ISSUED BY VOWELA INC.

Last Updated: 15 January 2024

1. INTRODUCTION AND GENERAL TERMS

These terms are relevant for the use of games and products created by VOWELA INC. (‘VowelA’), with a registered mailing address at 300 Delaware Ave Ste 210 #540, Wilmington, USA, 19801. VowelA, incorporated in Delaware, USA, has the file number 6960621.

This privacy and data policy (“Privacy Policy”) governs all games, online services (including network play and interaction), and other software and products offered by us (collectively referred to as the “Game(s)”), as well as related online features like our websites (vowela.com and forty-niner.net) (the “Website”), online forums, promotional sites managed by us or on our behalf, and our user Help Centre (https://vowela.zendesk.com/hc/en-us) (the “Help Centre”). These elements, encompassing the Game(s), Website, Forums, and Help Centre, are collectively termed “Online Services”.

For inquiries or feedback regarding this Privacy Policy, reach us at info@vowela.com.

We prioritize your privacy and outline our personal information processing approach in this Privacy Policy. As data controllers, we adhere to U.S. data protection laws, including the California Consumer Privacy Act (CCPA).

Important aspects covered in this Privacy Policy include: Types of information we collect; Usage of collected information; Disclosure of your information to third parties; and Your rights and choices concerning your personal information.

This Privacy Policy should be read in conjunction with our Website terms of use and the end-user license agreements for each Game. Our lists of processed personal data are illustrative, not exhaustive.

Our Online Services may link to third-party services with their own privacy policies. We advise reviewing these policies as they govern your submitted or cookie-collected personal information. We are not liable for the privacy practices of these third-party services, and you use them at your own risk.

This Privacy Policy may be updated, with changes posted on this page. Regularly review this page for updates. Changes may also be communicated through the Games when appropriate.

2. INFORMATION WE MAY COLLECT ABOUT YOU

We process information, which may include your personal data, as follows:

Information you provide when playing the Games (“Basic Information”) While playing our Games, we may collect: Your username; Text on plates, city names in Forty-Niner; Player ID; Unique device IDs for mobile and consoles; Third-party platform player IDs (PlayStation, Steam, Xbox); Third-party platform profile names; User preferences (language, country); Gameplay milestones (progression levels, activity completions).

Information you provide when contacting us or using the Help Centre (“Support Information”) Contacting us or using the Help Centre may involve submitting: Your name and email; City location data; Game device type; Platform player IDs (PlayStation, Steam); Debug logs (software operation and error records).

Information for Forum use (“Forum Information”) To set up a Forum account, we collect: Username; Email address; Password; Unique Forum User ID. Optional additional information for Forums includes: Birthdate; Location; Interests, occupation; Website link; Social media account details (Yahoo Messenger, AOL, Facebook, Google+, Skype, Twitter, YouTube, ICQ).

Information for Analytics purposes (“Analytics”) We collect technical data for Online Services use, including: Website visit frequency; Visited pages; Traffic data; IP and MAC addresses; ISP details; Device and Console IDs; Generated user ID; Device operating system and version, make and model; Gameplay data (attempts, progression, results); Session times and durations; Device country; Crash and defect identification.

Third-party analytics (Google Analytics, PlayStation, Steam) provide additional data collection as per their privacy policies. For more information, refer to Google's and Steam's privacy policies at https://policies.google.com/privacy and https://store.steampowered.com/privacy_agreement/. Crash data is also obtained from Microsoft and Sony, including technical device information, software and applications, and user ID.

Content created by users in the Forums and Help Centre, or submitted through the Website (“User Content”) User-submitted content in the Forums or Help Centre may include both personal and non-personal information. User Content submitted through our Website, such as through general inquiries (info@vowela.com) or job applications (jobs@vowela.com), may also contain various types of information, including the content's location or creation date or other user-specified information.

3. WHY WE COLLECT INFORMATION ABOUT YOU

We utilize your details (including Basic Information, Registration Information, Analytics, and User Content) to offer our Games under the agreed terms of use. This is essential for tracking your progress and status within a Game, ensuring the Games function as promised, and providing an optimal experience in our Games and Online Services.

