PRIVACY POLICY

The Monty Cloud Gaming Platform is owned and managed by Monty Mobile International Ltd, a company duly incorporated and registered in Seychelles under company registration number 065785, whose registered office is at 306 Victoria House, Victoria, Mahe, Seychelles (referred herein as “Monty Mobile”).

1. Introduction

At Monty Cloud Gaming we want to provide you with the best possible experience to ensure that you enjoy our service today, tomorrow and in the future. In order to do so, we need to know your gaming habits, so that we can offer you an exceptional and personalized service.

Having said that, the privacy and security of your personal data is of great importance to us. For this reason, we want to clearly explain how and why we collect, store, share and use your personal data, and show you the controls and options available for you to choose when and how you share your personal data.

That is our goal and we will explain it in more detail in this Privacy Policy ("Policy”).

2. About this Policy

This Policy provides essential information regarding the use that Monty Mobile International Ltd, (owner of the Monty Cloud Gaming platform, hereinafter “Monty Cloud Gaming“) makes of your personal data. The Policy applies to all Monty Cloud Gaming services and associated services (hereinafter the "Monty Cloud Gaming Service"). The terms governing the use of the Monty Cloud Gaming Service are defined in our Terms of Use and EULA (the "Terms of Use").

Regularly, we may develop new services or offer additional services. If the introduction of these new or additional services generates any kind of change in the way we collect or process your personal data, we will provide you with more information and additional conditions or policies. Unless otherwise indicated, when these new or additional services are introduced, they will be subject to this Policy.

The main goal of this Policy is:

Ensure that you understand what personal data we collect about you, the reasons why we do so, and with whom we share it;
Explain the way in which we use the personal data that you share with us in order to control, manage and ensure the functionality of the Monty Cloud Gaming Service when you use it; and
Explain your rights and options regarding the personal data we collect and process about you and how we will protect your privacy.

We hope this helps to understand our commitment to your privacy.

If you have any questions or comments related to the processing of your data, you can send an email to cloudgaming.support@montymobile.com. If you do not agree with the content of this Policy, remember that you decide if you want to use the Monty Cloud Gaming Service.

3. Your rights and preferences: options and control

As you may already know, the new European Union regulation known as the General Data Protection Regulation (“GDPR”) gives people certain rights related to their personal data. The rights granted to people are:

Right of access: the right to be informed and request access to the personal data we process.
Right to rectification: the right to request that we correct or update your personal data, when they are inaccurate or incomplete.
Right to erasure: the right to request that your personal data be deleted.
Right to restriction of processing: the right to request that the processing of all or some of your personal data be temporarily or permanently stopped.
Right of opposition:
- the right, at any time, to object to the processing of your personal data for reasons related to your particular situation.
- the right to object to your personal data being processed for direct marketing purposes.
Right to data portability: the right to request a copy of your personal data in electronic format and the right to transmit such data for use in the service of a third party;
Right not to be subject to automated individual decision-making: the right not to be subject to decisions based solely on automated decision-making, including profiling, when the decision may have a legal effect on you or produce a similar significant effect.
Right to revoke at any time the consent granted through the Privacy Settings panel.

In order to allow you to easily exercise these rights and record your preferences regarding how Monty Cloud Gaming uses your personal data, we will provide you with access to the following settings through the Account Settings page:

Privacy settings: it allows you to control some of the categories of personal data that we process, and it allows you to access your personal data, change your avatar, as well as consent or revoke your consent regarding the commercial communications that you may receive from Monty Cloud Gaming.

You can contact Monty Mobile International Ltd, (Monty Cloud Gaming) at C/Reina Cristina, 9, Principal, 08003, Barcelona, Spain or you can contact us through cloudgaming.support@montymobile.com Ref: Data Protection, to exercise your rights. You must indicate the rights you want to exercise and prove your identity as an applicant when appropriate. Likewise, we inform you that you have the right to file a claim before the Spanish Data Protection Agency if you consider that there has been some type of violation in relation to the processing of your personal data.

