6. Registration

You are responsible for any activity that occurs through your App account. To help maintain control over the account and prevent unauthorized access, you should maintain control over the devices used to access the Service. You agree to provide and maintain accurate information relating to your account, and to update your profile if that information changes. We can terminate your account or place it on hold in order to protect you.

Deleting your account. You may delete your account at any time from within the App, or by submitting a request through our web-based deletion request page at https://www.ensapia.com/lvlys/delete-account, which is accessible without installing or using the App. Deleting your account will result in the loss of your Virtual Content, including any unused GP, as described above.

7. Use of your Personal Data

We may ask you to submit personal information in order to use certain features of the Service. You agree to provide and maintain true, accurate, complete and current information. If you provide information that is untrue, inaccurate, incomplete or not current, we have the right to suspend or terminate your account and refuse any and all current or future use of the Service by you. We are committed to protecting your privacy — please review our Privacy Policy, which explains what information we collect and how it is used. By using the Service, you consent to all actions taken by us with respect to your information in compliance with the Privacy Policy.

8. Minor Users

The Service is not intended for children under the age of 13. If you are under 13, do not use the Service or provide any information to us. If you are over the applicable minimum age but under 18, you may use the Service only with the consent of your parent or legal guardian. We rely upon parents and guardians to determine whether the Service is appropriate for persons under 18. If you are over 18, you agree to monitor use of your account by persons younger than 18 and to accept full responsibility for any unauthorized use of your account by them, including any use of your credit card or other payment instrument. We ask for your date of birth when you first open the App to confirm you meet this minimum age requirement; if you indicate that you are under 13, you will not be permitted to create an account or use the Service.

9. Intellectual Property

All content included in the Service — including text, design, graphics, logos, avatars, user interfaces, button icons, images, photographs, audio clips, video clips, digital downloads, data compilations and software (collectively, "App Content") — is owned by us or our licensors and protected by applicable copyright laws. The Service may include registered and unregistered trademarks owned by or licensed to us, which may not be copied, imitated or used without our prior written permission. You agree that you will not apply for, register, or otherwise use or attempt to use any of our trademarks or service marks, or any confusingly similar marks, anywhere in the world without our prior written consent in each case, which we may withhold in our sole discretion.

10. User Content

You may create content using App Content made available through the Service ("UGC"). You agree that any UGC created using App Content constitutes a derivative work of our App Content, and that we retain all rights in and to the underlying App Content contained therein. We have no obligation to accept, display, review, maintain or otherwise exploit UGC, and you agree that UGC is not confidential. You retain any rights you may hold as the creator of the original, non-App Content elements of your UGC. However, you grant us a worldwide, irrevocable, perpetual, non-exclusive, transferable, royalty-free licence (with the right to sublicense) to use, copy, adapt, modify, distribute, license, sell, transfer, publicly display, publicly perform, transmit, stream, broadcast and otherwise exploit UGC for any purpose via the Service or by any other means. By making your UGC publicly available through the Service, you agree that other users may share, repost or link to it on third-party platforms including social media, provided such sharing is non-commercial and does not modify your UGC.

If you use any AI or machine learning tools within the Service to create UGC, you are responsible for ensuring that both your input data and any resulting output do not infringe any third party's intellectual property or other rights before any use, distribution or publication, and you must clearly disclose that AI or machine learning tools were used. You may use, distribute or reproduce UGC that incorporates App Content outside of the Service provided that such use is strictly non-commercial and for personal purposes only, and does not, in our reasonable opinion, harm, damage or otherwise adversely affect our reputation, brand, goodwill or business interests. Except as prohibited by law, you waive any rights of attribution and any moral rights you may have in UGC, regardless of whether it is altered or changed in a manner not agreeable to you.

Our obligation to monitor, verify, correct or remove UGC depends on your jurisdiction; we reserve the right to do so in our sole discretion from time to time. We are not liable for any damage resulting from infringement of copyright, trademark or other proprietary rights in any UGC. If you believe that any UGC infringes copyright rights held by you, you may contact us at [email protected] with: a description of the copyrighted work you claim has been infringed; a description of where the infringing material is located in the Service; your address (including country), telephone number and email address; a statement that you have a good-faith belief that the disputed use is not authorized by the copyright owner, its agent, or the law; a statement, made under penalty of perjury, that the information in the notice is accurate and that you are the copyright owner or authorized to act on their behalf; and an electronic or physical signature of the individual authorized to act on behalf of the owner of the copyright interest.

11. How We Protect You from Illegal Content

If you are a resident of the United Kingdom or the European Union, the following provision applies. This provision sets out what we do to protect you from illegal content and what technology we use to help us. We minimize the length of time for which terrorism content is present on the site, and will swiftly take it down when we find out about it. We will minimize the length of time for which child sexual exploitation and abuse content is present on the site, and will swiftly take it down when we find out about it. We will minimize the length of time for which other content amounting to an offence is present on the site — this applies to content relating to assisting suicide, threats to kill, public order offences, harassment, stalking and fear or provocation of violence, drugs and psychoactive substances, firearms and other weapons, assisting illegal immigration, human trafficking, sexual exploitation, sexual images, proceeds of crime, fraud, financial services, foreign interference, animal welfare, and offences relating to being involved in committing any of these offences (known as inchoate offences). We will swiftly take down such content when we find out about it.

