(updated as of July 2023)

General Information

FOCGames is committed to protecting the privacy of all who use our websites and

applications. This privacy statement is provided to offer transparency regarding FOCGames'

privacy practices and principles. It provides information about the data we collect from

visitors to our website Focgames.com.

The FOCGames website is intended for visitors over 15 years old. If you are under 16, this

website is not intended for you. This website is safe for children under 16, but it is not

recommended. If you have any questions related to this Privacy Policy, please contact us

through one of the provided contact methods.

Currently, content management and privacy policy control of the website are exclusively

handled by AFRICA TRADING COMPANY INTERNATIONAL BUSINESS SARL

(SNDKR2012B5557) based in Dakar, and thus under the jurisdiction of the country

currently limited in this regard. However, for this reason, we have chosen to follow the

rules imposed by the European Union and have various partners and support contacts in

Europe who oversee the ongoing project, particularly in Portugal, who can provide

assistance, if necessary, in this sensitive and important matter. All contacts for

FOCGames.com are available on the respective contact page of this website, and we also

have legal support in Senegal and Portugal.

In the textual information, "we," "our," or "FocGames" refers to the current content

manager of the website and its privacy policy, namely AFRICA TRADING COMPANY

INTERNATIONAL BUSINESS SARL.

What data is used, and for what purposes?

All features of the FOCGames website are available without the need for registration by

website visitors. We do not request or process personal data (such as email addresses and

phone numbers) from website visitors unless they actively contact us.

However, FOCGames collects certain electronic data. We may process this data in various

ways. Below is some information about our general data processing. Afterward, we will

provide an overview of various topics you can click on to obtain more detailed information

about the processing of your data in each context.

General Purposes of Data Processing

In general, we can always process your data for the following purposes:

- For website maintenance, administration, security, and networking;

- For internal control and business operations;

- For analysis and improvement of our products;

- For handling requests, complaints, and disputes;

- To determine, exercise, and defend our rights; and

- To fulfill legal obligations (including fraud prevention) and requests from authorized

government institutions.

General Legal Bases for Data Processing

In general, we can process your data based on a legal obligation. This means we will

process your data to the extent we are legally required to do so, for example, to comply

with legal retention periods.

Legitimate Interest

Sometimes, we indicate that we process your data based on the legal basis of "legitimate

interest." This means that we balance the interests served by the processing, on the one

hand, and your privacy interests, on the other hand, and that the interests in favor of the

processing prevail. The related legitimate interests are included below by topic. If you wish

to get more information about this matter, you can directly contact us through our

provided contact details.

Minors and Other Persons with a Legal Representative

The FOCGames website is not intended for individuals under 16 years old. We also do not

focus on individuals who are under a legal relationship, such as guardianship, or individuals

who are supervised or managed by another person. If, in exceptional cases, we focus on

such individuals, FOCGames will take into account the vulnerable position of these

individuals and take additional precautions, as is the case with our FOCGames website.

FOCGames Website in General

We process your data to provide, maintain, and improve the FOCGames website, our

applications, and our activities on social networks. For specific information about cookies

and similar technologies used in this context, please refer to our Cookie Policy.

Involved Individuals: Our Website Visitors - People who visit the FOCGames website.

Purpose of Data Processing: When you visit the FOCGames website, we process your data

for the following purposes:

- Functioning of the FOCGames website (including remembering your settings and consent

options);

- Targeted advertising and marketing to you, relevant advertisements, and presentation of

privacy information relevant to your region (the exact data we process will depend on the

region from which you access the FOCGames website).

Processed Data: When you visit the FOCGames website, we may process the following

information about you, which is collected automatically:

- IP address;

- Device ID;

- Browser type;

- Global geographical location (e.g., national or city-level location);

- Advertisements displayed to you and your interaction with them (e.g., whether you

clicked on an ad or not);

- Other technical information (e.g., about the interaction between your device and the

FOCGames website, visited web pages, clicked links, and log data).

Sensitive Information: In the context of the FOCGames website, we do not process

sensitive information, such as health information, in principle. If, in certain cases, we

decide to process sensitive information, you will be informed separately about this

processing and, when necessary, we will request your explicit consent.

Legal Basis for Data Processing: We base the use of your data in the context of the

FOCGames website on one of the following legal bases:

- Consent: Sometimes, we base the processing of your data on the (explicit) consent of the

relevant person. This applies, for example, to cookies and similar technologies that we only

use if you have given your consent through a cookie pop-up message. For more

information about this, please refer to our Cookie Policy.

- Legitimate Interest: Our legitimate interest in offering and using the FOCGames website,

applications, and social networks, and pursuing the other processing purposes listed

above.