4. How do we collect your personal data?

We collect your personal data as follows:

Checking in to Monty Cloud Gaming Service: When you register to create an account in the Monty Cloud Gaming Service, we collect certain personal data so you can use the Monty Cloud Gaming Service, such as an email and, afterwards, an username (alias) and coarse birth date (i.e. month and year). In those plans that require payment for their use, the data regarding the payment method is also collected and, therefore, the payment platform that uses the Monty Cloud Gaming Service ensures its correct protection.
Use of the Monty Cloud Gaming Service: when you use the Monty Cloud Gaming Service, we collect personal data about the use of the Monty Cloud Gaming Service, such as what games you have played, when you have done it and how long have you been playing each one, as well as what games have been selected as favorites from the Monty Cloud Gaming Service catalog. Each game has a classification of the minimum age that the user must be to be able to access and play the game. This classification is determined by the official classification, known as Pan European Game Information (“PEGI”), which establishes the appropriate minimum age to play video games according to their category. The PEGI has the purpose of guiding the consumer about the suitability of playing a specific game through the minimum age recommended by the PEGI. Therefore, when collecting data about the games the user plays, we can also collect PEGI data.
Collect personal data that allows us to provide you with additional features / functionalities: from time to time, we also offer you the possibility to provide us with additional personal data or to give us your permission to collect it; for instance, to provide you with more features or functionality.

We use anonymous and additional information for purposes that include testing our computer systems, research, data analysis, marketing and promotion modeling, improving the Monty Cloud Gaming Service, and developing new functionality and features within the Monty Cloud Gaming Service. However, since the data is anonymized, it dissociates itself from the person who owns the data, preventing its identification.

5. How and what personal data do we collect from you?

We have established in the tables below the categories of personal data that we collect and use about you:

Personal data collected when you register with the Monty Cloud Gaming Service

Personal data categories	Category description
Check-in data	It consists of the personal data that you provide or we collect to enable you to register and use the Monty Cloud Gaming Service. This includes your username, for the Monty Cloud Gaming Service, coarse birth date (i.e. month and year), and your email. At the same time, in order to record the acceptance by the user of the privacy policy and the terms and conditions of the Monty Cloud Gaming Service, we will register the email and the exact time (i.e. timestamp) in which the user has accepted it. The personal data that we request is necessary to create your account. However, you have the option to provide us with additional personal data in order to further personalize your account such as an image or avatar. The exact personal data that we collect may vary depending on the type of Monty Cloud Gaming Service plan that you have subscribed.

Personal data categories

Category description

Check-in data

It consists of the personal data that you provide or we collect to enable you to register and use the Monty Cloud Gaming Service. This includes your username, for the Monty Cloud Gaming Service, coarse birth date (i.e. month and year), and your email. At the same time, in order to record the acceptance by the user of the privacy policy and the terms and conditions of the Monty Cloud Gaming Service, we will register the email and the exact time (i.e. timestamp) in which the user has accepted it.

The personal data that we request is necessary to create your account. However, you have the option to provide us with additional personal data in order to further personalize your account such as an image or avatar.

The exact personal data that we collect may vary depending on the type of Monty Cloud Gaming Service plan that you have subscribed.

Personal data collected through your use of the Monty Cloud Gaming Service

Personal data categories	Category description
Monty Cloud Gaming Service usage data	These are the personal data collected when you use the Monty Cloud Gaming Service, and may include: Information about your type of Monty Cloud Gaming Service plan. Information about your interactions with the Monty Cloud Gaming Service, including the date and time of any requests you make and the games you have played and the games you have chosen as favorites. Messages you send and/or receive through Monty Cloud Gaming and your interactions with the Monty Cloud Gaming Customer Service team. Technical data that may include URL information, cookies data, your IP address, the unique device ID (to prevent undesired usage of the service) and the types of devices you use to access or connect to the Monty Cloud Gaming Service, device attributes, device and network performance, the type of browser (if you access from a web browser), the preferred language, Device Firebase Registration token (used to push messages to the app), the country you are connecting from, the information that allows the management of digital rights, operating system and version of the Monty Cloud Gaming application. You can find more information about the technical data that we process when you access from a web browser in our Cookies Policy.
Age	In the registration process, the user's age is requested in order to determine if he/she is a child and to activate the parental acceptance process and propose the games to the user within the informed age range with the recommendations of each video game based on their corresponding PEGI, which is a European system for classifying the content of video games and other types of entertainment software based on the users age.

Personal data categories

Category description

Monty Cloud Gaming Service usage data

These are the personal data collected when you use the Monty Cloud Gaming Service, and may include:

Information about your type of Monty Cloud Gaming Service plan.
Information about your interactions with the Monty Cloud Gaming Service, including the date and time of any requests you make and the games you have played and the games you have chosen as favorites.
Messages you send and/or receive through Monty Cloud Gaming and your interactions with the Monty Cloud Gaming Customer Service team.
Technical data that may include URL information, cookies data, your IP address, the unique device ID (to prevent undesired usage of the service) and the types of devices you use to access or connect to the Monty Cloud Gaming Service, device attributes, device and network performance, the type of browser (if you access from a web browser), the preferred language, Device Firebase Registration token (used to push messages to the app), the country you are connecting from, the information that allows the management of digital rights, operating system and version of the Monty Cloud Gaming application. You can find more information about the technical data that we process when you access from a web browser in our Cookies Policy.

