Privacy Policy

1. WHICH INFORMATION MAY WE COLLECT?

We collect data about you in connection with your transactions with us, or in processing data for enabling our Services. One type of data collected is non-identifiable and anonymous information ("non-personal data"). We also collect several categories of personal data ("Personal Data"), as described below.

Personal Data which is being gathered consists of any details which are personally identifiable and which are provided by you, through your registration and use of our websites, mobile applications or Facebook gaming platforms (as described below), by email, or other ways in which you communicate and interact with us. This generally includes your name (first and last), email address, log-in username and password, IP address, country, Facebook identifiers, date of birth, address, passport/ID info and user activity across Company's mobile and web applications and Facebook.

During your use of our gaming platforms, we also collect data regarding your activity, profiles, and in-app purchases.

Additionally, we may obtain location data related to the geographic location of your laptop, mobile device or other digital device on which the Baba Entertainment gaming platforms are used.

You do not have any legal obligation to provide any information to Baba Entertainment, however, we require certain information in order to perform contracts, or to provide any Services. If you choose not to provide us with certain information, then we may not be able to provide you or your organization with some or all of the Services.

We also collect your billing information in order to process your payments when conducting in-app purchases.

By contacting us or submitting requests for information or support via the websites, mobile applications or Facebook, email etc., Baba Entertainment will collect details, including also your name, phone number and personal or company email you provided, country and other information provided by you. Baba Entertainment uses this information to offer Baba Entertainment's Services and support.

2. HOW DO WE COLLECT PERSONAL DATA OF YOURS ON BABA ENTERTAINMENT SERVICES?

We collect Personal Data required to provide Services when you interact with, register, or when you provide us such information, by entering it manually or automatically, when using our gaming platforms or otherwise engaging with us. We also collect Personal Data when you call us for support, in which case we collect the information you provide us.

We also collect Personal Data through your use of our websites, mobile applications or other platforms. In other words, when you are using any one of our platforms, we are aware of it and may gather, collect and record the information relating to such usage, either independently or through the help of third-party services as detailed below. This includes technical information and behavioral information such as the user's Internet protocol (IP) address used to connect your device to the Internet, your uniform resource locators (URL), operating system, type of browser, browser plug-in types and versions, screen resolution, Flash version, time zone setting, the 'clickstream' on the platform, and the period of time the user visited the platforms. We likewise may place cookies on your browsing devices (see 'Cookies' section below).

3. WHAT ARE THE PURPOSES OF PERSONAL DATA WE COLLECT?

We will use Personal Data to provide and improve our Services to our users and others and meet our contractual, ethical and legal obligations. All Personal Data will remain accurate, complete and relevant for the stated purposes for which it was processed, including:

Processing which is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract: providing and maintaining the Services, including to monitor the usage of Services; carrying out obligations between you and Baba Entertainment and/or to provide you with the information, gaming elements, support and Services that you request from Baba Entertainment; verifying and carrying out financial transactions in relation to payments you make in connection with the Services.

Processing which is necessary for the purposes of the legitimate interests pursued by Baba Entertainment or by a third party of providing an efficient and wide-ranging service to users: notifying you about changes to our Services and/or to financial products we manage; contacting you to give you commercial and marketing information about events or promotions or additional products or Services offered by Baba Entertainment which may be of interest to you, including in other locations (these communications may be in the form of push notifications, email, or text messaging); soliciting feedback in connection with the Services; tracking use of Baba Entertainment Services to enable us to optimize them for security purposes and to identify and authenticate your access to the login zone.

Processing which is necessary for compliance with a legal obligation to which Baba Entertainment is subject: compliance and audit purposes, such as meeting our reporting obligations in our various jurisdictions, anti-money laundering, tax related obligations, and for crime prevention and prosecution in so far as it relates to our staff, users, service providers, facilities etc. if necessary, we will use Personal Data to enforce our terms, policies and legal agreements, to comply with court orders and warrants and assist law enforcement agencies as required by law, to collect debts, to prevent fraud, infringements, identity thefts and any other service misuse, and to take any action in any legal dispute and proceeding.

