Privacy Policy

This privacy policy (the “Privacy Policy”) outlines how Three Merged Pte. Ltd., and its affiliates (“3merged”, “Arena-z,” “we,” “us,” “our”) collects, utilizes, maintains, and shares information obtained through our Arena-z Platform from various sources, including Platform Game publishers and developers, Arena-z Platform and Game users, visitors to our website (Arena-z.gg), and any other webpages linked to this Privacy Policy (collectively, the “Site”), as well as individuals who inquire about and/or utilize the applications, networks, marketplaces, technologies, and other services we provide (the “Platform,” and together with the “Site,” the “Services”). Capitalized terms not defined herein have the same meanings as outlined in our Terms of Service. The term “Game” as used in this Privacy Policy refers to any game available on the Platform, including all updates, expansions, additional content, software, localized versions, and related products, applications, and services. Arena-z acts as a data controller when operating our Platform and as a data processor when providing our Site and/or Platform to third-party Game publishers, Game developers, service providers (including but not limited to our third-party KYC service provider), and their affiliates or agents (collectively, “Game Entity” or “Game Entities”). Please carefully review this Privacy Policy.

1. Information We Collect

The types of information we collect about you and your device as you interact with our Services depend on your relationship with us:

Information You Provide to Us

• When you use our Services, the information you provide may vary depending on which aspect of our Services you use:

• Contacting us directly via an online form on our website to inquire about the Services, request access to materials, submit questions, or for other purposes may entail providing your name, email address, telephone number, and affiliation to Arena-z.

• Utilizing our Platform to build or develop Game features or technologies requires Game developers to sign our Game development license agreement, wherein they must provide certain personal information such as contact names, email addresses, and wallet or bank account details.

• Engaging with transactions on any marketplace or storefront available on or via the Platform may involve providing information such as your username, player user name, password, Game profile details, email address, wallet address, and payment method information.

• Creating an account to use our application version of the Platform (“App”) may involve providing your name, email address, country of origin, crypto wallet address, avatar, nickname, and user behavior data for analysis and product improvement.

• Creating an account to use certain features of the Service, including a Platform-created digital asset wallet (the “Wallet”) and/or account, may involve providing your name, email address, or social media account information.

• Provding feedback or contacting us, may collect your name and contact information, as well as any other content included in the message. The information collected above will be mainly used for contact purpose.

Additionally, we may also collect Personal Data at other points in our Service where you voluntarily provide it or where we state that Personal Data is being collected.

The purpose will be illustrated by our notices accompanying the related data collection.

Information We Collect Through Our Services

We automatically receive and store information about you and your device(s) as you navigate through our Services, which may include:

• Device and Software Information: This includes details about the device and software you use to access the Services, such as your internet protocol (“IP”) address, device identification, web browser type, operating system version, and similar information.

• Interactions with the Services:** We collect information about your interactions with the Services, such as specific pages visited, content viewed, date and time of visits, and, where applicable, the website visited before accessing our Service. Additionally, Arena-z may conduct Know Your Customer (“KYC”) and Anti-Money Laundering (“AML”) verification as required by applicable law, which may involve collecting your name, address, phone number, email address, and forms of identification (such as a driver’s license and social security number).

For transactions conducted on the Arena-z Platform by users, KYC and AML verifications may be carried out by our appointed KYC provider. We suggest reviewing the privacy terms of our KYC provider, if available. Both Arena-z and our KYC provider employ a tiered system for KYC and AML, whereby larger transactions might necessitate more thorough verification procedures.

Information We May Receive From Third-Party Sources

We may also receive information about you, your account with the Game developer or Game publisher, your Wallet, other service providers, and/or your device from third-party sources, including:

• Third-Party Game Publishers or Developers: Information collected from third parties whose services are supported by our Platform may include your crypto wallet’s private and/or public keys, coarse location, and other necessary information to facilitate token or digital currency transfers into or out of your Wallet.

• Game Players: Information collected directly or through third-party providers may include:

  • Contact information like name, phone number, and email address (if provided).

  • Player user name and password.

  • Game profile details, such as profile picture and inventory of in-game items.

