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1 PRIVACY POLICY LEHBROTHERS S.R.L.
Privacy Policy
At LEHBROTHERS, accessible from www.LehBrothers.com or app mobile, one of our main
priorities is the privacy of our visitors. This Privacy Policy document contains types of information
that is collected and recorded by www.LehBrothers.com and how we use it.
If you have additional questions or require more information about our Privacy Policy, do not
hesitate to contact us.
This Privacy Policy applies only to our online activities and is valid for visitors to our website with
regards to the information that they shared and/or collect in www.LehBrothers.com and app
mobile. This policy is not applicable to any information collected offline or via channels other than
this website.
➢ Definitions
“Applicable Data Protection Legislation” means any legislation in force from time to time
which implements the European Union Directive 95/46/EC and Directive 2002/58/EC
and the General Data Protection Regulation (“GDPR”) 2016/679 of April27th, 2016 and
is applicable to this Agreement and all other applicable laws and regulations that may
apply to the transfer of Personal Data.
“Personal Data” shall mean any information relating to a Data subject; an identifiable
person is one who can be defined, directly or indirectly, notably by reference to an
identifier such as a name, an identification number, location data, an online identifier,or to
one or more factors specific to his/her physical, physiological, genetic, mental, economic,
cultural or social identity of that natural person. Contact data and Service Data are
Personal Data.
“Contact Data” means any names, phone numbers, e-mail addresses and certain financial
details held within commercial systems to conduct the Parties’ relationshipmanagement
and billing transactions between the Parties;
“Controller”, “Data Subject”, “Personal Data”, “Process/Processing” and “Processor”,

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shall have the same meaning as in the European Union Directive 95/46/EC or the
General Data Protection Regulation 2016/679 of April 27th, 2016.
“Service Data” means any Party’s Personal Data (that is not Contact Data) held withinthe
Parties’ systems, applications or databases and that may be accessed, processed, used
or stored as a consequence of performing the services under the Agreement.
“Third Country” means a country that is: (i) outside of the European Economic Area;and
(ii) not the subject of a formal decision by the European Commission, made pursuant to
Section 25(6) of the European Union Directive 95/46/EC or under Article45 (1) of the
General Data Protection Regulation 2016/679, stating that that country ensures an
adequate level of protection for personal Data.
➢ Consent
By using our website or app mobile, you hereby consent to our Privacy Policy and agree to its
terms.
You must be aged 13 or over to use our app. When you sign up to use Stereo you will be
askedto confirm your date of birth so that we can check that you are 13 or over. If you
are not aged 13 or over, you are not permitted to use our app.
➢ Age identification
To identify your age for data protection purposes, for example to determine the legal
requirements for processing of Personal Data. We request that anyone under the age of
13 notsend any Personal Data about themselves over the Internet unless sent under the
supervisionof their parent or guardian. We do not knowingly collect Personal Data from
children under 13years old in the Game. We believe it is important to safeguard the
privacy of children and encourage parents to regularly monitor their children’s use of
online activities. If you are a parent and believe that your child under the age of 13 has
accessed and/or played the Game and provided personally identifiable information to us,
please contact us at office@uptrust.euor the mailing address at the end of this Privacy
Policy and we will work to delete that accountand any such personally identifiable
information. This in compliance with Article 6(1)(c) of theGDPR.
Our apps do not knowingly collect any information about or market to anyone under the
ageof 13. If we become aware that somebody who is under 13 years old has registered
with us andprovided us with personal data, we will take steps to terminate that person’s

