FOR CALIFORNIA RESIDENTS Please visit California Privacy Addendum for special disclosures pertaining to California residents.

FOR INDIAN RESIDENTS Please visit India Data Privacy Addendum for country-specific addendum applicable to individuals located in India, including Users, suppliers, and service providers. In the event of any inconsistency between this Privacy Policy and India specific addendum, the addendum shall prevail to the extent required by applicable law.

FOR EU USERS Please visit EU Data Privacy Addendum for special disclosures pertaining to users located in the European Union.

Spillvoy Gaming Private Limited develops and publishes social games for the web and mobile devices. This Privacy Notice (this “Notice”) describes the ways Spillvoy Gaming Private Limited (“Studio,” “us”, “our” or “we”) collects, stores, uses, discloses or otherwise processes personal information of our users (“users” or “you”) in connection with their use of our products or services, including our product offerings such as our website available at spill.games and Studio game(s) provided on a mobile platform or any other Studio product or service that posts or links to this Notice (each a “Service” and collectively “Services”). This Notice describes the rights and choices concerning your information that may apply to you.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR PERSONAL DATA AND HOW WE TREAT IT. IF YOU HAVE ANY QUESTIONS REGARDING THIS PRIVACY POLICY, PLEASE SEND US AN EMAIL AT privacy@spill.games. IF APPLICABLE, YOU SHALL HAVE THE OPTION AT ANY TIME TO WITHDRAW YOUR CONSENT TO COLLECT, STORE, AND/OR PROCESS YOUR PERSONAL INFORMATION. SUCH WITHDRAWAL OF CONSENT SHOULD BE SENT TO US VIA EMAIL TO privacy@spill.games.

This Privacy Policy may be updated from time to time therefore it is advisable to review it frequently. We will notify you of material changes to this Privacy Policy via a notice on our home page (spill.games). Your continued use of our Platform or Services means that you accept any changes made. If you disagree with the processing of data described in this Privacy Policy, you may not be able to continue to use the Platforms or Services provided.

This Notice sets out our global baseline data practices. Users in specific jurisdictions should also read the applicable Regional Disclosure (Addendum) that supplements this Notice with jurisdiction-specific rights, obligations, and disclosures. In the event of any conflict between this Notice and an applicable Addendum, the Addendum shall prevail to the extent of the inconsistency. New country-specific obligations will be addressed by adding further Addendums without requiring material changes to this core Notice.

If you have questions regarding this Notice or our collection and use of personal information, please contact us as described in the “Contact Us” Section, or the “Grievance Redressal” Section.

PERSONAL INFORMATION WE COLLECT AND HOW WE COLLECT IT

When you interact with or use our Services, we are collecting personal information about you. Sometimes we collect personal information automatically when you interact with our Services (e.g., information about how you interact with our Services) and sometimes we collect the personal information directly from you when you use our Services (e.g., information you give us when setting up your account or user profile). At times, we may collect personal information about you from other sources and third parties, including other players.

Information We Collect Automatically or From You Directly

Registration Information

We may offer you the option to complete a user profile that is visible to other Studio users (“Account”). If you create an Account, you may provide us your name, a username, e-mail address, a password and other information that helps us confirm that it is you accessing your Account. We may do this through in-game dialog boxes, which you may choose to skip. If you sign into the Services with Facebook Connect, we will collect information that is visible via your Facebook account such as: (1) your first and last name, (2) Facebook ID, (3) Profile Picture/URL, and (4) list of Facebook friends. Your Account may be used to publicly identify you as part of social features of the Services, which may include user-to-user interaction, chat or messaging functionality, public leaderboards, head-to-head competition, and other similar features. Your username associated with your Account will be public and will be shown to other users. In addition, your username will allow others to access information on your user profile that is considered public or that you have designated as public in your user profile settings.

Technical and Usage Information

When you access our Services, we may use cookies and other similar technologies to collect (i) certain technical information about your mobile device or computer system, including IP Address, mobile device ID (IDFA, Google Advertising ID or other identifiers), and the version of your operating system; and (ii) usage statistics about your interactions with the Services, including the links, objects, products and benefits you view, click, or otherwise interact with (also known as “Clickstream Data”). Our emails may also contain tracking pixels that identify if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. In connection with your use of certain Services, we will create and assign to your device an identifier that is similar to an account number. In addition, in certain circumstances, we may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as username, character name, or e-mail address. We may also infer your approximate geographic location based on your IP address.

