Privacy Policy

Last Updated: 8 May 2024

Higgs Studio (“we”, “us”, “our”) fully respects and is committed to protecting the right to privacy of our users (“users”, “user”, “you”) who visit our websites, access or use our games whether played on mobile devices, personal computers, our websites or any other applicable platforms and/or devices (“our Games”), and access or use any services offered by us, including but not limited to technology services, customer support, competitive gaming activities, marketing and advertising (collectively, “our Services”).

This Privacy Policy (“Policy”) is provided to help you understand our practices related to the collection, use, storage, and disclosure of information we collect from or about you when you interact with us, your rights regarding the information provided to us, and how we transfer and secure such information.

Please make sure to read this Policy carefully to understand our practices regarding your Personal Data (as defined below) and access it frequently to understand the updates to this Policy.  By downloading, accessing, using and/or interacting with our Services, you agree and expressly consent to our collection, use and disclosure of the information that you provide as described in this Privacy Policy. This Privacy Policy is incorporated by reference into the Terms of Service available at【https://higgsweb.com/eula.html】(our “Terms of Service”) is subject to the provisions of the Terms of Service. If you have any concerns about providing information to us or the use of that information as described in this Policy you should not use our Services.

If we update this Policy, we will notify you by announcements in our Games to let you know about the changes we made and obtain your consent again. By accessing or using our Services after we have placed such a notice, you are deemed to have accepted the updated Policy. You can see when this policy was last updated by checking the “last updated” date displayed at the top of this policy. If we are required by applicable data protection laws to give you enhanced notice or seek your consent for any such changes, we will do so. Any revised Policy will supersede all previous privacy policies.

This Privacy Policy will help you understand the following contents:

I. Important Definitions

II. Data We Collect and Use

III. Promotional Communications

IV. How and Why We Use Your Personal Data

V. How We Store and Protect Your Data

VI. How We Share, Transfer and Disclose Your Data

VII. How Your Data Is Transferred Across Borders

VIII. How We Handle the Data of Children

IX. Your Data Protection Rights

X.  How To Exercise Your Rights

XI. Cookies and Similar Technologies

XII. Third-Party Service Providers and Services

XIII. How to Contact Us

XIV. Extra Help

XV. Jurisdiction Specific Supplemental Terms

XVI. Game Account Deletion Terms

I. Important Definitions

· “Personal Data” means any information that relates to a living individual directly or indirectly and can be used to identify a living individual, in particular by reference to an identifier, location, or factors specific to the physical, physiological, genetic, economic, cultural or social identity.

· “Usage Data” means data collected automatically either generated by the use of the Service or from the Service infrastructure itself.

· “Cookies” are small data files stored on your hard drive or in device memory that helps us to improve our Services and your experience and see which areas and features of our Services are popular and count visits.

· “Data Controller” means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Data is, or will be, processed. For the purpose of this Policy, we are a Data Controller of your data.

· “Data Subject” is any living individual who is the subject of Personal Data.

II. Data We Collect and Use

1. Overviews

For your better experience in our Services, we may require you to provide us with certain Personal Data while using our Services.

We may collect your Personal Data in the following ways: 1) information you directly provide to us (such as your nickname, profile picture and phone number you provide to us when you register or login to your account); 2) information we obtain automatically during your use of our Services (such as Device Information and Usage Data); or 3) information we obtain from other sources.

We will collect and use your Personal Data only for the purposes described in this Policy. The following describes your Personal Data that we collect and how we use it.

2. Data Collection and Purposes

We may collect some or all of the following information about you when you use our Services for legitimate interests.

III. Promotional Communications

We may use your Personal Data to send you updates about our Services, including exclusive offers, promotions, or new services. We have a legitimate interest in processing your Personal Data for promotional purposes. This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly. We will always treat your Personal Data with the utmost respect and never sell it to other organizations for marketing purposes.

You have the right to opt-out of receiving promotional communications at any time by:

· Contacting us (see “How to Contact Us” below); or

· Using the “unsubscribe” link in emails or “STOP” number in texts.

We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, applicable regulations, or structure of our business.

IV. How and Why We Use Your Personal Data

Under data protection law, we can only use your Personal Data if we have a proper reason for doing so, e.g.:

· To comply with our legal and regulatory obligations;

· For the performance of our contract with you or to take steps at your request before entering into a contract;

· For our legitimate interests or those of a third party; or

· Where you have given consent.

