Mini Hero: Survivor Privacy Policy

Introduction

 

This Mini Hero: Survivor User Privacy Policy (hereinafter referred to as the "Policy") applies only to the Mini Hero: Survivor application (hereinafter referred to as the "APP") and related services of Nox Future Corp (hereinafter collectively referred to as "we"), and does not apply to third-party products or services that have separate privacy policies and are not covered by this Policy. This policy describes which personal data is collected, saved, and used when you use our App. Also, this privacy policy describes the way your personal data is accessed, updated, managed, and protected. We hope that you will read this Privacy Policy ("Policy") carefully to learn more about how we collect and use information so that you can better understand our services and better match your true intentions when choosing whether and what services to use. If you choose to use the services we provide, it means that you agree to be bound by all the terms and conditions that we have stated in this policy.

 

We fully aware of the importance of personal information to you and will do our best to protect the security and reliability of your personal information, we are committed to maintaining your trust in us and adhering to the following principles to protect your personal information: the principle of consistency of rights and responsibilities, the principle of clear purpose, informed consent, data minimization, security guaranty, subject participation, openness and transparency, etc. At the same time, we commit/warrant to take appropriate security measures to protect your personal information in accordance with the industry's proven security solutions.

 

If you do not expressly agree to this policy and start using our app, we will not collect any information from you, which will result in our inability to provide you with full-functioned products and services. We strive to express this in easy-to-understand, concise language and use bold type to draw your attention to the terms of this policy that are material to your rights. If you have any questions, comments, or suggestions, please feel free to contact us.

 

Email: [mini_hero@noxgroup.com]

 

This privacy policy will help you understand the following.

1. How do we use SDK and similar technologies

2. How we share, transfer, and publicly disclose your personal information

3. How we protect your personal information

4. How you manage your personal information/your rights

5. How we handle the personal information of minors

6. Where and how long we store the information and how your personal information is transferred globally

7. How to update this privacy policy

8. How to contact us

9. Advertisements/information we send to you

10. The scope of application

11. Other

 

To better clarify, the following concepts in this policy refer to.

 

Personal information means, all kinds of information recorded in electronic or other means that can identify a specific natural person or reflect the activities of a specific natural person, or in combination with other information, including personal identification information (name, date of birth, identification document number, including ID card, officer's license, passport, driver's license), facial features, address, contact telephone number, address book, network identification information (including account name, account nickname, e-mail address, and the aforementioned password and password protection questions and answers); property information, transaction information, personal Internet records (Internet browsing records, click records, etc.), personal common equipment information (including hardware model, MAC address of the device, operating system type, software list unique device identification code and other information describing the basic situation of personal common terminal equipment) and personal location information, etc.

 

Personal commonly used device information: information describing the basic situation of personal commonly used devices, including hardware serial number, device MAC address, software list, unique device identification code (such as IMEI/IDFA/OPENUDID/GUID/OAID, SIM card IMSI information, etc.), etc.

 

Personal location information: refers to information including whereabouts trajectory, precise positioning information, accommodation information, latitude, and longitude, etc.

 

Personal sensitive information refers to personal information that, if leaked, illegally provided, or misused, may endanger personal and property safety, and is highly likely to lead to damage to personal reputation, physical and mental health or discriminatory treatment, etc. The personal sensitive information in this privacy policy includes: personal identification information (identification document number, including ID card, officer's license, passport, driver's license), facial identification features; property information, transaction information; network identification information (including account name, account nickname, email address, and password and password protection questions and answers related to the foregoing); other information (including address book, personal phone number (including address book, personal phone number, travel information, and precise positioning information).

 

De-identification refers to the process of personal information technical processing, which indicates that the subject of personal information cannot be identified without additional information.

 

Anonymization refers to the process of making the subject of personal information unidentifiable through technical processing of personal information, and the information cannot be recovered after processing.

 

1. How do we use SDK and similar technologies

Notifications we send to you by SMS or Mini Hero: Survivor customer service, site notifications may contain link addresses that link to content on our site. If you click on the link, click-tracking helps us understand your product or service preferences so that we can proactively improve our customer service experience. If you do not wish to have your activity tracked in this way, you may turn it off at any time.

