Dragon Privacy&Policy

Game Privacy Policy-Dragon Covenant

Update Date: May 11,2026

Effective Date: May 1,2016

Update Notice:

To better protect your rights, we have updated our Game Privacy Protection Policy in compliance with relevant laws and regulations. If you have any questions or suggestions, please contact us as outlined in Section 9 of this Policy.

Major Changes in This Update:

1.To clarify our game product's security policies more clearly, we have detailed the rules for handling personal information in anti-cheating and anti-hacking scenarios.

2.Other language optimizations.

Summary:

Welcome to the games and related services provided by Luminaya Games

This Game Privacy Protection Policy outlines how we collect, use, store, and share your personal information when you use our games, as well as your associated rights.

Address is:

ADENAN

BRANGKAL RT/RW 002/001 KEL. BRANGKAL KEC. BANDAR KEDUNGMULYO

JOMBANG - 61462

Indonesia (ID)

Key Points:

To provide you with gaming entertainment, player interaction, and consumption services, we need to collect your game history, device information, login logs, etc.

You can manage your personal information and related authorizations as outlined in this Policy.

We employ multi-faceted security measures to ensure a reasonable level of security for your personal information.

For a more detailed understanding of the correspondence between personal information types and their uses, please read the full version of this Policy.

Table of Contents:

1.Personal Information We Collect and Use

2.Sharing, Transferring, and Public Disclosure of Personal Information

3.Storage of Personal Information

4.Cross-Border Transfers of Personal Information

5.Information Security

6.Your Rights

7.Changes

8.Other Provisions

9.Contact Us

1. Personal Information We Collect and Use

In the process of using our game services, our games will collect the following information from you, either actively provided or generated through your usage, to provide, optimize our services, and ensure your account security:

1.1 When you register or use our game services, we collect your network identity information to identify you as a user of our games. You can use account registration, guest login, or other authorized accounts (hereinafter referred to as "third-party accounts") to register and log in to any of our game products.

If you use account registration, guest login, or third-party accounts, we collect unique identifiers, nicknames, avatars, friend relationships, or other authorized information to facilitate registration, login, and enhance social experiences. You can view and manage these authorizations within your account registration, guest login, or third-party platforms. You may also choose to fill in additional information such as gender, region, and other details to complete your game account profile.

1.2 During game usage, we collect game log information, including login logs, item logs, operation information, game match details, friendship records, etc., for you to view your game history in the client, and for customer service complaints and security analysis. To improve your gaming experience, we may sync this information to future versions of the game.

1.3 To ensure normal service usage, maintain game functionality, optimize performance, and safeguard your account, we collect device information such as app version, app ID, ADID, country/region code, device language, resolution, system version, and usage details like operation timestamps.

1.4 When using in-game consumption features, we collect recharge and transaction records to provide services, allow you to view your transaction history, and maximize virtual item security. Recharge and transaction records are sensitive personal information required for these functions; without them, transactions cannot be completed.

1.5 To maintain a fair, healthy, and secure gaming environment, we collect device and game identification information, including device IDs, hardware and OS details, installed app lists, processes, crash logs, and overall game usage. This information is used to combat cheating and disruptive behavior. We conduct scans locally and report abnormalities, without storing or using your app lists or package info for other purposes.

1.6 During in-game interactions (text, images, voice, video), we may collect and save your content to filter out inappropriate material, maintaining a clean gaming environment.

1.7 For in-game interactions involving photos, voice, or video, we access your photo/storage files, microphone, and camera with your consent, providing screenshot saving, image uploading, voice chat, and live streaming. Refusal of these permissions does not affect other game features, and you can revoke them anytime.

1.18 Please understand that the functions and services we provide to you are continuously updated and developed. If a function or service collects your information that is not covered in the aforementioned descriptions, we will explain the content, scope, and purpose of the information collection to you separately through page prompts, interactive processes, website announcements, and other means to obtain your consent.

1.19 Currently, in addition to collecting game research information from third-party research institutions to help us improve our game products and provide services suitable for you, as well as the situations clearly stated in this agreement, we will not actively obtain your personal information from third parties. If in the future, for business development purposes, we need to indirectly obtain and process your personal information from third parties, we will strictly comply with relevant laws and regulations, require that third party to obtain your consent, and ensure the legality of the information provided.

