Supplemental California Consumer Privacy Act Statement

Version effective date: December 22, 2024

We, MOONJOY LIMITED, issues this Supplemental California Consumer Privacy Act Statement to provide details about how we collect, use, disclose and otherwise process information that identifies, describes, or can reasonably be associated with California residents ("Personal Information"), and rights that California residents may have under the California Consumer Privacy Act ("CCPA").

This Statement only applies to you if you reside in California, and does not reflect our processing of California residents' Personal Information where an exception under the CCPA applies. Personal Information does not include publicly available information in government records or any data that has been deidentified, aggregated, or otherwise anonymized. This document supplements our Privacy Policy.

1. CCPA Notice at Collection

Collection: We may collect the following Personal Information about California residents:

Identifiers such as a real name, alias, postal address, unique personal identifiers, online identifiers, Internet Protocol address, email address, account name, and similar identifiers.
Commercial information, including records of personal property, products or services paid for, obtained, or considered, or other consuming histories or tendencies.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an internet website application, or advertisement.
Geolocation data. We may be able to infer your general location based on your Internet Protocol address.
Inferences drawn from any of the information identified herein to create a profile about a consumer reflecting the consumer's preferences.

Use: We may use Personal Information for the following purposes:

to enable us to personalize your in-game profile, provide our games (including the social elements of our games, such as team play and competitions), to ensure that the services you have paid for are activated in the games, and to provide you with player support if you need it;
to enable us to optimize our games for you and for the device that you are using, as well as to deliver customized in-game events, offers and promotions;
to manage our organization and its day-to-day operations;
to verify your identity and entitlement to products or via our website or mobile games (collectively, "Services") when you contact us or access our Services;
to request your participation in our surveys about our organization, organizations we partner with, and the Services;
to help maintain the safety, security and integrity of our property and Services, technology assets and business;
to operate, improve and optimize our games and other Services;
to personalize our Services, understand our users and their preferences to enhance user experience and enjoyment using our Services and improve our users' experience;
to provide access to certain areas, functionalities and features of our Services, including social features and multiplayer competitions;
to communicate with you regarding Services-related information, including confirmations, technical notices, updates, security alerts and support and administrative messages;
to enable players to communicate with each other in games or on our social media accounts;
to respond to your comments and inquiries and provide customer support services;
to prevent potentially prohibited or illegal activities, including cheating or fraud and to protect our players;
to measure interest in our Services;
to ensure internal quality control;
to enable us to comply with laws that apply to us, to prevent fraud, to ensure compliance with our Terms of Service or, where necessary, to defend, exercise or establish our legal rights, including our rights under our Terms of Service;
to comply with contractual and legal obligations and requirements;
to provide support through our customer service channels when requested;
to conduct internal research and analytics;
to evaluate and enter into a reorganization, restructuring, merger, acquisition, or whole or partial sale or transfer of our business or assets ("Business Transaction"); and
to engage in cross-context behavioral and other marketing.

Do Not Sell or Share My Personal Information: We do not "sell" Personal Information about California residents in the sense of exchanging Personal Information for money. However, we disclose certain Personal Information about players of our mobile games (collectively, "Users") to advertising networks and other advertising technology providers ("AdTech Providers") to provide Users with more interesting and customized information and advertising, which is considered "selling" and "sharing" under the CCPA. Such information may include online identifiers, IP addresses, information about Services of ours that they considered, Internet or other electronic network activity information, and inferences.

Retention: We retain Personal Information only as necessary for the purposes for which the Personal Information is processed or for legal requirements. The length of time for which we retain Personal Information depends on the purposes for which we collect and use it and how long we need to retain it to comply with applicable laws (including for the purpose of satisfying any legal, regulatory, tax, accounting or reporting requirements), to establish, exercise or defend our legal rights, or to make the data available to judges and courts or the competent public authorities. Once the Personal Information is no longer necessary for the purposes for which we collected it, we will delete it.

Below is a copy of our CCPA Privacy Policy.