A legitimate interest is when we have a business or commercial reason to use your Personal Data, so long as this is not overridden by your own rights and interests.

We may use your Personal Data for:  

· Providing Services to you for the performance of our contract with you or to take steps at your request before entering into a contract;

· Preventing and detecting fraud against you for our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you;

· Conducting checks to identify our customers and verify their indent to comply with our legal and regulatory obligations;

· Ensuring the confidentiality of commercially sensitive information for our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information, and to comply with our legal and regulatory obligations;

· Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you;

· Preventing unauthorized access and modifications to systems for our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you, and to comply with our legal and regulatory obligations;

· Updating and enhancing customer records for the performance of our contract with you or to take steps at your request before entering into a contract, to comply with our legal and regulatory obligations and for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products; and

· Marketing our Services and those of selected third parties to (i) existing and former customers; (ii) third parties who have previously expressed an interest in our Services; and third-parties with whom we have had no previous dealings for our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers.

We do not use your Personal Data for any automated decision making purposes.

V. How We Store and Protect Your Personal Data

Personal Data may be held at our offices and those of our third-party service providers or representatives and agents (see “How We Share, Transfer, and Disclose Your Data” below). Your data collected by us will be stored in accordance with the laws and regulations on the personal privacy data protection of the countries concerned. You acknowledge and agree that, to the extent not prohibited by local laws and regulations, your data will be processed on our servers which may not be located in your country of residence and can be accessed by our support, engineering and/or our affiliates around the world. Your information we collect may be stored and processed for the purposes set out in this Privacy Policy in Hong Kong, Singapore or any other country in which the Company, its subsidiaries, or third party agents operate. No matter where our servers are located, we will make great efforts to take the appropriate safeguards to guarantee your rights in conformity with this Policy and any applicable laws.

We will keep your Personal Data while you have an account with us or while we are providing you services. Thereafter, we will keep your Personal Data for so long as is necessary to:

· Respond to any questions, complaints or claims made by you or on your behalf;

· Show that we treated you fairly; or

· To keep records required by law.

· We will not retain your Personal Data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of Personal Data:

- Login information - Stored for so long as needed to provide our Services or we are required by law..

- Account information – Stored for so long as needed to provide our Services or we are required by law.

- Payment information – Stored for so long as needed to provide our Services or we are required by law.

- Information submitted to our support team – Stored for so long as needed to provide our Services or we are required by law.

- Advertising information – Stored for so long as needed to provide our Services or we are required by law.

- Automatically collected information – Stored for so long as needed to provide our Services or we are required by law.

- Survey information – Stored for so long as needed to provide our Services or we are required by law.  

- Other information – Stored for so long as needed to provide our Services or we are required by law.  

If your account is canceled or terminated pursuant to the Terms of Service, we will delete or anonymize your Personal Data.

The security of your Personal Data is important to us and we implement security safeguards designed to protect your Personal Data and regularly monitor our systems for possible vulnerabilities and attack. We are constantly working to improve on these safeguards to keep your Personal Data secure.

However, we need to remind you that that no method of transmission over the internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

VI. How We Share, Transfer and Disclose Your Personal Data

When sharing, transferring, and disclosing your Personal Data, we uphold the principles and requirements of minimization, necessity, and legality. Except as described below, we do not share, transfer or disclose your Personal Data externally:

1. How We Share Your Personal Data

WE DO NOT SELL ANY PERSONAL DATA TO THIRD PARTIES. We will share your Personal Data with only where necessary. Situations where this occurs are:

· Third parties that provide services in support of the Services, including providers of cloud and network services that process or back up information identified in this Policy on their servers for the purpose of providing the Services, for the purpose of user authentication, for the purpose of processing customer support and support communication, for the purpose of analysing crashes and improving service performance, for the purpose of providing marketing and advertisements and monitoring the success of our marketing and advertising programs, for the purpose of providing you with updates and information regarding the Services, for the purpose of providing translations, for the purpose of detecting whether user-generated content violates applicable laws, our terms or community rules, for the purpose of payment processing services (including security and fraud detection) and for the purpose of informing and improving the refund process if you request a refund. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services in support of the Services.

· Companies within our corporate group who process your personal information in order to operate the Services. All related group companies may only use your personal information in accordance with this Policy.

