Preamble

This policy is formulated by our platform regarding the products and services provided on its and/or its affiliated companies' website platforms and mobile terminals (including game services and other online services currently offered and those that may be provided to users in the future on the website platforms and mobile terminals, hereinafter collectively referred to as "products and services").

Our platform fully recognizes the importance of your personal information and will make every effort to ensure its security and reliability. We are committed to maintaining your trust in us and adhering to the following principles to protect your personal information: the principle of consistent rights and responsibilities, the principle of clear purpose, the principle of consent through choice, the principle of minimum sufficiency, the principle of ensuring security, the principle of subject participation, the principle of openness and transparency, etc.

Please note that our platform may modify and update this agreement from time to time, and you agree to regularly check for the latest version of this agreement. Before using our products (or services), please carefully read and understand this Privacy Policy to ensure that you are always aware of the latest version.

I. How We Collect and Use Your Personal Information

Personal information refers to various types of information recorded electronically or otherwise that can identify a specific natural person alone or in combination with other information, or reflect the activities of a specific natural person. Our platform collects and uses your personal information for the following purposes stated in this policy. If we need to use your information for purposes beyond those listed below, we will obtain your separate consent:

(I) Providing You with Products and Services on Our Platform and/or Its Affiliated Companies' Mobile Game Platform

1. Registration as a User

Information filled out to complete account creation includes: your name, mobile phone number, ID number, username you create, and other information you provide. According to current product regulatory policies in the industry and administrative departments, all online game users must use valid identity information to register for a game account. Therefore, to enable you to register for a game account normally and enjoy our services, we need to obtain your ID number and real name for real-name authentication, but we will not use this information for other purposes.

If you are a child, to meet legal and regulatory requirements, we also need to collect and use the information provided by your guardian when creating an account for you, including the guardian's name, mobile phone number, ID number, and other information provided by the guardian.

To provide users with continuous and stable services and ensure the security of their use of game services, our platform will require users to provide basic registration or login information and create user accounts and passwords. Users can choose the mobile phone registration function, in which case they need to provide their mobile phone number, and the game server will send a request SMS to help users complete registration. According to the current regulatory policy requirements for internet user account information management by administrative departments, when you use our game services, we need to collect your Internet Protocol (IP) address attribution information and display it on the game user account information page.

2. Information Notifications

To better help you obtain information about platform activities, etc., after you install our platform's related products, the platform product will automatically enable the information push permission upon startup, and the server will irregularly push information to you, usually no more than three times a day and no more than 30 times a month, and the content will all be related to the platform product.

You can choose to turn off the platform information notification function in the notification function of the system settings on your mobile terminal according to the relevant prompts on the mobile terminal.

To timely provide you with updates on platform products and services and enable the instant messaging push function of the product, we integrate message push SDKs. To ensure the stability, reachability, and timeliness of in-product message pushes, depending on the device brand and system version you use, the product may perform necessary self-starting or associated starting of other applications.

To better serve you, our platform will irregularly inform you about game product activities or conduct user surveys by phone. If you do not need to receive such information, you can inform us to cancel it when you receive our call.

In addition, our platform declares that there is no personalized recommendation behavior, that is, our platform does not collect user information or behavioral data to label specific user groups and send customized marketing information, provide or promote our platform's products and services to specific groups.

3. Payment and Settlement

To facilitate your comprehensive assessment of account and transaction risks, identity verification, and detection and prevention of security incidents during the payment of related orders, we may collect information related to your virtual assets (limited to transaction records, virtual currency, virtual transactions, game redemption codes, etc.) during the transaction process.

4. Security Guarantee

We will use some of your personal commonly used device information for identity verification, security prevention, fraud monitoring, archiving and backup, etc. For example, device identification codes are used for security prevention and user identification, and personal internet browsing records are used for security prevention and fraud monitoring.

When you use our customer service, we may save your communication/call records and content or the contact information you leave, etc., to contact you or help you solve problems, or record the solutions and results of related problems.

5. Product Development and Service Optimization

For example, to repair system failures and optimize our services, we may need to record and analyze information generated during system failures; to ensure the timely update of game product versions, we will collect information about users' mobile device application lists.

To facilitate communication between users, some of our platform's game products have built-in voice chat functions. If you install such game products, your mobile device's recording permission will be enabled to realize the voice chat function. This function is only used for interaction between users, and our platform does not retain any voice chat records.

6. Helping You Complete Orders and Deliver Goods or Services

When you participate in specific activities to redeem/order specific goods and/or services in the game services, to show you the transaction information of your account and ensure transaction security, we will generate an order for you to redeem/order such goods and/or services through the system, and collect information such as your specific order number, order creation time, and transaction amount (if any) to show you and facilitate your transaction management of the order. During the ordering process, if it is a physical commodity, we also need you to provide the recipient's name, shipping address, and contact phone number to deliver the commodity to you.

To complete order payment, deliver goods or services, confirm transaction status, and provide you with after-sales and dispute resolution services, we will collect information related to your transaction progress such as your account, order, transaction, and logistics information through the transaction objects, payment institutions, logistics companies, etc. you choose based on the transaction, or share your transaction information with the above service providers.

7. You understand and agree that some individual services in the game products and services provided by our platform may require you to enable specific access permissions on your device to realize the collection and use of information related to these permissions. For example:

(1) To verify user identity, realize mobile phone number login function, and ensure the network and account security of game services, after you confirm to enable the phone device permission again, our platform will have the right to obtain your device information (Android-id/hardware serial number/IMEI/phone number/OAID/MAC address information) as a unique identifier for your device, to provide you with a more convenient login function, display pages that better meet your needs, understand product adaptability, and identify abnormal states.

(2) To facilitate users to share game screens with other users, some of our platform's game products have built-in screenshot saving and sharing functions. After you confirm to enable the storage permission again, our platform will have the right to access your photos, media content, and files. This function is only used for users to share their own game screens.

(3) To facilitate users to find other users playing the same game nearby, some of our platform's game products have built-in positioning functions. After you confirm to enable the positioning permission again, our platform will have the right to use the network to obtain your approximate location or use GPS to obtain your precise location.

(4) To facilitate users to upload their real avatars to the game, some of our platform's game products have built-in photography functions. After you confirm to enable the camera permission again, our platform will have the right to use your mobile device's camera to take photos or record videos.

You can refuse to provide the above permissions and use the game products provided by our platform, but in this case, you may not be able to use some functions of the product, complete certain tasks of the product, realize certain interactions with other players, and fall behind other users in terms of game experience and benefits.

(5) To ensure account security and network communication detection and provide a good game operation experience, we will collect your game account registration information and user device information (used to detect game heartbeats, confirm whether users are online, and reconnect after network communication disconnections) during your use of game services, including when the application is silent or running in the background.

II. How We Use Cookies and Similar Technologies

(I) Cookies

To ensure the normal operation of the website, we will store small data files named Cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. Cookies help us identify you as our registered user, or save information you provide to us about your preferences or other information that helps us identify you as our registered user, or save information about your activities using the service or which services or services are most popular; and help us provide you with advertisements related to you based on your information instead of general advertising.

We will not use Cookies for any purposes other than those stated in this policy. You can manage or delete Cookies according to your preferences through your browser or other methods.

(II) Do Not Track

Many web browsers have a Do Not Track function, which can send Do Not Track requests to websites. Currently, major internet standard organizations have not yet established policies to regulate how websites should respond to such requests. But if your browser enables Do Not Track, all our websites will respect your choice. However, please note that this may affect your experience of using the products and services provided by our platform.

III. How We Share, Transfer, and Publicly Disclose Your Personal Information

(I) Sharing

You understand and agree that information that has undergone de-identification processing will not be able to identify your identity. In this case, we will use the de-identified information for the purposes of this Privacy Policy and provide it to third parties through sharing or transfer on the premise of ensuring that the data recipient cannot re-identify the personal information subject. We may share your personal information with any company, organization, or individual other than our platform in the following situations:

Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.
We may share your personal information externally according to legal and regulatory requirements or mandatory requirements from government authorities.

According to the current product regulatory policies in the industry and administrative departments, after obtaining your ID number and real name, we will entrust a third party for real-name authentication. For the organizations or companies we entrust to process personal information, we will require them to process personal information in accordance with our requirements, this Privacy Policy, and other relevant confidentiality and security measures.

Sharing with our affiliated companies: Your personal information may be shared with our platform's affiliated companies. We will only share necessary personal information and be bound by the purposes stated in this Privacy Policy. If an affiliated company wants to change the purpose of processing personal information, it will seek your authorization again.
Sharing with authorized partners: Some of our services will be provided by authorized partners only to achieve the purposes stated in this policy. We may share some of your personal information with our partners to provide better customer service and user experience. We will only share your personal information for legitimate, proper, necessary, specific, and clear purposes, and only share the personal information necessary for providing services. Our partners have no right to use the shared personal information for any other purposes. Among them, for the purpose of providing customer service, we will share your created username and information related to virtual assets (limited to transaction records, virtual currency, and virtual transactions) with authorized partners providing customer service. Authorized partners providing customer service will only use the above information for the purpose of providing customer service.
Sharing with user value-added service providers: Your account may be invited to join user value-added services provided by third parties when it meets specific conditions. User value-added services mean that according to your usage of the service, you may obtain different membership levels and enjoy different additional benefits. You do not need to pay any additional fees for these additional benefits. When you receive an invitation, you can refuse to accept the above value-added services. If you choose to accept the invitation, you agree that we will share your created username and information related to virtual assets (limited to transaction records, virtual currency, and virtual transactions) with user value-added service providers. User value-added service providers will only use the above information for the purpose of confirming your membership level and issuing benefits to you.

(II) Transfer

We will not transfer your personal information to any company, organization, or individual, except in the following situations:

Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties.
In the event of a merger, acquisition, or bankruptcy liquidation, if personal information transfer is involved, we will inform you of the relevant situation through push notifications, announcements, or other methods and continue to protect or require the new manager to continue to protect your personal information in accordance with the standards required by laws and regulations. Specifically, in such situations, we will require the data recipient to undertake the data security responsibilities and obligations. If there is no data recipient, we will destroy the data. If laws or administrative regulations stipulate otherwise, those provisions shall prevail.
In some scenarios, you can use the same account and password to log in and use on other third-party platforms to obtain a better game experience. To provide this service, we may need to transmit your personal information and game information to third parties, and we will continue to protect or require the new manager to continue to protect your personal information in accordance with the standards required by laws and regulations.

(III) Public Disclosure

We will only publicly disclose your personal information in the following situations:

After obtaining your explicit consent;
Related to national security or defense security;
Related to public security, public health, or major public interests;
Related to criminal investigation, prosecution, trial, and judgment enforcement;
To protect the major legitimate rights and interests such as the life and property of the information subject or other individuals, but it is difficult to obtain your consent;
The collected information is publicly disclosed by you to the public;
Collecting information from legally publicly disclosed sources, such as legitimate news reports and government information disclosure channels;
Necessary for signing a contract according to your requirements;
Necessary for maintaining the safe and stable operation of our platform's services, such as detecting and handling product or service failures;
Necessary for legitimate news reporting;
Necessary for academic research institutions to conduct statistical or academic research based on public interests, and when providing the results of academic research or descriptions to the outside, the information contained in the results is de-identified;
Other situations stipulated by laws and regulations.

IV. How We Protect Your Personal Information

(I) We will take all reasonable and feasible measures to protect your personal information. For example, we use SSL/hash to encrypt and protect your data; if we share your information with third parties, we will adopt encryption, desensitization, and other de-identification processing methods to ensure your information security.

(II) Other security measures we take to protect information

We manage and regulate the storage and use of information by establishing data classification and grading systems, data security management specifications, and data security development specifications.

We conduct comprehensive security control over data through information contact person confidentiality agreements, monitoring, and auditing mechanisms.

(III) We only allow our platform's staff and partners who need to know this information to access your information, and at the same time require all personnel who may have access to your information to fulfill corresponding confidentiality obligations. If they fail to fulfill these obligations, they may be held legally responsible or have their cooperation with our platform terminated.

(IV) We will take all reasonable and feasible measures to ensure that no irrelevant personal information is collected. We will only retain your personal information from the first time you use our products or services and agree to our collection of personal information until you cancel your account, unless laws and regulations explicitly require us to retain it for a longer period.

(V) The internet is not an absolutely secure environment, and email, instant messaging, and other communication methods with other users of our platform are not encrypted. Unless we explicitly require it, we strongly recommend that you do not send personal information through such methods. Please use complex passwords to help us ensure the security of your account. If we explicitly require you to send personal information using email or other methods when submitting specific service requests, we will take reasonable and feasible measures to protect the personal information you send in accordance with the requirements of this Privacy Policy.

(VI) The internet environment is not 100% secure. We will make every effort to ensure or guarantee the security of any information you send to us. If our physical, technical, or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of information, causing damage to your legitimate rights and interests, we will bear corresponding legal responsibilities.

(VII) In the unfortunate event of a personal information security incident, we will take necessary measures to prevent the security incident from expanding and inform you in the form of push notifications, announcements, etc.

V. Your Rights

In accordance with relevant Chinese laws, regulations, standards, and common practices in other countries and regions, we guarantee that you can exercise the following rights regarding your personal information:

(I) Access to Your Personal Information

You have the right to access your personal information, except for exceptions stipulated by laws and regulations.

(II) Control over Your Personal Information

You can query and manage the personal information under your account at any time. Your account name is an important online identity identifier for you. For security and identity recognition considerations, it cannot be changed after registration.

(III) Deletion of Your Personal Information

We will only collect and use your information to achieve the functions of our products or services as stated in this policy. If you find that we violate the provisions of laws, administrative regulations, or the agreement between us in collecting or using your personal information, or if you stop using our products or services by canceling your account, you can request us to delete it. If you find that the personal information we collect and store is incorrect, you can also request us to correct it. Please contact us through the contact information listed in this policy. For the avoidance of doubt, "deletion" includes anonymizing your personal information or irreversibly and permanently canceling the access rights of all our staff and all authorized third parties (if any) to your personal information.

(IV) Change the Scope of Your Authorization Consent

Each business function requires some basic personal information to be completed (see the first section of this policy). You can access, modify, and delete the registration information and other personal information you provide during the use of our services. The scope and method of accessing, modifying, and deleting personal information will depend on the specific service you use and the settings of your mobile device. For example, if you want to stop sharing your location information when using location-related services, you can stop sharing by turning off the location function on your mobile device or through the shutdown methods provided by software and hardware service providers and communication service providers.

Please note that the following personal information is the basic information required for our products and services. If you do not cancel your account, you cannot request the deletion of the following information alone. If the information is incorrect or changes, you can request modification. If you insist on requesting the deletion of the following information, you can cancel your account.

(1) Information filled out to complete account creation. Includes: your name, mobile phone number, ID number, and created username. If you are a child, it also includes your guardian's registration information, including the guardian's name, contact information, ID number, and guardianship relationship proof. Because this information is the basic basis for us to determine your identity. Except for contact information, this part of information is not allowed to be modified (except for changes in the guardianship relationship). If you need to modify the guardian's contact information in the child account information, the guardian must submit an application and re-verify the registration information (provide scanned copies of the guardian's ID card and guardianship relationship proof). If the guardianship relationship changes, the changed guardian should provide registration information, including the guardian's name, contact information, ID number, and new guardianship relationship proof.

(2) Information related to virtual assets collected during the transaction process (limited to transaction records, virtual currency, virtual transactions, and game redemption codes). Because this information may be the basic basis for judging responsibilities in case of disputes in subsequent services.

(3) When you use our customer service, we save your communication/call records and content or the contact information you leave. Because this information is the basic evidence for us to provide you with certain specific customer services and the necessary information for continuing to provide services in the future.

In addition, the device identification code is used for security prevention and user identification, which is information that we must collect. Therefore, even if you request the deletion of such information, if you continue to use our products or services after making the request, we will collect the above information again.

(V) Account Cancellation

When you submit an application, you should provide us with complete and correct account registration information (including but not limited to personal identity information). After review, we will cancel your account on our platform in accordance with relevant regulations. You can contact us through online customer service and follow the corresponding process to submit an account cancellation application.

(VI) Response to Your Above Request

To ensure security, you may need to provide a written request or prove your identity in other ways. We may first require you to verify your identity before processing your request. We will make a reply within fifteen working days. If you are not satisfied, you can contact our platform's customer service or handle it in accordance with the methods stipulated in the User Registration Service Agreement.

For your reasonable requests, we will not charge a fee in principle, but for repeated requests that exceed a reasonable limit, we will charge a certain cost fee according to the situation. For requests that are unreasonably repeated, require excessive technical means (for example, require the development of a new system or fundamentally change current practices), pose risks to the legitimate rights and interests of others, or are very impractical (for example, involve information stored on backup tapes), we may refuse them.

In the following situations, in accordance with legal and regulatory requirements, we will be unable to respond to your request:

Directly related to national security or defense security;
Directly related to public security, public health, or major public interests;
Directly related to criminal investigation, prosecution, trial, and judgment enforcement;
There is sufficient evidence to show that you have subjective malice or abuse of rights;
Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;
Involving trade secrets;
Other situations where we have reasonable grounds to refuse.

VI. How We Handle the Personal Information of Minors

Our products, websites, and services are mainly aimed at adults. Our platform complies with national policies, and minors/children are not allowed to create their own user accounts without the consent of their parents or guardians. For situations where we collect personal information of minors/children with the consent of their parents or guardians, we will only use or publicly disclose such information when allowed by law, explicitly agreed by parents or guardians, or necessary to protect minors/children.

VII. How We Store Your Personal Information

Except as otherwise stipulated by laws, regulations, or regulatory authorities, we will only store your personal information for the time necessary to achieve the purpose of the service.

(I) The Method and Period of Information Storage

We will store your information in a secure manner, including local storage (for example, using APP for data caching), databases, and server logs. Generally, we will only store your personal information for the time necessary to achieve the purpose of the service or under the conditions stipulated by laws and regulations. After the above period expires or you apply for account cancellation or actively delete personal information, we will delete or anonymize your personal information, except as otherwise stipulated by laws, regulations, or regulatory authorities.

Our criteria for determining the storage period of personal information mainly refer to the following standards, and the longer one shall prevail:

Complete the business function you agree to use;
Ensure the security and quality of the services we provide to you;
A longer retention period you agree to;
Whether there are other provisions on the retention period.

(II) The Geographical Location of Personal Information Storage

The personal information we collect and generate within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China.

(III) Global Transfer of Personal Information

If the game you use is developed or provided by overseas developers or related parties (hereinafter referred to as "overseas recipients") and is distributed and operated by us in China, to conduct game security analysis and improve game services, we may provide the relevant personal information we collect according to this Privacy Policy to the overseas recipients. Before providing your personal information to overseas recipients, we will obtain your separate authorization consent in accordance with legal requirements and ensure that it is implemented in accordance with national laws, regulations, and the requirements of relevant regulatory authorities to provide sufficient protection for your personal information.

VIII. Possible Changes to This Policy

Without your explicit consent, we will not reduce the rights you are entitled to under this Privacy Policy. We will publish any changes made to this policy on this page.

For major changes, we will also provide more prominent notifications. If you do not agree with the changed content, you can choose to stop using our services; if you continue to use our services, it means you agree to be bound by the revised Privacy Policy.

Policy Protection