Age

In the registration process, the user's age is requested in order to determine if he/she is a child and to activate the parental acceptance process and propose the games to the user within the informed age range with the recommendations of each video game based on their corresponding PEGI, which is a European system for classifying the content of video games and other types of entertainment software based on the users age.

Personal data collected with your consent to enable us to provide you with additional features or functionality

Personal data categories	Category description
Location data	Please note that we DO NOT access your GPS or Bluetooth to get the exact location of your mobile device. We use Google APIs to identify the country from the device is connected to validate the correct access and usage of the Monty Cloud Gaming service. For instance, the country or city where you are, to comply with our license agreements, offer features, information, advertising or any other content based on your location and use of the service. Besides, we use your IP address to ease the analysis to solve issues and validate the correct usage of the service.
Payment data	The personal data collected for the payment method will go directly to the payment platform used and therefore, the payment platform will be responsible for its correct management and protection. The exact personal data will vary depending on the payment method (for instance, directly through your mobile operator or by invoice), but may include information such as: Name and surname; Postal Code; Payment method, credit card or debit; If you decide to request an invoice, we will provide your personal data to our payment processors in order to carry out a credit check so that you can have the invoices you require.
Contests, raffles and survey data	This personal data is used to allow you to register and participate in these types of promotions. The exact personal data collected will vary depending on the promotion. Such personal information is used to allow Monty Cloud Gaming to send you marketing communications via email and push notifications.
Marketing data	Such personal information is used to allow Monty Cloud Gaming to offer games and other initiatives through the app alerts.
Google Play transaction	We collect information related to Purchases history including: Purchased subscription Purchase sources (Play Store or other future ones) Play Store purchase token: Used to uniquely ID a purchase on the store Play Store order ID Play Store country Paid price and currency Payment state: To determine if the purchase has been paid or not, before executing a game. Subscription state. PromotionCode: Determines if the user benefited from a promo. Cancelation reason and user comments. Start and Expire time of the subscription.

6. For what purpose do we use your personal data?

When you use or interact with the Monty Cloud Gaming Service, we use different technologies to process your personal data for various reasons. The following table shows the purposes of the processing of your personal data, the associated legal bases which allows us to process your personal data, and the categories of personal data (identified in section 5 " How and what personal data do we collect from you?") used for the following purposes:

Description of why Monty Cloud Gaming processes your personal data ("processing purpose")	Legal basis for the processing purpose	Categories of personal data used by Monty Cloud Gaming for the processing purpose
Provide and customize the functionality of the Monty Cloud Gaming Service according to the user.	Performance of Contract Consent	Account registration data Service usage data PEGI acceptance data of the video game
To understand the use of the Monty Cloud Gaming Service to improve the functionality of the service, develop new products and services provided by Monty Cloud Gaming, and analyze its use.	Consent and acceptance of this Privacy Policy, Cookies Policy and Terms of Use of the Monty Cloud Gaming Service.	Service usage data
To offer the user functions, information, recommendations, advertising or any other content based on their use of the service, including its location.	Consent	Service usage data Location data
To understand the use of the service to ensure the technical functionality of the Monty Cloud Gaming Service.	Performance of Contract Legitimate interests	Account registration data Service usage data PEGI acceptance data of the video game
To communicate with you for purposes related to the Monty Cloud Gaming Service.	Performance of Contract	Account registration data Service usage data
To validate your payment to prevent or detect fraud, including fraudulent payments and fraudulent use of the Monty Cloud Gaming Service, and manage billing services.	Performance of Contract To comply with legal obligations	Payment data
To communicate with you regarding your participation in surveys, contests, raffles and promotions.	Consent	Contests, raffles and survey data Marketing data

7. Shared use of your personal data

This Section introduces the different categories of the recipients of the personal data collected or generated through your use of the Monty Cloud Gaming Service.

Publicly available information

The following personal data will always be publicly available on the Monty Cloud Gaming Service: Avatar and username that will be shared with other Monty Cloud Gaming users who use the service.

