X. INTERNATIONAL DATA TRANSFERS

Our Service is global by nature and your data can therefore be transferred to anywhere in the world. We transfer, process and store your information outside of your country of residence, to wherever we or our third-party service providers operate for the purpose of providing you the Services. Whenever we transfer your information, we take steps to protect it.

When we transfer Personal Information outside of the European Economic Area (EEA) or other jurisdictions with data protection laws, we ensure appropriate safeguards are in place. This may include Standard Contractual Clauses (SCCs) approved by the European Commission or other legally recognized transfer mechanisms.

International transfers within the Subsidiary or Affiliate Companies. To facilitate our global operations, we transfer information to Belarus and allow access to that information from countries in which our owned or operated companies have operations for the purposes described in this policy. These countries may not have privacy and data protection laws equivalent to the laws of many of the countries where our customers and users are based. When we share information about you within and among corporate affiliates, we make use of standard contractual data protection clauses that have been approved by the European Commission.

International transfers to third-parties. Some of the third parties described in this privacy policy that provide services to us under contract, are based in other countries that may not have privacy and data protection laws equivalent to those of the country in which you reside. When we share the information of customers in the European Economic Area or Switzerland, we make use of the EU-U.S. and Swiss-U.S. Privacy Shield Frameworks, European Commission-approved standard contractual data protection clauses, or other appropriate legal mechanisms to safeguard the transfer. We will provide you with a copy of the standard data protection clauses upon your request.

XI. YOUR RIGHTS AND OPTIONS (GDPR & GLOBAL COMPLIANCE)

If you are a resident of the European Union (EU), European Economic Area (EEA), or other jurisdictions with data protection laws, you have certain rights regarding your personal data. Below is a list of key rights with references to applicable regulations.

• Right to Access (Article 15 GDPR, CCPA – California residents, other applicable laws) – You have the right to request access to your personal data, including details on how it is processed and for what purposes.
• Right to Rectification (Article 16 GDPR, other applicable laws) – You can request corrections to any inaccurate or incomplete personal data.
• Right to Erasure ("Right to be Forgotten") (Article 17 GDPR, CCPA – California residents, other applicable laws) – You may request deletion of your personal data when it is no longer necessary for the purposes for which it was collected, or if you withdraw consent and no other legal basis for processing exists.
• Right to Restriction of Processing (Article 18 GDPR, other applicable laws) – You can request that we restrict the processing of your personal data under certain circumstances, such as when you contest its accuracy.
• Right to Data Portability (Article 20 GDPR, other applicable laws) – You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller where technically feasible.
• Right to Object (Article 21 GDPR – EU users only, other applicable laws) – You may object to our processing of your personal data based on legitimate interests, including profiling, unless we can demonstrate compelling legitimate grounds for processing.
• Right to Withdraw Consent (Article 7(3) GDPR, other applicable laws) – If we process your personal data based on your consent, you have the right to withdraw it at any time without affecting the lawfulness of processing prior to withdrawal.
• Right to Opt-Out of Targeted Advertising (CCPA – California residents, other applicable laws) – You may opt out of interest-based advertising and certain types of data processing used for targeted ads.
• Right to Object to the Sale of Personal Data (CCPA – California residents only) – If you are a California resident, you have the right to opt out of the sale of your personal data. To exercise this right, please contact us at privacy@awem.com.
• Right to Lodge a Complaint (Article 77 GDPR, other applicable laws) – If you believe that our processing of your personal data violates applicable regulations, you have the right to file a complaint with a relevant data protection authority.

How to Exercise Your Rights

If you wish to exercise any of these rights, please contact us at:

Awem Games Limited
Address: Neofytou Nikolaidi, 17, S.P. CENTER, floor 5, 8011, Paphos, Cyprus
Email: privacy@awem.com

We will respond to your request in accordance with applicable laws, typically within one month. If additional time is required due to complexity or high volume of requests, we will notify you accordingly.

