We recognize that persons who access and/or use (“you” or “Users”) our games, whether played on our website, on mobile devices, PCs or on other platforms, (“Xingdong Games”) and other related services, including but not limited to customer supporting, marketing and advertising, (collectively, the “Services”) value their privacy.
i) the data collected from you and the ways we collect your data,
ii) the reasons why we collect your data,
iii) to whom we disclose your data, and
iv) the options you have about your personal data.
Any terms not defined herein but defined in the Terms of Service shall have the meaning ascribed thereto in the Terms of Service.
I. THE DATA COLLECTED FROM YOU AND THE WAYS WE COLLECT YOUR DATA
1. Data provided by you
To use the Services, you may directly provide certain personally identifiable information to us, such as:
· Contact information (e.g. your name, personal identification number, postal or e-mail address, telephone numbers)
· Registered user name and password
· Character Information (e.g. Account ID, character name, profile picture. Please be reminded that such information may be disclosed to other users in connection with the use of the Services and may also be made available to your connections or the public on third party services)
· Personal content preferences
· Profile information (e.g. profile photo)
· Messages to the Services (e.g. chat logs, your support tickets)
· Other data that you voluntarily provide (e.g. data to identify a lost account)
2. Data collected automatically
· Data about your Account
· Internet Protocol (IP) address, web request, domain name, URLs, referring/exit pages, platform type and mobile device identifiers (e.g. your device ID, advertising ID, MAC address, IMEI)
· Data about your device (e.g. device name, operating system, browser type and language)
· Data we collect with cookies and similar technologies
· Monitoring of aggregate metrics (e.g. total number of visitors, pages viewed, usage of the Services)
· General location data
· Precise geo-location data (i.e. GPS)
· Data about your use of the Services (e.g. number of clicks, landing pages, pages viewed and order of those pages, the amount of time spent on particular pages, the date and time of your request, your game play and activity, your game progress, your interactions with other players inside the Services)
· Other pieces of information in connection with your various activities within or through the Services or otherwise that are sent by your browser, device or computer system when you access the Services, which are automatically tracked and recorded by our servers
3. Data collected from our partners
When you access the Services through any third party services such as social networking sites (e.g. Facebook, WeChat, Google) or from any mobile devices, you allow us access to certain information stored on these third party services or mobile devices such as:
· Demographic data (e.g. determination of your IP address)
· Data to fight against fraud (e.g. refund abuse in games or click fraud in advertising)
· Data from platforms that the games run on (e.g. verification of payment)
· Data associated with your device (e.g. device type, technological information, telephone number, country, contacts)
· Data to do advertising, marketing and analysis
II. THE REASON WHY WE COLLECT YOUR DATA
1. To provide the Services
To provider the Services, we process data necessary to
· Create Accounts
· Allow you to play Xingdong Games and use the Services
· Operate the Services
· Verify and confirm payments
· Provide and deliver products and services that you request
· Send service-related communications to you
2. To improve and optimize the Services
To provide better Services to you, we have a legitimate interest to collect and process necessary data to
· Update and develop the Services
· Manage and update your Account
· Develop and improve your experience
· Manage the relationship with you
· Provide social features to you
· Customize your service experience
· Respond to your comments and questions and provide support to you
· Provide offers in the Services as well as in other websites and services
· Send related information (e.g. updates, security alerts, support messages) to you
· Enable you to communicate with other users
3. To carry out activities related to advertisements and marketing
To send you personalized advertising and marketing materials, we may use the information collected from you such as ad identifiers, age, country, region, gender, language, games played by you, information related to the interaction of you with the Services and with other users, and so forth.
We may also use various third party advertising and marketing partners to assist us on our behalf and may share information collected from you with such third parties for this purpose.
Hence, we have a legitimate interest to process necessary data to
· Track the content you access in connection with the Services and your online behavior
· Deliver, target and improve our advertising and marketing materials
· Pass the information collected from you to third party advertising and marketing partners
We encourage you to review the privacy policies of our third party advertising and marketing partners so that you can understand how these third parties collect, use and share your information. We are not responsible for the privacy policies of any third party whether accessed through the Services or otherwise.
For information on how to opt-out from receiving personalized advertising and marketing materials, see section 'The options you have about your personal data” below.
4. To secure the Services
Ensuring the security in the course of performing the Services is a top priority for us. We take appropriate security and technical measures to protect your information from unauthorized access, loss and misuse. To achieve this purpose, we also request our suppliers who process personal information on our behalf to take appropriate security measures.
In order to keep the Service and its social features safe and fair, to fight fraud and to ensure acceptable use otherwise, we have a legitimate interest to process necessary data to
· Analyze and monitor use of the Services and its social features
· Moderate and monitor chats
· Prevent cheating, crime or fraud
· Take action against fraudulent or misbehaving users
· Pass your information to agencies or organizations in charge of crime and fraud prevention and repression
Despite our efforts, we cannot guarantee the absolute security of your personal data, nor can we ensure the security of any of the communication facilities provided by us. We recommend that you exercise caution when disclosing any information through the Services. In particular, please note that any personally identifiable information or personally sensitive data that you communicate or disclose to any user in connection with the Services may be collected and used by others. As such, you should take care of the information shared online. Please also be reminded that any questions answers, comments, submissions that you post in the forum will be publicly available.
