Introduction
This Privacy Policy explains how we collect, use, share and store your personal data when you use our game, website and all associated services including customer support, marketing and advertising (collectively the “Services”).This document covers four core parts: what data we collect, our purposes for data collection, data recipients, and your legal rights over personal information.
This policy applies to all users and all data collected via our Services. We may update this policy by publishing revisions on our official website; your continued use of the Services after updates take effect means you accept the revised terms.
This Privacy Policy forms an integral part of our Terms of Service. All undefined expressions shall follow the definitions set out in the Terms of Service.1. Data We Collect1.1 Information You Voluntarily SubmitWhen registering and using our Services, you may provide personal data including:
Contact details: name, email, phone number, mailing address and ID information
Account credentials: username and password
Game character data: account ID, character name, avatar (visible to other players)
Personal preferences and profile photos
In-game chat records and support tickets
Payment and billing information (third-party payment providers follow their own privacy rules)
Supplementary information for account recovery
1.2 Automatically Collected DataWe deploy cookies and equivalent tracking technologies to gather device and usage data. You may disable cookies via browser settings, though this may limit partial service functions.
Automatically collected data includes:
Account status records
IP address, access URLs, page records, device identifiers (IDFA, device ID, MAC, IMEI)
Device model, operating system, browser type and language
General and precise GPS location data (if permission granted)
Game behavior logs: click records, page dwell time, play progress and in-game interactions
Aggregated service operation statistics
All access logs automatically recorded by our servers
1.3 Data Obtained from Third-Party PartnersIf you log in through social platforms (Google, Facebook, WeChat, etc.), we may receive authorized data such as:
Demographic and IP-based regional data
Anti-fraud data for refund abuse and ad click fraud prevention
Payment verification data from game distribution platforms
Device specifications, country and contact information
Data for advertising, marketing and data analysis
2. Purposes of Data Processing2.1 Deliver Core Game ServicesWe process your data to create accounts, support normal gameplay of Lil Devil Summoner, maintain server operation, verify in-app purchases, deliver requested game content and send official service notifications.2.2 Optimize and Upgrade the ServicesBased on legitimate business interests, we analyze user data to iterate game content, manage accounts, improve user experience, run in-game social functions, customize gameplay, respond to user feedback, push game updates and enhance website stability.2.3 Personalized Advertising & MarketingWe use device ad IDs, region, language, gameplay records and interaction data to deliver targeted ads. We may share non-sensitive data with authorized advertising partners for campaign optimization.
By agreeing to this policy, you consent to personalized marketing unless you opt out via game or device settings. We are not liable for the data practices of third-party ad platforms; you may review their respective privacy policies for details.2.4 Maintain Platform Security & FairnessWe monitor game activity, moderate chat content, block cheating, fraud and illegal acts, and penalize rule-breaking users. We may disclose relevant data to official anti-fraud authorities when required.
We implement standard security safeguards, but cannot guarantee absolute data security. Any personal information shared publicly in forums or chats may be accessed by other users at your own risk.2.5 Data Analysis, Testing & ResearchWe utilize internal and third-party analytics tools to conduct operational research, troubleshoot service defects and test new game features.2.6 Processing with Your ConsentWe may process your personal data for additional purposes upon receiving your explicit consent.3. Data Sharing & DisclosureWe will not sell your personal data. We only share information under the following legitimate scenarios:
Internal Sharing: Shared with our staff and affiliated companies for daily business operations. Authorized external service providers must sign confidentiality agreements and comply with our data protection standards.
Other Players: Your profile, game activities and chat messages are visible to other users as part of in-game social features. We take no responsibility for unauthorized misuse of user-shared information by third players.
Authorized Service Partners: We share necessary device and usage data with trusted providers for payment processing, advertising, statistics and personalized push services. These partners operate under their own privacy policies.
Legal Mandates: We may disclose data to government agencies, courts or regulatory bodies when required by law, court orders or subpoenas. We may also release data to enforce our user agreement, defend against legal claims and protect the safety of our platform, users and staff.
4. Your Rights to Personal Data
Opt out of personalized ads: Disable marketing push via in-game settings or system device options.
Access & correction: You may view and amend your stored personal information.
Data portability: Request an electronic copy of your account-related personal data, which we will provide within 30 days.
Deletion, objection & consent withdrawal: You can demand data deletion, object to data processing or revoke previously granted consent at any time.
For all data-related requests, contact us via the game client or the email listed below; we will reply within a reasonable timeframe.
Right to complain: You may submit complaints to the local data protection supervisory authority in your country.
5. Data Retention PeriodWe store your personal data while your game account remains active to provide continuous Services. After account deletion, we reserve limited data to satisfy legal compliance, resolve disputes and enforce contractual obligations.6. Cross-Border Data TransferYour data may be stored and processed globally. Data protection standards vary across jurisdictions. We adopt protective measures including EU Standard Contractual Clauses to secure cross-border data transmission. For users residing in the European Economic Area, cross-border transfers outside the EEA are protected by European Commission-approved standard contractual clauses.7. Governing Law & Dispute ResolutionThis policy and all related Services are governed by the laws of Singapore, excluding conflict-of-law rules. You submit to the non-exclusive jurisdiction of Singapore courts.
All disputes shall first be resolved through customer support. If negotiation fails, disputes will be settled by arbitration in Singapore under the SIAC Arbitration Rules with three arbitrators, conducted in English.
We reserve the right to initiate court proceedings and apply for injunctive relief without posting security. You irrevocably waive rights to class actions, representative lawsuits and restraining orders against our Services.8. Children’s PrivacyOur Services are designed for users aged 13 and above. We do not intentionally collect personal data from children under 13. If we discover child user data by accident, we will promptly erase such records.9. Data Security MeasuresWe adopt physical, administrative and technical safeguards to protect your personal information. However, no online transmission system can guarantee complete security against data leakage, tampering or loss.
If a security breach occurs, we will notify users via electronic means and post alerts on our website. You are fully responsible for keeping your account password confidential and logging out after each session. Notify us immediately if you detect unauthorized account access.
10. Merger, Acquisition & InsolvencyIf our company undergoes merger, acquisition or asset sale, user data may be transferred as part of business assets. In cases of bankruptcy or reorganization, we cannot fully control the subsequent processing of your personal data.
11. Policy UpdatesWe reserve the right to revise this Privacy Policy at any time. Continued use of the Services after updates constitutes acceptance of the latest version.
12. Contact InformationFor privacy inquiries or to exercise your data rights, email us at:ethelward1999@gmail.com
This policy is originally written in English. Translations are for reference only. In case of inconsistency between translation and the English text, the English version shall prevail.Version: 1.0