1.1 We will collect the following information on your own initiative:
We will collect personal information that you need to actively provide when using the corresponding functions or services according to the functions or services you need to choose. include:
-According to relevant laws and regulations and the requirements of relevant competent authorities, in order to meet the requirements of relevant laws, regulations and policies, such as the Notice of the State Press and Publication Administration on Preventing Minors from Addicting to Online Games, the Notice on Further Strict Management and Practically Preventing Minors from Addicting to Online Games, and the real name system requirements of relevant competent authorities, you need to provide your name and ID card number to complete the real name authentication. If you do not provide real identity information for real name authentication, we will not be able to provide you with relevant functions and services;
-If you choose to log in with a third-party account such as WeChat, QQ, or Apple, this login mode will facilitate the storage and synchronization of your game data. We will collect the avatar, nickname, and other information you provide;
-If you are an Apple user, you need to register an Apple mobile account when playing games. Only when you log in to this account can you perform normal downloading and purchasing operations, which follow Apple's own privacy policy;
-After registering an account, you can decide on your own to modify or supplement your profile picture, nickname, and other information, all of which belong to your account information. Not providing the above information will not affect your ability to play online games. We will protect the personal information related to the account information in accordance with the provisions of this policy.
-If you have any questions regarding product usage, account management, or recharging, you can contact customer service for assistance. You can submit relevant information in the feedback function so that customer service can contact you. If you refuse to provide relevant information, it may not be possible to help you solve the problem.
1.2 In order to provide you with services and protect account security, we will collect information that you voluntarily provide or generate due to the use of the service in the following ways:
-If you wish to implement or experience some of the features in our product, you may need to enable your corresponding access permissions on your device. If you want to cancel the corresponding authorization, you can choose to disable the corresponding permission in the device settings at any time to cancel it. The shutdown method may vary among different devices, please refer to the instructions and guidelines provided by the device and system developers.
1.2.1 Equipment or software information
The relevant device information includes device name, device model and advertising identifier (including IDFA, IDFV), MAC address, IMSI, IMEI, devsn, SSID, IP address, operating system and application version and type (information about user actions and behaviors on the device), language settings, resolution, mobile terminal random storage memory; Retrieve the software installation list and obtain information on running processes and sensors.
We collect the above information to achieve real-time data synchronization and analysis, anonymize integration, auditing, and analysis together with other information, provide users with secure and stable network services, better prevent phishing websites, fraud, network vulnerabilities, computer viruses, network attacks and other security risks, more accurately identify violations of laws and regulations or relevant protocol rules of our network services, ensure the security of your account login, and help continuously improve our products and/or services (including bug collection, the system will collect crashes or freezes that occur in the app, and repair app problems based on the collected information), optimize game product performance.
-When you use our products, we may receive and record relevant device or software information based on the specific permissions authorized by you during software installation and use, in order to provide you with continuous and stable online game operation support.
1.3 Device Permission Call
In the process of providing services, based on the specific scenarios and functions of the services, you may need to enable some device access permissions. Normally, we would apply for your following permissions in the following scenarios:
1.Locate permissions. Please note that with your authorization and consent, we may invoke the location permissions in the device you are using.
We collect the above information to enhance the user experience and convenience of the product. If you do not agree to provide this information, you may not be able to use the features related to improving user experience, and you may also need to manually fill in some information repeatedly during the use of the product. Not providing this information will not affect your ability to play online games.
When you participate in native or H5 activities, in order to provide you with high-quality services based on your different channels and regions, we need your authorization to call the location permission in the device you are using.
2) Read and write album permissions. Please note that, with your authorization and consent, when you actively provide or save relevant images using the relevant functions, in order to ensure the normal use of the game functions, we need to access your read-write album permissions.
3) Photography permission. Please note that when you need to take photos to use the relevant functions, in order to ensure the normal use of the functions, we will apply for your photo permission.
4) Apply notification permissions. Please note that if you wish to receive notifications related to game related information, including updates, maintenance, changes, and other product game services, we will apply for your application notification permission.