4. SHARING DATA WITH THIRD PARTIES

Personal Data is processed at Baba Entertainment's offices and in any other places where the parties involved in the processing are located – meaning that Personal Data may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

Your consent to this Privacy Policy followed by submissions of such information represents your agreement to that transfer. It is your decision whether or not to share your personal information, if you opt to provide us with your Personal Data by logging into the Services (and creating an account), this action will be considered opting-in to sharing your Personal Data. At any time, you may opt out of this. Please see below in order to learn more about our Opt Out Plan.

Baba Entertainment will take all reasonable steps to ensure that Personal Data is treated securely and in accordance with this Privacy Policy and no transfer of Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Personal Data and other personal information.

We transfer Personal Data to:

Third Parties. We transfer Personal Data to third parties in a variety of circumstances. We endeavor to ensure that these third parties use your information only to the extent necessary to perform their functions, and to have a contract in place with them to govern their processing on our behalf. These third parties include business partners, suppliers, affiliates, agents and/or sub-contractors. They assist us in providing the Services we offer, processing transactions, fulfilling requests for information, receiving and sending communications, analyzing data, providing IT and other support services or in other tasks, from time to time. These third parties may also include analytics and search engine providers that assist us in the improvement and optimization of our websites and Apps, and our marketing.

We periodically add and remove third party providers. At present services provided by third-party providers to whom we transfer Personal Data include also the following:

• Website and App analytics
• Document management and sharing services
• Client ticketing and support
• On-site and cloud-based database services
• CRM software
• Marketing, user acquisition and retargeting platforms (such as Bigabid, RTB House and others)
• Data security, data backup, and data access control systems
• Our lawyers, accountants, and other standard business software and partners.

In addition, we will disclose your Personal Data to third parties if some or all of our companies or assets are acquired by a third party including by way of a merger, share acquisition, asset purchase or any similar transaction, in which case Personal Data will be one of the transferred assets. Likewise, we transfer Personal Data to third parties if we are under a duty to disclose or share your Personal Data in order to comply with any legal or audit or compliance obligation, in the course of any legal or regulatory proceeding or investigation, or in order to enforce or apply our terms and other agreements with you or with a third party; or to assert or protect the rights, property, or safety of Baba Entertainment, our users, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction and to prevent cybercrime.

For avoidance of doubt, Baba Entertainment may transfer and disclose non-Personal Data to third parties at its own discretion.

The Services may also contain links to other websites that are not operated by Baba Entertainment. If you click on a third party link, you will be directed to that third party's site. We strongly advise you review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third party sites or services.

5. WHERE DO WE STORE YOUR DATA?

We store your Personal Data on servers owned or controlled by Baba Entertainment, or processed by third parties on behalf of Baba Entertainment, by reputable cloud-service providers (see the following section regarding international transfers).

6. INTERNATIONAL DATA TRANSFERS (EU DATA SUBJECTS)

EU Personal Data is transferred to, and stored and processed at, a destination outside the European Economic Area (EEA). This includes transfer to our headquarters in Israel, a jurisdiction deemed adequate by the EU Commission, and to the USA, not currently deemed adequate. Where your Personal Data is transferred outside of the EEA, we will take all steps reasonably necessary to ensure that your Personal Data is subject to appropriate safeguards, including entering into contracts that require the recipients to adhere to data protection standards that are considered satisfactory under EU law and other applicable law, and that it is treated securely and in accordance with this Privacy Policy. Transfers to Israel are made based on an adequacy ruling by the EU Commission. Transfers to the USA are made based on the Standard Contractual Clauses published by the EU Commission. For more information about these safeguards, please contact us as set forth below.

We transfer Personal Data to locations outside of the EEA, including in particular USA and Israel, in order to:

• store or backup the information
• enable us to provide you with the Services and products and fulfill our contract with you
• fulfill any legal, audit, ethical or compliance obligations which require us to make that transfer
• facilitate the operation of our group businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights
• to serve our users across multiple jurisdictions; and
• to operate our affiliates in an efficient and optimal manner

7. DATA RETENTION

Baba Entertainment will retain Personal Data it processes only for as long as required in our view, to provide the Services and as necessary to comply with our legal and other obligations, to resolve disputes and to enforce agreements. We will also retain Personal Data to meet any audit, compliance and business best-practices.