12. What Content and Behaviours You Should Report

If you are a resident of the United Kingdom or the European Union, the following provision applies. You can report or complain about:

• Content you consider to be illegal.
• When you think we are not dealing with illegal content or activity as we should.
• Where you think our content reporting systems and processes do not easily let users report content they believe to be illegal, or harmful to children and accessible to children.
• When you think we have insufficiently considered the importance of protecting users' rights to freedom of expression or privacy.
• Where your content has been taken down on the basis that it is illegal.
• Where we have given you a warning, suspended, banned or restricted you in any way as a result of content we consider to be illegal.
• Where technology we use results in your content being taken down, access-restricted or deprioritized and you think the technology has been used in a way not set out in these TOS.

How to complain or report content: please see the "contact" page on the Service.

Your rights to claim against us. If you are a resident of the United Kingdom and we take down or restrict access to any content which you generate, upload or share using the Service, and we did not have a right to do this in accordance with these TOS, you will have a right to bring a claim against us for breach of contract. The same applies if we suspend or ban you from using our Service without a right to do so under these TOS. Your right to bring a claim is subject to the exclusions and limitations set out in these TOS.

13. Third-Party Services

The Service may contain links, login interfaces and other connections to third-party websites and apps. Such services are provided solely as a convenience to you, and we are not responsible for, and do not sponsor or endorse, their content. Use of third-party services may require you to accept additional terms. We are not responsible for examining or evaluating, and do not warrant the offerings of, any third-party services, and you agree to use them at your sole risk. In particular, you acknowledge that use of a third-party service may cause personally identifying information to be publicly disclosed and/or associated with you. The terms of service, privacy policy and any other terms designated by the third-party service will govern your use of it. If you have questions, concerns or complaints about a third-party service, please contact that service's support personnel.

14. Prohibited Conduct

You agree not to post, upload, transmit, distribute or otherwise publish any content that: infringes any intellectual property or other proprietary rights of any party; you do not have a right to publish; poses a privacy or security risk to any person; is threatening, abusive, harassing, tortious or bullying; is excessively violent or depicts realistic serious violence against a person or animal in graphic detail; is defamatory, libelous, or verifiably false with the purpose of harming others; constitutes hate speech that demeans or promotes discrimination or violence on the basis of race, ethnicity, gender, religion, age, or other social, physical or mental characteristics; is obscene or pornographic; constitutes sexual harassment; constitutes sexual exploitation or abuse of a minor, including sharing child sexual exploitation or abuse imagery or content, grooming, or sexual extortion; glorifies or provides instructions for self-harm, including self-injury, suicide, or eating disorders, including extreme fitness and/or body shaming content; promotes terrorism or violent extremism; furthers or promotes criminal activity; seeks to buy or sell illegal drugs; or, in our sole judgment, is objectionable or restricts or inhibits any other person from using or enjoying the Service, or which may expose us or our users to any harm or liability.

We reserve the right to investigate and take appropriate action against anyone we conclude, in our sole discretion, has violated the above. That action may include restricting the visibility of content, suspending or removing content, suspending or terminating your account, and reporting you to law enforcement.

Reporting and blocking. The Service provides tools that allow you to report content or conduct that you believe violates these TOS, and to block other users so they can no longer interact with you or view your content. Reports are reviewed and, where a violation is identified, we act on them without undue delay. You may also report content or conduct to us at [email protected].

You further agree not to: archive, download, reproduce, distribute, modify, display, perform, publish, license, create derivative works from, offer for sale, or use contents and information obtained from the App without our approval; interfere with or disrupt the Service, servers or networks, or disobey requirements, procedures, policies or regulations of connected networks; interfere with, disrupt or circumvent any security feature or any feature that restricts or enforces limitations on use of or access to the Service; infringe any right of any person or entity, including any intellectual property right; use the Service to violate applicable laws or regulations, public order or morals, or these TOS; use the Service to harm minors in any way; use the Service to reveal any personal information about another individual; pursue or solicit romantic relationships online; stalk, threaten or otherwise harass or cause discomfort to another person; use the Service for any commercial purpose, including posting or transmitting unsolicited advertising, promotional materials or other solicitation; advertise or solicit political or religious activities; have multiple accounts on one device without our approval; sell, share or give accounts to other users; modify, damage, decompile, reverse-engineer or disassemble our Service; obtain in-game contents through fraudulent or deceptive means; defraud or mislead us or other users; impersonate any person or entity or misrepresent your affiliation; use any other user's account for any purpose, including to circumvent a suspension or ban; or cheat or use, develop or distribute automation software programs ("bots"), "macro" programs or other "cheat utility" software designed to modify the Service experience. We reserve the right to determine what conduct violates these restrictions and to take action as a result, which may include termination of your account and exclusion from further participation in the Service.

15. Changes, Suspension or Termination of the Service

We reserve the right to add, change, suspend or discontinue the Service, or any aspect or feature of it, without notice or liability. You agree that we may alter the Service — including changing the various terms and changing or eliminating parts of the Service — without contacting you in advance. You also agree that we may temporarily suspend the Service without prior notice, during which you may be unable to access information you have stored; this may occur, for example, during regular or emergency maintenance.

