Mobius Privacy Policy

This Privacy Policy (“Policy”) explains how Mobius Technologies Inc. (“Mobius”, “we”, “us”, or “our”) collects, uses, discloses, and protects your information when you use our website, mobile application, or any related services (collectively, the “Platform”). This Policy applies to all users of our Platform, including users who access our services via a browser, a mobile device, or our desktop application. By using our Platform, you agree to the terms outlined in this Policy. Please read it carefully.For your attention, our PC Platform application is powered by Overwolf, Ltd. (“Overwolf”) infrastructure and technology. For PC Platform users only, Overwolf’s Privacy Policy, which applies in conjunction with this Privacy Policy, can be accessed at: [https://legal.overwolf.com/docs/overwolf/platform/platform-privacy-policy/]. When using our PC Platform, the Company is considered an affiliate as defined in Overwolf’s Data Protection Agreement (“DPA”). Any changes that apply to Overwolf’s DPA will automatically apply to this Privacy Policy solely with respect to the PC Platform.We partner with Tebex Limited (www.tebex.io), who serves as the official merchant for payment processor for subscription payments only. In order to process subscription payments through Tebex, you must agree to their Privacy Policy, available at [https://www.tebex.io/terms-creator-agreement/privacy-policy]. When you access or use any external applications, platforms or services through our Platform, including but not limited to Overwolf and Tebex, the privacy policies and terms of those third parties will apply to your use of their services, in addition to this Privacy Policy. This Privacy Policy sets forth Our policy and practices with respect to personal information that will be processed by Us in relation to (i) Your browsing through our website, if applicable and (ii) Your access and use of the Platform. For our mobile application, we utilize third-party advertising technologies, including but not limited to Google Ads and Facebook Ads, to deliver relevant content and advertisements. These technologies may use cookies, web beacons, or other tracking technologies to collect information about your browsing activities. You can opt out of personalized advertising by adjusting your ad settings or using third-party tools like http://www.aboutads.info/choices. Please note that these advertising practices apply exclusively to our mobile application and not to our PC Platform. Any information that does not constitute personal data, is out of the scope of this Privacy Policy.
By creating a User Account or otherwise using our Platform, You expressly consent to the collection, processing, storage and sharing of Your personal data as described in this Privacy Policy. We are permitted to share Your Personal Data with third parties where You have provided Your express written consent, and we will take reasonable steps to obtain and maintain records of such consent. Any Personal Data shared by Us shall be considered Confidential Information of the relevant third party recipient. 
Personal Data that we collect and Process (“Personal Data”)

We collect several types of information from and about users of our Platform, including: Information you provide to us directly (such as your name, email address, account credentials, and any content you upload or submit).
Information collected automatically as you interact with our Platform, such as your IP address, device information, browser type, usage data, and other technical data.
Information received from third parties, such as service providers, business partners, or external platforms you link to your Mobius account.
Information relating to your activity and engagement with the Platform, including gameplay data, preferences, and communications.
We may also collect additional information as required by law or for specific features of the Platform, which will be disclosed at the point of collection.

The Types of Information that we might collect, receive, use and process

When You use our Platform (both through our website and mobile application), we may automatically collect, receive, use and process Personal Data:
1. Information regarding Your use of the Platform; game data such as achieved game levels, rewards, completed events, virtual currency and statistics including the playtime or the use of the various features. User preferences and settings, such as game language, settings regarding push-notifications and in-game sound and music.
2. Meta / Communication data; IP address and approximate location data (derived from your IP address), device data and technical data such as device type and operating system, network connection type and carrier network, device language.
3. You Voluntarily Provide; Contact information and identification information: name, e-mail address, username Discord username, Battle.net username, and any other information You Provide when creating a User Account; Demographic information: location; Data you upload to the Platform: videos, photos, free text, your correspondence in the Platform’s chat. We strongly advise You not to include any sensitive information in the free text You insert to the chat conversations in the Platform.
4. Usage data; third party websites visited, interest in content, and access times.
5. Support interaction data.
6. Information we collect via cookies; Cookies allow us to collect data, such as Your device’s model, operating system and screen size and other information about how You use Our Platform. When using our mobile application, we also collect your device manufacturer and device ID (serial number). Additionally, when You click on advertisements placed by Us, We may collect, process and store certain personal data related to Your interaction with such advertisements.
7. Data you have approved.

