PRIVACY POLICY

THE DA GAMES OU PRIVACY POLICY FOR LEGENDS OF ELYSIUM

1. INTRODUCTION

This privacy policy (“Privacy Policy”) sets out the ways in which we, DA Games OU, and its affiliates, collect and use your personal information in connection with Legends of Elysium (our “App”). It also explains what rights you have to access or change your personal information.

This Privacy Policy is prepared under applicable laws to inform you that your personal information will be processed by DA Games OU or its affiliate.

By accessing and using our App, you agree and consent to the terms of this Privacy Policy. If you are a minor in your country or region where you reside, you acknowledge that your parent or guardian has reviewed and consented to the terms of this Privacy Policy. If you or your parent or guardian does not agree to any term of this Privacy Policy, you must cease use of the App immediately.

2. ABOUT US

DA Games OU is a company registered in Estonia, with our address as set out below.

You can contact us:

• DA Games OU, Harju maakond, Kesklinna linnaosa, Narva mnt 13-27, 10151 Tallinn, Estonia

3. INFORMATION WE COLLECT ABOUT YOU

3.1 Information that you provide to us.

3.1.1 We will collect any information that you provide to us when you:

• Access certain features or functions in our App that require personal information.
• Choose to link your social networking service accounts (e.g., Facebook, Google, Apple ID) for purposes of login or data transfer.
• Make an inquiry, provide feedback, or make a complaint via email or our customer support site.
• Submit correspondence to us via post, email, or our customer support site.

3.1.2 The information you provide to us when you use our App will include (depending on the circumstances):

• Account ID for services provided by third parties. You may link your account with one or more accounts for services provided by third parties that we specify. Linkage to a Google account will provide your first and last name, the URL of icon images, and your email address, but such information will not be stored by us or used in the data transfer. Please also refer to the respective third parties’ privacy policies.
• Identity data. Country or region where you are located
• Player profile data.You may also provide a username, country or region preference, and language preferences.

NOTE: Do not use your real name, initials, or other customer-identifiable information in a username. This includes:

• Any in-game ID, passwords, etc.
• Inquiry information
• Any other personal information

3.2 Information we collect about you

• Transactional data. We will collect information related to your purchase transactions through our App, including the date and time, the amounts charged, and other related transaction details.
• Information contained in correspondence. We will collect any information contained in any correspondence between us, such as your name, address, email address, or telephone number. For example, if you contact us for customer support, we keep a record of that correspondence.
• Technical data. We will also collect certain information about how you use our App and the device that you use to access our App, even where you have not created an account or logged in. This might include: Device information (such as hardware model, operating system information, unique device identifiers, terminal identifier, advertisement identifier, terminal information, and terminal setting information). Unique player identifiers such as a support ID and key, transfer password, player ID, friend ID, player key, and access key. Data transmitted by your browser (such as your IP address, time zone settings, access status/HTTP status code, language settings, referral source). Information about your interactions with the App, including: Time- and date-stamped information such as page views, requests, number of sessions, and number of downloads. Users’ game progress and gameplay-related data, including game errors, in-app purchases, length of visit to the App, keystroke logs, and similar information. This information may be collected by a third-party analytics service provider on our behalf and/or may be collected using cookies or similar technologies. For more information on cookies, please read paragraph 7 below.
• App permissions. We may also request permission to access apps and certain features on your device.

4. HOW WE USE INFORMATION ABOUT YOU AND RECIPIENTS OF YOUR INFORMATION

4.1 We will use your information for the purposes listed below either on the basis of:

• Performance of your contract with us and the provision of our services to you.
• Your consent (where we request it).
• Our need to comply with a legal or regulatory obligation.
• Our legitimate interests.

