

to limit their usage to the services they provide for us. They adhere to

this Privacy Policy, but in some cases, we must use their privacy

policies.

We strive to commit our Partners to using the information solely for the

purposes as stated in this Privacy Policy. Notwithstanding the above, we

cannot guarantee that our Partners will adhere to the contractual

obligations or acceptable business practices. While we strive to protect

the information provided to our Partners, we have no direct control over

their use of the collected information and therefore you acknowledge that

we are not liable for any third party privacy breach and that our

liability for our Partner breaches is limited to the amount we can

receive as indemnification from our Partners (legal costs exempted).

Some of the Apps allow you to submit content generated in or by the Apps

to third party sites like Facebook, Vkontakte, Google Play Games, Game

Center and YouTube. These submissions follow the information transfer

protocols of such third parties, which are designed to enable content

sharing with such third parties.

ADVERTISING

When you use our Apps, we may display contextual advertisements to you.

In order to enable advertising, we allow our advertising partners to

collect online identifiers (such as Advertising ID on Android and IDFA on

iOS) that might be considered as personal information under some

legislations, but they should use it solely for the purposes of

contextual advertising. For any other purposes they should use the

information solely on anonymized and aggregated basis.

For some territories, we may use and share with our advertising partners

technical and advertising and application usage information we collect

from you (please see Information and Data We Collect From You Section of

this Privacy Policy) to enable our advertising partner to deliver, target

and optimize third party advertising in our Apps, so that the

advertisements you see are more relevant to you and are based on your app

and device usage, online behavior and interests (this is commonly

referred to as online behavioral or interest based advertising, i.e.

IBA). In addition, we may use and share such information with our

advertising partners to target and optimize our advertising and

promotions in our and other publisher's apps.

We will always follow applicable legislation and accepted market

practices; thus, we will not use and share information for the purposes

of behavioral advertising for users who did not pass the age gate in our

Apps and for those who opted-out of IBA. For more information on

behavioral advertising and our IBA providers please see Interest-Based

Ads Section of this Privacy Policy. For opting out from sharing your

information and data for the purposes of behavioral advertising please

visit Opt-Out Section of this Privacy Policy.

TRACKING

When you use the App, we or third parties operating the advertisement

serving technology may use information logged from your device using

SDKs, cookies, web beacons and other technologies to ensure that

appropriate advertising is presented within the App and to calculate the

number of unique and repeat views of advertising.

For some of our Apps we use third party tracking and data collection

tools from our service providers for the purposes of tracking

performance, ad visibility and privacy compliance of third party SDKs in

our Apps.

We use third party tracking and data collection tools from our service

providers, such as AppsFlyer, for the purposes of measuring performance

and optimizing our advertising campaigns, displaying advertisements,

conducting analysis to improve our services and for fraud prevention

purposes. Such tools may use cookies, APIs, and SDKs in our Apps to

enable them to collect and analyze user and device related data and

information, such as impressions, clicks, installs or other advertising

campaign performance indicators and post-install in-app events.

In addition, our Partners may use their own tracking technologies

(including and without limitation: SDKs, cookies, Web beacons, HTTP

cache, local shared objects and other technologies) in order to track

impressions, clicks, installs or other advertising campaign performance

indicators for the purposes of measuring third party advertising campaign

performance.

THIRD PARTY SOCIAL NETWORKS

1. Connecting to Third Party Social Networks

Some of our Apps use third parties' services such as Google Play Games

Service, Apple Game Center, Facebook, YouTube, Twitter or Vkontakte

("Third Party Social Network/s"). Such Apps enable you log in to your

Third Party Social Network account to connect to our App by using the

"Log in with »or "Connect to" feature in our App. You may also share the

content you created within the App on Third Party Social Networks. By

logging in to your Third Party Social Network account to connect to our

App or by using the App to share content on such Third Party Social

Network, you are authorizing us to collect, store, and use any and all

information, in accordance with this Privacy Policy, that you agreed that

such Third Party Social Network could provide to us through the

Application Programming Interfaces ("API"). You authorize us to do so

when you "accept" or "allow" (or similar terms) connection of one of our

Apps to such Third Party Social Network. The information you allow us to

access varies by App, and it is affected by the privacy settings you and

your friends establish on those Third Party Social Networks. You can

control and find out more about these settings at the Third Party Social

Network in question. Please note, Third Party Social Networks are

governed by their own privacy policies, terms and end user agreements and

we are not responsible for, and have no control over, the sharing

practices or policies of the third parties that operate those sites. For

additional questions you can contact us at privacy@mikaspin.com.

