This Privacy Notice explains who we are, how we collect, share and use personal
information about you, and how you can exercise your privacy rights. The Services are also
governed by the Terms of Service.
We are The Global Paradise (“ TGP”). This Privacy Notice applies to personal
information that we collect through our games, mobile applications and other products
(“Games”), forums and websites we control, like at www.theglobalparadise.com and www.gamegearltd.com (“Website”) (collectively “Services”).

1. WHAT PERSONAL INFORMATION DOES GLOBAL COLLECT?
   The personal information we may collect about you through the Services falls into the
   following general categories:
   1.1. Information that you provide voluntarily
   Certain parts of our Services may ask you to provide personal information voluntarily.
   For example, we may ask for certain information in order to register an account with us, to begin playing Games, to subscribe to marketing communications from us, and/or to submit enquiries to us, such as:
   ● your name, email address or other contact details
   ● any information you submit to our customer service team in the Game or via email
   The personal information that you are asked to provide, and the reasons why you are asked to
   provide it, will be explained to you when we ask you to provide your personal information.
   1.2 Information we collect automatically
   When you use our Services, we may also collect certain information automatically from
   you and/or your device which may be considered personal information under applicable data
   protection laws, such as:
   ● Your Service communications (e.g. in-game chats and messages with other players)
   ● Data and analytics about your use of our Services (e.g. in-game play progress, levels, games
   played, session length, preferred settings, which in-game adverts you may have viewed, in-game
   preferences or just game preferences, which friends you connect with, the means by which you
   were referred to our Services)
   ● Your IP address and device identifiers such as your Advertising ID, Device ID numbers (for
   more see here “Advertising IDs and Device IDs”)
   ● Your device type and the operating system that you use
   ● General geographic location (e.g. country or city location) based on your IP address
   ● GPS location, with your consent
   “Advertising ID” means the Apple Identifier for Advertisers (“IDFA”) on Apple, and
   Google Advertising Identity (“GAID”). These are unique identifiers for mobile devices that
   advertisers use for interest-based advertising. They are consistent across all apps and thus allow
   cross-app tracking. On Apple, you can opt out by choosing the “limit ad tracking” option in the
   privacy settings. On Google Android, you can opt out by choosing the “Opt out of interest based ads.” Advertising IDs are non-permanent, non-personal identifiers uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognize your device when you use websites and applications. “Device identifier / information” means device type, device model, device manufacturer, device operating system and language, or other technical data like screen size, processor, or a combination of this data, available from a device for a developer to check the device’s compatibility with a particular application. Some of this information may be collected using cookies and/or similar technologies (such as ” software development kits, or “SDKs”).
   1.3 Information we obtain from third party sources
   (a) Information from social media platforms. You may choose to connect to our
   Services via your social media account. The exact information we receive from you will depend
   on your social media privacy settings, but it will typically include your basic public profile
   information, such as:
   ● your username
   ● profile picture
   ● age range
   ● gender
   ● your friends playing the same Game
   Typical uses include updating game progress on multiple devices you may own so that
   you can continue your progress using multiple devices.
   (b) Third party service providers. We may receive personal information about you from
   third-party sources. We may get your personal information, for example, when you installed our
   Game or when, prior to installation, you click on an advertisement for the Game (see “Third
   Parties” section below for further detail).
   (c) Advertising partners. From time to time, we may also receive personal information
   about you from other third-party sources. For example, if you clicked on an advertisement
   directing you to one of our Services (such as an ad for one of our Games in another publishers’
   game), we will be provided with information about which ad network and advertising campaign
   the install originated from (See also “Advertising” below).
   1.4 No special categories of information
   We do not request or intend to collect any “special categories of information” such as any
   information on health, race, religion, political opinions or philosophical beliefs, sexual
   preferences or orientation. Please, be cautious when sharing this information about yourself (or
   others) in our forums.
