Privacy Policy

ARETIS LIMITED(“ARETIS” or “we”,“us”,“our”) highly values your privacy. This Privacy Policy (the “Policy”) sets out how we collect, use and protect your personal data(also known as personal information in certain jurisdictions)when you access, use and play games, features, content and services related to our games, related websites and other online services (the “Services”) as a data controller. Please read and understand this Policy carefully before using our Services so that you can better understand our Services and make appropriate choices.

You can review this Policy and adjust your privacy settings through the in-game settings interface at any time.If you are in any doubt, please contact us as described in Section 9‘Contact us’ below.

This Policy will help you understand the following content:

What Personal Data We Collect

How We Use Your Personal Data

How We Share Your Personal Data

Internal Transfer of Data

Data Security and Data Retention

Your Legal Rights

Children’s Privacy

Changes to this Policy

Contact Us

What Personal Data We Collect

We may collect personal data when you use our Services. Personal data usually means any information relating to an identified or identifiable natural person. An identifiable natural person usually refers to the one who can be identified, directly or indirectly, in particular by reference to an identifier of that natural person.

Please note that the data we listed in this Policy may not constitute personal data in according to the applicable data protection law, the personal data should be read and interpreted in the light of and shall not be interpreted in a way that runs counter to the rights and obligations provided for in the applicable data protection law.

Personal data does NOT include “anonymized” data, which is data we collect about the use of the Service or about a group or category of products, services or users, or other data from which individual identities or other personal data has been removed so that the individual concerned cannot be identified directly or indirectly. Such data helps us understand trends and our users’ needs so that we can better consider new features or otherwise tailor our Service. This Policy in no way restricts or limits our collection and use of such data. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we will treat the combined data as personal data which will be used in accordance with this Policy.

We may collect data that you voluntarily provide to us, data that we collect automatically through your use of the services, and certain data we obtain from third party sources.

Personal Data You Provide to Us

When you interact with our Services, you may provide us with the following types of data:

Advertising Preferences Data. If you authorize us to collect your advertising ID (e.g.IDFA), we may use it to provide more relevant advertising experiences.

Customer Service Data. When you contact us for support or feedback, participate in activities or surveys held by us, or subscribe to our information push, we may collect your information, which includes your name, email address, delivery address, and any additional details you provide to us. The specific personal data collected shall be subject to the relevant interface display or communication with you.

Personal Data We Collect Automatically

When you use our Services, we automatically collect certain information. This includes:

Identifiers Data.This includes your device ID (e.g., device IP address, IDFV, Android ID, Google AID, IMEI) and your device IP address. Approximate location is inferred from IP address.

Device and Technical Data.This includes your device model, CPU information, storage size, screen size, network type, device country, device language, operating system version, device timezone,and other technical information.

Usage Data.Information about how you interact with our Services, including game events, scores, session duration, interactions and other gameplay information.

Advertising Data.Information related to the ads and the advertising interactions, such as ads displayed, visible time period, the size of the ads, ad impressions, clicks, and conversions.This data helps us measure advertising effectiveness.

Personal Data We Received from Third Parties

We may also receive information about you from third parties, including:

Social Media Platforms

When you choose to log in with a Google account, we use the account verification service provided by it and will receive necessary information, such as login code (encrypted), login status, to enable account functionality. Please note that your use of any third-party solution for sign-up, and the personal data you provide to that third party or data collected by them, will be explained by that third party and access to their sign-up services is governed by their terms of use, privacy policies, and other policies. You may check its privacy policy for details at: https://policies.google.com/privacy.

When you participate in activities hosted on third-party platforms, we may receive the information about your participation, based on your authorization, which shall be subject to the notification of the relevant activities.

App Marketplaces

When you make in-app subscriptions through the Apple App Store and Google Play, we receive your device ID, payment time, payment order (encrypted), and payment status. Please note that payment transactions for in-app subscription are completed through the app marketplace via your app marketplace account. We do not process payments for in-app subscriptions, nor do we have access to your credit card information.

No Special Categories of Personal Data

Certain categories of personal data, such as details about your race or ethnicity, religious or philosophical beliefs and so on, are considered more sensitive than other categories of personal data in certain jurisdictions and require a higher level of protection. To clarify, our Services do not collect any types of those special categories of personal data.