2. CCPA Privacy Policy

We have set out below the categories of Personal Information (as defined by the CCPA) that we have collected about California residents in the preceding 12 months and, for each category of Personal Information collected, the categories of sources from which that information was collected, whether we "sold" or "shared" such Personal Information (as defined by the CCPA), and to whom and for what purpose if so, and categories of third parties to whom we disclosed the Personal Information and the purposes of such disclosures. The table is followed by a description of the purposes for which we collected Personal Information. The word "consumer" here refers to a California resident.

Category of Personal Information	Did we collect? If so, from what source?	Did we sell? If so, to whom and for what purpose?	Did we share? If so, to whom and for what purpose?	Did we disclose apart from selling or sharing? If so, to whom and for what purpose?
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers.	Yes, from California residents directly, third parties including social media platforms and networks, and automatically via cookies and other technology.	Yes, we "sold" California residents' unique personal identifiers, online identifiers, and IP addresses to our AdTech Providers. The purpose was so that we and they can serve Users cross-context behavioral and targeted advertising.	Yes, we "shared" California residents' unique personal identifiers, online identifiers, and IP addresses to our AdTech Providers. The purpose was so that we and they can serve Users cross-context behavioral and targeted advertising.	Yes, as described in our Privacy Policy.
Commercial information, including records of personal property, products or services paid for, obtained, or considered, or other consuming histories or tendencies.	Yes, from California residents directly.	Yes, we "sold" California residents' records of products or services considered to our AdTech Providers. The purpose was so that we and they can serve Users cross-context behavioral and targeted advertising.	Yes, we "shared" California residents' records of products or services considered to our AdTech Providers. The purpose was so that we and they can serve Users cross-context behavioral and targeted advertising.	Same as above.
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer's interaction with an internet website application, or advertisement.	Yes, from California residents directly, third parties including social media platforms and networks, and automatically via cookies and other technology.	Yes, we "sold" California residents' browsing history, search history, and information regarding a consumer's interaction with an internet website application, or advertisement to our AdTech Providers. The purpose was so that we and they can serve Users cross-context behavioral and targeted advertising.	Yes, we "shared" California residents' browsing history, search history, and information regarding a consumer's interaction with an internet website application, or advertisement to our AdTech Providers. The purpose was so that we and they can serve Users cross-context behavioral and targeted advertising.	Same as above.
Geolocation data (general location based on Internet Protocol address).	Yes, from California residents directly, third parties including social media platforms and networks, and automatically via cookies and other technology.	Yes, we "sold" California residents' geolocation data to our AdTech Providers. The purpose was so that we and they can serve Users cross-context behavioral and targeted advertising.	Yes, we "shared" California residents' geolocation data to our AdTech Providers. The purpose was so that we and they can serve Users cross-context behavioral and targeted advertising.	Same as above.
Inferences drawn from any of the information identified herein to create a profile about a consumer reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Yes, we make inferences about California residents' interests.	Yes, we "sold" inferences about California residents' interests to AdTech Providers. The purpose was so that we and they can serve Users cross-context behavioral and targeted advertising.	Yes, we "shared" inferences about California residents' interests to our AdTech Providers. The purpose was so that we and they can serve Users cross-context behavioral and targeted advertising.	Same as above.

We may have used Personal Information for the following purposes.

