GINGER JOY LIMITED PRIVACY NOTICE

(Last updated March 2026)

1. INTRODUCTION

Who are we?

We are GINGER JOY LIMITED, a company registered in Republic of Cyprus whose registered office is at Chanteclair Building, 7th Floor, Office 702 Sofouli Street 2 Nicosia 1096 12:25 Cyprus. ("GINGER JOY", "we" or "us"), and we are a technology company that develops, designs and publishes mobile games.

Where we decide the means or purpose of processing your personal data, we are the "controller."

What's this notice about?

If you are below the age of 18 years, we recommend that you refer to our Children's Privacy Notice, which you can access here.

This notice explains how we process personal data, as a controller, relating to:

• Visitors ("Website Users") to our website: https://gingerjoy.gs/ ("Website")
• Users ("Mobile App Users") of our mobile games ("Apps"), which are accessible via certain online stores, including: the App Store, here: https://apps.apple.com/tr/developer/ginger-joy-limited/id1689568870; and the Google Play Store, here: https://play.google.com/store/apps/developer?id=Ginger Joy;

Together the Website Users and Mobile App Users shall be the "Users" (and "you" and "your" shall refer to any User).

We update this notice from time to time, so Users should check back in on a regular basis.

Please note that other websites or services mentioned on the Website or our Apps are not operated by us, and you should refer to the privacy notices on those websites to understand how they process personal data.

What are your rights?

Users have the following rights, although these rights may be limited in some circumstances:

• Ask us to send (port) a copy of your personal data to you or to another organisation
• Ask us to restrict, stop processing, or delete your personal data
• Object to our processing of your personal data
• Object to use of your personal data for direct marketing purposes
• Ask us to correct inaccuracies in your personal data

We do not carry out any automated decision-making or profiling that produces legal or similarly significant effect on individuals.

California Residents: In addition to the rights mentioned above, you have the right to know whether your personal information (or personal data) is sold or shared and the right to opt-out of the sale or sharing of your personal information by us for targeted advertising purposes. We do not sell your personal information; however, we permit specific third-party advertising partners to collect information about our Users through our games for various purposes primarily to serve more relevant ads and to detect and report fraud. You have the right to opt-out of this sharing for targeted advertising purposes. You can submit a request to opt-out to the email address below by providing your primary residence, full name, email, device ID, valid California residence address and other details about your request or by using "do not sell my information" page (https://gingerjoy.gs/do-not-sell-my-information.html). We may verify your request by asking for certain information such as your device ID and/or User ID.

If we rely on consent to process personal data, or send direct marketing, you can withdraw consent by email to the email address below. However, should you decline to provide certain required personal data (e.g., device identifiers or payment information for purchases), your access to the entire App may be restricted, certain features may be unavailable, or we may be unable to complete your transaction.

How do you contact us?

If you have any questions concerning this notice, including how you can exercise your rights, please contact us at: legal@gingerjoy.gs

If we can't resolve your issue, you can also get in touch with the Office of the Commissioner for Personal Data Protection. If you are based in United Kingdom, your local data protection authority is the Information Commissioner's Office (https://ico.org.uk/concerns) If you are based in the European Union, information about how to contact your local data protection authority is available here (https://ec.europa.eu/newsroom/article29/items/612080/en). If you are based in Switzerland, your local data protection authority is the Swiss Federal Data Protection and Information Commissioner (https://www.edoeb.admin.ch/en).

2. YOUR PERSONAL DATA AND HOW WE USE IT

MARKETING

• PURPOSE: We process certain information relating to the device on which Mobile App Users are accessing our Apps to send Mobile App Users marketing notifications and serve personalised in-App advertisements.
• CATEGORIES OF PERSONAL DATA: Mobile App Users' IDFA (identifier for advertisers), AAID (advertising-related identifying data), and/or IDFV (Identifier for Vendor).
• HOW WE USE IT: We process some of this personal data if you have given your consent, and some of this personal data on the basis of our legitimate interests, being to: (i) promote the success of our business, our Apps and related services; and (ii) further our commercial interests. Such interests are not overridden by Mobile App Users' interests or fundamental rights and freedoms.
• SOURCES AND RECIPIENTS: We collect this personal data directly from Mobile App Users. And we share this personal data with: digital marketing platforms, ad mediation and app monetisation service providers, mobile app development platforms, analytics service providers and content development platforms.