2. Sharing, Transfer, and Public Disclosure of Personal Information

2.1 Sharing of Personal Information

Except for the situations stipulated in this agreement, we will not proactively share your personal information with third parties without your consent. If there are other situations where we need to share your personal information or if you request us to share your personal information with third parties for purposes beyond the original authorized scope, we will obtain your explicit consent directly or indirectly through the third party for these actions.

1. Agency Products: If you use the game products that we distribute on behalf of others, we may share the logs and related information (such as login logs) generated by you in the game with the development entity or relevant third parties for game security analysis, improving game services, and further optimizing the user's gaming experience. If we share the aforementioned information, we will strictly comply with relevant laws and regulations and take corresponding compliance measures to ensure that the sharing of personal information complies with relevant legal requirements.

These compliance measures include but are not limited to requiring the development entity or relevant third parties to strictly abide by the agreements made with you regarding the collection and use of your personal information, urging them to adopt appropriate security technologies and management measures to ensure the security of your personal information, etc.

2. Associated Product Services: When you use other products or services provided by us that are not our own games ("associated products"), with your explicit authorization, we will bind your selected game product account with the associated products and share your nickname, avatar, achievements, or other information you authorize with the associated products to display to you or other users within the associated products, so that you can participate in game benefit activities and redeem corresponding benefits within the associated products. Specific personal information collection and use rules will be synchronized with you during account binding and completed after obtaining your authorization and consent.

You can view and manage your game history information authorization on the [Settings] page of the associated product, or choose whether to display your game history information to other users. Refusing to authorize will not affect your use of other functions of our games and associated products.

3. Third-Party Services: To ensure the safe and stable operation of the game and to realize specific functions, some services in our games are provided by our affiliates or other third parties. We will carefully select third parties and third-party services, urge relevant third parties to collect and use your personal information in accordance with this agreement or separately agreed upon with you, and adopt appropriate security technologies and management measures to ensure the security of your personal information. Details are as follows:

Third-Party SDKs:

Meta (Facebook SDK): For login functionality, data encryption and storage are conducted in accordance with Meta's Privacy Policy during service provision.

Google Play: Enables Google account login and payment functionalities, allowing users to log in and make in-app purchases on the platform, adhering to Google Play's Privacy Policy.

Adjust Data Statistics: We report to Adjust: Device ID data, User Attribution data, Network Activity data, IP Addresses, and User Agents. We utilize this information for data analysis (including operational and usage analysis) to improve services on our game servers.

Firebase Advertising Information: This includes Device data (operating system, model, app store, app version), Device Identifiers, Event data (session duration, geolocation, opens/launches/updates, purchases, country/region, interests, language, new/established users, ad clicks, and impressions), and Analytics data (usage, clearances, crashes, deletions, payments).

AppsFlyer Data Statistics: Technical Information

Technology-related information pertaining to your device, including Technical Identifiers: Unique identifiers that typically only identify your device, browser, or application, such as IP addresses, Advertising IDs, Open IDs, and User Agents.

MQTT Protocol: We employ the MQTT protocol for pushing messages from our servers to game clients. MQTT is an efficient, lightweight messaging protocol suitable for real-time communication. We ensure appropriate security measures are in place during data transmission, including data encryption and identity authentication, to protect your privacy and data security. No personally identifiable information is transmitted via the MQTT protocol; the content is limited to game-related notifications and updates. If you have any concerns regarding data transmission methods or privacy protection measures, please feel free to contact us.

4. Statistical Analysis and Research

To enhance our capabilities in security management and technological research, as well as to improve service security and technical proficiency, we may share de-identified or anonymized data with research institutions, academies, universities, and other organizations within a reasonable and necessary scope, ensuring legitimate purposes and data security. Without your explicit authorization, we will not share information that could identify you personally with these organizations.

2.2 Public Disclosure of Personal Information

Unless otherwise specified in this Agreement, we will not publicly disclose the personal information we collect. If disclosure is necessary, we will inform you of the purpose of the disclosure, the types of information to be disclosed, and any potentially sensitive personal information involved, and obtain your express consent.

