We also recommend reading the methods available to OPT OUT and control your data, such methods are listed in this policy.

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1 Project Rad Privacy Policy Privacy policy last updated June Project Rad Ltd (Australian Business Number: (defined here as We or Our ), We value your comments, suggestions and feedback. Our Privacy Policy sets out how we collect, use and disclose personal information and other non-personal information we have gathered about you. We truly value our players privacy and always ask for consent when collecting any information. We will not share your information with anyone except as described in this policy. The primary purpose of your information being collected and used is to provide and improve our services, along with keeping communication channels open with users so they can stay up to date with our business practices. By using our service you agree to the collection and use of information in accordance with this policy. At anytime you can ask us to stop collecting, de-identify or implement erasure of data. You can do that by contacting us at and immediately ceasing use of our services and uninstalling SWIPR. We also recommend reading the methods available to OPT OUT and control your data, such methods are listed in this policy. If you do choose to OPT out, we hold no responsibility for the loss of your accounts data. Please feel free to contact us if you have any other queries in regards to our Policies. This policy will let you know: What information is collected from you; How your information is used; With whom your information may be shared; How you can access, update, or delete your information. We are bound by the Australian Privacy Act 1988 (Cth) ( Act ) regarding the manner in which We handle your personal information and how We respond to your requests to access and correct it. We adhere to the principles enshrined in the US Privacy Act (1974) ( US Act ) and although we do not target children, or collect data from them, we also adhere to the principles contained in the Children's Online Privacy Protection Act ( COPPA ). We will comply with all relevant legislative requirements, and, in the event of any inconsistency, the legislative requirements will override the provisions of this document. Children s Privacy We strictly adhere to Australian privacy law. Our games and our website are not aimed at children under 13 years of age. If you believe that We have inadvertently collected information from a person under the age of 13, please contact us at the address below and the information will be permanently deleted. Some areas in the European Union require consent from a parent, guardian or attorney for persons aged It is your responsibility to provide a copy of this consent to us at privacy@project-rad.com immediately after reading this whole document or discontinue use of our services. What information is collected from you: What is Personal Information and why do we collect it from you? Personal Information is information or an opinion that identifies you as an individual. We collect and store your when you sign up for our newsletter, or where you nominate to specifically allow our games to collect your . We will ask you to supply some information about yourself which in certain circumstances could be construed as personal information. It is not a requirement that you

2 supply any such information, and you are able to delete it at any time by contacting us via the listed at the conclusion of this policy. Such information that we ask for, includes: your age, your gender, a profile picture (this will also be publicly visible, keep it suitable for all ages), ( s will not be displayed publically) and your country of origin, all information requested is optional. We ask consent for this optionally provided information for the purposes of: Creating your account: Two options are available here; Facebook log in, and guest user. If you chose to log in with Facebook, information will be provided based off what you allow to be shared and shown on Facebook. For example your profile picture may be added to your account and it may generate your username based off your Facebook name, you can change this. Be aware of this when creating your username we advise you use an anonymous name that other players will not recognize. Making leader boards that are relevant to our users. This helps give users an understanding of how well they achieve against certain demographic factors. We would like to make regular score updates to inform the public in general how well our users are going. For example the average score from each country that we have users from. Or something along the lines of "donkeyname from Australia is currently the most intuitive 'swipr' based of our judgment and scoring system. Who thinks they can beat her?" Improving our product. This can be done in many ways, if for example, we feel the need to cater more to older users, by understanding our user base through data provided, we can make informed decisions that in the end help our users. Newsletter When you elect to provide your or join our mailing list, we may use that personal information to provide you with direct marketing communications about upcoming games, features of our websites and other events and promotions related to our products. If you contact us directly for any reason, we may also keep a copy of that correspondence. Your is collected only to keep you informed of new Project Rad products and changes to our existing products. Third Party Log-in Partners You may elect to log into our games through your facebook account. We welcome and encourage this, but you should be aware that in this case, your personal data will be stored with facebook. A copy of the facebook privacy policy can be found here: Third Party Advertising Advertisements from third party ad networks may be displayed in our Games from time to time. All reasonable endeavours are used to ensure that these ad networks comply with the Act, the US Act, and COPPA in the provision of their services towards us. If you click on any advertisements through Our game, the advertisers may use cookies and other web-tracking technologies to collect data. Some of this may be personal information, and some of it non-personal information. We recommend that you review the terms of use and privacy policy for any advertiser with whom you are interacting before doing so. The list of our ad networks privacy policies may be found here: Google AdMob& AdSense: Third Party Partners