2. HOW WE USE YOUR PERSONAL INFORMATION
   We use your personal information for the following purposes:
   2.1 To provide and operate our Services:
   ● To create user accounts/profiles to enable you to play our Games
   ● To provide you with the correct versions of our games and/or applications (e.g. knowing which language to make our games available to you in)
   ● To enable you to communicate with other users (including via chat rooms, forums and/or private messages) and leaderboards local to you
   ● To send you service-related communications including confirmations, technical notices, updates, security alerts, and support/administrative messages
   2.2 To improve our Services and keep them secure:
   ● To respond to your customer support requests (e.g. if you write to us with a complaint)
   ● To receive error messages about any issues you/your device encounters with our Services to
   enable us to fix bugs and interoperability issues
   ● To detect and prevent illegal activities (e.g. hacking or cheating)
   ● To track game installs (for purposes of measuring the effectiveness of marketing campaigns).
   ● To conduct optional user feedback surveys
   ● To understand you, your preferences and user traffic to enhance your experience and enjoyment using our Game
   ● To conduct research
   2.3 To personalize our Services:
   ● To remember you next time you visit one of our Services
   ● Communicate with you about promotions, rewards, upcoming events, and other news about
   products and services we offer 2.4 For promotional activities (including marketing and advertising) ● To provide you with in-game offers and rewards based on your in-game behaviors
   ● To serve you with relevant targeted advertisements (necessary to fund our Services)
   ● To make you offers to purchase in-game items on discount based on your in-game activity and
   purchase history.
   ● To send you marketing communications and/or newsletters about rewards and promotions if you
   have subscribed to them
   2.5 Other
   ● To comply with our legal obligations
   ● To exercise, establish or defend our legal rights, or to protect your vital interests or those of any
   other person
   ● To prevent and/or detect fraud or fraudulent behavior
3. ADVERTISING
   3.1 We may use advertising to fund our Services and to make our games available for free.
   We may show third-party advertising in our Games and also advertise our Services via third
   parties. We want to provide you with more detail about how we use information for advertising,
   both in our properties and in third-party properties. When you view ads in our games.
   3.2 To enable us to show in-game ads, we may send your advertising ID and IP address to
   advertisers (or ad networks) to enable them to find appropriate ads to serve to you in our Games and on third-party properties. You can control and limit our use of your advertising ID in your device settings. TGP does not control which specific ads are shown in our games (this is
   controlled by ad networks), but we may prohibit certain types of ads.
   3.3. Advertising IDs are used by ad networks for a number of purposes (please refer to the
   Privacy Notices of our advertising partners listed herein as “Third Parties”) including, for
   example, to:
   (a) limit the number of times you see the same ad
   (b) ensure they are dealing with humans with real devices and not automated “bots”
   (c) to serve you with advertisements likely to be relevant to you based on your
   advertising ID, your engagement with other brands and ads which is recorded using your
   advertising ID, and to use your general geographic area.
   (d) Other brands buy ad placements via an ad network or ad exchange to advertise their
   products in TGP Games. The ad network or ad exchange acts as intermediary between the other
   game companies and TGP. In order for an ad network to charge the company purchasing the ad, clicks from the ad and potential installs of other developers’ apps are tracked. Views, clicks and installs from ads are measured using the Advertising ID.
   (e) Ad networks track which games you have used to market you similar kind of games.
   Your IP address is typically used by advertisers to identify your general geographic
   location, for example, your country, state and, sometimes, your city).
   When you view TGP ads on third-party services
   3.4 TGP may also advertise its games on other apps by asking ad networks to place ads for
   audiences that will be interested in them (determined using Advertising IDs).
   3.5 Ad networks use Advertising IDs for this and other purposes (please refer to the Privacy
   Notices of our advertising partners listed as “Third Parties”) including, for example, to:
   (a) Measure ad effectiveness (looking at total views, clicks and installs generated by its
   advertising in other publishers’ games);
   (b) Inform players that have not played for a while about new content in the Game. TGP
   may give a list of these users in the form of Advertising IDs to an ad network. The ad network
   then shows these users ads about the new content.
