BREEZYBASE

Privacy Policy

Effective Date: 2026

The Mahjong Loop Privacy Policy ("Privacy Policy") describes how BREEZYBASE TECHNOLOGY - FZCO. ("we", "us", or "our") collects, uses, and discloses your personal information when you visit, use our services, or make a purchase from Mahjong Loop (the "Platform") or otherwise communicate with us regarding the Platform (collectively, the "Services"). We may collect and use your personal data during your use of our Services. Personal data refers to any data that identifies you directly or in combination with other data (the "Personal Data").

This privacy policy (the "Policy") explains how we collect, use, and protect your Personal Data. Please read this carefully before using the Services. By using or accessing the Services, you confirm that you fully understand and agree to the terms of this policy. If you do not agree to this policy, we will not be able to provide you with our Services.

"Personal Data" refers to any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by reference to such information alone or in combination with other information.

Please note that the precise definition, scope, and categories of personal data (which may also be referred to as "personal information," "personally identifiable information," or similar terms) may vary under the applicable data protection laws of different jurisdictions. Where a specific jurisdiction's laws apply to the processing of your data, the definition of personal data under such laws shall prevail to the extent of any inconsistency with this Policy. This Policy is intended to be interpreted and applied in a manner consistent with the applicable legal requirements in the relevant jurisdiction(s).

This Policy does not apply to third-party services, applications, websites, or content that may be embedded in or linked from our Services. Such third-party offerings are governed by their respective privacy policies and terms of use. We encourage you to review the privacy practices of any third-party services before providing your Personal Data to them.

1.What personal data do we collect

We collect Personal Data in order to provide and improve our Services. The types of data we collect include:

1.1 The data that you voluntarily provide to us

Account Data

You can access basic gameplay without connetcting with third-party account. However, please note that certain core social features, including but not limited to cross-device data synchronization, require you to connect and log in to an account through connecting your account with a third-party account (e.g. Facebook, Apple ID).

Profile Data

When using the Service, you may voluntarily provide your personal data in the profile section, including profile photo and username.

Payment Data

When you make any transaction, we may collect your payment data such as full name, billing address, billing zip code, billing country, date of birth, purchase amount, payment method, credit or debit card number or other payment data where required for payment.

If you make any transaction through Google Play, iOS App Store, or other third parties(if available), we will collect data to facilitate your transaction and maintain transaction records (including Open ID and transaction fees, currency, purchased products, purchase history, IP address, transaction details as well as device details, such as operating system version, mobile phone model or device type, and Internet connection).

Feedback Data

If you use in-app feedback or customer service function to deal with the problem such as program errors, we will collect some information, including name, OpenID, device ID, app version, battery power, WiFi intensity, available space in device, network type, operating system version, browser type, platform, operator, country/area code, coupon details, e-mail address and any information you provide in the message. You can also choose to provide photos to illustrate any errors.

1.2 The data that we collect through your use of the Services

Usage Data

When you use our Platform, we may collect data regarding your interactions to maintain service security and functionality. This includes time logs (such as registration time, login time, and operation timestamps), activity records of your service usage, device status, and permission settings (such as device startup permissions). Additionally, Our third-party partners collect interaction information with advertising partners, merchant sites, and specific ads, as well as your advertising tracking preferences (e.g., whether you have enabled limit Ad tracking), and for security purposes and malicious information detection, we may analyze data including your signature, images, username, and chat history to identify potential risks.

Technical Data

We will collect data during the use of the Platform, such as: your device identifiers (including Open ID, Ad ID such as IDFA and GAID, IMEI, IMSI, Android ID, Vendor IDs/IDFV, Platform Set IDs, Device information code, Device information series ID, Push messaging ID), and XID (an ID generated based on existing device data, model, manufacturer, Android ID and time zone settings). We also collect hardware and system information including device model, device name, manufacturer, screen size, screen orientation, MAC address, battery power, device memory usage, available space, operating system version, boot time, and device settings (such as accessibility settings, font size, and theme). Furthermore, we collect network information (including IP address, network type, WiFi intensity, network quality data, and carrier info), and software information (such as your list of installed apps for sharing functions, app name and properties, User-agent, and HTTP header information). Additionally, we record locale settings (such as country and preferred language), registration time, login time, and operation timestamps.

Order Data

We will collect data during your purchase, such as: items purchased, purchase history, transaction data, and any data you provide during a transaction, or other transaction-based content that you generate or connected to your account as a result of your transaction.

Other Data

We may also collect other data that cannot be used to identify a specific individual (that is, data that is not personal data). Such data is collected in order to improve the Services we provide to you. The type and amount of data collected will depend on how you use our products and/or Services.