3 Our websites and apps may also contain APIs from other third parties. As with Google, We do not control how they interact with you and you should ensure that you consent to the terms of use and privacy policies offered by the third party services before providing them with your information. Our third party partners, and their privacy policies are as follows: Firebase: Non-Personal Information Some non-personal information may be gathered while you use Our games. Non-personal information is general, non-identifiable and anonymous information that is gathered for statistical, analytical and research purposes such as the improvement of our games (for example, bug fixes). Understanding how our users interact with our application helps us determine what features need improvement, adjustment or removal. We analyse this session information and statistics through Firebase, which provides information on average session times, average user scores, percentile information on where users are from in the world and other default event information provided by the service that help with monitoring product performance and growth. Firebases privacy policy can be found here: Firebase: Though We do not use cookies in order to track your movement around the web, Our website ( uses Google Analytics to help analyse how users use these sites. The tool uses cookies to collect internet log information and general visitor behavior information in an anonymous form. The information generated by the cookie about your use of the website, including your IP address, is transmitted to Google. This information is then used to evaluate use of our website and to compile statistical reports on website activity. Please read our Cookie Policy which is available or visit or The Google Analytics privacy policy can be found here: Google Analytics: Sensitive Information Sensitive information is defined in the US Act to include information or opinion about such things as an individual s racial or ethnic origin, political opinions, membership of a political association, religious or philosophical beliefs, membership of a professional body, criminal records or health information. We will not attempt to obtain nor record any sensitive information. How you control your data There are many methods offered to help users understand what information is collected in regards to them and how they can control the process. Listed below are some options available to users. Opting out Users can manage their own data by other methods such as changing privacy settings directly their device or facebook account. Google also offer a variety of options in regards to how to control your privacy and settings.

4 You can also choose to OPT OUT of Google Analytics: You can also request removal of data via : Access to your Personal Information Under the Act, you have the right to access the Personal Information We hold about you and to update and/or correct it, subject to certain exceptions. If you wish to access your Personal Information, please make out your request to us in writing at the address listed below. Project Rad will not charge any fee for your access request, but may charge an administrative fee. Please be aware that in order to protect the Personal Information in our database, we will require identification from you before releasing any information. Information Retention We will continue to collect and retain your data for as long as you use our services. We will retain your data for as long as we still use it for the purpose in which it was obtained. We however have no obligation to retain your data and may dispose of it at any time, it is your responsibility to keep back up records. When your data is no longer needed for the purpose of which it was obtained, we will take reasonable steps to destroy or permanently de-identify your personal information Maintaining the Quality of your Personal Information It is important to us that your personal information is up to date, as we require up to date records in order to validate accounts. We will take reasonable steps to ensure your personal information is accurate, complete and up-to-date. If in any circumstance you find that the information we have is not up-to-date or correct/inaccurate, it is your duty to advise us as soon as practicable so we can update our records and ensure the continuity of our quality services to you. User generated content We reserve the right, however are not obliged, to review any content that you upload, create, or share through our services. We may remove any content that violates any terms set out in Our Policies, and if necessary terminate your SWIPR account at any time for any reason in our sole discretion with or without notice to you. Any content you upload from or to SWIPR is deemed publically available. Handling of Your Information As we Project Rad collect your data and provide it to the third parties as mentioned above, this makes us your data controller! We will only control and use your data in the ways mentioned in this policy. Its imperative to us that we maintain the trust of our customers and use this much needed data to help our business grow and offer insightful products to our end users. Disclosure of Personal Information We will not sell, trade, rent or disclose any of the personal information you provide to us for any reason, without your prior consent. Otherwise, your Personal Information will only be disclosed where required or allowable by law. There are also some certain scenarios where we will be required to share or disclose your information such as: We will share your data if we are legally required to do so. We will share your data to enforce applicable Terms violations investigations. We will share your data to protect harm against others. We will share your data to investigate, prevent or address fraud, security and other miscellaneous technical issues.

