Privacy Policy

Last Updated: May 2025

This Privacy Policy (the "Privacy Policy") serves to inform you of our policies and procedures regarding the collection, use and disclosure of the information we receive when you access and use all websites (the "Sites"), services, software, mobile applications (including without limitation mobile games), content, and all other products and services (all of the foregoing collectively and any of them, the "Services") owned, controlled or offered, directly or indirectly, by Suga Technology JSC or its subsidiaries and affiliates ("Suga", "we," "our" or "us"). Users, account holders, customers, visitors, and others who download, access, use and/or subscribe to the Services ("you" or "User") agree to the following Privacy Policy. The Privacy Policy is incorporated by reference into our Terms of Service, currently available at supga.net/terms. By using the Services, you hereby warrant and represent that you have read, understand and agree to this Privacy Policy and the Terms of Service and that you are over 18 years of age. PLEASE DO NOT USE, INSTALL OR ACCESS THE SERVICES IF YOU DO NOT AGREE TO THIS PRIVACY POLICY.

INFORMATION WE COLLECT

PERSONAL DATA

"Personal Data" means data about you that allows someone to identify you, including, for example, your name, address, geographic location of your computer or mobile device, telephone number, email address, payment method as well as any other information about you that is associated with or linked to any of the foregoing data. We may collect Personal Data from you when you:

The Personal Information we collect will vary depending upon the Services you use and may include, but not limited to:

a) Registration Information

If you create an account, you may provide us your name, username, e-mail address, password, and other information that helps us confirm that you are accessing your Account. If you sign into the Services with Facebook Connect, we will collect information that is visible via your Facebook account such as your first and last name, Facebook ID, profile picture/URL, and list of Facebook friends.

b) Payment Information

When you order any good or service through the Services or Sites, including any virtual currency or virtual good, our payment processing service provider will collect your name, phone number, e-mail address, mailing address, billing address, and complete credit card information. Payment transactions for in-app purchases are completed through the app store via your Apple iTunes Account or Google Play account.

c) Information Collected by 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 gameplay or activity on the Services, and your username or ID number.

d) Technical and Usage Information

When you access our Services, we may collect usage statistics about your interactions with the Services, certain technical information about your mobile device or computer system, location based on the IP address, and network-based geo-location data.

AUTOMATICALLY COLLECTED INFORMATION

We will also collect certain pieces of information automatically and passively in order to provide the Services. The information collected typically includes browser, mobile device model, device IDs or other device identifiers, operating system or platform type, IP Address, device language and time zone, network Media Access Control (MAC) address and connection, referring site, and the date and time of each visitor request.

COOKIES AND OTHER TECHNOLOGIES

A "cookie" is a small file stored by your browser when told to do so by a website. The cookies are typically used to quickly identify your device and to "remember" your browser or sessions during subsequent visits for purposes of functionality and preferences. We also use cookies to deliver content specific to your interest, to monitor Site or mobile application usage, and to collect information on which ads or links are clicked. You can instruct your browser to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.

IP ADDRESS

When you visit and interact with the Sites, we and/or third parties may collect your Internet Protocol Address ("IP Address"), which is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. We use IP Addresses to monitor the regions from which Users navigate the Sites and for fraud prevention purposes.

USE OF COLLECTED INFORMATION

Your Information is used and disclosed for, but is not limited to, the following purposes:

SERVICE PROVIDERS

Suga may engage certain service providers for additional features, such as payment processing, hosting, providing analytics, and helping us deliver and develop the Services. Third parties will not be able to use Your Information in ways that are prohibited by this Privacy Policy.

ADVERTISERS

We may use, share and disclose Your Information with our partners and service providers to deliver targeted advertisements that we believe will be of most interest to you. To the extent we display advertising in our Services, we may allow advertising networks of our affiliates and partner networks to collect information about your mobile device to enable them to serve targeted ads to you.

You may visit www.aboutads.info/choices to learn more about interest-based advertising and how to opt-out. You may also opt out of personalized advertising by adjusting the privacy settings on your device or browser.

ANALYTICS INFORMATION

We use third-party analytics tools to help us measure traffic and usage trends for the Services. These tools collect information sent by our mobile application that you have downloaded or are using, or your browser as part of a web page request, including the web pages you visit, your browser add-ons, and other information that assists us in improving the Services.

CORPORATE TRANSACTIONS

Suga may disclose certain information in the event that it is merged, acquired, sold, or some of its assets are acquired. Suga will endeavour to ensure that the entity who receives Your Information treats it in accordance with this Privacy Policy.

COMPLIANCE WITH LAW AND LAW ENFORCEMENT

We will disclose any information about you to government or law enforcement officials or private parties as we believe necessary or appropriate to comply with a legal requirement or process, enforce the Privacy Policy or the Terms of Service, respond to claims of a violation of the rights of third parties, or protect our rights, property, or safety.

TRANSFER OF PERSONAL DATA OUTSIDE YOUR COUNTRY

We may transfer information that we collect about you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. We take steps to ensure adequate safeguards are in place to enable transfer of information and the use and disclosure of information about you, including personal data, as described in this Policy.

SPECIFIC PROVISIONS FOR CALIFORNIA CONSUMERS

The California Consumer Privacy Act of 2018 ("CCPA") provides additional rights to know, delete and opt out. You can request to know what personal information we collected, disclosed, used and sold, and request that we delete your personal information at any time. To exercise your right to know and right to deletion, please submit a request by emailing tuyendung@supga.net with the subject line "California Rights Request".

SPECIFIC PROVISIONS FOR EU INDIVIDUALS

At any time, you may contact Suga and request to access the personal data that Suga holds about you. You also have rights to withdraw consent, erase or restrict access to your information, and data portability. If you consider that our processing of your personal data infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority.

SECURITY

Suga uses a variety of industry-standard security technologies and procedures to help protect your personal data from unauthorized access, use, or disclosure. However, we cannot guarantee that unauthorized third parties will never be able to overcome those measures or use your Personal Information for improper purposes.

CHILDREN

While we allow minors under 13 (and in certain jurisdictions under the age of 16) to use the Services, only parents, legal guardians, or other adults are allowed to make purchases through our Services. We may not knowingly collect information that includes Personal Information of children under the age of 13. If we learn that we have collected any Personal Information from children under 13, we will promptly take steps to delete such information.

MANAGING YOUR PRIVACY

You can correct or delete your account information by emailing us at tuyendung@supga.net. If you cancel your account or request us to delete Your Information, Suga will delete information accessible to Suga within thirty (30) business days.

CHANGES TO THE PRIVACY POLICY

Our Privacy Policy is periodically reviewed and enhanced as necessary. This Privacy Policy might change as we update and expand the Services. We will endeavour to notify you of these changes by email or in-app notification. Your continued use of the Services after any change in this Privacy Policy will constitute your acceptance of such change.

CONTACT US

To request data deletion, please visit our Data Deletion page or contact us directly:

APPENDIX A – ADVERTISING NETWORKS

For personalized advertisement experience, the following advertising networks may collect or receive device information from our apps:

APPENDIX B – ANALYTICS PROVIDERS