Embedded Files
Updated on:January 30, 2023
Effective from: January 30, 2023
Update Notice:
To better protect your rights, we have updated the “Game Privacy Policy” in accordance with legal regulations. If you have any questions or suggestions, please contact us as described in Article 9 of this agreement.
Main changes in this update:
We have provided more detailed explanations of the personal information processing rules in the context of anti-cheat and anti-hack scenarios to clearly explain the security strategies of our game products.
Other textual optimizations.
Summary: Welcome to the games and related services provided by [Apple developer and Google developer: Dolphin Games, Ltd. ] (hereinafter referred to as “Dolphin”). Through the “Game Privacy Policy,” we explain how we collect, use, store, and share your personal information when you use our games, as well as your related rights.
Our company’s registered address is [3/F, Block 15, 28 Cheung Sha Wan Road, Kowloon, Hong Kong].
Key points:
To provide you with gaming entertainment and related player interactions and consumption services, we need to collect your game history, device information, login logs, and other information.
You can manage your personal information and related authorizations as described in this agreement.
We adopt multi-faceted security measures to ensure that your personal information is protected at a reasonable security level.
By reading the full version of the agreement, you can understand the detailed personal information processing rules, including the types and purposes of personal information.
Personal Information We Collect and Use
Sharing, Transfer, and Public Disclosure of Personal Information
Storage of Personal Information
Cross-border Transfer of Personal Information
Information Security
Your Rights
Changes
Others
Contact Us
1. Personal Information We Collect and Use During your use of our game services, we will collect the information you actively provide or generate due to the use of services to provide and optimize our services and ensure the security of your account.
1.1 When you register or use our game services, we will collect your network identity information to mark you as a user of our games. You can register and log in to any of our game products using an account registration, guest login, or other accounts recognized by us (hereinafter referred to as “third-party accounts”). If you use account registration, guest login, or third-party accounts to log in to our games, we will collect the unique identifier, nickname, avatar, and friend relationships or other authorized information involved in the account registration, guest login, or third-party accounts to help you complete registration and login and achieve a better social experience. You can view and manage the authorization status of the above information in the account registration, guest login, or third-party platforms. You can also choose to fill in gender, region, and other information to improve your game account information according to the specific situation of the game product. 1.2 When you use our game services, we will collect your game log information, such as login logs, item logs, operation information, game match information, friend records, etc., so that you can view your game history in the client, and for customer service complaint handling and other game security analysis. To enhance your gaming experience, we may synchronize the aforementioned information to subsequent versions of the game. 1.3 To ensure your normal use of our services, maintain the normal operation of basic game functions, optimize game product performance, enhance your gaming experience, and ensure the security of your account, we will collect your device information: application version, application ID, ADID, country/region code, device language, device resolution, system version information, and information about your use of the game, such as the date and timestamp of operations. 1.4 When you use the consumption functions of our game products, we will collect your recharge records, consumption records, and other information to provide services and allow you to query your transaction records while maximizing the protection of your virtual items. Recharge records and consumption records are sensitive personal information, and collecting the above information is necessary to achieve the consumption functions of our game products; otherwise, the transaction cannot be completed. 1.5 To ensure the security of your gaming environment and devices and create a fair, healthy, and safe gaming environment, we will collect your device and game identification information, such as device identifiers, hardware and operating system information, installed application lists, process and game crash records, overall game usage, game channel sources, etc., to combat behaviors that disrupt the fair environment of the game or interfere with or disrupt the normal operation of game services (such as for scanning plug-ins, preventing cheating, etc.). Specifically, before you start a game match or when there is abnormal installation behavior, we will scan the feature values of suspicious application installation packages you have installed through the application list for plug-in or cheating software detection. We will only complete the above detection locally on your device and report abnormal results without storing your application list and installation package information on the server or using it for any other purpose. 1.6 When you interact with other players in the game through text, pictures, voice, video, and other means, we may collect and save the content of the information you send to filter inappropriate content such as pornography, violence, politics, abuse, malicious advertisements, etc., to purify the game environment and maintain a healthy online environment. 