  • Additional data provided to identify lost accounts.

  • Arena-z or Community-X specific Game user account profile ID and analytics ID.

  • Usage data, including website, product, and service usage, as well as game progress.

  • IP address, device identifiers, device details, and browser information.

  • Data related to fraud prevention and detection.

  • Marketing and communication preferences.

• Providers of Third-Party Cryptocurrency Wallets: Information may be collected from providers of cryptocurrency wallets used for transactions on the Platform, including Wallet identification numbers.

• Third-Party Providers: This may include KYC/AML service providers, payment processors, money transmission licensees, public blockchain data, and analytics providers tracking usage of our Site, Platform, and Services.

Moreover, we reserve the right to host or enlist third parties to host your information on behalf of specific third-party partners and service providers to facilitate participation in our services. Data obtained through our service providers and business partners may encompass but not limited to your name, email address, and Wallet addresses. This data will be shared through API and pertains to information gathered when utilizing the services provided by game developers, including in-game data and platform metrics. This information may be integrated with existing data collected from or pertaining to you through our Service. We utilize this information to facilitate your use of our Service and for marketing endeavors.

Information Obtained Through Cookies and Similar Technologies

We and our affiliates may gather information about you and/or your device(s) through the utilization of cookies, pixel tags, or comparable technologies. When we or our affiliates employ such methods, it will be in accordance with our cookies policy. Our affiliates, including analytics and advertising partners, may utilize these technologies to accumulate data regarding your online activities across various services over time. Cookies are diminutive text files comprising a sequence of alphanumeric characters. We may employ both session cookies and persistent cookies. A session cookie vanishes upon closing your browser, while a persistent cookie persists after browser closure and may be utilized by your browser during subsequent visits to our Site. To adjust your cookie settings appropriately, please consult your web browser’s “Help” file. Note that deleting or opting not to accept cookies from the Site may limit your ability to fully utilize its features. Online tools are available for eliminating all cookies retained by previously visited websites, such as www.allaboutcookies.org, and for users in the EEA & UK, https://www.youronlinechoices.eu/. Most advertising networks offer opt-out mechanisms for Interest-Based Advertising.

For more information, visit http://www.aboutads.info/choices/ or http://www.youronlinechoices.com.

The information we may collect via cookies could encompass:

• Internet Protocol (IP) address;

• Unique device identification numbers (e.g., Media Access Control (MAC) address);

• Identifier For Advertising (IDFA);

• Device type;

• Login data;

• Browser type and version;

• Time zone setting and location;

• Browser plug-in types and versions;

• Operating system and platform;

• Other technology utilized on the devices accessing the website;

• Usage data, including information on website, product, and service usage; and

• Marketing and communications data, including preferences for receiving marketing materials and communication preferences.

How We Utilize the Collected Information

We may employ the information gathered or received about you in various ways, including:

• Communication with you (e.g., newsletters), provision of updates and information regarding our products, Services, Platform, Games, and fulfillment of information requests, response to inquiries, and provision of customer support;

• Provision, maintenance, enhancement, and development of our Services, Platform, Games, and new products, services, features, and functionalities;

• Facilitation of actions initiated through our and third-party Games and other services available via our Platform, with the aim of enhancing and optimizing your gaming experience;

• Fulfillment of contractual obligations arising from agreements between you and us;

• Engagement in marketing and advertising activities, subject to your previous consent and your ability to opt out at your discretion, including the creation and provision of relevant and valuable materials;

• Analysis of how you utilize the Services;

• Management of competitions and promotions, and your registration for the same;

• Maintenance and security of our Site, Platform (including the Wallet and the Arena-z NFT marketplace), network systems, APIs, and other assets, including account verification and clearance;

• Administration of surveys and opinion polls, usually conducted anonymously;

• Detection and prevention of fraud, response to trust and safety concerns, provision of social features within our Services;

• Utilization of technical and usage information/analytics to aid in the development and improvement of Games, Services, and other products desired by our users;

• Compliance with legal and regulatory obligations across relevant jurisdictions, including KYC and AML compliance, transaction reporting, and the identification of Game cheating, security risks, fraud, and other illicit activities;

• Dissemination of Game-related information, such as updates, security alerts, and support messages to Game users;

• Provision of moderation services for Game players, including player communications;

• Fulfillment of legal or regulatory requirements;

• Verification and validation of payments;

• Administration of leaderboards, nicknames, and club information;

• Addressing everyday business needs, such as auditing, enforcement of our Terms, and compliance with applicable laws and regulations, or responding to judicial or governmental requests. Additionally, we may utilize your information for any other purpose(s) disclosed to you at the time of collection or reception.

