PRIVACY POLICY

Fanatee INC., a Delaware company, located at 78 SW 7th St, suite 500 Miami, FL 33130, USA (collectively referred to as "Fanatee", "we", "us" or "our" in this privacy notice) is aware of your concern about how your personal data (information which are related to an identified or identifiable natural person) (“Personal Data”) is used and shared, and we take your privacy seriously. Please read what follows to learn more about our Privacy Policy. By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent to the fact that we will collect, use, and share your data in the following manner.

OUR GAMES ARE INTENDED FOR INDIVIDUALS 13 YEARS OF AGE OR OLDER IN THE US AND 16 YEARS OF AGE OR OLDER IN THE EU. CHILDREN UNDER THE AGE OF 13 IN THE US OR UNDER THE AGE OF 16 IN THE EU MAY NOT ACCESS THE FANATEE SERVICES. ALSO, WE DO NOT KNOWINGLY COLLECT DATA RELATING TO CHILDREN FOR ADVERTISING PURPOSES.

Remember that your use of the Fanatee Services is at all times subject to the Terms of Service which incorporate this Privacy Policy. Any terms used in this Policy without a definition are to be defined pursuant to the definitions in the Terms of Use.

In case of divergence between the translations of this Privacy Policy, the English version shall prevail over other versions.

1. What Data does Fanatee Collect?

1.1. Personal data you provided us with

We collect some of Personal Data from you, such as your first and last names, as well as your email if you use your Facebook account to log into our network. If you provide us with feedback or contact us via email, we will collect your name and email address, as well as any other content included in the email, in order to send you a reply. We also collect other types of Personal Data that you voluntarily provide us with, such as operating system and version, Game type and version, and other requested information if you contact us via email regarding support for the Games. If you are a beta tester, to improve your in-Game experience, we may also capture your screen actions so we can prevent bugs, glitches and other errors from happening. In addition, we collect Personal Data from you, such as demographic information, via the Games or at other points in our website that state that Personal Data is being collected. Please see section 2.1 below for a full description of the data that we collect.

1.2. Personal data collected via technology

To make our Website and Games more useful to you, our servers (which may be hosted by a third-party service provider) collect Personal Data from you, including browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.

1.3. Personal data collected via cookies

“Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. You may choose to refuse or disable Cookies via the settings on your browser, however by doing so, some areas of our website may not work properly.

2. How we use your Data?

We use your Personal Data in the ways set out in the table below, where we also detail the legal basis we rely on to do so:

2.1. Legal Basis for use of your data

2.2. Creation of Anonymous Data

We may create Anonymous Data records from Personal Data by excluding information (such as your name) which makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Games and improve site navigation. We reserve the right to use and disclose Anonymous Data to Third-Party Companies at our discretion.

2.3. Your Feedback

If you provide feedback on any of our Games or our website, we may use such feedback for any purpose, provided that we do not associate such feedback with your Personal Data. We will collect any information contained in such communication and will treat the Personal Data in such communication in accordance with this Privacy Policy.

3. How does Fanatee Share the Personal Data it Receives?

3.1. Fanatee Third Parties

We do not rent, sell or transfer your Personal Data form to anyone except as expressly provided below. We may share your Personal Data with third parties as described below:

Advertisers: We may, from time to time, allow advertisers and/or merchant partners (the “Advertisers”) to choose the demographic data of users who will see their advertisements and/or promotional offers, and you agree that we may provide any of the data we have collected from you in non-personally identifiable form to an Advertiser, in order for that Advertiser to select the appropriate audience for those advertisements and/or offers. For example, we might use the fact that you are located in Sao Paulo to show you ads or offers for Sao Paulo businesses, but we will not tell such businesses who you are. Or, we might allow Advertisers to display their ads to users with similar usage patterns to yours, but we will not disclose usage data to Advertisers except in an aggregate form, and not in a manner that would identify you personally. Note that if an advertiser asks us to show an ad to a certain audience or audience segment and you respond to that ad, the advertiser may conclude that you fit the description of the audience they were trying to reach. You may at all times opt out of this type of advertising by contacting us through the email displayed at end of this Policy.

Affiliated Businesses: In certain situations, businesses or third-party websites that we’re affiliated with may, from time to time, sell or provide products to you through or in connection with the Services (either individually or jointly with us). You can recognize when an affiliated business is associated with such a transaction or service, and we will share your Personal Data with that affiliated business only to the extent that it is related to such transaction or service. We have no control over the policies and practices of third-party websites or businesses as to privacy or anything else, so if you choose to take part in any transaction or service relating to an affiliated website or business, please review all policies of such businesses or websites. Affiliated Business is Fanatee Brazil.

Our Partners: We employ other companies and people to perform tasks on our behalf and need to share your data with them to provide products to you; for example, we use a hosting service to store our database. Unless we tell you otherwise, our agents do not have any right to use the Personal Data we share with them beyond what is necessary to assist us.

Reports/Analytics: Fanatee stores data that are used in the form of aggregated and generic statistics or reports in order to better understand user profiles for the improvement of the Products offered by Fanatee.

User Profiles and Submissions: Certain account data, including your name and location, may be displayed to other users to facilitate user interaction within the Services or address your request for our services. Additionally, if you sign into the Services through a third-party social networking site or service, your list of “friends” from that site or service may be automatically imported to the Services, and such “friends,” if they are also registered users of the Services, may access certain non-public data you have entered in your Services user profile. Again, we do not control the policies and practices of any other third-party site or service.