5) Apply tracking permissions. Please note that if you want to optimize the game and have a better gaming experience, please authorize us to access the application tracking permission when we apply (please upgrade the system version to the latest version).
1.4 Information collected by third parties
Some third-party services used in our products may collect your personal information, which follows their own privacy policies, including:
a. Relevant information collected by third-party payment service providers: You can obtain virtual products related to products and/or services, including game coins, game props, game equipment, etc., by paying in your Apple account. You can also use your Apple account to purchase and subscribe to our products. This transaction occurs between you and Apple. If you want to cancel your subscription or apply for a refund, please refer to Apple's subscription and refund policy. The above payment services are directly provided by Apple, and we do not obtain payment account, password, or other information related to your payment. After you make a successful payment, we will only obtain verification information from the Apple payment service provider regarding the completion of your payment, and then provide you with the corresponding virtual product. If you would like to know the specific rules for Apple service providers to collect personal information, please refer to the Apple Privacy Policy you have chosen.
b. Collaboration with third-party service providers: We will collaborate with third-party service providers to integrate third-party services (including advertising and statistical third-party services) into our products and/or services. We will not share your personal information provided to us or collected by us with third-party services, nor will we collect your personal information on behalf of third-party service providers. Third party service providers accessing our products and/or services may have their own privacy policies, which are not subject to this privacy policy. Third party service providers may collect personal information necessary to provide services to you based on their own privacy policies. We will make commercially reasonable efforts to require third-party service providers to comply with relevant laws and regulations when processing your personal information, and to take relevant confidentiality and security measures. However, we cannot guarantee that they will definitely take corresponding measures according to our requirements.
Please note that when you use the products we provide, we will not collect or use any of your information while the products are in a silent state or running in the background.
When the third-party SDK is running silently or in the background, it will collect your relevant device information at a certain frequency, including IMEI, IMSI, OAID, GAID, ICCID, MAC address, WI-FI MAC， We cannot control the collection of device models and advertising identifiers (including IDFA, IDFV), devsn, SSIDIP addresses, software installation lists, running processes, current running processes, sensor information, and third-party SDK background operations. The collection and use of such information will comply with the SDK's own privacy policy, but we will fulfill our reasonable supervision obligations.
If the third-party SDK collects information more frequently than the industry default of 5 times per second when in silent mode or running in the background, we will try our best to coordinate with the third-party SDK.
1.5 How we use this personal information
We guarantee that we only collect personal information for the purpose of providing you with products and/or services, and ensure that we comply with applicable laws, regulations, and other normative documents.
Please refer to the previous text for the purpose of using specific information.
1.5.1 Please rest assured that we will use the collected personal information in accordance with the provisions of this Privacy Policy and for the implementation of product and/or service functions.
Please note that for all personal information provided by you when using the products and/or services, unless you delete or refuse our collection through relevant settings, you will continue to authorize its use during the use of the products and/or services. When you cancel your account, we will stop using and delete your personal information.
We will use your personal information and other data, through data analysis, to identify the acceptability of services, your usage, etc., in order to test and create new products, features, and services, improve service levels, assist us in designing and improving existing services, and develop new services;
Please note that after collecting your personal information, we may use technical means to de identify and anonymize the data. The de identified information will not be able to identify your identity. In this case, we have the right to use the de identified information to analyze and commercialize user databases without obtaining your consent again.
1.5.2 Change in the purpose of collecting and using personal information
When using your personal information for purposes not specified in this policy, or when using information collected for specific purposes for other purposes, we will actively seek your explicit consent in advance.
1.5.3 Exceptions to obtaining authorization and consent
Please note that we can collect and use information without your authorization and consent in the following situations:
1.Necessary to enter into or perform a contract based on your request;
2.Necessary for fulfilling statutory duties or obligations;
3.Necessary to respond to sudden public health emergencies or to protect the life, health, and property safety of natural persons in emergency situations;
4.To carry out news reporting, public opinion supervision and other activities for the public interest, and to process personal information within a reasonable range;
5.Other circumstances stipulated by laws and administrative regulations.
