PRIVACY POLICY

TOTL Tech Ltd., its subsidiaries and affiliates (“Company” or “we””) respects the privacy of the users (“User” or “you”) of the mobile applications we distribute (“Apps”) and are committed to protect Users’ information. We believe you have a right to know our practices regarding information we may collect and use when you use our Apps.

Note that the “Children Privacy Policy” (Chapter A below) and the “TOTL Tech Ltd. Privacy Policy” (Chapter B below), and each together with Chapter C detailed below, shall be referred to collectively as “this Privacy Policy”.

1. Your consent (important, please read carefully!)

BY INSTALLING THE APPS ON YOUR MOBILE DEVICE, ENTERING INTO, CONNECTING TO, ACCESSING AND/OR USING THE APPS, YOU AGREE TO THE TERMS AND CONDITIONS SET FORTH IN THIS PRIVACY POLICY, INCLUDING TO THE POSSIBLE COLLECTION AND PROCESSING OF YOUR PERSONAL INFORMATION.

PLEASE NOTE: IF YOU OR, AS APPLICABLE, YOUR LEGAL GUARDIAN, DISAGREE TO ANY TERM PROVIDED HEREIN, YOU MUST NOT INSTALL, ACCESS AND/OR USE THE APPS AND YOU ARE REQUESTED TO PROMPTLY ERASE ALL OUR APPS FROM YOUR MOBILE DEVICE.

If you are under the age of eighteen (18), please ensure that your legal guardian has reviewed and agreed to this Privacy Policy.

CHAPTER A: CHILDREN PRIVACY POLICY

This Children Privacy Policy is designated to provide you with guidance regarding our privacy practices and principles with respect to collecting, using and disclosing personal information regarding children using our Children Apps and Users who indicate at an age-gate in our Apps that they are under 16. For the purposes of Chapter A, the term “Children Apps” will include the age-gated section of Apps accessible only to Users indicating they are under 16, and “children” will include Users indicating at an age-gate that they are under 16. We do not knowingly collect any personal information from children other than as expressly specified in Sections below.

We hereby prohibit children from actively and directly providing us with any personal information other than as specified in the sections below. If you are a legal guardian of a child and believe your child has provided us with any personal information, please contact us at jim@totl.football we will delete such information from our servers.

We may collect and maintain the information described in Section 2, directly or through certain products or services, solely for providing support for our internal operations as permitted under applicable laws and rules (described in greater detail below).

2. Online Use

These are the types of data and information which may be collected from Users of our Children Apps:

2.1 Non-personal Information:

We and our Third Parties may passively collect non-identifiable and anonymous information as detailed below (“Non-personal Information”). To put it simply, with respect to such children Non-personal Information, we and our Third Parties are not aware of the identity of the User from whom children Non-personal Information has been collected. Children Non-personal Information collected by us or our Third Parties may include technical information such as: type and version of operating system (e.g. Android, iOS, etc.), User session ID, time zone, session start / stop time, source of traffic (e.g. which ads, sites, applications and campaigns a User came from and associated revenue), App version, language (e.g. English), device type/model (e.g. Galaxy, iPhone, etc.), data regarding User behavior within Children Apps (e.g. ad impressions, User’s response to ads, including ads viewed or clicked), User’s in-app purchases including data regarding receipt validation, User’s gameplay (e.g. level reached, frequency and time spent in the Children App and in each level, game progress, fail rate, mini game(s) played, virtual currency (if any) collected or earned, virtual inventory items (if any), tools and in-app functionalities used, screens accessed, User retention, performance errors and problems (e.g. Children Apps’ stability, crashes, functioning, etc.), and other predefined events and behavior relating thereto (e.g. if User viewed a specific ad and other game play events, time of the event, internet connectivity (Wi-Fi, 3G), device time zone, etc.), our other installed Apps, User age-related information (if a User passes an age-gate i.e. if the User is below or above the age of 13 or the minimum age of majority), and geo-location – only at a country and city level. It is hereby clarified that no street name is collected.