ANALYTICS

• PURPOSE: We process certain information relating to the device on which Mobile App Users are accessing our Apps to: (i) identify Mobile App Users; (ii) improve, test and monitor the quality and delivery of our Apps; (iii) identify and correct any problems in our Apps (such as bugs or problems preventing in-Game progression); (iv) perform essential business operations; (v) understand user engagement with our services and advertisements (vi) enable certain functionalities within our Services; (vii) comply with regional requirements; and (viii) enhance user experience.
• CATEGORIES OF PERSONAL DATA: Each Mobile App User's device's technical attributes including operating system, resolution settings, language settings, time zone settings, device brand and model, and network and connection data including IP address; as well as the version of the App downloaded to each Mobile App User's device. This also includes usage metrics and interaction patterns, event data and conversion tracking (e.g., how and when services are accessed), performance-related diagnostics (such as crash reports, loading times, latency, framerate, and battery status), and approximate location information inferred from your IP address or related metadata.
• HOW WE USE IT: We process this personal data on the basis of our legitimate interests, being to: (i) promote the success of our business, our Apps and related services; (ii) further our commercial interests; (iii) understand how Mobile App Users use our Apps; (iv) provide location-based features; (v) comply with legal obligations; and (vi) understand the geographical distribution of our users to improve service delivery. Such interests are not overridden by Mobile App Users' interests or fundamental rights and freedoms.
• SOURCES AND RECIPIENTS: We collect this data directly from Mobile App Users. And we share this personal data with: mobile app development platforms and content development platforms.

GAMEPLAY

• PURPOSE: We process certain information about Mobile App Users in order to: (i) allow Mobile App Users to use our Apps (including certain functionalities on our Apps); (ii) understand how Mobile App Users use our Apps; (iii) understand user preferences; (iv) analyse consumption trends; and (v) improve our services and offerings.
• CATEGORIES OF PERSONAL DATA: In-app purchase history, subscription data, player progress, services and items purchased or considered, transaction history, consumption trends or preferences across our services, IP-based location, Apple ID, Facebook ID and Facebook name. In certain apps, we process information relating to Mobile App Users' gender, age range, goal for how long they intend to use this App each day (i.e. the "daily goal"), main motivation or aim for using this App (i.e. the "primary goal") and the area in which the Mobile App User wishes to improve on by using this App (i.e. the "improvement area"), so that we can customise Mobile App Users' use of this App and optimize our marketing campaigns. Also, in certain Apps, we process Mobile App Users' usernames and player progress (e.g. the level that they have reached on the relevant App) so that we can maintain a leader-board for each App. We also share Mobile App Users' in-app purchase (IAP) subscription and consumption trend with App marketplaces such as Apple AppStore, Google Play Store for fulfilment and subscription management purposes.
• HOW WE USE IT: We process some of this personal data if you have given your consent, and some of this personal data on the basis of our legitimate interests, being to: (i) improve the delivery of our Apps; (ii) promote the success of our business; (iii) improve the Mobile App Users' user experience when using this App; (iv) analyse business performance; (v) develop and refine our products and services; and (vi) provide more relevant content and offers. Such interests are not overridden by Mobile App Users' interests or fundamental rights and freedoms.
• SOURCES AND RECIPIENTS: We collect this data directly from Mobile App Users. And we share this personal data with: Apple Inc., Meta Platforms (Facebook), Google LLC and content development platforms.