4.2 We use your information on the basis of the above (see paragraph 4.1) and for our legitimate business objectives, including for the following purposes:

• To provide access to our App. To provide you with access to our App in a manner convenient and optimal, with personalized content relevant to you. To allow you to have a record of your gameplay within the App.
• To allow you to access certain App features. To enable you to access features such as in-app purchases and gameplay.
• To enable you to play with other players. We will use the information you have provided (such as your username and language settings) to enable you to play with other players. We may also use your data to provide balanced and ongoing gameplay (e.g., to match players with similarly skilled players or computer-controlled players).
• To process and facilitate transactions between us. We will use your information to process transactions and payments, and to collect and recover money owed to us from you.
• User and customer suport. To provide customer service and support. To deal with inquiries or complaints about our App. To share your information with our App developers, IT support provider, and payment services provider as necessary to provide customer support.
• To send push notifications. To send you push notifications about: Your use of our App. Our news, events, new App features, products, or services that we believe may interest you. This will only be done if we have the requisite permission to do so.
• Analysis. To use data analytics to improve our App, products/services, marketing, customer relationships, and experiences.
• Fraud and unlawful activity detection and prevention. To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity, including identity fraud. To protect the rights and property of Legends of Elysium, our agents, our customers, and others. To enforce our terms, policies, rules, and agreements. To protect the safety and security of any person. To protect the safety and security of Legends of Elysium’s and our partners’ services, websites, and applications.
• Compliance with policies, procedures, and laws. To enable us to comply with our policies and procedures and to enforce our legal rights. To share your information with our technical and legal advisors. To comply with laws or respond to lawful requests and legal processes, including complying with a court order or subpoena.

4.3 If you are in the EU, the United Kingdom, or other certain countries/regions and have any concerns about our processing, please refer to details of “The Rights of Users in Certain Countries/Regions” in paragraph 10 below.

5. WHO WE MIGHT SHARE YOUR INFORMATION WITH

In connection with the purposes and on the lawful grounds described above, we will share your personal information when relevant with third parties such as:

• App users that you play with. Other App users who you interact with during gameplay. These users may be based both inside and outside the EU or the United Kingdom.
• Developers The following companies involved in developing and maintaining the App: Da Games OU, Exit Games Inc., Thirdweb Inc., 
• Our service providers. Third-party vendors, consultants, and other service providers who work for us. These parties may access your personal information as necessary to perform their services.
• Corporate affiliates. Our subsidiaries, including: DA Games SRL
• Prospective sellers and buyers of our business. Your information may be shared in connection with or during negotiations of: A merger. Financing. Acquisition. Bankruptcy. Dissolution. Any other transaction or proceeding involving the sale, transfer, divestiture, or disclosure of all or a portion of our business or assets.

• Ad network. Service providers that deliver advertisements to you via an ad network system related to Legends of Elysium’s current or future products and services. 
• Other third parties (including professional advisers) We may share your information with: Legal or other professional advisors. Regulatory authorities. Courts. Law enforcement agencies. Government agencies. These entities may be based in the UK, USA, EEA, and other countries/regions. Sharing may occur to: Enforce our legal rights. Protect the rights, property, or safety of our employees. Comply with legal obligations or requests where required by law.

6. USE OF INFORMATION COLLECTION MODULES FROM THIRD PARTIES

We may use third-party Information Collection Modules to Investigate trends in the use of the App. Effectively operate the App. Prevent fraud. Advertise to customers. In these cases, the following organizations may be provided with customer information for these purposes. Please also refer to the privacy policy set by the relevant company for further details.

Analysis of App Usage and Push Notifications

• Google Inc. (Google Firebase)
  • Privacy policy: https://policies.google.com/privacy

Account Linkage, Currency Management, Push Notifications, and Analytics of Usage Trends

7. COOKIES AND TRACKING

1. We, and others, use cookies, web beacons, device IDs, and other tracking mechanisms to ensure that you get the most out of our App. Cookies are small amounts of information in the form of text files that we store on the device you use to access our App. Cookies and other tracking mechanisms, such as device IDs, allow us and others to: Monitor your use of the software. Simplify your use of our App. Help us and others associate the mobile devices you use, your activities across websites, and your browsers for advertising purposes.