1.7 If you wish to interact with other game players through pictures, voice, video, and participate in live broadcasts, after you authorize and agree, the game will access your photos or storage files, microphone, and camera to provide you with screenshot saving, picture uploading, voice chat, live interaction, and other functions. If you refuse to authorize, you will not be able to use the corresponding functions, but it will not affect your normal use of other functions of our games, and you can cancel the relevant permissions at any time. 1.8 If you wish to interact with nearby game players, after you authorize and agree to our use of location permissions, we will collect your location information to find nearby game players, allowing you to match and team up with nearby players. Location information is sensitive personal information, and refusing to provide this information will only prevent you from interacting with nearby game players, but it will not affect your normal use of other functions of our games, and you can cancel your location information authorization at any time. 1.9 If you choose to use the photo face customization function, we need you to provide and use photos containing your facial recognition features. We will inform you again of the relevant personal information collection and use rules when you use the relevant functions and obtain your authorization and consent to access your photos through the album or camera. You can also choose to refuse authorization or refuse to use the relevant functions, and refusal will not affect your normal use of other functions of our games. Without further explanation and obtaining your consent, we will not retain or use your photos for other purposes. 1.10 When you copy information within the product for sharing or receive shared information within the product, we need to access your clipboard locally on the device to read the passwords, redemption codes, and other related information to achieve benefits acquisition, event participation, and sharing functions. We will only read information related to our services to complete the relevant instructions and will not store such information. We will not collect other unrelated information from your clipboard. 1.11 During game events, if you choose to subscribe to event reminders, we need to apply for calendar permissions to set reminders in your device calendar. 1.12 We may collect your phone number if you actively provide it to notify you of the results of the activities you participate in, report game failures, and provide feedback and communication on your inquiries, or with your consent, push information or promotional information you are interested in. 1.13 If you contact our customer service, we may need you to provide necessary personal information for identity verification to ensure the security of your account. To provide services based on your requests, with your authorization, customer service personnel need to query or verify your relevant information within the scope of your authorization. We will take technical and management measures as much as possible to ensure the security and confidentiality of your information and use it within the necessary scope. We may also save your contact information (phone number, account registration number, guest login number, or other contact information you use or actively provide), your communication records and content with us, and other necessary information to provide and record customer service. 1.14 We may analyze your game data to understand your preferences to better display content that may interest you in our games. If a product or service involves the above content display, you can manage the display content through the [Settings] of the product or service or other specified methods. For details, please refer to the instructions within the product. 1.15 We use cookies and other similar technologies (such as web beacons, log files, scripts, and electronic tags) (“Cookies”) to enhance your experience using our services. Cookies are small files placed on your device that allow us to provide certain features and functions. You can choose to allow the installation of such Cookies or disable them later. You can accept all cookies, instruct the device (for games) to provide notifications when cookies are installed, or refuse to accept all cookies by adjusting the relevant cookie retention function in the device. However, if you refuse to install cookies, the game may not function as designed. 1.16 We will analyze the operation of our products based on the frequency and situation of users using our game products, fault information, performance information, etc., to ensure service security and optimize our products and improve our service quality. However, we will anonymize or de-identify the relevant information before using it for analysis, and we will not
2. Sharing, Transfer, and Public Disclosure of Personal Information
2.1 Sharing of Personal Information Except as provided in this agreement, we will not actively share your personal information with third parties without your consent. If there are other situations where your personal information needs to be shared or used beyond the original authorized purpose, we will directly or indirectly obtain your explicit consent through the third party.
Agency Products
If you use game products distributed by us, we may share logs and related information (such as login logs) generated in the game with the development entity or related third parties for game security analysis, service improvement, and further optimization of the user experience. We will take appropriate compliance measures in accordance with relevant laws to ensure that the sharing of personal information complies with legal requirements. These measures include but are not limited to requiring the development entity or related third parties to strictly comply with the agreement reached with you, collect and use your personal information as agreed, and take appropriate security measures to protect your personal information.
Associated Product Services
When you use other products or services provided by us that are not our games (“associated products”), with your explicit authorization, we will bind your selected game account with the associated product and share your game account’s nickname, avatar, achievements, or other authorized information with the associated product. This is to display the information to you or other users within the associated product, allowing you to participate in game-related activities and receive corresponding benefits. The specific rules for collecting and using personal information will be synchronized with you when binding the account, and the account binding and information sharing will be completed after obtaining your authorization. You can view and manage your game history information authorization on the associated product’s [Settings] page or choose whether to display your game history information to other users. Refusing authorization does not affect your use of other functions of our games and associated products.