The types of data we collect depend on the Services you use, and the applicable laws. Data collected from our partners includes: data made available by you via your privacy settings in third-party services like Facebook, Google and Apple; demographic data (e.g., to determine the approximate location of your IP address); data to fight fraud related to refunds or advertising; data from the platforms that the games run on (such as purchase data for verifying payments); and additional information (e.g., advertising and analytics data) to improve the relevance of our ads and services we provide

Payment Information

When you order any good or service through the Services, including any virtual currency or virtual good, we collect certain non-financial transaction information related to these purchases, including what you purchased, the price, and the date. Your in-app purchase transactions are processed by third-party payment processors, such as Apple (for purchases on iOS devices), Google (for purchases on Android devices), or Amazon (for purchases on Kindle devices). The third-party payment processors will collect your name, phone number, e-mail address, mailing address, billing address, and complete credit card information to enable them to process your payment. The third-party payment processors may also retain this information to enable you to purchase additional items through our Services without having to re-enter your payment information each time. Please note third-party payment processors do not share your financial information, like credit card numbers, with us. In addition, please note that the third-party payment processors’ processing of transactions and collection and use of your personal information is governed by their terms of service and privacy policy, and purchases through these third parties may also be subject to additional policies. We encourage you to review the terms of service and privacy policies of those third parties to learn more about how they handle your personal information.

Information Collected by or Provided to Customer Support

When you ask for assistance from our Customer Support team, we will collect and store the contact information you provide (generally your name and e-mail address), information about your game-play or activity on the Services, and your username or ID number. We will also store the correspondence and information within the correspondence that you choose to share with us.

Communication Preferences

We may collect information about your interests and communication preferences that you choose to provide, such as when subscribing to news or alerts.

Surveys, User Research Projects, Competitions and Promotional Events

If you choose to participate in, or fill out any forms relating to, Studio surveys, user research projects, competitions (contests/sweepstakes), promotional events, or similar activities, we will collect your contact information (such as your name, email, and phone number, address, and postal code) to enable you to participate in the activity and to allow us to communicate with you, as well as any other information that we request that you provide for purposes of the activities, including audio or video recordings, photos, and/or screen captures. In connection with Studio surveys and user research projects, we may also collect your opinions, responses to certain research questions, prompts, or surveys, and other personal information, consistent with the purposes of the Studio survey or user research project. On occasion, we may also collect your shipping and billing information to send you certain rewards or incentives, such as if you are a participant in a Studio survey or user research project, a competition winner, or if you purchase our products or services. In addition, if you are a part of our event or promotion partner, we may also collect your personal information including your name, company email, and company address. Please note that your participation in any Studio surveys, user research projects, competitions (contests/sweepstakes), promotional events, or similar activities, is completely voluntary.

Information We Collect from Other Sources

We may collect or receive information from the following other sources (i) other Service users who choose to upload their email contacts; (ii) third party information providers, such as digital advertising companies; and (iii) social networking sites. We may combine this information with the information we collect from an individual directly.

Sensitive or Special Categories of Information

We do not request or seek to elicit sensitive or special categories of information, except where such information is inadvertently provided by you in the course of interactions with us, including when you ask for assistance from our Customer Support team.

Information You Choose to Share on the Services

A number of our Services provide features including chat rooms, messaging services, and community and event forums for collaboration, peer connection, games, and information exchange purposes. Any personal information that you voluntarily choose to display on any publicly available portion of our Services, such as when you publish content, comments, or profile information, becomes publicly available and may be collected and used by others.

The table provided hereinbelow list the category of your information we process:

* As further described above, we “share” this information with advertising partners for interest-based advertising.

HOW WE USE YOUR INFORMATION

We use information collected through our Services for purposes described in this Notice or disclosed to you in connection with our Services. For example, we may use your information for:

Service Delivery

• Create your Service accounts and allow access to our Services;
• Identify and suggest connections with other Studio users;
• Operate our Services;
• Improve our Services;
• Understand you and your preferences to enhance your experience and enjoyment using our Services;
• Respond to your comments and questions and provide customer service;
• Provide and deliver products and services you request;
• Send you related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;
• Conduct and administer surveys, user research projects, competitions and promotional events that you participate in;
• Prevent fraud or potentially illegal activities, and enforce our Terms of Use;
• Enable you to communicate with other users; and
• Fulfill any other purpose for which you provide personal information.