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registration and delete their profile information from our app. If we do delete a profile
because you violated ourage restriction rules, we may retain your mobile number and IP
address to ensure that you donot try to get around our rules by creating a new profile.
➢ Payment information
In order to access the complete Game, certain premium game functions, levels, content
and features etc. you are required to pay certain fees. When purchasing such features
andfunctions etc. you may be asked by the platform/service providers to provide certain
personallyidentifiable information, such as full name, billing address, email address,
phone number andcredit card number/expiration date etc. Please note that you must be
the age of 18 or older to make purchases in the Game, however children over thirteen but
under eighteen may access and play the game under the supervision of a legal guardian.
Once End Users have successfully entered valid credit card information etc. and
completed the order process, a purchasing account will be created and maintained for
them. Theplatform/service providers will use the information provided to process the End
User’s order and to send order confirmations via email, as well as to make future
purchases easier for the End User. c does not sell, transfer, or share customer
information with third parties, except where applicable the information is transferred,
disclosed, and shared with its third-party agent(s) who uses the information solely to
handle and deliver certain online activitiesnecessary to operate our gaming business
(e.g., processing orders and payments).
➢ Information we collect
The personal information that you are asked to provide, and the reasons why you are asked to
provide it, will be made clear to you at the point we ask you to provide your personal information.
If you contact us directly, we may receive additional information about you such as your name,
email address, phone number, the contents of the message and/or attachments you may send
us, and any other information you may choose to provide.
When you register for an Account, we may ask for your contact information, including items such
as name, company name, address, email address, and telephone number.
Information you provide or is collected from you in or in relation to the Game and information from
other sources.

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Information is provided by you or collected in or in relation to the Game and/or collected from
other sources to:
– Provide, operate, improve, and maintain the Game, game experience and services, your
account(s); personalize the Game, content, loyalty programs and related services to you.
– Alerts, for support and troubleshooting reasons.
– Send support and administrative messages provide news and information about the Game
and/or about our games and products.
– Monitor the end users playing of the Game and activities in the Game.
– Facilitate sharing on social networks.
– Provide adults with advertising in accordance with given consent and/or permissible laws.
– Provide children reasonable contextual advertisements in the Game accordance with
permissible laws.
– Identify, fix, and troubleshoot bugs and service errors, provide software updates etc.
– Resolve disputes, investigate, and help curb fraud and illegal behavior, comply with the
law, and to enforce our agreements and policies.
– Survey end user’s opinions about the game and related matters through surveys or
questionnaires; communication reasons related to the Game and related matters.
– To store, process and use User Created Content in accordance with our Terms of Use.
– To comply with applicable laws or respond to legal process (like requests from law
enforcement or other public or government authorities).
– To administer, process and examine claims of copyright infringements, or other
violations of ourTerms of Use.
– Manage the Game and send you confirmations and important information about your
account,products, purchases, subscriptions, and warranties.
– Present offers and/or information relating to the Games and other games that you might
like.
Make recommendations to you and personalize advertising for you and deliver targeted
marketing, service updates and promotional offers.
Processing of this information is necessary for the purpose of performance of a contract to which
you are a party, in order to support the operation of the Game, facilitate the delivery of requested
products and services, enable maintenance and update of the Game under Article 6(1)(b) of the
GDPR, and purposes justified by our legitimate interests in providing advertisements and content
of interest to you and improving our services in accordance with Article 6(1)(f) of the GDPR (“the
balancing-of-interest rule”). Disclosure of your advertising ID to third parties for the purposes of
behavioral advertising is based on your consent in accordance with Article 6(1)(a) of the GDPR.
We only process your information to the extent that is necessary to achieve the purposes for
which the information has been collected.
➢ Information collected through the Game
Where applicable, access and playing of certain basic Game versions, experience of certain basic
content and games features may not require registering of an account with applicable
platform/service providers that are providing the Game etc. to you. However, to access and play
the complete Game, access certain premium game functions, levels, content and features you

