Privacy Policy

1. Introduction

This Privacy Policy ("Policy") sets forth the manner in which APEX GAMES – FZCO, a company duly incorporated under the laws of Dubai, United Arab Emirates, with its principal office located at IFZA Business Park, Dubai Digital Park, Dubai Silicon Oasis, Dubai ("APEX GAMES," "we," "us," or "our") collects, processes, uses, stores, and discloses personal and non-personal data of individuals ("users", "you") in connection with their use of our interactive entertainment products, websites, applications, and related services ("Services").

By accessing, downloading, registering for, or otherwise using the Services, you expressly acknowledge that you have read, understood, and agree to be bound by this Privacy Policy and consent to the data practices described herein. If you do not agree with this Policy, you must refrain from using the Services.

This Policy is intended to comply with applicable data protection legislation, including but not limited to the General Data Protection Regulation (EU) 2016/679 (“GDPR”), the Brazilian General Data Protection Law (“LGPD”), and relevant privacy regulations within the United States and other jurisdictions.

2. Information We Collect

We may collect and process the following categories of personal and non-personal data, either directly from you or automatically through your use of the Services:

1. Personal Data

   Personal Data refers to any information relating to an identified or identifiable natural person. This includes, but is not limited to:

   • Identity data: nickname, username, and any identifiers provided via linked social media accounts;
   • Contact data: email address, phone number, mailing/billing address (as provided);
   • Financial and transactional data: purchase history, transaction identifiers, and other related metadata.

   Note: we do not retain or store your full payment card details; transactions are processed by PCI-DSS compliant third-party providers.

   • Technical data: IP address, device type, operating system version, hardware specifications, advertising identifiers, browser type, and other device-related diagnostics;
   • Usage and interaction data: session logs, in-game behavior, messages, in-game voice or text communications, support inquiries, and in-game purchases.
   • Geolocation data: region or country derived from IP address, used to optimize service delivery and server allocation.
   • Attribution data: marketing referral information for campaign performance analysis.

2. Non-Personal Data

   Non-Personal Data may include information that, by itself, does not identify you. It may include:

   • Aggregated or anonymized gameplay statistics,
   • Browser settings and configurations,
   • Clickstream data, event triggers, and interaction metrics.

   Such data is primarily used for system diagnostics, gameplay balancing, analytics, and product enhancement purposes.

3. Children’s Privacy:

The Services are not directed to, and we do not knowingly collect data from, individuals under the age of eighteen (18) or below the age of majority in their country of residence. If we discover that we have inadvertently collected Personal Data from such individuals, we will take prompt steps to delete that data and restrict further access.

In compliance with the Children’s Online Privacy Protection Act (COPPA) and related laws, we do not knowingly solicit or retain any Personal Data from individuals under thirteen (13) years of age in the United States. If we discover that we have collected such data, it will be immediately and permanently deleted.

Age Restrictions by Region:

• European Union (EU): Users must be 18 or older under GDPR. EU users have rights to access, correct, or delete their data as detailed in this Privacy Policy.
• Brazil: Users must be 18 or older under LGPD and have the right to access, correct, or delete their personal data.
• United States (USA): In accordance with COPPA and other applicable laws, users must be 18 or older. Parental or legal guardian consent is required for minors to use the Services, and we do not knowingly collect data from individuals under 13 years of age.
• Other Regions: Users are responsible for complying with local laws regarding age restrictions. Use of the Services where prohibited by law is not allowed. APEX GAMES is not liable for misuse by individuals who misrepresent their age.

4. Purpose and Legal Basis for Processing

We process your Personal Data only where there is a valid legal basis, which may include one or more of the following:

• Performance of a contract: to provide the Services, including account management, technical support, and in-game features, pursuant to our Terms of Use;
• Legitimate interests: to safeguard the integrity of our Services, prevent fraud and abuse, perform analytics, and enhance user experience, provided such interests are not overridden by your rights;
• Consent: where required by law, for optional features such as personalized advertising, email marketing, or participation in promotions;
• Legal obligation: to comply with applicable legal and regulatory requirements, including consumer protection, anti-fraud, tax, or age-restriction compliance.

We obtain your express consent before processing any personal data not strictly necessary for the performance of our services, such as personalized ads, marketing campaigns, or geolocation. Consent is granular, revocable, and recorded in accordance with Brazilian General Data Protection Law (LGPD) requirements.

Use of Email as an Identifier

To provide seamless access to your account across different login methods (such as Google or Facebook), we use your email address as a unique technical identifier. If you sign in via a new login method using the same verified email, we will provide access to the existing account associated with that email. We do not merge different accounts. Your email is used solely to verify your identity and grant access to your existing account.

