Cash Chick Privacy Notice

Version 1.0

Effective as of 2025-05-01

Please read the terms of this Cash Chick Privacy Notice (this "Notice") carefully. The Notice describes to users ("user", "users", or "you") how UAB E-Sourcing ("Cash Chick", "we", "us", or "our") collects, uses, discloses or otherwise processes your personal data collected in connection with websites, mobile applications, progressive web applications, content, features, digital events, referral programs, promotions or products we create or operate (the "Services"). This Notice is incorporated into and forms a part of Cash Chick's Terms of Use (the "Terms"). As used below, capitalized terms not defined in this Notice have the meaning given to them in the Terms. "Personal data" and "personal information" generally mean any information that directly or indirectly identifies you, which might vary slightly depending on applicable laws. Examples of personal data include your email address or information about you such as data about your device or how you use the Services. This Notice does not govern your use of a third-party developer's game that you discover and access through the Services. The processing of your data by the game developer ("Game Partners") is governed by the game developer's privacy policy which you should review prior to using their game and when exercising any rights subject to Game Partners privacy policy.

Please note, if you are younger than 18, you are prohibited from using the Services

Be sure to return to this page periodically to review the most current version of the Notice. We may change or otherwise modify the Notice, such as in order to reflect changes in the Services. If we modify it, we will update the "Last Updated" date and will alert users that a change has occurred within the affected Services. Please do not use the Services if you do not accept the current Notice, including any addendums that apply to you.

1. DATA PROTECTION PRINCIPLES

Cash Chick shall process all personal data adhering to the general data processing principles:

• lawfully, fairly and in a transparent manner in relation to the data subject (lawfulness, fairness, and transparency);
• collect and process personal data only for specified, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes (purpose limitation);
• ensure that personal data is adequate, relevant and limited to what is necessary for relation to the purposes for which they are processed (data minimization);
• ensure that personal data is accurate and, where necessary, kept up to date (accuracy);
• ensure that personal data is kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed (storage limitation);
• process personal data in a manner that ensures appropriate security of the personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures (integrity and confidentiality).

All and any information processed by Cash Chick is treated as strictly confidential. All information is stored securely and is accessed by qualified and authorized personnel only.

2. WHAT INFORMATION DO WE COLLECT ABOUT YOU?

Cash Chick is the controller, within the meaning of applicable laws, with regard to the collection, processing and use of personal data in the context of the Services and as described in this Notice. This means Cash Chick is responsible for deciding the purpose and the means of how your personal information will be used and processed. We collect information about you, which include:

• your email address;
• information regarding your activity and app interactions within Cash Chick, including game installations, play time, redeeming Cash Chick Coins, your activity and engagement within the Services (such as various in-app events, tasks, surveys, ratings), participation in surveys, tasks, and promotional offers ("In-App Activity Data");
• your device information such as device model, operating system, device ID, advertising identifiers, IP address, device location, information related to the apps installed in your device ("Device Data");
• crash logs, diagnostics, and other app performance data ("App Performance Data");
• data related to software or applications when you play and engage with games discovered in our Service, including the duration of your game play time (which may require you to change your device settings) as well as information collected about you from Game Partners, including your installation of a particular game, in-game purchase information and in-game advertising information, transaction types, events, actions, clicks, impressions, and use of virtual items, game achievements, statistics and information on bugs and malfunctions ("Gameplay Data").
• Account data, transaction data, technical browser and device information, usage data which allows us to determine whether user's actions demonstrate suspicious behavior (e. g. whether the user is a bot, has attempted to defraud us in the past and similar indications related to fraudulent behavior), internally generated additional information such as unique identifiers in addition to collected transaction, account, usage or other data ("Fraud Detection Data");
• your correspondence and communication content and metadata associated with the communication, such as data provided in support tickets or emails ("Communication Data").

3. HOW DO WE USE PERSONAL DATA?

Our main use of personal data is to provide you with Services as described in the Terms, ensure pleasant user experience and continuously develop and offer high quality products and services.