to enable us to personalize your in-game profile, provide our games (including the social elements of our games, such as team play and competitions), to ensure that the services you have paid for are activated in the games, and to provide you with player support if you need it;
to enable us to optimize our games for you and for the device that you are using, as well as to deliver customized in-game events, offers and promotions;
to manage our organization and its day-to-day operations;
to verify your identity and entitlement to products or via our Services when you contact us or access our Services;
to request your participation in our surveys about our organization, organizations we partner with, and the Services;
to help maintain the safety, security and integrity of our property and Services, technology assets and business;
to operate, improve and optimize our games and other Services;
to personalize our Services, understand our users and their preferences to enhance user experience and enjoyment using our Services and improve our users' experience;
to provide access to certain areas, functionalities and features of our Services, including social features and multiplayer competitions;
to communicate with you regarding Services-related information, including confirmations, technical notices, updates, security alerts and support and administrative messages;
to enable players to communicate with each other in games or on our social media accounts;
to respond to your comments and inquiries and provide customer support services;
to prevent potentially prohibited or illegal activities, including cheating or fraud and to protect our players;
to measure interest in our Services;
to ensure internal quality control;
to enable us to comply with laws that apply to us, to prevent fraud, to ensure compliance with our Terms of Service or, where necessary, to defend, exercise or establish our legal rights, including our rights under our Terms of Service;
to comply with contractual and legal obligations and requirements;
to provide support through our customer service channels when requested;
to conduct internal research and analytics;
to evaluate and enter into Business Transaction; and
to engage in cross-context behavioral and other marketing.

We do not have actual knowledge that we sell, or share for cross-context behavioral advertising, the Personal Information of California residents under 16 years of age. We may use deidentified information for any purpose. We commit to maintaining and using deidentified information in deidentified form and not to attempt to reidentify the information, except for the purpose of determining whether our deidentification processes satisfy applicable legal requirements.

3. CCPA Rights

As a California resident, you have the following rights under the CCPA:

The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom we disclose Personal Information, and the specific pieces of Personal Information we have collected about you. You may only exercise your right to know twice within a 12-month period.
The right to delete Personal Information that we have collected from you, subject to certain exceptions.
The right to correct inaccurate Personal Information that we maintain about you.
The right to opt out of the sale or sharing of your Personal Information by us. We disclose the Personal Information of Users residing in California to advertising business partners for the purposes of supporting our advertising efforts and, as such, we "sell" and "share" Personal Information as these terms are defined under the CCPA. Please note that we do not monetize Personal Information in the sense of disclosing your Personal Information in exchange for money. Please also note that, if you exercise your right to opt-out of the "sale" and "sharing" of your Personal Information, we may still disclose your Personal Information to third parties for purposes other than cross-contextual behavioral advertising, as described in our privacy disclosures.
The right to limit our use and disclosure of sensitive Personal Information to purposes specified at Section 7027(m) of the CCPA Regulations. We do not collect sensitive Personal Information as the CCPA defines this term.
The right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, in violation of California Civil Code § 1798.125, including an employee's, applicant's, or independent contractor's right not to be retaliated against for the exercise of their CCPA rights.

4. How to Exercise CCPA Rights

Methods of Submission and Instructions:

Do Not Sell or Share My Personal Information: To submit a request to exercise your right to opt-out of selling and sharing in-game, you may email cointalesvip@rjoy.com to submit an opt-out request.
Other CCPA Rights: To submit a request to exercise your rights to know, delete or correct, please contact us at the contact information further below and describe your request.

Verification: Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information. You may designate an authorized agent by taking the steps outlined under "Authorized Agent" further below. In your request or in response to us seeking additional information, you, or your authorized agent, must provide sufficient information to allow us to reasonably verify that you are, in fact, the person whose Personal Information was collected which will depend on your prior interactions with us and the sensitivity of the Personal Information being requested. We may ask you for information to verify your identity and, if you do not provide enough information for us to reasonably verify your identity, we will not be able to fulfil your request. We will only use the Personal Information you provide to us in a request for the purposes of verifying your identity and to fulfill your request.

Authorized Agents: You can designate an authorized agent to make a request under the CCPA on your behalf if:

The authorized agent is a natural person or a business entity and the agent provides proof that you gave the agent signed permission to submit the request; and
You directly confirm with Company that you provided the authorized agent with permission to submit the request.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4121 to 4130, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

5. Contact Us

If you have any questions about our privacy practices, personal data processing activities, or would like to exercise your rights under privacy laws, you may contact our Data Protection Officer at cointalesvip@rjoy.com.

6. Changes

From time to time, we may revise this Statement. When we do so, the changes will be posted and the revised document will be available online and the "last updated" date above revised.