1.3 The data that we collect through third party

We may obtain information about you from third parties, including from business partners, vendors and service providers who may collect information on our behalf, such as:

• Our payment service providers, who collect payment information (e.g., bank account, credit or debit card information, billing address) to process your payment in order to fulfill your orders and provide you with products or services you have requested, in order to perform our contract with you.
• To facilitate a quicker login process, we offer the option to sign in via third-party accounts. When you use this feature (e.g., via Facebook,Apple ID), we will request your permission to access public information registered on that platform, specifically your profile picture and nickname. This information is used solely to bind your account and populate your user profile; we do not collect sensitive information such as your third-party account passwords.
• Dealers, from whom we may collect customer information, including email address, name, order history and phone numbers.
• When you visit our Platform, open or click on emails we send you, or interact with our Services or advertisements, we, or third parties we work with, may automatically collect certain information using online tracking technologies such as pixels, web beacons, software developer kits, third-party libraries, and cookies.

Any information we obtain from third parties will be treated in accordance with this Privacy Policy.

2.How do we use your personal data and legal basis

We may only use your Personal Data when we have justifications (each called a "legal basis ") under applicable data protection law. To process your data as described in this Policy, we rely on the following legal bases that involve contractual necessity, legitimate interests, consent, compliance with legal obligations. And, specifically, we may use your data for the following purposes:

3.How do we use cookies and similar technologies

To provide our Platform and Services, websites, we use ad identifiers cookies and similar technologies.

Ad identifiers, cookies and similar technologies are used by us to provide our Services to you and to collect information from your device. For example, these technologies allow us and our third party advertising partners to:

• recognise you and your device;
• provide targeted advertising to you;
• allow our Services to interact with a third party social network or platform (where you have chosen to allow such interaction);
• allow us to understand how you interact with our Websites (for example, where we use cookies such as the Google Analytics cookie on our Websites);
• allow our payment processors to process your payment instructions; and
• enable us and third parties to provide you with more customised services, for example to provide our Services in the correct language.

How do ad identifiers, cookies and similar technologies work?

Our Platform include advertising for third party products and services.

Ad identifiers are identifiers such as the Android advertising ID and/or Apple's ID for advertisers (the ‘IDFA'), which are uniquely associated with your device. Similar technologies include tracking pixels within ads. These technologies allow companies (including marketers and advertisers) to recognise your device when you use websites and applications.

Cookies are small text files that are stored by your browser on your desktop computer or mobile device. You can withdraw your consent to cookies by updating the settings within your browser or by using the cookie settings on our websites.

You can choose to prevent your device's ad identifier being used for interest-based advertising by updating the settings on your device.

Players in the United States should review the US residents‘ section to know more about the sale and sharing of personal information and options available to residents of some states.

If you are not in the United States and would prefer that your personal information is not processed to receive targeted ads in Platform, you can update your preferences via the privacy and security setting in that Platform. You can also submit an opt-out request via contact us.

When we record that your preference is not to be shown targeted advertising, you will still be able to play our Platform and you will still see advertising in our Platform, but those ads will not be targeted using information that our advertising partners hold or collect about you. However, you will still receive ads based on criteria such as the Platform you are playing, the content of that Platform, or the region in which your device is located.

If you would prefer that your personal information is not processed to receive targeted ads in a particular Platform, you can update your preferences via the Privacy and Security setting in that Platform. You can also submit an opt-out request via contact us.

Opting out of targeted advertising at device level: You can choose to prevent your device's ad identifier being shared and used for targeted advertising by changing the settings of your device. On some devices it may be possible to reset your device's ad identifier. Settings vary from device to device but you will usually find the ad identifier settings under "Privacy", “Tracking” or "Ads" in your device's settings. If you live in the USA, the EEA or Canada, you can also opt-out from the collection of your information by some or all of our advertising partners who participate in the Digital Advertising Alliance by visiting http://www.aboutads.info/choices/ (for US users), http://www.youronlinechoices.com/ (for EEA users) or http://youradchoices.ca/choices (for Canadian users). You can also click on the AdChoices logo within an advertisement (where available).

4.How do we share your personal data

From time to time, we may share part of your personal data with our affiliates and partners to enable certain features of the Services or share your personal data in other circumstances in order to provide the services you request.

5.How do we protect your personal data

We are committed to protecting the security of your Personal Data and to prevent unauthorized access, disclosure or other similar risks. We have used security precautions to protect your Personal Data against unauthorized access or use, public disclosure, modification, damage or loss of data. We have put in place physical and technical safeguards to keep the data we collect secure.

While we have taken reasonable steps to protect your data, no website, Internet transmission, computer system, or wireless connection is secure. In the event of a Personal Data security incident, we will timely inform you in accordance with the requirements of relevant laws and regulations.