The licence is effective until terminated by you or us. Your rights under these TOS will terminate automatically without notice if you violate any of these terms, regardless of whether the violation is by, on behalf of, or through you. Upon termination you shall cease all use of the Service and delete all copies of it. You may, as a result of termination, lose your App account and all information and data associated with it. You will not be entitled to any refund, reimbursement or other liability as a result of any termination permitted under these TOS, whether by you or us. We reserve the right to refuse to keep accounts for, or provide access to the Service to, anyone.

16. No Warranty

YOU ACKNOWLEDGE AND AGREE THAT USE OF THE SERVICE IS AT YOUR SOLE RISK AND THAT THE ENTIRE RISK AS TO SATISFACTORY QUALITY, PERFORMANCE, ACCURACY, AND EFFORT IS WITH YOU. TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE", WITH ALL FAULTS AND WITHOUT WARRANTY OF ANY KIND, AND WE HEREBY DISCLAIM ALL WARRANTIES AND CONDITIONS WITH RESPECT TO THE SERVICE, EITHER EXPRESS, IMPLIED, OR STATUTORY, INCLUDING BUT NOT LIMITED TO THE IMPLIED WARRANTIES AND/OR CONDITIONS OF MERCHANTABILITY, OF SATISFACTORY QUALITY, OF FITNESS FOR A PARTICULAR PURPOSE, OF ACCURACY, OF RELIABILITY, OF QUIET ENJOYMENT, AND OF NONINFRINGEMENT OF THIRD-PARTY RIGHTS. WE DO NOT WARRANT THAT THE SERVICE OR E-MAIL SENT FROM US ARE FREE OF VIRUSES OR OTHER HARMFUL COMPONENTS. WE DO NOT WARRANT AGAINST INTERFERENCE WITH YOUR ENJOYMENT OF THE SERVICE, THAT THE FUNCTIONS OR FEATURES PROVIDED BY THE SERVICE WILL MEET YOUR REQUIREMENTS, THAT OPERATION WILL BE UNINTERRUPTED OR ERROR-FREE, OR THAT DEFECTS WILL BE CORRECTED. NO ORAL OR WRITTEN INFORMATION OR ADVICE GIVEN BY US OR OUR AUTHORIZED REPRESENTATIVE SHALL CREATE A WARRANTY. SHOULD THE SERVICE PROVE DEFECTIVE, YOU ASSUME THE ENTIRE COST OF ALL NECESSARY SERVICING, REPAIR OR CORRECTION. SOME JURISDICTIONS DO NOT ALLOW THE EXCLUSION OF IMPLIED WARRANTIES OR LIMITATIONS ON APPLICABLE STATUTORY RIGHTS OF A CONSUMER, SO THE ABOVE EXCLUSION AND LIMITATIONS MAY NOT APPLY TO YOU.

17. Limitation of Liability

If you are not a resident of the United Kingdom or the European Union, the following provision applies: TO THE EXTENT NOT PROHIBITED BY LAW, IN NO EVENT SHALL WE BE LIABLE FOR PERSONAL INJURY OR ANY INCIDENTAL, SPECIAL, INDIRECT, OR CONSEQUENTIAL DAMAGES WHATSOEVER, INCLUDING WITHOUT LIMITATION DAMAGES FOR LOSS OF PROFITS, LOSS OF DATA, BUSINESS INTERRUPTION, OR ANY OTHER COMMERCIAL DAMAGES OR LOSSES, ARISING OUT OF OR RELATED TO YOUR USE OR INABILITY TO USE THE SERVICE, HOWEVER CAUSED, REGARDLESS OF THE THEORY OF LIABILITY (CONTRACT, TORT, OR OTHERWISE) AND EVEN IF WE HAVE BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES. SOME JURISDICTIONS DO NOT ALLOW THE LIMITATION OF LIABILITY FOR PERSONAL INJURY, OR OF INCIDENTAL OR CONSEQUENTIAL DAMAGES, SO THIS LIMITATION MAY NOT APPLY TO YOU. IN NO EVENT SHALL OUR TOTAL LIABILITY TO YOU FOR ALL DAMAGES (OTHER THAN AS MAY BE REQUIRED BY APPLICABLE LAW IN CASES INVOLVING PERSONAL INJURY) EXCEED FIFTY U.S. DOLLARS ($50.00). Some jurisdictions do not allow the exclusion of certain warranties or the limitation or exclusion of liability for incidental or consequential damages, so some of the above limitations may not apply to you.

If you are a resident of the United Kingdom or the European Union, the following provision applies: we're responsible for losses you suffer caused by us breaking these TOS unless the loss is: unexpected (it was not obvious that it would happen and nothing you said to us before we accepted your purchase meant we should have expected it — in law, the loss was unforeseeable); caused by a delaying event outside our control; avoidable (something you could have avoided by taking reasonable action — for example, damage to your own digital content or device caused by digital content we supplied, which you could have avoided by applying a free update we advised, correctly following installation instructions, or having the minimum system requirements we advised); or a business loss (relating to your use of a product for the purposes of your trade, business, craft or profession).

18. Indemnification

You are responsible for damages incurred by us and our affiliates as a result of your use of the Service, and agree to defend, indemnify and hold harmless us, our affiliates and other users from and against any and all claims, damages, costs and expenses, including attorneys' fees, arising from or related to the use of the Service and any breach of these TOS, the Privacy Policy or any other policies posted on the Service from time to time.