Marketing and Advertising

• Deliver and target advertising and marketing and promotional information to you (subject to your consent where required by applicable law, including under India Data Privacy Addendum and EU Data Privacy Addendum; and
• Communicate with you (including via email and push notifications) about promotions, contests, rewards, upcoming events, and other news about products and services offered by us and our selected partners.

Research and Development

• Create aggregate or anonymous information derived from the personal information we handle, which we may use and disclose for research, development and other lawful business purposes;
• Link or combine personal information with other information we get from third parties to help understand your preferences and provide you better services; and
• Analyze information to choose to provide to us in connection with Studio surveys and user research projects to gain insights into how users engage with our Services, to improve our Services, to consider developing new products or services, and other lawful purposes.

Compliance and Protection

• Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• Protect our, your or others’ rights, privacy, safety, or property (including by investigating, bringing, making, or defending legal claims); Audit our internal processes for compliance with legal and contractual requirements or our internal policies;
• Enforce the terms and conditions that govern the Services; and
• Prevent, identify, investigate, and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Email or Push Notifications

We may occasionally send you email or push notifications through our Service to send you game updates, high scores and other service-related notifications that may be of importance to you, as well as to send marketing communications. You may at any time opt-out from receiving these types of communications by clicking on the “unsubscribe” link (or a similar link) at the bottom of our marketing emails or by turning them off at the device level through your settings.

SHARING OF YOUR INFORMATION

We may share information we collect with the following third parties for the specified purposes:

** We may also share your information with professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us. In addition, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, we may share your information (or it may be transferred) to our business transferees, successors, or assigns.

Because the specific information that we may share and our reasons for doing so vary depending on the circumstances, how long the information may be retained can also vary. As explained below, we and our affiliates, subsidiaries, agents, contractors, and service providers generally retain information for as long as we reasonably need it for the purposes described in this policy (like complying with our legal obligations, managing internal records, enforcing our terms, and resolving disputes), unless applicable law requires or permits a longer retention period.

ONLINE ADVERTISING

Interest-Based Advertising

To the extent we display advertising in our Services, with your consent as may be required by applicable law, we may share or we may allow online advertising networks, social media companies, and other third-party services to collect information about your use of our Services over time to enable them to play or display ads on our Services, on other devices you may use, and on other websites, apps, or services. Typically, though not always, the information we share is provided through cookies, software integrations, or similar tracking technologies, which recognize the device you are using. We and our third-party partners use this information to try to make the advertisements you see online more relevant and tailored to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics, and market research. Such information includes the following:

• Device make, model and operating system;
• Device properties related to screen size & orientation, audio volume and battery;
• Carrier;
• Operating system;
• Name and properties of mobile application through which the user interacts with the Services;
• Country, time zone and locale settings (country and preferred language);
• Network connection type and speed;
• IP Address;
• Keywords;
• City- and/or country-level geolocation data;
• Internet browser user-agent used to access the Services; and
• Advertising ID (IDFA on iOS devices and GAID on Android devices).

A list of these advertising partners and their privacy policies is available below. The privacy policies of our partners may include additional terms and disclosures regarding their data collection and use practices. We encourage you to review those privacy policies to learn more about their data collection and use practices.

AppBroda - https://www.appbroda.com/privacy-policy

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

AppLovin - https://www.applovin.com/privacy/

Bidmachine - https://www.bidmachine.io/privacy-policy/

ByteDance - https://www.tiktok.com/legal/page/eea/privacy-policy

Chartboost - https://answers.chartboost.com/en-us/articles/200780269

Facebook - https://www.facebook.com/about/privacy

Fyber - https://www.fyber.com/privacy-policy/

Google AdMob - https://policies.google.com/privacy?hl=en

InMobi - https://www.inmobi.com/privacy-policy/

IronSource - https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/

Line: https://line.me/en/terms/policy/

Mintegral - https://www.mintegral.com/en/privacy/

Ogury - https://ogury.com/privacy-policy/

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

Vungle - https://vungle.com/privacy/

Amazon Publishing Services - https://aps.amazon.com/aps/privacy-policy/

Verve - https://weareverve.co.uk/privacy-policy/

Mobile Fuse - https://mobilefuse.com/privacy-policy

ReclamUp - https://reklamup.com/privacy.php

A4G - https://a4g.com/privacy

Moloco - https://www.moloco.com/privacy-policy

HyperMx - https://jungroup.com/privacy-policy

Social Media Widgets/Plugins

Our Service may include social media features, such as the Facebook button, Google, Instagram, Twitter, or other widgets or plugins. These social media companies may recognize you and collect information about your visit to our Services, and they may set a cookie or employ other tracking technologies. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our Services while those users are on the social media platform or to groups of other users who share similar traits, such as likely commercial interests and demographics. Your interactions with those features are governed by the privacy notices of those companies.

