GOLDEN PHOENIX MEDIA TECHNOLOGY CO., LIMITED and its subsidiaries (collectively, "GOLDEN PHOENIX", "we", or "our") are a mobile game and application publisher. This Privacy Policy explains how GOLDEN PHOENIX collects and processes your personal data when you use our mobile applications. We process your information to provide you with high-quality applications and the best user experience.
1. How We Collect Your Personal Data
2. We acquire, use, and process your personal data in various ways. In all circumstances, we are committed to protecting the security of your personal data.
3. The following sections detail how we collect your personal data and how we process it.
Information Collection Scope
I. Device Identification and Advertising Information
Collection Content: Unique device identifier (e.g., IMEI, OAID), advertising identifier, advertising interaction records
Purpose: Device binding, precise advertising targeting, and performance statistics
II. Sensor and Basic Equipment Information
Collection Content: Motion/environment sensor data (e.g., acceleration, light), device model/brand/system version, screen/battery basic information
Purpose: Adapting to device scenarios and ensuring normal function operation
III. Network and Hardware Configuration Information
Collection Content: Network type (5G/WiFi), IP address, carrier information, CPU/memory/storage parameters, hardware interface/driver version
Purpose: Optimizing network connectivity, adapting to high-load functions, and avoiding lag
IV. System and Environment Information
Collection Content: Virtual machine/system kernel version, root/jailbroken status, storage format, battery health, region/time zone/system notification settings
Purpose: Ensuring system compatibility, identifying risky environments, and adapting to regionalized experiences
Personal Data
When you access or use our applications, we may collect general information about you, including:
Log Information: IP Address, access time, device type.
Device Information: Device manufacturer, device type, device operating system, device time zone, and device language.
Device Identification Number: The online identification number of the device you use to access the application, including IDFA, Google Ads ID, Google Device ID, Game Center ID, and Google Play Account ID.
Usage Information: Game progress, score, achievements.
Business Information: Purchase and usage history and preferences, receipt of in-game virtual items.
Other Data Sources
How We Use Information
We use your information for the following purposes based on the legal basis of the following categories of personal data:
- To process product orders and other requests, respond to your questions, and communicate with you.
- To provide services, enhance, and personalize your experience when using the services.
- To push technical information, updates, privacy warnings, and technical support to you.
- Our processing for the above purposes is necessary to fulfill the contracts you, as a party, to support the operation of the application, to facilitate the provision of the products and services you request, and to allow
- The maintenance and updates of the application, see Article 6(1)(b) of the GDPR (also known as the “Balance of Interest Rule”). - To enhance and personalize your experience using the Services, and to retain your preferences.
- To review the use and operation of the Services, develop new products or services, and conduct analysis to enhance or improve our software, content, marketing, support, and services.
- In accordance with Article 6(1)(f) of the GDPR, our actions for the purposes described above are based on our legitimate interests in providing you with advertising and content that may be of interest to you, and in improving our Services.
- To provide personalized advertising, marketing, and related promotional information to users who have consented to sharing their advertising IDs with our advertising network partners.
- Information from other sources is being processed.
- To process product orders and other requests, respond to your questions, and communicate with you;
- To understand your preferences and interests to provide you with better, more personalized services;
- To provide you with relevant information and news about services and applications that may be of interest to you.
- Our actions for the purposes described above are based on our legitimate interests in providing users with advertising and content that may be of interest to you, and in improving our Services, as required by Article 6(1)(f) of the GDPR.
Data Retention
1. We will retain your information only for as long as necessary to provide you with services, fulfill our legal obligations, and/or exercise, defend, or establish our rights. We may also retain portions of your personal information in our files for a reasonable period to resolve disputes, enforce our terms and policies, manage our services, comply with technical and legal requirements, and/or other limitations related to the security, integrity, and operation of our services.
2. We may also retain usage data for internal analysis. Usage data is typically retained for a shorter period unless it is used to enhance security or improve the functionality of our services, or we are legally obligated to retain it for a longer period.
Information Sharing
In accordance with Article 6(1)(b), 1(c), and 1(f) of the General Data Protection Regulation (GDPR), we may disclose information we collect about you to various third parties in various ways, and may allow you to share this information with various third parties in various ways, including:
- Other third parties (e.g., for collaborative promotion, legal and security purposes, in connection with the sale or transfer of a business or assets, and for other purposes permitted by you);
- We will report to the relevant authorities if we believe your actions are inconsistent with the spirit or wording of our policies, or if disclosure is necessary to protect the rights, property, and safety of GOLDEN PHOENIX or others;
- When you consent to the information described in Article 6(1)(1) of the General Data Protection Regulation (GDPR), we will share your device identifier with advertising network companies. This will help us provide you with personalized advertising. We use or may use the following advertising networks:
- Applovin： https://www.applovin.com/privacy/
- Google LLC： https://policies.google.com/privacy
- Google AdMob： https://support.google.com/admob/
- Unity Technologies： https://unity3d.com/legal/privacy-policy
- IronSource： http://www.ironsrc.com/wp-content/uploads/2019/03/ironSource-Privacy-Policy.pdf
- Vungle： https://vungle.com/privacy/
- Fyber： https://www.fyber.com/privacy-policy/
This Privacy Policy does not cover the recipient's use of the disclosed information. If you have any questions about the processing of information by third parties, please refer to their privacy policies.
