Privacy Policy

TL;DR (SUMMARY)

This Privacy Policy explains what types of personal data we – NOVABITS LTD – may collect when you play our game under the title “RioRise” https://riorise.com/, why we use it, and how we share it. In general, we may collect data you give us, data collected automatically while you play, and data from third parties. We use this data to operate the game, improve your experience, provide support, ensure security, and meet legal requirements.

We also explain how long we keep data, how we protect it, and what rights you have. In short, this document gives you a complete overview of what may apply in our Game, so you always know what to expect.

INTRODUCTION

We are NOVABITS LTD with registered address at: 13 Omonoias, SOHO EMBASSY, 3052 Limassol, Cyprus (“We” or “Us”). In this Privacy Policy, we will describe how we collect and process your personal data.

This Privacy Policy applies to our video game under the title RioRise, its upgrades, patches, updates and associated services (collectively, the “Game”).

This Privacy Policy operates alongside and is supplemented by our End-User legal documents available at www.riorise.com Any capitalized terms not defined in this Privacy Policy will have the meanings ascribed to them in those End-User legal documents.

Contact Us

Please contact us at [email protected] if you have any questions about this Privacy Policy or your personal data.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy can be updated from time to time. Please check back periodically for the latest version of the Privacy Policy. If there are any significant changes made to the use of your personal data, we will notify you. Your use of the Game following any changes to this Privacy Policy constitutes your acceptance of any such changes.

WHAT PERSONAL DATA DO WE PROCESS?

Data You Provide to Us

The types of data we collect may include the following categories:

• Identification and Contact Information. To access our Game, you may need to create a registered account. The registration data typically includes your email address, password, and username.
• Data Provided to our support team. When you submit a request to our support services, we collect the information provided with your request, such as your email, name, username, ID, and the contents of your message, which may contain your gameplay data, purchase and payment details, and any other information shared during your interaction with our support team.
• Other Data You Voluntarily Provide. Occasionally, users or others may contact us with inquiries, requests, or suggestions, which may include personal data.

Data We Collect Automatically

Such data may include the following categories:

• Game Data. We may collect data about your in-Game actions – the start and duration of your gaming sessions, their results, and data about choices made within gameplay. This may also include information related to in-Game communications (for example, voice or text chats) when necessary to ensure fair play, maintain safety, and preserve the integrity and enjoyability of the Game. We collect this data to analyze and improve your game experience, ensure fair play, and provide technical support.
• Identification Information. We may collect identifiers used within our Game, such as your Player ID, account ID, or other in-Game identifiers linked to your profile or device. This information helps us provide and improve our Game, ensure security, enhance your experience, and develop new features.
• Device Data. To optimize our Game for your device and usage circumstances, we may collect information about your device to ensure compatibility, functionality, and security of our Game. This data may include, but is not limited to, the following: device ID, MAC address, crash reports, and other relevant software and hardware information.
• Transaction Data. We may collect information related to purchases made in connection with our Game, whether through the Game itself or other platforms. We use this information to process and confirm your purchases, deliver in-Game items or other content, provide customer support, and comply with accounting and tax obligations.
• Events Data. If you participate in in-Game events within our Games, we collect information about your participation and performance, as well as any data you provide during these events.
• Advertising Data. We may analyze your interactions with advertisements in our Game (if any) or from our advertising partners to promote our Game and improve our advertising performance. This data may include your device ID or advertising ID, your device settings, and your actions related to advertisements (such as clicks, website visits and account registrations).
• Cookies and Similar Technologies. We may use cookies and similar tracking technologies to recognize you and/or your device for the purposes outlined in this Privacy Policy.

Data We Receive from Third Parties

• Third-Party Platform Account Login Information. You may be able to log into our Game using credentials from social networks (e.g., Facebook), gaming platforms and consoles (e.g., Steam), device accounts (e.g., Apple ID), or similar services and websites. In these cases, the respective platform may share specific information with us, in accordance with their privacy policies. This may include your third-party account display name, user ID, email address, device identification, and location.
• Advertising and Analytical Data. We may work with business partners and vendors for advertising and marketing analysis. These third parties provide us with enhanced data through analysis, which helps us improve our Game and your user experience.