Cross-Device Linking

We, or our third-party partners, may link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you are logged in to our Service. We may also work with third-parties who employ tracking technologies or the application of statistical modelling tools to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as an email address or user ID) with third-party advertising partners to help recognize you across devices. We, and our partners, can use this cross-device linkage to serve interest-based advertising and other personalized content to you across your devices, to perform analytics, and to measure the performance of our advertising campaigns.

Opting-Out of Interest-Based Advertising

As described below, under certain conditions, you have the right to object and/or restrict the processing or handling of your personal information under applicable law.

• Opt-Out through Device-Level Choices. You may limit data collection by third parties by visiting your mobile device settings and adjusting the device’s ad tracking settings (such as turning off the feature to “Allow Apps to Request to Track”) or by exercising other privacy options in your device’s settings.
• Opt-Out through Industry Consumer-Choice Platforms. You may also visit www.aboutads.info/choices or www.youronlinechoices.eu (for individuals in the EU) to learn more about interest-based advertising and how to opt-out of this form of advertising on your web browser by companies participating in the Digital Advertising Alliance (“DAA”) self-regulatory program. If you wish to opt-out of interest-based advertising in mobile apps on your device by companies that participate in the DAA’s AppChoices app, you may download that app onto your device and exercise your choice. AppChoices is available at the links below:
• DAA AppChoices iOS
• DAA AppChoices Android
• DAA AppChoices Amazon

For California users, please also see the California Addendum for the “Do Not Sell or Share My Personal Information” mechanism and our Global Privacy Control commitment.

Please note that electing to opt-out will not stop advertising from appearing in your browser or applications or reduce the number of ads that you receive. You will still receive ads, but those ads may be less relevant to your interests. In addition, if you use a different browser or erase cookies from your browser, or use a different mobile device, you may need to apply your opt-out choices to that particular browser or device.

Please note that the opt-out tools described in this section are provided by third parties, not by us. We do not control and are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

• Opt-Out through Ads. You may also be given the option to opt-out of interest-based advertising through an icon available on the face of an ad served to you.

If you have any questions about these opt-outs or rights you may have under applicable law, you can contact us at privacy@spill.games or by writing to us at the physical address in the “Contact Us” section.

Do Not Track

We recognise and honour opt-out preference signals, including the Global Privacy Control (GPC) signal, to the extent required by applicable law. If your browser or device transmits a GPC signal, we will treat it as a valid opt-out of the sale and sharing of your personal information for that browser or device. For California users, please refer to the California Addendum. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Managing Cookies

As described in this Privacy Policy, we use cookies to inform, optimize, and display ads based on your past visits to the Service and to tailor our advertisements and content to you.

Google Analytics and Advertising. We utilize certain forms of display advertising and other advanced features through Google Analytics, including, but not limited to, Remarketing with Google Analytics, the DoubleClick Campaign Manager Integration, Google Ads, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to the Service and to tailor our advertisements and content to you. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences. To learn how you can opt-out of data collection by Google Analytics, visit https://tools.google.com/dlpage/gaoptout.

You can also review your options to manage cookies by:

• Opening the “Help” menu on the browser menu bar. Most browsers will tell you how you can disable or delete cookies.
• Visiting your mobile device developer’s website or reviewing your device manual. Most mobile device developers will tell you how you can manage the settings on your mobile device to opt out of and/or delete cookies from your mobile device, or to limit the use of your advertising ID, reset your advertising ID, and/or opt out of targeted advertising.
• Visiting https://optout.networkadvertising.org and/or http://youronlinechoices.com, or if you are in the EU http://www.youronlinechoices.eu/, for choices to opt out of advertising. You can also click on the AdChoices logo within an advertisement (where available).

If you reject all cookies, you may not be able to use certain features of our websites and other products and services.