We only allow our service providers to handle your Personal Data if we are satisfied they take appropriate measures to protect your Personal Data. We also impose contractual obligations on service providers to ensure they can only use your Personal Data to provide services to us and you. Your Personal Data received by these third party service providers may be subject to their respective privacy policies or notices, and this Policy does not apply to any products, services, websites or content that are offered by third parties. We are not responsible for the third-party service provider’s collection, use and/or processing of your Personal Data.

2. How We Transfer Your Personal Data

We will not transfer your data to any other parties, except in the following circumstances:

· Where we have obtained your explicit consent.

· If we are involved in a merger, acquisition or sale of all or part of our assets, which may affect your Personal Data, we will issue a prominent notice via email and/or on our website or other appropriate methods to inform you of any changes in the ownership and your rights of your Personal Data, and any choices you may have about your Personal Data.

· Where we have explained we will transfer Personal Data to third parties in this Policy or have notified you by other means.

3. How We Disclose Your Personal Data

We may need to disclose data about you when required by law, subpoena, or other legal process or if we have a good faith belief that the disclosure is reasonably necessary to (1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services; or (5) exercise or protect the rights and safety of our Services, our users, personnel or others. We attempt to notify users about legal demands for their Personal Data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

Additionally, we may share your data with:

· Our attorneys, lawyers, accountants, auditors, or similar consultants when we request them to provide professional advice.

· Investors and other relevant third parties, if actual or potential sales or other company transactions occur and are related to entities within our group.

· Other third parties, for example, the disclosure of specific information with your authorization.

VII. How Your Data Is Transferred Across Borders

For the purposes described in this Policy, and to the extent permitted by applicable local laws and regulations and with your authorized consent, we may transfer your Personal Data to our servers stipulated in Section V (How We Store and Protect Your Personal Date) of this Policy for storage or processing, we may also transfer your Personal Data to third-party service providers and business partners and your data may therefore also be transmitted to other countries or regions.

In the circumstance that we transfer Personal Data outside of your jurisdiction, whether it is transferred to our affiliates or third-party service providers, we will comply with relevant applicable laws. We will take appropriate security measures and safeguards to make sure that all such transfers meet the requirements of applicable local data protection laws.

VIII. How We Handle the Data of Children

Our Services are not intended for children under the age of thirteen (13) or the minimum age in the relevant territory if that age is older than thirteen (13) (the “Child” or “Children”), and we do not knowingly collect any personal information from such Children. Children should not use or attempt to use our Services, and if you are a Child, please do not attempt to use our Services or send any information about yourself to the Company.

In the event that we learn that we have inadvertently gathered personal information from a Child, we will take reasonable measures to delete such information from our records. Parents who believe that we might have gathered any information from or about a Child may submit a request to delete such information to our email address listed in Section XIII (How to Contact Us) below.

IX. Your Data Protection Rights

You have specific rights regarding your personal information, which are described in this Section. You or an authorized agent acting on your behalf may exercise your personal information rights by submitting a verifiable request or through our platform (see “How To Exercise Your Rights” below). If an authorized agent submits a request to know or delete your personal information, we require you to:

· Provide your authorized agent with signed permission to exercise your rights and choices;

· Verify your identity directly with us; and

· Directly confirm with us your authorized agent has permission to submit the request.

You have the following data protection rights:

· The right to access or delete the data we have on you. You have the right to access your Personal Data that we hold about you. If you request a copy of your Personal Data, we will provide you a copy in an electronic format after passing our verification process. Subject to certain exceptions permitted by applicable law, on receipt of a verifiable request we will delete your Personal Data from our records and direct our service providers, contractors or other third party affiliates to delete your Personal Data from their records unless they have obtained your separate consent for processing. However, if you choose to delete any of your Personal Data, some features that require such data may no longer be available, and you acknowledge and agree that we may retain your Personal Data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

   For more instructions on how to proceed the deletion of your information, please refer to Section XVI “Game Account Deletion Terms” in the last part of this policy.

· The right to rectify. If you consider that Personal Data we hold about you is inaccurate or incomplete, you have the right to obtain rectification of your Personal Data without undue delay.

· The right to object and restrict. You have the right to object to our processing of your Personal Data (e.g., at any time to your Personal Data being processed for direct marketing) or request that we restrict the processing of your Personal Data. You can ask us to stop using all or some of your Personal Data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your Personal Data is inaccurate or unlawfully held).