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must register an account with the platform/service providers that are providing the Game etc. to
you. You must then create an account with the platform/service providers’ platforms that hosts
the Game to access such premium game functions, levels, content and features etc. To create
an account, you are required to provide certain mandatory information such as your name, your
email address, account login etc. which is mandatory to be able to establish an account. Our
game and/or the platform/service providers (i.e., Apple App Store, Google Playetc.) collects
financial information on the terms and conditions set out in this Privacy Policy and/or the
platform/service providers’ own Privacy Policies, which can be found on the respective platforms.
Our game does not use financial information for any purpose other than processing payments.
Further you may, but may not be required to, provide certain voluntary information such as date
of birth, screen name, your personal profile in the Game, interests in and use of various games,
products, and services, and any other personal or preference information.
Our Game may also collect and process other information when you interact with the Game
online, such as the type of browser you are using, the type of operating system you are using; the
IP address or other unique identifier such as a device identifier of any of your computer(s) or
device(s) that are used to access the Game. Such information will be collected and processed
irrespective of whether you only access the Game or if you actually play the Game. Our game
may also collect and process certain information when you as a user with a user account interact
with the Game such as the information in your personal profile, the relationships you form in the
Game, the messages you send, the groups you form, the events you set up, the applications you
add and the information you transmit information through various channels.
We share your data with the following categories off third parties:
– Information technology companies (hardware and software) which provide services to
support our products.
– Fraud prevention and anti-spam providers to protect the service from criminal activity
Moderators to monitor activity on the site/apps and approve content.
– Law enforcement agencies, where we are required to by law or to protect the vital interests
of a person.
– We ensure these parties must adhere to strict data protection and confidentiality
provisions that are consistent with this Policy. Measures are taken to ensure that the data
shared is non-attributable to the greatest extent possible.
How we use your information’s:
– We use the information we collect in various ways, including to: Provide, operate, and
maintain our website and app.
– Improve, personalize, and expand our website and app.
– Understand and analyze how you use our website and app.
– Develop new products, services, features, and functionality.
– Communicate with you, either directly or through one of our partners, including for
customer service, to provide you with updates and other information relating to the
website, and for marketing and promotional purposes.
– Send you emails.
– Find and prevent fraud.

6 PRIVACY POLICY LEHBROTHERS S.R.L. ➢ Log file LEHBROTHERS follows a standard procedure of using log files. These files log visitors when they visit websites or app. All hosting companies do this and a part of hosting services’ analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users’ movement on the website, and gathering demographic information. ➢ Cookies and Web Beacons Like any other website/app, uses ‘cookies’. These cookies are used to store information including visitors’ preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users’ experience by customizing our web page content based on visitors’ browser type and/or other information. ➢ Google DoubleClick DART Cookie Google is one of a third-party vendor on our site. It also uses cookies, known as DART cookies, to serve ads to our site visitors based upon their visit to www.website.com and other sites on the internet. However, visitors may choose to decline the use of DART cookies by visiting the Google ad and content network Privacy Policy at the following URL<ahref=”https://policies.google.com/technologies/ads”>https://policies.google.com/technolo gies/ ads ➢ Advertising Partners Privacy Policies You may consult this list to find the Privacy Policy for each of the advertising partners of www.LehBrothers.com and our app mobile. Third-party ad servers or ad networks uses technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on www.LehBrothers.com/app mobile, which are sent directly to users’ browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit.

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Note that LEHBROTHERS has no access to or control over these cookies that are used by thirdparty advertisers.
➢ Automated decision making
We use automated decision-making methods which do not involve human involvement to
process your information only in the ways that are described in this Privacy Policy
We process your personal information via automated decision-making methods in order
to identify users who are suspected of cheating in the Games. Our automated decisionmaking methods are designed to detect cheating by looking out for (i) excessive currency
stores against actual completed gameplay; and (ii) excessive content against actual
purchases made and completed gameplay.
If users are determined to be or suspected of cheating the following actions may be taken
and which will be unknown to the user:
– An increase in the number of advertisements displayed within the Games, and an increase
in the frequency of suspected cheats playing against other suspected cheats.
– We may block users from the Games and/or the Online Services who are determined to
be cheating following an automated decision process.
– In this scenario the user will be notified of the outcome and will have the right to obtain
human intervention to express his or her point of view and to contest the decision to block
access to the Games and/or the Online Services.
➢ International Data Transfers
We may transfer and share your information to third parties (including service providers
operating on our behalf) which may be located in countries outside the
European Union (“EU”) and/or the European Economic Area (“EEA”) which may not have
the same level of data protection laws as those in the country where you are located. Where
your data is sent to a country outside the EU/EEA that is not subject to an adequacy
decision by the EU Commission, the transfers will only occur based on the following
safeguards: i) If the entity is certified to comply with the principles for data protection
under the US-EU Privacy Shield Framework (“Privacy Shield”) (see Privacy Shield at
www.privacyshield.gov), or ii) If we have entered into EU Commission approved standard
contractual clauses with the entity, which is deemed to offer sufficient safeguards with
respect to the protection of the privacy and fundamental rights and freedoms of
individuals.

