Last updated: 【Dec. 20th 2021】
When you contract to use the Game (the “Game Services” or “Services”), you accept our rules and policies regarding your personal data and you expressly consent to us collecting, processing, using and storing your personal data, as described in this policy.
This section describes the different types of personal data we collect and how we collect it.
We will collect and use the following data about you:
1.1.1 When you register for the Game (including your nominated nickname, and information we import from your connected social media account, e.g. Facebook, Twitter or Apple sign-in account) in order to set up your profile, including your name as it appears on your social media profile and your profile picture;
1.1.2 When you set up your profile for the Game (including information you voluntarily elect to provide in order to customize gameplay, such as gender);
1.1.3 When you submit your contact details to us (including your name, email address and physical address) as part of promotional activities for the Game; and
1.1.4 When you make purchases in the Game (in which case we will process the information you provide to us to facilitate the payment);
1.1.5 When you want to see the regional leaderboards (in this case, we will use your geo-location information);
1.1.6 When you want to use features such as voice chat interaction (including microphone permissions on your mobile device).
We automatically collect certain data from you when you use the Game，including your IP address, physical location and device information (such as device type, network data, OS) and information regarding your use of the Game, such as date and time stamps of actions. We also collect and store your data each time you interact with us, for example, when you use in-app support to communicate with us.
You may provide additional information as part of your profile (such as gender). You may also provide or generate information when you communicate with other users in the Game (e.g., chat log data, chat content).
2.2 You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies, or instruct the device (in the case of the Game) or web browser (in the case of the Community Website) to provide notice at the time of installation of cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event of your refusal to install cookies, the Game may be unable to operate as designed.
We will use the data in the following ways and in accordance with the following legal bases:
(ID on social media accounts like Facebook, Twitter, Game Center, Google Play, Apple，collectively defined as “Social ID”), Open ID, nick name, email address, avatar)
(Device ID, Device Type, Operating System, CPU, RAM, IP address, MAC address)
We use this information to provide and improve the Game Services such as: to allow you to download and install the Game on their devices; to record and keep track of requests from you of the Game; to detect your network and device status when you is playing the Game; and to correct bugs or errors that occur when you are playing the Game. Use of Device Information is necessary to provide the Game.
(Name, Email, Address, Phone Number, and Instant Messaging Account)
(Gender, age, photo and etc.)
(Level, Heroes, Score, chat log and etc.)
We use this information to provide Services to you as it is the basis of our Game. Use of Game Data is necessary to provide the Game.
We will store your data in a secure way, including local storage (such as game caching), databases, and server logs.
In general, we store your personal data only for such period of time as may be necessary for the purpose of the service or under such conditions as may be required by laws and regulations. We promise that your personal data will always be stored for a reasonable and necessary period of time. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
6.1.1 Authorized partners of advertising and analysis Services. We will not share your personally identifiable data (such as your name or email address, through which you can be contacted or identified) with partners providing advertising and analytics Services unless we have your consent. We provide these partners with data about the coverage and effectiveness of their ads without providing personally identifiable data about you, or we aggregate that data so that it does not identify you personally.
6.1.2 Suppliers, service providers, and other partners. We send the data to support our business in the global scope of the suppliers, service providers and other partners, including but not limited to provide these data supporting technology infrastructure Services, analysis of the use of our service, to measure the effectiveness of advertisement and Services, to provide convenient customer service, payment or academic research and investigation.
We will not publicly disclose your personal data unless we obtain your express consent. In addition, we may disclose your personal data to competent authorities on the basis of laws, legal procedures, lawsuits or mandatory requirements of government authorities. However, we guarantee that in the event of such occurrence, we will verify the authenticity of the disclosure requester and the disclosure request, and if necessary, require the disclosure requester to issue corresponding valid legal documents and take security measures in accordance with legal and industry standards for the disclosed data.
7.2 Unfortunately, the transmission of data via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of the data transmitted to our Services; any transmission of your data is at your own risk.
Please use complex password to help us ensure the security of your Game account. We will do our best to ensure the security of your personal data that you send to us. If our physical, technical or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering or destruction of data, resulting in damage to your legitimate rights and interests, we will take appropriate remedial measures.
We will update and make public security risk, personal data security impact assessment report and other relevant contents from time to time, which can be obtained by 【come be soon】.
In the event of an unfortunate personal data security incident, we will inform you according to the requirements of laws and regulations: the basic situation and possible impact of the security incident, the measures we have ta-ken or will take to deal with it, the Suggestions you can take to prevent and reduce risks, the remedial measures for you, etc. We will inform you of relevant information by email, letter, phone call, push notification, etc. When it is difficult to inform the subject of personal data one by one, we will take a reasonable and effective way to release an announcement.
