Effective as of: March 15, 2025

This privacy policy (“Privacy Policy”) explains how information about you is collected, used and disclosed by Singapore Just Game Technology Pte. Ltd. and its affiliates (“Company”, “we”, “our” or “us”). This Privacy Policy applies to information we collect when you use our websites  https://www.lojofficial.com/(the “Site”), mobile applications and other online products and services (collectively, our “Services”).

By downloading, accessing, using and/or interacting with our Services, you agree and expressly consent to our collection, use and disclosure of the information that you provide as described in this Privacy Policy. This Privacy Policy is incorporated by reference into the Terms of Service available at https://sdkinit.rebxgame.com/protocol?language=1&typeFlag=2&appId=10185(our “Terms of Service”) and is subject to the provisions of the Terms of Service. Capitalized terms used but not defined in this Privacy Policy shall have the meaning ascribed to such terms in our Terms of Service. If you have any concerns about providing information to us or the use of that information as described in this Privacy Policy you should not use our Services.

Modifications

Because we are always looking for new and innovative ways to help you achieve your goals in connection with the use of our Services, this Privacy Policy may change over time. The effective date at the top indicates the last time this Privacy Policy was modified. You acknowledge and agree to check the updated terms of this Privacy Policy regularly. You can see when this policy was last updated by checking the “last updated” date displayed at the top of this policy. Any revised Privacy Policy will supersede all previous privacy policies. If you have any questions about the updated terms of this Private Policy, please contact us by emailing us at LandsOfJail@iyagames.com or submit feedback within the Software Product by navigating to the “Settings” and clicking “Customer Support”.  

Table of Contents

1.      How We Collect Information

2.      Information We Collect That You Choose To Provide To Us

3.      What Information We Collect Automatically When You Use Our Services

4.      Information Provided to Us by Third Parties

5.      How We Use Your Information

6.      What Kinds of Information We Share

7.      Ways You Might Share Your Information through Our Services

8.      How We Keep Your Information Safe

9.      Where We Store Your Information

10.  Our Policies Regarding Children

11.  Your Choices and Controls

12.  How We Respond to Do Not Track Signals

13.  Contact Us

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1.      How We Collect Information

We collect information: (i) that you choose to provide to us; and (ii) automatically through your use of our Services.

2.      Information We Collect That You Choose To Provide To Us

We collect information that you choose to provide to us, for example, when you create an account, manage your user profile, request our e-newsletter or other marketing communications, participate in any interactive features of the Services, participate in a promotion or survey, request customer support or otherwise communicate with us. You may share your personal information with us in the following ways:

Identifiers and User-Generated Profiles and Content. You may share personal information when you create an account with us and as you use and communicate through our Services, including your name, username, date of birth, gender, telephone number, email address, photograph, pictures, personal files, avatar, password, social media account, chat record, forum posts and comments. When sharing your personal information with others, always remember that users with whom you communicate or share such information may store or reshare your information with other third parties on and off our Services.

Customer Support and Other Communications. When you contact us for customer support or otherwise communicate with us, you may provide us with information related to your use of our Services, including copies of your messages, any contact or identifying information, or any other information you deem helpful.

3.      What Information We Collect Automatically When You Use Our Services

We automatically collect information about you including:

Device Information. We collect device-specific information when you access our Services from a computer, mobile, and/or other device, including your hardware model, operating system and version, unique device identifiers, mobile network information, country of access, crash reports, request and referral URL’s and system activity details.

Software Information. We collect software-specific information about your use of our Services, such as which version of our software and what updates you have installed or use, and the presence of required plug ins.

Use Information. We collect information about your use of our Services, including the language you prefer, access times, user activity, interactions with other users and your internet protocol (IP) address.

Transaction Information. When you purchase virtual currency or virtual items in our Services, we may collect and process your purchase and transaction record in the Services, including transaction details (such as transaction time, purchase price, product purchased, currency, order ID) and transaction records (such as player user account, country, email, phone number and purchase history). For the avoidance of doubt, all purchases are processed by payment processing companies. We do not process any payment nor do we have any access to your credit card information or billing information.