How We Use Your Personal Data

We process your personal data for specific purposes and process only the personal data relevant for achieving that purpose. Specifically, we use collected personal data for the following purposes as assigned to the above description of the respective processing activity:

To Provide, Maintain and Perform Our Services

In particular:

We use your personal data to deliver our games, ensuring that the games function correctly on your device, providing updates, and fixing any bugs or crashes;

We use your personal data necessary for in-game subscriptions verification to facilitate your subscription;

We use your personal data necessary for account login, verification and management to achieve the account function you requested; and

We use your personal data according to the rules of the activity you choose to participate in, in order to achieve the agreed-upon terms with you, such as reward distribution.

To Enhance Game Performance and User Experience

In particular:

We analyze your personal data to improve game stability, security, and overall performance. This helps us understand how you interact with our games, identify areas for improvement, and enhance the overall user experience; and

We analyze your personal data to understand user trends, preferences, and interactions with our games. This helps us make data-driven decisions to improve our services, develop new features, and tailor the gaming experience to your preferences.

To Push Our Services Information by Groups

We use your personal data to push information related to our Services, such as testing invitations, basic update instructions, new features that may interest you.

To Provide Customer Support and Respond to Your Inquiries

We use your personal data to provide timely and accurate customer support, respond to your inquiries, and handle complaints or feedback. This ensures that we can address any issues you may have and improve our services based on your input.

To Ensure Security and Compliance with Legal Obligations

We use your personal data to enhance the safety and security of our games, detect and prevent fraud, and comply with legal requirements. This includes verifying your identity, protecting your account, managing your consent and ensuring that our services are used in accordance with applicable laws and regulations.

To Deliver Advertising and Marketing Communications

In particular:

We use your personal data to deliver advertisements within our games and to measure their effectiveness. This includes general advertising and personalized advertising; and

We may also use your data to promote our games through other apps or online services.

To Administer Surveys and Other Activities

Participation in these activities is voluntary, and we will obtain your consent if it is required by applicable law.

We only process your personal data when there is a legal basis permitted by the applicable law. The legal basis will depend on the context and purpose for which we collect and use your data.

If you reside in the EEA, we process personal data relating to your use of our Products and Services when one of the following applies:

Contractual necessity: it is necessary for us to collect and process certain data to enable us to enter into a contract with you and perform our contractual obligations. This applies to Section 2.1 To Provide, Maintain and Perform Our Services.

Legitimate interests: we may rely on legitimate interests, where these are not overridden by your interests or fundamental rights and freedoms, to collect and use your personal data to operate and improve our business. This applies to :

---Section 2.2 To Enhance Game Performance and User Experience;

---Section 2.3 To Push Our Services Information by Groups;

---Section 2.4 To Provide Customer Support and Respond to Your Inquiries;

---Section 2.5 To Ensure Security and Compliance with Legal Obligations;

---Section 2.6 To Deliver Advertising and Marketing Communications. If the relevant processing behavior is necessary for the delivery and display of general advertisements that are not targeted at individuals, or to our basic advertising effectiveness measurement. The details are displayed on our CMP (consent management platform) when you open our App.

Fulfillment of legal obligation: we may be required by the applicable law to collect and use your personal data to comply with our legal obligations. This applies to Section 2.5 To Ensure Security and Compliance with Legal Obligations.

Consent: in limited circumstances and to the extent the legal bases for processing set out above do not apply, certain data will be collected when you have given us informed consent. This applies to Section 2.6 To Deliver Advertising and Marketing Communications and Section 2.7 To Administer Surveys and Other Activities. You may withdraw your consent at any time but this will not affect the validity of the processing activities prior to the withdrawal. For details, please refer to Section 6‘Your Legal Rights’.

Other: we may also collect and use your personal data based on other legal bases under the applicable law.

How We Share Your Personal Data

In order to provide you with more convenient and prompt services, we may share your personal data with our partners or engage a data processor (and/or sub-processor) to process your personal data for the purposes in this Policy, in which case we will request the data recipients to keep your personal data in strict confidence and only process data to the extent it is necessary to perform its contractual or statutory obligations within our controllable scope. We will not disclose your personal data to third parties unless we have obtained your consent or there are other legal bases for such sharing. We may share your personal data with the following categories of third parties:

Our affiliates. Your personal data may be shared with our affiliates insofar as necessary for fulfilling the processing purposes set in this Policy, to provide you the Services as requested or for the necessary IT maintenance and operation, during which we will abide by applicable data protection laws and ensure the adequate level of protection of your personal data.