We may utilize the personal data in any other manner as may be specified when you furnish the Personal Data.

3. How We Share the Information We Collect

We disclose your Personal Data in the following manner, as detailed below and elsewhere in this Privacy Policy:

• Third-Party Partners: We may share some or all of your Personal Data with third-party game developers collaborating with us or whose products Last updated: 4/16/2024 9 and/or services are linked with our Service. In such instances, we require these partners to adhere to this Privacy Policy.

• Affiliates: Some or all of your Personal Data may be shared with any subsidiaries, joint ventures, or other companies under our common control (referred to as "Affiliates"). We ensure that our Affiliates comply with this Privacy Policy.

• Corporate Restructuring: We may share some or all of your Personal Data in connection with or during negotiations for any merger, financing, acquisition, or dissolution transaction or proceeding involving the sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of insolvency, bankruptcy, or receivership, Personal Data may also be transferred as a business asset. If another company acquires our company, business, or assets, that company will assume the Personal Data rights and obligations as described in this Privacy Policy.

• Legal Rights: We may disclose Personal Data if we believe in good faith that such disclosure is necessary: (a) in connection with any legal investigation; (b) to comply with relevant laws or respond to subpoenas, warrants, or other legal processes served on us; (c) to protect or defend our rights or property or those of our users; and/or (d) to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our service terms. Notwithstanding the above, the following circumstances are not considered as disclosure by us: (a) voluntary sharing of your Personal Data stored with our Services on social media platforms by you; (b) choosing to share your Personal Data on your profile page with other users. You retain control over the Personal Data publicly displayed on your profile page, and you may hide such Personal Data from public disclosure if you opt not to share any of it.

4.Legal Bases for Processing Your Personal Information

Various legal grounds exist for processing personal information. Depending on the circumstances and applicable law, we may rely on the following legal bases for processing your personal information:

Consent: Processing your personal data is based on your explicit consent for a specific purpose. You retain the right to withdraw your consent through designated features provided for such purposes, such as an email unsubscribe link or account privacy preferences.

Contract: Processing your data is necessary for the performance of a contract with you or for taking pre-contractual steps at your request.

Legitimate Interests: Processing your data is necessary for our legitimate interests or those of a third party, provided they are not outweighed by your rights and interests. These legitimate interests may include gaining insights from your behavior on our Site or Platform, improving our Services, enhancing data security, among others.

Legal Obligations: Processing your data is necessary to comply with relevant legal obligations, such as KYC and AML regulations and other applicable laws, rules, or regulations.

In summary, each legal basis signifies:

• Consent: Clear permission given for a specific purpose.

• Contract: Processing necessary for contractual obligations.

• Legitimate Interests: Processing necessary for valid interests, not outweighed by your rights.

• Legal Obligations: Processing required to comply with legal requirements.

• For processing special categories of personal data, explicit consent is generally sought unless a legal requirement or other justification exists for processing such information.

Please note that our Platform and Games are not intended for users under the age of 13, and we do not knowingly collect data related to children under 13.

5. Choices Regarding Your Information

You have specific choices concerning the information we gather about you. You can view, access, edit, or delete your Personal Data of the Service by accessing, editing or deleting the information by yourself on our website or application, or by contacting us via email ([e-mail]) if you wish to delete your account, remove your wallet address or exercise your other rights under the GDPR, CCPA, or other applicable data protection or privacy laws. The email shall specify your request and reference the applicable law. We may ask you to verify your identity or ask for more information about your request. We will consider and act upon any above request in accordance with applicable law. We will not discriminate against you for exercising any of these rights.