If you are a California resident, you waive California Civil Code Section 1542, which says: "A general release does not extend to claims that the creditor or releasing party does not know or suspect to exist in his or her favor at the time of executing the release and that, if known by him or her, would have materially affected his or her settlement with the debtor or released party." If you are a resident of another jurisdiction, you waive any comparable statute or doctrine.

19. Third-Party Beneficiary

You acknowledge and agree that the mobile application store from which you obtained the App or any service available via the App is a third-party beneficiary of these TOS, and that upon your acceptance of these TOS, such store will have the right (and will be deemed to have accepted the right) to enforce these TOS against you as a third-party beneficiary. You acknowledge that, in the event of any user or third-party claim relating to the Service or your possession and use of it, that store (including Apple and Google Play) will not have any responsibility for the investigation, defense, settlement and discharge of any such claim — including product liability claims; claims of failure to conform to any applicable legal or regulatory requirement; claims arising under consumer protection or similar legislation; and claims of infringement of a third party's intellectual property rights. Nothing in these TOS limits our liability to you beyond what is permitted by applicable law.

20. Disputes

As used in these TOS, "Dispute" means any dispute, claim, demand, action, proceeding, or other controversy between you and us concerning the Service and your or our obligations and performance under these TOS, our Privacy Policy or with respect to the Service — whether based in contract, warranty, tort (including fraud, misrepresentation, fraudulent inducement, concealment, omission, negligence, conversion, trespass, strict liability and product liability), statute (including consumer protection and unfair competition statutes), regulation, ordinance, or any other legal or equitable basis or theory. "Dispute" will be given the broadest possible meaning allowable under law. However, it does not include a claim to enforce or protect, or concerning the validity of, any of your or our (or any of our licensors') intellectual property rights, or a claim related to or arising from allegations of theft, piracy or unauthorized use.

21. Mediation and Binding Arbitration

THE MEDIATION AND BINDING ARBITRATION PROVISIONS APPLY TO USERS WHO ARE IN THE UNITED STATES. PLEASE READ THIS CAREFULLY — IT AFFECTS YOUR RIGHTS. You may opt out of arbitration within a limited period; see "Opt-out right" below.

Informal negotiation. You and we agree to attempt in good faith to resolve any Dispute before commencing arbitration. Unless otherwise agreed in writing, the time for informal negotiation will be 60 days from the date on which either party provides written notice of the Dispute, and neither party will commence arbitration before the end of that period.

Binding arbitration. If informal negotiation is not effective, arbitration shall be conducted before a single arbitrator under the Commercial Rules of the American Arbitration Association (AAA). Your arbitration fees and your share of arbitrator compensation shall be governed by the AAA Commercial Rules, Consumer Due Process Protocol and the Supplementary Procedures for Consumer Related Disputes. Unless the claim is for more than US$10,000, the arbitration shall be conducted solely through the submission of documents, by phone or online. The arbitrator shall make a decision in writing and shall provide a statement of reasons if requested by either party. YOU UNDERSTAND AND ACKNOWLEDGE THAT BY AGREEING TO BINDING ARBITRATION, YOU ARE GIVING UP THE RIGHT TO LITIGATE (OR PARTICIPATE IN AS A PARTY OR CLASS MEMBER) ALL DISPUTES IN COURT BEFORE A JUDGE OR JURY. INSTEAD, ALL DISPUTES WILL BE RESOLVED BEFORE A NEUTRAL ARBITRATOR, WHOSE AWARD WILL BE BINDING AND FINAL, EXCEPT FOR A LIMITED RIGHT OF APPEAL UNDER THE FEDERAL ARBITRATION ACT. ANY COURT WITH JURISDICTION OVER THE PARTIES MAY ENFORCE THE ARBITRATOR'S AWARD. Nothing herein will prevent us or you from pursuing a claim in small claims court with applicable jurisdiction.

Limitation. Any arbitration shall be limited to the Dispute between us and you individually. YOU AND WE AGREE THAT EACH MAY BRING CLAIMS AGAINST THE OTHER ONLY IN YOUR OR OUR INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING. Unless both parties agree otherwise, the arbitrator may not consolidate more than one person's claims and may not preside over any form of representative or class proceeding. If this provision is determined to be unenforceable, the entirety of this section shall be null and void.

Opt-out right. You can reject and opt out of this binding arbitration agreement within thirty (30) days of your first use of the Service by emailing us at [email protected] stating your intent to opt out. Opting out does not affect any other part of these TOS, including the provisions regarding controlling law or the courts in which disputes must be brought.

22. Governing Law and Dispute Resolution

Resolving disputes without going to court: if we are unable to resolve Disputes with you, you may request that alternative dispute resolution ("ADR") is used. ADR is a process for resolving Disputes between you and us that does not involve going to court, and we will provide you with the name and website address of an ADR provider competent to deal with your issue. To the extent permitted by your local laws, the laws of England and Wales govern these TOS and your use of our Service. The courts of London, England shall have non-exclusive jurisdiction over any disputes arising out of or in connection with these TOS. Nothing in this clause shall limit your right to bring proceedings in the courts of the country in which you reside.

