CLOUD TRAVEL COMPANY LIMITED

Privacy policy - Last updated April, 10th 2023

CLOUD TRAVEL is an international entertainment company specialized in the publishing of mobile games.
The purpose of this policy is to provide you with all the important information and explanations about how and why some of your data may be collected and processed by CLOUD TRAVEL when you use one of our applications or browse on our website. This privacy policy governs and details the main principles that CLOUD TRAVEL applies to the data we collect and process to:

(i) develop, publish and monetize mobile games (“CLOUD TRAVEL Technologys”)

This policy also aims to remind you about your rights and to provide you with all the elements you need to exercise them.
Should you have any questions related to this policy or our practices around privacy and data protection in general, please don’t hesitate to contact CLOUD TRAVEL Data Protection Officer as indicated in the contact section of this policy.

CLOUD TRAVEL Technologys
Why does CLOUD TRAVEL collect data from its games?

When you install and use CLOUD TRAVEL Technologys, we can collect and process some of your data for different legitimate purposes.
You will find below explanations regarding the reasons why CLOUD TRAVEL may collect data and the legal bases CLOUD TRAVEL relies on in each case.

CLOUD TRAVEL collects data:
• To provide you with the services you asked for (e.g., knowing that you completed the first level to allow access to the second one)
  • Legal basis – such data processing is strictly necessary for the service(s) asked
• To run analytics and understand how users interact with our product and services in order to continuously improve it either directly or through third party partners (e.g. identifying that a feature is annoying for users or that a level is too difficult for most gamers)
  • Legal basis for third party analytics - Express consent. In the countries where collecting users’ consent may be required by applicable laws and regulations, CLOUD TRAVEL only shares personal data collected through CLOUD TRAVEL Technologys with third party partners that provide CLOUD TRAVEL with analytics services once you express your consent through the pop-up notice included in our apps.
  • Legal basis for first party analytics – Legitimate interest. CLOUD TRAVEL collects user data for the purpose of its own internal analytics tools. Data is used for the sole purpose of CLOUD TRAVEL analytics tool and is not shared with any third parties. This data processing is based on the legitimate interest of CLOUD TRAVEL.
• To serve advertising tailored to the preference and interests of our users and allow CLOUD TRAVEL to continue to provide free services and products
  • Legal basis – Express consent. In the countries where collecting users’ consent may be required by applicable laws and regulations, CLOUD TRAVEL only processes or shares personal data collected through CLOUD TRAVEL apps for personalized advertising purposes once you express your consent through the pop-up notice included in one of our apps.

For all data processing activities that rely on users’ consent, you can withdraw your consent at any time from the “settings” page in our various applications.
Please only note that in the case where you withdraw your consent or where you refuse to consent in the first place, you will still be served with advertising but that may be less relevant to you as it will not be tailored to your interests.

What data does CLOUD TRAVEL collect from its games?

For all the purposes listed above the data that CLOUD TRAVEL collect is limited to:
• The games you are playing
• Technical information about the device you use and your connection (user agent, type of connection, timestamp)
• Data pertaining to your activities on our applications and notably the way in which you interact with our applications (for instance, how and when you use our applications) and with the advertising served in our applications (for instance, number of ads served, potential clicks)

With who may your data be shared & why?

CLOUD TRAVEL does not share your personal data with third parties without your prior consent in the countries where collecting users’ consent may be required by applicable laws and regulations.
When you consent to the collection of data for advertising and analytics purpose, we may share the data listed above with the following categories of recipients:

• Ad Partners: that allow us to monetize the ad inventory of our apps and provide users with free products and services.

Those partners usually collect data via their own tools (Software Development Kits or “SDK”). You will find a list of our partners implementing advertising SDKs through our applications and the privacy policies of their services that describe their practices and allow you to exercise your rights directly toward them hereafter:

• Facebook -https://www.facebook.com/about/privacy
• Authorities: only to the extent we are obliged to by applicable laws and regulations.

CLOUD TRAVEL website
Why does CLOUD TRAVEL collect data from its website?

