Privacy Policy

1. Who decides how your data will be used?

Generally, the data controller responsible for deciding how your personal data will be used is Ludens LLC.

If you have any questions or comments about this policy, you can:

● email us at [email protected]
● contact the person responsible for processing personal data at [email protected]

2. What information we collect about you and how we use it

This Privacy Policy governs how we use any information that can or could be used to identify you ("Personal Information"). It does not cover information that cannot be used to identify you ("De- identified Information").

We need to collect and use certain Personal Information in order to provide you with the Services and to fulfill our promises in our User Agreement:

● When you sign up for the Services, you provide us with your Personal Information voluntarily by providing it to us, for example, when you create an account. We collect and use such information to enable us to authenticate you when you sign in to your account and use the Services, to verify your eligibility and ability to access the Services, and to ensure that you receive the correct version of the Services. This information includes your age, the in-game username you choose to use on our Services, and the internal identifiers we assign to your account.

● In order to use our Services, you must have an account on a third-party service we support
that provides a single sign-on capability. Because of this, the Personal Information we collect will also depend on which third-party accounts you choose to use, the privacy policies of those services, and your privacy settings on those services that allow us to see when you are using those services to access the ArCraft Services.
○ If you decide to link your Google account to Google Services, we will get your email address in Google Mail and an authentication token that Google will tell you.

If you choose to link your Apple account to the Services, we will get your email address registered in your Apple profile, or, if you use the "hide my email address" option that Apple provides, the email address usedto forward messages.

● Depending on which specific Service you subscribe to, we may maintain other third-party single sign-on services and receive additional Personal Information from them. For more information, see the "Game Specific Disclosures" section at the end of this Policy.

Some third-party providers may notify you that they provide us with additional information, such as your public profile information, when you use a login service through such services. We do not collect such information fromthem.

● We collect and use information about your device's location when you use our Services (and, if you choose to enable background location tracking by our Services when you are not interacting directly with the Services), including yourmovements and events that occur during the course of the game. Our Services include location-based games, the primary function of which is to provide in-game reality based on your location in the real world, so we need to know where you are in order to set up such games for you and schedule game resource locations in ArCraft). We determine your location using various technologies, including GPS, the WiFi access points you connect to when using the Services, and the location of mobile/cell phone transponder towers.

● We also collect and use data about your activities and achievements in the game, as well as
certain information about your mobile device (including device IDs, operating system, device model, configuration and settings, and the programs installed on it), which allows us to customize the Services and personalize your experienceand user interface.

● We also use the above information to show in-game sponsored locations that are close to you as part of the gameplay.

● In addition, we use the above information to provide you with technical and customer support.
● You also provide us with Personal Information when you make in-game purchases, subscribe to our publications, register for in-person events, participate in contests, promotions, sweepstakes or surveys, or communicate with us. Depending on which of our Services you use, you may include your name, mailing address, phone number, country of residence, age, and email address. We use such information to provide you with such Services and to provide you with related customer support.

In addition, we have a legitimate interest in using your Personal Information for the following purposes:

● Your IP address, browser type, your operating system, the web pages you visited before accessing our Services, the pages of our Services you accessed or features you used, and the time you spent on or with those features, the click-through links to our Services you activated, device IDs and ad networks, age, and actions you took in the game, your in-game user settings and preferences and your in-game microtransactions - in order to provide the

● Your contact information, namely your email address, in order to contact you for technical and customer support.

● Your internal account ID number and in-game user name to associate with your account any user content (such as local landmarks) that you choose to submit to ArCraft through the Services. You may choose not to have your in-game user name associated with your use of ArCraft products by indicating so in the appropriate ArCraft Wayfarer settings.

● your email address and information about your device - to share updates and news with you directly in the game or via email. You can unsubscribe from this at any time using your device or app settings.

● Analysis of your activities and achievements in the game - to show you gifts, promotions and other offers related to our Services, personalized to your personal user experience. You may opt-out of this and certain other forms of processing of your Personal Information by following the steps outlined in Section 7 below.

● To personalize the ads you see in our applications to make them more relevant to you, and to display sponsored giveaways containing messages and/or offers from our advertisers, taking into account your location on the game map. You can unsubscribe from receiving sponsored giveaways in the app settings. You can unsubscribe from receiving personalized advertisements by going to the settings section of your device and activating the "Limit

tracking of advertising preferences" function on Apple devices or the "Opt-out of personalized advertising"function on Android devices.