23. Severability and Delay in Enforcement

If any of the terms or conditions of these TOS shall be deemed invalid, void or for any reason unenforceable, that provision shall be deemed severable and shall not affect the validity and enforceability of any remaining portion of these TOS. No delay or failure to take action under these TOS shall constitute any waiver by us of any provision of these TOS.

24. Complete Agreement

These TOS, the Privacy Policy, and any other policies posted in the Service from time to time constitute the complete agreement between you and us with respect to the subject matter hereof and thereof, and supersede all prior agreements or representations between you and us.

2. How We Use Your Personal Information

We use personal information that we collect about you or that you provide to us for the purposes set out in this section. If we wish to make any changes to these purposes, or if we wish to use your personal data for any purpose that is not listed in this section, we will notify you using the contact details we hold for you.

PART A: PROVISION OF THE APPS

Purpose: To provide our Apps

Purpose: Customer feedback/enquiries

PART B: ADVERTISING/MARKETING

PART C: BUSINESS ADMINISTRATION, FINANCIAL AND LEGAL

3. How Long We Keep Your Information

We will only store your information as long as necessary to fulfill the purposes for which the information is collected and processed or, where applicable law provides for longer storage and retention periods, for the storage and retention period required by law. Where we process any other personal data, we will retain relevant personal data for up to six years from the date of our last interaction with you (and in compliance with our data protection obligations). We may then destroy such files without further notice or liability.

If any personal data is only useful for a short period (such as for a specific activity, promotion or marketing campaign), we will not retain it for longer than the period for which it is used by us.

If you have opted out of receiving marketing communications from us, we will need to retain certain personal data on a suppression list indefinitely so that we know not to send you further marketing communications in the future. However, we will not use this personal data to send you further marketing unless you subsequently opt back in to receive such marketing.

4. How We Share Your Information

We may disclose aggregated information about users, and information that does not identify any individual, without restriction.

We may also disclose personal information that we collect or you provide as described in this Privacy Policy:

• To our subsidiaries and affiliates;
• To contractors, service providers, advertising partners, event partners, and other third parties we use to support our business and/or the Apps and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Ensapia’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceedings, in which personal information held by Ensapia about App users is among the assets transferred.
• To auditors, lawyers, accountants and other professional advisers;
• From time to time, to other third parties for any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including responding to any government or regulatory request.
• To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
• If we reasonably believe (within the bounds of applicable law) disclosure is necessary or appropriate to protect the rights, property, security or safety of Ensapia, our customers, or others, or to address technical issues. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Apps may then be inaccessible or not function properly.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You may opt out of receiving targeted ads from members of the Network Advertising Initiative on their website.

California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.

5. Children’s Privacy

If we learn we have collected or received personal information from a child under thirteen (13) without verification of prior parental consent, we will delete that information. If you believe we may possess or have received any information from or about a child under thirteen (13) without such prior parental consent, please immediately contact us by email at the email address provided in the “Contacting Ensapia” Section 14 below.

Notwithstanding the foregoing, PetKart may collect personal information from users under the age of thirteen (13). For a description of our information collection, use, and parental consent practices with respect to PetKart, please refer to Section 16.

In one or more countries outside the United States, the applicable age is fourteen (14) years of age, rather than thirteen (13) years of age.

California residents under sixteen (16) years of age may have additional rights regarding the collection and sale of their personal information. Please see Your California Privacy Rights below for more information.

6. How We Protect Your Information

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, theft, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. All user data collected by the Apps is encrypted in transit using industry-standard TLS encryption, and payment transactions are encrypted using SSL/TLS technology.

The safety and security of your information also depend on you. Where we have issued you (or you have chosen) a password for access to certain parts of our Apps, you are responsible for keeping your password confidential. Please do not share your password with anyone.

We do not and will not, at any time, request your credit card information, your login information or other identification in a non-secure or unsolicited communication (such as email).

Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to or on our Apps. Any transmission of personal information is at your own risk. You assume this risk by using any part of the Apps. We are not responsible for circumvention of any of our privacy settings or security measures, and/or any damages resulting from such circumvention.

7. How You May Change, Remove, Or Export Your Information

Accessing and Correcting Your Information

You can review and change your personal information by sending us an email at the email address provided in the “Contacting Ensapia” Section 14 below to request access to, object to, correct or delete any personal information that you have provided to us.

We may not accommodate a request to change information if we reasonably believe the change would violate any law or legal requirement, or cause the information to be incorrect.

If you delete your user content, copies of your user content may remain viewable in cached and archived pages, or might have been copied or stored by other users. Proper access to and use of information, including without limitation user content, is governed by our Terms of Use.

You may contact us through the App or email us at the email address provided in the “Contacting Ensapia” Section 14 below, as applicable, to request that we delete your personal information from our database. For such requests, please write “delete my personal information” in the subject line, and include your email address in the body of the message. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for administrative purposes.

You may also request deletion of your account and associated personal information at any time through the in-app account settings, or through our web-based deletion request page at https://ensapia-london.com/#delete, which is accessible without installing or using the Apps.

Please note that we will store communications you may send through the Apps, as well as any comments you may post, and they may not be subject to modification or deletion.