Additionally, you can disable cookies in your browser settings: As explained in the section on Cookies and Similar Technologies above, you can block cookies by activating a setting on your browser that allows you to refuse them, and you can also delete cookies through your browser settings.

6. Third-Party Websites and Services

The Services may include links to other websites, products, or services that we do not own or operate. These third-party services may comprise Games, storefronts, marketplaces, and digital currency services operated by developers and other third parties. We are not responsible for the privacy practices of these third parties, who act as controllers for information provided in those contexts. For clarity, this includes any Game developer or publisher with which Arena-z collaborates, and any account you have directly with such developer or publisher is solely governed by them, with Arena-z having no control or input. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to review their privacy policies before providing any information to them.

7. Security & Retention

We take reasonable measures to safeguard your information by implementing and maintaining appropriate technical and organizational measures. We will retain your personal information until the earlier of: (i) the information no longer being necessary for the purpose for which it was provided, (ii) there being no ongoing business justification for retaining the information, or (iii) until you request deletion of your account.

We may retain your information for longer periods for specific purposes, as required by applicable laws and regulations, and/or to protect our legal rights or for certain business requirements.

Notwithstanding the foregoing, we may keep the data, which cannot identify you individually, to improve our product, such as your interactive data related to our product (e.g. clicks, savings, journal access data).

8. International Visitors & Data Transfers

We may transfer your personal data to our service providers or third parties located outside the European Economic Area (EEA) and the UK, where countries may offer a lower level of data protection than in the EEA and UK. Before doing so, we will take necessary steps to ensure that your personal data receives adequate protection as required by relevant data privacy laws. Any transfer of personal data from the EEA to third parties outside the EEA and the UK will be based on an adequacy decision or governed by standard contractual clauses, ensuring compliance with appropriate international data transfer mechanisms and standards. When engaging suppliers based in the United States, we verify whether they can host the data within EU countries. If not feasible, we ensure that standard contractual clauses are in place before transferring any personal data.

9. EEA and UK Data Subject Rights

You can exercise your rights by contacting us at [e-mail]. There is no fee required to exercise your rights, and we have 30 days to respond to your request. However, we may charge a "reasonable fee" for administrative costs if a request is deemed manifestly unfounded or excessive, or if additional copies of data are requested. The time frame for response may be extended by an additional two months for complex requests or in case of multiple requests from the same individual. Please note that we may verify your identity before processing any requests described in this section and reserve the right to deny requests if identity verification is not possible.

Under various data protection laws, your rights generally include:

• Right of Access: You can request copies of your personal information.

• Right to Data Portability: You can ask us to transfer your personal information to another organization or to you in certain circumstances.

• Right to Rectification/Correction: You can request correction of inaccurate or incomplete information.

• Right to Erasure/Deletion: You can request erasure of your personal information in certain circumstances.

• Right to Restrict Processing: You can request restriction of processing of your personal information in certain circumstances.

• Right to Object to Processing: You can object to processing of your personal data in certain circumstances.

• Right to Lodge a Complaint: You can file a complaint regarding our use of your data directly with Arena-z by emailing [e-mail] or by contacting our UK and EU representatives.

We have appointed GRCI Law Limited as our UK Representative. For inquiries regarding your rights or privacy matters under the UK General Data Protection Regulation (UK GDPR), please email our UK Representative at [e-mail], including our company name in the correspondence.

Additionally, we have appointed IT Governance Europe Limited as our EU representative. For inquiries regarding your rights under the EU General Data Protection Regulation (EU GDPR), or for general privacy matters, please email our EU Representative at [e-mail], ensuring to include our company name in all correspondence.

If your request or concern is not resolved satisfactorily by us, you may contact your local EU data protection authority: https://edpb.europa.eu/about-edpb/aboutedpb/members_en. For individuals in the UK, you can contact the Information Commissioner's Office (ICO) at https://www.ico.org.uk.

10. California Privacy Rights Notice

The California Privacy Rights Notice supplements this Policy and applies to California residents ("California Consumer"). This serves as notice under the California Consumer Privacy Act ("Act") of the categories of personal information we have collected from California Consumers in the past 12 months.