2.2 Children’ Persistent Device Identifier and No Other children personal identifiable information:

We and Third Parties may passively collect a persistent device identifier from children, such as advertising identifier (IDFA, Advertising ID). We do not collect and do not permit Third Parties to collect from children any information that may personally identify an individual (e.g. name, address, e-mail) or any other personally identifiable information of a private and/or sensitive nature about children. We note that we may collect, use and provide access to the User’s advertising identifier in accordance with the applicable platform provider’s policies.

We do not collect or process any financial or payment information, any government identification numbers, any non-public phonebook or contact information, any microphone and camera sensor data, or any sensitive device data concerning children.

2.3 Purpose of the collection:

The information described above is collected and processed solely for the purpose of supporting our internal operations. This means the following:

1. Providing and improving Children Apps as well as ensuring proper functioning of the Apps and services;

2. Maintaining or analyzing the functioning of Children Apps and services;

3. Authenticating purchases by Users in the app stores (to provide in-app purchases);

4. Personalizing content and enhancing User experience;

5. Performing network communications;

6. Protecting the security or integrity of Users, Children Apps and services;

7. Serving contextual advertisements;

8. Capping the frequency of advertising;

9. Ensuring legal or regulatory compliance;

   The collection and/or processing in connection with these purposes will performed as permitted under applicable laws and rules.

How is the Information about our Users of Children Apps being collected?

The Non-personal Information and Children Persistent Device Identifier are collected either by us or our Third Parties through the Users’ use of Children Apps, including through Third Parties’ SDKs embedded in our Children Apps. Non-personal Information and Children Persistent Device Identifier may also be stored locally on the Users’ device via generally accepted industry technologies used within Children Apps, such as “cookies-like technology” and local storage.

If Third Parties collect Non-personal Information, Children Persistent Device Identifier and/or any other information directly from children, such collection and processing is governed by such Third Parties’ privacy policies. However, all Third Parties are carefully selected to ensure compliance with applicable privacy laws, and we confirm that they are compliant with COPPA, this Privacy Policy and the rules, policies and guidelines of the applicable Platform Provider in performance of their services.

3. Sharing children information with third parties

We may share the Children Persistent Device Identifier only in limited cases, including the following:

1. to satisfy any applicable law, regulation, legal process, subpoena or governmental request;

2. to enforce this Children Privacy Policy or the Terms of Use, including investigation of potential violations thereof;

3. to detect, prevent, or otherwise address fraud, security or technical issues;

4. to protect the rights, property, or personal safety of the Company, its Users, suppliers, licensors, and/or licensees, or the general public;

5. when the Company is undergoing any change in control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Company, in which case it may also be disclosed, transferred and/or assigned; and/or

6. Pursuant to the approval of a child’s legal guardian, in order to supply certain services that such legal guardian or the User of Children Apps may have requested from the Company.

To clarify, we may transfer and disclose Children Non-personal Information to third parties at its discretion.

4. Advertising

We accept ads from Third Party ad networks which may be displayed in Children Apps. These Third Parties ad networks are carefully selected to ensure compliance with applicable privacy laws, and we confirm that they are compliant with COPPA, this Privacy Policy and the rules, policies and guidelines of the applicable Platform Provider. Note that if the User of Children Apps clicks on any of these ads, the User will leave our Children Apps and go to the advertisers’ site which the User selected, and the advertisers may use cookies and other tracking technologies to collect Non-personal Information and/or children personally identifiable information. We recommend that children and their legal guardians review the terms of use and privacy policies of these advertisers. Their privacy policy, not ours, will apply to any of those interactions. We may also promote Children Apps in Third Parties’ applications and platforms.

In addition, we may advertise our other Apps within Children Apps. Such ads are not directed towards specific Users but are rather broadly posted onto random Apps.

5. Additional Terms and Conditions

See further terms and conditions which also apply to Users of Children Apps in Chapter C below: “Terms and Conditions Common to Both Children Privacy Policy and TOTL Tech Ltd. Privacy Policy”.

