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Privacy Policy

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Last Updated: May 27, 2026

This privacy policy ("Privacy Policy") describes the ways DRAGON RISING

PTE. LTD. (hereinafter "DRAGON RISING"，"we", "us" or "our") collect,

manage, store, use, and protect the information, including personal

information, and data that you provide or we collect in connection with any

DRAGON RISING’s game, website or application ("Service"). By using our

Service, you agree to the collection and use of your personal information

as outlined in this Privacy Policy.

We pay great attention on protecting your privacy and safeguarding your

personal information. We understand how crucial your personal information

is to you and are committed to handling it with care and transparency. Your

personal data will be held by us in accordance with applicable data

protection laws. For the purposes of data protection laws, the data

controller will be DRAGON RISING.

If you are aged under 18 you must not use the app as it is not designed for

you. We do not intend to collect the personal data of anyone under 18. If

you are aware that any personal data of anyone under 18 has been shared

with the app, please let us know so that we can delete that data.

DRAGON RISING reserves the right to amend, modify or revise the Privacy

Policy at any time and you agree to check periodically for new terms.

Please note that your continued use of the DRAGON RISING’s Services shall

constitute your acceptance to be bound by the newly updated Privacy Policy.

1. Categories of information we collect

1) Data We Collect (either directly from users or through a third party) :

Account Data: During the process of creating your account, we may gather

personal information, including your name, email address, phone number,

birth day, as well as any additional details you share with us or that

we obtain through other means.

Game Data: While you play games, participate in discussion boards or

social media features, or report issues on our websites or mobile apps,

we collect information about your in-game behaviors and interactions.

Payment Data: If you choose to make purchase(s) with your Account, we

might be required to gather your payment information to facilitate the

processing of your transaction(s) and associated activities. This

information could encompass your name, bank account or debit/credit card

number, card expiry date, and contact information like your billing and

shipping address.

Browsing and Interaction Information: We track your visit details,

including the complete URL clickstream (to, through, and from our

websites and apps), services viewed or searched for, page response

times, download errors, length of page visits, interaction methods

(e.g., scrolling, clicks, and mouse-overs), and methods used to navigate

away. Additionally, we record any phone numbers used to contact our

customer service team.

Demographic, Location, and Device Information: This includes demographic

and location data, along with device-specific details like your IP

address, device UDID, IDFA, IDFV, Android ID, software, applications,

hardware specifications, browser information, internet usage patterns,

and in-game activity data.

Technical Information for Security and Verification: To ensure account

security and verify account activity, we collect technical data such as

your IP address, log-in details, access time and date, time zone,

visited web pages, software crash reports, browser type and version,

browser plug-ins, and operating system and platform.

We may also employ third party ad-serving and/or analytics technologies

that may use various methods to collect information through our software

and the Service. These technologies may be embedded within our software and

the Service and may collect, amongst other things, the above information.

Depending on the type of personal data in question and the grounds on which

we may be processing it, should you decline to provide us with such data,

we may not be able to fulfil our contractual requirements or, in extreme

cases, may not be able to continue with our relationship. We will inform

you if your failure to provide any requested personal information is going

to result in these consequences.

2) When We Collect Your Data:

We collect personal data about you in the following situations during your

use of DRAGON RISING’s services:

When you use our game applications.
When you create or manage a user account.
When you connect your user account to Facebook.
When you participate in interactive features of the Service.
When you communicate with us or interact through the Service.

Please note that when you use our services , we won’t collect your legally-

sensitive data (i.e. race, ethnicity, religious or philosophical beliefs,

trade union membership, genetics, biometrics, health, sexuality and/or

criminality) and other sensitive data (i.e. child data, social security

numbers, bank account or payment card details)

2. How We Use Your Personal Data

We use your personal data for a variety of business purposes, including:

1) To notify you about changes to our products and services and, with your

consent, to directly market them to you.

2) To send you relevant communications, such as confirmations, invoices,

updates, security alerts, and administrative messages.

3) To inform you about promotions, rewards, upcoming events, and other news

related to our products and services.

4) To administer and improve our websites, products, and services,

including troubleshooting, data analysis, testing, research, statistical

analysis, and survey purposes.

5) To allow you to participate in interactive features of our products and

services (including casino products) and ensure their technical

functionality and security.