Please note that if you violate the terms of this Agreement or engage in any illegal activities while using our games, we may announce the results of any disciplinary actions taken and disclose relevant account information in the announcement.

2.3 Personal Information Transfer

Without your authorization, we will not transfer your personal information to third parties. As our business continues to grow, there may be instances of mergers, acquisitions, asset transfers, etc. In such cases, we will inform you of the relevant situations and continue to protect or require the new processor to protect your personal information in accordance with laws and regulations, as well as standards that are no less stringent than those required by this Agreement.

3. Storage of Personal Information

3.1 Methods and Duration of Information Storage

We store your information securely, including through local storage (e.g., using app data caching), databases, and server logs. Generally, we only store your personal information for the time necessary to fulfill service purposes or as required by laws and regulations. After the expiration of the aforementioned period, we will delete or anonymize your personal information. Our determination of the storage period for personal information is primarily based on the following criteria, with the longer duration prevailing:

1.Completing the business functions you agreed to use;

2.Ensuring the security and quality of services we provide to you;

3.Any longer retention period agreed upon by you;

4.Other provisions regarding retention periods.

3.2 Geographic Location of Information Storage

We store user personal information collected in accordance with laws and regulations within the region where the game is distributed.

3.3 Notification Upon Discontinuation of Product or Service Operation

In the event that our products or services cease to operate, we will make an announcement and notification in accordance with relevant laws and regulations, ensuring the protection of your legitimate rights and interests.

4. Cross-border Transmission of Personal Information

If the game you use is developed or provided by overseas developers or related parties (hereinafter referred to as "Overseas Recipients"), and we are the agent responsible for its distribution and operation in that region, we may provide the relevant personal information collected under this Agreement to these Overseas Recipients for game security analysis and service improvement. Before providing your personal information to Overseas Recipients, we will obtain your separate consent as required by law and inform you of the detailed rules regarding cross-border transmission of personal information.

5. Information Security

5.1 Security Measures

We strive to ensure the security of user information to prevent leakage, loss, misuse, unauthorized access, and disclosure. We employ a multi-faceted approach to security, including technical protection measures, management controls, and security system guarantees, to maintain a reasonable level of security for user personal information.

We recommend that you pay close attention to the protection of your personal information when using our products and services, and we also provide various security features to assist you in safeguarding your personal information (e.g., password setting and modification).

5.2 Response Measures for Security Incidents

In the event of a security incident such as personal information leakage, we will activate emergency response plans to prevent the incident from escalating. After a security incident occurs, we will inform you of the basic situation, the measures we will take or have taken, remedies, and our recommendations for you through announcements, push notifications, or emails. If it is difficult to notify each individual, we will issue warnings through announcements.

6. Your Rights

During your use of our game services, we may provide you with corresponding operational settings specific to the game product, allowing you to inquire, copy, correct, supplement, delete, or withdraw your relevant personal information. You can refer to the specific agreement of the corresponding game product for operation. Additionally, we have established complaint and reporting channels to ensure timely handling of your feedback.

6.1 Inquiry into Personal Information Collection and Usage Rules

You can view the personal information collection and usage rules for each of our game products at any time in the "Settings" interface, including but not limited to this Agreement, the "Third-Party Information Sharing List," as well as the rules and authorization status for the use of sensitive permissions for that product.

Please note that the services and corresponding personal information collection and usage described in this Agreement may vary based on the specific services you choose to use, as well as factors such as the device model and system version you are using.

6.2 Personal Information Inquiry and Correction

1.You can inquire and access your account's basic information (avatar, nickname, and other personal information you choose to fill in), as well as game history information (such as character level, achievements, battle records, and specific game information for each product) within the game products provided by Luminaya Games that you use.

2.You can query your account registration information or guest login account information corresponding to the account you use to log in to our games through the account floating window. If you find any errors in the queried account information, you can apply for modifications by contacting customer service. However, please note that to ensure account stability and security, prevent unauthorized theft and transfer of accounts, the frequency of authentication modifications will be limited.

3.Within each product, you can query more information about your use of specific game products and services provided by Luminaya Games according to the prompts based on the actual situation of the product. For details, please refer to the instructions in the [Settings] interface of each product.