7.2 Our App and websites may contain content and links to other sites that are operated by third parties. These third-party sites may also operate cookies and other tracking mechanisms. We do not control these third-party sites or their tracking activities. This Privacy Policy does not apply to them. Please consult the terms, conditions, and Privacy Policy of the relevant third-party site to: Find out how that site collects and uses your information. Establish whether and for what purpose it uses cookies.

8. HOW WE LOOK AFTER YOUR INFORMATION AND HOW LONG WE KEEP IT FOR

1. We use appropriate technological and operational security measures to protect your information against unauthorized access or unlawful use.
2. We will retain your information for as long as necessary to: Provide you with the services that you have requested. Fulfill our lawful business purposes, such as legal compliance and enforcement. Resolve disputes. The actual retention period depends on various factors, including: The type of product. The type and sensitivity of the data. Business needs. Customer expectations and needs. Whether data has been deemed inactive. Available user controls. The form in which the data is stored.

8.3 We will delete your information when it is no longer required for its intended purpose. If applicable, different deletion methods apply: Printed information: Will be shredded using paper shredders or destroyed by incineration. Electronic files: Will be deleted using technical methods to ensure records cannot be restored.

9. INTERNATIONAL TRANSFERS OF YOUR INFORMATION

1. Our company is located in Estonia. The personal information we collect from you will primarily be stored in the European Economic Area (EEA). This means your data may be transferred outside your country or region, including the USA and the United Kingdom (UK).

9.2 Whenever we transfer personal information from inside the EEA or the UK to outside these regions, the transfer will be based on at least one of the following legal mechanisms: EU Standard Contractual Clauses These clauses are approved by the European Commission and the UK International Data Transfer Addendum issued by the Information Commissioner’s Office (ICO).

The transfer may be made to a country, territory, or specific sector that has been deemed by the European Commission or UK Parliament to provide an adequate level of protection for personal data.

The transfer is necessary for: The performance of a contract with you. The conclusion or performance of a contract in your interest. Taking measures at your request. Based on your explicit consent. Other legal methods available under applicable laws.

If you would like more details about the specific mechanisms we use for international data transfers, please contact us using the details provided in paragraph 2 of this Privacy Policy.

10. THE RIGHTS OF USERS IN CERTAIN COUNTRIES/REGIONS

If you are in certain countries/regions, including the European Union (EU) or the United Kingdom (UK), you have specific rights regarding the personal information we hold about you. These rights include: You have the right to be informed about how we use your personal information, as outlined in this Privacy Policy. You can request that we limit or cease processing your personal information or ask us to erase the data we hold about you. You can request access to the information we hold about you. In certain circumstances, you may also request that we transfer your data to another service provider in a structured, commonly used, machine-readable format. You can ask us to correct or rectify any outdated or incorrect information we hold about you. If we rely on your consent to process your information, you have the right to withdraw your consent at any time. If we process your information based on our legitimate interests, you may object to this processing if you believe there is something about your specific situation that justifies stopping it. You can lodge a complaint with the UK Information Commissioner’s Office (ICO): (https://ico.org.uk/). If you are outside the UK, you may also file a complaint with the relevant authority in your country/region of work or residence.

Additional Considerations. We may need to retain certain information for record-keeping and research purposes. Even if you opt out of marketing communications, we may still need to send you service-related messages regarding your user account. Some exceptions may apply to these rights in specific circumstances. If you are unable to exercise a right due to an exception, we will explain why. You can exercise your rights by contacting us using the details in paragraph 2 of this Privacy Policy. To stop receiving push notifications, update your preferences in your device settings.

