Effective Date: October 14, 2025

1.INTRODUCTION

1.1 Welcome to Products and/or Services run by DEQU PTE. LTD. and its affiliates and related corporations (individually and collectively, "DEQU", "we", "us" or "our"). DEQU takes seriously its obligations under applicable privacy laws and regulations ("Privacy Laws") and is committed to respecting the privacy rights and concerns of all users who use our games, products, websites, and mobile applications (we refer to the games, products, websites and the other services referred to in our Terms of Service collectively as the "Products and/or Services"). A "User" refers to an individual who registers an account or otherwise uses or accesses the Products and/or Services (individually and collectively, “users”, “you” or “your”). We recognize the importance of the personal data you have entrusted to us and

we will try our best to properly manage, protect and process your personal data. This Privacy Policy (hereinafter referred to as the "Policy") is designed to assist you in understanding how we collect, use, disclose, transfer and/or process the

personal data you have provided to us and/or that we hold (whether now or in the future), as well as to assist you in making an informed decision before providing us with any of your personal data.

1.2 By registering for our account or accessing our Products and/or Services, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT ACCESS OUR PRODUCTS AND/OR SERVICES. If we change our Privacy Policy, we will notify you, including by posting the revised Privacy Policy on sites, products or services. We reserve the right to amend this Privacy Policy at any time. To the fullest extent permissible under applicable law, your continued access to our Products and/or Services, including making any purchases or orders, shall constitute your acknowledgment and acceptance of the changes made to this Privacy Policy.

1.3 This Policy is intended to help you understand：

- Personal Data We Collect

- How We Use Your Personal Data

- How We Share Your Personal Data

- How We Transfer Your Personal Data

- How We Disclose Your Personal Data

- How We Retain Your Personal Data

- Your Rights

- Children's Privacy

- Changes to Privacy Policy

- Contact Us

2.PERSONAL DATA WE COLLECT

2.1 "Personal Data" refers to any information or data that relates to you as an identified or identifiable individual, such as name, gender, email address, government-issued identification, contact address, billing data, location data, occupation, personal interests, etc. We may collect your personal data through the following methods.

2.2 Data You Provide to Us

To access and use our Products and/or Services, where required or applicable, you may voluntarily

provide certain categories of Personal Data to us, including but not limited to:

2.2.1 Contact information (e.g. email address).

2.2.2 Account information (e.g. Account ID, registered username, password, age, gender, hobby).

2.2.3 Character information (e.g. character name and profile picture. Please be reminded that such information may be disclosed to other users during the provision of the services and may be accessible to your contacts or the public via third-party services).

2.2.4 Billing and transaction information (When you make a purchase using your account, we may collect your billing/delivery address, payment card or financial account details, and records of purchases and transactions. Please be reminded that payments processed through third-party merchant services are subject to the privacy policies of their respective providers.

2.2.5 Communications with us (e.g. content of emails, chat logs, and other communications submitted to our support channels. Such data is retained for service optimization and compliance with legal obligations).

2.3 Data We Collect

When you access and use our Products and/or Services, we automatically collect the following categories of personal data, which are strictly limited to what is necessary for service functionality, security, and legal compliance:

2.3.1 Location information (approximate geographic location derived from IP address, cellular tower ID (Cell-ID), and Wi-Fi access points).

2.3.2 Device, network and technical information

(a) Device attributes: Name, brand, model, version, type, operating system, system properties, resolution, settings;

(b) Technical identifiers: MAC address, IMEI, Android ID, IDFA, IDFV, OpenUDID, GUID, IMSI, OAID, VAID, AAID, UUID, CAID, device serial number;

(d) Connectivity details: Wi-Fi status/parameters, BSSID (router MAC address), SSID (access point name);

(e) Hardware specifications: CPU type/architecture, GPU information;

(f) System metrics: Time zone, software versions, active processes, input method list;

(g) Location-related signals: IP-based approximate location, GPS data (subject to explicit consent), nearby Wi-Fi access points, Bluetooth beacons, cell tower IDs (Cell-ID);

(h) Device sensors: accelerometer, gyroscope, gravity sensor, rotation vector, magnetometer, linear accelerometer, ambient light sensor, proximity sensor;

(i) Game session logs: Match records, item transactions, social interactions, game chatting records;

(j) Access logs: Login timestamps, IP geolocation;

(k) Error diagnostics: Error messages, crash reports, exception traces.