THIRD-PARTY SERVICES AND SDKS

We may use third-party services and software development kits (“SDKs”). All third-party services and SDKs provide the same or equal protection of your personal data as stated in this Privacy Policy.

LEGAL BASIS

Our legal basis for processing your personal data varies depending on the type of information we collect, and the context in which we collect it.

We rely on a number of legal bases to process information about you. We will process information about you where: (i) we have your consent, (ii) we have a legitimate interest to do so, (iii) the processing is necessary for the performance of a contract with you, and/or (iv) we have a legal obligation to process your information. For example, we may rely on:

• consent when placing Cookies on your device or sending you email marketing;
• our legitimate interests to process your information when providing you with service support, or for fraud prevention and security purposes, and to monitor and moderate in-game interactions (including voice and text communications) to maintain the integrity, safety, and enjoyability of the Game; and
• on contractual necessity to process information when you create an account, otherwise use our Game, participate in Events, or purchase Premium Content.

WHO DO WE SHARE YOUR PERSONAL DATA WITH?

In order to operate the Game, we may need to share certain personal data we collect from you with third parties, including:

• Service Providers. We might share your details with third-party entities that assist in the operation and enhancement of the Game. This means customer and technical support providers, storage solutions, newsletter and marketing service providers, payment processors, third-party account system, and other service providers.
• Public Authorities. We may need to share certain personal data if required by the law, judicial orders, or in response to legal requests.
• Protection & Security. If we decide that sharing of certain personal data is vital for the public safety, rights or assets of our users, we may need to disclose that personal data to third parties.
• Our affiliates, subsidiaries and co-owners. Should we undergo a merger, acquisition, or asset transaction, your personal data might be part of the transferred assets.

Please note that anonymous information which does not allow the identification of an individual user is not considered personal data. We may disclose such anonymous information to any third party without prior notice. Anonymous information includes aggregated, anonymized, or de-identified information about the use of our Game (e.g., "25% of players have unlocked the achievement" or “50% of players have made in-Game purchases”).

INTERNATIONAL TRANSFERS OF PERSONAL DATA

We may transfer your personal data to our affiliates and third parties located in different countries if it is necessary for the purposes described in this Privacy Policy. Some of these countries may have data protection laws that differ from those in your jurisdiction. In all such cases, we ensure that appropriate safeguards are in place and take reasonable steps to make sure your personal data is treated in accordance with the same level of protection set out in this Privacy Policy.

COOKIES

We use cookies (small files placed onto your device) and similar technologies (e.g., pixels, ad tags, local storage etc.) to recognize you and/or your device(s) across different services as well as in order to allow the use of certain functionality, including making your experience convenient and secure. For simplicity, we refer to all these technologies together as "cookies".

Cookies can be used to recognize you when you visit our Service, remember your preferences, and give you a personalized customer experience according to your settings. Cookies enable us to provide you Service faster. We use them for the following purposes:

• Security and fraud prevention. We use cookies in order to prevent fraudulent and other unlawful actions on our Services. These technologies are also vital to keep your information and our Services secure.
• Enabling features and services. Some cookies enable us to provide you with the functionality offered by the Services as well as to remember your settings and preferences. For example, such cookies are used to remember the language you chose.
• Advertising. We may use cookies to make advertising messages more relevant to you, choose ads that match your preferences and measure the number of ads displayed to you and their efficiency.
• Advertising. We may use cookies to make advertising messages more relevant to you, choose ads that match your preferences and measure the number of ads displayed to you and their efficiency.
• Analytics. This type of cookies helps us to evaluate how good are our Services, our marketing efforts, and help us customize and improve our Services.

By continuing to visit or use our Service, you are agreeing to the use of cookies and similar technologies for the purposes we describe herein. You can control cookies through your browser settings and other tools on your device.

