PRIVACY POLICY

1. INTRODUCTION

1.1 This Privacy Policy ("Policy") establishes the framework under which Mood Studios LLC ("Company," "we," "us," or "our") collects, processes, utilizes, and safeguards the personal information of our users in strict compliance with applicable data protection laws and regulations ("Data Protection Laws"). This Policy governs all personal information within our control or custody, including information held by third-party organizations engaged by us to collect, process, or handle personal data on our behalf.

1.2 We are committed to maintaining the highest standards of data protection and privacy in accordance with applicable Data Protection Laws and hold ourselves to rigorous standards in respecting the privacy rights of all individuals who utilize our products, websites, and mobile applications ("Platforms") (collectively referred to as the "Services" or "Applications").

1.3 "User" refers to any individual who creates an account or otherwise accesses or utilizes the Services through any platform or medium provided by us (individually and collectively, "User," "you," or "your").

1.4 We acknowledge the significant trust you place in us by sharing your personal information and accept our responsibility to manage, protect, and process such data with the utmost care. This Policy is designed to provide you with clear understanding of:

  • The circumstances under which we collect your personal information;
  • The types of information we gather;
  • Our use of cookies and similar technologies;
  • How we utilize your personal information;
  • Our practices regarding sharing, transferring, and disclosing your personal data;
  • Your right to withdraw consent;
  • Procedures for accessing and correcting personal information;
  • Our security measures for protecting personal data;
  • Data accuracy requirements;
  • Data retention practices;
  • Policies regarding minors;
  • Your individual rights (particularly for users in the European Union regarding rights under the General Data Protection Regulation);
  • International data transfers; and
  • Policy updates, dispute resolution, and contact information.

2. CIRCUMSTANCES OF DATA COLLECTION

2.1 We adhere to the principle of minimal data collection and generally refrain from collecting personal information unless: (a) you voluntarily provide it directly to us or through an authorized representative after receiving clear notice of collection purposes and providing explicit consent, or (b) collection is expressly permitted or mandated by applicable Data Protection Laws. We will always seek your informed consent before collecting additional personal information or using existing data for previously undisclosed purposes, except where legally authorized.

2.2 We may collect personal information in the following circumstances:

  1. During account registration for our Services (including chosen usernames, imported social media account information from platforms such as Facebook and Google for profile creation, including displayed names and profile images);
  2. When accessing Services as a guest user (including chosen usernames);
  3. Through voluntary participation in surveys within our Services (processing all information provided during such participation);
  4. During transactions conducted through our Services or with our authorized third-party payment processors;
  5. When linking your account with external social media platforms (Facebook, Google, etc.) or utilizing social media functionalities in accordance with provider policies;
  6. Through general use of our Services or interactions with other users and our company, including automated data collection such as cookies generated during your engagement with our platform.

3. DATA CATEGORIES AND COLLECTION PRACTICES

3.1 We may collect and process the following categories of personal information:

(a) Account Registration Data: During account creation, we collect essential information including usernames, birth dates, age, gender, email addresses, telephone numbers, passwords, verification codes, and unique identifiers to facilitate account establishment, provide authentication services, and fulfill additional purposes outlined in this Policy.

(b) User Profile Information: You may customize your profile within our Services by selecting display names, creating personal descriptions, uploading profile images, and providing additional details according to our platform specifications.

(c) Communication Records: When utilizing messaging features within our Services (such as in-application chat), we process communication logs and implement end-to-end encryption to protect your information.

(d) Survey Data: We collect responses when you voluntarily participate in our research surveys.

(e) Event and Promotional Participation Data: When you choose to participate in events, contests, or promotional activities organized by us, we collect relevant participation information including names, user identifiers, email addresses, telephone numbers, usernames, and geographical regions. Prize winners may be required to provide mailing addresses for prize delivery. This information may be associated with your account.

(f) Application Usage Data: We collect information regarding your in-application activities, including experience points, progression data, achievement levels, scores, user statistics, and similar metrics generated during Service utilization. This data enables us to understand user preferences, provide personalized experiences, and enhance overall Service quality.