2.3.3 Gameplay information (data related to how you play and actions you take in our games, including game version, game authentication tokens, character appearance and attributes, progression and results, virtual assets, currencies, and items, tasks and rewards, social connections, chat logs, crash/error logs, gameplay screen capture, sensor data).

2.4 Data Collected From Third-parties

We may receive certain categories of Personal Data from third-party platforms or service providers, strictly limited to what is necessary for service functionality and contingent upon your explicit authorization.

2.4.1 Social media and gameplay platform account information: When you choose to bind, connect, or log in with your third-party account on our Products and/or Services (such as Steam), we may be authorized to collect these data, which may include your platform account ID, username, profile picture, email address, activities or contact list associated with that account, specifically depending on the third party.

2.4.2 Payment information: Where you utilize third-party payment processors (e.g., PayPal, Alipay+、Apple Pay、Google Pay、Steam), we receive and retain: Hashed transaction identifier, country/region from which your payment originated, and transaction details.

Please note that we may combine and update the personal data we collect with that from third parties for market analysis to optimize our Services.

2.5 COOKIES

2.5.1 Cookies are identifiers we transfer to your computer or mobile device that record data about your computer or device, how and when the Services or websites are used or visited, by how many people and other activity within our Site and Games. We may link cookie information to personal data. We or our authorized service providers and authorized partners may from time to time implement "cookies" or other features to allow us or third parties to collect or share information in connection with your use of the Services. These features help us improve our Site, Games and the Services we offer, help us offer new services and features, and/or enable us and our advertising partners serve more relevant content to you, including through remarketing, subject to applicable law.

2.5.2 You may refuse the use of cookies or web beacons by selecting the appropriate settings or adjusting your preferences on your browser or device. However, please note that if you do this you may not be able to use the full functionality of our Products and/or Services. You may also be able to opt out of personalized advertisements on some mobile applications by following the instructions for Android and iOS.

3.HOW WE USE YOUR PERSONAL DATA

3.1 We may collect, use, disclose and/or process your personal data for one or more of the following purposes:

3.1.1 to consider and/or process your application/transaction with us or your transactions or communications with third parties via our services;

3.1.2 to manage, operate, provide and/or administer your use of and/or access to our Products and/or Services (including, without limitation, your preferences), as well as your relationship and user account with us;

3.1.3 to respond to, process, deal with or complete a transaction and/or to fulfil your requests for certain products and services and notify you of service issues and unusual account actions;

3.1.4 to prevent or investigate any actual or suspected violations of our Terms of Service, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us;

3.1.5 Protect the security of the game operating environment, the rights, property and safety of others;

3.1.6 for identification and/or verification;

3.1.7 to maintain and administer and improve any software updates and/or other updates, to support the Services, including to troubleshoot, report, or address any issues (e.g., to respond to errors or crash reports) that may be required from time to time to ensure the smooth running of the Games and/or our Services;

3.1.9 to allow other users to interact, communicate, or connect with you, including to inform you when another user has sent you a private message or posted a comment for you via the Games or Site;

3.1.10 to conduct research, analysis and development activities (including, but not limited to, data analytics, surveys, product and service development and/or profiling), to analyze how you use our services, to improve our Products and/or Services to enhance your customer experience;

3.1.11 to allow for advertising and other audits and surveys, validate the size and composition of our target audience, and understand their experience with DEQU’s Products and/or Services;

3.1.12 for marketing and advertising for any marketing activities where permissible under applicable law, and in this regard, to recommend products and/or services relevant to your interests, to send you by various mediums and modes (including email or SMS) of communication marketing and promotional information and materials relating to products and/or services that DEQU (and/or its affiliates or related corporations) may be selling, marketing or promoting, whether such products or services exist now or are created in the future. You can unsubscribe from receiving marketing information at any time. We may use your contact information to send newsletters or marketing materials from us and from our related companies;

3.1.13 to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on DEQU or on its related corporations or affiliates;

3.1.14 to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;

3.1.15 to enforce our Terms of Service or any applicable end user license agreements;

3.1.16 other purposes which are permissible under applicable law and which we notify you of at the time of obtaining your consent.