2. Data We May Access Via Third Party Social Networks

If you use the "Log in with" or "Connect to" feature we may access and

store some or all of the following information, as allowed by you, Third

Party Social Networks and your preferences: (i) your basic information

from your public profile, such as your name, surname, profile picture,

age range, gender, and other public information; (ii) email address,

any other information which is detailed and displayed to you in the

notice which appears during the "Log in with" or "Connect to" process. We

may share your name, profile picture and your game data (such as moves,

App progress and scores) with respect to the applicable App, with your

friends who have also used the "Log in with" or "Connect to" feature in

connection with such App or with your contacts in applicable Third Party

Social Media Network account.

The App may further ask you to allow us to post on such Third Party

Social Networks on your behalf (e.g., photos, e-cards, videos and status

updates). Please keep in mind that we will only do that if specifically

allowed by you and we will store ID and your full name for the purposes

of user identification. Other information will be merely stored within

the App on your device so that the App will be able to communicate with

Third Party Social Network directly; Voice recordings from Apps are also

only being collected and stored within the Apps solely upon your request.

3. Consent to Publicly Display Data on Third Party Social Networks

If you use Third Party Social Networks to participate in game related

activities, including but not limited to participation in leader boards,

multi-player games or the downloading and uploading of content, Mika Spin

and its affiliates may also collect, use, store, transmit and publicly

display statistical data regarding game play (including scores, rankings

and achievements), or identify content that is created and shared by you

with other players. Data that personally identifies you is collected,

used, stored and transmitted in accordance with this Privacy Policy.

THIRD PARTY TERMS AND CONDITIONS

Please note that your access to and ability to use and interact with the

Apps may be subject to certain third party terms and conditions and

privacy policies, including but not limited to application stores, mobile

software platforms, online gaming platforms, social networking services,

statistics services providers and payment providers. You recognize and

agree that Mika Spin is not liable for any such third party terms and

conditions and their use of your personal information.

Our Apps may contain links to third party websites, products, or

services. For example, the Apps may feature offers from third party

advertisers or the ability to engage in transactions with such entities.

Please note that while using such third party offerings, you are using

sites, products, and services developed and administered by people or

companies not affiliated with or controlled by us. We are not responsible

for the actions of those people or companies, the content of their sites,

products or services, the use of information you provide to them, or any

products or services they may offer. Our link to such third parties does

not constitute our sponsorship of, or affiliation with, those people or

companies. Nor is such linking an endorsement of such third party's

privacy or information security policies or practices or their compliance

with laws. Information collected by third parties, which may include such

things as location information or contact details, is governed by their

privacy practices. These other websites or services may place their own

cookies or other files on your computing device, collect information or

solicit personal information from you. We encourage you to learn about

the privacy practices of third parties with which you interact.

We are not responsible or liable for your interaction with such third

parties, the information requests initiated by such third parties, or the

subsequent use, treatment or dissemination of information you voluntarily

choose to provide to them.

CHILDREN'S PRIVACY

We consider ourselves to be family oriented, however we have decided to

voluntarily implement higher child protection standards even though our

products and services are not directed to, and we do not knowingly

collect personal information from children under 13, with the sole

exception of persistent identifiers as described below. If we learn that

we have collected personal information other than persistent identifier

of a child under the age of 13, we will take all reasonable steps to

delete the information as soon as possible. If you become aware that your

child has provided us with personal information without your consent,

please contact us at privacy@mikaspin.com.

To preserve the family-friendly reputation of our Apps, we age-gated some

of the features in our Apps, so that they are not available for use by

children under 13. The age gate is being conducted after the download of

some of our Apps for specific territories to assure the privacy and

protection of younger users of our Apps. The features enabling potential

collection and sharing of personally identifiable information, except for

persistent identifiers, are disabled for device IDs of users who did not

pass the age gate. For user's safety, it is not possible to change the

age later on. We do not store the year of birth of users who have

identified themselves as below the age of 13 in our Apps, but only the

information that their device ID did not pass the age gate.

The only personal information we collect from users who have identified

themselves as below the age of 13 for the purposes of offering our

services are persistent identifiers (such as device ID, IDFA, IDFV,

advertising ID, IP address). Such persistent identifiers are used and

shared with third parties solely for providing support for the internal

operations meaning to place contextual advertisement (including frequency

capping), to authenticate users of or personalize the content on Apps, to

maintain or analyze the functioning of the Apps, personalize the content

of the App (such as sending push notifications), to perform network

communications to protect the security or integrity of the user or the

App, to ensure legal or regulatory compliance.