· The right to data portability. You have the right to be provided with a copy of the data we have on you in a structured, machine-readable and commonly used format.

· The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your Personal Data. You can withdraw your consent previously granted to us for a specific purpose by deleting data, turning off device features, and requesting to withdraw consent by contacting us (see “How to Contact Us” below), including the collection, use and/or disclosure of your Personal Data that we manage or control. If you withdraw your consent, you may not be able to continue receiving the part and/or full benefit of our Services. The withdrawal of your consent or authorization will not affect the validity of our previous processing activities based on your consent.

· Right to control your privacy settings. You have the right to control your privacy settings and restrict our collection, use, disclosure, or processing of your Personal Data via such privacy settings. For example, you can choose to turn on or turn off the permissions of “Location Access” or “Storage”; you can obtain detailed data regarding the device security status or change such status in “Privacy Settings” on your device.

· Right to close your account. You can close your account via instructions in our Services or contact us for help. Please understand that for security reasons, your account cannot be closed unless you follow our instructions. We hereby kindly remind you that, if you wish to close your account, such closure may prevent you from using our Services, and such closure is irreversible. Once you close your account, we will delete or de-identification your relevant data. If you sign into the accounts through a third-party account (e.g., via Apple ID, Facebook, Google ID), you need to apply for account closure from such third party.

According to the applicable laws of some jurisdictions, you may have other data subject’s rights. Please refer to Jurisdiction Specific Supplemental Terms at the end of this Policy.

X. How To Exercise Your Rights

To easily access, view, update, correct, delete or port your Personal Data, or to update your subscription preferences, please sign into your account and visit “Account Settings” or contact our customer service. Where we rely on consent to collect and use information about you, you can withdraw your consent at any time. If you make a request to delete your Personal Data and that data is necessary for the Services you have purchased, the request will be honored only to the extent it is no longer necessary for any Services purchased or required for our legitimate business purposes or legal or contractual record keeping requirements.

Some jurisdictions’ laws contain additional terms for users of the Service, 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.

To exercise the access, data portability, correction, and deletion rights described above please submit a verifiable request to us by emailing us at higgsgamesgl@gmail.com.

Only you, or a person authorized by law to act on your behalf, may make a verifiable request related to your Personal Data. You may also make a verifiable request on behalf of your minor child.

You may only make a verifiable request for access or data portability twice within a twelve (12) month period. The verifiable request must:

·Provide sufficient information (including your account name, passwords, email address and other information reasonable requested by the Company) that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized agent;

·Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you.

If your account is lost, you can verify through SMS, email or contact customer service to reset your password. However, in this process, you need to provide some Personal Data to verify your identity. When retrieving your password, we may need you to provide frequent login location, frequent login device, frequent listening content, registration time and city information.

Making a verifiable request does not require you to create an account with us. We will only use Personal Data provided in a verifiable request to verify the requestor’s identity or authority to make the request.

We endeavour to respond to any verifiable request within one (1) month of its receipt. If we require more time, we will inform you of the reason and extension period required in writing. We will send you confirmation of receipt of any verifiable request within ten

(10) business days of its receipt.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by the method you submitted your request.

If we cannot comply with a verifiable request, we will explain our reasons to you in writing, if applicable. For data portability requests, we will select a format to provide your Personal Data that is readily usable and should allow you to transmit the information from one entity to another without hindrance.

Typically, you will not have to pay a fee to access your Personal Data or to exercise any of your privacy rights. However, except in relation to consent withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing the request. We may also refuse to comply with your request in such circumstances.

We may decline to comply with your request under the following circumstances, and in accordance with applicable laws and regulations:

· Where it is related to our obligations under law and/or regulation;

· Where it is related to national security and national defense security;

· Where it is related to public safety, public health and major public interests;

· Where it is related to criminal investigation, prosecution, and trial;

· Where there is sufficient evidence to show that you have subjective malice or abuse of rights;

· Where responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals and organizations;

· Where trade secrets are involved;

· Other conditions stipulated by laws and regulations.

XI. Cookies and Similar Technologies

Cookies are small text files to ensure that our software’s normal operation and your convenient access to it. Cookies usually contain identifiers, site names, and some numbers and characters. We may use Cookies and other similar technologies such as Pixel Tags and Web Beacons. We generally treat information collected by Cookies and similar technologies as non-Personal Data as they do not contain any of your personally identifiable information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered Personal Data by the laws of the countries concerned, we will also follow the laws of the countries concerned.