● To provide social features in our games so that you can interact and play with other players, including saving your correspondence, content, and other information you share with those players, finding your friends and allowing other players to find you, including through imported contacts, and sharing your gaming experience and achievements with friends. You can use the internal ArCraft profile settings to opt out of these features.

● To provide augmented reality functionality. To do this, ArCraft needs to acquire geospatial data from your device's camera. Such data is then processed by ArCraft servers in such a way as to allow you and other players to interact around the same virtual objects at the same time in a shared physical space. For more information about augmented reality functionality and data protection, please contact our Help Center.

● To offer new or additional features of our Services.

● To organize and host in-person events dedicated to or based on our games. Please note that when you participate in in-person events, your in-game activities and achievements, user name, your avatar, your team name and other attributes of your in-game profile will be visible to other event participants and the general public (for example, on banners displayed at the event and online).

● Data about your gaming activities and achievements, as well as certain information about your mobile device (including device IDs, operating system, device model, configuration and settings, and third-party applications and programs installed on it) - to implement measures against fraud and cheating ("cheating") - actions prohibited by our User Agreement, to ensure that we provide a level playing experience for all game participants.

● To disclose information when required by law and when necessary to assert claims, exercise rights, or defend againstthird-party claims.

We will only use your Personal Information for the following purposes with your consent:

● If you choose to enable background tracking on our Service (such as Adventure Sync in the ArCraft game), we will collect your Personal Information when you use the Services and in the background when the Services are not open on your devices. This includes data about your device's location and your physical activity (from your pedometer, calorie burner, and distance run counter). We use this background data about your activity to provide you with certain features as part of the Services, such as in-game items and prizes based on your exercise level and your location, and alerts about upcoming game events. You may change your mind and disable background activity tracking at any time through your device or app settings.
With your permission, we use your device's mobile fitness app (Apple HealthKit if you use an Apple device, or GoogleFit if you use an Android device) to collect your workout data: we read and/or record your workout data on the fitnessapp installed on your device to activate the background activity recording feature and ensure that all your movements during games are "scored" in your fitness app. We do not use data collected through the Apple Health Kit or Google Fit for advertising or marketing purposes. Our Services cannot read your fitness app data or record it on your devices without your consent. You can disable our access to any type of data about your physical activity through the Apple Health or Google Fit settings on your device at any time.

● If you choose to include information about any ArCraft in-person or in-game events on your mobile calendar, we will, with your permission, access the calendar app on your device to record such events on it. We do not collect any otherinformation from your calendar. You can change your mind and disable our access to your calendar at any time throughyour device or app settings.

● If you would like to help ArCraft in its work on developing new augmented reality mapping technologies, you can enable video recording of public spaces around landmarks when you participate in games and send us your video recordings with geolocation information from your device. We do not collect audio from these recordings. We will anonymize this information in various ways, including image blurring, and we will use it to build three- dimensional models of various real-world locations in order to create and offer our users new kinds of augmented reality objects. You can disable this feature at any time in your app's settings.

● If you choose to link your game account to any authorized external device, such as ArCraft,
we will request permission from your phone to establish a Bluetooth connection to the external device and activate the appropriate game functions. You can deny us access to your device's Bluetooth module at any time in the device settingsor by disconnecting the external device from the game.

● If you choose to import contacts from your device's address book to find out which of your contacts are using our Services and to send them requests to be added to your friend list or invitations to join you in our games or other aspects of our Services, we will periodically synchronize your contact information, including phone number and email address,through our servers. It is your responsibility to ensure that the collection and transmission of your contact information to us complies with applicable law. This may require obtaining consent from your contacts. We may also receiveinformation about you from other ArCraft users who import or enter data about their contacts. We will use and store such contact information to help you and your contacts communicate through our Services. You may change your mindand close ArCraft's access to your contacts at any time through your device or app settings.

● If you choose to upload content, such as photos or videos, from your mobile device to our
Services, we will access your device's media storage with your permission. You can change your mind and disable our access to your media storage at any time through your device or app settings.

● We will send you marketing materials via email or app notifications. You can unsubscribe from this service at anytime using your device or app settings.