When using the persistent identifiers, we will not contact users under

the age of 13, display behavioral advertising to them, nor do any user

tracking or profiling. In addition, we strive that all of our advertising

partners adhere to the same standards for the collection, usage and

disclosure of children's personal information as we do, but we cannot be

responsible if they breach the commitments, they gave to us regarding the

collection of information. In case of such breaches, you agree that our

liability is limited to the amounts we can receive as indemnification for

the breaches from our advertising partner. For the detailed information

about disclosure to third party service providers used in relation to

users under 13 please click here. For any additional questions about

third party information disclosure please refer to privacy@mikaspin.com.

We will send push notifications only to users who allow us to do so to

reengage them in terms of using the App. You may unsubscribe at any time

by following the instructions in section Push Notifications of this

notifications will always be family friendly. Push notifications are

local, contextual and sent in app only and not from a server or in

conjunction with other user information.

KIDS PRIVACY ASSURED BY PRIVO: COPPA SAFE HARBOR CERTIFICATION

Mika Spin is a member of the PRIVO Kids Privacy Assured COPPA Safe Harbor

Certification Program ("the Program"). The Program certification applies

to the digital properties listed on the validation page that is viewable

by clicking on the PRIVO Seal. PRIVO is an independent, third-party

organization committed to safeguarding children's personal information

collected online. The PRIVO COPPA certification Seal posted on this page

indicates Mika Spin has established COPPA compliant privacy practices and

has agreed to submit to PRIVO's oversight and consumer dispute resolution

process. If you have questions or concerns about our privacy practices,

please contact us on our toll-free telephone number (855) 9541152 or at

privacy@mikaspin.com. If you have further concerns after you have

contacted us, you can contact PRIVO directly at privacy@privo.com.

COPPA Safe Harbor Certification

OPT-OUT

You are always free to opt out from the future collection of your

personal information by Mika Spin in accordance with this Privacy Policy

by uninstalling all the Apps from each of your computing devices.

Opting Out of IBA

1. Via third party IBA providers

MoPub Ads http://www.mopub.com/optout/;

FB Ads https://www.facebook.com/settings?tab=ads;

InMobi Ads http://www.inmobi.com/page/opt-out/;

Google (Adx) https://www.google.com/ads/preferences/html/mobile-

about.html;

Google (AdMob) https://www.google.com/ads/preferences/html/mobile-

about.html;

AppLovin https://www.applovin.com/optout;

OpenX http://openx.com/legal/privacypolicy/interestbasedadvertising/;

Smaato https://www.smaato.com/privacy/#section4;

Maiden Marketing PTE Ltd, dba Pokkt - Please see Section "10. Your

choices and opting-out" of Maiden Marketing PTE's privacy policy

available at https://www.pokkt.com/privacy;

Vungle https://vungle.com/opt-out/;

PubMatic https://pubmatic.com/legal/opt-out/#IBA;

AdColony https://www.adcolony.com/privacy-policy/#targetingchoices;

Apple (Search Ads) https://support.apple.com/en-us/HT202074;

Google (Ad Words) https://support.google.com/ads/answer/2662922?hl=en;

Chartboostwww.chartboost.com/useroptout;

Matomy Media Group Ltd., dba Mobfox https://www.mobfox.com/privacy-

policy/#opt-out;

Click Tech Limited (dba Yeahmobi)

https://en.yeahmobi.com/html/privacypolicy/index.html;

Gameloft S.E. – Please see Section "Limit Ad Tracking / Do Not Track of

Gameloft Cookie Policy available at http://www.gameloft.com/en-

gb/legal/showcase-cookie-policy;

IQzone Inc. https://iqzone.com/about/privacy/#optout;

Twitter https://help.twitter.com/en/safety-and-security/privacy-controls-

for-tailored-ads;

Etermax S.A. http://www.etermax.com/en/privacy/#publicity-analytics.

Adverty AB https://www.adverty.com/privacy-policy#optout.

Mintegral (Mobvista)

https://www.mintegral.com/en/privacy/#yourDataRights.

ironSource https://developers.ironsrc.com/ironsource-

mobile/air/ironsource-mobile-privacy-policy/#how-to-control-your-info.

Fyber Monetization Ltd. https://www.fyber.com/privacy-policy/#user-

choice.

AdTiming Technology Company Limited https://www.adtiming.com/privacy-

policy.php#opt-out.

A9.com, Inc. and Amazon Europe Core S.а.r.l

https://www.amazon.com/adprefs.

The Rubicon Project, Inc https://rubiconproject.com/privacy/consumer-

online-profile-and-opt-out/.