 

2. How we share, transfer, and publicly disclose your personal information

Sharing

We will not share your personal information with companies, organizations and individuals other than the service providers of Mini Hero: Survivor, except for the following cases.

1) Sharing with explicit consent: We will share your personal information with other parties after obtaining your explicit consent.

2) Sharing under statutory circumstances: we may share your personal information with external parties in accordance with the provisions of laws and regulations, the need for litigation dispute resolution, or as required by administrative or judicial authorities in accordance with the law.

3) Sharing with affiliated companies: Your personal information may be shared with our affiliated companies in order to facilitate our joint provision of services to you based on affiliated accounts, to recommend information that may be of interest to you, or to protect the personal and property safety of Mini Hero: Survivor affiliates or other users or the public from infringement. We will only share necessary personal information (e.g. we will share your necessary account information with our affiliates to facilitate your use of our affiliates' products or services through your Mini Hero: Survivor account), and we will seek your authorized consent again if we share your sensitive personal information or if our affiliates change the purpose of using and processing personal information.

4) Sharing with Authorized Partners: For the sole purpose of achieving the purposes stated in this Privacy Policy, certain of our services will be jointly provided by us and authorized partners. We may share certain of your personal information with our partners to provide better customer service and user experience. Examples include arranging for partners to provide services. We will only share your personal information for lawful, legitimate, necessary, specific, and explicit purposes, and only as much personal information as is necessary to provide the service. Our partners do not have the right to use the personal information shared for any other purpose unrelated to the product or service.

We send information to vendors, service providers, and other partners who support our business by providing technical infrastructure services, analyzing how our services are used, measuring the effectiveness of advertising and services, providing customer service, facilitating payments, or conducting academic research and surveys.

For companies, organizations, and individuals with whom we share personal information, we enter into strict data protection agreements that require them to handle personal information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures.

 

Transfers

We will not transfer your personal information to any company, organization, or individual, except for the following.

1) Transfer with expressly consent: we will transfer your personal information to other parties after obtaining your express consent.

2) In cases involving mergers, acquisitions or bankruptcy liquidation situations, or other situations involving mergers, acquisitions or bankruptcy liquidation involving the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this policy, or we will require the company, organization and individual to seek your authorized consent again.

 

Public Disclosure

We will only disclose your personal information publicly Only in the following situation.

1) With your express consent or based on your unsolicited choice, we may disclose your personal information publicly.

2) If we determine that you have violated laws and regulations or seriously violated the rules of the relevant Mini Hero: Survivor agreement, or to protect the personal and property safety of users of Mini Hero: Survivor and its affiliates or the public from infringement, we may disclose personal information about you with your consent in accordance with laws and regulations or the rules of the relevant Mini Hero: Survivor agreement, including the relevant violations and the measures Mini Hero: Survivor has taken against you.

 

Exceptions to prior authorized consent for sharing, transferring, and public disclosure of personal information.

In the following cases, prior authorized consent is not required for sharing, transferring, or publicly disclosing your personal information.

1) Related to national security or national defense security.

2) Related to public safety, public health, and significant public interest

3) Related to crime investigation, prosecution, trial and execution of judgments, etc.

4) For the purpose of safeguarding your or other individuals' life, property and other significant legitimate rights and interests but where it is difficult to obtain your consent.

5) Personal information that you disclose to the public on your own.

6) Personal information collected from legitimate public disclosures, such as legitimate news reports, government information disclosure and other channels.

According to the law, sharing or transferring personal information that has been de-identified and ensuring that the recipient of the data cannot recover and re-identify the subject of the personal information is not an act of sharing, transferring or publicly disclosing personal information to the public, and there will be no need to separately notify you and obtain your consent for the preservation and processing of such data.

 

3. How we protect your personal information

In order to protect the security of your information, we will strictly comply with the technical measures and operational procedures required by laws and regulations and other regulatory documents to protect the secrecy of your information, while.

1) We have taken reasonable and feasible security measures to protect the security of personal information provided by you in line with common industry solutions to prevent unauthorized access, public disclosure, use, modification, damage or loss of personal information. We use encryption technology to enhance the security of personal information; we use trusted protection mechanisms to prevent malicious attacks on personal information; we establish a strict internal control system and a sound and adequate management process; we deploy access control mechanisms and make every effort to ensure that only authorized personnel has access to personal information, and we hold security and privacy protection training courses to enhance employees' awareness of the importance of We will hold security and privacy training courses to enhance employees' awareness of the importance of protecting personal information.

