Effective Date: 3 August 2020

1. WHO IS RESPONSIBLE FOR PROCESSING YOUR DATA AND HOW TO CONTACT US

This Privacy Policy applies to all of our games, websites and related services, collectively referred here as our Services. Your continued use of the Services after the effective date will be subject to new Privacy Policy.

Please read the following to learn more about how we use your personal information.

IVYMOBILE INTERNATIONAL ENTERPRISE LIMITED. (referred to as“PhotonFox”, “we”, “us”, or “our”) will be the data controller responsible for any personal data we process.

The data controller: IVYMOBILE INTERNATIONAL ENTERPRISE LIMITED.

Email: magicabingame@gmail.com

Address: Room 40,Blk AD, 19/F, Golden Bear Ind. Ctr., 66-82 Chai Wan Kok St., Tsuen Wan，New Territories.

2. WHAT PERSONAL DATA WE COLLECT AND WHY?

We may source, use and otherwise process your personal data in different ways. In all cases we are committed to protecting your personal data.

In each of the sections listed below, we describe how we obtain your personal data and how we treat it.

2.1 INDIVIDUAL CUSTOMERS

We collect personal data related to users of our Services.

A - SOURCES OF PERSONAL DATA

We may obtain your personal data from the following sources:

a)from you directly (through the game, website or online forms); and/or

b)from third parties, service providers that are assisting us in providing you with a service, or from your social networks accounts you used to sign in to our online services (for example, Facebook, Google, Game Circle, Weibo).

B - PERSONAL DATA THAT WE COLLECTAND PROCESS

We may collect the following categories of personal data relating to our existing or prospective individual customers:

a)Contact information (such as name or nickname or email you submit as part of your register for our Services or log-in or via social networks);

b)Data about your account and game progress, we create a PhotonFox-specific ID for you when you use the Services;

c)Your IP address and unique mobile device identification numbers (such as your device ID, advertising ID, MAC address);

d)Data about your device, such as manufacturer, operating system, CPU, RAM, browser type and language;

e)Broad location data (e.g. country or city-level location);

f)Precise geolocation data (GPS, with your consent);

g)Data we collect with cookies and similar technologies;

h)Data (such as your nickname, profile picture) we receive if you link a third-party tool with the Service (such as Facebook, Google or Weibo);

i)details of orders (amount spent, date, time, vouchers or offers used);

j)Data to fight fraud (such as refund abuse in games or click fraud in advertising);

k)Data from platforms that the games run on (such as to verify payment);

l)Data for advertising and analytics purposes, so we can provide you a better Service;

m)Your messages to the Services (such as chat logs and player support tickets)any feedback you submitted about your experience with us; and/or

n)Other data you choose to give us.

C - WHY DO WE COLLECT YOUR PERSONAL DATA AND WHAT ARE OUR LAWFUL BASES FOR IT?

Individual Customers

We may use your personal data to:

a)Provide you with our products or services (for example, play one of our online games and make online purchases).

Our lawful basis for doing so is:

a)Contract.

We may use your personal data to:

a)Establish and manage our relationship (this covers making your experience with us personalized, dealing with complaints or maintaining your account with us);

b)Learn about how our products and services are or may be used (for example, when we ask you to fill out surveys about the experience you had with us);

c)Security (ensuring confidentiality of personal information or preventing unauthorized access and modifications to our systems);

d)Let you know about our products, services and events that may be of interest to you by email or other forms of electronic communication.

Our lawful basis for doing so is:

a)Legitimate Interest.

Our legitimate interests in doing so are:

a)Account Management;

b)Exercise or defend legal claims;

c)Promote our goods and services;

d)Understand the market in which we operate;

e)Managing security, risk and fraud prevention;

f)Management Reporting (including at an intra-group level).

If you object to us using your personal data for the above purposes, including direct marketing, please let us know using the email address provided in section 1.

Where we use your email to communicate marketing information to you, we will seek your prior consent where required to do so by law.

We do not knowingly collect or solicit personal data about or direct or target interest-based advertising to anyone under the age of 16 or knowingly allow such persons to use our Services. If you are under 16, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 16 may provide any personal data. If we learn that we have collected personal data about a child under age 16, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 16, please contact us.

D – HOW LONG DO WE KEEP YOURPERSONAL DATA?