6) To fulfill our contractual obligations to you, including setting up,

managing, and administering your account (e.g., for identity

verification, anti-money laundering, prevention of terrorist financing,

self-exclusion requests, and processing bets and payments).

7) To measure and understand the effectiveness of our advertising and

marketing efforts.

8) To identify and analyze user behavior, preferences, and credit risk (if

applicable).

9) To ensure compliance with licensing and regulatory requirements and

support anti-money laundering, prevention of terrorist financing, and

disaster recovery efforts.

10) To handle payment and collection processes.

11) For customer service improvements, audits, and market research.

12) For other purposes with your consent.

3. Direct Marketing

We may use your personal data to send you updates by email or by Facebook

Messenger or iMessage about our services, including exclusive offers,

promotions or new services.

This marketing may relate to:

1) products and services we (or permitted third parties) feel may interest

you;

2) information about other goods and services we offer that are similar to

those that you have already used or enquired about;

3) upcoming events, promotions and new products/services or other

opportunities as well as those of selected third parties; and

4) information regarding any applicable loyalty programs (including points

earned and free, bonus and promotional points).

If you no longer wish to receive marketing communications when using our

apps, you may: contact us at support@dragonrisinggames.com for direct

marketing opt-out; or using the "unsubscribe" link in emails, or let us

know you intent to opt-out in our phone calls to you.

4. How We Disclose Personal Data

We may disclose your personal data with third parties or permit third

parties to collect this information from our services for a variety of

business purposes, including to provide the Services, to protect us or

others, or in the event of a major business transaction such as a merger,

sale, or asset transfer, as described below.

1) Service Providers and Business Partners

We may share your personal data with third-party service providers and

business partners who process data on our behalf and under our instructions

for purposes such as hosting, cloud services, data storage, analytics,

customer support, fraud prevention, security monitoring, payment

processing, and marketing support. These third parties are contractually

required to protect your personal data and to use it solely for the

purposes specified by us.

2) Payment Providers

When you make purchases through our Services, your payment is processed by

third-party payment providers or app marketplace operators (such as Apple,

Google, or other authorized payment processors). We may receive limited

transaction-related information from such providers (for example,

transaction status, partial or hashed identifiers, or invoice-related

contact details), but we do not receive or store your full payment card or

bank account information.

3) Third-Party Platforms and Social Networks

If you choose to connect your account or interact with our Services through

a third-party platform (such as Facebook, Google Play, or Apple Game

Center), we may share or receive certain information in accordance with

your settings on those platforms and their privacy policies. Your

interactions with such third-party services are governed by their own terms

and privacy practices.

4) Affiliates

We may share your personal data with our affiliates for purposes consistent

with this Privacy Policy, including account management, customer support,

analytics, and operational efficiency. All affiliates are required to

handle your personal data in accordance with applicable data protection

laws and this Privacy Policy.

5) Legal and Regulatory Requirements

We may disclose your personal data if required to do so by law, regulation,

court order, or other legal process, or if we reasonably believe that such

disclosure is necessary to comply with legal obligations, protect our

rights or property, investigate fraud or security issues, or protect the

safety of our users or others.

6) Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets,

financing, or similar corporate transaction, your personal data may be

transferred to a successor or affiliated entity as part of that

transaction, subject to applicable data protection laws. We will take

reasonable steps to ensure that your personal data remains protected and

used in accordance with this Privacy Policy.

7) With Your Consent or at Your Direction

We may share your personal data with third parties when you have given your

explicit consent or when you otherwise direct us to do so.

5. Cookies and Similar Technologies

We may use cookies and/or similar technologies, to store users’

preferences, and collect aggregated demographic data. Cookies allow the

website to identify and interact with your computer (for example so we can

remember your login details if you have opted to ‘stay signed in’). We do

not use cookies to retrieve information that was not originally sent by us

to you in a cookie.

You can set your browser to accept or reject all cookies, or notify you

when a cookie is sent. If you reject cookies or delete our cookies, you may

still use our websites, but you may have reduced functionality and access

to certain areas of our websites or your account. You may disable or accept

cookies at any time by changing your web browser’s options.

In addition to the express notice provided on our website when you first

visit, your continued use of our website is your acceptance of our

continued use of cookies on our website.

