Privacy Policy and Collection Notice

1. Introduction

1.1 Ewings LLC ("We", "Us", "Our"), with the business located at Al Muntazah - E48 - C17, Abu Dhabi, United Arab Emirates, is committed to protecting and respecting Your privacy. We are dedicated to ensuring the protection of personal information We process in accordance with all applicable Australian Privacy Principles (APPs 1-13) under the Privacy Act 1988 (Cth). This Privacy Policy constitutes a Privacy Collection Notice as required under APP 5.

1.2 This privacy policy explains what personal information We collect from individuals ("You", "Your") who use Our services, products, applications, and Websites (Our "Services"). It also explains what information We collect automatically when You interact with Our Services, why We collect it, and the legal bases for such collection.

1.3 Ewings LLC is the entity and information handler responsible for Your personal information in accordance with the Privacy Act 1988.

1.4 As an entertainment-led business, We prioritise the quality, confidentiality, integrity, and availability of the information We hold and are committed to meeting Our information protection obligations when processing personal information. We employ a variety of technical and organisational measures to help protect Your personal information from unauthorised access, use, disclosure or loss, including encryption, access controls, secure storage, and regular security assessments.

1.5 We update this privacy policy from time to time in response to changes in applicable laws and regulations, to Our processing practices, and to the products and services We offer. When We make significant changes, We will notify You via In-Game Notifications. Please review this privacy policy periodically to check for updates.

2. What information do We collect and why?

2.1 Personal information under the Privacy Act 1988 means information or an opinion about an identified individual, or an individual who is reasonably identifiable, whether the information or opinion is true or not, and whether recorded in a material form or not. We collect and process the information You give Us, whether through interactions with Our Services, Our website, or by any other form of correspondence.

2.2 Information you provide to Us (with Your consent where required)

The categories of personal information We process include:

• Contact details (title/name/address/email address/phone number)
• Date of Birth
• Any information you share through Our social media channels

2.3 Registration via Google

2.3.1 You may register for and access the application using Your Google account. If You choose this option, We will receive certain information from Google necessary to create and manage Your account, such as Your name, email address, and profile picture (if applicable). This information is provided in accordance with Google's privacy policy and with Your consent at the time of registration. We do not receive or store Your Google account password.

2.3.2 By registering via Google, You authorise Us to use the information provided by Google for the purposes of account creation, authentication, and the provision of the application in accordance with this privacy policy. You may revoke this authorisation at any time through Your Google account settings; however, doing so may limit or prevent Your ability to access the application.

2.3.3 By registering for Good Gamin via Google:

• 2.3.3.1 You represent and warrant that all information provided through Your Google account is true, accurate, current, and complete, and You accept full responsibility for ensuring its accuracy and for promptly updating it where necessary;
• 2.3.3.2 You acknowledge that We are entitled to rely on the information provided through Your Google account without any obligation to verify its accuracy;
• 2.3.3.3 You agree that any loss, liability, or damage arising from the provision of false, inaccurate, or incomplete information shall be solely Your responsibility; and
• 2.3.3.4 You acknowledge that if You revoke Our access to Your Google account or if Your Google account is suspended or terminated, this may limit or prevent Your ability to access the application.

2.4 Information We collect from You (collected only by lawful and fair means)

When You use Our Services, We may collect:

• Device details (including device identifiers, operating system information, and browser type)
• Login information and credentials
• Service usage data including interactions, preferences, and time spent using Our Services
• Location data (approximate location based on IP address or precise location with Your explicit consent where applicable)
• Information required for legal and regulatory compliance including identity verification documents where required by law

2.5 We may use cookies and similar tracking technologies to personalise the user experience of Our Services, which may be disabled at any time using the privacy settings in Our Services or on Your device. By continuing to Use Our Services, You consent to Our use of these technologies as described in this policy.

