Last Updated Date : December 30, 2021

1. Introduction

1.1 Moniwar Co., Ltd.’s goal is to make wonderful games for everyone to

enjoy. We, respect the privacy of everyone who uses our games (the “Game” or

“Games”), that are available via the Apple App Store, Google Play Store, and/or on

Facebook (the “Website” or “Websites”) and any related services which we or our

group companies may provide to you from time to time (together with the Games and

Website, the "Services"). In this document we refer to Moniwar Co., Ltd. as

"Moniwar" "us", "we" or "our" and we refer to you as "you" and "your".

This document, the "Privacy Policy", explains how we collect, process and store any

personal data belonging to you, overall information about you which is personally

identifiable such as your name, address, telephone number or email address. Such

information is referred to throughout this policy as "Personal Information" or "data".

By accessing and/or using our Services you consent to us collecting, processing,

storing and sharing your Personal Information in the ways set out in this Privacy

Policy. If you have any concerns about providing data to us or having it used in any

manner permitted in this Privacy Policy you should not use our Services. As set out

in the terms and conditions relating to our Services, you must be at least 13 years

old to access and/or use our Services. If you are between the ages of 13 and 18, you

represent that your legal guardian has reviewed and agreed to these Terms.

We never knowingly collect or solicit any information from anyone of 13 years and

younger. The App and its content are not directed at nor made look to appeal to such

persons. Parents or guardians that believe that we hold information about their

children aged 13 and under may contact us at privacy@moniwar.io

2. Information we collect about you, and how we collect it

2.1 We may collect and process the following data about you:

 information that you provide us with when you fill in forms when accessing and/or

using our Services directly or using a third party social network or service (for

example, using our services using your Facebook account), or when you create

an account with us;

 details of your use of our Services and the resources that you access (for

example, information about how and when you play our Games or visit our

Website, what device you use to access our Services or, details regarding profile

visits);

 if you contact us or respond to messages and communications that we send to

you, we may keep a record of that correspondence;

 your interactions with us on our social media channels such as Facebook;

 we may obtain information about you from third parties who hold data about you

and who agree to share this data with us; and

 information we collect via cookies and other similar technologies, as explained

further below.

Cookies & Tracking Devices

We may use cookies and similar tracking devices in our Services. These

technologies is a small bit of record-keeping information that websites often store on

your computer or mobile device. These technologies operate either by placing a

small file which stores some information on your computer or mobile device; and/or

by accessing information on your device. We use cookies and similar technologies:

 to allow us to recognize you and your device, for example by identifying your IP

address;

 to allow our Services to interact with a third party social network or platform

(where you have chosen to allow such interaction);

 to allow our payment processors to process your payment instructions;

 to enable us and third parties to provide you with more customized services, for

example to provide our services in the correct language or to enable the provision

of more relevant advertising to you; and

 to collect data such as: your device’s model, operating system and screen size,

the other applications installed on your device, and information about how you use

our Services.

By accessing and/or using our Services you consent to our use of cookies and

similar technologies in accordance with this Privacy Policy. You can disable cookies

through your web or phone browser settings but you may find you are not able to

enjoy all the features of our Services if you do so. Alternatively, if you do not wish us

to collect data as described in this section, you should stop using our Services.

Advertisers on mobile devices sometimes use advertising (or ad) identifiers to enable

and optimize their advertising. Ad identifiers are non-permanent, non-personal,

device identifiers such as the Android advertising ID and/or Apple’s ID for

advertising, or IDFA. When we advertise our Services on mobile devices, we may

use your device’s advertising identifier and other information associated with it, to

help us to deliver ads that relate to your interests and to improve and measure the

effectiveness of ad campaigns. You can choose to prevent your device’s ad identifier

being used for interest based advertising, or you can reset your device’s ad identifier,

by changing the settings of your device. Settings vary from device to device but if

you are using an Apple device with iOS 7 or later you can find the ad identifier

settings under Settings, and if you are using a Google Android device running

Android 2.3 or later you can find the ad identifier settings in your app drawer under

Google Settings.

Payment Information

When you purchase Services on our game or website, we may collect certain

payment information from you on behalf of our payment service providers, but this

information is temporarily cached in a way that is unreadable by Moniwar.

When you purchase items via our apps (such as those you can purchase in the

Apple App Store or the Google Play Store) we do not collect or store any payment

information from you.