4.      Information Provided to Us by Third Parties

In addition to the information that we collect directly from you, we also collect certain of your information from following third party sources.

Apple App Store. Our Services that are distributed through the Apple App Store may also request permission to automatically collect other information from your mobile or other device. The Apple App Store may collect information regarding customer activity on the Apple App Store and aggregate that information to understand which part of Apple’s services are of most interest to you. More information on Apple’s privacy policy can be found here. Our Services may only collect such information with your authorization in accordance with your device operating system’s permission process.

Google Play. Our Services that are distributed through Google Play may also request permission to automatically collect other information from your mobile or other device. Google Play may collect device-specific information to help the user decide on which devices the user would like purchases to be available for use. In mobile applications, Google Play may use identifiers specific to your device to serve you more relevant advertisements.  More information on Google’s privacy policy can be found here. Our Services may only collect such information with your authorization in accordance with your device operating system’s permission process.

Mobile Platforms. If you play or purchase our Services on your mobile device and/or tablet, we receive information about you from the app stores and other mobile platform providers. This information includes your username and/or device ID and the fact that you made a purchase, for instance, but does not include any sensitive or financial information. Some of our mobile platforms also may send information to us that you authorize them to provide. Our mobile products also may request additional personal information from you, such as push notification tokens, your precise location or contact list, and we will collect this information only if you give us your explicit consent.

Third Party Account Registration Services. You may log in to our products or Services through a third party service. In the event you log in to our product or Services through a third party service, after your authorization, we will collect personal information provided to us by the third party. We have identified the names of some third party services that allow you to register for and log in to our products or Services. Please see the links below to learn more about the personal information practices of such services and the personal information collected from the associated third party.

Third Party Services and User Information. We may allow third parties to serve advertisements in connection with our Services, to provide analytics services and provide you with other services, such as social media, rewards programs and promotions. These third parties may use cookies, web beacons, Flash Cookies, your account information (that you provide to such third parties) and other technologies to collect information about you on our Services and other websites and online services, such as your account information, mobile carrier information, your internet protocol addresses, software information, use information, clipboard information, identifiers associated with your mobile device or applications on the device, the browsers you use to visit our Services, pages viewed, time spent on pages, links clicked and conversion information. Some of such third party analytics and advertising services may offer you a choice to opt-out of the collection and/or sharing of this information. Links to the opt-out mechanisms for the third parties that offer such a choice can be found in the following section. This Privacy Policy does not apply to and we are not responsible for, third party cookies, web beacons, Flash Cookies or other tracking technologies. In addition, we may also receive information about you when other users choose to share their contact lists with us. For example, if you create or log into your account through a social media site, we might have access to certain information from that site, such as your name, account information, profile picture, phone number, email address, gender, date of birth and friends lists, in accordance with the authorization procedures determined by such social media site.

We have identified the provider names of some of the third-party analytics and advertising services we use. Please see the links below to learn more about the data practices of our third-party service providers (including opt-out mechanisms they may offer):

-          Firebase: https://policies.google.com/privacy

-          AppsFlyer: https://www.appsflyer.com/privacy-policy/

-          AppLovin: https://www.applovin.com/privacy/

-          Thinking Data: https://docs.thinkingdata.cn/ta-manual/latest/ja/installation/installation/privacy.html

-          Unity: https://unity.com/cn/legal/privacy-policy

-          Facebook: https://www.facebook.com/policy.php

-          Google: https://policies.google.com/privacy/embedded?hl=en-US

5.      How We Use Your Information

Under data protection law, we can only use your Personal Data if we have a proper reason for doing so, e.g.:

Ÿ   To comply with our legal and regulatory obligations;

Ÿ   For the performance of our contract with you or to take steps at your request before entering into a contract;

Ÿ   For our legitimate interests or those of a third party; or

Ÿ   Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your Personal Data, so long as this is not overridden by your own rights and interests.

