Last updated: Feb 28, 2025
This Privacy Policy is all about how we handle your info when you use the Service – like what we collect, how we use it, and when we might share it. It also covers your privacy rights and the protections you’ve got by law. By using the Service, you’re giving us the okay to collect and use your info as outlined here.
OVERVIEW OF PRIVACY POLICY
This User Privacy Notice ("Policy") gives you all the details on how 罗海镔 ("Haibin Luo", "we", "us", or "our") handles your personal data when you use our websites, apps, web apps, content, features, digital events, or products (we call them the "Services"). This Policy is a key part of 罗海镔's Terms of Service ("Terms"). When we say "Personal data," we mean anything that could identify you, either directly or indirectly – like your name, phone number, email, device info, and how you use the Services. Just so you know, this Policy doesn’t cover third-party games you might play through our Services. Those games have their own privacy policies, and you’ll need to check with the game developers ("Game Partners") for more info.
If you are under 18 years old, you are not permitted to use 罗海镔's applications.
We share data with third parties that assist us in delivering and analyzing the Services. These third parties will also implement user protection measures equivalent to ours, including:
· Our corporate affiliates and transaction parties when we’re doing business deals
· Law enforcement and regulators if it’s needed for legal or security reasons
· Service providers who help us run and secure our Services and handle marketing
· Advertising platforms and networks for managing our campaigns
· Marketing vendors who help with campaigns and event planning
· Analytics providers who give us insights and trends
· Game Partners to offer personalized content and marketing
We might also share aggregated or anonymized data that can't be used to identify individuals or devices, unless the law says otherwise.
We might link or combine your personal data to create a more personalized experience. How we use your personal data includes:
· Delivering and improving our Services, like awarding Points
· Customizing Services with game, feature, and event recommendations
· Marketing our Services on outside platforms
· Running contests, sweepstakes, and online events
· Handling operational and business stuff, like processing payments and giving out rewards
· Verifying identities to avoid fraud
· Innovating and improving new products and updates for our Services
· Generating reports and insights using aggregated or anonymized data
· Communicating with you based on your preferences
· Troubleshooting and fixing technical issues
· Offering full technical and customer support
The reasons we process your personal data might include:
· Fulfilling our contract with Users
· Following legal and regulatory rules
· Our legitimate business interests, like improving services and preventing fraud
· Getting your consent, if required by law
6.1 Children's Privacy: We follow all laws that protect kids’ privacy. If you think we’ve collected information about a child, get in touch with us.
6.2 Data Retention: We keep your personal data as long as it’s needed for its intended purpose, as long as you’re using the Services, or as required by law. If you’re inactive for a long time or decide to delete your account, your data may be removed. For data held by Game Partners, please reach out to them directly.
By using our Services, you acknowledge and agree to the practices and policies outlined in this Privacy Policy.
We may choose or be compelled by law to provide different or additional information regarding the processing of personal data for residents of certain countries, regions, or states.
SPECIFIC RIGHTS FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA, SWITZERLAND AND THE UNITED KINGDOM (“EEA, SUI & UK”)
This Europe and United Kingdom Notice offers additional details for users in the EEA, SUI, and UK. Unless otherwise stated in this Europe and United Kingdom Notice, all other terms and principles in 罗海镔’s Privacy Policy remain applicable.
Users in the EEA and UK have certain privacy rights as outlined under applicable laws, including the General Data Protection Regulations (“GDPR”), Article 13 of the Swiss Constitution and Federal Act on Data Protection (DPA), and the UK Data Protection Act. The Policy and the privacy options we provide to all users are aligned with these regulations. As a resident of the EEA, SUI & UK, you also have specific rights concerning your personal data.
You can exercise any of these rights by getting in touch with us using the details below:
Access: You can ask for a copy of the personal data we have about you. There are some exceptions though, and we might not give you access if, for example, sharing it would affect another person’s rights or if we’re legally not allowed to share it.
Accuracy: We aim to keep your personal data accurate and up to date. If anything changes, let us know and we’ll update our records.
Objecting: In some cases, you can object to how we process your personal data. You can ask us to stop, delete, or limit how we use it.
Rectification: If any of your personal data is wrong, you can ask us to fix it. You can also ask us to complete any missing info, based on what we’re using it for.
Data Portability: Depending on legal rules, you can request your personal data in a structured, commonly used, and machine-readable format so you can switch services, or ask us to send it to another provider, if it’s possible.