3. How will we use your Personal Information?

3.1 You agree that we (or a supplier or group company acting on our behalf and only

under our instructions) may use your Personal Information for the purposes of:

 contacting you, for example as part of our customer support or to send you

updates about our Services;

 managing your account and relationship with us and improving your experience

when you use our Services;

 improving our Services, for example by helping us fix bugs or by providing

Services updates;

 research, surveying, and engaging with you, for example by sending you

communications (including by email) for these purposes;

 marketing and promotion of our Services or related products, for example sending

you communications (including by email) for these purposes on our, or a third

party's behalf. For example, we might send you information about merchandise

relating to our Services If you do not want us to use your data in this way please

let us know by contacting us at support@moniwar.io or the respective

customer service e-mail address assigned differently to each Service;

 to personalize and optimize our Services, promotional content and advertising to

you. For example, we may use the information we collect through cookies, and

similar technologies. If you do not want us to use your data in this way, you can

opt-out by following the steps at section 3 section 2 above;

 to create reports, analysis or similar services for use by us for the purposes of

research or business intelligence, for example to track potential problems or

trends with our Services;

 preventing cheating, crime or fraud. We may also need to pass your information to

fraud prevention agencies and other organizations involved in crime and fraud

prevention;

 as otherwise expressly set out in this Privacy Policy or as required by law.

4. Will we share your Personal Information with third parties?

4.1 We will only share your data with third parties (for example, our group companies

or suppliers):

 with your consent (including as set out in this Privacy Policy);

 as reasonably necessary in order to provide the Services to you (for example, by

providing your Personal Information to suppliers we may use to fulfil the Services

or to communicate with you);

 where it is necessary to carry out your instructions (for example, to process a

payment instruction we must provide your Personal Information to our payment

processors);

 where your data is on an anonymous and aggregated basis, meaning you could

not be personally identified from it;

 when you submit information as part of a competition or otherwise interact with our

social media channels (for example, by providing a testimonial about one of our

Services) we may publish the information you submitted, alongside your name

and home country on our website(s) and social media channels;

 as we reasonably believe is permitted by law or regulation;

 in order to comply with any legal obligation, or in order to enforce or apply our

terms and conditions and/or any other agreement with you; or to protect the rights,

property, or safety of Moniwar, our users, or others;

 in the event that there is a sale of the assets of Moniwar or corporate

restructuring, or as a result of a change of control of Moniwar or one of its

group companies, or in preparation of any of these events. Any third party to

which Moniwar transfers of sells Moniwar's assets will have the right

to continue to use the personal and other information that you provide to us in the

manner set out in this Privacy Policy. We will not sell or rent your information to

any third party outside of these circumstances.

5. Interaction with social networks or platforms

5.1 You may allow our Services to interact with third party social networks or

platforms (such as Facebook or Apple’s Game Center), which will provide data about

you to us. These applications or websites are created and maintained by a third

party which is not a part of, or controlled by Moniwar. You should ensure that

you read their terms of service and privacy policies to understand how they treat

your data and what data they might share with us.

You understand that where you allow our Services to interact with any third party

social network or platform, we may share data about you with your contacts and

other users of our Services (and vice versa) in order that you may enjoy playing

socially (the “Social Data”). This Social Data may include your name, your social

media profile picture, your activity status (including the time and date you last used

our Services) and your scores and/or progress in our games.

You can make changes to what data a third party social network or platform shares

with us, or stop our Services interacting with that social network or platform by

adjusting your settings with that third party provider, however you may find you are

not able to enjoy all of the same features of our Services.

6. For how long will we retain your information?

6.1 We will retain your Personal Information for as long as is necessary to fulfil the

purposes for which it was collected or as needed to provide you with Services. We

may retain your Personal Information after you have closed any account you have

with us or after we have stopped providing Services to you if retention of your

Personal Information is reasonably necessary to comply with our legal obligations,

meet regulatory requirements, resolve disputes between members, prevent fraud,

cheating or abuse, or enforce this Privacy Policy or any other agreement we may

have with a user.

7. Will we transfer your Personal Information overseas?

7.1 Your Personal Information may be transferred to, and stored at, a destination

outside VietNam. It may also be processed by staff operating outside VietNam who work

for us or for one of our suppliers. We will take all steps reasonably necessary to

ensure that your Personal Information is treated securely and in accordance with this

8. How do we protect your Personal Information?

8.1 The security of your Personal Information is very important to us. We maintain

appropriate technical and physical safeguards to protect your Personal Information

against accidental or unlawful destruction or loss, alteration, unauthorized disclosure

or access, use and all other unlawful forms of processing of the data in our

possession. However, since the internet is not a completely secure environment we

cannot guarantee that information you transmit via our Games will not be accessed,

disclosed, altered or destroyed by breach of any of our safeguards.

