Personal Data and Privacy Protection Policy

Update Date: [September 22, 2022]

Effective Date: [September 22, 2022]


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.

Please be aware that we will not take the initiative to collect the personal data of users/minors under the age of 17 (subject to change if different from the age of majority stipulated by the laws of your country/region). 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 information, please cause him/her to cease the use of our Services immediately and notify us of the same in a timely manner so that we can take appropriate measures accordingly.

We also provide warnings in the Annex to this Policy in accordance with the personal data protection requirements of different countries/regions. If your country/region is listed in the Annex, please read the relevant regulations carefully.

This Personal Data and Privacy Protection Policy (hereinafter referred to as this “Privacy Policy”) is signed by and between you (hereinafter referred to as the “User”) and Ziyi Group HK Limited (also hereinafter referred to as “Ziyi Group” or “we/us/our”), having its registered address at SUITE 603, 6/F LAWS COM PLAZA 788 CHEUNG SHA WAN RD. This Privacy Policy is intended to take effect as a contract.

Table of Contents of this Personal Data and Privacy Protection Policy

Introduction

I. How we collect and use your personal data

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

III. How we store and protect your personal data

IV. Your right to manage your personal data

V. Protection of minors

VI. Amendment to this Privacy Policy

VII. Contact us

VIII. Miscellaneous

Introduction

Before using the Services provided by Ziyi Group, please be sure to carefully read and thoroughly understand this Privacy Policy, in particular the clauses marked in bold/marked in bold and with an underline, which you should pay special attention to and understand thoroughly and agree with before using the Services. If you disagree with the content of this Privacy Policy, we may be rendered unable to provide our Services normally or to achieve the service effectiveness intended by us, and you shall stop accessing/using our Services immediately. We want to remind you that due to the variety of our game products and services, the Services provided to you have varying contents and different core business functions (including the types of your personal data to be collected), which will be well suited for the products and Services actually provided.

After reading this Privacy Policy, if you have any queries about this Privacy Policy or other relevant matters, you may contact us through the feedback channels set forth in the “Contact us” section hereof, and we will respond as soon as possible.

I. How we collect and use your information

1. Information provided by you voluntarily

(1) In order for us to provide you with continuous and stable services and to guarantee the security of your use of our Services, you shall furnish to us the basic registration or login information (including mobile phone number and email address) and create your account, user name and password. In accordance with the relevant laws and regulations and the regulatory requirements, when you register a game account, the information furnished by you will be used to ascertain your age and provide you with better services. If you do not provide such real identity information or have provided us with false information, you will be unable to use our products and the related Services or be subject to corresponding restrictions in the process of using the Services. For the purpose of real-name authentication, you agree that we may, and authorize us to, make available to, seek from, and verify with the competent authorities of online games, public security organs or other agencies commissioned by or cooperating with them in your country/region your aforementioned identity information. 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), 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 as the unique identifier, account name, nickname, personal avatar, personal status, and list of friends to store your login information, so that you can log in to our system through different devices. 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) The information 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. Your failure to participate in the above activities/questionnaire surveys or to provide the above information to our customer service staff will not affect your access to other Services.

2. Information on your usage lawfully obtained by us in the process of providing services to you

(1) During your use of our online game services, in order to allow you 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, cyber attacks and network intrusions, and more accurately identify any violations of laws and regulations, we may collect and store information on the Services you use and the device or software used by you to access the Services, 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.

(2) During your use of our online game services, we may collect your game logs information, including 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 purposes 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 used by you.

(3) When you use the consumption services provided by Ziyi Group, in order to enable you to complete payment and top-up, show you the transaction information of your account and ensure transaction security, we will collect your top-up records and consumption records in case you request your transaction records, and we will do our utmost to protect your virtual items safe. Top-up records and consumption records are both important personal data. 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 use our Services to 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 gaming environment and ensure a safe environment for internet users.

Please note that the information you publish may contain your personal data or important personal data, which may be collected and used by others. Please consider carefully before publishing any such information. Even if it has been deleted by you, such information may still be saved in cache, copied or stored independently by other users or third parties 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 publishing the same. 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 “Contact us” section hereof.

(5) In order to 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 for use in contacting you or helping you solve problems in the future, or may record the solutions and handling results of the relevant problems.