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➢ Third Party Privacy Policies
LEHBROTHERS’s Privacy Policy does not apply to other advertisers or websites. Thus, we are
advising you to consult the respective Privacy Policies of these third-party ad servers for more
detailed information. It may include their practices and instructions about how to opt-out of certain
options.
You can choose to disable cookies through your individual browser options. To know more
detailed information about cookie management with specific web browsers, it can be found at the
browsers’ respective websites/app.
➢ GDPR Data Protection Rights
▪ You have a number of rights under UK/European data protection law.
▪ Right to be informed: what personal data an organization is processing and why (we
provide this information to you in this notice).
▪ Right of access: you can request a copy of your data.
▪ Right of rectification: if the data held is inaccurate, you have the right to have it
corrected.
▪ Right to erasure: you have the right to have your data deleted in certain circumstances.
▪ Right to restrict processing: in limited circumstances, you have the right to request that
processing is stopped but the data retained.
▪ Right to data portability: you can request a copy of your data in a machine-readable
form that can be transferred to another provider.
▪ Right to object: in certain circumstances (including where data is processed on the
basis of legitimate interests or for the purposes of marketing) you may object to that
processing.
▪ Rights related to automated decision-making including profiling: there are several
rights in this area where processing carried out on a solely automated basis results in
a decision which has legal or significant effects for the individual. In these
circumstances your rights include the right to ensure that there is human intervention
in the decision-making process.
So,
Your Choices and Controls
You have the following rights regarding your Personal Data.

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The right to request access
In accordance with Chapter III, Article 15 of the GDPR a Data Subject may request access
to processed Personal Data. This includes confirmation as to whether or not personal data
concerning him or her are being processed, and, where that is the case, access to the
personal data and the following information:
– The purposes of the processing.
– The categories of Personal Data concerned.
– The recipients or categories of recipient to whom the Personal Data have been or will be
disclosed, in particular recipients in third countries or international organizations.
– Where possible, the envisaged period for which the personal data will be stored or, if not
possible, the criteria used to determine that period.
– The existence of the right to request from the controller rectification or erasure of personal
data or restriction of processing of personal data concerning the data subject or to object
to such processing.
– The right to lodge a complaint with a supervisory authority.
– Where the Personal Data are not collected from you, any available information as to the
source.
– The existence of automated decision-making, including profiling, referred to in Article 22(1)
and (4) and, at least in those cases, meaningful information about the logic involved, as
well as the significance and the envisaged consequences of such processing for the data
subject
Where Personal Data are transferred to a third country or to an international organization,
you have the right to be informed of the appropriate safeguards pursuant to Article 46
relating to the transfer.
You shall be provided a copy of the Personal Data undergoing processing. For any further
copies requested, we may charge a reasonable fee based on administrative costs. Where
you make the request by electronic means, and unless otherwise requested by you, the
information shall be provided in a commonly used electronic form. The right to obtain a
copy shall not adversely affect the rights and freedoms of others. Please note that the
access may be restricted due to intellectual property rights or trade secrets.
The right to object
You have the right to object to the Personal Data processing on grounds relating to your
particular situation when the data are processed based on the balancing-of- interest rule
in Article 6(1)(f) of the GDPR, see Article 21 of the GDPR. In this case, we will cease the
processing unless there are compelling legitimate grounds for the processing which
override your interests, rights and freedoms or if the processing is necessary for the
establishment, exercise or defense of legal claims. You have the right to object to our
processing of your Personal Data for direct marketing purposes at any time. We will cease
the processing of your Personal Data for this purpose after the objection. Please note that
if you exercise this right, your user license to use the Game and related services will cease
automatically.