To achieve this, Cash Chick may link or combine the personal data we collect through several methods, including but not limited to software integrations, tools, and proprietary machine learning algorithms or artificial intelligence ("AI"), so that we may provide you with a personalized experience.

We generally use personal data to (purposes of the processing):

• provide, deliver, monitor and improve our Services (including customer support and respond to requests, complaints and feedback, troubleshoot software bugs and operational problems and to communicate with you according to your preferences), which requires us to track your progress in our app (conversions) to award points. This includes meeting operational and business transaction requirements such as billing advertising clients, attribution of game installs, accounting, calculating Cash Chick Coins or other in-app currencies earned in and otherwise enabling the Rewards Program and delivering prizes for promotions (email address, In-App Activity Data, Gameplay Data, Device Data, Communication Data are processed on the basis of our legitimate interest to provide adequate quality Services to Game Partners and users, and on the basis of contract concluded between the user and Cash Chick).
• provide Cash Chick users with Cash Chick Coins and/or other rewards in accordance with Cash Chick offers and Cash Chick Terms (email address, Gameplay Data, In-App Activity Data, Device Data are processed on the basis of contract concluded between the user and Cash Chick).
• personalize advertisements and promotions of games on the Cash Chick platform (including personalize the Services for you with tailored suggestions of games, features and events through the Services, promote games available in your country, and provide you with Cash Chick Coins and other rewards)(Device Data are processed on the basis of contract concluded between the user and Cash Chick).
• build the Cash Chick community of users by marketing Cash Chick's Services on third-party platforms, including for targeted advertising of Cash Chick on third party mobile applications and websites and for measurement and optimization of such marketing campaigns (In-App Activity Data, Device Data, App Performance Data are processed on the basis of our legitimate interest to constantly improve and develop our products and services).
• prevent fraud, ensure timely risk and fraud detection, effective prevention of fraudulent activities and to improve our fraud detection process, to ensure stability and security of our platform and Services, including automated detection of fraudulent activities (Fraud Detection Data, App Performance Data, Gameplay Data, In-App Activity Data, Device Data processed on the basis of our legitimate interest to prevent fraud and/or misuse of our Services and ensure security and stability of our platform).
• improve and develop new products and update features in our Services (App Performance Data, In-App Activity Data, Device Data are processed on the basis of our legitimate interest to constantly improve and develop our products and services).
• create industry reports and develop insights about our business with aggregate data or in a format that is anonymized and cannot be used to re-identify users (App Performance Data, In-App Activity Data, Gameplay Data, Device Data after aggregation and anonymization are processed on the basis of our legitimate interest to constantly improve and develop our products and services).
• carry out our legal obligations, including, but not limited to various accounting, reporting obligations, responding to law enforcement and supervisory authority requests and others (email address, Fraud Detection Data, Gameplay Data, App Performance Data, In-App Activity Data, Device Data may be processed to achieve these purposes, depending on the nature of the obligation. Data is processed on the basis of legal obligation(s) to which we are subject).
• establish, exercise or defend legal claims, whether in court proceedings or in an administrative or out-of-court procedure. We may process any of the above indicated data for this purpose, depending on the nature of the situation. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.

4. HOW WE SHARE PERSONAL INFORMATION ABOUT YOU

We treat your personal data as strictly confidential, and share it with external parties only in cases where it is necessary for us to continue providing Cash Chick Services, develop our products and services, to comply with legal or contractual obligations or to defend our legal rights. In cases where we share your personal data with our business partners and service providers, we ensure that the confidentiality of your personal data is maintained, and the partners commit to comply with applicable privacy and data protections laws and regulations.

Service Providers. We have agreements with various service providers to facilitate delivery of our Services, which include those we engage to operate the technical infrastructure needed to provide the Services, assist in providing you rewards and protecting and securing our systems and Services, and to help market Cash Chick Services. We take all the necessary measures to ensure that such subcontractors would implement proper organisational and technical measures to ensure security and privacy of your personal data.