Technical service providers. To provide you with our basic service, we may engage some service providers into our Products and Services, including:

Data storage service provider: We use the cloud storage service provided by Amazon Web Services, Inc. You may check its privacy policy for details at: https://aws.amazon.com/privacy/.

Crash analysis service provider: We use the “bugsnag SDK” provided by SmartBear (Ireland) Limited. You may check its privacy policy for details at: https://smartbear.com/privacy/ .

Information push service provider: We use the "Firebase Cloud Messaging" service provided by Google LLC through “Google Firebase SDK”. You may check its privacy policy for details at: https://policies.google.com/privacy .

Privacy management service provider: We use the "Google UMP SDK" provided by Google LLC for privacy management. You may check its privacy policy for details at: https://policies.google.com/privacy .

Advertising partners. We may share your data with advertising partners to recognize you or your device and to serve ads to you or your device and measure the effectiveness of those ads. The data we shared may include device identifiers (GAID or IDFA), IP address, and other information regarding the delivery of advertisements and your interaction with them such as data related to the device, display screen, App, version, user agent, network, SIM card, time zone, and cell location.

These providers may use APIs, SDKs, cookies or similar tracking technologies to collect information about your device and your Service use. We use a CMP to manage the consent and permission for our advertising based activity, and require our advertising partners to process personal data according to the permission situation we have transmitted. These partners may process your data under their own privacy policies. For further information, please refer to ‘Appendix-Advertising Partners List’. If you'd like to withdraw consent, or opt-out from advertisements related matters, please see the Section 6 ‘Your Legal Rights’ below.

Some third-party services also let you post information about your game activity to their sites to share with others. If you use these features, those third-party services' privacy policies and terms govern your actions on those sites and the information that those services collect.

In addition, we may disclose your personal data in the following cases:

Where we choose to sell, transfer or merge parts of our business or our assets, in such a case the new owners will assume all our rights and obligations in this Policy;

Where it is necessary for the purposes of national security, law enforcement, or public interests.

International Transfer of Personal Data

To facilitate our operations across global markets, we may choose to store your personal data on a local server or a server located in a foreign country depending upon the IT configurations of our Services, and may transfer and process your personal data with our service providers located at different countries, which may be adjusted from time to time. Currently, the personal data we collected is stored on AWS Cloud in the United States.

Where the transfer of your personal data to a recipient located in a foreign country satisfies the definition of international transfer or cross-border transfer of personal data under the applicable law, we will determine the legal basis for the transfer and take appropriate security measures to ensure a level of protection as required under the applicable law. Particularly:

If you reside in the EEA, and

If your personal data is transferred to entities located in countries/territories with adequacy decision (e.g., Israel, UK and US (commercial organisations participating in the EU-US Data Privacy Framework)), the cross-border transfer is subject to the mechanism of an adequacy decision;

If your personal data is transferred to entities in other countries/territories, we will evaluate the ability of personal data protection and network security safeguards and take measures from the catalogue set out in applicable laws. With recipient entities in other countries outside the EEA we usually agree to apply the EU standard contractual clauses (SCC) to ensure an adequate level of protection in accordance with legal requirements. You can find further information on SCC (including a copy) here: https://commission.europa.eu/publications/standard-contractual-clauses-international-transfers_en.

Data Security and Data Retention

We are committed to keeping your personal data safe. We take reasonable and appropriate administrative, technical, organizational, and physical security and risk management measures in accordance with applicable laws to ensure that your personal data is adequately protected against accidental or unlawful destruction, damage, loss or alteration, unauthorized or unlawful access, disclosure or misuse, and all other unlawful forms of processing of your personal data in our possession.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes set out in this Policy.We will either delete or anonymize your personal data when it is no longer required to satisfy the purposes set out in this Policy unless otherwise specified by applicable laws.

Your Legal Rights

You may have certain legal rights in relation to processing of your personal data vary by jurisdiction, which may include:

Access right. You may request access to your personal data in our possession.

Rectification right. You may request us to correct your personal data if it is inaccurate.