Managing Push Notifications and Communications

You may opt-out of receiving push notifications by adjusting the settings on your mobile device or web browser. If you have previously opted in and wish to stop receiving such notifications, you can change your preferences in the settings section of your device. Additionally, you can opt-out of marketing emails by following the instructions in our email communications or contacting us at privacy@awem.com.

You can also manage your marketing preferences through your account settings, where available. If you request to opt out of receiving marketing messages, we may still send you important service-related communications.

Filing Complaints and Dispute Resolution

If you have concerns about how we handle your data, you have the right to file a complaint with a data protection authority in your jurisdiction. Additionally, we offer an internal dispute resolution mechanism. If you have any complaints or questions regarding your privacy, please contact us first at privacy@awem.com, and we will attempt to resolve your concerns in a timely manner.

Legal Basis for Processing Personal Data

We collect and process personal data based on the following legal grounds:

• Performance of a contract – When processing is necessary to fulfill our contractual obligations with you.
• Legitimate interests – When processing is required for our legitimate business interests, provided that such interests do not override your rights.
• Legal obligations – When processing is required to comply with applicable legal and regulatory requirements.
• Consent – When you have provided explicit consent for specific data processing activities.

Note: Some of these rights apply only to residents of specific jurisdictions. Users from the EU are protected under GDPR, while users in the US may have rights under CCPA or other state laws. Please refer to your local regulations for more details.

Opt-Out of Targeted Advertising, Sale of Personal Data, and Profiling

In compliance with applicable privacy laws, including the Virginia Consumer Data Protection Act (VCDPA), we provide users with the right to opt out of certain types of data processing. You have the right to opt out of:

• Targeted Advertising – The processing of your personal data to deliver tailored advertisements based on your behavior, interests, or other personal attributes.
• The Sale of Your Personal Data – The transfer or disclosure of your personal data to third parties in exchange for monetary or other valuable consideration.
• Profiling that Produces Legal or Similarly Significant Effects – Automated decision-making that may impact you in a legally significant way, such as eligibility for credit, employment, or access to certain services.

How to Exercise Your Opt-Out Rights:
You may opt out of these practices by using one of the following methods:

• Submit a Request via Email: Send an email to privacy@awem.com with the subject line "Opt-Out Request" and specify which type of data processing you wish to opt out of.
• Browser Controls: Modify your browser settings to block or limit tracking technologies used for targeted advertising.
• Device Settings: Disable ad tracking through your device settings (e.g., "Limit Ad Tracking" on iOS or "Opt out of Ads Personalization" on Android).
• Industry Opt-Out Tools: Use opt-out tools provided by industry organizations such as the Network Advertising Initiative (NAI) or Digital Advertising Alliance (DAA).

Once we receive your request, we will process it within the time required by applicable laws and confirm the action taken. If we deny your request, we will provide a detailed explanation.

Opt-out of targeted advertising

You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting “limit ad tracking” (Apple iOS) or “opt-out of interest-based ads” (Android).

Access the Personal Information (Right of Access)

If you request, we will provide you a copy of your personal data in a structured, electronic format. Below, we describe the processes for making these requests. You may contact us as explained in the Contact Us section below to request assistance.

Change or Correct Your Information (Right to Rectification)

You can edit some of your personal data through your account. You can also ask us to change, update or fix your data in certain cases, particularly if it’s inaccurate.

Delete Your Information (Right to Erasure): You can ask us to erase or delete all or some of your personal data (e.g. if it is no longer necessary to Provide Services to you). As a result of deleting your Account, you will lose access to most Services, including the Account and game-related information linked to the Account, subscriptions, and the possibility to access other services for which you are using the Account. Please note that once your Account has been deleted, you will lose your gaming experience and all related information.

Request That We Stop Using Your Information (Right to Object): Where processing of your Personal Data is based on legitimate interests, you can use your right to object at any time. If you object, we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing, or the data is necessary for the establishment, exercise or defence of legal claims.

Opt-Out of Direct Marketing: You can also opt-out of our use of your information for marketing purposes by following instructions in promotional communications or by contacting us, as explained in the section “Contact Us”. When you make such requests, we may need time to investigate and facilitate your request. To change or delete push notifications, visit the settings section on your device and select the appropriate setting, or change the settings on your browser if you are accessing any of our websites.