Third-Party Services
To ensure the safe and stable operation of the game and achieve 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, urging relevant third parties to collect and use your personal information in accordance with this agreement or other agreements reached with you, and take appropriate security measures to protect your personal information. Details are as follows:
Meta: Facebook SDK login function, data encryption, and storage according to Meta’s privacy policy.
Google Play: Google account login and payment functions, enabling users to log in and make in-app purchases according to Google Play’s privacy policy.
Adjust Data Statistics: Reporting device ID data, user attribution data, network activity data, IP address, and user agent to Adjust for data analysis (including operational and usage analysis) to improve game server services.
Firebase Advertising Information: Device data (operating system, model, app store, app version), device identifiers, event data (session duration, location, open/start/update, purchase, country/region, interests, language, new/established, ad clicks and impressions), and analysis data (usage, clearing, crashes, deletions, payments).
AppsFlyer Data Statistics: Technical information related to your device, technical identifiers: usually unique identifiers for your device, browser, or app, such as IP address, advertising ID, Open ID, and user agent.
MQTT Protocol: We use the MQTT protocol to implement server-to-game client message push. MQTT is an efficient lightweight messaging protocol suitable for real-time communication. We ensure appropriate security measures, including data encryption and authentication, during data transmission to protect your privacy and data security. We do not transmit personally identifiable information through the MQTT protocol; the transmission content is limited to game-related notifications and updates. If you have any questions about the data transmission method or privacy protection measures, please feel free to contact us.
Statistical Analysis and Research To improve our security management and technical research capabilities, promote service security and technical levels, and provide better services to users, we may share data processed by de-identification or anonymization with research institutions, scientific research institutes, and universities within a reasonable and necessary scope, ensuring the legitimacy of the purpose and data security. Without your explicit authorization, we will not share information that can identify you personally with the above institutions.
2.2 Public Disclosure of Personal Information Except as otherwise provided in this agreement, we will not publicly disclose the collected personal information. If public disclosure is necessary, we will inform you of the purpose of the disclosure, the type of information disclosed, and any sensitive personal information involved, and obtain your explicit consent.
Please note that if you violate the content of this agreement or engage in any illegal activities while using our games, we may announce the handling results and disclose relevant account information in the announcement.
2.3 Transfer of Personal Information Without your authorization, we will not transfer your personal information to third parties. As our business continues to develop, we may engage in mergers, acquisitions, asset transfers, and other transactions. We will inform you of the relevant circumstances and continue to protect your personal information in accordance with legal requirements and standards no lower than those required by this agreement or require the new processor to continue protecting your personal information.
3. Storage of Personal Information
3.1 Methods and Duration of Information Storage We will store your information securely, including local storage (e.g., data caching using the app), databases, and server logs. Generally, we will only store your personal information for the time necessary to achieve the service purpose or as required by laws and regulations. After the aforementioned period expires, we will delete or anonymize your personal information. We determine the storage period of personal information mainly based on the following criteria, whichever is longer:
Completion of the business function you agreed to use.
Ensuring the security and quality of the services we provide to you.
The longer retention period you agree to.
Other provisions regarding retention periods.
3.2 Information Storage Location We will store the collected user personal information in the game distribution region in accordance with legal requirements.
3.3 Notification of Product or Service Termination If our products or services are terminated, we will notify you in accordance with relevant laws and regulations and protect your legal rights.
4. Cross-Border Transfer of Personal Information If the game you use is developed or provided by an overseas developer or related party (hereinafter referred to as “overseas recipient”) and distributed and operated by us in that region, we may provide the relevant personal information collected under this agreement to the overseas recipient for game security analysis and service improvement. Before providing your personal information to the overseas recipient, we will obtain your separate consent in accordance with legal requirements and inform you of the detailed rules for cross-border provision of personal information.
5. Information Security
5.1 Security Protection Measures We strive to ensure the security of user information to prevent information leakage, loss, misuse, unauthorized access, and disclosure. We use multi-faceted security measures to ensure that the protection of users’ personal information is at a reasonable security level, including technical protection measures, management system controls, and security system guarantees.
We recommend that you pay full attention to the protection of personal information when using products and services. We also provide various security features to assist you in protecting your personal information (e.g., password setting modifications).
