PRIVACY POLICY

Effective Date: 19th January, 2026

Thank you for playing our games! This Privacy Policy (this “Policy”) describes the ways Minimax PTE. LTD. (“Minimax”, “us”, “our” or “we”) collects, stores, uses, and discloses the information, including personal information, and data that our users (“users” or “you”) provide or we collect in connection with the Minimax website available at https://www.sg-minimax.com and any Minimax game provided on a mobile platform (each a “Service,” collectively, the “Services”). Additionally, this Policy describes your rights and choices concerning your information.

Please note that the scope of this Policy is limited to information and data collected or received by Minimax through your use of the Services. Minimax is not responsible for the actions of individuals with no relationship to Minimax or third-party companies, the content of their sites, the use of information or data you provide to them, or any products or services they may offer. Any link to those sites does not constitute our sponsorship of, or affiliation with, those individuals or companies.

If you do not want Minimax to collect, store, use, or share your information in the ways described in this Policy, you should not use our Services.

If you have questions about data protection, or if you have any requests for resolving issues with your personal data, we encourage you to primarily contact us through the game so we can reply to you more quickly.

Name of the controller: Minimax PTE. LTD.
email: contract@sg-minimax.com

THE DATA WE COLLECT

Data you provide us.

Contact information (such as name and email address)
Player name and password
Profile information (such as profile photo)
Your messages to the Service (such as chat logs and player support tickets)
Other data you choose to give us (such as data to identify a lost account)

Data we collect automatically.,

Data about your account and game progress
Your IP address and mobile device identifiers (such as your device ID, advertising ID)
Data about your device, such as device name and operating system, browser type and language
Data we collect with cookies and similar technologies (see more below)
General location data
Precise geo-location data (GPS, with your consent)
Data about your use of the Service, such as gameplay data and your interactions with other players inside the Service

In most cases, we also create a Minimax ID for you when you use the Service.

Data we collect from our partners.

Data we receive if you link a third party tool with the Service (such as Facebook, WeChat ,Apple or Google). For example, if you sign in with Google, we receive your account identifier and basic profile info to create your game account.
Demographic data (such as to determine the coarse location of your IP address)
Data to fight fraud (such as refund abuse in games or click fraud in advertising)
Data from platforms that the games run on (such as to verify payment)
Data for advertising and analytics purposes, so we can provide you a better Service

WHY DO WE COLLECT YOUR DATA

To make the Service work.

Legal basis: Performance of a contract.

To perform the contract, we process data necessary to

Create accounts and allow you to play our games and use our Service，including when you sign in through a third-party account.
Operate the Service
Verify and confirm payments
Provide and deliver products and services you request
Send you Service-related communications

To make the Service more suitable for our players.

Legal basis: Legitimate interests. We have a legitimate interest in providing a great Service, which includes developing and improving our games, managing our relationship with you, and promoting our Services.

To provide a great Service to our players, we have a legitimate interest to collect and process necessary data to

Update and develop player profiles
Develop and improve the Service and player experience
Manage our relationship with you
Provide social features as part of the Service
Customize your Service experience
Respond to your comments and questions and provide player support
Provide you Minimax offers in the Service as well as in other websites and services, and by email
Send you related information, such as updates, security alerts, and support messages
Enable you to communicate with other players

To show personalized advertisements.

Legal basis: Legitimate interests or Your consent,where required by applicable laws. We process personal data for personalized advertising purposes based on our legitimate interests in promoting our games and services and sustaining our business operations. Where required by applicable data protection laws (including in certain jurisdictions), we rely on your consent to process such data. You have the right to object to this processing as described in the “Your rights and options” section.

To show you personalized advertisements in the Service as well as in other websites and services (including email) we have a legitimate interest to process necessary data to

Track the content you access in connection with the Service and your online behavior
Deliver, target and improve our advertising and the Service

For information on how to opt-out from personalized advertisements, see section 'Your rights and options' below.

To keep the Service safe and fair.

Legal basis: Legitimate interests. We have a compelling legitimate interest in ensuring the security, integrity, and fairness of our Service for all players.

In order to keep the Service and its social features safe and fair, to fight fraud and ensure acceptable use otherwise, we have a legitimate interest to process necessary data to

Analyze and monitor use of the Service and its social features
Moderate chats either automatically or manually
Take action against fraudulent or misbehaving players

To analyze, profile, and segment.

Legal basis: Legitimate interests or Your consent,where required by applicable laws.Within the purposes described above, we may analyze, profile, and segment collected data based on our legitimate interests, and obtain user consent where required by applicable laws.

In all of the above cases and purposes, we may analyze, profile and segment all collected data.

With your consent.

Legal basis: Your consent.

With your consent, we may process your data for additional purposes, such as using your GPS location to show you local events.

HOW WE DISCLOSE YOUR INFORMATION

We may disclose your personal information to third parties in the following circumstances for the purposes explained in this Policy.

We will only disclose your personal information for lawful, legitimate, necessary, specific, and explicit purposes, and we will only share the personal information required to provide the Services. We will require our partners, through agreements, to retain data only for the necessary period and to implement adequate security measures to protect data security.

