Privacy Policy

This privacy policy ("Policy"), accessible within the mobile game application currently titled ["Deuce Gambit"] and via the Apple App Store listing, describes how Axelatoh Studio Pte. Ltd., a company incorporated in Singapore ("we", "us", or "our") collects, uses, discloses and protects personal data when you access or use our mobile application, game features, websites and related services (collectively, the "Services").

By accessing or using our Services, you confirm that you have read and understood this Policy and consent to the collection, use and disclosure of your Personal Data (as defined below). Where required, we will obtain your consent for the collection, use and disclosure of your Personal Data in accordance with applicable laws and platform requirements.

1. Personal Data and Information We Collect

1.1. "Personal Data" refers to data, whether true or not, about an individual who can be identified (a) from that data, or (b) from that data and other information to which we have or are likely to have access.

1.2. Depending on your interaction with our Services, we may collect:

(a) name, email address and contact number;

(b) username and account profile and authentication information;

(d) transaction information relating to in-app purchases (processed via the Apple App Store).

1.3. We may collect Personal Data in one or more of the following ways:

(a) directly from you, when you create an account, contact us, or otherwise interact with the Services;

(b) automatically, when you use the Services (including through device permissions, cookies and similar tracking technology); and/or

1.4. When you use our Services, we may automatically collect:

(a) Internet protocol ("IP") address, device identifiers and user identifiers;

(b) gameplay activity, feature interaction and progress; and

1.5. Our Services are not directed at (a) persons below the age of 13 (or such higher age as permitted under applicable law) or (b) persons below the sufficient legal age or otherwise lack the legal capacity to consent to this Policy. If we become aware of such collection without verifiable parental consent, we will take immediate steps to delete the Personal Data.

1.6. Where required, we will obtain your consent, including through in-app prompts or device permissions, before collecting or using your Personal Data.

2. Use of Personal Data

2.1. We may collect, use and disclose your Personal Data for the following purposes:

(a) to provide, operate and maintain the Services and game features;

(b) to manage your user account and verify your identity;

(d) to improve and personalise the Services through data analytics and service optimisation;

(e) to detect, investigate and prevent fraud or security breaches;

(f) to comply with legal obligations, including tax and regulatory reporting;

(g) to protect our legal rights and legitimate business interests, and for internal analytics, improvement of the Services and auditing; and

(h) such other purposes as may be reasonably related to or incidental to the purposes set out above.

3. Disclosure to Third Parties

3.1. We may share your Personal Data with trusted third party service providers (acting as data intermediaries), including:

(a) cloud hosting and infrastructure providers such as but not limited to Google Cloud or Amazon Web Services;

(b) analytics and performance monitoring providers; and

3.2. These third parties are contractually required to process Personal Data only for authorised purposes and to provide a standard of protection comparable to that described in this Policy.

3.3. We may disclose Personal Data to comply with a court order, law or legal processes, or in the event of a merger, acquisition or asset sale.

4. International Transfers

4.1. If your Personal Data is transferred to a country or territory outside Singapore, we will ensure that the recipient is bound by legally enforceable obligations to provide a standard of protection that is at least comparable to the protection under the Personal Data Protection Act 2012 of Singapore.

5. Access, Correction and Withdrawal

5.1. Subject to exceptions under the applicable laws, you may request access to your Personal Data in our possession or control and information about how it has been used. You may also request the correction of any inaccuracies.

5.2. You may withdraw your consent for the collection, use or disclosure of your Personal Data at any time by contacting us using the details provided at Paragraph 10.1 below. Please note that withdrawal may result in our inability to continue providing certain Services or features to you.

5.3. You may request the deletion of your account and associated Personal Data at any time through the in-app settings or by contacting us using the details in Paragraph 10.1 below. We will delete your data unless retention is required by law.

5.4. We reserve the right to charge a reasonable fee for processing complex access requests, as permitted by the applicable laws.

6. Security and Retention

6.1. We implement reasonable administrative, technical and organisational measures (such as encryption and access controls) to safeguard your data. However, no electronic storage or transmission is entirely secure.

6.2. We retain Personal Data only for as long as necessary to fulfil the purposes for which it was collected, or as required for legal or business purposes, including:

(a) account data, for as long as your account remains active;

(b) transaction data, as required for legal, tax and accounting purposes; and

7. Cookies and Tracking

7.1. We may use cookies and in-app tracking technologies to recognise returning users and analyse usage patterns. You may adjust your device settings to disable these, though it may limit Service functionality.

7.2. For iOS users, we adhere to Apple's App Tracking Transparency framework. We will seek your explicit permission before tracking your activity across third party apps or websites for advertising purposes.

8. App Store Data Disclosure

8.1. In accordance with Apple's requirements, we disclose that we collect the following data types which may be linked to your identity:

(a) contact information such as email address;

(b) identifiers such as user ID and device ID; and

8.2. We collect diagnostics (such as crash reports, error logs or performance data used to improve the stability and functionality of the Services) which are generally not linked to your identity.

8.3. We do not sell your Personal Data to third parties or use it for third party targeted advertising without your explicit consent.

9. Changes to This Policy

9.1. We may update this Policy from time to time to reflect changes in our practices or applicable laws.

9.2. The "Last Updated" date above indicates the latest revision. Continued use of the Services after updates constitutes acceptance of the revised Policy.

10. Contact Us

10.1. If you have questions, wish to exercise your rights, or have a complaint regarding our data handling, please contact us at info@deucegambit.com.

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