(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 the information involved in such permissions. Before enabling such permissions, we will inform you of the purposes of such enabling and seek your consent. 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 refuse to provide the said permissions and contents, you will be unable to use these functions/Services, but this will not affect 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 have authorized us to collect and use the relevant information to provide you with the corresponding Services. By disabling any permission, you have withdrawn 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 (the ID, serial number, manufacturer, 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 prevent cheating).

4. We may send information to you

(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 issue Services-related announcements to you when necessary (for example, when a given service will be suspended due to system maintenance). You may not be able to opt out from these Services-related announcements which are not of advertising nature.

5. Exceptions to the authorization and consent requirement

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

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

1. Sharing

(1) We attach great importance to the protection of your personal data, and we will 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 by implementing any other relevant confidentiality and security measures.

(2) In order to achieve the purposes stated herein, we may cooperate with third parties by accessing the SDKs or other similar applications provided by third-party service providers (such as in the form of embed code, plug-in, H5, etc.), so as 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 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, 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. The collection and processing of information and other activities by third-party SDKs or other similar applications shall be in accordance with their own privacy regulations or other relevant statements. We recommend that you read their privacy regulations before using any third-party services. In order to protect your legitimate rights and interests, if you find that any risks exist in any relevant third-party services, you are advised to immediately cease the relevant operations and contact us promptly. Please refer to Ziyi Group’s list of information shared with third parties for the information currently being shared by us:

No.Name of SDKName of Third PartyPurposes of UseName of Information SharedMethod of ProcessingLink
1GoogleSDKGoogle, Inc.Used for account login, payment, and data monitoringidentifiers (IMEI, GAID, Android ID), browser type and settings, device type and settings, operating system, mobile network information, application version number, IP address, crash reports, system activities, and the dates, times, source sites and cookies of the corresponding requestsDe-identified and encrypted before transmission and processinghttps://policies.google.com/privacy#infocollect
2iOSSDKApple,Inc.Used for account login and paymentAccount information (email address, device used for registration, account status and age), unique device identifiers (device serial number, browser type), contact information, payment information, transaction information, browsing history, crash dataDe-identified and encrypted before transmission and processinghttps://www.apple.com/legal/privacy/en-ww/
3twitterSDKTwitter, Inc.Used for account login and sharingIP address, browser type, device ID, advertising ID, operating system, operator, language, memory, apps installed and battery level, logs information, cookiesDe-identified and encrypted before transmission and processinghttps://twitter.com/en/privacy#twitter-privacy-9.1
4FacebookSDKMeta Platforms, Inc.Used for account login and sharingUnique device identifiers (device number, mobile advertising client number, or identifiers provided by the game you play or the app or account you use), device type, details about its operating system, details about its hardware and software, battery level, signal strength, available storage space, browser type, names and types of apps and files, IP address, cookiesDe-identified and encrypted before transmission and processinghttps://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0
5AihelpSDKShareFun Network LimitedUsed for provision of intelligent customer servicesPlatform, language, SDK version, area code, operator, network, device model, available storage space, total storage space, OS version, application information, server ID, custom fieldsDe-identified and encrypted before transmission and processinghttps://aihelp.net/privacypolicy/
6appsflyer SDKAppsFlyer Inc.Used for ads releasing and data monitoringNetworking information, MAC address, unique device identifiers (IMEI, IDFA, Android ID, hardware serial number of the device), advertising logo, operator informationDe-identified and encrypted before transmission and processinghttps://www.appsflyer.com/legal/privacy-policy/
7unity3DUnity Software (Shanghai) Co., Ltd.Used for provision of game engine servicesIMEI, IP address, unique device identifiers (IDFV\IDFA\Android ID\ hardware serial number of the device), operating environment of the device and other information about software featuresDe-identified and encrypted before transmission and processinghttps://unity.cn/legal/privacy-policy
8SDK ANO anti-cheat SDK used to ensure gaming securityAceville Pte LtdUsed for protection against mainstream general-purpose plug-insGame account, device model, system version, device brand, CPU architecture, device name, frequency, Rooted or not, system startup time, country code and language, information about periodically obtained and installed APKs, host files, key system library files, target feature files of the SD card, app bundle name, app version number, periodically obtained running process information, startup time, in-game scenes, connected to VPN or notDe-identified and encrypted before transmission and processinghttps://www.anticheatexpert.com/#/doc-center/8fc4c1195346a2c74e472881bca42c4010698921