SECURITY OF YOUR INFORMATION

We implement reasonable and appropriate technical and organizational measures to protect the security of your personal information against accidental or unlawful destruction, loss, change or damage as listed hereinebelow:

• We utilize industry-standard Transport Layer Security (TLS) encryption to protect data transmitted between your device and our servers.
• Personal information stored on our servers is encrypted using advanced encryption algorithms (AES-256 or equivalent) to prevent unauthorized access.
• We employ firewalls, intrusion detection and prevention systems, and network segmentation to protect our infrastructure from unauthorized access and cyber threats.
• We implement secure authentication mechanisms including password hashing using industry-standard cryptographic algorithms and support for multi-factor authentication where available.
• We maintain strict role-based access controls (RBAC) to ensure that only authorized personnel have access to personal information on a need-to-know basis.
• We employ secure data destruction methods including cryptographic erasure, overwriting, and physical destruction of storage media where appropriate to ensure that deleted data cannot be recovered.
• Backup copies of personal information are encrypted and stored securely with restricted access until they can be permanently deleted in accordance with our retention schedule.
• We maintain procedures to verify that personal information has been properly deleted or anonymized when no longer needed.

Further we implement organizational safeguards as enlisted hereinbelow:

• We conduct appropriate background checks on employees and contractors who have access to personal information in accordance with applicable laws.
• All personnel with access to personal information are bound by contractual confidentiality obligations.
• We maintain logs of access to personal information and regularly monitor these logs for suspicious activity.

To help protect your privacy and security, you should: (1) never share your username or password; (2) always sign out when you are finished using the Platform; (3) use only secure web browsers; (4) employ common anti-virus and anti-malware tools on your system to keep it safe; (5) use a strong password with a combination of letters and numbers; and (6) change your password often.

However, no security system is impenetrable, and we cannot guarantee the security of your personal information. Any transmission is at your own risk.

DATA RETENTION

We store data on servers in the U.S. or any other country in which the Studio or its affiliates, subsidiaries, agents or contractors or service providers maintain facilities. We retain your personal information for as long as needed to provide you Services, unless we are required by law to delete or if we accept your request to delete the information pursuant to applicable law. We will also retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

When we no longer require your personal information, we will look to delete, destroy, or anonymize it pursuant to our typical procedures. If this is not possible (for example, because your personal information has been stored in backup archives), then we will apply security measures to your personal information and isolate it from any further processing until deletion or destruction can occur pursuant to our typical procedures. If we anonymize your personal information (so that it can no longer be associated with you), we may use this information indefinitely without further notice to you.

CHILDREN’S PRIVACY

Our Services are intended solely for persons who have attained the age of 18 (eighteen) years, or such minimum age as may be required under the applicable laws of the user’s jurisdiction (the “Applicable Minimum Age”). No person below the Applicable Minimum Age is permitted to create an Account, access or use the Services, or provide us with personal information of any kind. We do not knowingly collect, process, or retain the personal data of minors. Parents and legal guardians bear sole and primary responsibility for supervising, monitoring, and controlling the online activities of any minor child in their care, including by ensuring that such child does not create an Account, access, browse, or use the Services in any capacity, and does not submit or transmit personal information to us in any form. This responsibility expressly extends to implementing appropriate parental controls to prevent unauthorised access to the Services by minors, and to refraining from sharing account credentials, devices, or network access in a manner that would enable a minor to use the Services. If you discover that a person below the Applicable Minimum Age has created an Account or provided personal information to us, please contact us at privacy@spill.games, and we will promptly suspend the relevant Account and delete all associated personal data in accordance with our obligations under applicable law. Misrepresentation of age (if any) constitutes a material breach of these Terms.

MANAGING YOUR INFORMATION

Information-Related Requests - If you wish to review, change, or correct the information we have about you, or to withdraw your consent to the processing of your personal information, you may send an e-mail to privacy@spill.games making this request.

Deleting Your Account - If you would like us to delete your information, you may send an e-mail to privacy@spill.games and place “Delete My Account” in the subject line. Please note that, if you proceed with the deletion of your account, you will no longer have access to the game account or services associated with your account. Other steps you should take should you wish to delete your account include disassociating your Facebook account from our mobile games, if applicable, and deleting the game from your mobile device. Please note that if you ask us to delete your account, all your progress in the game and any unused virtual items will be lost and we may not be able to restore them in the future. Please note that your information, for example records pertaining to payments or customer service matters, may be retained for legal and accounting purposes. If you have sent or posted content on the Service, we may not be able to delete it.