1.6 Regarding Personal Sensitive Information
The information provided by you or collected by us above may include your personal sensitive information (ID number, location information, device information). Please be cautious and pay attention to personal sensitive information. You agree that we may process your personal sensitive information in accordance with the purposes and methods described in this policy.
Special reminder: Individual device information, application notification permissions, application tracking permissions, etc. cannot identify specific natural person identities. If we combine this type of non personal information with other information to identify a specific natural person's identity, or combine other personal information for use, during the period of combined use, this type of non personal information will be considered personal information. Unless authorized by you or otherwise provided by laws and regulations, we will anonymize and de identify this type of personal information.
2. Transfer and disclosure of personal information involved in the use of data
2.1 Collaboration involved in the use of data
2.1.1 Principles
a. Principle of legality: In the process of cooperating with partners, any data usage activities must have a legitimate purpose and comply with the legal basis of legality. If the partner's use of information no longer complies with the principle of legality, they should not use your personal information again, or use it after obtaining the corresponding legal basis.
b. Principle of legitimacy and minimum necessity: Data use must have a legitimate purpose and should be limited to what is necessary to achieve the purpose.
c. Principle of safety and prudence: We will carefully evaluate the purpose of data usage by our partners, conduct a comprehensive assessment of their security capabilities, and require them to comply with the cooperation legal agreement.
2.1.2 Commissioned Processing and Joint Processing
We will not entrust or collaborate with third parties to process your information. If we cooperate with third parties to process your information in the future, we will obtain your separate explicit consent in advance. If you refuse, we will not entrust the information to a third party.
2.1.3 Sharing
We will strictly abide by relevant laws and regulations and keep your personal information confidential. We will not share your personal information with others except in the following circumstances:
2.1.3.1 Obtain your explicit consent or authorization in advance;
2.1.3.2 Provide in accordance with applicable laws and regulations, or based on mandatory requirements from judicial or administrative authorities;
2.1.3.3 Within the scope permitted by laws and regulations, it is necessary to provide necessary services to safeguard your or other users' or individuals' legitimate rights and interests such as life, property, or social public interests;
2.1.3.4 Provide your information at the lawful request of your guardian;
2.1.3.5 Provided in accordance with relevant agreements signed with you (including electronic agreements signed online and corresponding platform rules) or other legal documents;
2.1.3.6 Your personal information may be shared with related parties based on your corresponding authorization. But only necessary personal information will be shared and subject to the purposes stated in this Privacy Policy. If related parties want to change the purpose of processing personal information, they will obtain your explicit consent in a timely manner.
We will only share your de identified and anonymized personal information for legitimate, legitimate, necessary, specific, and clear purposes. For companies, organizations, and individuals with whom we share personal information, we will sign strict confidentiality agreements requiring them to handle the information in accordance with our instructions, this policy, and any other relevant confidentiality and security measures.
2.2 Transfer
Please note that we will not transfer your personal information to any third party, except in the following circumstances:
2.2.1 Obtain your explicit consent or authorization in advance;
2.2.2 must be provided in accordance with applicable laws, regulations, legal procedures, mandatory administrative or judicial requirements;
2.2.3 Provided in accordance with relevant agreements signed with you (including electronic agreements signed online and corresponding platform rules) or other legal documents;
2.2.4 When it comes to changes such as acquisitions, mergers, bankruptcy liquidation, restructuring, etc., if it involves the transfer of personal information, the new company or organization holding your personal information will be required to continue to fulfill its responsibilities and obligations under this Privacy Policy. If the changed subject needs to change the purpose of using personal information, we will require them to obtain your explicit consent in advance.
2.3 Public disclosure
We will not disclose your information unless it complies with industry standard security measures and meets the following conditions:
2.3.1 According to your needs, disclose the personal information you have specified in the disclosure method that you have explicitly agreed to;
2.3.2 According to the requirements of laws, regulations, and mandatory requirements of administrative or judicial authorities, we may publicly disclose your personal information. When receiving the above disclosure request, the requesting party will be required by law to provide relevant legal documents, such as subpoenas or investigation letters. We will carefully review each disclosure request to ensure compliance with relevant legal regulations. Under the premise of legal regulations, files containing disclosed information will be encrypted and protected.