In the process of data processing, we use data processors such as server hosting providers, technology service providers supporting internal operations, user login service providers, and analytics service providers:
- Firebase（Google LLC） https://firebase.google.com/support/privacy
Children
- This service is not intended for users under the age of 16. We do not knowingly collect personally identifiable information from children under the age of 16. If you are a parent or guardian and you discover that your child has provided us with personal information, please contact us so that we can take the necessary measures.
- Security
- We value your trust in the personal information we provide, and therefore we are committed to protecting this information in a commercially acceptable manner. However, please remember that no method of internet transmission or electronic storage is absolutely secure, and we cannot guarantee the absolute security of your information.
Push Notifications
- If you have consented to receiving such notifications, we will send push notifications or alerts to your mobile device to provide game-related information, service updates, promotions, and other relevant messages. You can turn off these notifications by changing your device's notification settings.
- Your Rights Rights of Eurasian Economic Union Residents
We will process and respond to your request as soon as possible, no later than one month after receiving your request, unless the request is complex and requires a longer period. In such cases, our response time may be up to three months in accordance with Article 12 of the GDPR.
Right to Request Access
You have the right to request access to the data we process about you, please refer to Article 15 of the General Data Protection Regulation (GDPR), which includes the following information:
- The purpose of processing;
- The category of the personal data in question;
- The recipients or categories of recipients to whom the personal data has been or will be disclosed;
- The expected retention period for the personal data.
In addition, you have the right to obtain a copy of the personal data being processed. Please note that access may be limited due to the involvement of intellectual property or trade secrets.
Right to Object
Under the principle of balancing interests set forth in Article 6, paragraph 1(f) of the GDPR, you have the right to object to our processing of your personal data based on your specific circumstances (see Article 21 of the GDPR). In such cases, we will cease processing unless there are compelling and legitimate reasons superseding your interests, rights, and freedoms, or processing is necessary to establish, exercise, or defend a legal claim.
You have the right to object at any time to our processing of your personal data for direct marketing purposes. Upon receiving your objection, we will cease processing your personal data for that purpose.
Right to Restriction
In certain circumstances, you have the right to request restriction of processing of your personal data, as detailed in Section 18 of the General Data Protection Regulation (GDPR). If you have the right to restriction of processing, we will only process your data with your consent, or to establish, exercise or defend a legal claim, or to protect an individual or vital public interest.
Right to Withdraw Consent
If we have obtained your consent to process your data, you have the right to withdraw your consent at any time, see Article 7 of the GDPR.
If you withdraw your consent, we will cease processing the data for which you have withdrawn your consent, unless we have a legal obligation to retain some or all of your data.
Withdrawing your consent does not affect the legality of processing based on your consent prior to the withdrawal.
Right to Data Portability
You have the right to receive your personal data that we are processing in a structured, commonly used, and machine-readable format, and, if processing is based on consent or contractual performance, you have the right to transfer such data to another controller, see Article 20 of the GDPR.
Rights of California Residents
We strive to respond within 45 days of receiving a verified consumer request.
If we require more time (up to 90 days), we will inform you in writing of the reasons and the extension period. We will send our written response by mail.
Any disclosures we provide cover only the 12 months prior to receiving a verifiable consumer request.
Where applicable, our responses will also explain why we are unable to fulfill the request. Regarding data portability requests, we will provide your personal data in an easy-to-use format so that you can smoothly transfer information from one entity to another.
Op-Out Right
Under the California Consumer Privacy Act (CCPA), every California resident can request any business to stop selling personal information to third parties.
Right to Know
You have the right to know what categories of personal data we collect, including the purposes for which it is collected.
You can find this information in our Privacy Policy. Our Privacy Policy is updated at least every 12 months.
Right to Disclosure
- You can request that we disclose the personal data we have collected about you in the past 12 months.
- We assure you that our Privacy Policy is a relevant document in which you can find information about the personal data we have collected about you in the past 12 months, the personal data we intend to collect, the sources of your personal data, and how we use your personal data.
- The categories of personal data we collect about you are as follows:
- Categories of personal data sources
- Purpose of collecting your personal data
- Categories of third parties with whom we share your personal data are as follows:
- Specific personal data we collect about you.
Right to Erasure
You can request that we erase your personal data collected within the past 12 months.
We fully respect your right to erasure; however, it should be noted that in certain circumstances, we are obligated to retain your personal data for a specific period.
For example, if we need to retain your personal data for the following purposes: to provide you with services, to detect or resolve safety or functionality-related issues, to comply with the law, to conduct research in the public interest, to protect freedom of expression, or for any internal purpose you may reasonably expect. If we are not obligated to perform any of the above actions, we may erase your personal data upon your request.
Data Erasure
When GOLDEN PHOENIX no longer needs to retain your personal data, you can request GOLDEN PHOENIX to erase your personal data immediately.To request the erasure of your data, you can send an email to admin@pscrewlose.comto GOLDEN PHOENIX.
Contact Us
If you have any questions about this Privacy Policy, please contact us through the following methods:
admin@pscrewlose.com