   (c) Not display ads for a game a player is already playing. TGP may send a list of active
   players in the form of Advertising IDs to an ad network. The ad network then excludes these
   players from seeing the ad.
   (d) Market games to a group of potential players.
   3.6 You can opt out of interest-based advertising on mobile applications by changing the
   privacy settings of your device and selecting “limit ad tracking” (Apple iOS) or “opt out of
   interest-based ads” (Android).
4. COOKIES AND SIMILAR TRACKING TECHNOLOGY IN WEBSITES
   The Services may use “cookies” and other technologies such as pixel tags, local shared
   objects, hardware-based device identifiers, flash cookies, operating system-based identifiers,
   clear GIFs and web beacons. Cookies: A “cookie” is a small file your browsers stores when told to do so by a website. Typically, websites place a number of different cookies on an end-user’s device. Some are “First-party” cookies,’ i.e. from the website itself, and others are “Third-party” cookies, meaning they belong to advertising and analytics entities or social networks. Cookies are personal information. However, TGP’s cookies do not include any other personal information and are typically used to quickly identify your device and to “remember” your device during subsequent visits for purposes of functionality, preferences, and website performance. You can disable cookies on your device or set your device to alert you when cookies are being sent to your device; however, disabling cookies may affect your ability to use the Services.
5. LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
   Our legal basis for collecting and using the personal information described above will
   depend on the personal information concerned and the specific context in which we collect it.
   However, we will normally collect personal information from you only where (i) we need
   the personal information to perform a contract with you, (ii) the processing is in our legitimate
   interests and not superseded by your rights, or (iii) we have your consent to do so.
   (a) Under our terms of service, “performance of contract” as a legal basis for processing
   your information refers to when we make the Game and Services available to you, provide
   customer support, integrate Games with technology and distribution platforms such as Apple iOS and Google Android, and inform you of service-related changes and Game progress.
   (b) We process your personal data on the basis of our legitimate interests for example
   when we provide you the Game and Game events, serve interest based advertisements to you
   (both in-game and on third-party properties), carry out marketing, keep our games secure, for
   engineering purposes, analyzing the users’ behavior across our Games, moderating chat
   discussion.
   (c) We have a “legal obligation” to process your personal data when complying with a
   legal obligation, such as the preventing a crime or fraud or maintaining tax records.
   (d) If we ask you to provide personal information to comply with a legal requirement or
   to perform a contract with you, we will make this clear at the relevant time and advise you
   whether the provision of your personal information is mandatory or not (as well as of the
   possible consequences if you do not provide your personal information).
   If you have questions about, or require, further information concerning the legal basis for
   collecting and using your personal information, please contact us using the contact information
   provided in the Contact section below.
6. WHO DOES TGP SHARE MY PERSONAL INFORMATION WITH?
   We may share your personal information with the following types of recipients:
   (a) With companies in our business group, third-party service providers and
   partners who provide data processing services to us (for example, to support the delivery of,
   provide functionality on, or help enhance the security of our Services), or parties that otherwise
   process personal information for the purposes described in this Privacy Notice or communicated to you when we collect your personal information. A list of current companies in our business group is available on our website.
   (b) With any competent law enforcement body, regulatory authority, government
   agency, court of law or other third party where we believe disclosure is necessary (i) as a
   matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person
   (c) With a potential or actual buyer (and its agents and advisers) in connection with any
   proposed or actual purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information solely for the purposes disclosed in this Privacy Notice
   (d) With any other person, with your consent for such disclosure.
7. HOW DOES TGP KEEP MY PERSONAL INFORMATION SECURE?
   We use appropriate technical and organizational measures designed to protect the
   personal information that we collect about you and process. The measures we adopt are designed to provide a level of security appropriate for the degree of risk involved with processing your personal information. Specific measures include encrypting your personal information in transit and at rest.