2) We have an industry-advanced data security management system that focuses on the data lifecycle and enhances the security of the entire system in multiple dimensions, such as organizational construction, system design, personnel management, and product technology.

3) We will take reasonable and feasible measures to avoid collecting irrelevant personal information to the best of our ability. We will only retain your personal information for as long as necessary to achieve the purposes described in this policy unless the retention period needs to be extended or is permitted by law.

4) The Internet is not an absolutely secure environment, and we strongly recommend that you do not send personal information using communication methods other than those recommended by Mini Hero: Survivor. You may establish connection and share with each other through our Services. When you create communication, transaction, or sharing through our services, you can independently choose the person to whom you communicate, trade, or share as a third party who can see your transaction content, contact information, communication information, or sharing content and other related information.

 

From time to time, we will update and disclose the contents of our security risk and personal information security impact assessment reports.

The Internet environment is not 100% secure and we will do our best to ensure or warrant the security of any information you send to us. If our physical, technical, or administrative safeguards are breached, resulting in unauthorized access, public disclosure, tampering, or destruction of information, resulting in damage to your legal rights and interests, we will be liable.

After the unfortunate occurrence of personal information security events, we will, in accordance with the requirements of laws and regulations, promptly inform you of: the basic situation of the security event and the possible impact, the disposal measures we have taken or will take, the suggestions you can independently prevent and reduce the risk, the remedial measures for you, etc. We will promptly inform you of the event-related situation by way of push notifications and take reasonable and effective ways to send announcements.

At the same time, we will also take the initiative to report the disposition of personal information security incidents in accordance with the requirements of the regulatory authorities.

 

4. How you manage your personal information / your rights

In accordance with the relevant laws, regulations, and national standards of the People's Republic of China, as well as common industry practices, we protect your right to exercise the following rights to your personal information.

1) Managing the scope of your authorization

Each business function requires basic personal information to be able to complete. You may give or withdraw your authorized consent at any time for the collection and use of additional collected personal information.

You can do this on your own in the following ways.

You can change the scope of your authorization for features and services by deleting information, turning off device features, as well as setting "Settings" - "Account & Security, Notification Alerts, Privacy" in the APP.

Specific business functions and services will require your personal information to complete. After you withdraw your consent, we will not be able to provide you with the functions and services for which you have withdrawn your consent, and we will no longer process your personal information. However, your decision to withdraw your consent will not affect our previous processing of personal information based on your consent.

2) Respond to your request above

For security purposes, you may need to provide a written request or otherwise prove your identity. We may ask you to verify your identity first before processing your request.

We will respond within 15 days. If you are not satisfied with our response, you may also initiate a complaint through Mini Hero: Survivor Customer Service.

For your reasonable requests, we will try to fulfill your requests. We may reject requests that are unwarrantedly repetitive, require excessive technical means (for example, requiring the development of new systems or fundamental changes to current practices), pose a risk to the legal rights of others, or are highly impractical.

Related restrictions

In the following cases, we will not be able to respond to your request in accordance with the requirements of laws and regulations.

a. Related to national security and national defense security.

b. Related to public safety, public health, and significant public interests.

c. Related to crime investigation, prosecution, trial and execution of judgment, etc.

d. Where there is sufficient evidence of subjective malice or abuse of rights by the subject of personal information

e. Responding to your request will lead to serious damage to the legitimate rights and interests of you or other individuals or organizations

f. Where commercial secrets are involved.

 

5. How we handle the personal information of minors

Our products are mainly for adults, we expect parents or guardians to guide minors to use our services, if you are a minor under the age of 18, before using our products, you should read and agree to this policy together under the supervision and guidance of your parents or other guardians. Children (under the age of 14) are not allowed to create their own user accounts without the consent of their parents or guardians.

We protect the personal information of minors in accordance with the relevant national laws and regulations, and in the case of personal information collected from minors with parental consent, we will only use, share or publicly disclose this information as permitted by law, with the express consent of the parent or guardian, or as necessary to protect the minor.