Social Media Platforms: FOCGames may use different social media platforms, for example,

for self-promotion and own or partner marketing purposes. FOCGames is not responsible

for managing social media platforms, but it is responsible, for example, for the content of

the FOCGames website that is shared through a social media platform. For more

information about how your data will be used by these social media platforms, please refer

to the information already available on the websites of these platform providers.

Support from FOCGames:

Involved Individuals: People who send an email, for example, through

info@soraiapublisher.top or gamesfoc@gmail.com

Purpose of Data Processing: When you contact FOCGames customer support or contact

FOCGames in another way, we process your data for the following purposes:

- Providing support to you;

- Responding to any questions you have asked us;

Processed Data: When you contact FOCGames customer support or FOCGames in another

way, we process the following information about you:

- Email address;

- Name (if provided);

The message you sent us and related metadata.

Legal Basis for Data Processing: We base the use of your data in the context of FOCGames

customer support on the legal basis of legitimate interest. This is our legitimate interest in

providing you support and responding to any questions you may have for us.

How do we obtain your data?

We obtain your data in various ways:

Provided by You: Some information about you is received directly from you. Examples

include information in your messages to us and information you enter in our application

form.

Internally Obtained: We may obtain your data through other FOCGames systems. An

example for game developers is data processing included in our CRM system.

Obtained from Third Parties: We may also obtain information about you from other

individuals or external entities. Specifically, we make use of this possibility in two

scenarios:

Website Visitors: We may receive information about you from private third parties, such as

in advertisements displayed on the FOCGames website. More information on this subject is

included in our Cookie Policy.

Applicants: We may obtain information from a reference provided by you in your

application.

Obtained Automatically: Some data is obtained automatically, for example, through

cookies and similar technologies. When your computer or mobile device contacts our web

servers (e.g., when you visit the FOCGames website), our web servers automatically collect

usage information. This usage information includes information about how our website

visitors use and navigate the FOCGames website. It may include the number and frequency

of website visitors on each web page and the duration of their visits, the type of browser,

and referring data that identifies the web page visited before and after visiting the

FOCGames website. More information on this subject is included in our Cookie Policy.

Derived Data: Certain data is not received directly but can be derived from information

already in our possession. For example, information about your language preferences.

In principle, you are not obligated to provide any information about yourself to us.

However, refusal to provide certain information may have a negative impact, for example,

on your experiences or functionalities on the FOCGames website. If providing certain

personal data is a legal or contractual obligation or an essential requirement for entering

into a contract with us, we will provide additional information on this matter, to the extent

not clear in advance. In that case, we will also inform you about the possible consequences

if such information is not provided.

With whom do we share your data?

We only share your data with third parties if:

- It is necessary for the provision of a service or the involvement of the third party.

Subcontractors, for example, will, in principle, only have access to the data they need for

their part in providing the service, for example, in advertising.

- Individuals within the third party who have access to the data are bound to treat your

data confidentially. When necessary, this is also agreed contractually.

- The third party is obligated to comply with the applicable regulations for the protection of

personal data, for example, because we have entered into an agreement with this party or

because our Terms of Use apply. This includes that the party is required to ensure

adequate technical and organizational security measures.

We may share your data with the mentioned parties below, when necessary, in principle,

only sharing your data on a need-to-know basis, meaning a party will only have access to

your data to the extent necessary for the professional services provided by this party.

- Authorized persons employed by FOCGames who are involved in the relevant processing

activity. Such as the support team members you are in contact with.

- Authorized persons employed by service providers/subcontractors contracted by

FOCGames who are involved in the relevant processing activity.

- Authorized persons employed by private sector entities with whom we may share certain

data, such as our game developers and advertising partners. Traffic information may be

shared with game developers and advertisers in an aggregated and anonymous form.

Additionally, advertisers on the FOCGames website may receive information collected by

cookies for targeted advertising purposes. More information on the use of cookies can be

found in our Cookie Policy.

- Authorized government institutions, such as courts, police, and law enforcement

agencies. We may disclose information about our website visitors when legally required to

do so, at the request of government institutions conducting an investigation, or to verify or

ensure compliance with the policies governing the FOCGames website and applicable laws.

We may also disclose user information whenever we believe such disclosure is necessary

to protect the rights, property, or safety of FOCGames, or any of our respective business

partners, customers, or others.

- Aggregated Information: We may also disclose aggregated and non-identifiable statistics

about users to third parties for various purposes, including describing our services to

potential partners and other third parties. Examples of such non-personal information

include the number of users who visited the FOCGames website during a specific period or

played a specific game.

How do we protect your data?

