THE PATG GROUP, INC. Privacy Policy

Last modified: May 1, 2022

THE PATG GROUP, INC. (“PATG”) is committed to protecting your privacy. We have prepared this Privacy Policy to describe our practices regarding the Personal Data we collect via any PATG website (the “Site’) or downloadable application (“App”).

1. User Consent. By downloading or using any Site or App, you agree to the terms of this Privacy Policy and you expressly consent to the collection, use and disclosure of your Personal Data in accordance with this Privacy Policy.

2. Children. We do not intentionally gather Personal Data from users who are under the age of 13.

3. Users Outside of the United States.  You acknowledge and consent that your Personal Data may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country.

4. Types of Data We Collect Generally.  We collect only Anonymous Data from you via our Site and our Apps, and this may include location data as further described below. In some cases, as described below, we also collect Personal Data. “Personal Data” means data that allows someone to identify you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data. “Anonymous Data” means data that is not associated with or linked to your Personal Data; Anonymous Data does not, by itself, permit the identification of individual persons. Anonymous Data includes unique but anonymous profiles of users. We collect one or more unique identifiers for the device on which you install an App (“DID”, which may by your Apple Game Center ID (if you have signed up to Game Center and we have access to that ID) or your unique device ID(s) as provided by the device) and develop a profile about you keyed to that DID. We may store your DID with your contact information (like your email address) when you contact us for support, but otherwise we do not associate your DID with Personal Data we collect about you. Other Anonymous Data includes your coarse location which may be sent to us from your device. This coarse location is approximate location derived from network location sources such as cell towers and Wi-Fi.

(a) Data You Provide to Us.

• If you provide us feedback or contact us (for support, for example), we will collect Personal Data including your name (and e-mail address or other address you provide), as well as any other content included in the communication. We use this information to assist you with your query or support request and to send you communications as described in Section 5.

• If you respond to one of our surveys, if any, we will collect any Personal Data you provide in the survey, we may use it to communicate with you about products or services we think you may be interested in, and we may share it with partners who participated in the survey.

• If you participate in a contest, sweepstakes or other promotion, we will collect any Personal Data you provide, we may use it for the purpose of the promotion, we may use it to communicate with you about products or services we think you may be interested in, and we may share it with partners who participated in the promotion.

• We collect your email address (if you choose to provide it), and we use it to send you the communications, including a newsletter, product updates, product announcements, and messages about products or services we think you may be interested in.

• If you provide job application information to us via our Site, we collect that Personal Data for the purpose of evaluating your application.

• We may also collect Personal Data, such as at other points in our Site or App that state that Personal Data is being collected.

• When you provide comments on our social networking service accounts (like the PATG Facebook page), we collect your information to communicate with you as described herein.

(b) Data Collected via Technology.

• Our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, application software, Internet Protocol (IP) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, date/time stamps for your visits to the Site or use of the App, your DID, your location, your device type.

• We also use cookies and URL information to gather information regarding the date and time of your visit to the Site and the information for which you searched and which you viewed. “Cookies” are small pieces of information that a website sends to your computer’s hard drive while you are viewing a web site. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on our Site. Persistent Cookies can be removed by following Internet browser help file directions. If you choose to disable Cookies, some areas or features of our Site may not work properly.

5. Use of Your Data (a) Personal Data. In general, we use Personal Data as described in Section 4 above. We also use Personal Data to:

• send you a welcome e-mail when you sign up to receive a newsletter; • send you administrative e-mail notifications (like notices of changes to our Privacy Policy); • respond to your inquiries related to employment opportunities or other requests;

• to send newsletters, surveys, offers, and other promotional materials related to our Site/Application and for other marketing purposes of PATG;

• We use your DID to track your in-App currency, to send relevant ads to you, to save your scores, and to provide the services you request. (b) Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that make the data personally identifiable to you. PATG reserves the right to use Anonymous Data for any purpose and disclose Anonymous Data to third parties in its sole discretion, but generally:

• Our Apps collect and send us your DID and we may use it to back up App-related data, like high scores, levels completed, in-game currency earned or purchased, etc.

• We use your IP address to determine your device’s general location, such as the city, state, or country in which you are located. If you allow the App (or if you install the App on Android) to use your device’s coarse location (i.e., latitude/longitude or address, as specified in your device’s settings), the App will collect that information and send it to our servers. We may use your location information for geographic leaderboards (e.g., to show scores on a map), advertising, and geographic analysis (e.g., regional App popularity). This location data may be sent to third party leaderboard services if you have chosen to use those third party services.

• We also use Anonymous Information to improve our products and services. 6. Disclosure of Your Data. We disclose your Personal Data as described in this Privacy Policy.