We shall not be liable for any security omission caused by a third party's access to your Personal Data due to your failure to keep your Personal Data private. Notwithstanding the above, we will make reasonable efforts to ensure the security of your data. Please immediately notify us of any unauthorized use of your account or any other security breach, which will help us to protect the privacy of your Personal Data.

6.How do we store and transfer your Personal Data?

We primarily host your Personal Data in the Germany. As a global business, we may also transfer your personal information to, and process it in, countries outside your country of incorporation, residence, or where our affiliates, partners, and service providers are located.

These countries may have data protection rules that are different from (and potentially less stringent than) the laws of your country. In certain situations, we may be required to disclose your personal information pursuant to lawful requests from local law enforcement or government authorities. However, no matter where our servers are located or where data is transferred, we implement appropriate measures to protect your rights.

We will store your Personal Data only for the necessary and reasonable storage period required for the purposes specified in this Policy and as required by applicable laws and regulations.

Standard Deletion: In principle, we will remove your Personal Data without delay after the purpose of collection is achieved or the required storage period expires.

Alternatively, we may anonymize your data. "Anonymization" refers to the technical processing of Personal Data such that the subject cannot be identified and the data cannot be recovered. Data obtained after anonymization is no longer considered Personal Data.

We may retain your Personal Data even after you have closed your account or we have ceased providing Services to you, if retention is reasonably necessary to comply with legal obligations, meet regulatory requirements, resolve disputes, prevent fraud, cheating or abuse, or enforce this Policy.

If we cease operation, we will stop collecting your Personal Data in a timely manner, notify you via direct notification or public announcement, and delete or anonymize the Personal Data held by us.

7.Your rights to your personal data

Please note that when you make a request to exercise your rights, we may require that you provide data and follow procedures so that we can verify your identity. Where possible, we will attempt to match the data that you provide in your request to data we already have on file to verify your identity. If we are able to verify your request, we will process it.

We will assess any request to exercise these rights on a case-by-case basis. We will respond to your request within the periods required by applicable data protection law. However, we may not always be able to comply fully with your request. We will notify you in that event.

8.Children

We do not knowingly or intentionally collect Personal Data from individuals below the age of 13 or age of majority in their respective jurisdictions. Our Services are not directed to children, and we do not encourage individuals under the applicable age of majority to use our Services.

To ensure compliance with global safety standards, we utilize the official age verification and account authentication tools provided by the Google Play Store. By accessing the Platform through your Google Play account, you represent that the age information provided to Google is accurate and that you meet the minimum age requirement to use this Service.

If you believe we have collected Personal Data from an individual below the age of majority in their jurisdiction without parental/guardian consent, or if you are the parent or guardian of such an individual and wish to have their data removed, please contact us through the email address provided in the "How to contact us" section. Upon notification, we will promptly investigate the matter and take appropriate steps to delete any such Personal Data.

8.How to update this policy

We reserve the right to update this Policy at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your Personal Data.

9.How to contact us

If you have any question/complain/suggestion/request regarding this Policy, you can contact us using any of the following ways:

• Email: breezybaseteam@gmail.com
• Mail address：DSO-IFZA IFZA Properties Dubai Silicon Oasis
  

Jurisdiction-Specific Terms

ADDITIONAL TERM FOR U.S. USER

In addition to the information provided throughout this Policy, state privacy laws in the United States require that we disclose to consumers in those states additional information about the processing of their personal information. Below we describe the purposes for which we use and disclose personal information and, for each purpose, the categories of personal information we use and disclose and the categories of third parties to whom we disclose the personal information.

1.How We Use Your Personal Information

The purposes for which the Platform collects and processes personal data may include, but not limited to:

• Operating our Platform to provide you access to and use of our Platform and Services;
• Enforcing or defending our policies or contract with you;
• Managing your account;
• Administering your use of our Services, to communicate with you and respond to your requests;
• Customizing your Service experience with us, to improve our Services and products;
• Marketing and advertising. We do not collect, process, or store the advertising data on our own servers, it is collected directly by third-party partners to improve targeting, attribution, and measurement systems, ensuring the advertisements you see are relevant to your interests.

We recommend that you review our advertising partners' privacy policies for more information.

You should note that if you opt out of receiving targeted advertising, you will still see advertising and you will see advertising for our products, but that advertising will not be targeted using your personal information.

For more information, please refer to "How do ad identifiers, cookies and similar technologies work?"

• To detect and prevent fraud, verify payments, and improve service security and reliability.
• To protect the rights, property and/or security of us, or any of our affiliates, business partners and/or customers.
• To comply with laws, regulatory obligations, and legal processes.