We will process your personal data only for as long as is necessary for the purposes for which it was collected in connection with the provision of service to you, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defense of legal claims.

2.2 REPRESENTATIVES OF OUR EXISTING OR PROSPECTIVE CORPORATE CUSTOMERS, BUSINESS PARTNERS, AND VENDORS

We may collect personal data related to employees, directors, authorized signatories, or other individuals associated with PhotonFox’s existing or prospective corporate customers, business partners, and vendors.

A - SOURCES OF PERSONAL DATA

We may obtain your personal data from the following sources:

a)from you directly,

b)from a company that employs you, if you are an employee of our existing or prospective customer, business partner, or vendor,

c)during networking events that we have either hosted, or sponsored, or attended; and/or

d)from publicly available sources (for example, your company website or social media sites, such as LinkedIn).

B - PERSONAL DATA THAT WE COLLECTAND PROCESS

We may collect the following categories of personal data relating to our existing or prospective customers’, business partners’, and vendors’ employees, officers, authorized signatories, and other associated individuals:

a)name;

b)business address;

c)business email address;

d)business telephone number; and/or

e)job title.

C - WHY DO WE COLLECT YOUR PERSONAL DATA AND WHAT ARE OUR LAWFUL BASES FOR IT?

We may use your personal data to:

a)Provide you with our products or services or receive products or services from you;

b)Establish and manage our relationship;

c)Learn about how our products and services are or may be used;

d)Security;

e)Let you know about our products, services and events that may be of interest to you by letter, telephone, email or other forms of electronic communication.

Our lawful basis for doing so is:

a)Legitimate Interest.

Our legitimate interests in doing so are:

a)Account Management;

b)Exercise or defend legal claims;

c)Promote our goods and services;

d)Understand the market in which we operate;

e)Managing security, risk and fraud prevention;

f)Efficiently fulfil our contractual and legal obligations;

g)Management Reporting (including at an intra-group level);

If you object to us using your personal data for these purposes, including direct marketing, please let us know using game’s Help & Support tool or via the email provided in section 1 above.

Where we use your email to communicate marketing information to you, we will seek your prior consent where required to do so by law.

D – HOW LONG DO WE KEEP YOURPERSONAL DATA?

We will process your personal data only for as long as is necessary for the purposes for which it was collected in connection with your business relationship with us, unless we have a legal right or obligation to retain the data for a longer period, or the data is necessary for the establishment, exercise or defense of legal claims.

2.3 WEBSITE VISITORS

A - SOURCES OF PERSONAL DATA

We may obtain your personal data from the following sources:

a)from you directly (for example, at the time of subscribing to any services offered on our website, including but not limited to email mailing lists, interactive services, posting material); and/or

b)from your device or browser.

If you contact us, we may keep a record of that correspondence.

B - PERSONAL DATA THAT WE COLLECTAND PROCESS

a)browser type;

b)information on the use of our website (for example, pages visited, geographical location, time spent on the website, online transactions);

c)cookie data (for more information please see our Cookie Notice;

d)preferences regarding online marketing; and/or

e)IP address.

C - WHY DO WE COLLECT YOUR PERSONAL DATA AND WHAT ARE OUR LAWFUL BASES FOR IT?

Website Visitors

We may use your personal data to:

a)Provide our website services to you;

b)Establish and manage our relationship;

c)Learn about our website(s) users’ browsing patterns and the performance of our website(s);

d)Security;

e)Let you know about our products, services and events that may be of interest to you by letter, telephone, email or other forms of electronic communication;

f)Learn about how our products or services may be used.

Our lawful basis for doing so is:

a)Legitimate Interest.

Our legitimate interests in doing so are:

a)Website Management;

b)Account Management;

c)Promote our goods and services;

d)Understand the market in which we operate;

e)Managing security, risk and crime prevention;

f)Management Reporting (including at an intra-group level).

If you object to us using your personal data for the above purposes, including direct marketing, please contact with us using the email address in section 1.

Where we use cookies or similar technologies, we will seek your prior consent where required to do so by law.

Where we use your email to communicate marketing information to you, we will seek your prior consent where required to do so by law.

D – HOW LONG DO WE KEEP YOURPERSONAL DATA?

We will keep your personal data only for as long as is necessary for the purposes for which it was collected in connection with your requests via our website or your use of our website.