DATA RETENTION

We retain your personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy, including providing and improving our Game, complying with our legal obligations, resolving disputes, and enforcing our agreements.

For example:

• Account Data is kept for as long as your account remains active. If you delete your account, we will delete or anonymize your data within a reasonable period, unless retention is required by law.
• Transaction Data is retained as required by applicable tax and accounting laws.
• Game and Event Data are stored for as long as needed to operate, analyze, and improve our Game.
• Moderation Data (such as voice or text chat logs, reports, and related evidence) is retained only for the time necessary to review and resolve moderation cases, enforce our Terms of Service, and ensure player safety. Temporary voice data may be processed in real time and not stored unless required for investigation.
• Technical and Security Logs may be kept for a limited period to detect and prevent fraud or misuse.

When the data is no longer necessary for these purposes, we will either delete it or anonymize it so that it can no longer be linked to you.

DATA DELITION

When you request yout Personal Data deletion, we will delete or anonymize your data so that it can no longer be linked to you. However, in some cases we may retain certain information if we have a lawful basis or legal obligation to do so - for example, to comply with accounting, tax, or fraud-prevention requirements.

Any data we retain for such purposes will be kept securely and used solely for the specific purpose for which it is retained, and not for any other reason.

DATA SECURITY

We follow generally accepted industry standards and maintain appropriate safeguards to help protect the security, integrity, and privacy of the information we collect about you. These security measures are designed to protect against the accidental or unlawful destruction, loss, misuse, alteration, and unauthorized disclosure of, or access to, the information under our control.

CHILDREN’S PRIVACY

We don’t knowingly collect any personal data from children under the age of 13. We also don’t knowingly allow them to create accounts, sign up for newsletters, make purchases, or use the Game.

We may also limit our personal data processing for EU-based users between the ages of 13 and 16.

If you are the holder of parental authority over a minor under the minimum legal age for personal data processing in your country of residence and you believe that we inadvertently received personal information about him/her/they, please contact us at [email protected] and we will delete the information from our systems as soon as possible.

DATA SUBJECT RIGHTS

You have certain rights regarding how your personal data is processed.

You may have the right to access, correct, or delete personal data we have collected about you in connection to our Game. You may also have the right to a portable copy of the personal data you have provided, and to object to or restrict processing of your personal data, such as for direct marketing. If applicable, you can request human review or contest decisions made by automated means. Where you have provided your consent to our data processing, you have the right to withdraw consent.

To protect your privacy and security, we reserve the right to verify your identity and your ownership of the account before responding to any request relating to your personal data. If we are unable to verify your identity or ownership of the account to a reasonable degree of certainty, we may reject your request.

You also have the right to make a complaint against us by contacting your local supervisory authority for data protection (if one exists in your country). We would, however, appreciate the chance to address your concerns before you contact a data protection regulator, and ask that you direct your complaint to us first.

Please see the “Contact Us” section above to learn more about how to contact us with any relevant concerns you may have.

Residents of Brazil

If you are located in Brazil, the processing of your personal data is subject to the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados — LGPD).

Under the LGPD, you have certain rights regarding how your personal data is handled, including the rights to confirm the existence of processing, access your data, correct inaccurate or outdated information, request the anonymization, blocking, or deletion of unnecessary or excessive data, request the deletion of data processed based on consent, obtain information about how we share your data, withdraw your consent at any time if processing is based on consent, and object to processing that does not comply with the LGPD.

To protect your privacy and security, we reserve the right to verify your identity and your ownership of the account before responding to any request relating to your personal data. If we are unable to verify your identity or ownership of the account to a reasonable degree of certainty, we may reject your request.

You also have the right to file a complaint with the National Data Protection Authority (Autoridade Nacional de Proteção de Dados – ANPD), though we encourage you to contact us first so we can address your concerns directly.

Please see the “Contact Us” section of this Privacy Policy to learn how to reach us regarding your personal data.

Last updated: November 6, 2025