Erasure right. You may request us to delete your personal data. If your country/territory of origin is within the EEA, under the following conditions, you have the right to request us to delete your personal data:

a) The respective processing purpose has been achieved;

b) We have unlawfully processed your personal data;

c) You have withdrawn your consent without another legal basis applying to the data processing;

d) You have successfully objected to the data processing;

e) In cases where there is an obligation to delete personal data on the basis of EU law or the law of an EU member state to which we are subject; or

f) the personal data have been collected in relation to the offer of information society services referred to in Art 8(1) of the GDPR.

Restriction right. You may request us to restrict how we process your personal data. If your country/territory of origin is within the EEA, you have the right to request us to process your personal data only to a restricted extent under the following conditions:

a) the accuracy of your personal data is contested;

b) you request limited processing instead of deletion under the conditions of a justified right of erasure;

c) the data is no longer required for the purposes pursued by us, but you need the data to assert, exercise or defend legal claims; or

d) the success of an objection is still disputed.

Portability right. You may request us to help you transfer your personal data to other entities. If your country/territory of origin is within the EEA, you have the right to receive from us personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format, as well as the right to request us to forward this personal data to another controller under the following conditions:

a) the data processing is based on consent or the contract; or

b) the processing is carried out by automated means.

Objection right. You may object to the processing of your personal data. If your country/territory of origin is within the EEA, when you object, we will no longer process your personal data unless we can prove compelling legitimate reasons for the processing that outweigh your interests, rights and freedoms, or the processing serves to assert, exercise or defend legal claims on our part. Where personal data are processed for direct marketing purposes, including profiling related to marketing purposes, you shall have the right to object at any time and we will no longer process your personal data.

Withdrawal of consent. You may withdraw your consent at any time. As a result, we are no longer allowed to continue the processing based on this consent in the future. This does not affect the legality of the processing carried out on the basis of the consent up to the point of withdrawal. Where applicable, we use a CMP to gather and share consent and permissions for our advertising-based activity. You can change your preferences at any time in the Privacy settings of our Games. You may manage your consent related to advertisement through the in-game settings interface. Please note that you may still receive advertisements from us and third parties on our Services even if you withdraw your consent of tailored advertising; but these ads will not be tailored to you.

Right to complain and report. You have the right to complain to the relevant supervisory authority. Please see this directory (https://edpb.europa.eu/about-edpb/board/members_en) for more details with regard to the local data protection authorities if your country/territory of origin is within the EEA.

If you reside in California, you may have the right to:

Request we disclose to you free of charge the following information covering the 12 months preceding your request:

--- the categories of personal data about you that we collected;

--- the categories of sources from which the personal data was collected;

--- the purpose for collecting personal data about you;

--- the categories of third parties to whom we disclosed personal data about you and the categories of personal data that was disclosed (if applicable) and the purpose for disclosing the personal data about you; and

--- the specific pieces of personal data we collected about you;

Request we delete personal data we collected from you, unless CCPA recognizes an exception; and

Right to opt-out of the sale or sharing of your personal data.In some cases, you may have the right to request a restriction of the processing of your personal data. You are always free to opt out from the future collection of your personal data by us and other companies by choosing one of the following methods:

--- Turning on “Do Not Sell My Data” in our app settings.

--- Sending your requests regarding your personal data to exercise your rights to service@aretis.cc at any time.

Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.

The above rights may only apply in limited circumstances under the applicable law. We may ask you to verify your identity and request before taking further action on your request, and if we decide not to respond to your request for the above rights, we will explain reasons.

Children's Privacy

Our Services are designed and provided to users of various age groups. We do not knowingly collect personal data from, or serve targeted advertisements to, children as defined and required by applicable laws. If you believe we have served a targeted advertisement to a child or might have any personal data from or about a child, may be designed for, directed to, or pass personal data knowingly from, children in violation of our policies, please contact us via email at service@aretis.cc.

Changes to this Policy

This Policy may be changed from time to time. If we change anything important about this Policy (e.g., the type of personal data we collect), we will provide a prominent link together with the updated policy for your reference on our Services. By continuing to use the Services, you acknowledge that you have read and understood the updated Policy.

Contact Us

If you have any queries, complaints, feedback or other matters on personal data protection which arise from the use of our Services, including any requests to exercise your legal rights, please contact us through the following ways:

contact us via the in-game settings interface;

contact our data protection department at service@aretis.cc.

Last Updated: June 12, 2025

Appendix: Advertising Partners List

Last Updated: June 12, 2025