Poltica de Privacidad y Protecin de Datos Personales de MagnoJuegos. 1s506x

1. Introduction: 4o6w6k

AtMEGAJOGOS, we aim to provide the best possible experience tos. Therefore, in order for us to provide an increasingly personalized service for you, ours, we need to understand your gaming and interaction habits. However, the privacy and security of your personal data has always been of paramount concern to us. That is why we wish to explain, in a transparent and detailed fashion, how we collect, store, share and use personal data froms, as well as detail the choices and control options you shall have at your disposal when and if you decide to share said personal data. This is the main purpose of this Privacy and Personal Data Protection Policy ("Policy").

2. About this Policy 61217

This Policy determines the key details of the relationship between s personal data andMEGAJOGOS. The Policy applies to allMEGAJOGOSservices as well as any associated services (hereinafter referred to as "MEGAJOGOS services"). The governing the use of theMEGAJOGOSservices bysare defined in our and Conditions of Use.

From time to time, we may develop new services or offer additional services. If the introduction of these new or additional services results in any changes in how we collect and handlespersonal data, we shall provide more information and additional or policies. Unless otherwise stated, whenever we introduce new or additional services, these shall be subject to this Policy.

The purposes of this Policy are:

Ensure thatsunderstand exactly what personal data we collect about them, the reasons why we collect and use such data and with whom we share these;

Explain how we use the personal datasshare with us, in order to provide you with a great experience whenever you use MEGAJOGOS services; and

Explain tostheir respective rights and choices regarding the personal data we collect and process, as well as how we protect their privacy.

We expect that this Policy helpssunderstand our commitment to their privacy. For information on how to us in case you have any questions on concerns, please refer to section 14"ing us"below.

On the other hand, if adoes not agree with the content of this Policy, we hereby declare that s are free to decide whether to use and/or continue usingMEGAJOGOS services.

3. rights and preferences: providing you with choices and control options: 5n3466

If you do not already know, there are European Union and Brazilian laws, the General Data Protection Regulation (or "GDPR") and the Brazilian General Personal Data Protection Law (or "LGDP"), respectively, which grant certain rights to individuals in relation to their personal data. As provided for under the applicable laws and except for any limitations found therein, the rights granted to individuals are as follows:

Right to access - the right to be informed and request access to the personal data we process about the ;
Right to rectification - the right to request that we change or update the 's personal data whenever these are incorrect or incomplete;
Right to information erasure - the right to request us to delete your personal data from our database;
Right to restriction - the right to request that we, either temporarily or permanently, stop processing all or some of your personal data;
Right to objection - the right to, at any given time, object to the processing of your personal data for reasons related to your particular situation; the right to object to your personal data being processed for direct marketing purposes;
Right to data portability - the right to request a copy of your personal data in electronic form and the right to transmit such personal data for use in third-party services; and
Right to not be subject to automated decisions - the right not to be subject to a decision based solely on an automated decision with respect to personal data, including profiling, in cases where the decision may have a legal effect for you or have an equally significant effect.

In order forsto be able to easily exercise these rights and record their preferences regarding howMEGAJOGOSuses their personal data, we provide the following options through our Privacy settings, located on the "MY PROFILE" page:

Control some of the categories of personal data we handle;
Manage your publicly available personal data; and
Set sharing preferences.

If we send you electronic marketing messages based on your consent or as otherwise permitted by applicable law, smay at any time, respectively, withdraw their authorization or state their objection ("refusal") without any additional charges. To do so, all they have to do is use the link found in the electronic message itself to unsubscribe from the mailing list.

In case of questions regarding their privacy, rights, or how to exercise such rights,sshould our data protection officer by writing an email message to protecaodedados@MEGAJOGOS.com.br. We shall issue a reply within a reasonable period of time after ing the identity of the in question.

If you are unhappy with how we are using your personal data, you may also file a written complaint with the Data Protection Authority in your local jurisdiction.

4. How do we collect personal data from s? 381b

We collect personal data fromsin the following ways:

Whenss with aMEGAJOGOSservice: upon registration, we collect certain personal data, such as, but not limited to: email address, full name, sex, country, IP address, access device and its identifier so that they can use theMEGAJOGOS service in question.

Through the use of aMEGAJOGOSservice: whenuse aMEGAJOGOS service, we collect personal data about their use of theMEGAJOGOS service in question, such as games played, history of plays, list of devices used to access the services, nicknames that accessed the services from a single device, variation of ranking positions, variation in the balance of virtual credits for each , IP addresses used for access, among other information deemed necessary to achieve our corporate goals. From time to time, smay also provide us with additional personal data or grant us permission to collect additional personal data in order to provide you with more features or functionalities, for instance. The personal data collected also allows us to mitigate risks and/or frauds regarding s and against the services.