2.How We Disclose Your Personal Information

In certain circumstances, we may disclose your personal information to third parties for contract fulfillment purposes, legitimate purposes and other reasons subject to this Privacy Policy. Such circumstances may include:

• To vendors or other third parties who perform services on our behalf (e.g., payment processing, data analytics, player support, cloud storage).
• To business and marketing partners to provide services to you, solely for the purposes specified in our agreements with such partners. Our business and marketing partners will use your information in accordance with their own privacy policies.
• When you direct or request us to disclose certain information to third parties, or when you otherwise consent to disclose, such as to purchase virtual products or login integrations.
• With our affiliates or otherwise within our corporate group, in our legitimate interests to run a successful business.
• To comply with any applicable legal obligations, including to respond to subpoenas, court orders, search warrants, and similar legal requests.
• To enforce the Policy.
• To protect or defend the Services, our rights, and the rights of our users or others.
• Type of personal information disclosed that may be considered "sale" (as defined under applicable privacy law) include hashed email address, hashed phone number, user browsing activity information, user interaction information.
• Marketing and advertising. We do not collect, process, or store the advertising data on our own servers, it is collected directly by third-party partners to improve targeting, attribution, and measurement systems, ensuring the advertisements you see are relevant to your interests.

Categories of third parties to whom personal information was disclosed that may be consider "sale" and share (as defined under applicable privacy law) include social media networks and advertising partners.

We share certain information with third parties who do work on our behalf for the business purposes we describe above.The personal information collected through these methods is associated with your browser or device, so if you would like to opt out for this information you will need to disable cookies or trackers as described above. Because your opt-out preference is stored in a cookie, if you reset your advertising ID or clear your cookies then we will not recognise your device or your choices, so you must opt out again. You will also disable non-advertising cookies through your browser or device settings.

• We also will allow third-party advertising companies to collect information about your activity on our Websites and in our Platform and other Services for example through cookies, mobile ad identifiers, pixels, web beacons and social network plugins. These advertising entities use information they collect to help us provide more relevant advertisements and for other purposes described in our Privacy Policy. For more information, please refer to "How do ad identifiers, cookies and similar technologies work?"

3.Your Rights

You are able to exercise your following privacy rights by contacting us via contact information in the Contact Us in accordance with the applicable law as well as subject to certain limitations at law, including but limited to:

• Right to know: You may have the right to know what personal information we have collected about you, including the categories of sources from which the personal information is collected, the business or commercial purpose for collecting or sharing personal information, information about third parties to whom we share the personal information, and the specific pieces of personal information we have collected about you.
• Right to Access: You may have the right to request access to personal information that we hold about you, including details relating to the ways in which we use and share your information.
• Right to Delete: You may have the right to request that we delete personal information we maintain about you.
• Right to Correct: You may have the right to request that we correct inaccurate personal information we maintain about you.
• Right to Take Your Data with You / to Request A Copy of Your Data: You may have the right to receive a copy of the personal information we hold about you and to request that we transfer it to a third party, in certain circumstances and with certain exceptions.
• Right to Opt-out Sales of Your Data. You have the right to direct us not to sell your personal information to third parties. This allows you to exercise control over who has access to your data and how it's used. When you exercise this right, we will cease selling your information upon receiving your request, subject to certain exceptions permitted by applicable privacy laws.
• Right to Opt-out Targeted Advertising or Profiling. Under the laws of some states, consumers have the right to opt out of the sale of personal information or the sharing of their personal information with third parties for targeted advertising (also known as cross-context behavioural advertising or interest-based advertising). We do not use your personal data for automated decision-making or profiling that produces legal or similarly significant effects.
• Right to Non-discrimination. We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights, unless allowed under applicable law.
• Right to Platformeals. Some state laws allow residents who are not satisfied with our response to their requests to appeal our decision by contacting us as described in the written notice we will provide to you.

You may exercise any of these rights were indicated on our Platform or by contacting us using the contact details provided above.

You have the right to appeal any decision we have made about your request by following the instructions in the communication you receive from us notifying you of our decision.

We may need to collect information from you to verify your identity, such as your email address or account information, before providing a substantive response to the request. In accordance with applicable laws, you may designate an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us. We will respond to your request in a timely manner as required under applicable law.

ADDITIONAL TERM FOR CALIFORNIA USER

Consumers residing in California are afforded certain additional rights with respect to their personal information under the California Consumer Privacy Act or ("CCPA") and the "Shine the Light" Law.

1.Our collection and use of personal information ("Notice at Collection")

As described above, we have disclosed the information about our collection, use and disclosures of your personal information in the "What personal data do we collect", "How do we use your personal data and legal basis" and "How do we share your personal data" of this Privacy Policy. As required by certain state laws, we use extra tables below (served as "Notice at Collection") to explain this same information, including the categories of personal information we collect (and have collected over the preceding 12 months), types of recipients to which we disclose such information, and the ways we use each category of information.