Last updated: 25 May 2018

This Privacy Policy (hereinafter the "Policy") applies to Software Products (hereinafter "Game", "Games"), developed, published, and/or under the direction (control) of 101XP LIMITED (hereinafter "the Company") placed on the website https://en.101xp.com, Google Market, AppStore, Facebook, as well as other services and resources that are directly related to the Games.

PREAMBLE

The company, through its activities, namely the publication, distribution and management of the Games via the Internet, receives access to information which is confidential, as well as the data of individuals that use the Game (hereinafter "the User", "Users").

The Company may need to get from the user certain specific information and data for the purposes of proper identification of the user in the Games and fulfillment of the conditions of the EULA. In so doing, the Company affirms that such confidential information and/or data shall be protected from unauthorized distribution and/or use, in accordance with the requirements stipulated by the legislation of Cyprus and the provisions of this Policy.

INFORMATION AND DATA OBTAINED BY THE COMPANY

The User, by using the Games, including completing registration (if applicable), sending messages and letters, and otherwise interacting with the Company, provides the company some information and data, such as:
· IP address
· Email
· Geolocation for up to 10 previous logins
· Operating system version
· Browser version
· Applications where the User has been active
· Screen resolution
· User’s language
· HWID
· Payment history on 101XP.com and in-app purchases in the Games
· Phone number, First name, Second name, Middle name, Birth date (Only in case of additional clear consent of the User and only for the purposes of additional personal technical support provided for the User by the Company)
· Login
· Password
· Social network ID
· Mobile_id
· Advertising_id.

Company doesn't store users credit or debit card data or other User’s data in respect of financial operations.

The User agrees not to upload in Game and to Company’s websites any personal data of his or her own or third parties’, not to collect, use, or place into the game or any of its services the personal data of any third parties without their consent, including first, middle, or last names, phone numbers, email addresses, residential addresses, passport details, or any other information.

The User is liable for the security of his or her own login data, including the username and password used to access his or her user account in the Game or any of its services. In case of breach of User’s data security while such data was under Company’s control, the Company is to inform the User within reasonable time.

The User is advised, during the registration process and other actions performed when using the Games, to not disclose to third parties his or her login details, as well as other personal information, including phone numbers, addresses, bank account numbers, or other information and data that the User considers confidential.

The User agrees that the Company, as it oversees the Games, also receives some information of a technical/in-game nature, among which is information about the User's activity within the game, including:
(a) information about logging in to a Game (time and quantity of logins);
(b) in-game locations visited by the User while using a Game;
(c) items purchased while using a Game;
(d) items sold while using a Game;
(e) missions (tasks) the User accepts as assignments to complete;
(f) missions (tasks) the User completes;
(g) the number of gaming actions performed by the User with other Users;
(h) the number of invitations sent by the User to other Users;
(i) the amount of virtual game currency owned by the User;
(j) the amount of virtual game currency earned/purchased by the User;
(k) Information about approximate time spent in game;
(l) Character information (server, name, level).

THE USE OF INFORMATION AND DATA OBTAINED BY THE COMPANY

The Company may use information and data received from Users for the following purposes:
(a) to manage the User's account;
(b) to provide the User with access to the Games;
(c) to provide the User with additional information and materials related to the Games;
(d) to provide the User with access to additional services, including services to which the User has subscribed;
(e) to provide for communication between Users;
(f) to provide customer support;
(g) to make changes, additions, and improvements to the Games.

OBLIGATION TO MAINTAIN CONFIDENTIALITY AND THE DISCLOSURE OF DATA

The Company shall keep information and data received from the User strictly confidential, taking all legal, organizational, and technological measures necessary to protect such information from unauthorized or accidental access, destruction, modification, locking, copying, transfer, distribution, and all other illegal actions involving such information and data. The Company shall also take all measures to prevent the disclosure or use of information and data in any way not expressly provided for in this Policy.

Access to the User's information and data, can only be granted to employees working for the Company, who shall obtain access to such information which is necessary for the performance of their duties and Company’s partners for proper Game operation. Such access shall be subject to the measures necessary to protect the confidentiality of such information.

The Company may only disclose to third parties the information and data provided by the User only with the User's consent. The User agrees that the Company may disclose information about the User to third parties in the following cases:
(a) to provide the User with additional information and services;
(b) to complete the financial transactions carried out by the User while using the Games;
(c) when such disclosure is necessary for the execution of justice or the execution of a judicial act or an act from another body or official which must be executed in accordance with the applicable legislation.

The Company shall store the User's information and data for as long as is necessary for the purposes of carrying out the EULA, complying with legal requirements, and fulfilling any relevant court decisions.