CHAPTER B: TOTL Tech Ltd. APPS PRIVACY POLICY

This TOTL Tech Ltd. Privacy Policy is designated to provide you with guidance regarding our privacy practices and principles with respect to collecting, using and disclosing personal information regarding Users of our TOTL Tech Ltd. Apps and Users who indicate at an age gate in our Children Apps that they are above the age of 16. For the purposes of Chapter B, the term “TOTL Tech Ltd. Apps” will include the age-gated section of Apps accessible only to Users indicating they are above the age of 16.

6. Which information may be processed from Users of our TOTL Tech Ltd. Apps?

There are two types of information which may be processed about Users of our TOTL Tech Ltd. Apps:

6.1 Non-personal Information:

Non-identifiable and anonymous information (“Non-personal Information”).may be collected, stored and/or processed by us and/or third party providers of certain products and services, such as ad networks, analytics, etc. (“Third Party(ies)”). We and our Third Parties do not know the identity of the User from whom Non-personal Information has been collected. Non-personal Information is any information which is available to us and/or our Third Parties through use by Users of the TOTL Tech Ltd. Apps. For details of the categories of data constituting Non-personal Information please refer to Section 3.1 above. Some jurisdictions consider this information to be personal information. Game Center Features: If a User enables Game Center Features in TOTL Tech Ltd. Apps, then we will be provided with access to the identifier number of the User’s Game Center account (i.e. access token).

In addition, we may collect and/or process, directly or through Third Parties, the following Personal Information:

We note that we may collect, use and provide access to the User’s advertising identifier in accordance with the applicable Platform Provider’s rules, policies and guidelines.

In addition, Third Parties may track and collect information regarding your on-line activities over time and across different online platforms (such as websites, applications, etc.).

To clarify, any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.

We do not collect or process any financial or payment information, any government identification numbers, any non-public phonebook or contact information, any microphone and camera sensor data, or any sensitive device data concerning Users.

7. How is the Information about Our Users collected?

7.1 Non-personal Information may be collected through your use of the TOTL Tech Ltd. Apps.

In other words, when you are using a TOTL Tech Ltd. App, we and our Third Parties are aware of it and may gather information relating to such usage, through the TOTL Tech Ltd. Apps, APIs or SDKs embedded in our TOTL Tech Ltd. Apps. In addition, local Non-personal Information may also be stored on your device via generally accepted industry technologies used within the TOTL Tech Ltd. Apps, such as “cookies” and local storage

7.2 Personal Information which you provide us directly and/or through Third Parties via your installation and/or use of the TOTL Tech Ltd. Apps or your behavior to ads inside such Apps.

This information is collected via the TOTL Tech Ltd. Apps or such Third Parties’ APIs or SDKs embedded in our TOTL Tech Ltd. Apps. In addition, local Personal Information may also be stored on your device via generally accepted industry technologies used within the TOTL Tech Ltd. Apps, such as “cookies” and local storage.

8. What are the Purposes of the Collection of Information?

Non-personal Information is collected in order to:

• Use it for statistical, analytical and research or business intelligence purposes (e.g., to track trends within our TOTL Tech Ltd. Apps, for reports and for public relations purposes); and for customization, development and improvement of our TOTL Tech Ltd. Apps (for example, analyzing and fixing of problems, frequency capping (limiting the number of times a specific advertisement is presented to the same mobile device), developing new offerings, providing better content, simplifying and improving the User experience including based on behavior and preferences shown by Users usage within the TOTL Tech Ltd. Apps).

• Measure traffic and usage on the TOTL Tech Ltd. Apps.

• Promote our Apps.

Personal Information is collected in order to:

• Personalize and enhance the Users’ experience while using the TOTL Tech Ltd. Apps.

• Improve the TOTL Tech Ltd. Apps.

• Provide the Users with personalized content and information, including customized ads, interest-based ads, targeted ads, etc.

• Enable certain ad serving features, such as frequency capping etc.

• Enable certain functionalities available within the Apps, such as the Game Center Features, Social Features and the features which are available while using the “Log in with Facebook” feature.

• Provide Users with updated information regarding our products and services, including about competitions which we may hold.