We will need to verify your identity before processing your request. In order to verify your identity, we will generally require the matching of sufficient information you provide us to the information we maintain about you in our systems. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

Acting through an Authorized Agent or Representative - In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf where (i) you provide sufficient evidence to show that the requestor is an authorized agent with written permission to act on your behalf and (ii) you successfully verify your own identity with us.

Response Time - In accordance with applicable law, we aim to respond to a consumer request as soon as possible after receiving that request and any necessary verification. If we require more time, we will inform you of the reason and extension period in writing.

THIRD-PARTY WEBSITES AND SERVICES

The Services may contain integrations or links to third-party websites or services, including those of our business partners. By interacting with these third parties, you are providing information directly to the third party. Please note that the Studio is not responsible for the privacy practices of these third parties or any entity that it does not own or control. We encourage you to review the privacy policies and online terms of those third parties to learn more about how they handle your personal information.

TRANSFER OF PERSONAL INFORMATION OUTSIDE YOUR COUNTRY

We may transfer information that we collect about you (detailed in Section 1) to other countries or jurisdictions where we or our service providers and vendors operate for our legitimate business purpose, including our cloud storage provider located in the United States, and advertising partners listed above. The data protection laws and rules in these countries may be different from those in the country where you live. In these cases, we will provide appropriate safeguards to protect your personal data. This may include applying the standard contractual clauses approved by the European Commission for transfers of personal data or other safeguards recognized by applicable laws and regulations.

For jurisdiction-specific transfer safeguards, please refer to the applicable Regional Disclosure (Addendum) for your jurisdiction.

If you have any questions regarding potential transfers of personal information outside of the country where you live or would like to exercise your data rights in relation to such transfers, please contact us at privacy@spill.games or write to us at the address set forth in the “Contact Us” section.

CHANGES TO THIS NOTICE

We may update this Notice to reflect changes to our data and information privacy practices. If we make any material changes, we will notify you by means of a notice on the Services prior to the change becoming effective. We encourage you to periodically review this Notice for the latest information on our privacy practices. Please note that if we need to adapt the Notice to legal requirements, the new privacy Notice will become effective immediately or as required.

Changes to the applicable Regional Disclosures (Addendums) will be treated as material changes under this section. Where a new Addendum is added to address a new jurisdiction, we will provide notice to affected users.

GRIEVANCE REDRESSAL

For any complaints, concerns, or grievances related to our Services, you may contact our designated Grievance Officer:

Escalation India: If you are not satisfied with the resolution provided by our Grievance Officer, you may lodge a complaint with the Data Protection Board of India.

You may also approach:

• National Consumer Helpline: 1800-11-4000 or 1915 (8:00 AM to 8:00 PM daily, except national holidays); or
• Consumer Forums: District, State, or National Consumer Disputes Redressal Commissions under the Consumer Protection Act, 2019; or
• Online Portal: consumerhelpline.gov.in.

You may file grievances by contacting the Grievance Officer through email, phone, or written communication at the address provided above. Each complaint will be assigned a unique ticket number for tracking purposes. The resolution period for grievances is specifically set out in the Privacy Policy. If you are not satisfied with the resolution provided by the Grievance Officer, you may escalate the matter by writing to our senior management at the address provided in the “Contact Us” section.

SECURITY INCIDENT RESPONSE

We maintain a documented security incident response plan that outlines procedures for detecting, responding to, and recovering from security incidents.

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and relevant regulatory authorities in accordance with applicable data protection laws and regulations. We investigate all security incidents to determine their cause, impact, and appropriate remediation measures.

CONTACT US

You may contact us at privacy@spill.games or at the address below for further information.

Prestige Kew Gardens, Yemalur - 560037, Bengaluru

If you have any questions about this Privacy Policy or if you believe that your personal data or Information is not handled in accordance with the applicable laws or this document, then you may contact us as at harsh@spill.games. Details of our Nodal Officer is as under:

Name: Harsh Garg

Email: harsh@spill.games

Contact Number: 7986554028

Address: Prestige Kew Gardens, Yemalur - 560037, Bengaluru, India

For users in India with grievances or complaints related to our services, please refer to the “Grievance Redressal” section above for details of our Grievance Officer and the complaint resolution process.