OBTAINING AND USING CONFIDENTIAL INFORMATION AND DATA FROM MINOR PERSONS

The Company, acting in good faith, shall not accept or knowingly collect any data on persons who, in accordance with the legislation of their country of residence, are underage, for the use of services related to Games developed by and/or under the direction (control) of the Company.

Persons under legal age of 18 many not use the Game or give out their information and data.

TECHNICAL DATA (cookies)

Games developed by and/or under the direction (control) of the Company use cookies (a "cookie" is a small file stored on the User’s computer and containing information about the User's recent activity) to facilitate logging in and to remember the language in which the User uses the Games.

The Company is entitled to place, on its website and the websites for its Games, cookies and web beacons in order to collect information about the sections of the sites the User visits, the Games and services which interest the User, and the User's movement around the various Game sites and the Company's site(s). If the User is logged in, this information is stored in Company's database. The Company uses this information to improve the performance of the Games, to provide Users with additional information and services, and for other marketing purposes.

The User has the right to regulate the use of cookies in the browser he or she uses. In this case, by disabling the use of cookies, the User will in some cases be unable to fully utilize some of the functions of the Games.

THE ACTIVITY OF THIS POLICY AND THIRD-PARTY RESOURCES

The terms of this Policy apply only to games developed by, published by, and/or under the direction (control) of the Company. However, the Company specifically states that some Games use hyperlinks and banners belonging to third parties, including those which lead to the sites of these third parties. The Company does not guarantee compliance with the provisions of this Policy on these sites and shall not be liable for the disclosure of confidential information and/or personal data by the User on such sites. Service providers in third countries are also accessed for providing Company's services, although data will only be forwarded to recipients in third countries which offer an appropriate level of data protection, such as by means of self-certification for a non-European service or the agreement of so-called EU standard contract clauses for the European Union with the recipient.

ANALYSIS SERVICE VIA GOOGLE INC.

Company uses web analysis services from Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, henceforth referred to as Google, for analyzing website usage.

The methods provided by Google Universal Analytics allow a cross-device analysis of website usage by means of cookies. The information on website usage generated in this way is, as a rule, transferred to a Google server in the United States and also saved there. Google uses the information collected to analyze website usage, to create reports and to make services available for market research and website optimization purposes on Company's behalf. The IP address automatically sent to Google is not merged with other Google data and only used by Company for statistical assessments.

Company uses Google's remarketing function, which is a function that allows a website's visitors to be addressed with personalized and interest-based advertising as soon as they visit another Google Display Network website. To this end, Google cookies are used for carrying out the analysis of website usage, which is used as the basis for settings for the online interest-based advertising. To carry out the process, Google deposits a small file with a code number on the User's end device by means of which visits to websites and anonymized data for using said websites can be collected. As soon as visitors have agreed to linking their Google web and app processes with their Google account and as soon as information from their Google account is used for displayed notices, Google shall use the data from these registered users together with Google Analytics data to create and define target groups for cross-device remarketing. In this way, website visitors are also targeted across their devices with personalized interest-based adverts. If any other websites are subsequently accesses on the Google Display network, then the adverts will be displayed, which, in all likelihood, will take the products and information into account that were previously visited by the user.

THE USER'S RIGHT TO ACCESS AND CHANGE INFORMATION AND DATA

The User has the right to access all of his or her personal information and data stored in the Company's databases. The User has the right to prohibit the Company's use of the information and data mentioned in this Policy. In so doing, after its receipt of such a prohibition from the User, the Company cannot guarantee the User smooth, complete access to the Games and other services of the Company. The User has the right to delete all User’s personal data. Company notifies the User that while the User decides to delete all User’s personal data, the Company will not be able to restore it in the future.

The User who wish to object to their data being processed can send this objection to the contact details below by email or by post. This also applies to exercising any rights to information, to correcting, deleting their data or limiting the processing of their data, as well as the right to transfer their personal data. If consent has been given to process the personal data, then this may be withdrawn at any time and apply to the future. The legality of any consent granted for processing data prior to such an objection being received shall remain unaffected. Information and data can be changed by the User at any time, subject to the restrictions established in this Policy.

Contacts
The following party is responsible for processing personal data:
101XP Limited
6 Ioanni Stylianou,
2nd floor, office 202, 2003
Nicosia, Cyprus
Email: privacy@101xp.com

CHANGES TO THIS POLICY AND TO APPLICABLE LAW

The Company reserves the right to modify this Policy at any time, including modifications for the purpose of taking into account changes in legislation.
This Policy, and any disputes that may arise between Users and the Company, is governed by the laws of Cyprus, without regard for any conflict with local laws and regardless of location.