(g) Technical and Location Data: We collect technical information including IP addresses, geographical location data, network status information, and device specifications such as device identifiers, device names, device types and models, MAC addresses, IMEI data, processor information, graphics hardware specifications, operating system versions and languages, time zones, screen specifications, device resolution, memory specifications, and graphics capabilities. We also gather diagnostic information including bugs, errors, crashes, registration and login timestamps, application versions, stack traces, crash reports, and system anomalies to better understand device compatibility, usage patterns, and user location.

(h) Advertising Identifiers: We store advertising identifiers and selected device information for each advertisement impression, combined with your profile data, to measure advertising campaign effectiveness. We may also utilize de-identified email addresses, including those obtained from third-party social media providers during social login, to track marketing campaign performance using appropriate technical safeguards.

(i) Financial Transaction Data: For account-based purchases, we collect payment information and transaction-generated data, including points and membership levels, to process purchases and related activities. This may include names, payment card numbers, expiration dates, billing addresses (including country, city, postal code, and street address), and security codes.

(j) Customer Support Data: We maintain records of support requests, including ticket identifiers and communication history with our support team, to provide effective assistance and improve our Services.

(k) Marketing and Communication Preferences: We collect information regarding your marketing preferences, communication settings, and interaction history with us and our service providers to customize our communications and enhance user experience.

(l) Security and Authentication Data: We collect and process account security information, including password modifications and login history, to maintain platform security and integrity.

(m) Anti-Fraud and Security Monitoring: We collect specific data and employ various methodologies to detect and analyze fraudulent activities or security violations within our Services. These methods include monitoring for external programs that may compromise our Services, detecting unauthorized access attempts by external applications or plugins, and implementing similar security measures to ensure fair and secure user experiences. This data is used exclusively for fraud prevention and security purposes.

(n) Supplementary Information: We may collect additional information as required by specific Service features or functionalities. In such cases, we provide separate privacy notices detailing the collection and use of such information.

To provide comprehensive user experiences, we may aggregate and update our collected personal data with information from third-party service providers to enhance your profile (such as connected third-party account information), conduct market research, and fulfill other purposes outlined in this Policy, with your prior consent or other lawful basis.

When you engage with third-party services that may be integrated into our Services, such as social media widgets, sharing buttons, or external login systems, this Policy does not govern such features, which are subject to their respective privacy policies.

3.2 Information collected from our partners:

  1. Social media account data received from third-party providers when you choose to access our Services through social media platforms, which is integrated with your account information;
  2. Demographic information (such as approximate location based on IP address geolocation);
  3. Fraud prevention data (including transaction abuse detection and advertising click fraud identification);
  4. Platform verification data (such as payment authentication from application stores);
  5. Advertising and analytics data to enhance Service provision.

4. COOKIES AND SIMILAR TECHNOLOGIES

We utilize cookies and similar technologies (including web beacons, log files, scripts, and eTags) ("Tracking Technologies") to enhance your Service experience. These are small data files that, when stored on your device, enable us to provide specific features and functionality. You may choose to permit or disable these Tracking Technologies. You can accept all cookies, configure your device to notify you when cookies are being installed, or reject all cookies through your device's privacy settings. However, disabling cookies may limit the functionality of our Services.

5. DATA UTILIZATION PURPOSES

5.1 We utilize collected information for the following purposes:

5.1.1 Account creation and management in accordance with your requests;

5.1.2 Username generation and unique identifier creation, along with storing your application data (including levels and progress) within your profile;

5.1.3 Communication with you through various channels including telephone, SMS, email, postal mail, and other means to manage your relationship with us and administer your Service usage;

5.1.4 Maintaining comprehensive records of your transaction history;

5.1.5 Managing, operating, providing, and administering your Service access and usage, including preference management and account relationship maintenance;

5.1.6 Identity verification and authentication purposes;

5.1.7 Conducting research, analysis, and development activities (including data analytics, surveys, product development, and user profiling) to analyze Service usage, improve our offerings, and enhance customer experiences;

5.1.8 Processing and delivering messages to other users when you utilize chat services (audio or text);

5.1.9 Security and verification purposes, including bug identification, functionality assessment, optimization, anti-fraud measures, crash resolution, device compatibility optimization, and preventing multiple account registrations;