Data Portability: Data portability is the ability to obtain some of your personal information in a format that you can move from one service provider to another (for instance, when you transfer your email address to another carrier). Depending on the context, this applies to some, but not to all of your data.

In compliance with applicable data protection regulations, you have the right to request a copy of your personal data in a structured, commonly used, and machine-readable format.

You may withdraw consent where processing of your personal information is based on consent, by contacting us as explained in the section “Contact us”. If you withdraw your consent, it will not affect the lawfulness of processing based on your consent before its withdrawal.

Withdrawal of Consent and Data Deletion
If you have provided consent for the collection or processing of your personal information, you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing conducted before its withdrawal.
If you request the deletion of your personal data, we will comply with your request in accordance with applicable data protection laws, except where data retention is required by legal obligations, security purposes, or dispute resolution.
To withdraw consent or request data deletion, please contact us at privacy@awem.com.

In most instances, we will respond to all requests within one calendar month. If we are unable to deal with your request fully within a calendar month (due to the complexity or number of requests), we may extend this period by a further two calendar months. Should this be necessary, we will explain the reasons for such a delay. If you make your request electronically, we will, where possible, provide the relevant information electronically unless you request otherwise.

You have the right to complain to the Data Protection supervisory authority within the European Economic Area for unresolved complaints.

In addition to the rights listed above, California users have the right to request disclosure of whether their personal information has been shared with third parties for targeted advertising or other business purposes. Upon request, Awem Games will provide:

• A report detailing the categories of personal data shared
• The recipients of such data
• The purpose of sharing

If you would like to exercise this right, please submit a request to privacy@awem.com with sufficient information to verify your identity. Awem Games does not discriminate against users who exercise their privacy rights under the CCPA.

Depending on your jurisdiction, you may have additional rights under laws such as the Personal Information Protection Law (PIPL) in China, the Personal Information Protection Act (PIPA) in South Korea, or the Digital Personal Data Protection Act (DPDPA) in India. These may include rights to request corrections, data portability, or to object to automated decision-making. To exercise these rights, please contact us at privacy@awem.com

Please refer to the Terms of Service for more information about your right of withdrawal and refund conditions regarding purchases made through our Services.

XII. CALIFORNIA PRIVACY RIGHTS

This section provides additional details about the personal information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act or “CCPA.”


For more details about the personal information we collect, please see the USE OF INFORMATION section above. We collect this information for the business and commercial purposes described in the HOW WE USE YOUR INFORMATION section above.

Awem Games does not sell (as such term is defined in the CCPA) the personal information we collect. Please note that we do use third-party cookies for our advertising purposes as further described in the COOKIES section above.
Under the California Consumer Privacy Act (CCPA), California users have the right to know whether their personal information is shared with third parties and to whom it has been disclosed. "Sharing" under the CCPA refers to the disclosure of personal data to a third party for cross-context behavioral advertising purposes. Awem Games may share personal data with certain third parties, including advertising networks, analytics providers, and business partners, as described in the DISCLOSURE OF INFORMATION section of this policy.

Users have the right to request detailed information regarding the categories and specific pieces of personal data shared, the purposes for sharing, and the recipients of such information. If you would like to exercise this right, please contact us at privacy@awem.com. We will respond to verifiable requests in accordance with the timeframes established by the CCPA.

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt-out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us privacy@awem.com. We will verify your request using the information associated with your account, including email address.

XIII. VIRGINIA PRIVACY RIGHTS

If you are a resident of Virginia, you have certain rights under the Virginia Consumer Data Protection Act (VCDPA) (Va. Code Ann. § 59.1-578(C)). These rights include:

• Right to Access – You have the right to confirm whether we process your personal data and access such data.
• Right to Correct – You may request that we correct inaccuracies in your personal data, taking into account the nature of the data and the purposes of its processing.
• Right to Delete – You may request the deletion of personal data that you have provided to us or that we have collected about you.
• Right to Data Portability – You may obtain a copy of your personal data in a portable and readily usable format.
• Right to Opt-Out – You may opt out of:

      - Targeted advertising,
      - The sale of personal data,
      - Profiling that produces legal or similarly significant effects.

