PRIVACY NOTICE
Last updated: December 17, 2021
Sea of Vanguard and its affiliates (“Sea of Vanguard” or “we”, “us”, “our”) provide various game products and services.
Sea of Vanguard respects your right to privacy. This Privacy Notice describes how we collect, use and share personal data about you and how you can exercise your privacy rights. This Privacy Notice applies to personal data that we collect when you use our products and services.
If you have any questions or concerns about our use of your personal data, then please contact us using the contact details provided at the bottom of this Privacy Notice.
Quick links
We recommend that you read this Privacy Notice in full to ensure you are fully informed. However, if you only want to access a particular section of this Privacy Notice, then you can click on the relevant link below to jump to that section.
1. What personal data does Sea of Vanguard collect and why?
2. Who does Sea of Vanguard share your personal data with?
3. Legal basis for processing personal data
4. Cookies and similar tracking technology
5. How does Sea of Vanguard keep your personal data secure?
6. International transfers
7. Data retention
8. Protection of children’s personal data
9. Your data protection rights
10. Updates to this Privacy Notice
11. How to contact us
1. What personal data does Sea of Vanguard collect and why?
The personal data that we may collect about you broadly falls into the following three categories:
Data you provide voluntarily
When you use our game products and services, or when you otherwise need to provide your personal data to us, we may ask you to provide your personal data voluntarily as followed.
Network identification data: such as nickname, game ID, character image, avatar, game friend list;
Personal property data: such as transaction order records, transaction and consumption records (including recharge), completed payment verification information, virtual currency, virtual transactions, game redemption codes, game coins, game props, game equipment;
Personal data related game and Internet: such as communication records between customer service and player, player/user/visitor’s complaint content, game login/item log, game match information, game friend information, player game progress, game crash records;
Other data: game research results information.
We may use this data to provide and improve our products and services, optimize users’ experiences in games, enable our customer service to solve your problems, protect your game account, etc.
We may collect your personal data under the requirements of applicable data protection laws, which will only be used for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal data. However, we may also use your personal data for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.
Data we collect automatically
When you visit or use our websites/applications, we may collect certain data automatically from your device.
Specifically, the data we collect automatically may include:
device ID/name/model, MAC address;
device platform, manufacturer brand of device, screen size of device (Xiaomi, Meizu, Huawei);
unique device identification code (such as IME/Android ID/IDFA/OPENUDID/GUID);
random storage memory and external storage permissions;
application version and type;
system type/version, language settings, resolution;
mobile network status/WIFI status/WLAN hotspot information, mobile terminal;
broad geographic location, technical information;
information about how your device has interacted with our websites/applications, including the pages accessed and links clicked.
Collecting this data enables us to better understand the users who come to our applications, where they come from, and what content on our applications is of interest to them. We use this data for our internal analytics purposes and to improve the quality and relevance of our websites/applications to our users.
Some of this data may be collected using Cookies and similar tracking technology, as explained further under the heading “4. Cookies and similar tracking technology”.
Data that we obtain from third party sources
From time to time, we may receive your personal data mentioned above from third party sources, but only where these third parties either have your consent or are otherwise legally permitted or required to disclose your personal data to us.
Our third party sources include AppsFlyer, Applovin, Admob(Adsense), UnityAds, Vungle, Facebook, Google Ads, ironSource, Pangle(bytedance), Mintegral, etc. These third parties provide us with services such as attribution and marketing analysis, collecting device information, as well as matching and delivering customized ads.
In general, we will use the personal data we collect from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your personal data. However, we may also use your personal data for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws.
2. Who does Sea of Vanguard share your personal data with?
We may share your personal data to the following categories of recipients:
to third party suppliers/services providers, partners who provide data processing services to us, and who otherwise process personal data for purposes that are described in this Privacy Notice or notified to you when we collect your personal data;
to any competent law enforcement body, regulatory, government agency, court or other third parties, only for the reasons of (i) as a matter of applicable laws or regulations, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person, if such disclosure is necessary;
to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal data only for the purposes disclosed in this Privacy Notice;
to any other person with your consent.
3. Legal basis for processing personal data
Our legal basis for collecting and using the personal data described above will depend on the personal data concerned and the specific context in which we collect it.
However, we will normally collect personal data from you only (i) where we need the personal data to perform a contract with you, (ii) where the processing is in our legal interests and not overridden by your rights, (iii) where we have your consent to do so. In some cases, we may also have a legal obligation to collect personal data from you or may otherwise need the personal data to protect your vital interests or those of another person.