Please note, similar rights will apply in the UK, EEA and Switzerland. Please see the Privacy section for users from the EEA. UK and Switzerland for further information

8. Links To Third-Party Websites And Services

The Apps may contain links to other websites and online services. If you choose to click through to one of these other websites or online services, please note that any information you may provide will be subject to the privacy policy and other terms and conditions of that website or service, and not to this Privacy Policy. We do not control third-party websites or services, and the fact that a link to such a website or service appears in the Apps does not mean that we endorse its or its provider, or have approved the provider’s policies or practices related to user information.

Before providing any information to any third-party website or service, please review the privacy policy and other terms and conditions of that website or service. You agree that Ensapia will have no liability for any matters relating to a third-party website or service that you provide information to, including their collection and/or handling of that information.

9. Non-U.S. Users

When we refer to the term “GDPR” in this Privacy Policy we mean the European Union General Data Protection Regulation. Information that you provide may be transferred or accessed by entities around the world as described in this Privacy Policy. If you are located outside the United States, you understand that we may transfer personal information to and process it in the United States. In such event, transferred personal information will nonetheless be processed and held in accordance with the requirements of the applicable law in your place of residence. If you are located in the UK, EEA or Switzerland please note that your personal information may be transferred outside of the UK, EEA or Switzerland. Your consent to this Privacy Policy together with your submission of personal information constitute your agreement to these transfers. Please see the Privacy section for users from the EEA, UK and Switzerland for further information.

10. Privacy section for users from the UK, EEA and Switzerland

By continuing to use our Apps you acknowledge that your data will be processed in accordance with this Privacy Policy.

A. Data Controller

For the purposes of this Privacy Policy, ENSAPIA Corporation is the Data Controller of your personal information.

With respect to LVLYs, ENSAPIA London Ltd (126-128 New Kings Road, London, SW6 4LZ, United Kingdom) is the Data Controller of your personal information, and is the entity responsible for determining the purposes and means of processing in connection with LVLYs. Please see Section 17 for further information.

B. International transfers of personal data

Non-UK/EEA countries may not provide the same degree of protection for your personal data, may not give you the same rights in relation to your personal data and may not have a data protection supervisory authority to help you if you have any concerns about the processing of your personal data. However, when transferring your personal data (that originates from the UK, EEA or Switzerland) outside the UK, EEA or Switzerland, we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data. We will take reasonable steps to ensure the security of your personal data in accordance with applicable data protection laws.

When transferring your personal data outside the UK, EEA or Switzerland, we will, where required by applicable law, implement at least one of the safeguards set out below. Please contact us if you would like further information on the specific mechanisms used by us when transferring your personal data outside the UK, EEA or Switzerland.

• Adequacy decisions: We may transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission and/or the UK/Swiss Government (as applicable).
• Model clauses: Where we use certain service providers, we may use specific standard contractual clauses approved by the European Commission and/or the UK/Swiss Government which give personal data the same protection it has in Europe, Switzerland and/or the UK.

C. Rights of EEA Residents

If you are accessing or using the Apps from within the UK, EEA or Switzerland you may have the following rights under the GDPR (as well as other rights). If you wish to exercise any of these rights, you may do so by contacting us as provided (a) in Section 14 below, or (b) otherwise in this Privacy Policy.

• Right of Access: You have the right to obtain confirmation from us as to whether or not we process personal information from you and you also have the right to at any time obtain access to your personal information stored by us.
• Right to Correction of your Personal Information: If we process your personal information, we use reasonable measures to ensure that your personal information is accurate and up-to-date for the purposes for which your personal information was collected. If your personal information is inaccurate or incomplete, you have the right to require us to correct it.
• Right to Deletion of your Personal Information or Right to Restriction of Processing: You may have the right to require us to delete your personal information or to restrict of processing of your personal information.
• Right to Withdraw your Consent: If you have given your consent to the processing of your personal information, you have the right to withdraw your consent at any time, without affecting the lawfulness of processing based on the consent before the withdrawal.
• Right to Data Portability: You may have the right to receive personal information concerning you and which you have provided to us, in a structured, commonly used and machine-readable format or to transmit this data to another controller.
• Right to Object: You may have the right to object to the processing of your personal information as further specified in this Privacy Policy.
• Right not to be subject to automated decision making and profiling: You have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for the entering into, or the performance of, a contract between you and us.
• Right to Lodge a Complaint with Supervisory Authority: You have the right to lodge a complaint with your relevant data protection supervisory authority located in the European Union. If you are located in the EEA, further information about how to contact your local data protection authority is available on the website of the European Commission. If you are located in the UK the regulatory authority is the Information Commissioner’s Office (“ICO”). Contact details for the ICO can be found on its website at https://ico.org.uk.

D. If you fail to provide your personal data

Where we are required by law to collect your personal data, or we need to collect your personal data under the terms of a contract we have with you, and you fail to provide that personal data when we request it, we may not be able to perform the contract we have or are trying to enter into with you. This may apply where you do not provide the personal data we need in order to provide the Apps or to process an application to register an account. In these circumstances, we may have to cancel your application or the provision of the relevant Apps to you, in which case we will notify you.

11. Privacy Section For Users From the U.S.

A. Application

If you reside in California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, Nevada, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Vermont, Virginia, or Washington, this section applies to you.

B. Authorized Agent

You may designate an authorized agent to submit requests on your behalf by designating such an agent in writing. We may require the agent to provide us with proof that you have authorized the agent to make requests on your behalf prior to accepting requests from the agent.