We will disclose personal information to the following categories of third parties for the purposes explained in this Policy:

· Affiliates and corporate partners. We disclose the categories of personal information described above between and among our affiliates and related entities, for legitimate business purposes and the operation of the Services, in accordance with applicable laws.

· Service providers and business partners. Third-party service providers who provide us with IT services (such as cloud storage service) and business support (such as statistical analysis and/or advertising service provider) may need to process your data. These third parties will process your personal information on our behalf under relevant contracts.

· Law enforcement agencies, public authorities or other judicial bodies and organizations. We disclose your personal information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to comply with a legal obligation, process or request; enforce our [Terms of Service] and other terms, policies, and standards, including investigation of any potential violation thereof; detect, prevent or otherwise address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by applicable laws (including exchanging information with other companies and organizations for the purposes of fraud protection).

· Change of corporate ownership. If we are involved in a merger, acquisition, bankruptcy, reorganization, partnership, asset sale or other transaction, we may disclose your personal information as part of that transaction.

HOW DO WE PROTECT MINORS

Our Services are not directed towards, and we do not knowingly collect personal information from children under 18 years old, unless permitted to do so by applicable law. If we become aware that we have unknowingly collected personal information from a child, we will make commercially reasonable efforts to delete such information in our database. If you are a parent or guardian of a child, and you believe your child has provided us with their Personal Information on our Services, please contact us immediately using the contact details provided in Section [CONTACT US].

HOW DO WE PROTECT YOUR DATA

We are committed to ensuring the security of your personal information. We have physical, technical and administrative safeguards in place to protect the confidentiality of your personal information. In addition, we require that our service providers handling personal information also maintain appropriate physical, technical and administrative safeguards to protect the security and confidentiality of the personal information you provide to us.

Although we will implement all reasonable measures to protect your personal Information, we cannot guarantee its absolute security of your personal information or ensure that loss, misuse, unauthorized acquisition, or alteration will not occur. We also have no way of protecting any of your personal information that is not in our control, such as any information transmitted via email or wireless connections.

Maintaining the security of your personal information is also your responsibility. Where we require you to register an account, you should choose a password of sufficient length and complexity and keep your password confidential. Do not leave your device unlocked so that other individuals may access it. Make sure you trust the wireless connections you are using to access or use our Services.

If you think there has been unauthorized access to or use of your account, please contact us immediately using the contact details provided in Section [CONTACT US]

COOKIES AND SIMILAR TECHNOLOGIES

At present, the Game does not use cookies or similar browser-based tracking technologies (such as web beacons, pixel tags, or local storage) to collect personal data.

If cookies or similar technologies are introduced in the future for functional, compliance, or operational purposes, we will update this Privacy Policy accordingly and, where required by applicable laws, obtain your prior consent.

HOW LONG DO WE KEEP YOUR PERSONAL DATA?

We adhere to retention policies for the personal information we collect to ensure that it is not retained longer than necessary for the intended purpose. Different retention periods are applied to the various types of personal information collected by us in accordance with the service needs and regulatory requirements.

Upon expiration of the retention period, we will either delete or anonymize your personal information. Measures will be taken to render the information irrecoverable or irreproducible.

When assessing how long your personal information is retained, we consider criteria such as: (i) the nature of the personal information and the activities involved; (ii) the time when and for how long you use the Services; and (iii) our legitimate interests and our legal obligations.

INTERNATIONAL DATA TRANSFERS

Your personal information will be processed and stored on servers located in the Singapore. In line with the international nature of our business, your personal information may also be accessed by our affiliates or be transferred to third-party service providers and business partners, in connection with the purposes set out in this Policy. For this reason, we transfer personal information to other jurisdictions that may have different laws and data protection compliance requirements to those that apply in the jurisdiction in which you are located.

In the event of an international transfer of personal information, when required by applicable laws, we will provide an adequate level of protection for your personal information using various means, including implementing Standard Contractual Clauses or data transfer agreements that comply with applicable laws between our affiliates and third parties or any other lawful approach that permits the lawful transfer of personal information from those countries.

YOUR RIGHTS AND OPTIONS

Subject to applicable law and depending on where you reside, you may have some rights regarding your personal information, as described further below. If you have any other requests relating to the access of your personal information, please contact us using the contact details provided in Section [CONTACT US].

A. Data Access

You may have the right to know what personal information we process about you, including the categories of personal information, the business or commercial purposes for collection, and the categories of third parties to whom we disclose it and other information according to the applicable law. If you request a copy of your personal information that we hold, we will provide you with a copy without undue delay and free of charge, except where we are permitted by law to charge a fee.

B. Data Correction

You may have the right to request that we correct inaccurate personal information that we retain about you, subject to certain exceptions.

C. Data Portability

You may contact us to request the personal information you have provided to us in a structured, commonly used and machine-readable format and have it transferred to another controller, to the extent applicable.

D. Data Deletion

You have the right to delete your account and erase your personal information. Upon deleting your account, all your personal information will be deleted. Additionally, you may also request deletion of the personal information you provide by contacting us. If some of your personal information cannot be deleted, we will inform you of the reasons for not taking action.