Anzu Virtual Reality LTD https://anzu.io/privacy,https://anzu.io/sub-

processor-list/

Vdopia Inc DBA Chocolate https://chocolateplatform.com/opt-out/

Verve GmbH (ex PubNative GmbH) https://pubnative.net/privacy-notice/#opt-

out

My.com B.V https://target.my.com/optout/

Tappcelerator Media https://www.tappx.com/privacy-policy/#opt-out

Snap Inc. https://support.snapchat.com/en-GB/a/advertising-preferences

AppicPlay Co., Limited https://www.appicad.com/privacy.html

ScaleMonk, Inc. https://www.scalemonk.com/opt-out/index.html

Firebase Analytics (Google Analytics for Firebase)

https://policies.google.com/technologies/ads

Liftoff Mobile, Inc., https://liftoff.io/opt-out/

Verve Inc., https://verve.com/product-privacy-policies/#using-personal-

information

Bidmaching Inc. (Stack), https://bidmachine.io/sdk-opt-out/

Huawei (Aspiegel SE),

https://consumer.huawei.com/minisite/cloudservice/ads/privacy-

statement.htm?country=EU&language=en-eu (please see section 5.4)

If you choose to opt out by following one of the third party IBA

provider's opt out mechanisms, you should stop receiving ads based on

your interest via the selected third party IBA provider, but you may

continue to receive interest-based or targeted ads via other IBA

providers. For opting out from receiving interest-based or targeted ads

through all IBA providers, please see opt out options 2. and 3. below.

2. Via "Do Not Track Settings" in mobile phone

If you choose to opt out via "Do Not Track Settings" in your mobile phone

all providers of advertising services are bound to comply with such "Do

Not Track" setting, but we cannot provide any guarantees on their behalf.

If you choose the opt-out option available via our Apps, we will not

share your advertising ID with advertisers for the purposes of IBA. We

provide no guarantees regarding the information provided prior to opting

out. Some providers may have additional opt-out mechanisms implemented.

If you turn on "Limit Ad Tracking" on your iOS device or "Opt Out of

Interest-Based Ads" on your Android device, you can restore interest-

based ads by turning the settings off. When you opt out, you may still

see the same number of ads on your mobile device; however, these ads may

be less relevant because they won't be based on your interests. Our

advertising partners may continue to serve you ads based on other non-

personal information, such as ads related to the content of the

application you are using.

Your iOS or Android mobile device may provide a "Limit Ad Tracking" or

"Opt Out of Interest-Based Advertising" setting. When you have opted out

using this setting on a device, our partners will not use information

collected from that device to infer your interests, or to serve ads to

that device that are targeted based on your inferred interests.

You can find the setting for your mobile device by following the

directions below or contact your device provider.

The reason for switching from device IDs to Advertising Identifier is

that advertisers can use this identifier only for advertising and for no

other purpose, while users can choose to opt out of tracking via the

settings of mobile phone. Advertising Identifier is an anonymous

identifier for advertising purposes which enables users to reset their

identifier or opt out of interest-based ads. The parties participating in

advertising are obligated to follow users' choice for opting out of

tracking according to the app store guidelines.

IOS DEVICE

• iOS 7 or Higher

Go to your Settings \> Select Privacy \> Select Advertising \> Enable the

"Limit Ad Tracking" setting

• iOS 6

Go to your Settings \> Select General \> Select About \> Select

Advertising \> Enable the "Limit Ads Tracking" setting

More information about the iOS setting can be found here:

https://support.apple.com/en-us/HT202074

ANDROID DEVICE

For Android devices with OS 2.2 and up and Google Play Services version

4.0 and up:

Open your Google Settings app \> Ads \> Enable "Opt Out of Interest-Based

Advertising"

3. Via our apps

We have created an opt-out option within some of our Apps. You may choose

it by visiting ''Info Screen'', ''Settings'' and ticking the ''Disable

Interest-Based Ads''. Choosing this option will mean that you will still

be served ads, but they will not be tailored to your preferences. Should

you decide to opt out of advertising altogether, you may make an in-app

purchase to do so, or you can delete the App.

IN-APP PURCHASES

Our Apps enable in-app purchases. We do not process payments for in-app

purchases nor have access to your credit card information. Payment

transactions for in-app purchases are completed through the app store via

your app store account. Any post-purchase processes are controlled by the

app store and are subject to specific terms of such app store.

For more information on in-app purchases in our Apps please see In-App

Purchases Section of the End User License Agreement available at

http://mikaspin.com/eula/.