6. Personalized Advertising

We may work with third-party advertising partners, ad networks, analytics

providers, and other service providers to display advertisements in our

Service, measure ad performance, prevent fraud, and improve our Service and

advertising activities. These partners may use cookies, SDKs, device

identifiers, pixels, local storage, and similar technologies to collect or

receive information from your device and interactions with our Service.

The information collected or shared for these purposes may include

identifiers such as advertising IDs, IP address, device information,

browser or operating system information, location information (which may

include approximate or precise location data), gameplay and usage data, and

information regarding your interactions with advertisements and our

Service.

We and our advertising partners may use this information to provide

personalized advertising, interest-based advertising, cross-app

advertising, analytics, attribution, and advertising measurement services,

including showing advertisements that may be more relevant to your

interests. In some cases, our advertising partners may combine information

collected through our Service with information collected from other apps,

websites, or services for these purposes, in accordance with their own

privacy policies.

Some of our advertising and analytics partners may use non-cookie

technologies, such as SDKs, pixels, local storage, eTags, or device

identifiers, to recognize your browser, device, or application over time.

Please note that blocking or disabling cookies through your browser or

device settings may not fully prevent the use of these technologies.

You may be able to limit personalized advertising by adjusting your device

settings or privacy preferences. For example:

On Apple iOS devices, you can manage app tracking permissions in

“Settings” → “Privacy & Security” → “Tracking”.

On Android devices, you can manage advertising preferences through your

device settings, including resetting or limiting your advertising ID.

Depending on your jurisdiction, you may also have the right to object to or

opt out of certain personalized advertising, direct marketing, profiling,

or data sharing activities. Where required under applicable law, we will

honor requests to restrict or stop the processing of your personal

information for such purposes. You may exercise these rights by adjusting

your device settings where available or by contacting us at

support@dragonrisinggames.com.

Please note that opting out of personalized advertising does not mean you

will stop seeing advertisements. You may continue to receive non-

personalized or contextual advertisements

7. Your Controls, Choices and Rights

We offer you certain controls, choices and rights regarding the information

we collect, which are explained below.

1) Data subject access requests

You may ask us for a copy of the information we hold about you at any time,

and request us to modify, update or delete such information. If we provide

you with access to the information we hold about you, we will not charge

you for this unless permitted by law. If you request further copies of this

information from us, we may charge you a reasonable administrative cost.

Where we are legally permitted to do so, we may refuse your request. If we

refuse your request we will always tell you the reasons for doing so.

2) Right to object

This right enables you to object to us processing your personal data where

we do so for one of the following reasons:

because it is in our legitimate interests to do so (for further

information please see section 11 below);

to enable us to perform a task in the public interest or exercise

official authority;

to send you direct marketing materials; or
for scientific, historical, research, or statistical purposes.

3) Right to withdraw consent

Where we have obtained your consent to process your personal data for

certain activities (for example, for marketing), you may withdraw this

consent at any time and we will cease to use your data for that purpose

unless we consider that there is an alternative legal basis to justify our

continued processing of your data for this purpose, in which case we will

inform you of this condition.

4) Right to erasure

You have the right to ask us to erase your personal data in certain

situations, such as when:

The data is no longer needed;
You withdraw your consent, and we have no other reason to keep it;
The data was processed unlawfully;
We need to erase the data to follow the law; or
You object to the processing, and we have no valid reason to continue.

We can only refuse to erase your data in specific cases, and we will

explain why. If your request is valid, we will take reasonable steps to

erase the data.

5) Right to restrict processing

You have the right to request that we restrict our processing of your

personal data in certain circumstances, for example if you dispute the

accuracy of the personal data that we hold about you or you object to our

processing of your personal data for our legitimate interests. If we have

shared your personal data with third parties, we will notify them about the

restricted processing unless this is impossible or involves

disproportionate effort. We will, of course, notify you before lifting any

restriction on processing your personal data.

6) Right to opt-out of targeted advertising

You have the right to opt-out of targeted advertising. This means you can

choose not to receive targeted ads based on your interests. To do so, you

can adjust your settings in our app or website, or follow the instructions

provided in the ads you see.