5. Data Sharing and Disclosure

We may disclose your Personal Data to the following categories of recipients, subject to applicable data protection safeguards:

• Service providers and vendors: including hosting providers, analytics services, advertising networks, and customer support tools, all of whom are contractually bound to protect your data.
• Payment processors: we share transaction-related data (excluding full card details) with authorized payment service providers to facilitate secure transactions.
• Affiliates and corporate partners: where necessary for operational integration or business development, provided such disclosures comply with applicable laws.
• Regulatory and legal authorities: in response to lawful requests, legal obligations, or to protect the rights, safety, and interests of APEX GAMES or its users.
• Successors or assignees: in connection with any merger, acquisition, reorganization, sale of assets, or bankruptcy.

We do not sell your Personal Data to third parties under any circumstances.

6. Data Transfers and International Processing

Due to the global nature of our Services, your Personal Data may be transferred to and processed in jurisdictions outside of your country of residence. We implement appropriate safeguards, including the Standard Contractual Clauses (SCCs) approved by the European Commission, including contractual clauses approved by Brazil's National Data Protection Authority (ANPD), or other mechanisms authorized under Articles 33–36 of the LGPD, and other jurisdictions.

7. Data Retention

We retain Personal Data only for as long as is necessary to fulfill the purposes outlined in this Policy or as required by law. The duration of retention may vary depending on:

• The nature of the data,
• Applicable legal obligations,
• Whether you maintain an active account with us.

When retention is no longer justified, your data will be securely deleted or anonymized.

8. Data Security

We implement and maintain appropriate technical and organizational security measures to protect your Personal Data from unauthorized access, disclosure, alteration, or destruction. These measures include , but are not limited to:

• Encryption protocols,
• Access controls,
• Secure data storage,
• Monitoring and intrusion detection systems.

Despite our best efforts, no system can guarantee absolute security, and you acknowledge and accept this risk by using the Services.

9. Cookies and Tracking Technologies

We use cookies, web beacons, software development kits (SDKs), and device identifiers to:

• Authenticate user sessions,
• Measure application performance,
• Enable personalized content and advertising.

You may manage your cookie preferences through your browser settings or your mobile operating system. Disabling certain cookies may affect functionality.

10. External Links and Third-Party Content

Our Services may include links to external websites or services operated by third parties. We are not responsible for the privacy practices or content of those third-party sites and encourage you to review their privacy policies prior to engaging with them.

11. Your Rights and Controls

Subject to local laws, you may have the following rights in relation to your Personal Data:

• Right of access – to know what data we hold about you;
• Right of rectification – to correct inaccurate or incomplete data;
• Right to erasure – to request deletion of your data ("right to be forgotten");
• Right to data portability – to receive your data in a machine-readable format;
• Right to object – to processing for certain purposes, such as direct marketing;
• Right to restrict processing – in certain scenarios;
• Right to withdraw consent – where processing is based on consent;
• Right to lodge a complaint – with a supervisory authority in your jurisdiction;
• Right to review decisions – you have the right to request human review of any automated decisions that affect your rights.

We will respond to verified requests within the time frames required by applicable law.

12. Jurisdiction-Specific User Rights

• European Union / EEA / UK (GDPR):
  You are entitled to all rights enumerated under Articles 12–23 of the GDPR, including objection to automated processing and profiling.
• Brazil (LGPD):
  You may request confirmation of data processing, access to or correction of your data, anonymization, data portability, and information about data-sharing practices.
• United States (Federal and State Law):
  Residents of California, Virginia, Colorado, Connecticut, and other states may have rights under their respective laws, including:
  Right to know categories of data collected and shared;
  Right to access, correct, or delete data;
  Right to opt out of sale/sharing of personal information;
  Right not to be discriminated against for exercising these rights.v
• Global Users: Users from other regions may have similar rights under local laws. We endeavor to accommodate all legitimate requests in good faith.

13. Modifications to This Policy

We reserve the right to revise this Privacy Policy at any time in response to legal, regulatory, or operational changes. If material changes are made, we will notify you through appropriate channels, such as in-game notifications or updates to our website. The effective date will always be noted at the end of this document.

To exercise your rights, please email [email protected]. We may request verification of identity before processing such requests.

14. Contact Us

If you have any questions regarding this Policy, or if you wish to exercise your data protection rights, you may contact:

APEX GAMES – FZCO
Address: IFZA Business Park, Dubai Digital Park, Dubai Silicon Oasis, Dubai, United Arab Emirates
Email: [email protected]

Last updated: June 11, 2025