3. Who we share information with

We will only share any Personal Information we receive from or about you in the following situations:

Communicating information to our service providers. We engage third-party service providers to administer and provide Services to us. As part of this process, they will process your Personal Information on our behalf. Such third-party service providers will only have access to your Personal Information to provide services on our behalf and in accordance with this Privacy Policy. We ensure that each service provider is contractually bound not to disclose or use your Personal Information forany other purpose. The service providers whose services we use help us:

● run, administer and maintain our Services using third-party platforms and software tools;
● perform content moderation and failure analysis;
● conduct email and mobile messaging campaigns;
● conduct game and marketing analytics;
● Conduct in-person events, competitions, sweepstakes and promotions, including player registration, managing participant registration and attendance, checking attendance eligibility and awarding prizes;
● determine the origin of payments;
● provide technical and customer support; and
● process payments for tickets to in-person events and other purchases.

Some third party service providers may also collect information directly from you (for example, a payment processor may request your billing or financial information) as a third party in accordance with their own privacy policies. Such third-party service providers do not share your financial information, such as your credit card number, with ArCraft, but may share with us a limited amount of information related to your purchases, such as your zip code.

Communicating information to other players. When you use the Services, in particular when you play our games, engage in our social features (including cross-game features) or participate in in- person events, we will share your Personal Information with other players. This Personal Information includes your in-game profile information (such as your user name, your avatar, your online status, and your team), your in-game activities and achievements, the real-world locations associated with your playthrough and the resources you interact with in ArCraft games, your in-game messages, and related content you share with other players. In addition, certain games contain links to third-party services through which you may share information outside of the Services; ArCraft does not control and is not responsible for the operation of such third-party information-sharingfunctionality.

Publicly Disclosed Information: When you use the Services, particularly when you play our games, use the competitive features, or participate in our forums, the following information may appear on publicly accessible web pages and therefore become publicly available: your user name, in-game profile, achievements, and public messages.

Information shared with third parties. We share anonymized data with third parties for industry and market analysis purposes. We may share data with our third-party publishing partners for their direct marketing activities, but only with your express consent. We do not share Personal Data with any other third parties for direct marketing purposes.

Information disclosed for our protection and the protection of others. We assist government and law enforcement agenciesor private organizations in enforcing the law. We disclose information about you to government and law enforcement agencies or private parties when in our reasonable judgment it is necessary or appropriate: (a) to respond to claims, service of process (including subpoenas and warrants), (b) to protect and secure our property and our rights and the safety of third parties or the public, and (c) to detect and stop any conduct that we consider illegal, unethical or likely to result in prosecution.

Information disclosed in connection with transactions. Information we receive from our users, including Personal Information, is a business asset. If we are acquired by a third party in a transaction such as a merger, acquisition or acquisition of an estate, or if our assets are acquired by a third party in the event we go out of business or bankruptcy proceedings, some or all of our assets, including your Personal Information, will be disclosed or transferred to the acquirer in connection with such atransaction.

4. How your Personal Information is transferred

ArCraft provides its Services worldwide. Your Personal Information may be transferred outside of your country and stored inanother country, including the United States, for the purposes set forth in this Privacy Policy if permitted by applicable law. The laws in those countries regarding the protection of Personal Data may differ from the laws in your country.

If we transfer your Personal Information from the United Kingdom or the EEA to other countries, including the United States, we will ensure that your Personal Information has the same level of protection as in the United Kingdom or the EEA, asapplicable, by ensuring that at least one of the following conditions is met:

● The country to which your Personal Data is transferred is deemed by the European Commission (or the UKGovernment, if you are in the UK) to provide an adequate level of protection for Personal Data, as in the UK or theEEA, as the case may be.
● When engaging service providers, we use specific contracts on a form approved by the European Commission (or the UK Information Commission if you are in the UK) that provide the same protection for Personal Data that they use inthe UK or, as the case may be, the EEA.

5. How we protect your Personal Information

We use appropriate legal, organizational and technical security measures to protect your Personal Information from accidental loss, unauthorized use or access, improper alteration or disclosure. We also provide access to your Personal Data only to those employees, agents, contractors, and other third parties who need it for their work. They will only process your Personal Information based on our instructions and are bound by confidentiality obligations. We have implemented procedures that setout how to proceed if we suspect a breach of confidentiality (a leak) of Personal Data. If we have a legal obligation to do so, we will notify you and the competent supervisory authority of such a leak.

6. How long we keep your Personal Information

We retain your Personal Information for as long as we provide the Services to you and until we achieve the purposes outlined inthis Privacy Policy. This also applies to anyone with whom we share your information and who provides services on our behalf.

When we no longer need to use and store your Personal Information in accordance with our legal obligations, we will either delete it from our systems or anonymize it so that it can no longer be associated with you. When we delete Personal Information, we will take commercially and technically reasonable steps to ensure that such Personal Information cannot be recovered or reproduced.