7) Right to rectification

You have the right to request that we rectify any inaccurate or incomplete

personal data that we hold about you. If we have shared this personal data

with third parties, we will notify them about the rectification unless this

is impossible or involves disproportionate effort. You may also request

details of the third parties that we have disclosed the inaccurate or

incomplete personal data to. Where we think that it is reasonable for us

not to comply with your request, we will explain our reasons for this

decision.

8) Right of data portability

If you wish, you have the right to transfer your personal data between

service providers. In effect, this means that you are able to transfer the

details we hold on you to another third party. To allow you to do so, we

will provide you with your data in a commonly used machine-readable format

so that you can transfer the data. Alternatively, we may directly transfer

the data for you.

9) Right to complain

You have the right to complain to a data protection authority about our

collection and use of your personal information.

8. How to Exercise Your Rights

If you would like to exercise any of your rights as described in this

“Contacting Us” heading below. We will aim to respond to your request as

quickly as possible, and within one month (unless we are allowed more

time). Please note that we may keep a record of your communication to help

us address your concerns.

If you choose to contact us directly by email, you will need to provide us

with:

Enough information to identify you [(e.g., your full name, address and

customer or matter reference number)];

Proof of your identity and address (e.g., a copy of your driving license

or passport and a recent utility or credit card bill); and

A description of what right you want to exercise and the information to

which your request relates.

You may only make a CCPA-related data access or data portability disclosure

request twice within a 12-month period.

We are not obligated to make a data access or data portability disclosure

if we cannot verify that the person making the request is the person about

whom we collected information, or is someone authorized to act on such

person’s behalf.

Any personal information we collect from you to verify your identity in

connection with you request will be used solely for the purposes of

verification.

9. Account Deletion

You have the right to delete the account which you have registered with us

to access its products or services at any time. We will delete the account

after verifying your identity information. To ensure the security of your

account and property, you shall submit your account deletion request to us

via one of the following ways：

● by using the contact information displayed on our official

website（https://www.dragonrisinggames.com/delete-account）; or

● by clicking the “Account Deletion ”option provided in the APP.

Unless otherwise stipulated by laws and regulations, after account

deletion, we will delete all information related to your account, including

personal information and game logs, thus you will be unable to normally use

the products or services provided by us. After you complete the deletion,

your account cannot be retrieved and your account data cannot be recovered.

Please maintain your account information properly.

10. Data Retention

We will retain your personal data only for as long as necessary to fulfill

the purposes for which it was collected, unless required by law or

regulation (e.g., tax authority requests or anticipated litigation) or to

enforce our agreements. Generally, we keep your data while providing

services to you and your account is active, and for a reasonable period

afterward if we continue offering you other services directly.

Once retention is no longer necessary, we will delete your personal data

from our systems. Although we strive to permanently erase it after the

retention period, some data may linger in our systems (e.g., awaiting

overwriting). For practical purposes, this data is effectively unusable—it

remains in electronic storage but is inaccessible and unused by our

employees.

11. Data Transfer and Security

All personal information processed by us may be transferred, stored, and

accessed globally, including in countries such as the United States or

others with data protection laws that differ from those in your

jurisdiction. We are committed to protecting your personal information in

accordance with applicable legal requirements.

For transfers of personal information originating from the European

Economic Area, Switzerland, or the United Kingdom to countries deemed

insufficient under applicable data protection laws, we may implement

safeguards such as the EU Standard Contractual Clauses to ensure adequate

protection.

We will take all reasonable precautions necessary to protect your personal

data from

1) loss, theft, misuse and interference;

2) unauthorised access, disclosure, use or modification.

Such measures will vary depending on the sensitivity, amount, format,

nature and storage of the information and will involve, as applicable,

physical, organizational and electronic security measures.

This includes, for example, the protection of passwords using industry

standard encryption, measures to preserve system security and prevent

unauthorised access and back-up systems to prevent accidental or malicious

loss of data. We may use third party data storage providers to store

personal data electronically. We take reasonable steps to ensure this

information is held as securely as information stored on our own equipment.

Unfortunately, there is always risk involved in sending information through

any channel over the internet. You send information over the internet

entirely at your own risk. Although we will do our best to protect your

personal data, we cannot guarantee the security of your data transmitted

over the internet and we do not warrant the security of any information,

including personal data, which you transmit to us over the internet.

12. Contacting Us

Should you have any questions or concerns about our Privacy Policy and/or

privacy practices, please contact us through the following

method：support@dragonrisinggames.com.