5 If we are involved in a merger, acquisition or sale to another entity that meets privacy regulations in your area. We will notify our users before any transfer of information. Security of Personal Information Your security and privacy is a priority to us here at Project Rad, We provide procedural, electronic and physical safeguards to protect any information we process or maintain. It is made clear that no matter how much security we provide, we cannot prevent all possible breaches and our services and information is provided under this acceptance. Rest assured, Your Personal Information is stored offsite in a manner that reasonably protects it from misuse, loss, unauthorized access, modification or disclosure. We don t guarantee website links or policy of authorised third parties and you access those sites at your own risk. European users Here is some additional information for our users in the European Union and the bases for us collecting and using this data. Certain conditions must apply for us to be able to use your data. These are referred to as legal bases. At all times we will adhere to at least one of these legal bases for the collection and use of your information. Consent: We ask permission to collect and use any data that may be obtained through our application or website. By providing the information freely to enable use of a certain feature our service offers or through methods of consent, such as allowing personalized advertisement, you have provided us a legal bases to use your information as per this policy. You can withdraw consent at anytime. Contract: Another reason we may use your information is due to you entering into a contract with us. For example if you chose to or try to participate in any of our promotions offered on our website, we will need your information to provide or disallow that service or payment. Legitimate interest: Our legitimate interests, such as providing our service, improving our product, customer support, working with third parties to allow advertisement and maintaining your security are all very important to us. However your privacy is more so, this leads us to providing you options of how you control what data we collect or use. Legal obligation: We may be required to provide your information to legal entities as part of complying with the law. Your right to object At anytime you have the right to object the use of your information. We simply ask you to stop using our services that require the information to function and contact us immediately. You can also adjust your device or web browser settings. Your right to complain Every user has the right to lodge a complaint with a supervising authority if they believe the processing, control or collection of data or personal information infringes their relevant regulations in their Member State. For example, residences of the UK would lodge a complaint via the 'Information Commissioners Office: International Transfer As PROJECT RAD PTY LTD operate out of Australia but have global customers, we must ensure safe transfer of data to our servers. This means we maintain and process the data outside of your

6 state, province, country or jurisdiction where data protection laws may differ. If you are outside Australia, and provide us with information, please be aware of this as your submission of such information represents your agreement to that transfer. In saying this Project Rad abide by strict international privacy regulations. Storage Data collected through SWIPR will be stored in Sydney, Australia on servers hosted by Amazon Web Services and owned by PROJECT RAD PTY LTD. Service providers such as Amazon who work on our behalf do not have independent access to the information provided through SWIPR or our services. Amazon follow strict privacy laws that adhere to the EU(Directive 95/46/EC) - US (ISO 27018) Privacy Shield. For more information in relation to Amazon's privacy, please visit: Information gathered by using SWIPR or our website are also stored in Google's Analytic Cloud Servers (Likely located in Sydney, Australia or the United States of America or any other country that they operate in) and is analysed via Firebase console page and Google's Analytic Console page. Google and Firebase abide by strict frameworks put in place to help users understand what data is being collected, how it's used and the choices users have. These compliance factors are laid out in the EU-US and Swiss-US privacy shields. To view more information on Google's privacy policy please view: Policy Updates This Policy may change from time to time. We will always keep this up to date so that you know what information we will collect from you, how we may use it, and when we may disclose it. Continued use is deemed approval of accepted changes. Consent Consent matters. By using SWIPR you warrant your ability to be able to give consent under Australian Law and the applicable law of your jurisdiction, in the event you do not have the ability to give to consent, you warrant that parent, guardian or attorney has given consent for us to deal with your personal information in accordance with the terms of this Privacy Policy. Consent obligations can vary in jurisdictions, It is your responsibility to ensure consent is legal in your jurisdiction. Complaints You can lodge a complaint with us about any breach of our Privacy Policy at the address below. Privacy Policy Contact Information To find a copy of our Privacy Policy please visit : If you have any questions about our Privacy Policy, please contact us at: privacy@project-rad.com or write to us at :PROJECT RAD PTY LTD, PO BOX 420, JAMISON CENTRE, 2614, ACT, AUSTRALIA