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Right of correction and erasure
You have the right to have inaccurate Personal Data rectified, in accordance with Article
16 of the GDPR.
You have the right to have your Personal Data erased where one of the following grounds
applies, see Article 17 of the GDPR:
– The Personal Data is no longer necessary in relation to the purposes for which it was
collected or otherwise processed.
– If you have withdrawn your consent and there are no other legal grounds for the
processing,
– If you have objected to the processing and there are no overriding legitimate grounds for
the processing,
– The Personal Data have to be erased for compliance with a legal obligation in Union or
Member State law,
– The Personal Data have been unlawfully processed or
– The Personal Data have Been collected in relation to the offer of information society
services.
Please note that you right to erasure may be limited if the data are necessary for
compliance with a legal obligation or for the establishment, exercise, or defense of legal
claims.
The right to restriction
You have the right to obtain restriction of processing in certain circumstances, in
accordance with Article 18 of the GDPR. If you have the right to restriction, we will only
process your Personal Data with your consent or for the establishment, exercise or
defense of a legal claim or to protect a person or important grounds of public interest.
The right to withdraw consent
If we have asked for your consent to our processing of your Personal Data, you have the
right to withdraw your consent at any time, in accordance with Article 7 of the GDPR. You
may at any time opt out of and/or unsubscribe from emails from Our games and our service
providers, or withdraw consent to Personal Data storage, either via the unsubscribe link
included in the emails, or by emailing office@uptrust.eu . If you withdraw your consent,
we will cease processing of the Personal Data for which you have withdrawn consent,
unless we have a legal obligation to keep some or parts of your data. Please note that if
you withdraw your consent, your right to play the Game and related services will cease
automatically.
The withdrawal of your consent does not affect the lawfulness of processing based on
your consent before its withdrawal.

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The right to data portability
You have the right to receive your Personal Data that you have provided to us in a
structured, commonly used and machine-readable format and have the right to transmit
those data to another controller without hinderance if the processing is based on consent
or contract performance, sin accordance with Article 20 of the GDPR.
Changing or Removing Account Information
Access and control over most Personal Data in the Game is readily available through the
profile editing tools on your account with the applicable platform/service provider that you
are accessing the game through. End Users may modify or delete any or all of their profile
information at any time by logging into their accounts. Information will be updated as soon
as possible. End Users who wish to deactivate their Game account may do so in their
accounts with the applicable platform/service provider that you are accessing the game
through. Removed information may persist in backup copies for a reasonable period of
time but will not be generally available to other End Users or visitors of the Game. You
cannot however remove communications made in any communication features in the
Game, which might have been shared with other End Users (for example sending personal
messages to another End Users).
If you wish to invoke any of the rights described above, you may contact us at any time by
emailing us at office@uptrust.eu . We will process and answer your requests without
undue delay and in any event within one month of our receipt of the request unless a longer
period is required due to the complexity of the request. In this case, our response time can
be up to three months in total as permitted by Article 12 of the GDPR.
➢ Disputes
Disputes between you and Our games
OUR GOAL IS TO RESOLVE DISPUTES FAIRLY AND QUICKLY. FOR ALL DISPUTES
AGAINST OUR GAMES, YOU AGREE TO FIRST CONTACT OUR GAMES AND TRY TO
RESOLVE THE DISPUTE INFORMALLY BY SENDING A WRITTEN NOTICE OF THE CLAIM
(“NOTICE”) TO OUR GAMES. THE NOTICE TO OUR GAMES MUST BE SENT VIA
REGISTERED LETTER TO THE ADDRESS LISTED IN SECTION BELOW OR BY EMAIL WITH
CONFIRMATION OF RECEIPT. THE NOTICE MUST (A) INCLUDE YOUR NAME, YOUR
RESIDENTIAL ADDRESS AND E-MAIL ADDRESS AND / OR MOBILE PHONE NUMBER
ASSOCIATED WITH YOUR ACCOUNT REGISTERED WITH OUR GAMES AND/OR THE
PLATFORM/SERVICE PROVIDER; (B) DESCRIBE THE TYPE AND REASON FOR THE
CLAIM; AND (C) SPECIFY THE SPECIFIC COMPENSATION SOUGHT, IF ANY. IF YOU AND
OUR GAMES CANNOT AGREE ON A SOLUTION TO THE DISPUTE WITHIN 60 DAYS OF
RECEIVING SUCH A NOTICE, EITHER PARTY MAY INITIATE LEGAL PROCEEDINGS IN
ACCORDANCE WITH SECTIONS BELOW.