Through third parties - we may also receive personal data in connection withsand their activities from third parties, including rs and partners we work with, so that we may provideMEGAJOGOS services(please refer to Section 7"Sharing s personal data" below). We shall use these personal data if thein question authorized the relevant third party, orMEGAJOGOS, to share such data, or ifMEGAJOGOShas a legitimate interest in using these personal data to provide aMEGAJOGOSservice to the.

As described below, we do not collect photographs, exact geographic locations obtained from mobile devices, voice data or lists fromswithout their previous authorization. You can always change your mind and withdraw your consent at any time.

5. What kind of personal data ers do we collect? t1o3g

In the tables below, we organize the categories ofspersonal data that we collect and use:

Personal data categories	Category description
registration information	These are the personal data provided bysor data that we collect so thatsmay use aMEGAJOGOS service. These include name, surname, ID, email address, date of birth, sex and physical address ofs. Some personal data requested are mandatory forsto create their . salso have the option of providing us with some additional personal data so that their experience is more personalized. The specific personal data we collect depends on how theMEGAJOGOSservices are used bysand whether they use a third party service (as defined in the and Conditions of Use), such as Facebook, to useMEGAJOGOS services. Ifa uses a third party service to create an , we shall receive personal data through such third party service, but only if the has authorized the third party service in question to share their personal data with us.
Usage data	These are the personal data collected aboutswhen they use aMEGAJOGOS service, which may include: Information about the kind ofMEGAJOGOS service plan. Information oninteractions with theMEGAJOGOS services, such as games played, history of plays, list of devices used to access the services, history of nicknames used to access the services from a single device, variation of ranking positions and variation in the balance of virtual credits for each , in addition to their interactions with other MEGAJOGOS s. These may also include information about the use of third-party applications and any ments you receive. content (as defined in the and Conditions of Use of the services) they publish onMEGAJOGOS, including the messages they send and/or receive throughMEGAJOGOSand their interactions with theMEGAJOGOS Customer team. Technical data, which may include URL information, cookie data, IP address of the, the devices used to accessMEGAJOGOS services, exclusive device identifications, device attributes and type of network connection (Wi-Fi, 3G, LTE, Bluetooth etc.), as well as network provider, network and device performance, browser, language, information that allows for the management of digital rights, operating system and MEGAJOGOS application version.

Personal data categories

Category description

registration information

These are the personal data provided bysor data that we collect so thatsmay use aMEGAJOGOS service. These include name, surname, ID, email address, date of birth, sex and physical address ofs.

Some personal data requested are mandatory forsto create their . salso have the option of providing us with some additional personal data so that their experience is more personalized.

The specific personal data we collect depends on how theMEGAJOGOSservices are used bysand whether they use a third party service (as defined in the and Conditions of Use), such as Facebook, to useMEGAJOGOS services. Ifa uses a third party service to create an , we shall receive personal data through such third party service, but only if the has authorized the third party service in question to share their personal data with us.

Usage data

These are the personal data collected aboutswhen they use aMEGAJOGOS service, which may include:

Information about the kind ofMEGAJOGOS service plan.
Information oninteractions with theMEGAJOGOS services, such as games played, history of plays, list of devices used to access the services, history of nicknames used to access the services from a single device, variation of ranking positions and variation in the balance of virtual credits for each , in addition to their interactions with other MEGAJOGOS s.
These may also include information about the use of third-party applications and any ments you receive.
content (as defined in the and Conditions of Use of the services) they publish onMEGAJOGOS, including the messages they send and/or receive throughMEGAJOGOSand their interactions with theMEGAJOGOS Customer team.
Technical data, which may include URL information, cookie data, IP address of the, the devices used to accessMEGAJOGOS services, exclusive device identifications, device attributes and type of network connection (Wi-Fi, 3G, LTE, Bluetooth etc.), as well as network provider, network and device performance, browser, language, information that allows for the management of digital rights, operating system and MEGAJOGOS application version.

