Privacy Policy

1. Introduction

1.1 Ewings LLC ("We", "Us", "Our"), with its principal place of business at Al Muntazah – E48 – C17, Abu Dhabi, United Arab Emirates, is committed to protecting and respecting Your privacy. We are dedicated to ensuring that personal information We process is handled responsibly and in accordance with international standard data protection measures and generally accepted privacy principles.

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 responsible for determining how and why Your personal information is processed.

1.4 As an entertainment-led business, We prioritise the quality, confidentiality, integrity, and availability of the information We hold and are committed to protecting it through appropriate safeguards. We employ a variety of technical and organisational measures to prevent unauthorised access, use, disclosure, or loss, including encryption, access controls, secure storage, and periodic security assessments.

1.5 We may update this Privacy Policy from time to time, without having to give notice, in response to changes in applicable laws, Our processing practices, or the products and services We offer. Please review this Privacy Policy periodically to stay informed.

2. What information do We collect and why?

2.1 Personal information means information that identifies or can reasonably identify an individual, whether true or not and whether recorded in material form or otherwise. We collect and process information You give Us directly or that is automatically generated through Your interaction with Our Services.

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 external accounts (including but not limited to Google or Apple)

An external account ("External Account") means an account that is associated with a third-party that can be selected upon registration or login to retrieve Your credentials.

2.3.1 You may register for and access the application using an External Account. If You choose this option, We will receive certain information from the External Account provider 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 the respective provider's privacy policy and with Your consent at the time of registration. We do not receive or store Your External Account's password.

2.3.2 By registering via an External Account, You authorise Us to use the information provided by the External Account provider for account creation, authentication, and provision of the application in accordance with this Privacy Policy. You may revoke this authorisation at any time through Your External Account provider's account settings (if available); however, doing so may limit or prevent Your ability to access the application.

2.3.3 By registering for Good Gamin via an External Account:

• You represent and warrant that all information provided through Your External Account is true, accurate, current, and complete, and You accept responsibility for keeping it up to date
• You acknowledge that We may rely on the information provided through Your External Account without obligation to verify its accuracy
• You agree that any loss or damage arising from false or inaccurate information is solely Your responsibility
• You acknowledge that revoking Our access to Your External Account, or any suspension or termination of that account, 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 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 based on IP or precise with Your consent)
• Information required for legal or regulatory compliance, including identity-verification documents where required

2.5 Cookies and tracking technologies

We may use cookies and similar technologies to personalise and improve Your user experience. You can disable them at any time in Your device or in-app settings. Continued use of Our Services constitutes consent to such use.

3. Purposes and lawful bases for processing Your personal information

3.1 We may use Your information for the following purposes and lawful bases:

• To perform and deliver Our Services in accordance with Our terms and conditions
• To provide information on Your account, including transaction history, in-app rewards, and activity trends
• To enable gameplay functionality, matchmaking, leaderboard features, in-app communication, and other core interactive elements of Our gaming platform
• To prevent and detect fraud or other unlawful activities and to maintain the security and integrity of Our Services
• To comply with applicable laws and regulations
• To provide updates, new features, or promotional offers (with Your consent, which may be withdrawn at any time)
• To improve Our Services, analytics, and user experience
• To maintain a secure connection between Our Services and Your device
• To take action against Users who violate any laws, regulations, or Our Terms and Conditions

3.2 Where We process personal information to perform a contract with You, We may not be able to provide Our Services if You do not provide the necessary information. Where processing is based on consent, You may withdraw it at any time using the contact details below.

4. Sharing Your information and international transfers

4.1 We may share or transfer Your personal information with recipients located outside of Your country of residence. These recipients may include cloud-hosting providers, payment processors, analytics partners, or affiliated entities that support the operation of Our Services as We aim to guarantee the best available technology and services. Where We transfer personal information internationally, We take appropriate steps to ensure that adequate safeguards are in place and that the receiving country guarantees an adequate level of protection. Such safeguards include contractual protections, technical security measures, or compliance with recognised international data-protection standards.

4.2 We may also share information with service providers that process data on Our behalf (for example, IT, support, or marketing providers). Such processors are bound by contractual obligations to keep Your information secure and to use it only in accordance with Our instructions.

4.3 Our Services may include links to social-media pages or external websites. These third-party platforms may collect information such as Your IP address or device ID and may set cookies. Please read their privacy policies before sharing any personal information, as We are not responsible for their data practices.

5. Your rights

5.1 Depending on the laws of Your country, You may have certain rights regarding Your personal information, including to:

• Request access to the personal information We hold about You
• Request correction or updating of inaccurate information
• Request erasure of personal information, subject to legal retention obligations
• Request restriction or object to certain types of processing
• Request data portability in a machine-readable format

5.2 To exercise any of these rights or to withdraw consent for marketing communications, You may contact Us at privacy@ewings.com. We may request verification of Your identity before processing such requests.

5.3 If You have concerns about how We handle Your information, We encourage You to contact Us first so that We can address Your complaint. You may also have the right to lodge a complaint with Your local data-protection authority.

6. Data retention and security

6.1 We retain personal information only for as long as necessary for the purposes described in this Policy. For example:

• Account data is retained for the duration of Your account and for up to seven (7) years after closure
• Transaction data is retained for legal and compliance purposes for up to seven (7) years
• Customer-service communications are kept for three (3) years
• Marketing preferences are retained for two (2) years from Your last interaction

6.2 We may be required by applicable laws to retain certain data for longer periods (for example, for tax, anti-money-laundering, or crime-prevention obligations).

6.3 When retention periods expire, We securely delete or anonymise the data in accordance with standard international data-protection practices, ensuring it cannot be recovered or reconstructed.

7. Contact Us

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