9. Links from our Services

9.1 We may provide links to third party websites from our Services. You understand

that when you click on these links any data which you provide afterwards is subject

to that third party's privacy policy and not to ours. Although we will try only to link to

reputable websites, Moniwar takes no responsibility for the content, safety or

security of any third party website.

10. Your rights in relation to your Personal Information

10.1 We want to make sure that your Personal Information is accurate and up to

date. You may ask us to modify, correct or remove information by contacting us at

support@moniwar.io or the respective customer service e-mail address

assigned differently to each Service.

10.2 Information that you have shared via our Services on any social network or third

party platform cannot be amended or deleted by us where it is in the control of that

social network or third party platform. In addition, where any third party copies

information which you have made available via the use of our Services (for example,

one of your friends on a social network you allow to interact with your account), we

may not be able to amend or delete it because it may not be in our control.

11. How to contact us

11.1 To find out more about how your Personal Information will be used please

service e-mail address assigned differently to each Service.

12. Legal matters

12.1 If any court or other competent authority finds any of the terms of this Privacy

Policy to be invalid or unenforceable, the other terms of this Privacy Policy will not be

affected.

This Privacy Policy is governed by and interpreted in accordance with the laws of

VietNam. Any dispute arising in connection with this Privacy Policy will be subject to the

exclusive jurisdiction of the courts of VietNam unless you choose the courts of your

home country. We are constantly innovating and looking for new ways to improve

our Services and our Games. We reserve the right to change, amend and/or modify

this Agreement, in whole or in part, at any time, and when we do so, we will provide

you with reasonable notice that a change, amendment or modification has been

made. You hereby acknowledge and agree that such changes, amendments and/or

modifications will become effective when posted on the Service or as otherwise

provided by us. If you object to any of the changes you should immediately stop

using our Services and close any account you may have with us.

13 Compliance to the EU General Data Protection Regulation

13.1 This clause concerns you if you are residing in Europe and using our service

and we strongly advise that you understand the terms of this clause if this concerns

you.

13.2 We at Moniwar will take necessary actions to protect your personal

information and comply with the General Data Protection Regulation (the “GDPR”) of

the European Union.

13.3 We define and process personal information in compliance to the GDPR, and

collect personal information in order to provide service, and will discard the collected

personal information as soon as the purpose of collecting the information has been

fulfilled.

13.4 We collect personal information including but not limited to your account

information (including your Facebook account), information about your Facebook

Friends, Push Notification token, your unique device ID, in order to properly provide

service to you.

13.5 We will comply with and follow the procedures and methods listed in the GDPR

when you wish to exercise your rights defined in the GDPR including but not limited

to viewing, correcting, deleting, and limiting your personal information we have

access to.

13.6 Moniwar provides specialized customer service to ensure the your rights

defined in the GDPR including but not limited to viewing, correcting, deleting, and

limiting your personal information we have access to. If you wish to exercise your

rights concerning your rights defined in the GDPR, please contact our Data

Protection Officer (the “DPO”) at privacy@moniwar.io. By accepting this

information by our DPO in order to process your wish to exercise your rights to view,

correct, delete, and limit your personal information and agree that this may be limited

if you do not provide us with the additional personal information.

13.7 If we have collected and processed your personal information with your

consent, then 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 processing of your personal information conducted in

reliance on lawful processing grounds other than consent.

13.8 Moniwar has assigned a designated DPO as stated in the GDPR to

handle your requests, inquiries, and opinions regarding your personal information. If

you have anything to say to us regarding your personal information, please contact

our DPO at the contact information below.

- Company: Moniwar

- Contact: contact@moniwar.io

14 Compliance to Regulations of Local Jurisdictions

Wonder People respects and complies with the regulations of local jurisdictions. We

prohibit the access of our services from locations which our service is seen illegal

based on the regulation imposed by the local jurisdiction. By agreeing to this Privacy

Policy, you agree that your location data may be collected and used by us to

determine if you are using our services in a location where our service is deemed

illegal, ad you understand that we may limit your access to our services if this is the

case.