Personal data collected with your authorization that allow us to provide you with additional functions or functionalities:

Personal data categories	Category description
Optional mobile data	In addition to the mobile data we collect to provide swith theMEGAJOGOSservices (described above),salso have the option to authorize us to collect additional personal data from their mobile devices so that we can provide them with features and functionalities that shall enhance their experience regarding MEGAJOGOS services. We shall not collect any of the personal data listed below without first obtaining consent: sphotographs - If agives us permission to access their photographs or their camera, we shall only collect the images they specifically choose to share with us and the metadata related to such images, such as file type and image size. We shall never scan or import as photo library or camera roll; Exact geographic location obtained fromsmobile devices - Ifsauthorizes us to access specific geographic locations, this shall allow us to usesGPS or Bluetooth in order to provideMEGAJOGOSservice functionalities that require exact geographic location. Please note that this does not include s IP address. We usesIP addressto determine non-exact geographic location, such as in which country they are located, in order to comply with the purpose of our and Conditions of Use; voice data- Ifa gives us authorization, we can access voice commands through thes device microphone, in order to allow them to interact withMEGAJOGOSservices using their voice. Note that thecan always turn off the microphone functionality; and, s list- If agives us authorization to access their list, we can consult the list of s stored on their device in order to helpsuch to find friends who useMEGAJOGOS.
Payment information	We may collect this personal data if as for a Trial Period or makes any purchase through aMEGAJOGOSservice (as defined in the and Conditions of Use). The actual personal data collected may vary depending on the payment method, but may include information such as: Name; Date of birth; ID; Type of debit or credit card, expiration date and certain card number digits; Physical address; Phone number; and s transaction history information; If achooses to pay by invoice, we shall provide their personal data to our payment processors so that they may carry out credit checks and send invoices tothe .
Special offers, contests and sweepstakes	These personal data are used to enablesto and participate in special offers. Specific personal data collected may vary, depending on the special offer.
Marketing data	These personal data are used to allowMEGAJOGOSand its partners/service providers to send marketing communications tos: by email, while using theMEGAJOGOS service, and/or directly from a third party.

6. For what purposes do we use personal data from s? 6r2n

Whensuse or interact withMEGAJOGOS services, we use various technologies to process the personal data collected aboutsfor various reasons. In the table below, we set out the reasons why we process s personal data, the associated legal grounds on which our actions are based and which allow us to legally processspersonal data and the categories of personal data (identified in section 5 "What kind of personal data about s do we collect?") used for these purposes:

Indication of the reason why MEGAJOGOS handles s personal data ("processing purposes")	Legal grounds for processing purposes	Categories of personal data used by MEGAJOGOS for processing purposes
In order to provide, customize and improveexperience with regard to MEGAJOGOS services as well as other services and products provided byMEGAJOGOS, such as when providing content that is personalized, individualized or adjusted according to location, as well as recommendations, features and ments inside or outsideMEGAJOGOS(including third-party products and services).	Celebration of an agreement Legitimate interests	registration data Service use data Optional mobile data, if necessary
In order to ensure the integrity of the rankings for the modalities offered, theMEGAJOGOSentertainment environment and mitigate actions related to fraud and collusion betweens.	Celebration of an agreement Legitimate interests	registration data Service use data
In order to understand howsaccess and useMEGAJOGOS services, aiming at ensuring the technical functionality of theMEGAJOGOS services, develop new products and services and analyze the use ofMEGAJOGOSservices bys, including its interaction with applications, ments, products and services that are made available, associated with, or offered by way ofMEGAJOGOS.	Celebration of an agreement Legitimate interests	registration data Service use data
In order to establish communication withsfor purposes related to theMEGAJOGOS services.	Celebration of an agreement Legitimate interests	registration data Service use data
In order to processspayments and prevent or identify frauds, including fraudulent payments and fraudulent use of theMEGAJOGOS services.	Celebration of an agreement Fulfillment of legal obligations Legitimate interests	registration data Service use data Payment information
In order to establish communication with s, either directly or through our partners, for the following purposes: marketing, surveys, participation in contests and special offers through emails, notifications or other messages, in accordance with any authorizations that may have been transmitted bystoMEGAJOGOS(through the Privacy settings, for instance).	Authorization Legitimate interests	Contest and sweepstakes data Marketing data
In order to provideswith functionalities, information, ments or content based on s exact location.	Authorization	Optional mobile data

We use anonymized and aggregated information for purposes that include testing our IT systems, researching, analyzing data, creating marketing and promotion models, improvingMEGAJOGOSservices and developing new features and functionalities for MEGAJOGOS services.

7. Sharing s personal data: 6t4672

We list below the categories of the recipients of personal data that have been collected or generated through the use of theMEGAJOGOSservice bys, as applicable:

Publicly available information 1k2a4o

The following personal data fromsshall always be publicly available on theMEGAJOGOS service: s nickname, profile picture, game performance information and creation date, among other personal data that can be verified on the s Profile page.