We and our partners may use cookies and similar technologies (e.g., pixels and ad tags) to collect data (e.g., device IDs) to recognize you and your device(s) on, off and across different services and devices where you have engaged with our Services. You can manage or delete Cookies according to your preferences.

Because consumers are often unaware that their do not track beacons are active, Do Not Track signals frequently do not reflect the actual preferences of our users. We do not respond to Do Not Track signals. In the meantime, you may opt out of certain types of tracking, including certain analytics and tailored advertising by changing your cookie settings.

XII. Third-Party Service Providers and Services

You may receive links to third-party websites or content and services provided by third parties other than us during your use of our Services, and some third parties’ products or services can be accessed in the form of SDKs and others in order to provide you with some functions and features, such as to provide you with third party logins, notifications and user analysis (collectively, the “Third-Party Services”).  

You can choose whether to visit or accept such Third-Party Services at your sole discretion., and we encourage you to read and review the privacy statements of each Third-Party Service that you may choose to use.

XIII. How to Contact Us

For the purpose of establishing the Personal Data protection in a better and more efficient way, we, as the Data Controller, designate a Data Protection Officer (in short, “DPO”) who is responsible for the oversight and implementation of the Personal Data protection strategy and ensures our processing of Personal Data is in compliance with necessary legal requirements stipulated in the applicable laws. If you have any comments, questions or concerns with respect to our Privacy Policy or Personal Data protection practices, please contact our DPO Stevie at higgsgamesgl@gmail.com (All requests must be labeled “Privacy Policy request” on the email subject line for us to better assist you).

We will review your privacy or Personal Data requests and respond to you as soon as possible after verifying your user identity. If your request itself involves any complicated or significant issue, we may ask you for more information.

XIV. Extra Help

If you would like this Policy in another format (for example: audio, large print, braille) please contact us (see “How to Contact Us” above).

XV. Jurisdiction Specific Supplemental Terms

Some jurisdictions’ laws contain additional terms for users of the Service, 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. In case of any conflict between the following supplemental terms and the provisions of general terms above, those following terms will take precedence over the general terms of this policy.

Indonesia

If  you are using our Services in Indonesia, the following terms apply：

1. Age, Parental and Guardian Consent. By using the Services, you represent that you are at least 21 years of age or married or not  under guardianship. If you are below 21 years old and you are not married, or under guardianship:

  1. You must obtain approval from your parent(s) or legal guardian(s); and

  2. Your parent(s) or legal guardian(s) are responsible for: (i) all your  actions in connection with your access to and use of the Services; (ii)  your compliance with this Policy; and (iii) ensuring that any of your  participation in Services will not, in any event, result in any  violation of applicable laws and regulations relating to child  protections.

  If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or guardian(s) is not willing to open the account under  their name, you must cease accessing the Services.

2. Your Choices. You may withdraw your consent to 【 】’s disclosure of  personal data to third parties. Upon your request, we will cease to display, publish, transmit, disseminate, and/or open the access to your  personal data to third parties. Please note that by withdrawing your consent to the disclosure and/or collection of your personal data, we  may not be able to fulfill your requests and you may not be able to use  some features and functionality of the Services.

You  may request 【  】to (i) disclose the history of personal data that  we have collected; and/or (ii) erase and dispose of your personal data  that we have collected on our server. Please note that by requesting us  to erase and dispose of your personal data, you may not be able to use  some features and functionality of the Services. To exercise any of your  rights, contact us at the information listed in the “Contact Us”  section.

3. Notification.  In the event of any breach of personal data, we will notify you and  provide you with information regarding such breach of personal data.

4. Data  Retention. We retain your information for as long as it is necessary to  provide you with the service. Where we do not need your information in  order to provide the service to you, we retain it only for so long as we  have a legitimate business purpose in keeping such data. However, there  are occasions where we are likely to keep this data for five (5) years  (or longer if required) in accordance with our legal obligations or  where it is necessary for the establishment, exercise or defence of  legal claims.

  After  you have terminated your use of our Services and the five (5) years  retention period has lapsed, we store your information in an aggregated  and anonymised format. Non-personally identifiable information may be  retained indefinitely for analytics.

Singapore

By continuing, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, the locations specified in Section 5 (How We Store and Share Your Personal Information).