C. Your Rights

• Right to Access: You may request a copy of your personal information that we have collected about you.
• Right to Delete: You may request to delete your personal information.
• Right to Correct: You may request to update or correct your personal information.
• Right to Opt Out: You may have the right to opt out of targeted advertising and the sale of your data (as defined under relevant and applicable law).
• To make such a request, please send an email to the email address provided in the “Contacting Ensapia” Section 14 below or write us at the address provided in the “Contacting Ensapia” Section 14 below.

We will not discriminate against you for exercising any of these rights above.

D. California Residents

As the terms are defined under the California Privacy Rights Act, we do not knowingly sell or share your personal information. We do not have actual knowledge that we sell or share the personal information of minors under 16.

If you are a resident of California, you have specific rights regarding our handling of your “personal information” as specifically defined in California’s “Shine the Light” law (Cal. Civil Code Section § 1798.83). This law permits users of our Apps who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to the email address provided in the “Contacting Ensapia” Section 14 below or write us at the address provided in the “Contacting Ensapia” Section 14 below.

Within thirty (30) days of receiving such a request, we will provide a list of the categories of personal information disclosed to third parties for such third parties’ direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. A request may be made no more than once per calendar year and we are not required to respond to requests made by means other than through the email address and mailing address above.

12. Privacy section for users from the Republic of Korea

We provide the Apps and web services around the world. In accordance with the precedents in the Republic of Korea, personal information includes the user ID and account password you set on the Apps.

Subsidiaries or affiliated entities of ENSAPIA Corporation in the Republic of Korea may share personal information with our affiliates and/or third parties, including entities located outside of the Republic of Korea, on prior notice for the following purposes:

• To support the operation of the Apps; and
• To support the customer support services.

Personal information that subsidiaries or affiliated entities of ENSAPIA Corporation in the Republic of Korea share shall be or may be used, processed, and stored in accordance with the purposes below. We share personal information as follows:

13. Privacy section for users playing Fashion Fable: Dress Up Style

If you play Fashion Fable: Dress Up Style, this section applies to you.

Personal Information We Collect

We may collect the same personal information detailed in Section 1, with the exclusion of photos, videos, and recordings.

How we collect your personal information

In addition to the methods detailed in Section 1, we may collect personal data about you from third parties as follows:

• Firebase
• Google Play Services (Android)
• Game Center (iOS)

14. Contacting Ensapia

If you have any questions, inquires, requests, comments or complaints concerning this Privacy Policy or our information practices, please contact us below.

15. Standards Against Child Sexual Abuse and Exploitation

Ensapia does not allow users to create or post contents or engage in activities that sexually exploit, abuse or endanger children. We report all identified instances of sexual exploitation, abuse or endangerment of a minor to the appropriate regional authority.

Ensapia also prohibits users from posting or sharing any pornographic content such as photos, videos, illustrations, images and computer-generated imagery, including those that depict a minor engaging in sexually explicit conduct.

Users are prohibited from posting content or engaging in interactions or activities that depict, encourage or promote sexual abuse and exploitation of children, including real human children as well as non-real depictions of children such as avatars, characters or other forms of art or AI-generated content.

Examples of child sexual abuse and exploitation that are prohibited include:

• Inappropriate interaction targeted at a child such as groping or caressing.
• Child grooming, such as befriending a child online to facilitate, either online or offline, sexual contact and/or exchanging sexual imagery with that child.
• Sexualization of a minor, such as imagery that depicts, encourages or promotes the sexual abuse of children or the portrayal of children in a manner that could result in the sexual exploitation of children.
• Sextortion, such as threatening or blackmailing a child by using real or alleged access to a child’s intimate images.
• Trafficking of a child, such as advertising or solicitation of a child for commercial sexual exploitation.

Users are also prohibited from posting content or engaging in interactions or activities that depict, encourage or promote excessive violence, blood and gore, harmful and dangerous activities as well as negative body or self-image.

Users should report any inappropriate content they encounter through [email protected]

16. Children’s Privacy Policy for PetKart

This section describes how we collect, use, and share personal information from or about children under the age of 13 in connection with PetKart.

When a child uses PetKart, we may collect the following categories of personal information:

• Apps Profile data: Your username, your avatar, interests and preferences.
• Technical and Usage Data/Networking Activity: including:
  • Details of your visits to and actions in PetKart, including traffic data, location data, logs and other communication data, the resources that you access, and your use of PetKart.
  • Information about your device and internet connection, including as applicable, your IP address through which you access PetKart, operating system, browser type, mobile network information, location, time zone, the unique mobile device ID or virtual unique device identifier for any mobile device used to access your account.
  • Metadata and other information associated with files stored on your device.
  • Information about your internet connection, the device you use to access PetKart, and related usage details.
• User Content: Chat communications you upload or submit through the Apps.
• Messages: Communications you send to us through the Apps, as well as any information you provide when contacting us.
• Transaction data: Details of transactions you carry out through PetKart using in-game currency.
• Automatic Data-Collection Technologies

When you access and use PetKart, we will collect resettable device identifiers. Resettable device identifiers can be used like cookies and are found on many mobile devices and tablets (for example, the “Identifier for Advertisers” on Apple iOS devices and the “Google Advertising ID” on Android devices). Resettable device identifiers are used to make online advertising more relevant, and for analytics and optimization purposes.