2.4 VISITORS TO OUR PREMISES

A - SOURCES OF PERSONAL DATA

We may obtain your personal data from you directly and from our systems’ records.

B - PERSONAL DATA THAT WE COLLECTAND PROCESS

a)name;

b)business contact details;

c)organization;

d)role;

e)time and date of your visit; and/or

f)image (for example, from CCTV cameras at our premises).

C - WHY DO WE COLLECT YOUR PERSONAL DATA AND WHAT ARE OUR LAWFUL BASES FOR IT?

Visitors to our Premises

We may use your personal data to:

a) Security;

b) Maintain records of visitors to our premises.

Our lawful basis for doing so is:

a) Legitimate Interest.

Our legitimate interests in doing so are:

a) Managing security, risk and crime prevention;

b) Management Reporting.

If you object to us using your personal data for the above purposes, please let us know using the email address provided in section 1.

D – HOW LONG DO WE KEEP YOURPERSONAL DATA?

We keep your personal data for as long as necessary to ensure security of visitors to our premises and as soon as it is no longer necessary, usually after 90 days, we delete it.

3. WHO DO WE SHARE YOUR PERSONAL DATA WITH

We do not sell your personal data to third parties.

Our Partner Organizations and Service Providers

We may disclose information about you to organizations that provide a service to us, ensuring that they are contractually obligated to keep your personal data confidential and will comply with the relevant data protection laws.

We may share your information with the following types of service providers:

a)technical support providers who assist with our website and IT infrastructure,

b)third party software providers, including ‘software as a service’ solution providers, where the provider hosts the relevant personal data on our behalf;

c)professional advisers such as solicitors, accountants, tax advisors, auditors and insurance brokers;

d)providers that help us generate and collate reviews in relation to our goods and services;

e)our advertising and promotional agencies and consultants and those organizations or online platforms selected by us to carry out marketing campaigns on our behalf and to advertise their own products or services that may be of interest to you; and/or

f)service providers that assist us in providing our services.

Law enforcement or government bodies

We may disclose your personal data as permitted by law in order to investigate, prevent or take action regarding illegal activities, suspected fraud, violation of our intellectual property rights, situations involving potential threats to the physical safety of any person, violation of our Terms and Conditions or other agreements, or as required by law.

4. TRANSFERS OF PERSONAL DATA OUTSIDE CHINA

We share your personal data with our affiliates in China and outside China.

We share personal data with external vendors or service providers or suppliers that we engage to perform services or functions on our behalf and under our instructions. We also ensure in our contracts with these organizations that they only Process Personal Data in accordance with our instructions and in order to provide the agreed services and protect the integrity and confidentiality of your personal data entrusted to them.

We may also disclose personal data to our advisers, consultants, law enforcement and other public authorities (such as tax and social security bodies), the police, prosecutors, courts and tribunals. All these recipients are themselves responsible to comply with the data protection rules.

You may request a copy of these agreements by contacting us using the email address in section 1.

5. YOUR RIGHTS

You are entitled to obtain information from us on how we handle your personal data, to see copies of all personal data held by us and to request that your personal data is amended, corrected or deleted from our systems. You can also limit, restrict or object to the processing of your data.

We do not carry out any decision-making based solely on automated processing, including profiling.

If you gave us your consent to use your data, e.g. so that we can send you marketing emails or display personalized ads, you can withdraw your consent at any time. Please note that even if you withdraw your consent, we can still rely on the consent you gave as the lawful basis for processing your personal data before you withdraw your consent.

You can object to our use of your personal data where we stated we rely on our legitimate business interests to do so. We explained the legitimate interests we rely on in sections ‘Why do we collect your personal data and what are our lawful bases for it?’ above.

If you would like to exercise any of your above rights, contact us using the contact details in section 1 above.

6.THIRD-PARTIES

Magicabin Offerings may allow you to play or direct Magicabin to share information through social media (such as by logging in through a social media account or using a “Like” button”) or contain links to social media services or other third parties. The use of these features and links are subject to the privacy policies of those companies and your settings on those services. Magicabin has no control over, and is not responsible for, the information submitted to or collected by social networks or other third parties. We encourage you to review those third-party privacy policies to understand the way your information may be collected and handled by such third parties.