The Purposes for which We use Your Personal Data

The Information We collect is used for the following purposes:
1. Provision of the Platform’s services and use and access thereto: Your Personal Data as described above is used by us for (i) allowing You access to the Platform (ii) provision of the services of the Platform as intended, and (iii) for our mobile application only, delivering relevant content and advertisements through third-party advertising technologies including Google Ads and Facebook Ads. This is based on our contract with You as stipulated in the Terms.
2. Certain Purpose: If You provide Personal Data for a certain purpose, we may use the Personal Data in connection with that purpose for which it was provided. For instance, if You contact us by e-mail, we will use the Personal Data You provide to answer Your question or resolve Your problem and will respond to the email address from which the contact came. This is based on Your consent and on our obligations under the Terms.
3. Internal-Business Purpose: We may use Your Personal Data for internal business purposes, including without limitation, to help Us improve the content and functionality of the Platform, to better understand Our Users, to improve and enhance our website and services, to conduct data analysis and generate insights, to protect against, identify or address wrongdoing or fraud, to enforce our Terms of Use and this Privacy Policy, to manage Your User Account and registration and provide You with customer service and support, and to generally manage the Platform, Our services and our business. Information collected for the purposes of operating the Company’s community on Discord, and for providing you with support, is kept for a maximum of 3 years. This is based on our legitimate interests, and our contractual obligations set forth in the Terms of Use.
4. We use analytics tools, which will include third party analytics tools, to collect information about how You play the games on the Platform or use Our Platform. Those tools will use cookies or other similar tracking technologies. We will use Your data to carry out research, surveys or to engage directly with You, for example by sending You communications (including by email), for these purposes. We will also create reports, analysis or similar services for use by Us for the purposes of research or business intelligence, for example to track potential problems or trends with Our Platform, or to test out new game features and content.
5. Security and Dispute Resolution: We may use Personal Data to protect the security of the Platform, to detect and prevent fraud, fishing, identity theft, data leakage, to confirm the validity of software licenses, to resolve disputes and enforce Our agreements. This is based on Our legitimate interest, and Our contractual obligations as set forth in the Terms of Use, as applicable.
6. Data Retention, Archives: We retain and archive Personal Data as long as it necessary to use Our Platform, meet with contractual obligations, laws and regulations and subject to Our retention policies, User’s “right to be forgotten” and this Privacy Policy.
7. Transfer/Share/Disclose Data: We will not Transfer/Share/Disclose any Personal Data unless it is necessary to perform our services to You and on “need to know basis”. Therefore, We may share Your Personal Data with Our affiliates, contractors and service providers who process Personal Data on Our behalf to perform the services of the Platform, its performance and certain business-related functions. While We do so We make sure that they will be bound to maintain that Personal Data in accordance with this Privacy Policy, with the DPA, Overwolf’s privacy policy, any standard local privacy policy or guidance that may apply.
8. Other Purposes: If We intend to use any Personal Data in any manner that is not consistent with this Privacy Policy, You will be informed of such anticipated use prior to or at the time the Personal Data is collected, used or processed, unless such other purposes are related to the purposes above. Such changes may be personal (affecting only your data) or public (affecting all users), and will be communicated appropriately.

Use of Cookies

1. We and our partners use cookies and similar tracking technologies to enhance your experience, analyze usage, and deliver personalized content and advertisements. You can control the use of cookies through your browser settings or device preferences. Please note that disabling cookies may affect the functionality of certain parts of our Platform.
2. One of the primary purposes of Cookies is to provide a convenience feature to save You time. The purpose of a Cookie is to tell the web server that You have returned to a specific page. For example, if You personalize Your Account pages, or register to the Platform and/or to a specific service, a Cookie helps Us to recall Your specific information on subsequent visits. This simplifies the process of recording Your Personal Data, such as IP addresses, username and so on. When You return to the Platform, the information You previously provided can be retrieved, so You can easily use the Platform features that You customized.
3. You have the ability to accept or decline Cookies. Most web browsers automatically accept Cookies, but You can usually modify Your browser setting to decline Cookies if You prefer. If You choose to decline Cookies, You may not be able to fully experience the interactive features of the services provided in the Platform or other websites You visit.

With whom we share Your Personal Data

1. For data storage and cloud services, the Personal data collected by Us is stored at Amazon North America (AWS), located in Virginia.
2. Data may be processed by Our third party service providers Tremendous (“Provider”). We transfer only the minimum data necessary for conducting Our services. in compliance with GDPR requirements. Provider does not have any right to use Personal Data collected from our Platform beyond what is necessary to facilitate the Platform services.
3. We may disclose Your Personal Data if required to do so by law in order to, for example, respond to a subpoena or request from law enforcement, a court or a government agency (including in response to public authorities to meet national security or law enforcement requirements), or in the good faith belief that such action is necessary to (a) comply with a legal obligation, (b) protect or defend Our rights, interests or property or that of third parties, (c) prevent or investigate possible wrongdoing in connection with the Platform, (d) act in urgent circumstances to protect the personal safety of Users or the public, (e) protect against legal liability, or (f) make any filing that may be applicable in accordance with the DPA and data protection regulations.
4. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Data may be part of the transferred assets. Your information may be transferred as part of that transaction to a successor in interest and to the applicable legal authorities as well as legal counsels and other professional counsels involved such as accountants, and other officers of the government or of the applicable judiciary instance. You acknowledge and agree that any successor to or acquirer of Company (or its assets) will continue to have the right to use Your Personal Data and other information in accordance with the terms of this Privacy Policy.