Data that is no longer retained will be anonymized or deleted. Likewise, some metadata and statistical information concerning the use of our Services are not subject to the deletion procedures in this policy and will be retained by Baba Entertainment. We will not be able to identify you from this data. Some data may also be retained on our third-party service providers' servers until deleted in accordance with their privacy policy and their retention policy, and in our backups until overwritten.

8. SERVICES AND WEBSITES DATA COLLECTION AND COOKIES

Baba Entertainment uses cookies, pixel tags and other forms of identification and local storage (together referred to as "tags/files" hereunder) to distinguish you from other users of the platform. This helps us to provide you with a good user-experience when you browse the platform and also allows us to improve our Services.

In many cases, these tags/files lead to the use of your device's processing or storage capabilities. Some of these tags/files are set by Baba Entertainment itself, others by third parties; some only last as long as your browser session, while others can stay active on your device for a longer period of time.

These tags/files can fall into several categories: (i) those that are necessary for functionality or Services that you request or for the transmission of communications (functionality tags/files); (ii) those that we use to carry out website performance and audience metrics (analytics tags/files) and (iii) the rest (tracking across a network of other websites, advertising, etc.) (other tags/files).

Internet browsers allow you to change your cookie settings, for example to block certain kinds of cookies or files. You can therefore block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies, you may not be able to access all or parts of the website, due to the fact that some may be functionality cookies. For further information about deleting or blocking cookies, please visit: https://www.aboutcookies.org/how-to-delete-cookies/

Functionality and analytical tags/files do not require your consent. For other tags/files, however, we request your consent before placing them on your device. You can allow cookies in your browser settings and using our website cookie management too.

To consult the list of cookies which we use on our website, please check your browser's settings. Instructions: https://www.wikihow.com/View-Cookies

The Services may include links to other websites, such as banner ads and other advertising tools. These websites and other advertisers may place and access their cookies on your devices. Any such actions or use of cookies by any other entity other than Baba Entertainment, is subject to such third parties' privacy policies and not the Privacy Policy of Baba Entertainment.

9. SECURITY AND STORAGE OF INFORMATION

We take great care in implementing, enforcing and maintaining the security of the Personal Data we process. Baba Entertainment implements, enforces and maintains appropriate security measures, technologies and policies to prevent the unauthorized or accidental access to or destruction, loss, modification, use or disclosure of Personal Data. These safeguards are designed to prevent loss, misuse, and unauthorized access, disclosure, alteration, and destruction of the information we collect from you and the Services. We likewise take steps to monitor compliance of such policies on an ongoing basis. Where we deem it necessary in light of the nature of the data in question and the risks to data subjects, we encrypt data. Likewise, we take industry standard steps to ensure our gaming platforms and Services are safe.

Note however, that no data security measures are perfect or impenetrable, and we cannot guarantee that unauthorized access, leaks, viruses and other data security breaches will never occur.

Within Baba Entertainment, we endeavor to limit access to Personal Data to those of our personnel who: (i) require access in order for Baba Entertainment to fulfill its obligations, including also under its agreements, and as described in this Privacy Policy, and (ii) have been appropriately and periodically trained with respect to the requirements applicable to the processing, care and handling of the Personal Data, and (iii) are under confidentiality obligations as may be required under applicable law.

Baba Entertainment shall act in accordance with its policies and with applicable law to promptly notify the relevant authorities and data subjects in the event that any Personal Data processed by Baba Entertainment is lost, stolen, or where there has been any unauthorized access to it, all in accordance with applicable law and on the instructions of qualified authority. Baba Entertainment shall promptly take reasonable remedial measures.

If you believe your account may have been compromised, please contact us immediately at support@HomeGymFood.com. You should not share your password or login information and you should keep your account secure. You are responsible for maintaining the secrecy of your password and account information.