ENQUIRIES

• PURPOSE: We process certain information about Website Users in order to: (i) review and respond to their enquiries, complaints or questions about our Apps, Website or related services; (ii) provide quality customer care; and (iii) improve, test and monitor the quality and delivery of our Apps.
• CATEGORIES OF PERSONAL DATA: Name, contact information (such as email address or telephone number) and any other information that Mobile App Users submit as part of their enquiries, complaints or questions.
• HOW WE USE IT: We process this personal data on the basis of our legitimate interests, being to: (i) understand how Website Users use our Apps, Website or related services; and (ii) promote the success of our business. Such interests are not overridden by Website Users' interests or fundamental rights and freedoms.
• SOURCES AND RECIPIENTS: We collect this data directly from Website Users. And we do not share this personal data with any third parties.

APP SUBMISSIONS

• PURPOSE: We process certain information about Website Users in order to assess the Website User's app submission with a view to publishing it.
• CATEGORIES OF PERSONAL DATA: App information (including title, gameplay video link, App Store or Google Play Store link, information on what the app is made with and any additional information shared regarding the app), contact details (name, email address, location), website or portfolio link, team size and number of games published with a publisher.
• HOW WE USE IT: We process this personal data on the basis of our legitimate interests, being to: (i) promote the success of our business; and (ii) further our, and the Website User's, commercial interests. Such interests are not overridden by Website Users' interests or fundamental rights and freedoms.
• SOURCES AND RECIPIENTS: We collect this data directly from Website Users. And we do not share this personal data with any third parties.

JOB APPLICATIONS

• PURPOSE: We process certain information about Website Users in order to assess whether they are suitable for a role at GINGER JOY, including to consider your skills and qualifications, when they submit a job application on our Website. We'll also communicate with you about the role and the recruitment process and keep appropriate records of the process.
• CATEGORIES OF PERSONAL DATA: First name and last name, email address, phone number, resumé/CV, LinkedIn profile URL, personal website URL and your message submitted as part of your application.
• HOW WE USE IT: We process this personal data to pursue our legitimate interests, being to: (i) hire suitably qualified individuals; and (ii) operate our business and promote its success. Such interests are not overridden by Website Users' interests or fundamental rights and freedoms.
• SOURCES AND RECIPIENTS: We collect this data directly from Website Users. And we do not share this personal data with any third parties.

3. STORAGE, TRANSFERS AND DISCLOSURE

Data retention

We hold personal data for as long as necessary bearing in mind the purpose for which it was collected. At the end of the retention period, we assess whether it is necessary to continue to retain personal data to achieve the purposes for which it was collected. To determine appropriate retention periods, we consider the amount, nature, and sensitivity of the data, the potential risk of unauthorised access, and legal requirements.

Storage & Transfers

We are based in the Republic of Cyprus, regularly collaborate with an international network of partners and may from time-to-time use subcontractors based in other countries. As a result, there may be occasions where we transfer personal data to a country which does not provide an adequate level of protection. Where this is the case, we use contracts which give personal data the same protection it has in the Republic of Cyprus. For more information, please contact us using the contact details at the start of this notice.

Disclosure

We may disclose your personal data:

• Where required by law, government, competent authorities or the courts or to establish, exercise or defend our legal rights, and for the purposes of preventing crime and fraud (for example, we may share personal data with our professional advisors, investigators, or credit reference agencies).
• With suppliers and subcontractors, as necessary for the purposes set out in this notice.
• With other members of our corporate group and our international network of partners.
• If involved in an investment, merger, acquisition, or sale of our organisation or assets, personal data we hold may be shared on the basis of the legitimate interests of us, our shareholders, customers and other parties to a transaction, unless those interests are outweighed by prejudicial impacts upon you.

4. COOKIES, ANALYTICS AND SIMILAR TECHNOLOGIES

Cookies, pixels and other similar technologies store and access data on your device for certain purposes. You can find out more information on such technology in our "Cookies, Pixels and Other Similar Technology" annex, which you can access below. This annex explains each technology's purpose, how long they last and who else can access the relevant data that the technology collects. We get your consent to use them in our Apps unless they're essential for our Apps to function.

COOKIES, PIXELS AND OTHER SIMILAR TECHNOLOGY ANNEX

(Last updated March 2026)

All technology included within this annex are included within all Apps, and therefore will collect your personal data until you delete the relevant App.