8. INTERNATIONAL DATA TRANSFERS
   Your personal information may be transferred to, and processed in, countries other than
   the country of which you are a resident. These countries may have data protection laws that are
   different from the laws of your country.
9. Specifically, our Game servers are currently located in multiple countries, and our business group members, third-party service providers and partners operate around the world.
   This means that when we collect your personal information we may process it in any of these
   countries. However, we ensure appropriate safeguards are in place so that your personal
   information will remain protected in accordance with this Privacy Notice. This includes
   complying with the European Commission’s Standard Contractual Clauses for transfers of
   personal information among companies in our business group and third-party service providers
   and partners, which require all members of our business group to protect the personal
   information they process from the EEA in accordance with European Union data protection law.
   It also includes the transfer of personal information to third-party service providers and partners
   that are certified under the EU-US Privacy Shield.
   The Standard Contractual Clauses can be provided on request. We have implemented
   similar appropriate safeguards with our third-party service providers, and partners and further
   details can be provided upon request.
10. DATA RETENTION
    We retain personal information we collect from you where we have an ongoing legitimate
    business need to do so. For example, to provide you with a Service you have requested, or to
    comply with applicable legal, tax or accounting requirements. For example, we periodically
    de-identify unused Game accounts and regularly review and de-identify unnecessary personal
    information.
    When we have no ongoing legitimate business need to process your personal information,
    we will either delete or de-identify it, or, if this is not possible – for example, because your
    personal information has been stored on a backup server – then we will securely store your
    personal information and isolate it from any further processing until deletion is possible.
11. YOUR DATA PROTECTION RIGHTS
    You have the following data protection rights:
    (a) To access, correct, update or request deletion of your personal information. You
    may do so in your account settings (via “Terms of Service and Privacy Notice”) or by contacting
    us using the information in the Contact section below.
    (b) To object to the processing of your personal information (which is processed on the
    grounds of legitimate interests), ask us to restrict processing of your personal information
    or request portability of your personal information. Again, you may do so by opting out of
    personalized offers based on in-game behavior, or by contacting us using the information in
    the Contact section below.
    (c) To opt out of marketing communications we send you, at any time. You can
    exercise this right by clicking on the “unsubscribe/opt out” link in the marketing
    communications we send you or by contacting us using the information in the Contact section
    below.
    (d) If we are processing your personal information with your consent, you can withdraw
    your consent at any time. Withdrawing your consent will not affect the lawfulness of any
    processing we conducted prior to your withdrawal, nor will it affect the processing of your
    personal information conducted pursuant to lawful processing grounds other than consent. You
    may do so by contacting us using the details at Contact heading below.
    (e) You have the right to file a complaint with a data protection authority about our
    collection and use of your personal information. For more information, please contact your local
    data protection authority.
    You can control and limit the type of personal information we collect and process about
    you in a number of ways. For example, you can disconnect your social media account(s) from
    our games or control your social media privacy settings to limit the information shared with us.
    You can also reset your mobile advertising identifier or limit ad tracking altogether using the
    settings on your phone. You can also limit or disable the use of cookies (or similar technologies).
    We will respond to all requests we receive from individuals wishing to exercise their data
    protection rights in accordance with applicable data protection laws.
12. AGE LIMIT
    When we collect personal information we do not know the age of our players. If we collect data from a minor under 13 years of age, we will take reasonable measures to promptly delete such personal information from our records.
13. UPDATES TO THIS PRIVACY NOTICE
    We may update this Privacy Notice from time to time in response to changing legal,
    technical or business developments. When we update our Privacy Notice, we will take
    appropriate measures to inform you, in accordance with the significance of the changes we make.
14. HOW TO CONTACT US
    Data controller: The Global Paradise LLC 2976 E State St, Ste 120-1061, Eagle, ID
    83616-6394; email us at: [email protected]
    Please note that other third parties (our data partners) may be data controllers of your
    information.