5. To analyze, research and test
In all of the above cases and purposes, we may use analytic tools, which may include third party’s analytic tools, to carry out research, surveys and analysis, to create reports for use, to track potential problems of the Services or to test out new game features and content.
6. To obtain your consent
With your consent, we may process personal data for additional purposes.
III. TO WHOM WE DISCLOSE YOUR DATA
1. Our personnel, related or affiliated companies
2. Other users
As social features are a core element of our games, other users may see your profile data, in-game activities and read the messages you have posted.
Any user who receives any information including personally identifiable information, from another user shall not disclose or use such information, save where expressly permitted by that user or save where such information has ceased to be of a confidential nature. In any event, we shall not be liable for any unauthorized disclosure or use by another user or other person of any content.
3. Partners working for us
We have partners (including but not limited to advertising, marketing and social media partners) to perform services for us. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.
4. Other companies and public authorities
We may release personally identifiable information and/or non-personally-identifiable information to, exchange such information with companies and organizations or provide such information to public authorities if required to do so by law, or in the good faith belief that such action is necessary to comply with all and any applicable laws, or where it is pursuant to we are required to respond to a governmental, regulatory, administrative or court order or directive, a subpoena or a search warrant, or to combat fraud and illegal activity.
We also reserve the right to disclose personally identifiable information and/or non-personally-identifiable information that we believe, in good faith, is appropriate or necessary to enforce the Agreement, take precautions against liability, to investigate and defend against any third-party claims or allegations, to assist government authorities and enforcement agencies, to protect the security or integrity of the Services, and to protect the rights, property, or personal safety of ourselves, our users or others.
IV. THE OPTIONS YOU HAVE ABOUT YOUR PERSONAL DATA
1. Opt out of advertising and/or marketing materials
You may opt out of receiving advertising and/or marketing communications by following the instructions in such communications or by using options provided in the game settings.
2. Access and correct the personal data we hold about you
You have the right to access and correct your personal data.
3. Other rights
You also have the right to have your personal data deleted, object how we use or share your personal data, and restrict how we use or share your personal data. You can always withdraw your consent.
If you have questions about data protection, or any requests for resolving issues with your personal data, we encourage you to primarily contact us through the game so we can reply to you more quickly. We will respond to all requests within a reasonable time frame.
4. Your California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information.
V. INTERNATIONAL DATA TRANSFERS
VI. SPECIAL NOTE TO INTERNATIONAL USERS
The use of the Website and Services and this Agreement is governed by and shall be construed and enforced under the laws of Singapore, without applying any conflicts of law principles that would require application of the law of any other jurisdiction. You agree to submit to the personal non-exclusive jurisdiction in Singapore and any other court of competent jurisdiction chosen by us.
In the event of any dispute arising out of or in connection with this Agreement, including any question regarding its existence, validity or termination, (a “Dispute”), we strongly encourage that a resolution first be sought through our Customer Support service.
You agree that in the event that a resolution is not obtained through our Customer Support service, such Dispute shall be referred by you and may be referred by us to and finally resolved by arbitration in Singapore in accordance with the Arbitration Rules of the Singapore International Arbitration Centre ("SIAC Rules") for the time being in force, which rules are deemed to be incorporated by reference in this clause. The Tribunal shall consist of three (3) arbitrators, with you appointing one (1) arbitrator and us appointing one (1) arbitrator and the third arbitrator to be selected by the two (2) arbitrators so appointed. The language of the arbitration shall be English.
Notwithstanding any of the foregoing, you agree that we are entitled to submit such Dispute for resolution through any other dispute resolution mechanism including the courts of any jurisdiction and we shall further be entitled to seek any injunctive or other equitable relief in the event of any breach or anticipatory breach by you, without any obligations of providing any bond or surety or proof of damages.
You irrevocably waive all rights to seek any injunctive or other equitable relief or to enjoin or restrain the operation or exploitation of the Services or any part thereof. You further irrevocably waive all rights to a class or representative action or as a named or unnamed member in a class, consolidated, representative or private attorney general action.
VII. OUR POLICIES CONCERNING CHILDREN
The Services are not intended to be accessed by persons under the age of 13, nor do we knowingly collect or solicit personal data therefrom. In the event that we learn that we have inadvertently gathered personally identifiable information from persons under the ages set out below, we will take commercially reasonable measures to ensure that such information is removed from our records.
VIII. DATA SECURITY
We use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. We cannot, however, ensure or warrant the security of any information you disclose on, through or within the Services and you do so entirely at your own risk. Please note that we cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.
If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice on the Website if a security breach occurs.
If you create an Account with the Xingdong Platform, you will be required to select a password that can be changed at any time after you first log into the Account by using your current password. You are solely responsible for maintaining the confidentiality of your password and are fully responsible for all activities that occur under your Account and password or your account with any other third party service. Users agree to (i) notify us immediately if you are aware or reasonably suspect of any unauthorized use of your Account or password or of any unauthorized access of the Services through your Account, and (ii) ensure that you exit from your Account at the end of each session.
IX. MERGER, ACQUISITION, SALE OR INSOLVENCY
1. In the event that we are acquired by or merged with another entity, we reserve the right, in any of these circumstances, to transfer the information or assign our rights to the information that we have collected from our Users as part of such merger, acquisition, sale, or other change of control.
2. In the event of our insolvency, reorganization, receivership, winding-up or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your personal information is treated, transferred, or used.
XI. CONTACT US