Information that we can share

Recipient Category	Sharing purpose
Service providers and other collaborators	We use technical service providers that procure the technical infrastructure we need to provide the Monty Cloud Gaming Service, in particular the providers that host, store, manage and maintain the Monty Cloud Gaming application, its content and the data we process. We use technical service providers to help us communicate with you, as described in Section 6 of this Policy, among others, for the resolution of technical incidents that may lead to an exchange of questions-answers-technical data that we may need in order to resolve the incident. We use marketing and advertising partners to display more personalized content, or to help us understand your use of the Monty Cloud Gaming Service provide you with a better service. We may also share personal data with some marketing or advertising partners or providers in order to send you promotional communications about Monty Cloud Gaming. We may also share your personal data in a pseudonymized format with our industry partners to help them understand how activities and games work on Monty Cloud Gaming. Similarly, we share your personal data in a pseudonymized format with marketing partners who help us with promotional activities, and with advertisers who allow us to offer a free service.
Academic researchers	We will share your personal data for activities such as statistical analysis and academic study, but only in a pseudo-anonymised format.
Other trading companies	We will share your personal data with other companies with which there are marketing agreements to carry out our daily business operations and to enable us to maintain and provide the Monty Cloud Gaming Service. We will share your personal data in order to comply with a legal obligation under applicable law, or to respond to a valid legal process, such as a search warrant, court order, or subpoena.
Compliance with the law and data protection authorities	We may also share your personal data when we believe in good faith that it is necessary for our own interest or the legitimate interest of third parties related to national security, law enforcement, lawsuits, criminal investigation, protection of the safety of any person, or avoid imminent death or bodily harm, provided that we consider that such interest is not overridden by your interests or the fundamental rights and freedoms that require the protection of your personal data.

8. Data retention and erasure

We retain your personal data only for the time necessary to provide the Monty Cloud Gaming Service and for legitimate and essential business purposes, such as maintaining the performance of the Monty Cloud Gaming Service, making data-driven business decisions about new features and offerings, complying with our legal obligations and resolving disputes. We retain some of your personal data while you are a user of the Monty Cloud Gaming Service.

Upon request, we may delete or anonymize your personal data so that you are not identified, unless, we can or are legally required to retain certain personal data, including the following cases:

If there is an unresolved issue related to your account, such as pending payments on your account or an unresolved claim or dispute, we will retain the necessary personal data until such issue is resolved;
When we are obliged to retain personal data to comply with our legal, tax, accounting and auditing obligations, we will keep the necessary personal data for the period required by applicable law; and/or
When necessary for our legitimate business interests, such as fraud prevention or maintaining the security of our users.

9. Transfer to other countries

Monty Cloud Gaming does not share your personal data with other companies located outside the territory of the EU.

10. Links

We may display third party advertisements and other content linked to third party websites. We cannot control or be responsible for the privacy practices and content of third parties. If you click on a third-party advertisement or link, you understand that you are leaving the Monty Cloud Gaming Service and any personal information you provide will not be covered by this Policy. Please read the privacy policies of the third parties responsible for the website you access to find out how they collect and process your personal data.

11. Protection of your personal data

We are committed to protect the personal data of our users. We implement the appropriate technical and organizational measures to help protect the security of your personal data. However, keep in mind that no system is completely secure. We have implemented various policies including pseudonymization, encryption, access and retention policies to protect against unauthorized access and unnecessary retention of personal data on our systems.

The password protects your user account, so we recommend that you use a unique and firm password, to limit access to your computer and browser, and log out after using the Monty Cloud Gaming Service.

12. Conditions applicable to child's consent in relation to Monty Cloud Gaming services

Pursuant to the GDPR the processing of a child's personal data is lawful when the child is at least 16 years old. If the child is under 16 years of age, such process shall only be considered lawful if and only to the extent that consent was given or authorized by the holder of parental authority or guardianship over the child. Member States may provide by law for a lower age for such purposes, provided that it is not less than 13 years. In the case of Spain it is set at 14 years. Monty Cloud Gaming will make reasonable efforts to verify that consent was given or authorized by the holder of parental or guardianship over the child, taking into account available technology.

In case you have any doubt or comment regarding Monty Cloud Gaming's parental control process or you want to inform us about any aspect related to a child, you can do it by email (using the email cloudgaming.support@montymobile.com). Monty Cloud Gaming will act with total confidentiality in the analysis of the information provided.