You have the right to access your personal information, how we use it, and who we disclose it to. You have the right to correct any of your personal information that is inaccurate.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted as set out in Section 9 (Contact).

Vietnam

If  you are using our Services in Vietnam, the following terms apply：

1. By clicking "accept", you acknowledge that you have read, understood, and agree to the Privacy Policy.

2. Age, Parental and Guardian Consent. If you are below 18 years old or under guardianship:

- you must obtain approval from your parent(s) or legal guardian(s); and

- your parent(s) or legal guardian(s) are responsible for: (i) all your actions in connection with your access to and use of the Platform; (ii) your compliance with this policy; and (iii) ensuring that any of your participation in the Platform will not, in any event, result in any violation of applicable laws and regulations relating to child protections.

3. Data  Retention. During your use of the service and within 6 months after ceasing to use the service, we store your information in an aggregated  and anonymised format. Non-personally identifiable information may be  retained indefinitely for analytics.

Thailand

If  you are using our Services in Thailand, the following terms apply：

1. By clicking "accept", you acknowledge that you have read, understood, and agree to the Privacy Policy. If you do not agree with the Privacy Policy, you must not use the Service.

2. By using the Services,  you represent that you are at least 20 years of age or married or not  under guardianship.If you are under the age of 20, you undertake that you have obtained your parent or legal guardian’s consent to register an account on and use the Service.

3. To the extent provided for by the Thai Personal Data Protection Act (PDPA), you may:

  · withdraw your consent to the processing of your personal data (only where the legal basis for our processing is consent); however, please note that where consent is required to process your personal data, we may not be able to deliver the expected service without it;

  · request us to provide you access to, make any correction to, cease any automated processing or profiling (if applicable), discontinue, restrict the use or provision of and/or erase your personal data;

  · request us to provide you or a third party with your personal data which is stored by us in a machine readable format; and/or

  · lodge a complaint to a relevant authority.

Where you wish to make such requests, please contact us as set out in Section XIII.

Egypt

If you are using our Services in Egypt, the following terms apply:

- You must confirm that you are over 18 years old. If you are under 18, you should review this document with a parent(s) or legal guardian(s). If you are a parent or legal guardian reading these terms on behalf of a minor under 18, you must affirm that the minor is at least 13 years old, and that you have reviewed and accepted 【XXXX's】Privacy Policy and Terms of Use, consenting to your child’s use of our Services.

- If you consider that we have personal data about or collected from a child under the relevant age, please contact us at 【XXX@XXX.com】 and we will ensure that it is deleted.

South Africa

If  you are using our Services in South Africa, the following additional  terms apply. In the event of any conflict between the following  additional terms and the provisions of the main body of this Policy, the  following terms shall prevail.

You  declare that you are over the age of 18. If you are under the age of  18, please have your parent or legal guardian read this with you. If you  are reviewing these terms as the parent/legal guardian of a user who is  under the age of 18, you hereby declare that such user is above the age  of 13 and that you have read and acknowledged the Privacy Policy and  Terms of Service and agree to the use by your child of the Services and  registration for an account.

 EEA and UK

If you are in the European Economic Area (EEA) or the United Kingdom (UK), the following additional information applies to you in addition to the Privacy Policy set out above.

Data Subject Rights

In addition to the information set out in the in the Privacy Policy above, you have the right to:

● ask us to restrict the processing of your personal data,

● data portability,

● to object to the processing of personal data.

Legal basis for processing your personal data

Our legal basis and purposes for collecting and using the information described in Section II for the of our Privacy Policy above is:

● To establish and perform our contract with you (i.e. our Terms of Service) and to provide our services;

● For our or our partners’ legitimate interests, where those interests are not overridden by your data protection interests of fundamental rights and freedoms, e.g. to protect our legal rights, to pursue or defend legal claims, to improve our services;

● Consent, where obtained separately;

● For compliance with our legal obligations under applicable laws and regulations;

● To protect our or your vital interests or those of another person (for example, another player), e.g. against fraud and violations of our terms;

● While we typically do not collect sensitive or special category personal information, where we do this, it will be on the grounds of consent or other applicable lawful basis.

If you have questions, need further information about the legal bases for processing your personal information, or want to withdraw your consent, please see sectionX “Contact and Complaint” in the Privacy Policy above.