13. Supplemental Terms

1) Additional Information for California Residents

We collect the categories of personal information about California

consumers identified in the chart below. As further set forth in the chart

below, in the past 12 months we have disclosed and "sold" (as defined in

the CCPA) California consumers' personal information to third parties for

business or commercial purposes.

|or | |Legal compliance; | | |

|) | |against security | | |

| | |Debugging; | |and |

2) California Privacy Rights

If you are a California resident and the processing of personal information

about you is subject to the California Consumer Privacy Act (“CCPA”), you

have certain rights with respect to that information.

|Disclosure of Personal Information We Collect About You |

|You have the right to know: |

|The categories of personal information we have collected about |

|you; |

|The categories of sources from which the personal information is |

|collected; |

|Our business or commercial purpose for collecting or selling |

|personal information; |

|The categories of third parties with whom we share personal |

|information, if any; and |

|The specific pieces of personal information we have collected |

|about you. |

|Please note that we are not required to; |

|Retain any personal information about you that was collected for a|

|single one-time transaction if, in the ordinary course of |

|business, that information about you is not retained; |

|Reidentify or otherwise link any data that, in the ordinary course|

|of business, is not maintained in a manner that would be |

|considered personal information; or |

|Provide the personal information to you more than twice in a |

|12-month period. |

|Personal Information Sold or Used for a Business Purpose |

|In connection with any personal information we may sell or |

|disclose to a third party for a business purpose, you have the |

|right to know: The categories of personal information about you |

|that we sold and the categories of third parties to whom the |

|personal information was sold; and |

|The categories of personal information that we disclosed about you|

|for a business purpose. You have the right under the California |

|Consumer Privacy Act of 2018 (CCPA) and certain other privacy and |

|data protection laws, as applicable, to opt-out of the sale of |

|your personal information. If you exercise your right to opt-out |

|of the sale of your personal information, we will refrain from |

|selling your personal information, unless you subsequently provide|

|express authorization for the sale of your personal information. |

|To opt-out of the sale of your personal information, you may |

|contact us using the contact details under the “Contacting Us” |

|heading below. |

|Right to Deletion |

|Subject to certain exceptions set out below, on receipt of a |

|verifiable request from you, we will: |

|Delete your personal information from our records; and |

|Direct any service providers to delete your personal information |

|from their records. |

|Please note that we may not delete your personal information if it|

|is necessary to: |

|Complete the transaction for which the personal information was |

|collected, fulfill the terms of a written warranty or product |

|recall conducted in accordance with federal law, provide a good or|

|service requested by you, or reasonably anticipated within the |

|context of our ongoing business relationship with you, or |

|otherwise perform a contract between you and us; |

|Detect security incidents, protect against malicious, deceptive, |

|fraudulent, or illegal activity; or prosecute those responsible |

|for that activity; |

|Debug to identify and repair errors that impair existing intended |

|functionality; |

|Exercise free speech, ensure the right of another consumer to |

|exercise his or her right of free speech, or exercise another |

|right provided for by law; |

|Comply with the California Electronic Communications Privacy Act; |

|Engage in public or peer-reviewed scientific, historical, or |

|statistical research in the public interest that adheres to all |

|other applicable ethics and privacy laws, when our deletion of the|

|information is likely to render impossible or seriously impair the|

|achievement of such research, provided we have obtained your |

|informed consent; |

|Enable solely internal uses that are reasonably aligned with your |

|expectations based on your relationship with us; |

|Comply with an existing legal obligation; or |

|Otherwise use your personal information, internally, in a lawful |

|manner that is compatible with the context in which you provided |

|the information. |

|Protection Against Discrimination |

|You have the right to not be discriminated against by us because |

|you exercised any of your rights under the CCPA. This means we |

|cannot, among other things: |

|Deny goods or services to you; |

|Charge different prices or rates for goods or services, including |

|through the use of discounts or other benefits or imposing |

|penalties; |

|Provide a different level or quality of goods or services to you; |

|or |

|Suggest that you will receive a different price or rate for goods |

|or services or a different level or quality of goods or services. |

|Please note that we may charge a different price or rate or |

|provide a different level or quality of services to you, if that |

|difference is reasonably related to the value provided to our |

|business by your personal information. |