13. THIRD PARTY SERVICES: DISCLAIMER OF WARRANTIES AND LIABILITIE

Monty Cloud Gaming offers to its users a Free to Play access to other third party games that are not related to Monty Cloud Gaming. That means that Monty Cloud Gaming may contain links or facilitates access to third party websites and platforms Monty Cloud Gaming which may also collect, use and share information about you and your device and your usage of the game while you are on that third party site. In this sense, you must take into consideration that Monty Cloud Gaming’s terms and conditions and privacy policies do not cover nor regulate nor control any third parties' products, actions or services. For more information about third-party practices, please consult their own terms and conditions and privacy policies.

If you access third party sites through Monty Cloud Gaming, you do it freely and without any responsibility for Monty Cloud Gaming. Monty Cloud Gaming will process the correspondent data at all times according to our Privacy Policy, which you can visit here.

Monty Cloud Gamings reserves the right to terminate your access to the third party website or platform through Monty Cloud Gaming, as well as the provision of any or all content provided through it at any time and without notice, for technical, security, maintenance or power failure reasons or any other reasonable cause. Accordingly, Monty Cloud Gaming does not guarantee the reliability, availability or continuity of a third party site or its content, so that the use of them by users is done at their own risk, and Monty Cloud Gaming cannot be held accountable for the discontinuance or unavailability of such services.

In accordance with the above, Monty Cloud Gaming is in no way responsible for any damages caused and disclaims any and all warranties or conditions, express, statutory and implied, including, by way of example and without limitation:

by errors or missing information in the content published by third parties;
by temporary unavailability of the third party website, app or platform;
warranties or conditions of uninterrupted or error-free access or use;
for the content of the information collected in the third party website or platform, nor for those opinions, comments, insights or other communications that are not issued directly by Monty Cloud Gaming;
for any banned user account of the third party website or platform done by the third party, due to the user's misbehavior or any other reason, such as the detection of viruses, use of automated software or bots, perform in-game services, suspicious IP addresses, etc, as stated in the Terms and Conditions of the correspondent third party, for which Monty Cloud Gaming has no control nor liability;
for the unsuccessful access to the third party website or platform through Monty Cloud Gaming;
by any situation considered fortuitous or by unforeseen circumstances, despite having adopted all the reasonable technological measures necessary to avoid is, as defined in clauses 5.3 and 8 of Monty Cloud Gaming's EULA;

The exclusion of damages under this paragraph is independent of your exclusive remedy and survives in the event such remedy fails of its essential purpose or is otherwise deemed unenforceable.

These limitations and exclusions apply without regard to whether the damages arise from (a) breach of contract, (b) breach of warranty, (c) negligence, or (d) any other cause of action, to the extent such exclusion and limitations are not prohibited by applicable law. In case you do not agree with any of the above, or you have any dispute or claim against Monty Cloud Gaming or its suppliers with respect to the above, then your sole and exclusive remedy is to discontinue using the Monty Cloud Gaming Platform, its data, its brand and related links.

14. Avatar or Profile Picture

We inform you that if you add your own image as a profile picture, it will be public and any person or user will be able to access and view it. To configure the Privacy of the profile picture you have chosen, you must access the Profile Settings.

15. Developer App Data

The developer of the Monty Cloud Gaming app is:

Ludium Lab, S.L

C/Reina Cristina, 9, Principal

PC 08003

Barcelona, Spain

16. Changes to this Privacy Policy

Occasionally, we may make changes to this Policy. If we make material changes, we will provide you with a prominent notice under the circumstances, for example, by displaying one in the Monty Cloud Gaming Service or by sending you an email. We can notify you in advance.

Therefore, be sure to read any notification carefully.

17. How to contact us

If you have any questions about this Policy, please contact our Data Protection Officer by email to cloudgaming.support@montymobile.com or by writing at the following address:

Monty Mobile International Ltd, (Monty Cloud Gaming)

306 Victoria House,

Victoria, Mahe, Seychelles

The Data Controller is Monty Mobile International Ltd, (owner of the Monty Cloud Gaming Platform).

TEXT TO INCLUDE IN THE SPACE ADDRESSED TO INCLUDE IN THE PAYMENT FORM WHERE PERSONAL DATA ARE COLLECTED (BILLING)

You authorize Monty Cloud Gaming to automatically charge you each month until you cancel your subscription. You consent to gain access to your Monty Cloud Gaming subscription immediately and agree that it is only possible to make a return within 14 days if you have not accessed Monty Cloud Gaming. You have the full conditions and instructions to cancel here.