5.1.10 Providing geographical leaderboards and similar features by determining your location based on IP address analysis;

5.1.11 Data storage, hosting, and backup services (including disaster recovery) whether within or outside your jurisdiction;

5.1.12 Due diligence and screening activities (including background checks) in accordance with legal obligations and risk management procedures;

5.1.13 Legal compliance and regulatory requirements, including responding to legal processes and meeting disclosure obligations under applicable laws binding us or our affiliated entities;

5.1.14 Marketing and advertising activities where legally permissible, including recommending relevant products and services, sending promotional communications through various channels (including email and SMS) regarding our products and services and those of our business partners, whether currently available or future offerings. You may unsubscribe from marketing communications using the unsubscribe mechanism provided in electronic materials. We may use your contact information for newsletters and marketing materials from us and affiliated companies;

5.1.15 Other purposes permitted by applicable law and disclosed at the time of consent.

5.2 The specific purposes for data collection, use, disclosure, and processing depend on particular circumstances. Unless Data Protection Laws permit processing without consent, we will notify you of additional purposes when obtaining your consent.

6. DATA SHARING, TRANSFER, AND DISCLOSURE PRACTICES

6.1 Information Sharing

We prioritize the protection of your personal information as a fundamental aspect of our service provision. We collect and use personal information solely for purposes within the scope of this Policy and as required by applicable laws, maintaining strict confidentiality. We do not share personal information with external companies, organizations, or individuals except in the following circumstances:

  1. With your explicit prior consent;
  2. When sharing is required by applicable laws, regulations, legal processes, governmental mandates, or judicial orders;
  3. When legally required or permitted to protect our interests, our users, or the public from harm to rights, property, or safety;
  4. Among our affiliated entities, limited to necessary information sharing consistent with this Policy's stated purposes. If an affiliate seeks to change processing purposes, we will obtain your renewed consent;
  5. With authorized partners who provide certain Services to enhance quality and user experience. We share only the minimum personal information necessary for service provision and require partners to handle your information according to our instructions, this Policy, and applicable confidentiality and security measures. Partners are prohibited from using shared information for unauthorized purposes. If you refuse partner data collection necessary for service provision, certain third-party services may become unavailable.

Partner information collection and processing is governed by their own privacy policies, which are not covered by this Policy. We recommend reviewing third-party service privacy policies before use. If you identify risks with third-party services, we recommend discontinuing use and contacting us promptly.

Current third-party partner information is available upon request through our contact channels.

6.2 Information Transfer

We do not transfer personal information to external companies, organizations, or individuals except in the following circumstances:

  1. Consensual Transfer: Following explicit consent, we may transfer your personal information to other parties;
  2. Legal Compliance: When required by applicable laws, legal proceedings, or mandatory administrative or judicial requirements;
  3. Business Transactions: In connection with mergers, acquisitions, asset transfers, bankruptcy, liquidation, or similar transactions involving personal information transfer, we require the receiving entity to remain bound by this Policy and seek renewed consent as necessary.

6.3 Information Disclosure

We publicly disclose personal information only in the following circumstances:

  1. After obtaining your express consent;
  2. Legal Mandate: When compelled by law, legal process, litigation, or governmental authority.

6.4 Disclosure Without Prior Consent

In accordance with applicable laws and regulations, we may share, transfer, or publicly disclose personal information without obtaining prior consent in the following circumstances:

  1. In fulfillment of legal and regulatory obligations;
  2. In connection with national security or defense matters;
  3. In relation to public safety, public health, or significant public interests;
  4. In connection with criminal investigations, prosecutions, trials, or judgment enforcement;
  5. To protect the life, property, or other significant legitimate interests of data subjects or others when consent cannot be reasonably obtained;
  6. Information voluntarily made public by the data subject;
  7. Information collected from legally public sources, such as legal news reports or government disclosures.

Under applicable law, sharing, transferring, or publicly disclosing de-identified information that cannot be used to re-identify individuals is not considered personal information sharing and may be conducted without notice or consent.