Service Providers and Partners:

We use third parties to help us operate and improve our Services. These third parties assist us with various tasks, including hosting and maintenance, on-going development, analytics, customer care, marketing, advertising. We may also share information with advertising partners who distribute advertising in our Services.

a) Advertising networks and their partners

The below companies assist us by providing services relating to advertising and marketing. If you reside in the European Economic Area (“EEA”), the advertising networks, analytics providers, and other companies listed below may collect or receive device information from our apps on your browser or device for advertising purposes, including personal and non-personal information, such as advertising (or ad) identifiers, IP address, or other information regarding the delivery of advertisements and your interaction with them, the inventory of installed apps and/or other tracking technologies to provide measurement services, personalization, ad selection, delivery, reporting, and optimize targeted ads. Ad identifiers are non-permanent device identifiers such as the Android advertising ID and/or Apple's ID for advertising (IDFA). For more information on how to opt-out of advertising, please see the “How To Manage Tracking Technologies” section above. In addition, the advertising networks listed below, with the exception of Fyber, Mobfox, and PubNative, who act as data processors upon our instructions, are independent data controllers in respect of your personal information and you can learn more about how each handles your data or provides opt-outs by accessing their respective privacy notices using the hyperlinks below.

Company Name	Brief Introduction	Privacy Policy
AppLovin	AppLovin is an advertising service provided by AppLovin Corporation. (US)	https://www.applovin.com/privacy
Facebook Audience Network	Facebook Audience Network is an advertising service provided by Facebook, Inc. (US) that may collect or receive information from our apps and other apps and use that information to provide measurement services and targeted ads. Facebook does not require opt-in or opt-out signals from users in our services. Relevant signals are collected directly from the user upon creating an account in such Services.	https://www.facebook.com/about/privacy/
Fyber	Fyber is an advertising service provided by Fyber Group. (Israel)	https://www.fyber.com/legal/privacy-policy/
Google AdMob and their partners	AdMob by Google is provided by Google Inc. (US)	http://www.google.com/policies/privacy/ For more information on AdMob Partners, please visit: https://support.google.com/admob/answer/9012903 You can opt-out from AdMob by Google service by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=en
IronSource	IronSource is an advertising service provided by IronSource, Inc. (US) and does not require opt-in or opt-out signals from users in our Services, since they provide only non-personalized ads in our Services.	https://www.is.com/privacy-policy/
Unity Ads	Unity Ads is an advertising service provided by Unity Ads Inc. (US)	https://unity3d.com/legal/privacy-policy
Vungle	Vungle is provided by Vungle, Inc. (US)	http://vungle.com/privacy/
Mintegral	Mintegral is provided by Mintegral International Limited (China)	https://www.mintegral.com/en/privacy/
Yandex	Yandex is provided by Yandex Europe AG (Russia)	Yandex is provided by Yandex Europe AG (Russia)

b) Analytics and other service providers

We use your information to perform our own analytics and to enable analytics provided by third parties and other essential functions. We use analytical information for supporting business analysis and operations, business intelligence, product development, improving the Services, personalizing content, providing advertising, and making recommendations. In order to learn about how your information is used by our analytics service providers, you can follow the hyperlinks in the list below to each provider’s privacy notice.

Company Name	Brief Introduction	Privacy Policy
AWS	AWS is a cloud computing service provided by Amazon Web Services, Inc. (US).	https://aws.amazon.com/privacy/
Facebook Analytics	Facebook Analytics is an analytics tool provided by Facebook, Inc. (US) that may collect or receive information from our apps and other apps and use that information to provide measurement services.	https://www.facebook.com/about/privacy/
Firebase	Firebase is an analytics service provided by Google Inc. (US). You may opt-out of certain Firebase features through your mobile device settings.	http://www.google.com/intl/en/policies/privacy/
Google Analytics	Google Analytics is an analytics service provided by Google Inc. (US).	https://policies.google.com/privacy
Appsflyer	Appsflyer Analytics is an analytics service provided by Appsflyer Ltd. (Israel).	https://www.appsflyer.com/privacy-policy
ThinkingData	ThinkingData is an analytics service provided by ThinkingData Information Technology (Shanghai) Co., Ltd.	https://docs-v2.thinkingdata.cn/?version=4.5&lan=en-US&code=privacy_policy&anchorId=