The protection of your privacy and data is very important to us. Therefore, FOCGames has

implemented appropriate technical and organizational measures to protect and ensure the

security of personal data, in order to prevent breaches of confidentiality, integrity, and

availability of data. All FOCGames employees and other individuals involved in data

processing are required to respect the confidentiality of personal data.

FOCGames has internal documentation describing how we safeguard an adequate level of

technical and organizational security. Additionally, we have a procedure for data breaches

within FOCGames, explaining how potential data breaches should be handled. We will

inform the competent supervisory authority and the affected data subjects when required

by applicable laws.

To which countries will we transfer your data?

Your data are transferred to a country where there is no adequacy decision or regulation.

However, we have voluntarily agreed to use the relevant version of the Standard

Contractual Clauses with the relevant party. This is a standard contract that safeguards the

protection of your data and is approved by the European Commission. You can find several

versions of the Standard Contractual Clauses by visiting this link. If necessary, additional

safeguards will be implemented.

The parties involved in processing your data, originating from the European Economic

Area, may be located in a different country. If data is processed outside the European

Economic Area, the transfer is legitimized as follows:

Transfers can be legitimized based on an adequacy decision by the European Commission,

confirming that the third country in question provides an adequate level of data

protection. You can find a summary of applicable adequacy decisions by visiting this link.

You can contact us if you wish to obtain additional information about how we legitimize

the transfer of your data to other countries. Our contact details are provided at the end of

this Privacy Policy.

Blocking Google Analytics: When you visit our website, your data will be shared with

Google for Google Analytics. Follow this link to enable or disable analytics.

How do we determine the retention period for your data?

In general, we do not retain your data for longer than necessary for the purposes of data

processing. However, there may be exceptions to the general retention periods.

Exception: Shorter retention period

If you exercise certain privacy rights, it is possible for FOCGames to remove your data

before the general applicable retention period, or conversely, retain it for a longer period.

Exception: Longer retention period

In certain situations, we may process your data for a longer period than necessary, such as

to comply with a minimum retention period or other legal obligations, for legal

proceedings, or to exercise the right to freedom of expression and information.

- Retention obligation: To comply with a minimum retention period or other legal

obligations we are subject to under applicable law.

- Legal proceedings: Your personal data is needed in relation to a legal proceeding.

- Freedom of expression: When further processing of your personal data is necessary to

exercise the right to freedom of expression and information.

What are your privacy rights (including the right to object)?

Based on the General Data Protection Regulation of Europe, which we aim to adhere to for

credibility and visitor trust, you have several privacy rights. The extent to which you can

exercise these rights may depend on the circumstances of the processing, such as how

FOCGames processes personal data and the legal basis for processing. For more

information about your privacy rights, visit this web page or this web page of the European

Commission.

We will respond to all requests promptly. If our response takes more than a month due to

complexity or the number of requests, we will inform you and keep you updated.

Additionally, please note that we may request more information to confirm your identity

before taking action on any request.

Your privacy rights.

Regarding our processing of your personal data, you have the following privacy rights.

Right to withdraw consent: To the extent that our processing of your data is based on your

consent, you have the right to withdraw your consent at any time through our contact

details provided below. The withdrawal of consent does not affect the lawfulness of

processing prior to the withdrawal. If you withdraw your consent, FOCGames will stop

processing your data for the purpose you gave consent to. However, we may still process

personal data for other purposes, such as to comply with a minimum retention period. In

such case, you will be informed.

Right of access: You have the right to request access to your data. This allows you to

receive a copy of the data we have about you (but not necessarily the documents

themselves). We will provide you with more information about our processing of your

personal data, such as the purposes for which we process your data, where we obtained it,

and with whom we share it.

Right of rectification: You have the right to request the rectification of your personal data

that we have. This allows you to correct any incomplete or inaccurate data we have about

you. You have this right if we process personal data about you that: is factually inaccurate;

is incomplete or unrelated to the purpose for which it was collected; or is being used in a

way that conflicts with applicable law.

The right of rectification is not intended to correct opinions, conclusions, or professional

findings with which you disagree. However, FOCGames may consider including your

opinion on the matter in your data.

Right to erasure: You have the right to request the erasure of your personal data. This

allows you to ask us to delete or remove your data when: the data is no longer necessary,

you have withdrawn your consent, you have objected to processing activities, the data has

been processed unlawfully, the data must be erased based on a legal requirement, or the

data has been collected in connection with the offer of information society services.

However, we do not have to comply with your request to the extent that processing is

necessary: to exercise the right of freedom of expression and information, to comply with

a legal obligation that requires processing, for reasons of public interest in the area of

public health, for archiving purposes, or for the establishment, exercise, or defense of legal

claims.