Cross-border data transfer

As a global company, 【  】 may transfer your personal data to our affiliates, third party service providers and partners that operate around the world, which are located in countries other than the country in which you are resident (e.g. Singapore). These countries may have data protection laws that are different to the laws of your country.

Where we transfer your personal information to countries and territories outside of the European Economic Area and the UK, which have been formally recognised as providing an adequate level of protection for personal information, we rely on the relevant “adequacy decisions” from the European Commission, where applicable.

Where the transfer is not subject to an adequacy decision, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy. The safeguards we use are the European Commission’s Standard Contractual Clauses as issued on 4 June 2021, including the UK Addendum, and/or the UK International Data Transfer Agreement permitted under Article 46 of the UK GDPR. This is how transfers of personal information between us and other companies will be safeguarded.  All companies are required to protect personal information that they process from Europe in accordance with European Union data protection law. Transferred personal information includes basic information such as your name or contact information such as your email address.

Children's Notice

Our Services are not marketed to, or intended for, children.  Children for the purposes of our Services are (a) under the age of 13 years old or, if older (b) between 13 and 18 years old but under the age at which they can give valid digital consent to processing of their personal information under applicable data privacy laws. We strive to follow the different minimum age guidelines set by the laws of individual regions when determining the age that children can access certain features of our Services.

Children are not permitted to use these Services, and we do not knowingly collect any personal information from children. Though our Services are not intended for children as the primary audience, we may collect age information before allowing a user to proceed for certain Services. If we learn that we have inadvertently gathered personal information about a child that is not subject to an exemption under applicable privacy law, we will take measures to promptly remove that information from our records.

Data Protection Supervisory Authority

To lodge a complaint with your national or regional data protection supervisory authority, please contact the competent authority.

XVI. Game Account Deletion Terms

Please read this Game Account Deletion Terms (hereinafter referred to as "Terms") carefully, fully understand the terms and conditions contained herein, and agree to be bound by this Terms, if you decide to deliberately delete your game account.

If you start the deletion process according to our deletion process/guidelines, you acknowledge that you have read, understood and agreed to be bound by this Terms. 

This Terms includes additional terms that work in conjunction with our Terms of Service, which can be found in our games. Such Terms of Service are incorporated into this Terms by reference. Capitalized terms that are used but not defined in this Terms shall have the meanings assigned to such terms in the Terms of Service. If there is any conflict between this Terms and the Terms of Service, this Terms shall prevail.

NOTICE: ONCE YOUR GAME ACCOUNT HAS BEEN DELETED, WE WILL NOT BE ABLE TO RECOVER YOUR ACCOUNT. ALSO, YOUR DATA (INCLUDING YOUR PERSONAL INFORMATION AND ANY OTHER INFORMATION GENERATED THROUGH USING OUR GAMES AND SERVICES) WILL BE DELETED OR ANONYMIZED, UNLESS OTHERWISE PROVIDED FOR BY APPLICABLE LAWS AND REGULATIONS. PLEASE DECIDE AND PROCEED CAREFULLY.

1. Consequences of Game Account Deletion

You acknowledge and agree that upon deletion of your game account, there are consequences including but not limited to those outlined below. You agree that, to the fullest extent permitted by applicable law, we shall not be liable to you for such deletion.

1.1 You cannot use the Games and Services any more.

1.2 You will lose and we may delete or anonymize your data we have associated with your game account, including but not limited to your profile, username, password, avatar(s), game progression, virtual family or relationships, chat records, any virtual currency and items which have been purchased but not yet redeemed and all related information and files you have passed on to us, together with any Content you may have published, uploaded, made available on the Services.

1.3 If you delete your game account by completing the account deletion process or contacting our customer service, your account will be temporarily disabled, and we will review your account deletion request within 30 days ("deletion confirmation period", "30-day period"). Beyond this period, your game account will be deleted permanently.

1.3 In some cases, such as for the purpose of protecting our legitimate rights and interests, we reserve the right to store personal data relating to your profile for a reasonable period of time to the extent permitted by applicable laws and regulations.

1.4 Once the deletion confirmation period is up, you will no longer have access to your account and you will lose all your save files and in-game progression related to the Services.

1.5 You agree that, beyond the 30-day period, no credit, including but not limited to, unused/unexpired Services, unused virtual currency and items, unused subscription period, all data related to the upgrading of game, and other virtual property generated in the games and services (collectively, "in-game virtual property”) will be recoverable or credited to you or converted into cash or any other form of reimbursement.