10. DATA SUBJECT RIGHTS

Depending on where you live, you may have certain rights regarding the Personal Data that we collect. This includes users to whom the GDPR or UK GDPR applies. These rights may include (depending on the lawful basis for processing): rights to data portability, rights to access data, rectify data, restrict processing, and erase data. Data subjects also have the right to object to processing of their Personal Data. It is clarified for the removal of doubt, that where Personal Data is provided by a user being the data subject's employer, such data subject rights will have to be effected through that user, the data subject's employer. In addition, data subject rights cannot be exercised in a manner inconsistent with the rights of Baba Entertainment employees and staff, with Baba Entertainment proprietary rights, and third-party rights. As such, job references, reviews, internal notes and assessments, documents and notes including proprietary information or forms of intellectual property, cannot be accessed or erased or rectified by data subjects. In addition, these rights may not be exercisable where they relate to data that is not in a structured form, for example emails, or where other exemptions apply. If processing occurs based on consent, data subjects have a right to withdraw their consent. You can do so by emailing Baba Entertainment at privacy@baba-ent.com.

A data subject who wishes to modify, delete or retrieve their Personal Data, may do so by contacting Baba Entertainment (privacy@baba-ent.com). Note that Baba Entertainment may have to undertake a process to identify a data subject exercising their rights. Baba Entertainment may keep details of such rights exercised for its own compliance and audit requirements. Please note that Personal Data may be either deleted or retained in an aggregated manner without being linked to any identifiers or Personal Data, depending on technical commercial capability. Such information may continue to be used by Baba Entertainment.

Data subjects in the EU or UK have the right to lodge a complaint, with a data protection supervisory authority in the place of their habitual residence. If the supervisory authority fails to deal with a complaint, you may have the right to an effective judicial remedy. A list of supervisory authorities in the EEA is available here: https://edpb.europa.eu/about-edpb/board/members_en. The UK supervisory authority may be contacted at: https://ico.org.uk/make-a-complaint/.

Direct Marketing and Certain Third-Party Data Sharing. When we process your Personal Data for direct marketing purposes or share it with third parties for their direct marketing purposes, you can exercise your right to object to this processing at any time by emailing us at privacy@baba-ent.com. You may unsubscribe from our marketing or promotional emails by clicking the "Unsubscribe" link in our emails.

SMS Text Messaging. If you opt in, you may receive text messages from Baba Entertainment. We may send account related texts to, for instance, alert you to important account information. We may also send you marketing related messages to the cell number you provided when signing up. To opt-out of receiving text messages from us, text "Stop" to the number from which you received the message. We will send you one final message to confirm that you have been unsubscribed, and will process your request within a reasonable time after receipt. You may also email us at privacy@baba-ent.com. Message and data rates may apply.

11. GENERAL

Minors. We do not knowingly collect or solicit information or data from or about children under the age of 18 without parental consent, or knowingly allow children under the age of 18 to register for Baba Entertainment Services. If you are under 18, do not register or attempt to register for any of the Baba Entertainment Services or send any information about yourself to us. If we learn that we have collected or have been sent Personal Data from a child under the age of 16 without appropriate permissions, we will delete that Personal Data as soon as reasonably practicable without any liability to Baba Entertainment. If you believe that we might have collected or been sent information from a minor under the age of 18, please contact us at: privacy@baba-ent.com as soon as possible.

California Shine the Light Disclosures. If you reside in California, you may request certain general information regarding our disclosure of personal information during the preceding year to third parties for their direct marketing purposes. To make such a request, please write to us at the following address: support@HomeGymFood.com

Changes to this Privacy Policy. The terms of this Privacy Policy will govern the use of the Services, websites, mobile applications and any information collected in connection with them. Baba Entertainment may amend or update this Privacy Policy from time to time. The most current version of this Privacy Policy will be available at: https://www.baba-entertainment.com/play-privacy-policy. Changes to this Privacy Policy are effective as of the stated "Last Revised" date and your continued use of our Services will constitute your active acceptance of the changes to and terms of the Privacy Policy.

Baba Entertainment aims to process only adequate, accurate and relevant data limited to the needs and purposes for which it is gathered. It also aims to store data for the time period necessary to fulfill the purpose for which the data is gathered. Baba Entertainment only collects data in connection with a specific lawful purpose and only processes data in accordance with this Privacy Policy. Our policies and practices are constantly evolving and improving, and we invite any suggestions for improvements, questions, complaints or comments concerning this Privacy Policy, you are welcome to contact us (details below) and we will make an effort to reply within a reasonable timeframe.

Baba Entertainment's data protection officer (DPO) may be contacted at: privacy@baba-ent.com.