(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. to the extent necessary for achieving such purposes as set out in the “How we collect and use your personal data” section;

iii. for the purpose of performing our obligations and exercising our rights under this Privacy Policy or other agreements between you and Ziyi Group;

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

v. as otherwise requested by you or your guardian according to law;

vi. as otherwise required by the laws and regulations or requested by the competent authorities.

2. Transfer

We will transfer your personal data only under the following circumstances:

(1) with your explicit consent;

(2) if required by the laws and regulations or requested by the competent authorities;

(3) As our business continues to grow, we and our affiliates may engage in mergers, acquisitions, asset transfers or other similar transactions, in which case your personal data may be transferred as part of such transactions. We will inform you of the case by push notification, announcement or otherwise, and continue to protect, or require the new managers to continue to protect, your personal data in accordance with the relevant laws and regulations and standards not lower than those required hereunder.

3. Public disclosure

We will publicly disclose your personal data only:

(1) with your explicit consent;

(2) if required by the laws and regulations or requested by the competent authorities.

4. Cases in which your prior consent is not required

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

(2) You acknowledge and agree that we may de-identify the information we have collected and use it for optimizing the gaming performance and 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) Unless otherwise provided by the laws and regulations or required by the regulatory authorities in the territory where you use our products and Services, and except to the extent reasonably necessary for safeguarding the social and public interest or protecting the lives and property or legitimate rights and interests of our customers, us or our group companies, other users or employees, we will store your personal data only for the shortest necessary period of time for such purposes as stated herein. Our group companies conduct operations all over the world. In accordance with the User Agreement we have signed with you, your personal data will be processed on servers that may be located outside your place of residence. Regardless of where the servers are located, we will take appropriate steps to protect your rights in accordance with this Privacy Policy. The servers used for this service are located at:

Frankfurt, Germany

Singapore

California, United States

Your data collected by us or shared 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, our support team, engineering team and other teams around the world (including in Singapore) may access your information from outside your place of residence.

(2) If we terminate the Services or operations, we will cease the collection of your personal data promptly, and will give prior notice to you as required by the relevant laws and regulations, and delete or anonymize your personal data after such termination, except as otherwise provided by the relevant laws and regulations or required by the regulatory authorities.

(3) If you request deletion of your account or voluntarily delete your personal data, or if your personal data has been stored for a period of time longer than necessary, we will delete or anonymize your personal data, unless a certain retention period has been provided by the laws and regulations.

(4) If the information we have collected needs to be transferred across borders, we will ensure such transfer is in accordance with the national laws and regulations and the requirements of the relevant regulatory authorities in the territory from which the information originally comes and provide adequate protection for your personal data.

2. Protection of personal data

(1) We will take security measures conforming to industry standards, including establishing reasonable rules and specifications and employing reasonable security technologies, to prevent unauthorized access, use and modification of your personal data and avoid data corruption or loss. We have adopted de-identification and various encryption technologies in the process of provision of 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 incidentsa

(1) 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 one by one, 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) Please understand that due to technical limitations and various malicious means that may exist, even if we have done our utmost to intensity our security measures, we cannot always keep your data 100% secure. You should 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 have disclosed 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 leaked, please contact us immediately so that we can take appropriate measures in a timely manner to avoid or reduce the losses caused.

IV. Your right to manage your personal data

1. Right of access

You may access the personal data you have provided to us (including avatar, nickname, player number, basic information of the guild, personal status and rankings (if any)) according to the relevant instructions (or settings) of the products and Services we provide. If you encounter any problems during such access attempt and need to access other personal data which is unobtainable in such way as stated above, you may contact us using the contact information provided in this Privacy Policy.

2. Right to correct/amend

(1) When you find that the personal data you have provided to us is inaccurate or incomplete or needs to be updated, you may correct/amend your personal data when using our products and/or Services. For some of your personal data, we have provided you with operation settings on the relevant function pages of the product, and you can make correction/amendment directly, for example: the “avatar/nickname/personal status” shall be corrected/amended in the game client in the following way: click on the avatar - click the Edit button/the area corresponding to the content to be amended.