Personal data that s may choose to share 1b1u3u

The following personal data shall only be shared with the recipient categories indicated in the table below if:

s choose a specific functionality of theMEGAJOGOSservice for which the sharing of personal data is necessary for the appropriate use of the functionality of theMEGAJOGOS service; or
s explicitly authorize the sharing of personal data, for instance, by selecting the appropriate setting in the Privacy settings of theMEGAJOGOS service.

Recipient categories	Reason for sharing
Third-party application used by s to to MEGAJOGOS	When accessingtheir MEGAJOGOS from a third-party application, such as social media applications,MEGAJOGOSmay share their data so thatsare linked in both s, that is, theMEGAJOGOSnetwork and any third party;
Third-party applications associated by the with their respective MEGAJOGOS	If a associates a third-party application using theirMEGAJOGOS credentials, then such third-party application may have access to certain service use data, stored content and activities. Before connecting to the Third Party Application, theshall receive a notice stating that their personal data shall be shared with/may be accessed by such Third Party Application.
Community	When as theMEGAJOGOS Community, they shall use the same nickname as the one from their . Suchnickname shall be publicly displayed to anyone who also accesses theMEGAJOGOS Community area, along with any questions, comments and other content that they can post or make public through theMEGAJOGOS service's Privacy settings.

Recipient categories

Reason for sharing

Third-party application used by s to to MEGAJOGOS

When accessingtheir MEGAJOGOS from a third-party application, such as social media applications,MEGAJOGOSmay share their data so thatsare linked in both s, that is, theMEGAJOGOSnetwork and any third party;

Third-party applications associated by the with their respective MEGAJOGOS

If a associates a third-party application using theirMEGAJOGOS credentials, then such third-party application may have access to certain service use data, stored content and activities.

Before connecting to the Third Party Application, theshall receive a notice stating that their personal data shall be shared with/may be accessed by such Third Party Application.

Community

When as theMEGAJOGOS Community, they shall use the same nickname as the one from their . Suchnickname shall be publicly displayed to anyone who also accesses theMEGAJOGOS Community area, along with any questions, comments and other content that they can post or make public through theMEGAJOGOS service's Privacy settings.

More details on publicly available information and on what sshare with third parties are available in Section 3, " rights and preferences: providing you with choices and control options", of this Policy and the Privacy settings.

Information we may share 1e7348

Recipient categories	Reason for sharing
Service providers and other parties	We use technical service providers that operate the technical infrastructure we need to provide theMEGAJOGOS Services, in particular providers that host, store, manage and maintain theMEGAJOGOS application, its content and the data we process. We use technical service providers to help us communicate with s as described in Section 6 of this Policy. We use marketing and advertising partners to show more personalized content or to help us understand how s use theMEGAJOGOS services and provide them with better service. We may also share personal data with certain marketing and advertising partners in order to send s promotional communications aboutMEGAJOGOS. Additionally, we use payment partners; however, in this case we do not store or share credit card data or other payment methods, and all data with regard to payments that are entered on our pages are encrypted and sent to the respective payment APIs.
MEGAJOGOS Partners	Shouldsaccess theMEGAJOGOS service through an offer that they have received or acquired through a third party, such as their mobile network operator, we shall share personal data with such third party about their use of theMEGAJOGOS service, such as if and to what extentthey used the offer, if they activated a MEGAJOGOS or whether they have actively used theMEGAJOGOS service. We also sharespersonal data in a pseudonymous format with marketing partners that help us in promotional efforts and with rs that allow us to offer a free service.
Compliance with the law and data protection authorities	We shall sharespersonal data when we believe, in good faith, that this is necessary in order to fulfill a legal obligation under the applicable law, or to respond to a valid legal proceeding, such as a search warrant, a court order or a subpoena. We shall also sharespersonal data if we believe, in good faith, this is necessary for our legitimate interest, or the interest of third parties, as well as in of matters of national security, law enforcement, litigation, criminal investigation, protecting anyone's safety, or to prevent death or imminent physical harm, provided that we take into the fact that such interest does not prevail over the interests or fundamental rights and freedoms of s that require the protection of s personal data.
Buyers of our business.	We shall sharespersonal data when we sell or negotiate the sale of our business to a buyer or potential buyer. In this case,MEGAJOGOSshall continue to ensure the confidentiality of spersonal data and we shall notify them before their personal data is transferred to the buyer or is subject to a different .