According to laws and regulations, sharing, transferring, and disclosing personal information that has undergone de identification processing, and ensuring that the data recipient cannot recover and re identify the information subject, does not constitute external sharing, transfer, or public disclosure of personal information. The storage and processing of such data will not require separate notification to you and your consent.
2.4 When you use our services, some services require the use of tools provided by third parties. Third party SDKs may collect your personal information for the purpose of providing the aforementioned services. For specific information on the collection and processing of user personal information by the SDK, please refer to the SDK's privacy policy. The third-party privacy policy or other relevant personal information disclosure terms for third-party products or services involving personal information processing are detailed in the attachment at the end of this Privacy Policy.
3. How to use cookies and similar technologies
In order to better provide you with products and/or services, cookies and similar technologies are used. With the help of these technologies, we can track your game progress in real time and understand your relevant information, providing you with a smooth and high-quality user experience. We will not use the above technology for any purposes other than those stated in this policy. Please understand that certain services can only be achieved through the use of the aforementioned technologies. If your device or related program allows, you can turn off or remove the above technologies by changing settings or by accessing the provider's webpage. But this action may affect your use of the product and/or service.
4. How do we store personal information
4.1 Storage location
We store your personal information collected and generated during our operations within the territory of the People's Republic of China in accordance with the provisions of laws and regulations. At present, we will not transmit the above information overseas. If we do so, we will strictly comply with relevant Chinese laws and regulatory policies and seek your separate consent.
4.2 Storage period
We only retain your personal information for the period necessary for the purpose of providing services.
According to Apple's regulations, Apple will keep your virtual currency purchase records in your Apple account, and the retention period of this data will be managed by Apple. For the retention period of other data, we promise that it will be the shortest period necessary to achieve the purpose of the product and/or service. After exceeding the above period, we will delete or anonymize your relevant information, except as otherwise stipulated by laws, regulations or regulatory authorities.
5. How do we protect the security of personal information
5.1 We attach great importance to personal information security and will take all reasonable and feasible measures to continuously protect your personal information to prevent unauthorized access, tampering, or disclosure of the collected personal information by others
5.1.1 We have adopted industry standard security measures to protect your personal information and prevent unauthorized access, public disclosure, use, modification, damage or loss of data. We will take all reasonable and feasible measures to protect your personal information. For example, implementing SSL encryption protection; We will use encryption technology to ensure the confidentiality of data; We will use trusted protection mechanisms to prevent data from being maliciously attacked.
5.1.2 Only personnel with necessary knowledge are allowed to access relevant personal information, and strict access control and monitoring mechanisms have been established for this purpose. We only allow employees who need to know this information to access your personal information. We also require all personnel who have access to your information to fulfill corresponding confidentiality obligations. If these obligations are not fulfilled, legal responsibility may be pursued or the corresponding legal relationship with you may be terminated.
5.2 We will take all reasonable and feasible measures to ensure that irrelevant information is not collected.
5.3 Please understand that due to technical restrictions and possible malicious means, in the Internet industry, even if we try our best to strengthen security measures, it is impossible to always ensure 100% security of information. You need to understand that the system and communication network used by the service you are accessing may experience issues due to uncontrollable factors.
5.4 In the event of an unfortunate information security incident, we will promptly inform you of the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you in accordance with legal requirements. Please understand that when it is difficult for us to inform the information subjects one by one, we will take reasonable and effective measures to publish announcements. At the same time, we will proactively report the handling of information security incidents in accordance with regulatory requirements.
6. Manage your personal information
We attach great importance to your management of personal information and make every effort to protect your rights to access, copy, correct, supplement, delete, revoke consent authorization, cancel account, file complaints and reports regarding your personal information, in order to safeguard your privacy and information security.