Protection of Fanatee and Others: We reserve the right to access, read, preserve, and disclose any data that we believe are necessary to comply with the law or court order; enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of Fanatee, our employees, our users, or others.

3.2. International Data Transfer

Fanatee collects and transfers Personal Data from and to countries located in the EEA, U.S., and Brazil to companies listed in our list of Partners. If you are a resident of the EEA, please be aware that countries outside of the EEA may not have the same level of data protection as the EEA; however, our collection and use of your data will continue to be governed by this Privacy Policy. By using the Fanatee Services, you consent to such transfers.

4. What rights do I have?

You can always opt not to disclose your Personal Data to us, but keep in mind that some Data may be needed to register with us or to use some of our features.

You may add or update Data as explained above. When you update Data, however, we may maintain a copy of the unrevised data in our records. You may request the cancellation of your account by email at hello@fanatee.com or through in-game contact support. Some Personal Data may remain in our records after you request for its deletion from your account in the manner described below. We own and may use any aggregated data derived from or incorporating your Personal Data after you update or delete it, but not in a manner that would identify you personally.

4.1. Your EU Privacy Rights

Depending on your country of residence, you may have additional rights relating to our processing of your Personal Data. If you are an EU resident, in addition to your right to be informed in this Policy of how we process your Personal Data, these rights are:

• i. the right to access;
• ii. the right to rectification;
• iii. the right to erasure;
• iv. the right to restrict processing;
• v. the right to object to processing;
• vi. the right to data portability;
• vii. and the right to withdraw consent.

If you have any questions or concerns regarding how to exercise any of your rights, please send us a detailed message to hello@fanatee.com, then we will serve you.

4.2. Your California Privacy Rights

If you are a California resident, California law provides you with specific rights regarding your Personal Data, including the right to request that we disclose certain information to you about the collection and use of your Personal Data over the past 12 months and the right to request that we delete any of your personal information that we have collected from you, subject to certain exceptions. To make such a request, contact us at hello@fanatee.com. Please note that we are only required to respond to two such requests per customer each year.

You also have the right not to be discriminated against if you exercise any of your rights under California privacy law.

Fanatee may have collected the following categories of personal information of California residents in the past 12 months:

• Identifiers such as a name, Internet Protocol address, email address, or other similar identifiers.
• Commercial information, including records of products or services purchased or considered.
• Internet or other electronic network activity information.
• Inferences drawn from any of the information identified above.

This information is collected and used for the purposes disclosed in this Privacy Policy. Fanatee has not sold personal information of California residents in the past 12 months. Fanatee may have disclosed any of the above categories of personal information pursuant to an individual’s consent or under a written contract with a service provider for a business purpose in the past 12 months.

5. How is my Personal Data secured?

Your account is protected with a password for your privacy and security. If you access your account via a third-party site or service (like Facebook login), you may have additional or different sign-on protections via that third-party site or service. You must prevent unauthorized access to your account and Personal Data by selecting and protecting your password and/or other sign-on mechanism appropriately.

Fanatee is committed to the safety of your information, some measures we take to improve security are:

• Cryptography on all server communications
• Multi Factor authentication on cloud services
• Server architecture with highly secure access environment
• Internal policy with restricted access to server information

We endeavor to protect the privacy of your account and other Personal Data we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user data at any time.

Fanatee is based in Brazil and the data we collect is governed by the Brazilian law. By accessing or using the Fanatee Services or otherwise providing data to us, you consent to the processing and transfer of such data in Brazil and to other countries.

6. How long Fanatee will maintain the Data?

6.1. Data Retention

We will retain your Personal Data only for as long as necessary to fulfill the purposes we collected them for, including for the purposes of complying with any legal, contractual or accountability obligations, or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider the amount, nature, and the sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data and whether we can achieve such purposes through other means, and the applicable legal requirements.

Although, if you have registered for a Fanatee account, your account information will be retained for as long as you maintain an active account. Your account and account information will be deleted if you do not log in for 48 (forty-eight) consecutive months. Fanatee retains records of that deletion for 365 days.

7. How to contact Fanatee if you have questions, comments or complaints?

Fanatee is the Controller and Processor of Personal Data submitted in accordance with this Privacy Policy and is responsible for that Personal Data.

If you believe your personal information has been used in a way that is not consistent with this Privacy Policy or with your choices as a data subject, or if you have questions, comments or suggestions regarding this Privacy Policy and our handling of your Personal Data, please contact us. We have a Data Protection Officer who is available at the following contact addresses:

Data Protection Officer: Baptista Luz Advogados
E-mail: privacy@fanatee.com

8. Other Provisions

We are constantly trying to improve our Services, so we may also need to change this Privacy Policy from time to time. In the event of significant changes in this Privacy Policy, Fanatee will previously communicate by email to users for whom we have email addresses, indicating the date on which such amendment will become effective. We will also notify users through a pop-up within the app. In order to keep using the Fanatee services, you may accept them with the indication that you agree with all of these changes.

If you have further questions, comments, or suggestions regarding the Privacy Policy please don’t hesitate to contact us via email hello@fanatee.com.

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Last updated on 11/27/2023