We do not sell personal data as defined under the VCDPA. However, if you wish to exercise your rights under this law, you may submit a request by contacting us at privacy@awem.com.
We will respond to your request within 45 days of receiving it, with the possibility of an extension for an additional 45 days when reasonably necessary. If we decline your request, we will provide an explanation and instructions on how you can appeal our decision.
For more information about your rights under the VCDPA, please refer to the official Virginia Consumer Data Protection Act at Virginia Code Ann. § 59.1-578(C).

XIV. CONTACT US

If, for any reason, you are concerned with the way that we may be using your personal information, you have questions about the privacy aspects of the Services please contact us at:
Awem Games Limited
Address: floor 5, S.P. CENTER,
Neofytou Nikolaidi, 17, S.P. CENTER, office 207, 8011, Paphos, Cyprus
Contact E-Mail: privacy@awem.com.

XV. BRAZILIAN USERS’ RIGHTS UNDER LGPD

If you are a user in Brazil, you have certain rights under the Lei Geral de Proteção de Dados (LGPD) – General Data Protection Law No. 13.709 regarding the collection, use, and sharing of your personal data. Awem Games is committed to protecting your rights and ensuring compliance with LGPD.

1. Rights Granted Under LGPD

Under LGPD, you have the following rights regarding your personal data:

• Right to Confirm the Existence of Processing: You have the right to confirm whether we process your personal data.
• Right to Access: You may request access to your personal data that we process.
• Right to Correction: If your data is incomplete, inaccurate, or outdated, you have the right to request corrections.
• Right to Anonymization, Blocking, or Deletion: You may request the anonymization, blocking, or deletion of unnecessary or excessive data, or data processed unlawfully.
• Right to Data Portability: You have the right to receive your personal data in a structured format and transmit it to another service provider.
• Right to Information About Data Sharing: You may request information about the entities with whom we share your data.
• Right to Revoke Consent: If data processing is based on your consent, you may withdraw it at any time. However, this will not affect prior lawful processing.
• Right to Oppose Processing: You may object to data processing when it violates LGPD.

2. Legal Basis for Processing Personal Data

We process your personal data based on one or more of the legal grounds permitted under LGPD, which include:

• Your Consent (when required);
• Fulfillment of Legal or Regulatory Obligations;
• Execution of a Contract in which you are a party;
• Legitimate Interests, provided that processing does not override your fundamental rights;
• Protection of Credit and prevention of fraud;
• Compliance with Legal or Regulatory Requirements.

3. How to Exercise Your LGPD Rights

To exercise any of your rights under LGPD, you may contact us using the details provided below:

Awem Games Limited
📍 Address: Neofytou Nikolaidi, 17, S.P. CENTER, floor 5, 8011, Paphos, Cyprus
📧 Email: privacy@awem.com

Upon receiving a request, we will respond within the timeframe established by LGPD (normally within 15 days for access and confirmation requests and 30 days for other types of requests). If an extension is required, we will notify you with a justification.

4. Data Transfers and Processing Outside Brazil

Awem Games may transfer and process personal data outside Brazil, including in the European Economic Area (EEA), the United States, and other jurisdictions where our servers or third-party partners are located. When transferring data internationally, we ensure adequate protections as required by LGPD Article 33, using:

• Standard contractual clauses approved by Brazilian authorities,
• Compliance with adequacy decisions,
• Binding corporate rules, or
• Other appropriate safeguards to protect your data.

By using our services, you acknowledge that your data may be transferred and processed in these jurisdictions.

5. Contacting Brazil’s Data Protection Authority (ANPD)

If you believe that we have not adequately addressed your data protection concerns, you have the right to file a complaint with Autoridade Nacional de Proteção de Dados (ANPD), Brazil’s data protection authority. More information on filing complaints can be found on ANPD’s official website.