3.2 Legal basis of our data collection and processing

Under certain relevant laws (including the EU GDPR and Singapore's PDPA), we are required to disclose the legal basis for processing your data. Where these laws apply to you, we rely on the following legal bases to collect and process your Personal Data:

3.2.1 The legal necessity for performing the service contract.

3.2.2 Your consent, where required by law (you may contact us at any time to withdraw your consent according to the Provision 11 of this Policy).

3.2.3 Compliance with statutory obligations.

3.2.4 Protecting the vital interests of you or others (unless overridden by your interests).

3.2.5 Our legitimate interests and the legitimate interests of third parties, including providing renewed services, targeted marketing, and security assurance.

4.HOW WE SHARE YOUR PERSONAL DATA

4.1 We do not sell your personal data. We do not disclose your personal data to independent third parties without your explicit knowledge and consent, except in the following circumstances expressly stated in this Privacy Policy:

4.2 We may share your personal data with our affiliates (including parent companies, subsidiaries, joint ventures, and entities under common control) to facilitate unified service delivery and account management. In such cases, we contractually require affiliates to adhere to this Privacy Policy and implement equivalent data protection measures.

4.3 To enhance service functionality and user experience, we may engage authorized partners for advertising, payment processing, analytics, marketing, social media integration, and personalized services. We may disclose specific personal data to these partners, limited to: Device information, Installed applications list, Network information. All partners are bound by strict data processing agreements prohibiting independent use of your data beyond contracted purposes. We are not responsible for the privacy practices of these partners, and the use of your data by those companies (such as for product improvement) will be governed by those specific companies’ privacy policies, which you may find on each company’s website.

4.4 In the event of mergers, acquisitions, asset transfers, or similar transactions where personal data is transferred, we will:(a) ensure the transferee assumes compliance with this Privacy Policy; or (b) require re-obtainment of your consent if the transferee cannot comply. You will receive prior notification of such transfers.

4.5 We may disclose personal data to public authorities when: (a) required by applicable laws, regulations, court orders, subpoenas, or search warrants; (b) necessary to combat fraud, financial crimes, or cyberattacks; (c) essential to protect user safety, defend legal rights, or enforce our Terms of Service. Disclosures will be proportionate to legal requirements.

4.6 We reserve the right to disclose personal data where necessary to: (a) Investigate and defend against third-party claims or allegations; (b) prevent unauthorized access, data breaches, or service integrity compromises; (c) protect the rights, property, or safety of our users, the public, or us.

5.HOW WE TRANSFER YOUR PERSONAL DATA

5.1 Our servers, service providers, affiliates and subsidiaries, and partners are located in various countries around the world. Your personal data may be transferred to, and processed in, these countries, which may be different from the territory in which you reside. These countries may have data protection laws that are different from those of your jurisdiction (and, in some cases, may not be as protective).

5.2 We are committed to processing data in compliance with applicable data protection laws and to implementing appropriate security measures to protect your data no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

5.3 Unfortunately, although we have implemented and maintained reasonable measures to protect your personal data, the transmission of data via the internet is not completely secure. In the event of a security incident such as a personal data breach, we will initiate an emergency plan to prevent the magnification of the security incident, and will notify you via push notifications, announcements, etc.

6.HOW WE DISCLOSE YOUR PERSONAL DATA

We will only disclose your personal data publicly when:

6.1 After obtaining your explicit consent;

6.2 In accordance with relevant laws and regulations, we may share, transfer, and publicly disclose personal data without obtaining your prior authorized consent in the following cases:

6.2.1 In connection with the performance of our obligations under laws and regulations;

6.2.2 Directly related to national security and national defense security;

6.2.3 Directly related to public safety, public health, and significant public interests;

6.2.4 Directly related to crime investigation, prosecution, trial and execution of judgments, etc.;

6.2.5 For the purpose of safeguarding the life, property and other significant legitimate rights and interests of the subject of personal data or other individuals but where it is difficult to obtain his or her consent;

6.2.6 Personal data disclosed to the public by the subject of the personal data himself/herself;

6.2.7 Personal data collected from information that is legally and publicly disclosed, such as legal news reports, government information disclosure and other channels.