Category Examples Collected?

A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol (IP) address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

C. Commercial information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

D. Internet or other similar network activity. Browsing history, search history, information on an individual’s interaction with a website, application, or advertisement.

E. Geolocation data Physical location or movements. See Section 2 - HOW WE USE THE INFORMATION WE COLLECT for details on why we collect and process personal information.

We obtain the categories of personal information listed above from the following categories of sources:

• From individuals, directly

• From search engines, advertising networks, government entities, social networks, and data brokers

• From Game Entities

• From service providers including digital asset wallet providers, payment processors, internet service providers, and data analytics providers

We may disclose your personal information to a third party for a business purpose and when we do so, we enter into a contract describing the purpose for sharing the data. This contract also requires the recipient party to keep the personal information confidential and not use it for any other purpose except as described by the contract. We disclose your personal information for a business purpose to the following categories of third parties:

• Service providers

• Game entities

• Digital asset Wallet providers

• Payment processors

• Data analytics providers

In the preceding twelve (12) months, we have not sold any personal information. Data Subject Requests If you are a California consumer, the CCPA provides specific rights regarding your personal information.

Right To Know & Data Portability

You may request that Arena-z discloses to you what personal information we have collected, used, and shared, and why we collected, used, or shared that information. Specifically, you may request that we disclose:

• The categories of personal information collected

• Specific pieces of personal information collected

• The categories of sources from which we collected personal information

• The purposes for which we use the personal information

• The categories of third parties with whom we share the personal information

• The categories of information that we disclose to third parties

You may also request that we provide you a copy of your personal information in a readily portable format. Right to Delete: You have the right to request we delete any of your personal information we collected from you and retained, subject to certain exceptions. Once we receive and confirm your request, we will delete, and direct our service providers to delete, your personal information from our/their records, unless an exception applies.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights.

Methods For Submitting Request

You can only make two Requests to Know in a 12-month period, and the information provided need only cover the 12-month period prior to receipt of your request. You may submit Requests to Know and Requests to Delete by sending an email to [e-mail].

Verification of Requests

We will need to verify your identity to respond to Requests. We cannot respond to your request or provide you with personal information if we cannot verify your identity or your authority to make the request and confirm the personal information relates to you. Making a verifiable request does not require you to create an account with us. We will only use personal information provided in a request to verify the requestor's identity and/or authority to make the request.

Time for Response

Please note that once you have submitted a Request to Know or Request to Delete, we will send you a receipt, acknowledging your request, within 10 business days. If, for some reason, you do not receive such a receipt within 10 days of your submitted request, please send us an email to [e-mail] as an error may have occurred. We make every effort to respond to Requests to Know and Requests to Delete within 45 calendar days after they are received, but if necessary, we may take up to an additional 45 calendar days to respond to your request. If we require the extra time (up to 90 days), we will inform you of the reason and extension period in writing.

No Sale of Personal Information - California and Nevada Law

We do not sell your personal information as defined under California and Nevada law and therefore are not required to provide an opt-out.

Authorized Agent

As a California resident, you have the right to designate an agent to exercise these rights on your behalf. We may require proof that you have designated the authorized agent to act on your behalf and to verify your identity directly with us. Please contact us at [e-mail] for more information if you wish to submit a request through an authorized agent.

11. Children’s Privacy

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of our Services are directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at [e-mail]. If we become aware that a person under the age of 13 has provided us with personal data without verification and parental consent, we will work to delete it immediately.

12. Updates to This Privacy Policy

This Privacy Policy may be updated from time to time for any reason. The date the Privacy Policy was last revised is identified at the beginning of this Privacy Policy. Last updated: 4/16/2024 20 You are responsible for periodically visiting our Service and this Privacy Policy to check for any changes.

13. Contact Us

If you have any questions or concerns about our Privacy Policy or our data collection or processing practices, or if you want to report any security violations to us, please contact us at:

[e-mail].

Three Merged Pte. Ltd.

68 CIRCULAR ROAD #02-01

SINGAPORE