If you wish to exercise these rights, please send us an email and we will reply and process it within 15 working days.
Please note that after collecting your personal information, we will de identify or anonymize it, and the information processed in this way will not be able to identify your identity.
6.1 Accessing and Correcting Your Personal Information
Unless otherwise provided by laws and regulations, you have the right to exercise data access rights. When you discover errors in our processing of your personal information or if you have other needs for modification or supplementation, you also have the right to request us to correct or make corrections on your own. You have the right to know the identity or type of third party who obtains your personal information. You can learn about the identity or type of third parties through this Privacy Policy.
The ways in which you exercise your right to access and correct data include but are not limited to:
6.1.1 Your account information. If you want to access or modify your account information in products and/or services, including avatar, nickname and other information, name, ID card number and other real name authentication information, account password, etc., please contact us, and we will reply to you and handle it within 15 working days.
6.1.2 The personal information you share or provide in the community through posting topics, participating in discussions, or posting on your social circle. We have no authority to modify or delete, please keep your personal information safe to prevent leakage. If you have any other questions, please contact us.
6.2 Delete Your Personal Information
6.2.1 In the following situations, you may request the deletion of personal information from us:
6.2.1.1 If the handling of personal information violates relevant laws and regulations;
6.2.1.2 If your personal information is collected or used without your consent;
6.2.1.3 If the handling of personal information violates the agreement with you;
6.2.1.4 If you no longer use the products and/or services, or if you cancel the relevant account;
6.2.1.5 If we no longer provide you with products and/or services.
If we decide to respond to your deletion request, we will also notify the entities that have obtained your personal information from us to delete it in a timely manner, unless otherwise provided by laws and regulations or these entities have obtained your independent authorization.
If you have any other questions, please contact us and we will handle them within 15 working days.
6.2.2 Account Cancellation
You have the right to cancel your account registered in the product and/or service at any time. To ensure the safety of your account and property, you can submit your account cancellation request to us through customer service or the contact information specified in this Privacy Policy. We will verify your relevant situation and process your account cancellation request within 15 working days. You can also click the logout button in the product. Please carefully read the account logout instructions before logging out to ensure that you are fully aware of the consequences of account logout.
Please note that logging out of related product and/or service accounts is an irreversible operation. After canceling the account, we will cease to provide you with products and/or services and delete your personal information under the account, except as otherwise provided by laws and regulations.
6.3 Withdrawal of Consent
Each business function requires some basic personal information to be completed (see Part 1 for details). After you withdraw your consent, we will no longer process your relevant personal information. But your decision to withdraw consent will not affect the personal information processing activities previously carried out based on your authorization. You can contact us to request your withdrawal of consent, and we will process it within 15 working days.
6.4 Obtaining a copy of personal information
According to your request, we can provide you with a copy of the personal information we hold about you (such as personal basic information). You can make a request to us through customer service or the contact information provided in this Privacy Policy, and we will process it within 15 working days.
6.5 Constrained Information System Automatic Decision Making
In cases where decisions are made solely based on non manual automated decision-making mechanisms such as information systems and algorithms, and these decisions significantly affect your legitimate rights and interests, you have the right to request an explanation and will also provide appropriate remedies.
6.6 Responding to your request
To ensure the security of your personal information, we will first verify your identity before processing your requests to access, correct, delete your personal information, as well as withdraw your consent, cancel your account, or obtain a copy of your personal information. We will respond and provide a reasonable explanation within 15 working days or within the time limit prescribed by laws and regulations. If we decide not to respond to your request, we will also contact you and inform you of the reasons for that decision.
For your reasonable requests, we generally do not charge any fees, but for requests that are repeated multiple times or exceed reasonable limits, we will charge a certain cost fee depending on the situation. We may refuse requests that are unnecessarily repeated, require excessive technical means, pose risks to the legitimate rights and interests of others, or are very unrealistic.