• Advertising Platforms and Networks. We partner with certain providers, including but not limited to Google, Unity, social media companies and other ad networks, to display, target, and suppress Cash Chick advertisements on their or their partner sites (such as advertisements within games and other mobile apps). Such providers may conduct analytics in relation to advertisements and to manage our advertising on other sites. Personal information we disclose to these providers include device identifiers (e.g., Google Advertising Identifier), IP addresses, time and event data for certain actions (such as new game installation or in-game purchase made or game playtime milestone achieved). These providers use this information for marketing optimization, reporting, and analysis, and to prevent display of Cash Chick advertisements to you and existing users, retarget inactive users, and reach new potentially interested users.
• Technical Service Providers. Our technical service providers, acting as data processors, may receive and process your personal information to support the Services, including to store your data, detect and prevent fraudulent activity, provide communications (such as email and push notifications), and deliver surveys, promotional content, and events to engage with users, subject to applicable law.
• Analytics Service Providers. We work with analytics service providers that act as data processors to help us analyze and understand the personal data about you and develop trends, patterns and insights to personalize your experience with Cash Chick, curate your game selection, improve our Services, optimize sales and advertising, and create new products. These analytics providers, such as Appsflyer, also measure, verify, and analyze performance of our marketing campaigns.

Game Partners. The main purpose of the Cash Chick rewards program is to promote and advertise the games of our Game Partners in the Cash Chick platform. In order to reward you for your engagement, (a) we must allow tracking and collection of certain personal data by applicable Game Partners and their analytics providers, such as your game installs or survey answers, for purposes of reporting, attribution, and billing of the Game Partners; and (b) collect Gameplay Data from Game Partners, including your in-game purchases and advertising views, in order for Cash Chick to reward you, provide you with personalized content, market new games of interest to you, grow our business and community of users, and for development of new products, features, and services. If you choose to access or install a game recommended through our Services, you acknowledge that Game Partner and its analytics partner will collect your personal data from Cash Chick and employ tracking technologies as set forth below in Section 7.3 "User Tracking".

Corporate Affiliates and Transaction Parties. We may share your personal data with our subsidiaries or affiliates under common corporate control for the purposes described in this Notice, including provision of Services and/or development of the app and its functionalities. We may also share your personal data with counterparties as part of corporate transactions such as mergers, transfer of business, sales of company assets, financings or acquisitions but only to the extent necessary to evaluate and complete such transactions and subject to applicable legal or contractual requirements.

Law Enforcement, Regulators and Other Parties for Legal and Security Reasons. We may disclose personal data when necessary to protect the legal rights of Cash Chick, users or third parties, in order to avoid fraud, manage our risks or comply with applicable laws, legal orders or processes. This includes exchanging information with the authorities and security companies which act on our behalf for these purposes. In these cases and where permitted by applicable laws, we disclose personal data to comply with legal obligations or to protect the legitimate interests of Cash Chick or affected third parties, for example if we are obliged to cooperate with government authorities in the context of legal investigations.

When necessary, the categories of data disclosed to such third parties may include your identifiers, Internet or other similar network activity, inferences drawn from other personal information and other information as lawfully requested by the authorities. Where required or permitted by law or regulation and reasonably practicable, we will attempt to notify you of such requirements.

Cash Chick may also disclose aggregated information about users along with information that does not and cannot identify any individual or device, except where limited by applicable laws. For example, we may use anonymized user ratings, review of apps and aggregated information for statistical and machine learning purposes, to provide insights into developing or enhancing Services, for marketing and advertising and for other legally permissible purposes such as testing our IT systems and features.