If we ask you to provide personal data to comply with a legal requirement or to perform a contact with you, we will make this clear at the relevant time and advise you whether the provision of your personal data is mandatory or not (as well as of the possible consequences if you do not provide your personal data).
If we collect and use your personal data in reliance on our legal interests (or those of any third party), this interest will normally be to operate our websites/applications and communicate with you as necessary to provide our products and services to you and for our legal commercial interest, for instance, when responding to your queries, improving our products and services, undertaking marketing, or for the purposes of detecting or preventing illegal activities. We may have other legal interests and if appropriate we will make clear to you at the relevant time what those legal interests are.
If you have questions about or need further data concerning the legal basis on which we collect and use your personal data, please contact us using the contact details provided under the “How to contact us” heading below.
4. Cookies and similar tracking technology
We use Cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal data about you, which enable us to track your game progress, understand your preferences, and provide you with a smooth, high-quality and personalized user experience. A Cookie is a data file containing small amounts of information that a website can send to your browser (and many websites do), which may then be stored on your computer as a tag that distinguishes your computer but does not name you.
---AppsFlyer
Collected Information:
Device Information
Payment information
Personal Information
Business Scene: Data Analysis
Collected Information:
Device Information
Payment information
Personal Information
Business Scene: Account Binding
---ironSource
Device Information
Payment information
Personal Information
Business Scene: Advertising Services
---Firebase
Device Information
Payment information
Personal Information
Business Scene: Data Analysis
5. How does Sea of Vanguard keep your personal data secure?
We have implemented technical, administrative, and physical security measures that are designed to protect your Personal Data from unauthorized access, disclosure, use and, modification, including using encryption technology (e.g.SSL) to keep your personal data confidential, adopting protection mechanisms to prevent malicious attacks on your personal data, and strictly limiting the scope of people who can access your personal data.
From time to time, we review our security procedures to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable and we cannot guarantee that our security procedures will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
The security of your personal data also depends on you. For example, you are responsible for keeping your password secure and confidential.
6. International transfers
Your personal data may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
Specifically, our application servers are located in the People’s Republic of China, and our group locations and third party service providers and partners operate around the world. This means that when we collect your personal data we may process it in any of these countries.
However, we have taken appropriate organizational and technical measures to ensure that your personal data is properly protected. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal data, which require us to protect personal data processed from the EEA in accordance with European Union data protection law.
7. Data retention
We retain personal data we collect from you during the time that you use our products or services, and for the shortest period necessary to achieve the purpose of our legal business purpose. We may also retain your personal data where we have an ongoing legal business need to do so (for example, to provide you with a service you have requested, to perform a contract with you or to comply with applicable legal, tax or accounting requirements).
When we have no ongoing legal basics to process your personal data, we will either delete or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.
8. Protection of children’s personal data
We attach great importance to the protection of personal data of children under applicable laws and regulations and we keep exploring new ways to protect children’s personal data.
If you are the legal guardian of a child, please pay attention to whether the child uses our products or services, or provides his or her personal data after obtaining your authorization and approval. Before using our products or services, both the child and his/her legal guardian shall read our Children’s Personal Data Protection Policy carefully. Only with your legal guardian’s consent to our Children’s Personal Data Protection Policy, shall you be able to use our products or services.
If you have questions about the personal data of the child under your guardian, please contact us using the contact details provided under the “How to contact us” heading below.
9. Your data protection rights
Your rights
You have the following personal data protection rights:
If you wish to access, correct, update or request deletion of your personal data, you can do so at any time by contacting us using the contact details provided under the “How to contact us” heading below;
In addition, you can object to processing of your personal data, ask us to restrict processing of your personal data or request portability of your personal data. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below;
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please contact us using the contact details provided under the “How to contact us” heading below;
Similarly, if we have collected and process your personal data with your consent, then you can withdraw your consent at any time, unless otherwise provided by law. It is important to note that withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal;
You have the right to complain to a data protection authority about our collection and use of your personal data. Contact details for data protection authorities in the European Economic Area are available here.
If you wish to make such a request, please contact us by using the contact details provided under the “How to contact us” heading below. Before responding to your request, we may ask you to verify your identity and to provide further details about your request. We respond to all requests we receive from individuals wishing to exercise their personal data protection rights in accordance with applicable data protection laws.
10. Updates to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, technical or business developments, such as changes in business function, your rights and the way they are exercised, contact information and complaint channels, and others may affect the security of your personal data.
You can see when this Privacy Notice was last updated at the top of this Privacy Notice.
11. How to contact us
If you have any questions or concerns about our use of your personal data, please contact us using the following details:
Email: billzee77@gmail.com