Right to object: You have the right to object to the processing of your data when we base it

on legitimate interests as a basis for processing (see above). In respect to processing your

data for direct marketing purposes, we will always respect your request. In the case of

processing for other purposes, we will also cease processing unless we have compelling

legitimate grounds that override your interests, rights, and freedoms, or that are related to

the establishment, exercise, or defense of a legal right. If this is the case, we will inform

you of our compelling justifications and the balancing of interests made.

Right to restriction of processing: The right to restriction of processing means that

FOCGames will continue to store personal data at your request but will, in principle, do

nothing further with it. In essence, you have this right when FOCGames no longer has (or

no longer has a legal basis for) processing your data or if it is under dispute. This right

specifically applies in the following situations:

Unlawful processing: We may not process certain personal data (or cease processing)

when you do not want us to delete it. For example, because you may still wish to request

the data at a later stage.

Data no longer needed: FOCGames no longer needs your data for our processing purposes

but still needs the personal data for a legal claim. For example, in case of a dispute.

Awaiting appeal: If you have objected to the processing of your data by FOCGames (see

the right to object above). While we verify your appeal, we will cease processing this

personal data at your request.

Contested accuracy of data: You have contested the accuracy of certain data we process

about you (e.g., through the right of rectification; see above). While we assess your

challenge, we will cease processing this personal data at your request.

Right to data portability: You have the right to request the transfer of your data to yourself

or to a third party of your choice (right to data portability). We will provide you, or that

third party, with your personal data in a structured, commonly used, and machine-

readable format. Note that this right only applies to processing carried out by us through

automated means and only if the basis for such processing is your consent or the

performance of a contract of which you are a party (see above).

Automated decisions: You have the right not to be subject to a decision based solely on

automated processing, which significantly affects you ("which produces legal effects that

concern you or significantly affect you"). In this regard, we inform you that in processing

your personal data, we do not use automated decisions that significantly affect you.

Right to lodge a complaint: In addition to the rights mentioned above, you have the right

to lodge a complaint with a supervisory authority. You can visit this web page for an

overview of EU supervisory authorities and their contact details. However, we would

appreciate the opportunity to address your concerns before you approach them, so please

How to exercise your rights: You can exercise your privacy rights free of charge, by phone,

or by email, using the contact details provided below. If requests are manifestly unfounded

or excessive, particularly due to their repetitive character, we may charge a reasonable fee

or refuse to comply with the request.

Identity verification: We may request specific information to help us confirm your identity

before responding to your privacy request.

Tracking your requests: We will provide information about the progress of the request

without undue delay and, in principle, within one month of receiving the request.

Depending on the complexity of the request and the number of requests, this period may

be extended by two more months. We will notify you of such an extension within one

month of receiving the request. Applicable (privacy) legislation may allow or require us to

refuse your request. If we cannot comply with your request, we will inform you of the

reasons, subject to any legal or regulatory restrictions.

Who is responsible for the processing of your data?

AFRICA TRADING COMPANY INTERNATIONAL BUSINESS SARL is primarily responsible for

processing your data in the context of the FOCGames website and may provide information

to partners in Europe.

Developers: If developers collect personal data for their purposes, FOCGames is not

responsible for this processing: only the developer decides what (personal) data will be

processed and for what purpose. They may only include cookies and similar technologies in

their games if it is not necessary to obtain consent based on applicable law.

Advertising partners: FOCGames uses the services of various advertising companies. These

companies provide ads for the FOCGames website and are responsible for the part of the

processing of your data in that context. More information about the use of cookies, also in

the context of advertising partners, can be found in our Cookie Policy available on this site.

Externally hosted games, third-party games, and other websites: This Privacy Policy does

not apply to the processing of your data by data controllers other than FOCGames, such as

providers of third-party games available on the FOCGames website. The relevant provider

of such third-party game is responsible for ensuring that any processing of your data by

them, in the context of a game, is in compliance with applicable data protection laws. In

principle, FOCGames does not allow third-party content providers to collect personal data

about website visitors.

Please note that random cookies and cookies used by developers may change over time.

How to contact us?

If you have any questions about this privacy policy or about data collection in particular,

please contact us via the email info@soraiapublisher.top or gamesf[email protected] or at the

address:

Africa Trading Company International Business Sarl

163 Hlm Grand Yoff Zone Commerciale

11500 Dakar - Senegal

The phone contact provided on the contact page is not available to provide support for this

sensitive matter.

Changes

We may change this Privacy Policy from time to time to accommodate new technologies,

industry practices, regulatory requirements, or other purposes. The most recent version

can always be found via this same URL.