5.2 Security Incident Handling Measures In the event of a personal information leakage or other security incident, we will initiate an emergency plan to prevent the expansion of the security incident. After the security incident occurs, we will inform you of the basic situation of the security incident, the measures we are taking or have taken, and the remedial measures, as well as our suggestions for your response, through announcements, push notifications, or emails. If it is difficult to notify each individual, we will issue a warning through announcements and other means.
6. Your Rights
During your use of our game services, we may provide you with corresponding operation settings based on the specific situation of the game product, allowing you to query, copy, correct, supplement, delete, or withdraw your relevant personal information. You can refer to the specific agreement of the corresponding game product for operation. In addition, we have set up complaint and reporting channels, and your opinions will be handled promptly.
6.1 Querying Rules for Personal Information Collection and Use You can view the rules for personal information collection and use of each product in our games at any time on the [Settings] interface of the product, including but not limited to this agreement, the “Third-Party Information Sharing List,” and the rules and authorization status for the use of sensitive permissions of the product.
Please be aware that the services and corresponding personal information collection and use described in this agreement may vary depending on the specific services you choose to use and factors such as the model and system version of the device you use.
6.2 Querying and Correcting Personal Information
You can query and access your account basic information (such as account avatar, nickname, and other personal information you choose to fill in), game history information (such as character level, achievements, battle records, and specific game information) in the game products you use.
You can query the account information corresponding to the account registration account or guest login account you use to log in to our games through the account floating window. If you find that the queried account information is incorrect, you can apply for modification through customer service. However, please note that to ensure account stability and security and prevent illegal use and transfer of accounts, the frequency of authentication modifications will be limited.
You can query more information about your use of specific game products and services of our company according to the actual situation of the product and the prompts in the product. For details, please refer to the instructions on the [Settings] interface of each product.
If you have other needs for querying, copying, correcting, or supplementing personal information, you can also contact us through the contact information described in Article 10 of this agreement. However, please note that when you contact us to apply for a response to your personal information rights, we may verify your identity, account security status, etc., to ensure the security of your account and personal information. We will support your reasonable requests as much as possible. However, if 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 request.
6.3 Display and Sharing of Personal Information
Your game account basic information (avatar, nickname, character level) will be displayed on your personal homepage, the rankings you participate in, or related functions.
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 according to your choice. The game products will provide you with relevant permissions according to the specific situation, allowing you to set whether to publicly display the aforementioned information. For details, please refer to the instructions within each product.
Information you upload or publish in our game products, or information you actively share with others, will be displayed to users within the scope you choose to publish or share.
When you authorize third parties to obtain your information in our games, the third parties will publicly disclose your relevant information to you or other users of the third party within the scope of your authorization. Please pay attention to the rules of the third-party platform for specific display rules and public scope settings.
6.4 Changes to the Authorization for Collection and Use of Personal Information
You can change the scope of authorization for us to collect and use your personal information by deleting information, closing or enabling specific product functions, or closing or enabling device permissions obtained by specific products (the specific permissions may vary depending on the device model and system version used by the user). After withdrawing authorization, you may not be able to use the functions corresponding to the authorization, but it will not affect the use of other functions. Withdrawing authorization does not affect the effectiveness of personal information processing activities that have already been carried out based on your authorization before the withdrawal.
Some personal information collection and use correspond to the basic functions of our services. If you wish to withdraw the authorization for the collection and use of related personal information, it may result in our inability to provide you with services. In this case, if you still wish to withdraw the relevant authorization, you can achieve this by applying for account cancellation. For example, based on legal requirements, using game services requires real-name authentication. If you wish to withdraw the 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 providing you with basic game services.
6.5 Account Cancellation
You can apply for account cancellation in our game products through [Settings] - [Account Cancellation] or other channels separately notified within the product. When you apply for account cancellation, we will verify your identity, account security status, and cancellation conditions. Please carefully read the instructions in the account cancellation process. Unless otherwise provided by laws and regulations or this agreement, the personal information under the game account will be deleted or anonymized, and the related products and services previously associated with the game account will no longer be associated. Once the game account is canceled, it cannot be restored. Please operate with caution.
The specific operation process is as follows:
Open App——come to My Center——Settings-Delete account ——AgreeCancellation Agreement——Complete
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