8. Data conservation and erasure: 5r23n

We retainspersonal data for as long as necessary in order to provide theMEGAJOGOSservice and for legitimate and essential business purposes, such as to maintain the performance of theMEGAJOGOS service, make business decisions about functionalities and offers based on data, fulfill our legal obligations, and resolve disputes. We retain some of the personal data obtained fromswhile they remainsof theMEGAJOGOS service. For instance, we keep history and their purchase history, profile, ranking positions, credit history and other information.

At thes request, we shall erase or anonymize their personal data so that they do not allow for identification, unless it is legally permitted or mandatory to keep certain personal data during processing, including situations such as the following:

If there is an unresolved issue with a s , such as an outstanding credit to their or an unresolved complaint or dispute, we shall retain all the necessary personal data until the issue is resolved;
If we are required to retain personal data in order to comply with our legal, tax, auditing and ing obligations, we shall retain all the necessary personal data for the period required by applicable law; and/or,
Whenever deemed necessary for our legitimate business interests, such as fraud prevention or to maintain the security of ours.

9. Transfer to other countries: 4x396e

MEGAJOGOSshares some personal data obtained from s on a global level with the company UNITED JOY LLP, headquartered in the city of London - UK, in order to carry out the activities specified in this Policy.

MEGAJOGOSmay also subcontract processing services or share the personal data obtained fromswith third parties located in countries other than their country of residence. The personal data obtained fromsmay, therefore, be subject to privacy laws different from those in force in their country of residence.

Personal data collected in the European Union and Switzerland may, for instance, be transferred and processed by third parties located in a country outside the European Union and Switzerland. In these cases,MEGAJOGOSshall ensure that the transfer of spersonal data is carried out in accordance with the applicable privacy laws, as well as ensure, in particular, the adoption of the appropriate contractual, technical and organizational measures, such as the standard contractual clauses approved by the European Commission.

More information about the security measures we use to protectspersonal data is available in Section 11, "Keeping s personal data safe".

10. URLs: 3x32i

We may exhibit third-party ments and other content such as URLs redirecting to third-party websites. We cannot control, nor may we be held responsible for, the privacy practices and content by third parties. If aclicks on an ment or a third-party URL, they should be aware that they are exiting theMEGAJOGOSservice and that any personal data they provide shall not be covered by this Policy. sshould read the respective privacy policies in order to find out how they collect and process their personal data.

11. Keeping s personal data safe: 6u2x1o

We are committed to protecting the personal data of ours.

We implement technical and organizational measures to help protect the security of the personal data obtained from ours, namely: creation of nicknames, encryption and access and retention policies to prevent unauthorized access and unnecessary retention of personal data in our systems. However, s must be made aware of the fact that no system is completely secure.

A protects s, and that is why we encouragesto use a unique and robust , to limit access to computers, browse rs and other devices deemed secure (trusted), and to log out after using theMEGAJOGOS service.

12. Children: 5o24v

We understand that our service can be used by people of all ages. However, age limits may apply in some countries according to local law. More details about this matter are available in our and Conditions of Use.

We do not knowingly collect personal data from children below the applicable age limit (hereinafter referred to as the "age limit"), when and if there is an age limit. In this case, if ais under the age limit that may be foreseen, they must neither use theMEGAJOGOSservice nor provide us with any personal data.

If ais one of the parents of a child under the age limit and becomes aware that the child has provided personal data toMEGAJOGOS, they should us by writing a message to [email protected] and request the exercise of their applicable rights as detailed in section 3, " rights and preferences: providing you with choices and control options", of this Policy.

If we become aware that we have collected personal data from a child under the applicable age limit, we shall take all reasonable steps in order to delete the personal data in question. To do this, it may be necessary to delete theMEGAJOGOS associated with that child.

13. Changes to this : 1z4m23

From time to time, we may make changes to this Policy.

When we make material changes to this Policy, we shall draw up a notable and appropriate communication, depending on the circumstances, by exhibiting, for instance, a notable communication on theMEGAJOGOSservice or by sending an email message tos. We may send a communication tos in advance.

Therefore, it is essential thatsread all communications carefully.

14. ing us: 351u24

Thank you for reading our . If you have any questions regarding this Policy, please our Data Protection Officer by writing a message to [email protected]. We shall issue a reply within a reasonable period of time after ing the identity of the in question.

MEGAJOGOSis responsible for the processing data for the purposes of the personal data obtained fromsprocessed under this Policy.

Latest update: valid from 12/4/2019.