• To allow Users to participate in contests or other online game events and to publicly display achievements or statistical data (such as scores, rankings and achievements) that is generated through such User’s participation.

• Authentication purposes include to verify clicks and/or installs, verify User’s identity for the purpose of dealing with inappropriate interactions of Users and/or fraudulent use of our Apps.

• Measure reach and effectiveness of ad campaigns, to offer targeted ads, to personalize experience by showing ads for products and services that are more likely to appeal to the User (i.e. behavioral ads).

Any other purpose explained at the time of collection.

9. Sharing Information with other third parties

In addition to the sharing of Personal Information with Third Parties described above, we may share Personal Information in the following cases:

• to satisfy any applicable law, regulation, legal process, subpoena or governmental request;

• to enforce this Privacy Policy and/or the TOS and other of our terms or policies, including investigation of potential violations of such policies;

• to detect, prevent, or otherwise address fraud, security or technical issues;

• to respond to claims that any content published on the TOTL Tech Ltd. Apps violates any right of a third-party;

• to protect the rights, property or personal safety of the Company, its Users, suppliers, licensors, licensees or the general public;

• when the Company undergoes any change of control, including by means of merger, acquisition or purchase of all or substantially all of the assets of Company, in which case your Personal Information may also be disclosed, transferred and/or assigned;

• pursuant to your explicit approval prior to the disclosure;

• as part of a competition, receiving rewards or otherwise interacting with our social media channels.

For clarification, we may transfer and disclose Non-personal Information to third parties at our discretion.

Please note that some of the TOTL Tech Ltd. Apps include a sharing feature which allows Users to share their User Generated Content with others. User Generated Content may include Personal Information. We do not access or use this User Generated Content in any way. It is stored locally on your device. YOU ACKNOWLEDGE AND AGREE THAT YOU ARE SOLELY RESPONSIBLE FOR SHARING YOUR PERSONAL INFORMATION WITH OTHERS AND THAT YOU ARE DOING SO AT YOUR OWN RISK.

10. Advertisements

We accept ads in various formats (such as banners, interstitial, rewarded videos, etc.) from Third Party ad networks which may be displayed in our TOTL Tech Ltd. Apps. These Third Party ad networks may collect and use: (i) information about your visits to TOTL Tech Ltd. Apps in connection with such marketing, sales and advertising activities; and (ii) geographic tracking and carrier network preferences; (iii) information, such as age, gender and other information logged from your device to ensure that appropriate advertising is presented within the App, to calculate or control the number of views of an ad, to deliver ads relating to User’s interests and to measure the effectiveness of ad campaigns. The delivery of ads to you may be based on IP address, device identifiers and other Personal Information gathered during your use of the TOTL Tech Ltd. Apps. You may also be presented with contextual or non-targeted ads, i.e. ads which are not directed towards specific Users but are rather broadly posted onto random Apps. If you chose to receive contextual or non-targeted ads only within our Apps, please be aware that you may still see some targeted ads served by third parties if you have separately (e.g. on that third party’s website or app) agreed to personalized advertising directly to those third parties. You can find the list of Third Parties Ad Networks providing services in relation to TOTL Tech Ltd. Apps at: Note that if you click on any of these ads, the advertisers may use cookies and other tracking technologies (such as tracking pixel agent or visitor identification technology, etc.) on your device to collect data regarding ad performance, your interaction with such ads and our TOTL Tech Ltd. Apps and your interests (which may include, non-personal and/or personal information such as, device and network information, unique identifiers, gender, age and geo-location about you) in order to serve you ads, including targeted ads, and for the legitimate business interests of such Third Parties ad networks. We recommend that you review the terms of use and privacy policy of any third party advertisers with whom you are interacting before doing so. Their privacy policy, not ours, will apply to any of those interactions.

We may promote TOTL Tech Ltd. Apps in Third Parties applications and platforms. In addition, we may, at our discretion, advertise our other Apps within the TOTL Tech Ltd. Apps. Such advertisements are not directed towards specific Users but are rather broadly posted onto random Apps.