Like on most websites, when you browse on CLOUD TRAVEL certain information about your connection and device(s) are automatically collected for the website to operate properly.
CLOUD TRAVEL and its partners also use cookies and similar technologies to analyze how our users interact with our services and administer the website. Cookies are small text files stored on your browser that allow the collection of non-personally identifiable information related to your navigation on a website.
You can control the use of cookies in your browser settings but if you choose to disable cookies it may affect certain websites’ functionalities.

What data does CLOUD TRAVEL collect from its website?

For the purposes listed above the data that CLOUD TRAVEL and its partners collect is limited to:
• Browsing events and interactions with the website’s contents and services
• Anonymized IP address and technical information related to your browser and/or device (user agent)
• Information you provide us with voluntarily when you contact CLOUD TRAVEL.

Social networks and other communication tools

Our website also offers communication tools allowing users to share content on social networks. When you interact with such social media widgets or “share buttons”, these social network companies may collect information about you and/or your device and connection. your interactions with these services are governed by the respective privacy policies of the companies providing these services. For more information on the data protection and privacy practices of these companies, you can refer to their specific policies listed below:

• Facebook:https://www.facebook.com/about/privacy/
• Linkedin:https://www.linkedin.com/legal/privacy-policy

Security and other important information
How long does CLOUD TRAVEL keep your data?

Personal data collected, received and processed for the purposes described in this policy is not kept longer than necessary by CLOUD TRAVEL.
CLOUD TRAVEL does not retain user level data for more than 13 months except for the data collected for the purpose of its first-party analytics tool which can be stored up to 25 months based on the guidelines of our Supervisory Data Protection Authority.

Children data

CLOUD TRAVEL never knowingly or willingly collect any personal data concerning children under 16 years of age.

International transfers

Some of the partners and processors referred to in this policy are located outside of the European Union.
In such case, we ensure that:
• the personal data is transferred to countries recognized as offering an equivalent level of protection or,
• For personal data transferred outside of countries recognized by the European Commission as having a sufficient level of protection, any of the mechanisms offering appropriate guarantees is used, for which provision is made by applicable regulations, and notably the adoption of the standard contractual clauses of the European Commission.

What rights do you have?
Consent withdrawal and opt-out of sale of information

You can change your consent status at any time from the Privacy Settings available in Stellar Obelisk mobile games and applications.
Please note that if CLOUD TRAVEL does not sell the personal information of its users, we may share it with third parties such as analytics and advertising companies in order to improve and personalize your experience and adapt the content and ads of our services.
Adjusting your consent settings within CLOUD TRAVEL apps and games, will allow you to block the collection of data for these purposes and will de facto prevent the sharing of information with our analytics and/or advertising partners.

Access right

Upon request, CLOUD TRAVEL will provide you with information about whether we hold any of your personal information. You may access or request deletion of your personal information directly in CLOUD TRAVEL mobile apps or by contacting CLOUD TRAVEL Data Protection Officer as indicated in the “Contact” section below. We will respond to your request within a reasonable timeframe.

Rectification and erasure

You may request CLOUD TRAVEL the rectification of inaccurate personal data concerning you, as well as the completion of incomplete personal data. You may also request CLOUD TRAVEL to erase without undue delay your personal data when it is no longer necessary for CLOUD TRAVEL to retain such data. In order for your data to be erased or rendered inaccessible you can either:

• reset your mobile advertising identifier (IDFA on iOS, GAAID on Androïd) or activate “Limit Ad Tracking” in your device’ settings in order to make previously collected data non linkable to you or your device anymore and limit further data collection if you choose to enable the “Limit Ad Tracking” option
• contact CLOUD TRAVEL Data Protection Officer, as indicated in the “Contact” section below in order to have the data previously collected by CLOUD TRAVEL on you and/or your device permanently erased or anonymized

Portability

Upon request, CLOUD TRAVEL will provide you with the personal data that you provided to us and, if possible, will communicate this information directly to another data controller of your choice in a portable format when the processing is based on consent or contract.