5. HOW WE STORE, TRANSFER AND SECURE PERSONAL INFORMATION ABOUT YOU

We are based in Lithuania, and we store information that we collect from your device on our Amazon Web Services servers located in Europe. The information that we collect may be transferred, stored, or used in other jurisdictions, where some of our providers may be located. While we protect your information by choosing appropriate providers and having contractual safeguards in place with those vendors, the privacy laws in such jurisdictions may not be as protective as in, for example, Canada, the UK or the US.

We maintain administrative, organizational procedures, technical and physical safeguards, consistent with legal requirements where the personal data was obtained, designed to ensure the security and confidentiality against unlawful or unauthorized destruction, loss, alteration, use or disclosure of, or access to, the personal data we collect and process.

6. EXERCISING OF YOUR RIGHTS

You can always update preferences and exercise rights you may have under applicable data protection laws by contacting us as directed below. However, if you do choose to change preferences, opt-out or withdraw consent where it has been given, your experience with our Services may change, be diminished or your ability to use some of the features and options in our Services may be limited (such as access to Cash Chick Coins and the Rewards Program described in our Terms). Please keep us informed if your personal data changes or should be corrected.

We will handle your request in accordance with applicable laws, such as in relation to response time, verification of identity and content. If we cannot fulfill your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions.

Depending on your jurisdiction, your rights may include:

• The Right to Opt Out of Marketing Communications sent by Cash Chick. This can be done also by clicking on the unsubscribe link in the marketing or promotion emails you receive. Please note that if you opt out of receiving marketing or promotion messages from us, we may still send you important Service-related messages, from which you cannot opt out. You can opt out of receiving push notifications through your device settings. Please note that opting out of receiving push notifications may impact your use of the Services.
• The Right to Withdraw Consent. Where you provided us with your consent, you may withdraw your consent to the collection and processing of personal data at any time by changing your device setting permissions, contacting us as directed below or by sending a written request to [email protected]. Upon receiving notice that you have revoked your consent, we will stop processing your personal data without undue delay. Withdrawing consent may impact your use of the Services, such as access to the app, certain events, and eligibility for earning rewards.
• The Right to Deletion of Data. By deleting your data, any Cash Chick Coins that you have earned and not redeemed will be deleted. Please note that we will send you an email requesting your confirmation before we delete your data, and we may not be able to delete all data you requested, for instance to comply with applicable tax laws or to ensure adequate fraud prevention.
• The Right to Object to the Processing of Personal Data. If we receive such a request, we will review your objection and delete personal data that we processed for the purpose to which you objected without undue delay, unless another legal basis for processing and retaining this data exists or applicable law requires us to retain the data. Please note that certain types of personal data processing is required to enable the Cash Chick rewards program, and your opt-out of such processing may impact your ability to continue receiving rewards from Cash Chick. Please note that certain processing of personal data is necessary for Cash Chick to provide you with the Services, including personalized game offers, reward programs, etc. Thus, if you object to some of them, we may not be able to provide you with such Services..
• The Right to Access data. You have the right to the confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
• The Right to Rectification. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
• The Right to Restrict the Processing of Data. You may exercise this right if at least one of the following circumstances apply: (i) you contest the accuracy of the personal data; (ii) processing is unlawful but you oppose erasure; (iii) we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and (iv) you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data, however we will only further process such data in any other way: (i) with your consent; (ii) for the establishment, exercise or defence of legal claims; (iii) for the protection of the rights of another person; or (iv) for reasons of important public interest.
• The Right to Object to Processing of Data for Scientific or Historical Research Purposes or Statistical Purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
• The Right to Data Portability. You have the right to receive your personal data from us in a structured, commonly used and machine-readable format, provided that: i) it will not adversely affect the rights and freedoms of others, and ii) the legal basis for our processing of your personal data is your consent or the contract between you and Cash Chick.
• If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement. Our data processing is supervised by State Data Protection Inspectorate of the Republic of Lithuania, registered office at L. Sapiegos St. 17, LT-10312, vdai.lrv.lt.