11. THIRD-PARTY LINKS

Our App may include links to third-party websites, plug-ins, and apps. Clicking on these links or enabling these connections may allow third parties to collect or share data about you. We do not control these third-party websites, plug-ins, and apps and are not responsible for their privacy statements. When you leave our website, we strongly encourage you to read the privacy policy of every third-party service you visit.

12. WHAT TYPES OF INFORMATION DO WE COLLECT ABOUT CHILDREN?

Child-Specific Experience. If a user indicates that they are a child when trying to use our App, we will direct them to a different experience within the App. This experience allows the child to use our services similarly to other users but prevents the collection of additional personal information (as defined under applicable laws, including COPPA). Limited Data Collection. When a user identifies themselves as a child, we only collect a limited subset of personal information, including: Username. Unique identifiers Children can use our App, view content, and access many features without the collection of personal information (as defined under applicable law). If parental consent is required by law, we will request it before collecting any personal information.

13. ADDITIONAL PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS

1. California Privacy Law Disclosures. This section provides additional disclosures required under California law.

13.2 California Consumer Privacy Act (CCPA) Rights. If you are a California consumer whose personal information is collected through the App (“customer”), the CCPA grants you certain rights regarding your personal data. You have the right to request that companies provide you with the following information: The categories and specific pieces of personal information we have collected about you. The categories of sources from which we collect personal information. The purposes for collecting and using personal information. The categories of third parties with which we share personal information. The categories of personal information disclosed for a business purpose. 

13.3 Right to Delete or Correct Personal Information You can request that we: Delete your personal information. Correct inaccurate personal information. These rights apply under certain circumstances and may be subject to exceptions. You also have the right not to be discriminated against for exercising any of these rights.

4.  How to Exercise Your Rights You may exercise your rights by contacting us using the details in paragraph 2 of this Privacy Policy. When submitting a request, we will verify your identity where feasible. We may match your identification information with the personal data we have about you, depending on: The type of request. The level of risk associated with the requested information. Some types of information, such as unique identifiers (cookie IDs, device ID, IP address), may not be verifiable if they are not linked to directly identifiable personal data. If an exception prevents you from exercising a right, Legends of Elysium will provide an explanation. Legends of Elysium will use reasonable efforts to fulfill your request within the response times required by applicable laws.

13.5 Targeted Advertising and Data Sharing If you have given consent in the App, we may use your personal information to show ads targeted to your interests. These ads may appear: Within the App. On third-party platforms such as social media sites. Personal information shared for this purpose may include: Device technical and advertising identifiers. App activity, such as purchases. This may be considered “sharing” for cross-context behavioral advertising under California privacy law.

13.6 Other Third-Party Data Sharing In addition to the data-sharing purposes described in Sections 5 and 6, we may share data for business purposes, such as: Cloud data storage services. Security maintenance of our systems. Customer support services. 

7. California Civil Code Section 1798.83 – Direct Marketing Disclosures Under California Civil Code Section 1798.83, California customers can request information about our disclosure of personal data to third parties for their own direct marketing purposes. Legends of Elysium does not share customer personal information with unaffiliated third parties for their direct marketing purposes without your consent. For inquiries about our disclosure policy, please contact us using the details in paragraph 2 of this Privacy Policy.

14. DATA PROTECTION OFFICER

If you wish to contact our Data Protection Officer, please use the following details:

DA Games OU, Harju maakond, Kesklinna linnaosa, Narva mnt 13-27, 10151 Tallinn, Estonia

15. CHANGES TO THIS PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES

Privacy Policy Updates. We may amend this Privacy Policy at any time by updating the last modified date. If we make material changes to how we collect, use, or share your personal information: We will describe the changes in the updated Privacy Policy. If required by law, we will seek your consent for such changes. Keeping Your Information Up to Date. It is important that the personal information we hold about you is accurate and current. Please inform us of any changes to your personal information during your relationship with us by: Updating your profile account information within the App. Contacting us using the details provided in paragraph 2 of this Privacy Policy.

This Privacy Policy was updated on 3 March 2025.