Erasure: You can ask for your personal data to be erased if it’s no longer needed for the purposes we collected it for, or if the legal conditions for erasure are met.
Automated Decision-Making: You have the right not to be subject to decisions based only on automated processing (including profiling) that have significant effects on you, as long as certain legal conditions are met.
Complaints: If you're not happy with how we’re handling your data, you can file a complaint with the relevant data protection authority.
For France: You also have the right to give instructions about how your personal data should be handled after your death, like how long it’s kept, deleted, or communicated.
The specific legal requirements for exercising these rights depend on the data protection laws that apply to you. For your security, we’ll only respond to requests about personal data linked to the email address you use in your request, and we might need to verify your identity before processing certain requests. If you’re a data subject in the EEA, SUI, or UK, you can access your rights with respect to 罗海镔 by reaching out as directed in the Contact Us section of this Policy.
1. SUBMITTING COMPLAINTS
If you are a resident in the European Economic Area (EEA), you have the right to lodge a complaint at any time to your local regulatory authority. For information on how to contact your local regulator, please visit EDPB
For those residing in the UK, you can submit a complaint at any time to the Information Commissioner’s Office (ICO), the UK's supervisory authority for data protection issues. Complaints can be filed via the ICO’s website at ICO, where you will also find additional contact information for the ICO.
2. TRANSFERS OF PERSONAL DATA
For users based in the EEA, Switzerland (SUI), and the UK, we may transfer your personal data outside of the EEA, for instance, to countries where we operate or where our service providers are located, such as the United States, where our affiliated corporation and hosting provider are situated. By agreeing to the transfer of your personal data outside of your country of residence, you understand that your information may be sent to recipients in the United States and other nations that might not provide the same level of data protection as the laws in your country of residence or citizenship.
Some non-EEA countries have been deemed by the European Commission to provide an adequate level of data protection in line with EEA standards. For transfers to countries not recognized by the European Commission as having adequate protection, we have implemented appropriate safeguards, such as standard contractual clauses approved by the European Commission, to ensure the protection of your personal data. In certain situations, courts, law enforcement, regulatory bodies, or security authorities in countries outside the EEA may have the right to access your personal data. If you wish to obtain a copy of the safeguards we have put in place (where possible), please contact us as indicated in the Policy.
1.ADDITIONAL DISCLOSURES FOR RESIDENTS OF CALIFORNIA, USA
This section is specifically for residents of California and supplements the other sections of 罗海镔's Privacy Policy, which remain applicable.
Collection and Use of Personal Information: Over the past 12 months, we have collected the following categories of personal information about you:
CATEGORY
EXAMPLES
SOURCE
BUSINESS PURPOSE
Identifiers
Name, email, unique personal identifier, other accountId,online identifier, IP address, account name, and phone number
User provided on upon redeeming coins using online catalog; related and third-party sources to verify user supplied information;
Operational purposes including customer service; fraud & security incident detection; website improvement; award prize winners; and deliver our Services to you, including personalized recommendations and advertisements
Internet or other similar network activity
Browsing and searching history, or information about your interaction with a website, application, or advertisement
System-collected activity logs and cookies
To determine performance of media content and analytics purposes and to secure our Services
Approximate geolocation data
Country
Identified using IP address
To recommend games based on your country and to secure our Services
Please note that we use and disclose sensitive personal information only for purposes expressly permitted under California law. Personal data does not include publicly available information from government records and de-identified or aggregated consumer information.
Disclosure of Personal Information: We may disclose your personal information to third parties for the business purposes outlined in our Privacy Policy. In the past 12 months, we may have disclosed your personal information for a business purpose or at your direction. For more details on third parties we share data with, see the "How We Share Personal Information About You" section of this Policy. Although we do not "sell" personal information in exchange for money, some of our sharing of personal information as part of our Services may be classified as a "sale" under applicable California laws. We do not knowingly sell or share the personal information of anyone under the age of 16.
Retention of Your Data: 罗海镔 will retain personal data only as long as necessary for providing the Services, as required by law, or for as long as it is needed for the purposes for which it was collected. For instance, account balances or rewards earned as of termination must be preserved for a period to allow for billing and tax reporting. Under our Terms, if a user does not use the Service for at least one hundred eighty days, the user’s inactive account may be terminated, units earned may expire, subject to the Terms of Use, and the user’s personal data may be destroyed.