7. CONSENT WITHDRAWAL AND DATA DELETION

7.1 Your consent for personal data collection, use, and disclosure remains valid until withdrawn in writing. You may withdraw consent and request cessation of data collection, use, and disclosure for any or all listed purposes by submitting written requests via email as specified in Section 15.4, contacting our customer service, or using our designated online portal.

7.2 You have the right to request deletion of your personal data, available to all users subject to applicable laws. Deletion requests may be submitted via email as specified in Section 15.4, through customer service, or via our designated online portal.

7.3 Upon receiving consent withdrawal or deletion requests, we require reasonable processing time, typically fifteen (15) calendar days. We will inform you of the consequences of your request, including potential legal implications affecting your rights and obligations to us.

7.4 Depending on your request's nature and scope, we may be unable to continue providing Services, and we will notify you before completing request processing. If you decide to cancel your withdrawal or deletion request, please inform us in writing as described in Section 15.4.

7.5 Consent withdrawal or deletion requests do not affect our right to continue collecting, using, and disclosing personal data where such activities are permitted or required by applicable laws without consent.

7.6 Additional deletion processes and procedures may be established and communicated as necessary.

8. DATA ACCESS, CORRECTION, AND DELETION RIGHTS

8.1 You may submit the following requests: (a) access requests for copies of personal data we hold about you or information about our data use and disclosure practices; (b) correction requests to update or correct personal data we hold about you; or (c) deletion requests for personal data we hold about you. Submit requests in writing or via email to our Data Protection Officer at the contact details provided below, through customer service, or via our designated online portal.

8.2 Reasonable fees may be charged for access requests, and we will inform you of any fees before processing your request.

8.3 We respond to requests promptly, typically within fifteen (15) calendar days. If we cannot respond within this timeframe, we will notify you in writing within fifteen (15) calendar days of our expected response time. If we cannot provide requested data, make corrections, or delete data as requested, we will explain the reasons (except where not required by Data Protection Laws).

9. PERSONAL DATA PROTECTION MEASURES

9.1 To protect your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal, and similar risks, we implement comprehensive administrative, physical, and technical safeguards including minimal data collection, authentication and access controls (including strong password requirements and need-to-know data access), data encryption, anonymization, current antivirus protection, regular system patching, secure storage media disposal, web security measures, multi-factor authentication (including OTP, 2FA, and MFA), and regular security reviews and testing.

9.2 While no internet transmission or electronic storage method is completely secure, we continuously strive to protect your information security and regularly review and enhance our security measures.

10. DATA ACCURACY REQUIREMENTS

We rely primarily on personal data you provide (or your authorized representative provides). To ensure your personal data remains current, complete, and accurate, please update us of any changes by contacting our Data Protection Officer in writing or via email at the contact details provided below.

11. DATA RETENTION POLICIES

11.1 We retain personal data only as long as necessary to fulfill collection purposes or as required or permitted by applicable laws.

11.2 We cease retaining personal data or remove identifying associations when retention no longer serves the original collection purpose and is no longer necessary for legal or business purposes.

12. POLICIES REGARDING MINORS

12.1 Our Services are not designed for or targeted at children under age 13. We do not knowingly collect or maintain personal data or non-personally identifiable information from individuals under 13, nor do we target any portion of our Services toward them.

12.2 Parents and legal guardians should not permit children in their care to submit personal data to us. Please consult our Terms of Service for additional information.

12.3 If personal data of a child under 13 in your care is disclosed to us, you consent to the child's personal data processing and agree to be bound by this Policy on the child's behalf.

12.4 If you do not consent to processing personal data of a child under 13 in your care, please contact our Data Protection Officer. We will close accounts used exclusively by such children and delete personal data submitted without parental consent, as required by applicable law.

13. GDPR RIGHTS FOR EUROPEAN USERS

This section applies to users in the European Economic Area (EEA) and outlines rights under the General Data Protection Regulation (GDPR).

13.1 Rights Overview

Under GDPR, you possess the following rights:

  • Access Rights
  • Rectification Rights
  • Erasure Rights ('Right to be Forgotten')
  • Processing Restriction Rights
  • Data Portability Rights
  • Objection Rights
  • Automated Decision-making and Profiling Rights
  • Consent Withdrawal Rights

13.2 Rights Exercise Procedures

To exercise these rights, you may:

  1. Email us as provided in Section 15.4;
  2. Contact our customer service; or
  3. Submit requests through our designated portal

We respond without undue delay, generally within fifteen (15) calendar days. We may extend this period or request additional information as needed. For detailed procedures and potential extensions, refer to Section 7 of this Policy.