We may use information about you for various purposes, including to:

-          Provide, maintain and improve our Services;

-          Provide and deliver the products and/or services you order and send you related information, including confirmations and invoices;

-          Send you communications about products, services, offers, promotions, rewards or events offered by us and other companies and provide news and information we think will be of interest to you;

-          Send you technical notices, updates, security alerts and support and administrative messages;

-          Respond to your comments, questions and requests and provide customer service;

-          Monitor and analyze trends, usage and activities in connection with our Services;

-          Personalize and improve our Services and provide advertisements, content and suggest connections or features that match user profiles or activities;

-          Link or combine with information we receive from others to help understand your needs and provide you with better service; and

-          Preventing and detecting fraud against you for our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you.

We retain your data only for as long as necessary to provide the Services you have requested and thereafter for a variety of legitimate legal or business purposes. These might include retention periods: (i) mandated by law, contract or similar obligations applicable to our business operations; (ii) for preserving, resolving, defending or enforcing our legal/contractual rights; or (iii) needed to maintain adequate and accurate business and financial records.

6.      What Kinds of Information We Share

In certain circumstances, we may share (i.e., share, release, disclose, disseminate, make available, transfer, or otherwise communicate) personal information with others for our operational and business purposes. We will only share your personal information for legal, legitimate, necessary, specific and clear purposes, and will only share the personal information necessary to provide the Services. At the same time, we will enter into agreements with third party recipient where necessary and require them to process your personal information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures. Except as described in this Privacy Policy, we will not share your personal information with any other third parties. In particular, we may share personal information with:

-          Our affiliates, who are subject to the processing scope and purpose of this Privacy Policy;

-          Our vendors, consultants and other service providers who need access to such information to carry out work on our behalf, based on our instructions and in compliance with our Privacy Policy and other appropriate confidentiality and security measures; if you refuse to allow our service providers to collect the personal information necessary for providing specific services, you may not be able to use such service in our platform. Our service providers are not authorized to use your personal information for any other purpose;

-          Platforms, such as Apple and Google, to assist in reviewing the user’s app refund requests (for example, your transaction information, such as order numbers, consumption status, delivery status, user communication, purchase amount, and refund amount);

-          Our third party advertisers, who we partner with to display advertising on our website or to manage, serve our advertising on other sites, or for our marketing purposes.

-          Other users of our Services in connection with the social features of our Services (for example, your username, profile picture and the virtual content, such as virtual currency or virtual items, you have accumulated in our Services that may be visible to other users of our Services, or information that you provide in your account registration for forum use and your forum comments may be visible to other forum users);

-          Any competent law enforcement body, regulatory body, government agency, court or any other third party where we believe disclosure is necessary as a matter of applicable law or regulation, to exercise, establish, or defend our legal rights, to protect your vital interests or those of any other person, or in response to lawful requests by public authorities or as otherwise required by law.

In case of a merger, acquisition, bankruptcy, or liquidation of our Company where the transfer of personal information may be involved, we will require new companies and/or organizations that come into possession of your personal information to continue to be bound by this Privacy Policy. If the new company or organization wishes to change its practices with respect to the collection and processing of your personal information and as outlined in this Privacy Policy, such new company or organization will ask for your consent before doing so.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. When we provide this information, we perform appropriate procedures so that the information does not identify you and we contractually prohibit recipients of the data from re-identifying this information to associate the information with you. If your account is canceled or terminated pursuant to the Terms of Service, we will delete or anonymize your Personal Data.

7.      Ways You Might Share Your Information through Our Services

Social Sharing Features. Our Services may offer social sharing features and other integrated tools, which let you share actions you take on our Services with other media, such as Facebook, Line, X, or Naver. The use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide such features.

8.      How We Keep Your Information Safe

We take commercially reasonable security measures to help protect information we collect about you from loss, theft, misuse, unauthorized access, disclosure, alteration and destruction. Unfortunately, however, no security system is 100% secure, and we cannot guarantee that the information we collect from you will be free from unauthorized access by third parties. Unauthorized entry or use, hardware or software failure and other factors may compromise the security of user information. Your password is an important component of our security system, and as a result it is your responsibility to protect your password. Do not share your password with any third parties. If your password has been compromised for any reason, you should change your password immediately.