Notice of Financial Incentive: Under California law, the Rewards Program that allows you to earn Units may be considered a financial incentive provided in exchange for the collection and retention of personal information. While 罗海镔 does not assign a monetary value to the data we collect, the value received from the insights and the Rewards Program is estimated to be reasonably equal to or greater than the value received from the use of this information. We use the information to better understand how you use our Services, improve our products and Services, and enhance our user analytics. Participation in the Rewards Program is entirely voluntary, and you can withdraw at any time. For further details of the Rewards Programs and its terms, including how to withdraw or terminate your participation, please refer to the Terms.
Your CCPA Rights: The California Consumer Privacy Act (CCPA) provides California consumers with the following rights regarding their personal information:
· Right to Know. You have the right to know what personal information we have collected about you, including the categories of personal information, the sources from which it is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
· Right to Delete. You have the right to request that we delete any of your personal information that we have collected and retained, subject to certain exceptions.
· Right to Correct. You have the right to request that we correct inaccurate personal information that we maintain about you.
· Right to Opt Out of Sales and Sharing. You have the right to opt out of sales of your personal information to third parties and to opt out of the disclosure of your personal information to third parties for cross-context behavioral advertising, if applicable.
· Right to Limit Use or Disclosure of Sensitive Personal Information. You have the right to limit the use and disclosure of your sensitive personal information to certain specific business purposes.
· Right to Non-discrimination. You have the right not to receive discriminatory treatment for exercising any of your CCPA rights.
Exercising Your Rights:
You may opt out of sales and/or sharing or exercise your right to limit the use/disclosure of your sensitive personal information by sending a request to potatojulius@163.com We also honor opt-out requests submitted via privacy preference signals, such as Global Privacy Control (GPC). (For more information on the GPC and how to use a browser or browser extension incorporating the GPC signal, visit GPC)
You may submit requests to access, delete, or correct your personal information by contacting us as outlined in the Policy. To make such a request, please include the phrase "Personal Information Privacy Request" in the subject line, specify the Service you are inquiring about, and provide your name, address, and email address. If we receive a request to delete your data, we will confirm whether you wish to have your personal information completely removed or if you prefer to be placed on a list of individuals who do not wish to be contacted in the future (for a specified period or indefinitely). Once we delete your personal information, we cannot maintain a record of your details, so you may be contacted again by us if we obtain your personal information anew at a later time. We aim to respond to requests for access and deletion within 45 days; if we require additional time, 罗海镔 will inform you of this extension.
The California Consumer Privacy Act (CCPA) allows California residents to designate an authorized agent to make requests for disclosure or deletion of their personal information under the CCPA on their behalf. We will comply with requests from an authorized agent to make requests for disclosure or deletion of their personal information under the CCPA on their behalf. We will comply with requests from an authorized agent as long as: i) you provide written consent for the authorized agent to act on your behalf and we can verify your identity, and ii) the agent provides us with proof of your authorization.
Browser "Do Not Track" Signals. Most web browsers include a "do-not-track" feature. When activated, this feature signals to websites that the user does not want their personal information and online behavior to be tracked or used, for instance, for targeted advertising purposes. In accordance with California law, we are obliged to inform you that, like many websites, we do not change our practices in response to a "do-not-track" signal in the web browser.
1. ADDITIONAL DISCLOSURES FOR RESIDENTS OF COLORADO, CONNECTICUT, AND VIRGINIA, USA:
This section pertains to the personal data of residents of Colorado, Connecticut, and Virginia and complements the other sections of this Policy.
For information on the categories of personal data that we collect, the purposes for which we process that personal data, and how we disclose that personal data, please refer to the "Information We Collect About You," "Use of Personal Data and Legal Basis for Processing," and "How We Share Personal Information About You" sections above, as well as the "Table for Legal Processing Activities" below. For an explanation of the types of information we share with third parties, please refer to the Disclosures of Personal Information section in the Additional Disclosures for Residents of California notice above.
In some cases, we may share your information with third parties who may use your information for their own purposes, including for marketing and advertising. These disclosures may be considered "sales" or "targeted advertising" under applicable privacy laws. For more information about the categories of personal data that we may sell to or share with third parties and the categories of such third parties, see the Disclosure of Personal Information subsection in the Additional Disclosures for Residents of California, USA section above.
Depending on where you reside, and subject to certain exceptions, you may have the following rights with respect to your personal data:
· Access: You may have the right to request that we confirm whether we process your personal data and that we provide you access to such personal data.