13.3 Detailed Rights Explanations

13.3.1 Access Rights
You may obtain confirmation of our personal data processing activities and access this data along with information about our processing methods.

13.3.2 Rectification Rights
You may request correction of inaccurate personal data or completion of incomplete data.

13.3.3 Erasure Rights ('Right to be Forgotten')
You may request deletion of your personal data, subject to applicable laws. Submit requests using methods outlined in Section 13.2.

13.3.4 Processing Restriction Rights
You may request processing restrictions in certain circumstances, such as when contesting data accuracy.

13.3.5 Data Portability Rights
You may receive your personal data in structured, commonly used, machine-readable formats and transmit this data to another controller.

13.3.6 Objection Rights
You may object to personal data processing in certain circumstances, particularly regarding direct marketing processing.

13.3.7 Automated Decision-making and Profiling Rights
You have the right not to be subject to decisions based solely on automated processing, including profiling, that produce legal effects or similarly significant impacts.

13.3.8 Consent Withdrawal Rights
When we process data based on consent, you may withdraw this consent at any time.

13.4 Response Limitations

We may retain certain information for legal or legitimate business purposes. If we cannot comply with your request, we will explain the reasons within the response timeframe mentioned in Section 13.2.

13.5 Complaint Procedures

If you believe our personal data processing violates data protection laws, you may file complaints with relevant supervisory authorities.

13.6 Fee Structure

You typically will not be charged fees for accessing personal data or exercising other rights. However, we may charge reasonable fees for clearly unfounded, repetitive, or excessive requests.

13.7 Digital Markets Act Compliance

13.7.1 This section outlines our data sharing practices under the European Union's Digital Markets Act ("DMA") and applies specifically to users in the European Economic Area.

13.7.2 Gatekeeper Partnerships: To enhance service quality and provide personalized experiences, we may share data with third-party service providers designated as "Gatekeepers" under the DMA. This involves transferring user information as described in this Privacy Policy for purposes including advertising and service optimization.

13.7.3 Additional Consent Requirements: In accordance with DMA requirements, we seek explicit additional consent from European Economic Area users before data sharing occurs. An in-application Consent Banner will be displayed to obtain this consent, which is essential for utilizing your data in collaboration with Gatekeepers to enhance your service experience.

13.7.4 Non-Consent Consequences: If you decline the Consent Banner, your Services may be affected, potentially impacting personalization and overall service quality.

14. INTERNATIONAL DATA TRANSFERS

14.1 We generally do not transfer personal data outside our jurisdiction. However, if transfers occur, we obtain your consent and ensure your personal data continues receiving protection standards at least comparable to those provided under applicable Data Protection Laws.

14.2 For users in certain jurisdictions, personal data is processed and stored on our servers in accordance with applicable local laws. We transfer information internationally only in accordance with Data Protection Laws, and you consent to such transfers and processing.

14.3 European Union residents should refer to the "GDPR RIGHTS FOR EUROPEAN USERS" section regarding additional personal data rights.

15. GENERAL PROVISIONS

15.1 This Policy applies alongside other policies, contractual clauses, and consent clauses relating to personal data collection, use, and disclosure by us.

15.2 We may revise this Policy periodically. You can determine if revisions have occurred by checking the last updated date. Your continued Service use constitutes acknowledgment and acceptance of changes.

15.3 This Policy and related matters are governed by United States law without regard to conflict of law provisions. Disputes arising from or related to this Agreement, including questions regarding existence, validity, or termination, shall be resolved through binding arbitration under American Arbitration Association rules. Arbitration proceedings shall be conducted in the United States in English.

15.4 Contact Information and Complaints: For inquiries, feedback regarding our personal data protection policies and procedures, or to make requests, contact us as follows:

Name: Protection Officer

Email: [email protected]

Last Updated: June 10, 2025