(a) Third Party Service Providers. We may share your DID or Personal Data with third party service providers (or allow them to collect such information and IP addresses): to host or provide you with the Site or App services; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; and/or to provide other services to or for PATG.

(b) Analytics and Advertising. We may share your DID or Personal Data with companies that perform analytics regarding our Site or our Apps (or allow them to collect your DID, Personal Data and IP addresses): to analyze the use of the Site or the Apps for us; and for advertising about PATG and other companies. These companies may combine data we provide to them or allow them to collect from or about you with data they collect in connection with other websites or applications.

(c) Acquisitions. If another company acquires our company, business, or our assets, that company will possess the Personal Data and Anonymous Data collected by us and will assume the rights and obligations regarding your Personal Data and Anonymous Data as described in this Privacy Policy.

(d) Other Disclosures. Regardless of any choices you make regarding your data (as described below), PATG may disclose your data if it believes in good faith that such disclosure is necessary

(a) in connection with any legal investigation;

(b) to comply with relevant laws or to respond to subpoenas or warrants served on PATG;

(c) to protect or defend the rights or property of PATG or users of the Site or Apps; and/or

(d) to investigate any violation or potential violation of the law, this Privacy Policy, or our terms of use or license.

7. Third Parties.

(a) App Integration with Social Networking Sites (SNS). If you use an App in connection with a social networking site (e.g., Facebook or Twitter) (“SNS”), we may receive Personal and/or Anonymous Data about you from such SNS, in accordance with the terms and conditions (e.g., terms of use and privacy policy) of the SNS (“SNS Terms”). If you elect to share your App-related information with these SNSs, we (or the App) will share information with them in accordance with your election. The SNS Terms of these SNSs will apply to the information we disclose to them. If you associate your App with your Facebook account, for example, Facebook will provide the App the applicable information (which may include your name, profile picture, gender, networks, user ID, list of friends, your email address, location, birthday and publishing stream, and other information you store on Facebook. This SNS information is not sent to the PATG servers but is stored in the App. Once information (such as your App scores) is provided to an SNS, the applicable SNS Terms (not this Privacy Policy) will govern the SNS’s use of this information.

(b) Third Party Services. Our Apps may provide you access to third party services such as leaderboards. Those services are not developed or operated by PATG and may have their own terms and conditions and privacy policies. PATG is not responsible for the content provided by third party services or their use of any Personal Data you may provide to them. If you sign up to or log in to a third party service (including a leaderboard or social networking service) from within an App, your user ID and password for that service may be temporarily stored by the App on your device, but is not stored on PATG servers.

(c) Third Party Websites. When you click on a link to any other website or location, you will leave our Site or App and go to another site and another entity may collect Personal Data or Anonymous Data from you. We have no control over, do not review, and cannot be responsible for, these outside websites or their content. Please be aware that the terms of this Privacy Policy do not apply to these outside websites or content, or to any collection of data after you click on links to such outside websites.

8. Your Choices Regarding Your Personal Data.

(a) Choices. We offer you choices regarding the collection, use, and sharing of your Personal Data and certain Anonymous Data.

(i) When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive.

(ii) Despite your indicated e-mail preferences, we may send you service related communication, including notices of any updates to our Privacy Policy, terms of use, or license.

(b) Changes to Personal Data. You may request deletion of your Personal Data by us, but please note that we may be required to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives.

9. Security of Your Personal Data. PATG is committed to protecting the security of your Personal Data. We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. While PATG uses reasonable efforts to protect your Personal Data, PATG cannot guarantee its absolute security.

10. Contact Information. PATG welcomes your comments or questions regarding this Privacy Policy. Please contact us at the following: support@palmeacres.com

11. Changes to This Privacy Policy. This Privacy Policy is subject to occasional revision, and if we make any material changes in the way we use your Personal Data, we will notify you by sending you an e-mail to the last e-mail address you provided to us and/or by prominently posting notice of the changes on our Site. Any changes to this Privacy Policy will be effective upon the earlier of thirty (30) calendar days following our dispatch of an e-mail notice to you or thirty (30) calendar days following our posting of notice of the changes on our Site. These changes will be effective immediately for new users of our Site or App. Please note that at all times you are responsible for updating your Personal Data to provide us with your most current e-mail address. In the event that the last e-mail address that you have provided us is not valid, or for any reason is not capable of delivering to you the notice described above, our dispatch of the e-mail containing such notice will nonetheless constitute effective notice of the changes described in the notice. In any event, changes to this Privacy Policy may affect our use of Personal Data that you provided us prior to our notification to you of the changes. If you do not wish to permit changes in our use of your Personal Data, you must notify us prior to the effective date of the changes. Continued use of our Site or App, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.