· Data Portability: You may have the right to request that we provide a copy of your personal data in a portable and, to the extent technically feasible, readily usable format.
· Correction: You may have the right to request that we correct inaccuracies in the personal data that we process.
· Deletion: You may have the right to request deletion of your personal data.
· Opt Out of Sales and Targeted Advertising: You may have the right to request that we not process your personal data for the purposes of targeted advertising, sales, or profiling in furtherance of decisions that produce legal or similarly significant effects, as those terms are defined by applicable state law.
· Opt Out of Profiling: You may have the right to request that we not process your personal data for the purpose of profiling in furtherance of decisions that produce legal or similarly significant effects.
You may opt out of sales and/or targeted advertising using information as directed in the Policy. Where required, we also honor requests to opt-out submitted via privacy preference signals recognized under applicable local law, such as Global Privacy Control (GPC).
You may submit requests to exercise your other rights as directed in the Policy. Please include the phrase "Personal Information Privacy Request" in the subject line, the Service you are inquiring about, along with your name, address, and email address. If we receive a request to delete your personal data, we will ask you if you want your personal data to be removed entirely or if you want to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise). We cannot maintain a record of individuals whose personal data we have deleted, so you may be contacted again by us, should we come into possession of your personal data at a later date.
You may also have the right to appeal a refusal to take action on your request as directed in the Policy.
Depending on where you reside, you may also use an authorized agent to act on your behalf to submit requests to exercise your rights. We will honor a request from an authorized agent provided that: i) you provide written authorization to the authorized agent to act on your behalf and we can verify your identity, and ii) the agent submits proof of authorization.
PROCESSING PURPOSE
CATEGORIES OF DATA USED
SOURCES
Account creation, and to provide access to and deliver our Services.
IP address (including approximate location and country), mobile device identifier, advertising identifier (e.g.Google advertising ID) or other unique identifiers, data about your operating system, device model, device timezone, and device language, user agent, carrier, battery level, log data (e.g. network connection type, applications connected to the platform including the site you came from, go to next, and the web page(s) you access during your session in the platform). (“Device Data”).
Processing is necessary for the performance of a contract with the User (i.e. the account creation). Without this information, we will not be able to provide the service you have requested.
User consent
To maintain and improve the Services
IP address (including approximate location and country), mobile device identifier, advertising identifier (e.g.Google advertising ID) or other unique identifiers, data about your operating system, device model, device timezone, and device language, user agent, carrier, battery level, log data (e.g. network connection type, applications connected to the platform including the site you came from, go to next, and the web page(s) you access during your session in the platform). (“Device Data”).
It is in our legitimate interest to maintain and improve our Services in order to provide you with the best possible Service.
Where required by applicable laws we will obtain your consent.
Enabling you to redeem rewards earned in our Services or claim prizes on our Promotions
· Device Data
· Directly or indirectly we collect data related to software or applications when you play our games. We also collect in-game purchase information, including name,phone,email,other accountId Information(“ Personal Data”).
· - Session ID, information on how you access the Services (including frequency, what time, how long, and from which device(s)), and your approximate location or the country from which you are accessing the Services (“Usage Data”).
Processing is necessary for the performance of a contract with the User (i.e. providing you with the reward or prize from Promotions we run). Without this information, we will not be able to provide the service you have requested.
Where required by applicable laws, we will rely on User consent.
Personalization of ads and targeted advertising
· Device Data
It is in our legitimate interest to show you advertisements that are tailored to your interests.
Where required by applicable laws we will obtain your consent.
Personalization of the Service and building User profiles
· Device Data
· Personal Data
· Usage Data
It is in our legitimate interest to provide you with a service personalized to your needs.
Where required by applicable laws, we will obtain your consent.
Monitor and analyze usage and activity trends, including measuring the effectiveness of our services and marketing campaigns
· Device Data
· Usage Data
It is in our legitimate interest to monitor and analyze the use and effectiveness of our Services in order to improve our Services.
Where required by applicable laws, we will obtain your consent.
Customer service, including when contacting us by phone, email or otherwise
· Device Data
It is in our legitimate interest to provide you with customer support.
Where required by applicable laws, we will obtain your consent.
Security and fraud prevention
· Personal Data
· Device Data
· Usage Data
It is in our legitimate interest to keep our platform safe and secure and to protect our Services from fraud, and to protect your personal data and our systems from any security incidents or personal data breaches.
Where required by applicable laws, we will obtain your consent.