Privacy Policy

1. Our Relationship with You

Certain data protection and privacy laws, including those applicable in the European Economic Area ("EEA"), the United Kingdom ("UK"), Singapore under the Personal Data Protection Act 2012 ("PDPA"), and the United States (including the California Consumer Privacy Act ("CCPA") as amended by the California Privacy Rights Act ("CPRA")), distinguish between entities acting as "controllers" (or "businesses") and those acting as "processors" (or "service providers").

This Notice applies to the processing of personal information by NURITOPIA PTE. LTD. in its capacity as a data controller (or equivalent role under applicable law). As a controller, NURITOPIA determines the purposes and means of processing your personal information.

While you are not obligated to provide personal information, failure to do so may limit our ability to provide certain Services.

2. Personal Information We Process

We may collect personal information directly from you or from authorized third-party sources, depending on how you interact with the Services.

Categories of Personal Information

Personal information processed may include:

• Personal identifiers (e.g., name, email address, phone number);
• Account and authentication information (e.g., login credentials, OAuth identifiers);
• Device and technical information (e.g., IP address, operating system, app version, language settings);
• Usage and activity data (e.g., in-game actions, timestamps, interaction logs);
• Visual or audio information voluntarily provided by users (e.g., profile images, support communications);
• Approximate geolocation data (e.g., country or region inferred from IP address).

We do not intentionally collect government-issued identification numbers or biometric data in connection with standard gameplay Services.

Automatically Collected Information

When you use the Services, we may automatically collect:

• Online identifiers (e.g., IP address);
• Device and network activity data;
• Application usage metrics and crash diagnostics.

Cookies or similar technologies may be used in connection with web-based Services. Additional information is available in our Cookie Notice (where applicable).

Information from Third Parties

Where permitted by law, we may receive limited information from trusted third-party partners such as analytics providers, advertising partners, or platform operators (e.g., Google, Apple) to support service delivery, security, and analytics.

3. How We Use Personal Information

We process personal information for the following purposes:

• To provide, operate, and maintain the Services;
• To authenticate users and manage accounts;
• To improve gameplay experience, performance, and features;
• To conduct analytics, research, and service optimization;
• To detect, prevent, and address fraud, abuse, or technical issues;
• To comply with legal obligations and enforce our terms;
• To support corporate transactions such as mergers or reorganizations.

Where possible, data may be aggregated or anonymized for statistical purposes.

4. How We Share Personal Information

We may share personal information with:

• Affiliates or group companies of NURITOPIA, where necessary for internal operations;
• Service providers acting on our behalf (e.g., cloud hosting, analytics, customer support);
• Platform providers (e.g., Apple App Store, Google Play) in accordance with their policies;
• Legal, regulatory, or governmental authorities where required by applicable law;
• Professional advisors such as auditors, lawyers, or consultants;
• Successors or acquirers in connection with a corporate transaction.

We do not sell personal information as defined under the CCPA/CPRA.

5. Data Retention and International Transfers

Retention

We retain personal information only for as long as necessary to:

• Fulfill the purposes described in this Notice;
• Comply with legal or regulatory requirements; or
• Resolve disputes and enforce agreements.

International Transfers

NURITOPIA is based in Singapore, and personal information may be transferred to and processed in other countries where our service providers are located. These countries may have data protection laws different from those in your jurisdiction.

Where required, we implement appropriate safeguards, including:

• Reliance on adequacy decisions;
• Standard Contractual Clauses (SCCs);
• Other lawful transfer mechanisms recognized under applicable law.

6. Security

We employ commercially reasonable administrative, technical, and organizational measures designed to protect personal information against unauthorized access, disclosure, alteration, or destruction. However, no system is completely secure, and we cannot guarantee absolute security.

7. Your Privacy Rights

Depending on your location, you may have rights including the right to:

• Access your personal information;
• Request correction or deletion;
• Object to or restrict certain processing;
• Request data portability where applicable;
• Withdraw consent where processing is based on consent;
• Lodge a complaint with a data protection authority.

Requests may be submitted to: privacy@havfun.com. We may require identity verification before responding.

8. Consent

By using the Services, you acknowledge that we may collect, use, and share personal information as described in this Notice. Where required by law, we rely on your consent, which may be withdrawn at any time without affecting prior lawful processing.

9. Children’s Privacy

The Services are not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If such information is identified, we will delete it promptly.

10. Legal Basis for Processing (EEA / UK Users)

Where applicable, we rely on the following legal bases:

• Consent;
• Legitimate interests;
• Compliance with legal obligations;
• Establishment, exercise, or defense of legal claims

11. Updates to This Notice

We may update this Notice from time to time. Material changes will be reflected by an updated "Last Updated" date. Continued use of the Services constitutes acceptance of the updated Notice.

12. Contact Us

If you have questions or concerns regarding this Privacy Policy, please contact us at:

Email: info@havfun.com
Company: NURITOPIA PTE. LTD.
Location: Singapore