Our Services are operated in【Hong Kong】, and other countries/areas/regions around the world. Please be aware that information we collect, including Personal Information, will be transferred to, processed and stored in these countries/areas/regions and, as such, courts, law enforcement, and other authorities in these countries may, in certain circumstances, be entitled to access your Personal Information. However, if we do so, we will take reasonable steps to safeguard the privacy of your personal data. These steps may include implementing standard contractual clauses where recognized by law, obtaining your consent, or other lawful means of transferring personal data. By using our Services or providing us with any information through them, you acknowledge this transfer, processing, and storage of your information in these countries in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen. However, if we do so, we will take reasonable steps to safeguard the privacy of your personal data. These steps may include implementing standard contractual clauses where recognized by law, obtaining your consent, or other lawful means of transferring personal data. By using our Services or providing us with any information through them, you acknowledge this transfer, processing, and storage of your information in these countries in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen.
We generally rely on personal data provided by you (or your authorized representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
You may opt-out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications.
You can opt-out of interest-based advertising on mobile applications. For personalized in-game offers opt-out, you can use the options provided in the game settings. Note that we will always slightly customize what you see (e.g. to avoid displaying content you've already purchased).
You have the right to inquire, correct or supplement your information. You can do this by yourself in the following ways:【email@example.com】.
You may request removal of personal data from us in the following situations:
10.4.1. If our handling of personal data violates laws and regulation;
10.4.2. If we collect and use your personal data without your express consent;
10.4.3. If our handling of personal data seriously violates our agreement with you;
10.4.4. If you no longer use our products or Services, or you take the initiative to cancel your account;
If we decide to respond to your removal request, we will also notify, as far as possible, the subjects who received your personal data from us and request that it be removed in a timely manner (unless otherwise provided by laws and regulations or if such subjects have independently obtained your authorization).
When you or we assist you in removing the information, we may not be able to immediately remove the information from the backup system due to applicable laws and security techniques, and we will securely store your personal data and isolate it from any further processing until the backup can be erased or anonymous.
Each business function requires some basic personal data to complete. In addition, you can give or take back your authorization consent by setting or contacting customer service in【firstname.lastname@example.org】or changing the Settings of your smart mobile device.
When you withdraw your consent, we will no longer process the appropriate personal data. However, your decision to withdraw your consent will not affect the processing of personal data previously carried out on the basis of your authorization.
You can apply for cancellation of your account by the following means: 【email@example.com】. After you voluntarily cancel your account, we will stop providing Services for you, delete your personal data as required by applicable law, or make it anonymous.
For the above to security, you may need to provide a written request, or otherwise we may ask you to prove your identity to verify their identity, and then we will process your request within 15 days to respond, if you are not satisfied, you can also lodge a complaint by 【firstname.lastname@example.org】.
We do not charge a fee for your reasonable request in principle, but we will charge a fee for requests that are repeated more than once and beyond reasonable limits. We may reject information that is not directly related to your identity, unwarranted duplication of information, or requests that require too much technology (for example, the need to develop a new system or radically change existing practices), that pose a risk to the legitimate interests of others, or that are unrealistic.
Under the following circumstances, we will not be able to respond to your request as required by laws and regulations:
(a) National security;
(c) Public safety;
(d) Prevention of criminal offences, investigation, investigation, prosecution or enforcement of criminal penalties, including prevention and prevention of threats to public security;
(e) Other important objectives of the general public interest of the union or of a member state, in particular the important economic or financial interests of the union or member state, including matters of currency, budget and taxation, public health and social security;
(f) Independence of the judiciary and protection of judicial procedures;
(g) Prevention, investigation, investigation and prosecution of breaches of professional ethics;
(h) Supervisory, inspection or related regulatory functions and even the occasional exercise of official authority in cases involving subparagraphs (a) (b) (c) (d) (e) (f) and (g).
(I) Protection of the rights and freedoms of the data subject or other person.
(j) Enforcement of compensation in civil proceedings.
We may from time to time send you announcements when we consider it necessary to do so (such as when we temporarily suspend The Service access for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.
If you are children (a minor and under the age of 13), you are not allowed to use our Services, and we do not knowingly collect personal data from children in connection with our Services. If you believe that we have unintentionally collected your children’s personal information, you may request the deletion of the information by contacting us at 【email@example.com】. In some cases we may ask the user to provide us with their birth date. If such information indicates the user is under the age stipulated by the applicable laws and deemed as child under such laws, we will not collect further personal information from the child until a parent/guardian’s verifiable consent is obtained.
You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Contact No.: 【+8618916310814】
Email Address: 【firstname.lastname@example.org】
Address:【FLAT/RM A1 BLK A 11/F, SUCCESS COMMERCIAL BUILDING, 245-251 HENNESSY ROAD, WAN CHAI, HK】
If we make any material changes to this policy, we will post the updated policy here and notify you. Please check this page frequently to see any updates or changes to this policy. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.