We do not knowingly collect real names, home addresses, phone number, photographs, or any other directly identifying information from children beyond what is listed above. We collect only the minimum information necessary to provide the Service.

How We Use Your Personal Information

We use personal information that we collect about you or that you provide to us for the purposes set out in this section.

• To provide you with PetKart;
• To process your registration and to identify you when you log into your account;
• To detect, prevent, and respond to unauthorized access, and other security threats;
• To identify and resolve technical bugs, crashes, and service disruptions;
• To measure aggregate performance indicators. This analysis is used solely for internal improvement.

Parental Consent

We will not knowingly collect personal information from a child under 13 without first providing notice to the child’s parent or guardian, where required, and obtaining verifiable parental consent.

Where PetKart requires account creation for a child, we will:

• Notify the parent or guardian by email, explaining what information we collect and how we use it.
• Provide the parent or guardian with the ability to consent to our collection and use of the child’s information.
• Refrain from collecting personal information if consent is not provided within a reasonable time.

How We Share Your Information

We may disclose personal information that we collect, or you provide as described in this section:

• To Zendesk for handling user inquiries and support;
• To Braze for marketing activities;
• To Firebase (Google) for App analytics, quality improvement; and
• To Google/Apple for login authentication.

How We Protect Children’s Information

We take the security of children’s personal information seriously and implement technical and organizational measures to protect it. If you believe your child’s information has been compromised, please contact us immediately at [email protected]

Data Retention

We retain children’s personal information only for as long as is necessary to fulfil the purposes described in this section, or as required by applicable law.

Parents Rights and Controls

Parents and guardians have the following rights with respect to their child’s personal information:

• Right to Review: Parents and guardians may request a copy of the personal information we have collected from your child.
• Right to Correct: Parents and guardians may request that inaccurate information be corrected.
• Right to Delete: Parents and guardians may request that we delete your child’s personal information. Please note that deletion may result in the child’s account or certain features being unavailable.
• Right to Withdraw Consent: Parents and guardians may withdraw consent for our continued collection and use of your child’s information.

To exercise any of these rights, please contact us:

ENSAPIA Xenon Inc.
Email: [email protected]
Address: 115 Broadway, 3rd Fl. Room#142, New York, NY 10006, USA

17. Privacy Section for Users Playing LVLYs

If you play LVLYs, this section applies to you in addition to the rest of this Privacy Policy.

Notwithstanding anything to the contrary elsewhere in this Privacy Policy, including Section 2 (Part B: Advertising/Marketing) and Section 4 (How We Share Your Information), the provisions of this Section 17 govern with respect to LVLYs. We do not engage in cross-context behavioural advertising, behavioural tracking, or personalised advertising based on your activity on third-party websites or services in connection with LVLYs.

Data Controller and UK Representative

ENSAPIA London Ltd is the Data Controller for personal information processed in connection with LVLYs. ENSAPIA London Ltd is established in the United Kingdom at 126-128 New Kings Road, London, SW6 4LZ, United Kingdom, and is also designated in writing as the United Kingdom representative of ENSAPIA Corporation for the purposes of Article 27 of the UK General Data Protection Regulation in respect of LVLYs. Users in the United Kingdom, and the Information Commissioner's Office, may contact ENSAPIA London Ltd at the address above or at [email protected] in relation to all matters concerning the processing of personal information in connection with LVLYs.

Personal Information We Collect

In addition to the personal information described in Section 1, we collect your date of birth to verify that you are at least 13 years of age and eligible to use LVLYs.

Analytics and Advertising Measurement

Some of the personal information we collect is used and disclosed for analytics and advertising measurement purposes. In addition to the technologies we operate, we incorporate technologies offered by service providers. For example, we use technologies from analytics providers to help evaluate and report on the use of LVLYs, and we engage a mobile measurement partner to measure the effectiveness of our advertising campaigns on our behalf.

We have chosen not to utilize advertising services that constitute a “sale,” “share,” or use of personal information of consumers for “targeted advertising” purposes in those U.S. states that require such activities to be subject to an opt-out. For those U.S. states that require an opt-out, we require the advertising partners with whom we work to process the personal information they receive only as permitted by a service provider or processor under applicable state privacy law, and solely to provide the contracted services. We enforce these restrictions through contractual obligations and, where available, technical controls such as Limited Data Use and Restricted Data Processing settings. Accordingly, we are not required to provide an opt-out of the “sale,” “share,” or use of personal information for “targeted advertising,” as those terms are defined under applicable laws.

Location Information

LVLYs does not request or collect precise or approximate geolocation information from your device. References to location data elsewhere in this Privacy Policy do not apply to LVLYs, other than to the extent that your general country or region may be inferred from your IP address for security, fraud prevention, and legal compliance purposes.

Deleting Your Account and Your Data

You may delete your LVLYs account and the personal information associated with it at any time from within the App, or by submitting a request through our web-based deletion request page at https://ensapia-london.com/#delete. This page is accessible without installing or using LVLYs. Upon deletion, we will delete or de-identify your personal information, except where we are required to retain certain records to comply with legal, accounting, tax, or fraud-prevention obligations.