11. Using Game Center Features and Social Features

Our TOTL Tech Ltd. Apps may enable using certain Game Center Features and may include Social Features. The Game Center Features and the Social Features are operated or allow for social integration with certain third party social networks or third party platforms (“Social Network” or “Platform”) .

The Game Center Features and Social Networks and Platforms are created and maintained by third parties who are not affiliated with and/or controlled by us. If you enable this integration, your use of the Game Center Features and/or the Social Features is subject to the terms of use and privacy policies of the applicable third party provider of the Social Network’s or Platform (for example, Apple Game Center which terms are available at:

http://www.apple.com/legal/internet-services/itunes/gamecenter/us/terms.html;

Google Play Games which terms are available at:

https://play.google.com/store/apps/details?id=com.google.android.play.games

You should ensure that you read their terms of use and privacy policies to understand how they treat your information and to understand the methods for changing the privacy or sharing settings on such services. If you do not agree to the practices described in such terms you should not allow our TOTL Tech Ltd. Apps to interact with such Social Networks or Platforms, however you may find that you are not able to enjoy all the features that may be made available by our TOTL Tech Ltd. Apps. You understand that where you allow interaction with any third party Social Network or Platform, we may share data about you with your contacts (and vice versa) in order that you may enjoy social elements. This data may include your scores and/or progress in our TOTL Tech Ltd. Apps, your name, your social media profile picture and any test that you may upload.

By using the Social Features and/or the Game Center Features you hereby agree and understand that the applicable Social Networks or Platforms may collect certain Personal Information, such as your IP address, Non-personal Information and may set cookies and/or other tracking technologies to enable the functionality of the Social Features and/or the Game Center Features. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the third party that provides the Social Features and/or the Game Center Features. You hereby understand and agree that when you share content via Social Networks or Platforms your content may become public and any person may re-post-it.

12. Additional Terms and Conditions

See further terms and conditions which also apply to Users of the TOTL Tech Ltd. Apps in Chapter C below: “Terms and Conditions Common to both Children Privacy Policy and TOTL Tech Ltd.Apps Privacy Policy”.

CHAPTER C: TERMS AND CONDITIONS COMMON TO BOTH CHILDREN PRIVACY POLICY AND TOTL Tech Ltd. APPS PRIVACY POLICY

13. Third Party Providers

When you use the Apps Third Parties may collect, store and/or process the information detailed in this Privacy Policy. You may find the list of Third Parties Ad Networks These Third Parties are carefully selected to ensure that they, and their related entities who may access Your information, provide Your information with equal protection to that stated in this Privacy Policy and required by applicable privacy laws and the Platform Providers’ rules, policies and guidelines. We use commercially reasonable efforts to engage with Third Parties that post a privacy policy governing their collection, retention, processing and use of non-personal and personal information. For further information regarding the collection, processing and usage of your information by the Third Parties, please review their privacy policy practices.

14. The User’s compliance with Certain Additional Terms and Conditions

A User’s access to and use of the Apps (including use of Promotional Codes defined in TOS) may be subject to certain third party terms and conditions and privacy policies, including but not limited to those of application stores, mobile software platforms, Third Parties and payment providers. We do not exercise control of such third parties and are not responsible for their privacy practices and their use of the Users’ personal information. You should review the privacy policies of these third parties to learn how they may collect and use your Personal Information.

15. Links to third party sites

Certain links provided in the Apps through ads or otherwise permit Users to leave our Apps and enter third party sites, products or services. These linked sites, products and services are not under our control . Most of such linked sites, products and services provide legal documents, including terms of use and privacy policies, governing the use of these sites. It is always advisable to read such documents carefully before using those sites and services so that you know what kind of information they are collecting.