For Sharing Experiences in Forty-Niner

A major aspect of Forty-Niner is interaction. Plates created in the game, such as shop title or city names, will be named after you based on your Forty-Niner username, visible to other players. This processing helps deliver Forty-Niner according to our agreed terms.

Even if you stop playing Forty-Niner, your username will continue to be used for naming your plates, aligning with our legitimate interests.

For Improving Online Services and Resolving Issues

We process information about you (including Basic, User, Registration Information, and Analytics) to analyze and enhance our Games and Online Services, ensuring they function properly and are of high quality. This also involves identifying and fixing bugs.

For Handling Enquiries and Support Requests, and Enabling Forum and Help Centre Usage

We process Support Information and User Content to effectively address your enquiries and support needs via our Help Centre. Additionally, we process Forum Information and User Content for Forum usage, all under our agreed terms of use.

Zendesk facilitates our Help Centre, processing Support Information.

For Recruitment Purposes We use User Content, including CVs and references, for recruitment, driven by our legitimate interests.

4. COOKIES

Cookies are text files placed on your device when accessing our Games or Website. They are used for authentication, preferences, and analytics, to improve our Website and Games.

Your personal data is typically not included in this information, which may contain device details like IP address and browser data.

Consent for cookie usage is sought through a notice on our Website, with an assumption of consent if usage continues post-notice.

Disabling cookies might limit your experience with our Games and Website.

We collaborate with third parties like Google Analytics, Facebook, Twitter, and YouTube, who may also set cookies on our Website.

For opting out of Google's cookie use, visit https://tools.google.com/dlpage/gaoptout/. Google Analytics' terms are available at www.google.com/analytics/terms/us.html.

5. DATA SHARING

We share your information as described in this Privacy Policy.

With Group Members, Personnel, Suppliers, or Subcontractors: Confidential information may be shared with our group entities, personnel, suppliers, or subcontractors as necessary, under agreed safeguards.

During Mergers or Acquisitions: In such events, you'll be informed via account message or website notice about any ownership changes or information usage, including your options regarding this information.

Legal Obligations: Your information might be disclosed if legally required, for legal proceedings, or to protect our legal rights, including for fraud prevention purposes.

Enforcement: Your personal data may be shared with third parties for agreement enforcement, investigating breaches, or safeguarding VowelA's rights and safety.

Digital Content Stores: For Games downloaded through platforms like Steam, Xbox Live, and PSN, your personal information may be shared with companies like Valve Corporation, Microsoft, Sony, Google, and Apple for payment facilitation.

Help Centre: Zendesk, a third-party provider, manages support requests and queries, handling Support Information. Their privacy policy is available at https://www.zendesk.co.uk/company/customers-partners/privacy-policy/.

6. CONSUMER CONTROL AND OPT-OUT OPTIONS

To exercise your rights regarding your personal data, contact us at info@vowela.com.

7. YOUR RIGHTS CONCERNING PERSONAL DATA

You have rights over your personal data processing, as outlined below. We aim for prompt compliance, ideally within one month.

For data requests or corrections, contact our Data Protection Officer at info@vowela.com.

Rights include requesting data copies, correcting inaccuracies, objecting to processing, obtaining machine-readable data copies, and filing complaints with a Supervisory Authority.

8. DATA RETENTION

Your personal information is held as long as necessary for the relevant service, as described in this Privacy Policy.

To request deletion of your Forum account or User Content, email info@vowela.com.

9. CHILDREN

We do not knowingly collect information from children under 13. Our services are not for users under 13 years. If we find data from a child under 13, it will be promptly deleted. Contact us at info@vowela.com for concerns.

10. SECURITY

We take measures to protect your personal information but cannot guarantee complete security.

11. INTERNATIONAL DATA TRANSFERS

Your data may be transferred to third parties like Microsoft Azure, Zendesk, Google, Valve Corporation, Microsoft, Sony, and Apple. Our servers are hosted in New York, USA.

CONTACT INFORMATION

All questions, comments or enquiries should be directed to VowelA at info@vowela.com. We will endeavour to respond to any query or questions within three business days.