3. Purposes and lawful bases for processing Your personal information

3.1 We may Use Your information for the following purposes and on the following lawful bases (Use and disclosure):

• Performance and delivery of Our Services in accordance with Our terms and conditions (primary purpose of collection)
• Providing information on Your account, such as transaction history, rewards, and trends (primary purpose of collection)
• Prevention and detection of crime, including money laundering, fraud, or other crimes (legal obligation and legitimate interests)
• Compliance with sector-specific laws, regulations, and guidelines (legal obligation)
• Providing you with updates about Our Services, additional features, and exclusive promotions (with Your consent, which may be withdrawn at any time). You may unsubscribe or opt out of receiving marketing communications from Us, including email and WhatsApp promotional material, at any time by following the "unsubscribe" or "opt-out" instructions provided in such communications or by adjusting Your preferences in the Application. Please note that opting out of marketing communications will not affect Our ability to send You non-marketing communications related to Your account, the application, or transactions You have initiated.
• Improving Our Services and the overall user experience.
• Ensuring maintenance of a secure connection between Our Services and Your device.
• Initiating action against any User who acts outside any laws, regulations, or Our Terms and Conditions.

3.2 Where personal information is processed because it is necessary for the performance of a contract to which you are a party, We will be unable to provide Our Services without the required information. Where processing is based on consent, You have the right to withdraw consent at any time by contacting Us using the details provided below.

4. Sharing Your information and overseas disclosure

4.1 We may share Your personal information with recipients located outside Australia. These recipients may be located in the United States, European Union, United Kingdom, United Arab Emirates, and Singapore. Before disclosing Your personal information to overseas recipients, We take reasonable steps to ensure that the overseas recipient does not breach the APPs in relation to Your personal information, or We obtain Your consent for the disclosure. We ensure appropriate safeguards are in place through contractual arrangements with these recipients.

4.2 We may share Your information with service providers and suppliers to Our business who process information on Our behalf, including cloud service providers, payment processors, analytics providers, and customer support services. In such cases, Our service providers and suppliers are information processors and may only Use the information in line with Our instructions and not for any other purpose. We maintain appropriate contracts with these parties.

4.3 Our Services include links to Our social media pages, enabling You to view Our content through selected sites. These applications may collect Your IP address or device ID and may set a cookie on Your device. Please read the privacy policies provided by the particular social media Website You are sharing through before posting any personal information using these links, as We are not responsible for how these third parties collect or handle Your information.

5. Your rights

5.1 Under the Privacy Act 1988 and the APPs, You have certain rights in relation to Your personal information, including to:

• Request access to personal information about You. We will respond to Your request within 30 days and provide the information in a clear and accessible format
• Request rectification, correction, or updating to any of the personal information that We hold about You. We will respond to correction requests within thirty (30) days
• Request personal information provided by You to be transferred in machine-readable format
• Request erasure of personal information (subject to legal retention requirements and legitimate business needs)
• Request the restriction of processing of Your personal information
• Object to the processing of Your personal information in certain circumstances

5.2 If at any time You decide that You no longer wish to be contacted for marketing purposes, or if You would like to exercise any of Your rights as set out above, You can contact Us at privacy@ewings.com. To protect Your privacy, We may require verification of Your identity before responding to such requests. You will not have to pay a fee to access Your personal information (or to exercise any of the other rights). However, We may charge a reasonable fee if Your request for access is clearly frivolous or vexatious or refuse to comply with Your request in these circumstances.

5.3 In addition to the above, please note that you have the right to make a complaint at any time to the Office of the Australian Information Commissioner (OAIC) if you are concerned about the way in which We are handling Your personal information. We encourage You to contact Us first to resolve Your concern. The OAIC can be contacted at www.oaic.gov.au, by phone on 1300363992 (within Australia), or by email at enquiries@oaic.gov.au.

6. Data retention period and security

6.1 We will retain Your personal information only for as long as is necessary for the purposes set out in this Privacy Policy.

Specifically, We retain:

• Account information for the duration of Your account plus seven (7) years following account closure
• Transaction data for seven (7) years to comply with tax, financial and Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) laws and regulations
• Communications with Our customer service team for three (3) years
• Marketing preferences for two (2) years from Your last interaction with Us
• When a retention period ends, We securely destroy or de-identify the information

6.2 In some circumstances, We are legally obligated to retain information for longer periods to comply with legal obligations related to crime prevention, anti-money laundering requirements, tax regulations, or other specific legal requirements.

6.3 At the end of the retention period, Your personal information will be securely deleted or anonymised in accordance with Australian Data Privacy Law. Our destruction methods ensure that information cannot be recovered or reconstructed.

7. Contact Us

You can contact Us in relation to information protection and this privacy policy by: