Personal Data and Privacy Protection Policy

Last Updated: [February 27^th 2024]

Effective Date: [February 27^th 2024]

Ziyi Group has always been earnestly committed to protecting the personal data and privacy of users who use the products or services provided by Ziyi Group. In order to better protect your legitimate rights and interests, this Personal Data and Privacy Protection Policy is specially made by us to explain to you the processing rules under which we collect and use your relevant personal data when you are using our products or services (including your interaction with Ziyi Group and your registration as a user of Ziyi Group and/or use of Ziyi Group’s products or services, hereinafter collectively referred to as the “Services”) and other related matters.

THIS PERSONAL DATA AND PRIVACY PROTECTION POLICY (HEREINAFTER REFERRED TO AS “PRIVACY POLICY” OR “POLICY”) IS MADE BY AND BETWEEN YOU (HEREINAFTER REFERRED TO AS “YOU/USER”) AND ZIYI GROUP HK LIMITED (HEREINAFTER REFERRED TO AS “ZIYI GROUP” OR “WE/US/OUR”) WHOSE REGISTERED OFFICE IS AT SUITE 603, 6/F LAWS COM PLAZA 788 CHEUNG SHA WAN RD. THIS PRIVACY POLICY SHALL BE LEGALLY BINDING TO YOU.

PLEASE BE AWARE THAT WE DO NOT KNOWINGLY COLLECT PERSONAL DATA OF USERS UNDER THE AGE OF 17 AND/OR MINORS (WHETHER YOU ARE A MINOR WILL DEPEND ON THE AGE OF MAJORITY IN YOUR COUNTRY/REGION). IF YOU ARE THE GUARDIAN OF A MINOR AND YOU FIND THAT YOUR MINOR HAS USED OUR SERVICES AND SUBMITTED HIS/HER PERSONAL DATA, PLEASE INSTRUCT HIM/HER TO STOP USING OUR SERVICES IMMEDIATELY AND INFORM US PROMPTLY SO THAT WE CAN TAKE APPROPRIATE MEASURES ACCORDINGLY.

In the Annex to this Policy, we remind you of personal data protection requirements in different countries/regions. If your country/region is listed in the Annex, please read the relevant regulations carefully.

Table of Contents

Preamble

I. How do we collect and use your personal data

II. We may share, transfer or disclose your personal data

III. How do we store and protect your personal data

IV Your rights to manage your personal data

V. Protection of minors

VI. Updates

VII. Contact us

VII. Miscellaneous

Preamble

Please read and understand this entire Privacy Policy before using the Services provided by Ziyi Group. You shall also carefully review the terms marked in bold/ bold and with an underline, and confirm you understand and agree to them before using the Services. If you do not agree to the content of this Policy, we may not be able to provide our Services properly or to deliver the expected Services., and you shall stop accessing/using our Services immediately.

If you have any questions or concerns about this Privacy Policy or other relevant matters after reading entire Policy, Please contact us through the feedback channels set forth in the section “Contact us” hereof, and we will respond you as soon as possible.

I. How do we collect and use personal data

1. Personal data you provide

(1) In order to provide you with continuous and stable Services and maintain the security, you shall provide us with basic registration or login information (including mobile phone number and email address), and create your account, User name and password. The information you provide when you register an account will be used to ascertain your age and provide you with better services in accordance with the relevant laws and regulations. If you do not provide such real identity information or provide us with false information, you will not be able to use our Services or be subject to corresponding restrictions in the process of using the Services. You agree that we may collect your online identification information (including system account number, password, IP address, personal digital certificate) and information on your commonly used personal device (including hardware serial number, hardware model, MAC address of the device, OS type, OS version, software list, unique device identifiers, device name, network status, operator, browser identification, language of the device, time zones of the device), which will be used to mark you as a User of Ziyi Group. Please be aware that when you log in to the system of Ziyi Group through a third-party account (Apple ID, Google, Facebook, Twitter), we may collect such information of your relevant account such as your unique identifier, account name, nickname, personal avatar, personal status, and list of friends, which are used to store your login information, so that you can log in to our system on different devices. In some cases, we may provide you with an account linking function: you may link your e-mail address to the third-party account you use to log in, and you may log in to the Game through that email address after the linking is successful. We may synchronize your Personal data to that email address to ensure that you can use our services properly. If you do not agree to authorize the collection of such information, you will not be able to log in to the system of our products/Services using a third-party account.

(2) Personal data you submit for participating in the activities/questionnaire surveys held or conducted by us, or through our customer service staff, i.e. your name, gender, phone number, address, educational attainment, occupation, and personal income. If you do not participate in such activities/questionnaire surveys, or not to provide the above information to our customer service staff, your access to other Services will not be affected.

2. We collect your usage information legally when you use our Services, including:

(1) when you use our Services, we may collect and store your device or software information about the Services you use and how you use them, including the configuration information, IP address, model and OS version of the mobile device used, device identifier, MAC address, unique device identifiers, clipboard information, battery, signal strength, network type, and operator information provided by your mobile device, web browser or any other programs used to access our products or Services, in order to provide you with the access to the basic game features, identify any abnormalities in your account, understand and improve the adaptability of our products, and guarantee the network and operational security of the Services to maintain the normal functioning of our Services, protect the lives and property of you or other users or the public from harm, better prevent security risks such as phishing sites, fraud, network vulnerabilities, computer viruses, cyberattacks and network intrusions, and more accurately identify any violations of laws and regulations.

(2) When you use our online game services, we may collect your game log information, including your login logs, item logs, matches information, purchase logs, activity logs, upgrade logs, chat logs, guild logs and social networking records, which will be used for statistical analysis in game operations, handling of customer complaints, anti-cheat analysis and other analysis for optimization of gaming experience. Moreover, in order to enhance your gaming experience, we may synchronize the aforementioned information with the subsequent versions of the game or our other products you use.

(3) When you make purchases within the Services provided by Ziyi Group, we will collect your top-up records and your transaction records, in order to enable you to complete payment and top-up, to show you the transaction information of your account, to ensure transaction security, to facilitate your checking of transaction records and protect your virtual property to the maximun extent. The collection of the above information is necessary for Ziyi Group to deliver the consumption services, and it will be impossible to complete transactions without such information.

(4) When you upload and/or publish any information and engage in any relevant interactive activities (such as making comments, publishing posts, or leaving messages in the form of text, picture, voice, video or otherwise), we will collect and store the information you send for the purpose of filtering pornographic, violent, political or abusive information, malicious advertisements and other inappropriate contents, so as to create a clean and safe gaming environment.

Please be aware that the information you publish may contain your personal data or certain important personal data, which may be collected and used by others. Please consider carefully before publishing any such information. Even if you delete such information, they may still be saved in cache, copied or stored independently by other users or third parties which are not under our control, or be kept in the public domain by other users or such third parties. In particular, if the information you publish involves the personal data of others, you shall obtain their consent before posting it. Once you discover that your information is being improperly collected or used by others, you may contact us through the feedback channels listed in the section “Contact us” hereof.

(5) When you complete the payment for an order, deliver goods or Services, confirm the transaction status and provide you with after-sales and dispute resolution services, we will collect your personally identifiable information as consignee (such as name, shipping address, zip code, phone number, payment status, and logistics information) relating to the progress of transaction through the counterparty, payment institution and logistics company selected by you for the transaction, or share your transaction information with such service providers. If you do not provide such information, we will not be able to complete the relevant delivery services, but this will not affect your normal use of other Services of Ziyi Group.

(6) When you contact us, we may collect your communication/call records and contents or the contact information you leave in order to contact you or help you resolve a problem, or to record the resolution and outcome of the relevant issue.

(7) Device permissions: You understand and agree that during your use of our Services, we will ask for permissions to access your system when necessary to collect and use certain information. We will inform you of the purpose of the permission and seek your consent before getting your permission. If you disagree, we will not enable the relevant permissions and will therefore not be able to provide you with the Services corresponding to such permissions. After you authorize and consent to such permissions, we will access your camera and photo album, and we also require permissions to access your list of applications and store data in external storage to complete the storage and caching of the corresponding results, so as to enable photographing, screenshot, sharing, provision of pictures/videos to customer service staff, anti-cheat for gaming security and other functions involved in the Services we provide. If you object to provide such permissions and contents, you will be unable to use these functions/Services, without affecting your use of other Services of Ziyi Group.

You may enable/disable the aforementioned permissions at any time on the system permissions management interface of your device. Please note that by enabling any permission, you authorize us to collect and use the relevant information to provide you with the corresponding Services. By disabling any permission, you withdraw the corresponding authorization, and we will no longer collect and use the relevant information based on such permission and therefore become unable to provide you with the Services corresponding to such permission. However, your decision to disable any permission will not affect our previous collection and use of information based on your authorization.

(8) In order to ensure the security of your game account and create a fair, sound and safe gaming environment, we will collect your gaming application information, device information (such as ID, serial number, manufacturer, device name, type and version, model, and style of the device), online identification information, hardware and OS information, process and game crash records, network type, and information on the operator, which will be used to combat activities that may undermine the fair gaming environment or interferes with the normal operation of our game services (for example, such information may be used to detect piracy, screen plug-ins, and anti-cheat).

4. We may send notification to you, including:

(1) When you use our Services, we may contact you by phone or send you SMS messages or push notifications. You may choose to unsubscribe from our calls and messages on your device by following our instructions.

(2) We may send services-related announcements to you when necessary (for example, when a given service will be suspended due to system maintenance). You may not unsubscribe from any services-related announcements which are not of advertising nature.

5. Exceptions to consent and authorization

(1) We may collect and use your certain personal data without your authorization and consent in compliance with the relevant laws, regulations, and national standards in the country where you use our products and services, as well as to meet the request of judicial authorities and law enforcement agencies.

II. We may share, transfer or disclose your personal data

1. Sharing

(1) We attach great importance to the protection of your personal data, and we share your personal data with third parties only for lawful, legitimate, necessary, specific and explicit purposes. We will sign strict confidentiality agreements with companies, organizations and individuals that receive personal data from us, requiring them to process such information at our instruction, in accordance with this Policy and any other relevant confidentiality and security measures.

(2) To achieve the purpose detailed in this Privacy Policy, we may cooperate with SDKs provided by third-parties or other similar third-party applications (such as embed code, plug-in, H5, etc.), to provide you with better customer services and User experience. For the purpose of providing the above services, third-party SDKs or other similar applications may collect your Personal Data, such as your real name, ID card information, online identification information (including system account number, password, IP address, personal digital certificate), information of your commonly used personal devices (including hardware serial number, hardware model, MAC address of the device, OS type, OS version, software list, unique device identifiers, OAID, network status, operator, etc.), SIM card information (ICCID, IMSI), system- and software- related configuration information, WIFI and Cellular network information (MAC address of the WIFI interface controller, MAC address of the WIFI hotspot, WIFI name, list of surrounding WIFI networks, network connection method), country code, etc. When collecting and processing your information and other activities, third-party SDKs or other similar applications shall be in accordance with their own privacy policy or relevant statements. We recommend you to read their privacy policy before using any third-party services. To protect your legitimate rights and interests, if you find any risks in any relevant third-party services, you are advised to stop using it and contact us immediately.

We share your information with third parties, including as follows:

(3) Without your consent, we and our affiliates will not share your personal data with any third parties, except:

i．for the purpose of providing you with our products or Services;

ii. for the purpose as described in the section “How do we collect and use personal data” ;

iii. for the purpose of fulfilling obligations and exercising rights as described in this Privacy Policy or other agreements made by and between you and Ziyi Group;

iv. for the purpose of understanding, maintaining and improving our products or Services;

v. on the basis of a legal request from you or your guardians;

vi. required by laws and regulations or relevant authorities.

2. Transfer

We will transfer your personal data only when:

(1) you expressly consent;

(2) required by laws and regulations or relevant authorities;

(3) we and our affiliates merge, consolidate, transfer assets or carry out any other similar transactions as our business continues to grow, we may transfer your personal data as a part of such transactions. We will inform you of that by push notifications, announcements or otherwise, and continue to protect, or request the new managers to continue to protect your personal data in accordance with the relevant laws and regulations which go no less than the standard described in this Policy.

3. Disclosure

We will disclose your personal data only when:

(1) you expressly consent;

(2) required by the laws and regulations or relevant authorities..

4. Cases in which your prior consent is not required, including when:

(1) We may share, transfer or disclose your personal data without your consent in compliance with the relevant laws, regulations, national standards of the territory where you use our products and Services, and the writs of execution issued by the administrative or judicial authorities.

(2) You acknowledge and agree that the information we collect may be de-identified and used for optimizing the gaming performance, experience, and enhancing the big data analysis on service quality.

III. How we store and protect your personal data

1. Storage of personal data

(1) we will only store your data as long as necessary to fulfill the purpose described in this Privacy Policy, unless:

when required by the laws, regulations or regulatory authorities where you use our Services;

for reasonable and necessary purpose to safeguard the public interest or to protect the personal rights, property safety or other legitimate interests of our customers, we ourselves, our group companies, our Users or employees.

Our group companies operates all over the world. Pursuant to our contract with you, your personal data will be processed on servers that may not be located where you reside. No matter where the servers are located, we will take appropriate steps to safeguard your rights in accordance with this Privacy Policy. Our servers are located in:

Frankfurt, Germany

Singapore

California, United States

Your data we collect or share with third-party partners may also be stored and processed on our third-party SDK servers located in the United States, Germany and Singapore.

In addition, your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including Singapore.

(2) If we terminate the Services or operations, we will cease the collection of your personal data promptly, and will notify you in advance as required by the relevant laws and regulations, and we will delete or anonymize your Personal Data after such termination, unless otherwise required by relevant laws, regulations and regulatory authorities.

(3) We will delete or anonymize your personal data if you request to delete your account, voluntarily delete your data or after a certain necessary period of time, unless otherwise a certain retention period is required by laws and regulations.

(4) If the information we collect needs to be transferred across borders within ziyi group, we will ensure that such transfer is in accordance with laws, regulations and the requirements of the country where the data originates, and in compliance with the requirements of the relevant regulatory authorities, to provide adequate protection for your personal data. We will de-identify and anonymize your personal information to ensure security and confidentiality, and we ensure that the region where the data is received has the same level of data protection capability as your region.

2. Protection

We will take security measures conforming to industry standards, including establishing reasonable institutional norms and security technologies, to prevent unauthorized access, use, modification of your personal data and to avoid data corruption or loss. We have adopted de-identification and various encryption technologies when providing the Services, and will use these technologies (such as SSL) to encrypt and retain your personal data and isolate it with isolation technologies for the sake of protecting your personal data.

3. Handling of security incidents

Where a data security incident may occur or has unfortunately occurred, we will immediately take remedial measures in accordance with the relevant laws and regulations and promptly inform you of the following: the basic information and possible impact of the security incident, measures we have taken or will take to handle it, recommendations on what you can do to prevent and reduce risks, remedies available to you, etc. In addition, we will promptly notify you of the relevant information of the incident by email, letter, phone, push notification or otherwise. If it is difficult to give notice to the data subjects individually, we will publish announcements in a reasonable and effective way. We will also take the initiative to report our handling of the data security incident as required by the regulatory authorities.

4. Security notice

(1) You understand that due to technical limitations and various malicious means that may exist, we cannot guarantee 100% security of your information, even if we have done our utmost to intensity our security measures. You understand that the system and communications network you use to access our Services may have problems due to factors beyond our control.

(2) Please be sure to properly keep your account number, password and other identity information. When you use the Services provided by us, we will verify your identity through your account number, password and other identity information. Once you disclose any such information, you may suffer losses and be otherwise negatively affected. Once you find that your account number, password and/or other identity information may be or has been revealed, please contact us immediately so that we can take prompt measures to avoid or reduce the relevant losses.

IV. Your rights to manage your personal data

1. Right of access

You have the right to access the personal data you have provided to us (including avatar, nickname, player number, basic information of the guild, motto and rankings (if any)) according to the relevant instructions (or settings) of the Services we provide. If you have any problems when accessing, and intend to access other unavailable personal data described above, you may contact us through the contact information provided in this Privacy Policy.

2. Right to correct/modify

(1) When you find the personal data you provide is inaccurate, incomplete or update needed, you may correct/modify your personal data when using our products and/or Services. For some of your personal data, we provide you with operation settings on the relevant function pages of the product, and you can make correction/modification directly, for example: the “avatar/nickname/motto” shall be corrected/modified in the game client in the following way: click on the avatar - click the Edit button/the area corresponding to the content to be modified.

(2) If you have any difficulties in exercising the above rights, or if online correction/modification services are currently unavailable to you, you shall have the right to correct or amend the inaccurate or incomplete data, provided that your identity has been verified and the correction/modification will not affect the objectivity and accuracy of the data; or in certain circumstances, especially when the data is inaccurate, you have the right to request us to correct or modify your information by submitting a correction/modification request to us via our feedback/error reporting/customer service and other channels published by us, unless otherwise required by laws and regulations. However, for security and identification reasons, you may not be able to modify certain initial registration information submitted during registration.

3. Right to delete

You may directly request that we delete your personal data unless your Personal Data has been anonymized or required by laws and regulations, including when:

(1) our handling of your personal data violates any laws or regulations;

(2) we collect or use your personal data without your consent;

(3) our handling of your personal data violates the agreement with you;

(4) you delete your game account;

(5) we terminate the Services and operations.

If we decide to respond to your request for deletion, we will also notify the entities that have obtained your personal data from us and request their prompt deletion, unless otherwise required by the laws and regulations, or if these entities are independently authorized by you. When you delete your information from our service system, we may not delete the corresponding data from the backup system immediately, but will delete such data at the time when the backup is updated.

4. Right to revise the scope of authorization and consent

You may revoke (or cease) your authorization (such as device permissions) at any time after granting such authorization. After you update the app version, we will not change the status of your previously set permissions without your expressly consent. You may also permanently withdraw in full the authorization granted to us for collecting your personal data by delete your account. When the authorization is withdrawn, we will no longer be able to provide you with the corresponding Services, nor will we be able to handle your corresponding data. However, your decision to withdraw such authorization will not affect our previous handling of your data based on your authorization.

5. Right to delete your account

You may request to delete your account through the deletion function within our service system, or through our customer service staff ptnsupporten@ziyitech.net or other means we have publicized. Once you delete your account, you will no longer be able to use our Services with that account; and all rights and interests that have accrued but not consumed of the account during your use of all Services, as well as all future overdue benefits and other rights and interests will be erased; contents, information, data and records of the account will be deleted or anonymized (unless otherwise required by laws and regulations or regulatory authorities); once your game account is deleted, it cannot be restored. For more information on our process and conditions of deleting accounts, please contact our customer service.

6. Right to make copies

You have the right to request copies of your personal data by contacting us at any time via the contact information provided in this Privacy Policy.

7. Right to constrain the automated decision-making power of the information systems

In certain business functions, we may make decisions based only on non-human automated decision-making mechanisms, including information systems, algorithms, etc. If these decisions significantly affect your legitimate rights, you have the right to request an explanation and we will provide appropriate remedies.

9. How we respond to your requests for the rights above

We will respond to your requests as soon as possible within 15 working days while verifying your identity as a User. If you have any doubts when processing your personal data, you may contact us via the contact information provided in section VIII “Contact us” hereof. However, we will not be able to respond to your requests if we are prohibited by any writs of execution issued by administrative or judicial authorities in the territory where you use our products and Services.

V. Protection of minors

IF YOU ARE THE GUARDIAN OF A MINOR, ONCE YOU FIND THAT THE MINOR UNDER YOUR GUARDIANSHIP HAS USED OUR SERVICES AND SUBMITTED HIS/HER PERSONAL DATA, PLEASE INSTRUCT HIM/HER TO STOP USING OUR SERVICES IMMEDIATELY AND INFORM US PROMPTLY SO THAT WE CAN TAKE APPROPRIATE MEASURES ACCORDINGLY. IF YOU REQUEST TO ACCESS OR DELETE SUCH DATA, PLEASE REFER TO THE SECTION [IV. YOUR RIGHTS TO MANAGE YOUR PERSONAL DATA]. OUR CUSTOMER SERVICE MAY VERIFY AND CONFIRM YOUR RELATIONSHIP WITH THE MINOR TO THE EXTENT NECESSARY. AFTER SUCH CONFIRMATION, WE WILL ASSIST YOU IN DELETING SUCH DATA AND LOGGING OUT OF THE CORRESPONDING ACCOUNT.

VI. Updates

WE MAY UPDATE THIS POLICY FROM TIME TO TIME, AND SUCH MODIFICATIONS SHALL FORM A PART OF THIS PRIVACY POLICY. IF WE CHANGE ANY TERMS OF THIS PRIVACY POLICY, WE WILL PROVIDE APPROPRIATE NOTICE TO YOU VIA PAGE ALERTS, POP-UPS, ANNOUNCEMENTS, ETC. YOUR CONTINUED USE OF OUR PRODUCTS OR SERVICES MEANS THAT YOU ACCEPT THESE CHANGES.

VII. Contact us

1. We set up a dedicated department for personal information protection in compliance with this Policy. If you have any questions, comments or suggestions about this Policy, about our privacy measures or matters relating to your personal data, you may contact us in any of the following ways or send an email to dpo@ziyitech.net.

generally, we will respond to your questions, comments or suggestions within 15 working days while verifying your User identity, unless otherwise required by the laws and regulations of the territory where you use our products and Services.

VIII. Miscellaneous

1. This Privacy Policy applies to all our Services. In the event of any discrepancy between any personal data protection statements or rules and this Privacy Policy, the former shall prevail.

2. Except as otherwise provided in this Privacy Policy, the terms used herein shall have the same meanings as those defined in other publicly available clauses made by Ziyi Group.

3. The headings of this Policy are for convenience and reading purposes only, which do not affect the meaning or interpretation of any provisions in the text.

4. If any terms of this Privacy Policy is, for any reason, wholly or partly invalid or unenforceable, the remaining terms of this Privacy shall remain valid, binding and enforceable to you

SUPPLEMENTAL JURISDICTION-SPECIFIC TERMS

Some jurisdictions’ laws contain additional terms for users of the Game Services, which are set out in this section.

If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our privacy policy above.

Australia

Overseas Recipients

We take reasonable steps to ensure that third party recipients of your personal information located outside Australia handle your personal information in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at 【dpo@ziyitech.net】.

Correction

You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your Game account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at 【dpo@ziyitech.net】.

Children

If you are under the age of 17, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game.

Transacting Anonymously

Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the Game Services. You acknowledge that if you do not provide us with your personal information, we may be unable to provide you with access to certain features or sections of the Game Services, including social media integration and in-Game purchases.

Data Transfers

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.

California

This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).

Rights under the CCPA

If you are a California resident, you have the right to:

· Request we disclose to you free of charge the following information covering the 12 months preceding your request:

o the categories of personal information about you that we collected;

o the categories of sources from which the personal information was collected;

o the purpose for collecting personal information about you;

o the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and

o the specific pieces of personal information we collected about you;

· Request we delete personal information we collected from you, unless CCPA recognizes an exception; and

· Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.

We aim to fulfil all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may also exercise your rights, if any, regarding other data by contacting us at 【dpo@ziyitech.net】.

Canada

If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us at dpo【dpo@ziyitech.net】. Our privacy experts who monitor this email address are also able to answer any questions users may have about the collection, use, disclosure or storage of personal information by our service providers.

Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this privacy policy.

France

Your Rights

Instructions for the processing of your personal data after your death

You have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal data after your death.

The specific instructions are only valid for the processing activities mentioned therein and the processing of these instructions is subject to your specific consent.

You may amend or revoke your instructions at any time.

You may designate a person responsible for the implementation of your instructions. This person will be informed of your instructions in the event of your death, and be entitled to request their implementation from us. In the absence of designation or, unless otherwise provided for, in the event of the death of the designated person, their heirs will have the right to be informed of your instructions and to request their implementation from us.

When you wish to make such instructions, please contact us at dpo【dpo@ziyitech.net】.

Indonesia

Consent

By accepting and consenting to this privacy policy, you agree that we may collect, use and share your personal information in accordance with this privacy policy, as revised from time to time. If you do not agree to this privacy policy, you must not access or use our services and we have the right to not provide you with access to our services.

Parental and Guardian Consent

If you are under the age of 17, you undertake that you have the consent of your parent or legal guardian to register an account on the Game and use the Game Services.

Data Subject Rights

You have the right to access your personal information stored in our Game from time to time in accordance with applicable data privacy laws and regulations in Indonesia.

Data Breach

In the event we fail to maintain the confidentiality of your personal information in the Game, we will notify you through the contact information provided by you or via the Game, to the extent required by local laws and regulations.

Data Retention

We will retain your personal information in line with legal requirements.

Notification to Amendment of this Privacy Policy

If you fail to explicitly express your objection to any amended version of this privacy policy within fourteen (14) days of the date the relevant amended version of this privacy policy is made available, you will be considered as having accepted the changes and agreed to the new privacy policy. However, you may stop using or accessing our Service by unsubscribing or ceasing your use of the Game Services at any time, if you cease to agree with the amended privacy policy.

Data Accuracy and third Party Consent

You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

Malaysia

Parental and Guardian Consent

If you are under the age of 17, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game.

In the event you are agreeing to this privacy policy in order for a minor to access and use the Game Services, you hereby consent to the provision of personal information of the minor to be processed in accordance with this privacy policy and you personally accept and agree to be bound by the terms in this privacy policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor’s compliance with this privacy policy.

Your Rights

Right of access: You have the right to request access to and obtain a copy of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law.

When handling a data access request, we are permitted to request for certain information to verify the identity of the requestor to ensure that he/she is the person legally entitled to make the data access request.

Right of correction: You may request for the correction of your personal information. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requestor to ensure that he/she is the person legally entitled to make the data correction request.

Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details provided above. However this may affect our provision of the Game Services to you.

Contact

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

New Zealand

This section applies to users located in New Zealand:

Overseas Recipients

We take reasonable steps to ensure that third party recipients of your personal information located outside New Zealand handle your personal information in a manner that is consistent with New Zealand privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at 【dpo@ziyitech.net】.

Correction

You have the right to request the correction of any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at 【dpo@ziyitech.net】.

Children

If you are under the age of 17, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game.

Your Rights

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the New Zealand Privacy Commissioner (www.privacy.org.nz).

Data Transfers

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.

Philippines

Minimum Age

You must be at least 18 years of age to be able to use the Game Services.

Your Rights

You are entitled to the following rights:

· Right to be informed. You may in certain circumstances have the right to be informed whether personal data pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.

· Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for direct marketing, automated processing or profiling.

· Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.

· Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.

· Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.

Consent

By consenting to this Privacy Policy, you consent to us:

collecting and processing your personal information as described in the section “How We Use Your Personal Information” above;

sharing your personal information with third parties, companies within our corporate group, and a third party that acquires all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and transferring or storing your personal information in destinations outside the Philippines as described in the section “How We Store and Share Your Personal Information” above.

Singapore

By clicking the button to proceed, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, Indonesia, the People’s Republic of China and the United States.

Access

You have the right to access your personal information, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at 【dpo@ziyitech.net】.

Correction

You have the right to correct any of your personal information that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact 【dpo@ziyitech.net】.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted at【dpo@ziyitech.net】.

Thailand

By accepting this privacy policy, you acknowledge that you have read, understood, and agree to this privacy policy. If you do not agree with this privacy policy, you must not use the Game Services.

You may request us to discontinue, to restrict the use or provision of, and/or to request for data portability of any and all of your personal information which is stored by us, to the extent provided by the Act on the applicable data privacy laws and regulations in Thailand, including the Thai Personal Data Protection Act. When you wish to make such requests, please contact us at【dpo@ziyitech.net】.

We will give you notice of any material changes to this privacy policy, and give you an opportunity to reject such changes, failing which the changes will become effective as stated in the notice.

By accepting this Privacy Policy, you expressly authorize us to collect, use, store, and process your personal data, including disclosing to third parties and transferring to countries other than Thailand, to the extent and for the purpose provided by this Privacy Policy.