We will not be able to respond to your request in the following situations:
6.6.1 Relevant to the obligations of personal information controllers in accordance with laws and regulations;
6.6.2 Directly related to national security and defense security;
6.6.3 Directly related to public safety, public health, and major public interests;
6.6.4 Directly related to criminal investigation, prosecution, trial, and execution of judgments;
6.6.5 If the personal information controller has sufficient evidence to indicate that the personal information subject has subjective malice or abuse of rights;
6.6.6 For the purpose of safeguarding the significant legitimate rights and interests of personal information subjects or other individuals, such as life and property, but it is difficult to obtain their consent;
6.6.7 The request of the corresponding personal information subject will cause serious damage to the legitimate rights and interests of the personal information subject or other individuals or organizations;
6.6.8 Involving trade secrets.
6.7 Complaint and Appeal Management
We have established a relevant appeal management mechanism, including a tracking process to solve your related questions, and also set up a personal information security complaint channel. To ensure the safety of your account and property, we will process and handle it within 15 working days after verifying your identity. If you have any objections to our response or handling methods, you can appeal to us.
7.Provisions for Minors
7.1 If you are a minor under the age of 18, you should read and agree to this privacy policy under the supervision and guidance of your parents or other guardians before using our products.
7.2 If you are the guardian of a minor under the age of 14, you should read and agree to this privacy policy for your guardian before using our product.
7.3 We protect the personal information of minors in accordance with relevant national laws and regulations. We will only collect, use, or disclose the personal information of minors when permitted by law, with the explicit consent of parents or other guardians, or when necessary to protect minors; If we find that personal information of minors has been collected without obtaining verifiable consent from parents or other guardians in advance, we will try to delete the relevant information as soon as possible. At the same time, we have established strict rules for the collection and use of minors' information to protect the personal information security of children and adolescents. You can learn more specific content by reading the "Guidelines for the Protection of Children's Privacy".
7.4 If you are the guardian of a minor and have any questions about the personal information of the minor under your guardianship, please contact us through the contact information disclosed in this privacy policy.
7.5 We will actively comply with the national anti addiction policy requirements and verify users' real identity and other information to determine whether they are minors, in order to promote the healthy use of the internet by minors.
7.6 In order to better protect the physical and mental health of minors and promote their healthy online behavior, we may implement stricter anti addiction measures based on relevant national policies and regulations on online game addiction prevention.
7.7 According to relevant national policies, in order to prevent minors from indulging in online games, our game has set up a real name authentication, in which your name and ID card number need to be filled to identify whether you are a minor or an adult, so as to better prevent minors from indulging in online games. If you are a minor, please obtain your parents' consent when doing this operation and making payment. If you have any questions, please contact us and we will reply to you within 15 working days.
8. Revision and Notification of Privacy Policy
If our product undergoes the following changes, we will promptly revise this policy and publish the latest version on the relevant interface of this product, so that you can keep up with the latest version of this policy in a timely manner:
8.1 Changes in business functions related to products and/or services, resulting in changes in the purpose, type, and usage of personal information processing;
8.2 There has been a significant change in your right to participate in the processing of personal information and the way you exercise it;
8.3 The contact information and complaint channels of the department responsible for handling your personal information security have changed;
8.4 Other changes that may affect the security of users' personal information or their privacy rights occur.
Please note: Without your explicit consent, we will not reduce the rights you enjoy based on this policy.
X. Account Deletion
1. You can delete your account or delete certain personal information by logging into your game account. If you think we would like you to delete any other personal information we process, please send an email to [e3lanotopia13@gmail.com ].
2. You can ask us to delete the personal information we hold about you in the following circumstances: (a) you think we no longer need to hold such personal information; (b) you think the personal information we hold about you is being processed illegally.
3. While we consider your request, you can also exercise your rights to restrict our processing of your personal information (as described below).
4. If data protection law provides that we have a legitimate reason to retain personal information (for example, to defend legal claims or freedom of speech), we may need to retain personal information, but we will notify you if this is the case. If you ask us to delete personal information that has been made public on the game service and there is reason to delete it, we will take reasonable measures to try to tell others who display the personal information or provide links to the personal information to delete the personal information as well.