7. OTHER IMPORTANT INFORMATION

1. 1. CHILDREN PRIVACY

   Cash Chick Services are intended for users that are at least 18 years old or older. Cash Chick does not knowingly collect or process personal data of anyone under 18, and does not advertise its or any other services to minors.

2. 2. DATA RETENTION

   Cash Chick will only retain personal data for as long as is required by law, as long as you use the Services, or as long as is necessary to meet the purposes for which it was collected. Cash Chick account balances or rewards earned as of termination must be preserved for some period to allow for such matters as billing and tax reporting.

   Note, if a user does not use the Services for at least one hundred eighty days, the user's inactive account may be terminated, Cash Chick Coins earned may automatically expire and personal data may be deleted.

   You may also ask us to delete your data. By deleting your data, however, any Cash Chick Coins that you have earned and not redeemed will be deleted. Otherwise, if we choose to maintain or use de-identified information (where permitted by applicable law), we continue to do so in a de-identified manner and will not attempt to re-identify you. To delete personal data held by Game Partners, please contact them as directed under the terms of the Game Partners privacy policy.

3. 3. USER TRACKING

   Like most online services and mobile applications, we or our Game Partners may use technologies, such as tracking links (embedded URLs), mobile measurement providers (e.g., Appsflyer, Adjust, Singular, etc.) or integrated software development kits (SDKs) in connection with our Services. We use these technologies to secure and improve our Services, for attribution and billing our Game Partners, to understand your preferences, collect information about your activity, browser, and device, and to tailor our Services to your interests. We also use these technologies to collect information when you install games that were discovered from Cash Chick, when you make in-game purchases or watch in-game advertisements, or when you engage or click on Cash Chick ads in other digital media channels. Our Game Partners employ their mobile measurement partners to collect your information when you download games that you have discovered on Cash Chick. These tracking technologies and the collection of Gameplay Data enable Cash Chick to verify your task completion, calculate your rewards, and monitor against fraudulent behavior. As such, these are necessary tracking technologies for the operation of the Cash Chick reward program. If you choose to opt out of this tracking, we may not be able to provide you with our Services.

4. 4. FRAUD PREVENTION AND AUTOMATED DECISION MAKING

   We use automated anti-fraud measures and machine learning to detect and prevent fraudulent behavior and to avoid misuse of the Services, including to combat against bots and synthetic users. The information processed for this purpose may include in-app behavior modeling and user device characteristics, among others. This processing is necessary for securing the Services and preventing misuse of the rewards program. Without this activity, we will not be able to provide the Cash Chick rewards program and rewards.

   When fraudulent or synthetic behavior is detected, we will remove or block the account. We have implemented suitable measures to safeguard user's rights and freedoms and legitimate interests, including the right to obtain human intervention, to express their point of view and to contest the decision by means of appealing the account block or termination by contacting customer support at [email protected].

5. 5. TRANSFERS OF PERSONAL DATA

   Some service providers indicated in this Section may be established outside the Republic of Lithuania, European Union, and European Economic Area (EEA). However, we always try to ensure that all of your data is processed within EEA. Please note that personal data may be less protected in non-EEA countries than in EEA countries. We closely monitor the evolving case law and guidelines of the Court of Justice of the European Union and data protection supervisory authorities on transfers outside the EEA, and carefully assess the conditions under which your data is transferred and may be further processed and stored after transfer to the above entities. To ensure the appropriate level of data security and to guarantee the lawful transfer of data, we conclude Standard Contractual Clauses approved by the European Commission or ensure other grounds and conditions established by legal acts. We will take all the necessary measures to ensure that your privacy will remain properly secured and protected. To find out more information regarding appropriate safeguards you may contact us via email: [email protected].

8. CONTACT US

If you have questions that do not relate to this Notice or data privacy, please write to our customer support team. To exercise applicable data protection rights or comment about this Notice and our privacy practices, you may reach out to our data protection officer at:

Data Privacy Officer
[email protected]