We hereby remind you to settle in-game virtual property associated with your game account before you request deletion of your game account. If you complete the game account deletion process, you are deemed to voluntarily forfeit any in-game virtual property associated with your game account and we reserve the right to clear such in-game virtual property without reimbursement or compensation.

1.6 In the event of game account deletion (which means the deletion confirmation period is over, and the account is officially deleted), the Terms of Service signed by and between you and us will be terminated (except for those terms which remain in effect, including Section 3 (Content), Section 5 (Restrictions), Section 6 (Use and Transaction Policies), Section 9 (Third Party Links and Offerings), Section 10 (Indemnity) Section 11 (Disclaimers and Limitations of Liability), Section 13 (Governing Law and Dispute Resolution), Section 15 (Suspension, Termination or Cancellation) and Section 16 (Miscellaneous)). However, you are still obliged to comply with the Terms of Service when you use our games or services prior to the deletion of the game account, including but not limited to bearing the liabilities for breach of the Terms of Service and associated damages and performance obligations.

1.7 Upon the completion of the game deletion process, you, on your own behalf and on behalf of your successors, assigns, affiliated entities, shall and do thereby forever, fully and completely, relieve, release, and discharge us, our successors, beneficiaries, heirs, assigns, affiliated entities, and each or any of these entities’ or individuals’ agents, representatives, officers, directors, shareholders, employees, attorneys, affiliated entities, from any and all lawsuits, actions, omissions, causes of action, debts, obligations, promises, guarantees, Termss, contracts, rights of indemnification, claims, liabilities and/or demands, of whatever kind or nature, whether known or unknown, now existing or arising or coming into being in the future, based on, arising out of, related to and/or in any manner connected with the Service and the Terms of the Services (the “Release”). Notwithstanding anything herein to the contrary, each of the following is specifically excluded from the Release: (i) any dispute under or arising from this Terms and/or any lawsuit, action, proceeding or claim to enforce or interpret its terms and (ii) any obligation or duty created by or set forth in this Terms or the terms of the Terms of Service that survive termination pursuant to Section 1.6 hereof.

2. You represent that the game account you would like to delete has met the following conditions when you would like to delete your game account, including but not limited to:

2.1 The game account is legally owned and logged in by yourself and complies with the Terms of Service and relevant applicable rules.

2.2 The game account is used in compliance with the Terms of Service and all applicable laws, and there are no disputes (including complaints, lawsuits, arbitrations, etc.) or sanctions with respect to the game account.

2.3 Any in-game virtual property has been settled. If any in-game virtual property remains unsettled when you complete the game account deletion process, you are deemed to voluntarily forfeit any in-game virtual property associated with your game account.

2.4 There are no outstanding orders in your game account, including virtual currency and items, subscriptions, etc.

2.5 The game account has not changed passwords or modified the connected mobile phone number or email account in the last 7 days.

2.6 Other conditions (if any) announced in the games.

3. Account Deletion Process

If you represent that you would like to delete your game account permanently, you can do so directly in the Services or by contacting us for help. Please understand that for security reasons, your account cannot be deleted unless you follow our instructions.

3.1 You can log in to your game account, navigate to the Account Setting/User Center, click the Request Account Deletion button and follow the deletion process instructions.

3.2 To confirm your account deletion request, you may be asked to verify your account, such as email verification and entering security code.

3.3 If you complete the account deletion process, your account will be temporarily disabled in the 30-day period. Once the 30 days has passed, your account will be permanently deleted. You can reactivate your account or cancel your request at any time before the 30-day period is over by logging in or contacting us. Please note that the deletion process will be canceled if you reactivate your account.

4. Miscellaneous

4.1 This Terms is an integral part of the Terms of Service, and matters not covered herein shall be governed by the Terms of Service.

4.2 You agree that, if your game account is being or needs to be verified with respect to your relevant transactions or such account when you apply for deletion of such account, we shall have the right to continuously freeze all or part of your account in order to facilitate such verification, and shall have the right to report any fraud or illegal activity to the relevant regulatory or judicial authorities if necessary. The deletion of your game account for this game will not relieve or exempt you from the relevant liabilities you may be required to assume according to the Terms of Service, and any applicable laws and regulations.

If you have any questions, please contact us for assistance.