If we find that we have collected personal information from minors without prior verifiable parental consent, we will seek to delete the relevant data as soon as possible.

 

6. Where and for how long the information is stored, and how your personal information is transferred globally.

The geographical area where personal information is stored.

We store the personal information collected and generated within the territory of the user in China in strict accordance with the laws and regulations.

In the case that personal information leaves the country, we will not transfer the above information outside the country. If some products involve cross-border business and we need to transfer the relevant personal information collected in the country to overseas institutions, we will follow the relevant national regulations and at the same time evaluate the information security of the information leaving the country, and obtain your explicit authorization, and implement it in accordance with the laws and regulations and the regulations of the relevant regulatory authorities, We will require the overseas institutions to keep your personal information confidential through effective measures such as signing agreements and on-site verification, except for your personal initiative such as cross-border posting through the internet.

 

In the above cases, we will ensure that your personal information is totally protected in accordance with this privacy policy.

 

Duration of storage of information

In general, we will only retain your personal information for the shortest period of time necessary to achieve our purposes, and we will delete or anonymize your personal information beyond the corresponding period. However, we may change the period of storage of personal information due to the need to comply with legal requirements in the following cases.

1) In order to comply with the relevant provisions of applicable laws, regulations or policies, and other regulatory documents.

2) To comply with the provisions of decisions, etc. of administrative organs or similar authorized organizations, judgments or rulings of judicial organs, awards of arbitration organs, or other legal proceedings.

3) In order to comply with the relevant provisions of laws, regulations, etc., which we are reasonably certain are required.

4) For purposes reasonably necessary to enforce the relevant service agreement or this policy, to safeguard the public interest, and to protect the personal and property safety or other legitimate rights and interests of third parties such as our customers, our affiliates, other users or employees.

When Mini Hero: Survivor ceases operation, we will notify you in the form of push notifications, website or in-program announcements, and delete or anonymize your personal information within a reasonable period of time.

 

7. How this privacy policy is updated

Our privacy policy is subject to change. In the event of changes in business functions, changes in the purpose of use, or changes in the contact information of the person in charge of personal information protection, we will revise our privacy policy accordingly.

We will not limit your rights under this Privacy Policy without your express consent. We will provide prominent notice of material changes (including notice via a public notice on the Mini Hero: Survivor platform, Mini Hero: Survivor customer service notice, etc.).

 

Major changes within the meaning of this policy include, but are not limited to.

1) Significant changes to our service model. Such as the purpose of handling personal information, the type of personal information handled, the way personal information is used, etc.

2) Changes in the primary recipients of the sharing, transfer, or public disclosure of personal information.

3) Significant changes in your rights to participate in the processing of personal information and the manner in which they are exercised.

4) When there is a change in the department responsible for handling personal information security, our contact information and complaint channels.

5)When the personal information security impact assessment report indicates that there is a high risk.

If you choose to continue to use our services after being notified, you agree to be bound by the revised policy.

We will also keep an older version of this policy on file for your review, which you may request from us through the contact information reserved in this policy.

 

8. How to contact us

If you have questions or suggestions about this policy or related matters, etc., we have established a dedicated line for personal information protection, and you can contact us through the following complaint channels.

Report Email: [mini_hero@noxgroup.com]

We will properly receive and promptly reply to your complaint within fifteen days after verifying your user identity.

If you are not satisfied with our response, especially if you think our personal information processing behavior has damaged your legitimate rights and interests, you can also seek a solution by filing a lawsuit to the court with jurisdiction in the place where the contract was signed. This agreement was signed in Haidian District, Beijing, People's Republic of China.

 

9. Advertising/Information we send to you

We may use your relevant information to send you commercial advertisements on relevant websites, applications, and other channels.

If you do not wish to receive commercial advertisements from us, you may unsubscribe at any time through the appropriate product unsubscribe function.

 

10. Application scope

This privacy policy applies to all services provided by Nebula Game, including the Mini Hero: Survivor client, etc., but does not apply to third-party products or services that have separate privacy policies and are not included in this privacy policy.

 

11. Others

The headings in this Privacy Policy are for convenience and reading only, and do not affect the meaning or interpretation of any provision of this Privacy Policy.

This Privacy Policy is copyrighted by us, and we reserve the right to interpret and modify it to the extent permitted by law.