6.3 In accordance with the law, sharing, transferring or publicly disclosing personal data that has been de-identified to the extent that the data recipient is unable to recover and re-identify the information subject shall not be deemed as sharing, transferring or publicly disclosing personal data and such data shall be stored and processed without notice to or consent from you.

7.HOW WE RETAIN YOUR PERSONAL DATA

7.1 We retain your personal data for the period necessary to fulfil the purposes outlined in this Privacy Policy, including but not limited: (a) performing our contractual obligations towards you; (b) complying with legal obligations (e.g., taxation, accounting, or auditing requirements under applicable laws and regulations); (c) protecting against cheating, fraud, or security incidents. If you cease using our Products and/or Services, or your permission to use the Products and/or Services is terminated or withdrawn, we may continue storing, using and/or disclosing your personal data in accordance with this Privacy Policy and our obligations under the Privacy Laws. Subject to applicable law, we may securely dispose of your personal data without prior notice to you.

7.2 Data retention shall adhere strictly to the principle of data minimization and shall not exceed the minimum duration required to achieve the processing purposes. We will not keep your data longer than necessary unless the law requires us to do so.

7.3 We implement a variety of security measures and operational controls, and we strive to ensure the security of your personal data on our systems. Your personal data is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems. However, we cannot guarantee absolute security.

8.YOUR RIGHTS

8.1 Right to Access your Personal Data

You have the right to access to your personal data or request a copy of your personal data.

8.2 Right to Correct Your Personal Data

You have the right to correct or update your personal data where it's inaccurate or incomplete.

8.3 Other rights - deletion, objection, and withdrawal

You have the right to request the deletion of your personal data, object to the manner in which we use or share your personal data, and restrict the manner in which we use or share your personal data. You may withdraw your consent at any time.

8.4 If you have questions about data protection or any requests for resolving issues with your personal data, we encourage you to contact us according to the Provision 11 of this Policy, and we will respond to all requests within a reasonable time frame. Please note that we reserve the right to charge you a reasonable fee for data access requests, and we may not accommodate a request to change or delete data if we believe the changes or deletions would violate any legal or regulatory requirements or negatively impact the accuracy of the data.

9.CHILDREN'S PRIVACY

9.1 Our Products and/or Services are not marketed to children and are not intended for use by children. We only provide Services to natural persons who have reached the age of 18 or the applicable age of majority in your jurisdiction. When determining the age at which children may access certain features of our Products and/or Services, we strive to comply with the different minimum age guidelines specified by the laws of various regions. As a parent or guardian, if you believe your child has used our Products and/or Services to process their personal data without your consent, please contact us according to the Provision 11 of this Policy.

9.2 Children are not permitted to use our Products and/or Services, and we will not intentionally collect any personal data from children. Although our Products and/or Services are not intended for children as the primary audience, we may collect age information before allowing a user to proceed for certain Products and/or Services. If we learn that we have unintentionally collected personal data from a child that is not within the scope of exemptions under applicable laws, we will take measures to delete such data from our records as soon as possible.

10.CHANGES TO PRIVACY POLICY

10.1 We may update this Privacy Policy from time to time, including to align with changes in our services or processes or comply with updated laws and regulations. We recommend that you review this Privacy Policy regularly to stay informed of updates. If necessary or required by law, we will notify you of any updated terms to either obtain your consent again or enable you to exercise your rights.

10.2 Your continued use of our services shows that you acknowledge how we will collect, handle, and use your personal data according to the revised Privacy Policy.

11.CONTACT US

If you have any question about the Privacy Policy, please contact us by DPO@dequgames.com， You can also write to the following address:

DEQU PTE. LTD.

1 PHILLIP STREET, #09-00, ROYAL ONE PHILLIP, SINGAPORE 048692