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

3. Right to delete

You may directly request us to delete your personal information, except when it has been anonymized or otherwise required by law or regulation, when.:

(1) we have handled your personal data in violation of any laws or regulations;

(2) we have collected or used your personal data without your consent;

(3) we have handled your personal data in violation of the agreement with you;

(4) you have logged out of your game account;

(5) we have terminated 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 require them to delete the same in a timely manner, save as otherwise required by the laws and regulations, or unless these entities have otherwise obtained permission from you. When you delete your data 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 permission status previously set by you without your explicit consent. You may also permanently withdraw in full the authorization granted to us for collecting your personal data by deleting your account. When the authorization is withdrawn, we will not be able to continue providing you with the Services corresponding to the portion of authorization withdrawn, 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 delete your account through the deletion function provided inside our service system, our customer service staff or other means we have publicized. Once you have deleted your account, you will no longer be able to use our products and Services by logging in to the account; and all rights and interests that have accrued under the account during your use of all products and Services but remain outstanding, all future overdue benefits and other rights and interests will be eliminated; the contents, information, data and records under the account will be deleted or anonymized (unless otherwise provided by the laws and regulations or save as otherwise required by the regulatory authorities); once your game account is deleted, it cannot be restored. For more details about the Ziyi Group’s account deletion process, conditions and other matters, please refer to the Game Account Deletion Agreement or consult with our customer service staff.

6. Right to make copies

You have the right to request copies of your personal data by contacting us at any time with the contact information provided in this Privacy Policy, and we will respond to your request within 15 working days.

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 and rights, you have the right to request explanation from us and we will provide appropriate remedies.

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

We will respond to your requests as soon as possible within 15 working days of verifying your identity as a user. If you have any doubts about our handling of your personal data, you may communicate with us using the contact information provided in Article VII “Contact us” hereof. However, we will not be able to respond to your requests if the responding thereto is prohibited by any writs of execution issued by the 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 cause him/her to cease the use of our Services immediately and notify us of the same in a timely manner so that we can take appropriate measures accordingly. If you request access to or deletion of such data, please refer to the provisions of [IV. Your right to manage personal data]. Our customer service staff 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. Amendment to this Privacy Policy

We may amend the terms hereof from time to time, and such amendments shall form a part of this Privacy Policy. In the event of any changes to the terms hereof, we will notify you of such changes by page alert, pop-up, announcement and other appropriate means after the current version is updated. By using or continuing to use our products or Services, you agree that we will handle your relevant data in accordance with this or the updated Privacy Policy.

VII. Contact us

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

(1) Under general circumstances, we will respond to your queries, comments or suggestions within 15 working days of verifying your identity as a user, save as otherwise provided 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 in relation to a particular service and this Privacy Policy, the former shall apply.

2. Unless otherwise provided in this Privacy Policy, the terms used herein shall have the same meanings ascribed to them in other publicly available clauses made by Ziyi Group.

3. The headings contained herein are inserted for convenience of reference only, and do not affect the meaning or interpretation of any provisions of the main body.

4. If any provision of this Privacy Policy becomes wholly or partly invalid or unenforceable for any reason, the remaining provisions hereof shall remain valid, binding and enforceable.

5. Any controversies or disputes arising out of (and/or in connection with) this Privacy Policy between you and Ziyi Group shall first be resolved through friendly negotiation; if the negotiation efforts fail, any disputes, controversies, differences or claims arising out of or in connection with this Privacy Policy, including the existence, validity, interpretation, performance, breach or termination hereof, or any non-contractual disputes arising out of or in connection with this Privacy Policy, shall be referred to and finally resolved by arbitration administered by the Hong Kong International Arbitration Center (HKIAC) in accordance with the HKIAC Administered Arbitration Rules in force at the time of submission of the notice of arbitration. This arbitration clause shall be governed by the laws of Hong Kong, and the seat of arbitration shall be Hong Kong, China. The number of arbitrator(s) shall be three (one or three). The arbitral proceedings shall be conducted in [English].


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.h

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.

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.