9.      Where and How We Store Your Information

We store information about users on servers primarily located in Singapore. If you are accessing our Services from outside of Singapore, please know the data and personal information you submit may be transferred to and stored on servers in Singapore. The data protection and other laws of Singapore and/or other countries might not be as comprehensive as those in your country. By submitting your data and/or using our Services, you acknowledge that your data might be transferred, stored and processed in and to Singapore and other countries where we may choose to store data. In addition, where we transfer to your information to any of the third parties, we also take appropriate steps to ensure that we have implemented appropriate safeguards to ensure that such protection is maintained and is not undermined as a result of that disclosure.

10.  Our Policies Regarding Children

As set out in our Terms of Service (available at https://sdkinit.iyagame.com/protocol?language=1&typeFlag=1&appId=10185), you must be at least 13 years old (or such other minimum age as is applicable in your country of residence) to use the Services. If you are between the relevant minimum age and 18 years old (or the age of majority where you live), you must obtain the consent of your parent or legal guardian to use the Services. Our Services are not intended for children under the age of thirteen (13) or the minimum age in the relevant territory if that age is older than thirteen (13) (the “Child” or “Children”), and we do not knowingly collect any personal information from such Children. Children should not use or attempt to use our Services, and if you are a Child, please do not attempt to use our Services or send any information about yourself to the Company.

In the event that we learn that we have inadvertently gathered personal information from a Child, we will take reasonable measures to delete such information from our records. Parents who believe that we might have gathered any information from or about a Child may submit a request to delete such information to LandsOfJail@iyagames.com, or submitting feedback within the game by navigating to the “Settings” and clicking “Customer Support”, or write to our address listed in Section REF _Ref490151425 \r \h \* MERGEFORMAT 13 (Contact Us) below.

11.  Your Choices and Controls

We give you meaningful choices when it comes to important uses and collection of your information. To access, view, update, correct, delete or port your personal data, or to update your subscription preferences, you may exercise your personal information rights by emailing us at LandsOfJail@iyagames.com or submitting feedback within the game by navigating to the “Settings” and clicking “Customer Support”. We will send you confirmation of our receipt of any verifiable request within ten (10) business days of its receipt.  We endeavor to substantively respond to any verifiable request within one (1) month of its receipt. If we require more time, we will inform you of the reason and extension period required in writing.

Where we rely on consent to collect and use information about you, you can withdraw your consent at any time. If you make a request to delete your personal data and that data is necessary for the products or services you have purchased, the request will be honored only to the extent it is no longer necessary for any Services purchased or required for our legitimate business purposes or legal or contractual record keeping requirements.

Push Notifications. We may send push notifications or “alerts” to your device to provide information regarding our Services, service updates, promotional communications and other related messages. You can deactivate push notifications by changing your notification settings via your device.

Promotional Communications. You may opt-out of receiving promotional messages from us by following the instructions in those messages or by contacting us at LandsOfJail@iyagames.com or submitting feedback within the game by navigating to the “Settings” and clicking “Customer Support”. If you opt out, we may still send you administrative, transactional, or relationship messages, such as those about your account or our ongoing business relations including but not limited to administrative confirmations, order confirmations, important updates regarding our Services and notices regarding this Privacy Policy and our Terms of Service.

12.  How We Respond to Do Not Track Signals

Because consumers are often unaware that their do not track beacons are active, do not track frequently does not reflect the actual preferences of our users. We currently do not respond to Do Not Track signals. In the meantime, you may opt out of certain types of tracking, including certain analytics and tailored advertising by changing your cookie settings.  

13.  Contact Us

If you have any questions about this Privacy Policy or any other matter, please contact us via the methods outlined below.

Please email us at LandsOfJail@iyagames.com. You may also submit feedback within the application by navigating to the “Settings” and clicking “Customer Support”.