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➢ User disputes
You are solely responsible for your interactions with other users of the Game. We reserve
the right, but have no obligation, to monitor disputes between you and other users.
➢ Arbitration
If you are located within the United States of America, the following applies to you: Any
claim (excluding claims for injunctive or other equitable relief) where the total amount of
the award sought by either party is less than $10,000 shall be resolved via binding nonappearance-based arbitration initiated through the American Arbitration Association
(“AAA”). The AAA Rules are available online at www.adr.org or by calling the AAA at 1-
800-778-7879. In any such arbitration, the parties and AAA must comply with the following
rules: (a) the arbitration shall be conducted by telephone, online and/or be solely based on
written submissions, the specific manner shall be chosen by the party initiating the
arbitration; (b) the arbitration shall not involve any personal appearance by the parties or
witnesses unless otherwise mutually agreed by the parties; (c) the arbitrator may award
injunctive or declaratory relief only in favor of the individual party seeking relief and only
to the extent necessary to provide relief warranted by that party’s individual claim; and (d)
any judgment on the award rendered by the arbitrator may be entered in any court of
competent jurisdiction. Nothing in this Agreement shall prevent either party from seeking
remedies in small claims court of competent jurisdiction.
The right to refrain from arbitration. You may choose to waive this arbitration term. Then
neither you nor Our games can demand that the other party take part in arbitration
proceedings. In order to refrain, you must inform Our games in writing about this within
30 days of obtaining notice of this Arbitration section. You must provide the name and
address, the e-mail address associated with your Game account (if you have one) and a
clear wording that you want to waive the arbitration terms. All requests to refrain from
arbitration must be sent to: Uptrust CyberSec SRL, Romania, Cluj County, Strada
Gospodarilor Nr. 11A, Cluj-Napoca 400403, office@uptrust.eu do not waive this arbitration
section it will.
➢ Class action waiver
YOU AGREE THAT ANY AND ALL CLAIMS MUST BE MADE IN YOUR INDIVIDUAL
CAPACITY, AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS
OR REPRESENTATIVE PROCEEDING.

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➢ Claims
YOU AND OUR GAMES AGREE THAT ANY CAUSE OF ACTION ARISING OUT OF OR
RELATED TO THE TERMS OF USE OR THIS PRIVACY POLICY MUST COMMENCE WITHIN
ONE (1) YEAR AFTER THE CAUSE OF ACTION ACCRUES. OTHERWISE, SUCH CAUSE OF
ACTION IS PERMANENTLY BARRED.
Governing law
▪ If you are located outside of the United States of America this Agreement shall be
governed by and construed in accordance with the laws of Romania, without giving effect
to any principles of conflicts of law, and the parties hereby consent to the sole and
exclusive jurisdiction of the courts of Romania, with the district court of Cluj as first venue,
to resolve any disputes arising out of or relating to this Agreement unless otherwise
required by mandatory applicable laws.
▪ If you are located within the United States of America, and unless otherwise required by
a mandatory law of any jurisdiction, this Agreement shall be governed by and construed
in accordance with the laws of the state of New York, without giving effect to any principles
of conflicts of law. You agree that any action arising out of or relating to this Privacy Policy
that is not subject to mandatory arbitration as set forth above in section 12 shall be filed
only in the state or federal courts in and for New York County, New York and you hereby
consent and submit to the personal jurisdiction of such courts for the purposes of litigating
any such action.
▪ Notwithstanding anything to the contrary, WE may apply to any court of competent
jurisdiction for injunctive or other equitable relief or payment claims.
➢ Changes to our Privacy Policy
This Privacy Policy applies to all information collected by us or provided to us on and after
the Effective Date. This Privacy Policy is subject to change, and we may make any changes
to this Privacy Policy as we see fit. Our games will notify you of material changes by
posting them on applicable game/app stores, and/or on the websites etc. You are
encouraged to check back and review this Privacy Policy from time to time so that you will
always know what information is collected how it is used and to whom it is disclosed. Your
continued use of our services and playing of the Game subject to this Privacy Policy will
signify your acceptance of Privacy Policy Changes.
THANK YOU,
LEHBROTHERS

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Information

Contact us

info@lehbrothers.com

support@lehbrothers.com

legal@lehbrothers.com

gdpr@lehbrothers.com

Romania, Cluj County, Cluj-Napoca. 8 Soporului Street, 400482.