7. Your rights and choices

You have certain rights with respect to your Personal Information. This means that you can:

● Request access to your Personal Information that we hold by sending an email request to [email protected]

● Delete or correct your Personal Information. The easiest way to update your account information is to change the information in your account or in your application settings. You can also do this by sending a request to our customer support team at [email protected].

● link for ArCraft [email protected]

● link for Ingress, [email protected]

● Ask us to stop processing your Personal Information, including for promotional and marketing purposes, such as personalized rewards, promotions and other offers, by emailing us at [email protected] . Keep in mind that sometimes we need your Personal Information to provide the Services to you;

● Request that your Personal Data be transferred to another organization (if technically possible);

● to file a complaint with the competent supervisory authority. We would like to be able to resolve problems directly with you, so we would prefer that you contact us first. However, if you are in the United Kingdom or an EEA country and you believe that we are not complying with data protection laws, you may file a complaint with your local competent supervisory authority;

● If you are in the European Economic Area (EEA), you can also contact our representative in the European Union (EDPO). The EDPO can be contacted by:

The law provides exceptions to these rights in certain circumstances. When you cannot exercise any of these rights because ofan exception, we will tell you why.

We offer you choices regarding the collection, use and transfer of your Personal Information and will respect your choice. Please note: If you choose not to provide us with the Personal Information we request, you will not be able to access allfeatures of the Services.

After you contact us, you may receive an email to verify the authenticity of your appeal. We will endeavor to provide you with the information or fulfill your other request within 30 days or such shorter period as may be required by the laws of your country.

8. Children

Unless otherwise specified for a particular Service, children are not allowed to use the Services and we do not collect their Personal Information. We define "children" as follows:

● UK residents: persons under 13 years of age;
● EEA residents: persons under the age of 16 or the age at which a person can consent to the processing of personaldata in the relevant country;
● residents of the Republic of Korea: persons under 14 years of age;
● Residents of other regions: persons under the age of 13 or the age at which a person can consent to the processingof personal data in the country concerned.

The collection, use or disclosure of Personal Information about a child requires the verifiable consent of the child's Parent. ArCraft will not collect, use or disclose any Personal Information about a child without obtaining such consent from the child's parent or guardian. We may ask the child to provide the Parent's email address to request such consent; however, the Parent's email address will be deleted if consent is not received by us within a reasonable time.

Upon completion of verification, the Parent may provide their consent to their child's access to the Service. When creating a user account, ArCraft will collect such information as the in-game user name the child chooses to use on our Services, the internal account identifiers we will assign to the child's account, and, with Parent's permission, the child's personal email address. We need this information to authenticate your child's account, to verify your child's eligibility and ability to access theServices, and to ensure that you receive the correct version of the Services. As Child accesses and uses the Services, ArCraft will also collect and use Child's device location information and other Personal Information listed in this Privacy Policy in order to make the Services work for Child as

described in this Privacy Policy. If we require additional information for any other purpose, we will first seek your permissionto obtain it.

If we learn that we have received a child's Personal Information without parental consent, we will take steps to delete such information from our files as soon as possible.

If you have any questions about how we handle Children's personal information, please email us at [email protected] or write to us at the ArCraft mailing address listed in Section 1.

9. Changes to this Privacy Policy

Any Personal Information we collect is subject to the Privacy Policy as in effect at the time it is collected. We may make changes to this Privacy Policy. You will be notified in advance and in due course of any material change.

10. Third parties

When using our Services, you may access links to websites and services owned or operated by third parties (each, a "Third Party Service"). Any information you provide to or collect through a Third Party Service will be provided directly to the owner or operator of that Third Party Service and will be subject to the privacy policies of that owner or operator. We are not responsible for the content, security or reliability of any Third Party Services or their information practices or privacy practices.
In order to protect your information, we recommend that you carefully read the privacy policy of any Third Party Service thatyou access.

Special Disclosure Requirements for Persons Residing in California

California law requires us to disclose certain information about you. We do not sell your Personal Information. The information listed in Section 2 falls under the following categories of the California Consumer Data Protection Act (CCPA): identifiers, business information, Internet or other electronic network activity, geolocation data, and video information.

More privacy information for ArCraft

If you choose to link your ArCraft account to the Services, we will store the unique user ID provided by ArCraft and your email address on file with your ArCraft account (if available). You can also import your Mii avatar into certain ArCraft Services. If you register for an ArCraft account on behalf of a child, we will also collect some of your child's personal information. See Section 8 ("Children") for more information.

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