4.If you have other inquiries, replication, correction, or supplementation needs regarding personal information, you can also contact us through the contact information specified in Article 10 of this Agreement. However, please note that when you contact us to apply for a response to your personal information rights, to ensure account and personal information security, we may verify your identity, account security status, etc. We will support your reasonable requests as much as possible. However, in cases where your request exceeds our personal information storage scope, exceeds reasonable limits, or responding to your request will cause serious damage to the legitimate rights and interests of you or other third parties, we may not be able to respond to your application.

6.3 Personal Information Display and Sharing

1.Your game account's basic information (avatar, nickname, character level) will be displayed on your personal homepage, rankings you participate in, or related functions.

2.Your game history information (including but not limited to your login status, battle information/status, achievement information) will be displayed to you or other users or friends based on your choices. The game product will provide you with relevant permissions according to specific circumstances, so that you can set whether to publicly display the aforementioned relevant information. Please refer to the instructions within each product for details.

3.Information that you upload or publish on your own within our game products, or information that you actively share externally, will be displayed to users within the scope you choose to publish or share.

4.When you authorize a third party to access your information within our games, the third party will disclose your relevant information to you or other users of that third party within the scope of your authorization. Please pay attention to the rules of the third-party platform for specific display rules and settings for the scope of disclosure.

6.4 Changes to Personal Information Collection and Use Authorization

You can change the scope of your authorization for us to collect and use your personal information by deleting information, turning on or off specific product functions, or turning on or off device permissions accessed by specific products (specific permissions vary depending on the device model and system version used by the user).

After revoking your authorization, you may not be able to use the product features corresponding to that authorization, but it will not affect the use of other features. Your revocation of authorization does not affect the validity of personal information processing activities that have already been carried out based on your authorization before the revocation.

Some personal information collection and usage correspond to the basic functions of our services. If you wish to withdraw the authorization for the collection and use of relevant personal information, it may result in our inability to provide services to you. In this case, if you still wish to withdraw the relevant authorization, you can achieve this by applying for account deletion. For example, based on legal and regulatory requirements, real-name authentication is necessary to use game services. If you wish to withdraw your authorization for us to collect real-name authentication information and request us to delete your real-name authentication information, we may not be able to continue to provide you with basic game product services.

6.5 Account Deletion

You can apply for account deletion through [Settings] - [Account Deletion] in our game products or through other channels notified within the product. When you apply for account deletion, we will verify your identity, account security status, and deletion conditions. Please carefully read the instructions in the account deletion process. Unless otherwise specified by laws, regulations, or this Agreement, your personal information under this game account will be deleted or anonymized, and previously associated products and services related to this game account will no longer be associated. Once the account deletion is completed, it cannot be recovered. Please operate with caution.

7.Changes

8.We may revise this Agreement from time to time. When changes occur to the rules of personal information collection and use stated in this Agreement and other matters prescribed by laws and regulations, we will appropriately notify you of the revised Agreement upon version update. Please read the revised Privacy Protection Agreement or the content of the Agreement carefully. Your continued use of our games indicates your agreement to our collection, processing, or use of your personal information in accordance with the updated Privacy Protection Agreement.

9.Others

10.The "Game Privacy Protection Agreement" is a general privacy policy uniformly applicable to our games, and the content stipulated therein, including but not limited to user rights and information security measures, applies to all our game users. Some game products are equipped with their own separate privacy policies to further elaborate on the collection and use of personal information specific to those products. In case of any inconsistency or contradiction between this Agreement and the separate privacy policy of a game product, the privacy policy separately configured and displayed within that product shall prevail.

11.Contact Us

12.We have established a dedicated personal information protection team and a personal information protection officer. If you have any questions, complaints, or suggestions regarding this Privacy Policy or personal information protection, you can contact us in the following ways:

1）Send your inquiry to dmmxransdigital.official@gmail.com

2)Mail your inquiry to the following address:

ADENAN

BRANGKAL RT/RW 002/001 KEL. BRANGKAL KEC. BANDAR KEDUNGMULYO

JOMBANG - 61462

Indonesia (ID)

We will review the matter promptly and respond to your request within 15 working days or within the time limit prescribed by laws and regulations.

By developer [ Luminaya Games]