Please note that we reserve the right to retain some of your personal information where there are valid grounds for us to do so under applicable laws.

E. Withdrawal of Consent

Where we process your personal information on the basis of your consent, you may withdraw your consent by contacting us. The withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal.

You may withdraw your consent to receiving direct marketing messages and/or emails by using the unsubscribe mechanism at the bottom of such communications, or by contacting us using the contact details provided in Section [CONTACT US].

F. Objection to the Processing

Subject to applicable laws, you may object to the processing of your personal information based on our legitimate interests where there are grounds relating to your particular situation by contacting us. Please note that we may have an overriding legitimate interest to keep processing your personal information, but we will let you know where this is the case.

G. Restriction to the Processing

If you would like to restrict our processing of your personal information, you may contact us. You have the right to restrict the processing of your data where one of the following applies:

the processing is unlawful and you oppose the erasure of relevant personal information;
for the purpose of establishment, exercise or defense of legal claims, you request us to retain your personal information that we were supposed to delete;
your objection regarding the accuracy of your personal information is pending our verification;
your request to object to the processing of your personal information is pending our verification.

H. Other Rights

Depending on your jurisdiction, you may be entitled to additional rights in relation to your personal information. For example, you may also have the right to lodge complaints with an applicable data protection authority if you consider that the processing of your personal information infringes any applicable data protection laws (for example, the EU GDPR). For United States residents, please find more details of your rights in Section[Special Information for U.S. State Residents] below.If you would like to contact us to exercise one or more of these rights, to ask a question about these rights or any other provision of this Policy or about our processing of your personal information, or to file a complaint about how we process your personal information, you may contact us using the contact details provided in Section [CONTACT US]. When submitting a right request, please specify the scope and basis of your request and provide us with the necessary information to verify your identity. We may contact you to confirm your identity in order to handle your request. We will respond to your request or complaint in due course under applicable data protection laws.

Special Information for U.S. State Residents

We collect personal information from and about you in the preceding 12 months as described in Section 【THE DATA WE COLLECT】above.

We disclose personal information with third parties for business purposes in the preceding 12 months as below. You also have the right to request for a list of third parties to which we have disclosed your personal information under certain State data protection laws.

Categories of personal information	Collected	Categories of Third Parties to Whom Disclosed
Identifiers (e.g., player ID, device ID)	YES	Service Providers (e.g., cloud hosting, analytics), Advertising Partners
Personal Records (e.g., support ticket info)	If provided	Service Providers (e.g., customer support platforms)
Commercial Information (e.g., purchase history)	YES	Service Providers (e.g., payment processors)
Internet Activity (e.g., gameplay data)	YES	Service Providers (e.g., analytics), Advertising Partners
Geolocation Data	YES (General); Precise (with consent)	Service Providers (e.g., analytics)
Inferences (e.g., player preferences)	YES	Advertising Partners
In addition to the disclosures described above, we may share any personal data we collect about you with our affiliates, to protect us or others, or in the event of a merger, sale, or other asset transfer. See the section “ HOW WE DISCLOSE YOUR INFORMATION” above for more information.

To the extent provided for by local law and subject to applicable exceptions, you may have the following rights:

Limit the Use of Sensitive Personal Information. “Sensitive personal information” may have different definitions and scopes according to applicable State data protection laws, but generally include personal race or ethnicity, religious beliefs, sexual orientation, personal health data, biometric data, financial data, credit data, online data of children under 13, and precise location data.

You have the right to request limitation of use and disclosure of your sensitive personal information, subject to certain exceptions. If you would like to limit the use of your sensitive personal information, please contact us by using the contact details provided in the Section [CONTACT US].

l Do Not Sell or Share My Personal Information. Certain data collection on our sites and applications by third parties for purposes of interest-based advertising and social media tools may be a “sale” or “sharing” under California privacy law. As defined by California law, we “sold” or “shared” certain data elements within the following categories of personal information: [Identifiers、Internet Activity 、Inferences] from the above.

If you would like to opt out of the sale or sharing of your personal information, Please contact us by using the contact details provided in the Section [CONTACT US].

Appeal. You may appeal our refusal to take action on a request by contacting us using the contact details provided in Section [CONTACT US].

The Right to Non-discrimination. You have a right to not be discriminated against for exercising any of your rights.

The Right to an Authorized Agent. You may have the right to designate another person to make a request on your behalf under certain State data protection laws. We verify all requests through email before taking any action and reserve the right to deny a request where we are unable to verify your identity satisfactorily. This also applies to requests submitted on your behalf by someone else.

If you would like to contact us to exercise one or more of these rights, to ask a question about these rights or any other provision of this Policy or about our processing of your personal information, or to file a complaint about how we process your personal information, you may use the contact details provided in the Section[CONTACT US]. According to applicable laws, we may request you to provide documents such as application form and proof of identity. We may contact you to confirm your identity in order to handle your request. We will respond to your request or complaint in due course under the applicable laws.