Transfer and Disclosure of Data

1. Data collected or received may be transferred to, and maintained on, computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.
2. Your information may be transferred to and processed in countries outside your country of residence, which may have data protection laws different from those in your jurisdiction. We take appropriate measures to ensure that your information is treated securely and in accordance with this Policy. Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.
3. We will take steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.
4. We may disclose Your Personal Data in the good faith belief that such action is necessary to comply with a legal obligation, to protect and defend the rights or property of Mobius, to prevent or investigate possible wrongdoing in connection with the Platform, to protect the personal safety of Users of the Platform or the public and to protect against legal liability.
5. We may disclose Your Personal Data in any territory where the laws of the State of Israel may apply, subject to applicable data protection regulations.

Your Rights in Relation to Your Personal Data

1. Right of Access, Updating, Correcting and Deleting: in accordance with applicable laws and regulations, You have a right to request access to Your Personal Data that We process. You also have the right to request to correct or rectify any inaccurate Personal Data that We process about You, or delete it, depending on the circumstances, all subject to applicable laws and regulations, and our internal processes and procedures for complying with such requests. Such requests should be sent to us directly on support@playmobius.com, and we will attend your request promptly.
2. Company allows you to view, edit and/or delete Your Personal Data by submitting request to Us through support@playmobius.com. Please note however, that deleting information from the Platform or otherwise through submitting a request to Us, may have detrimental effect on Your ability to use the Platform or on the performance of the Platform, and any such effects and results are at Your own risk and liability. Certain information, if deleted, will effectively constitute deletion of Your User Account and termination of Your subscription.
3. Please note that unsubscribing from the Platform does not delete Your information. Your information will be automatically deleted from our systems three years after your last activity, or promptly upon your explicit request to exercise your right to be forgotten, in accordance with section 1 above.
4. We will respond to requests to access, edit or delete your Personal Information within 30 days, or according to applicable law.
5. Right to Restriction of Processing: You may have the right to restriction of processing subject to applicable laws. If you wish to object the processing, you are required to contact us at: info@playmobius.com.
6. The right to object to processing – You have the right to object to Company’s processing of your Personal Data, under certain conditions.
7. If allowed by applicable laws, You have the right to withdraw Your consent at any time when Company processes Your Personal Data based on Your consent on any of these rights. However, withdrawal does not affect the legitimacy and effectiveness of how we process Your Personal Data based on your consent before the withdrawal is made; nor does it affect any data processing based on another justification other than your consent.
8. If You think that the way we process Your personal information does not comply with applicable data protection laws, You can contact Us first at support@playmobius.com so we can address your concerns. If you still believe that we are violating data protection regulations after our response, You can contact the relevant competent data protection authority. If You are located in the European Economic Area (EEA), You have the right to lodge a complaint with Your local data protection authority. A list of national data protection authorities can be found at: https://edpb.europa.eu/about-edpb/board/members_en.

Security of Personal Data

We are committed to protecting the security of any Personal Data on our database and network. We use a variety of security technologies and procedures to help protect all Personal Data from loss, misuse, unauthorized use, access, inadvertent disclosure, alteration and destruction. However, no network, server, database or internet or e-mail transmission is ever fully secure or error free. Therefore, You should take special care in deciding what information You disclose.

Children’s Privacy

Our Platform is not intended for children under the age of 13, and we do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete such information as soon as possible. If you believe we might have any information from or about a child under 13, please contact us at support@playmobius.com.

Links to Other Websites

Our Platform may contain links to third-party websites or services that are not operated or controlled by Mobius. We are not responsible for the privacy practices of such third parties. We encourage you to review the privacy policies of any third-party sites you visit.

Changes to this Policy

1. We may update this Privacy Policy from time to time. If we make material changes, we will notify you by posting the updated Policy on our Platform or by other appropriate means. Your continued use of our Platform after the changes become effective constitutes your acceptance of the revised Policy.
2. If We make significant changes, We will make that clear on the Platform or by some other means of contact such as email, so that you are able to review the changes before you continue to use the Platform.

Contact information

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If You have any questions about this Privacy Policy, including any requests to exercise Your legal rights, please contact the DPO at Eyal@kdlaw.co.il. For any other privacy-related concerns or complaints, You should write to us at support@playmobius.com. We will take reasonable steps to work with You to attempt to resolve Your complaint.