16. Cookies & Local Storage

When you access or use the Apps, we and/or our Third Parties may use industry-wide technologies such as “cookies”, web beacons, tags and local storage (or other similar technologies), which store certain local information on your device(“Local Storage”) , to identify a User’s device and ‘remember’ things about the User which may enable automatic activation of certain features (for example, if a User muted the sound within the App at a certain stage, this preference will be stored in the cache on the device and maintained the next time the User accesses the App on his device), monitoring of use of the Apps (counting Users who visit certain pages, use certain tools, viewed certain advertisements), frequency capping (for example, if we promote another App, this ensures that we do not advertise the same App more than a set number of times), to improve the quality of our services, measure ad performance, provide relevant ads etc. and making the User’s App experience and usage simpler, more relevant, convenient and effortless. Such information is locally stored in the User’s device. We and/or our Third Parties may access such information. Third Parties may use both session cookies (which expire once you close the App) and persistent cookies (which stay on the User’s device until he/she deletes them). Such Local Storage used by the Apps may store non-personal information (such as the different pages viewed by a User within the App) as well as User persistent identifier and geo-location data, which will be collected in accordance with the terms specified herein. It is easy to prohibit and/or delete the Local Storage, including via uninstalling the App from your mobile device and/or through the Settings option of your device. Most browsers and platforms will allow you to erase cookies from a device, block acceptance of cookies, or receive a warning before a cookie is stored. In order to erase or disable the Local Storage option you may use the settings option of your device or according to the specific instructions provided by the technology provider and/or Third Parties privacy policies and terms of use. However, if you block or erase cookies, or change the settings of your device, your App experience may be affected and may be limited.

17. “Do Not Track” and Opt-out of Certain Third Parties’ Interest-Based Services

A User may prevent or limit targeted advertising from device settings which may vary from device to device. For example, if you are using an iOS device with iOS 7 or a newer version, this can be done from settings/privacy/advertising by resetting advertising identifiers or limiting ad tracking settings. If you are using a Google Android device with Android 2.3 or a later version, you can find the ad identifier settings in the app drawer under Google Settings> Ads. Please note that activation of any applicable “Do-not-track” settings on the User’s mobile device or any other device-level setting opt outs for targeted advertising, (to the extent such options exist) may not cease all tracking activities by our Third Parties’ service providers.

If you would like to cease the tracking by third parties of your on-line activities over time and across different online platforms (such as, websites, applications, etc.) and opt out of the use of your information for interest-based and targeted advertising and/or other services by certain of our third party service providers, please visit the privacy practices of such Third Parties and follow the instructions specified therein. You can see a list of our Third Parties Ad Networks with instructions on how to opt-out when available.

Note that electing to opt-out will not stop advertising from appearing in your browser or applications, but may make the ads you see less relevant to your interests, and the companies you select may still collect information for other purposes, such as research, analytics, and internal operations. In addition, note that if you use a different browser or erase cookies from your browser, or use a different mobile device, you may need to renew your opt-out choice.

18. International Data Transfer

We may transfer (and store) information collected about you, including Personal Information, to affiliated entities, or to other third party service providers across borders and from your country or jurisdiction to other countries or jurisdictions around the world (all solely for legitimate business purposes). Please note that we may transfer such information to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, wherever your Personal Information is transferred.

We will take reasonable steps to ensure the protection of your Personal Information (such as making transfers subject to standard contractual terms or engaging with host providers which are privacy-shield certified or offer an equivalent level of protection). Where we receive requests for information from law enforcement or regulators, we will carefully validate these requests before Personal Information is disclosed. You can ask for more details of the steps we take by contacting us as set out in the “Got Any Questions” section below. We will centralize all privacy-related decisions in (and the Personal Information may be accessed from) countries that are declared as offering an adequate level of protection of personal data by the European Commission.

19. California Privacy Rights

19.1 To the extent applicable, if you are a California resident under the age of 18 and a User, California Business and Professions Code Section 22581 may permit you to remove content or Personal Information you have publicly posted. If you wish to remove such content or Personal Information and you specify which content or Personal Information you wish to be removed, we will do so in accordance with applicable law.

Please be aware that after removal you will not be able to restore removed content. In addition, such removal does not ensure complete or comprehensive removal of the content or Personal Information you have posted and that there may be circumstances in which the law does not require us to enable removal of content. 19.2 This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and applies only to “personal information” that is subject to the 0 CCPA.