SPECIAL PRIVACY FEATURES IN SOME OF OUR APPS

Some of our Apps offer you the option to talk to the virtual character of

such Apps. All of our Apps that offer such feature will always ask you

for your permission to access the microphone on your device in advance.

If you decide to give us the permission, the virtual character will be

able to repeat what you say to him. Please note that our Apps do not have

a function to record audio, so what you say to the virtual character is

not stored on our servers, it is only used by the App to repeat to you in

real time. If you decide not to give us the permission to access the

microphone on your device, the virtual character will not be able to

repeat after you.

Some of our Apps offer you to compete and interact with your Facebook

friends, but you need to login with your Facebook account. By doing so,

the App will receive your public profile and the list of friends. If you

do not want to share the list of friends with the App, you can uncheck

the box next to the permission for sharing the list of friends in the

notice that appears during the "Log in with Facebook". If you choose to

to your Facebook friends.

Some of our Apps can be played in a single or a multiplayer mode. In a

multiplayer mode you can play matches with random players or your

Facebook friends. Such Apps will ask you to choose your name. Please do

not choose your real name. You can always change your name by going to

"Settings" and selecting "Change Name". The name you enter, and your rank

will be publicly displayed when playing with random players in a

multiplayer mode. To play matches with Your Facebook friends, you need to

public profile and the list of friends. If you do not want to share the

list of friends with the App, you can uncheck the box next to the list.

However, you cannot play matches with your Facebook friends without

giving the App the permission to share your public profile. If you choose

to login with Your Facebook account, the application will show Your

public profile when playing with your Facebook friends or random players.

PROTECTION OF PERSONAL INFORMATION

We have implemented: reasonable security measures to protect the

confidentiality, security and integrity of the collected information, and

to prevent unauthorized access and the use of information contrary to

this Privacy Policy. Although we use commercially reasonable efforts to

assure that your information remains secure when maintained by us, please

be aware that no security measures are perfect or impenetrable.

INTEGRITY OF PERSONAL INFORMATION

We strive to enable you to keep your information accurate, complete and

up to date. You can access, check and ensure the integrity of your

information as described below.

ACCESS TO PERSONAL INFORMATION

We make good faith efforts to provide you with access to the personal

information you provide to us (information associated with your account).

You can also request that we correct or delete information if we are not

required to retain such information by law or for legitimate business

purposes.

We may decline to process requests that are unreasonably repetitive,

require disproportionate technical effort, jeopardize the privacy of

others, are extremely impractical, or for which access is not otherwise

required by local law. Access, correction or deletion requests regarding

your personal information may be submitted to privacy@mikaspin.com. For

some of our Apps we may develop in-app deletion request functionality

which can be used in addition to the address above.

For Privacy enquiries you may contact us via privacy@mikaspin.com or by

calling us on our toll-free telephone number: (914) 91404032.

INTERNATIONAL TRANSFER

We operate globally, thus we may for the purposes described in this

and/or to other third party service providers across boarder and from

your country or jurisdiction to other countries or jurisdictions around

the world. Please note, that these countries and jurisdictions may not

have the same data protection laws as your own jurisdiction, but wherever

your personal information is transferred, stored or processed by us, we

will take reasonable steps to safeguard the privacy of your personal

information.

STORING OF INFORMATION

We store your information for as long as needed to provide you with our

services. We may store information longer, but only in a way that it

cannot be tracked back to you. We delete the information as soon as we do

not need them for providing our services unless a longer retention period

is required or permitted by applicable legislation.

Storing might be different depending on the territory of collecting the

information and the applicable legislation, but we always strive to store

the information only if it is needed for the purposes of providing,

improving or personalizing our services.

DELETION OF INFORMATION

When information is no longer needed, we shall delete it using reasonable

measures to protect the information from unauthorized access or use.

CHANGES TO OUR PRIVACY POLICY

We will occasionally update this Privacy Policy as necessary to protect

our users, furnish current information, and respond to legal and

technical changes. The most current version of the Privacy Policy will

govern our use of your information and will be available at

http://mikaspin.com/privacy/.

Should you request so by informing us on privacy@mikaspin.com, we will

send you all the updates of this Privacy Policy to your e-mail. We will

also inform you about any material updates of our Privacy Policy with an

in-app banner and a link.

PRIVACY QUESTIONS

If you have questions or concerns about Mika Spin's Privacy Policy or

information processing, please contact us through privacy@mikaspin.com,

or call us on our toll-free telephone number: (914) 0407388.

Mika Spin Privacy Policy, v. 2, updated June 2021