Privacy Policy
Release Date: 12/14/2022
Effective Date: 12/14/2022
Introduction
The Privacy Policy (hereinafter referred to as “this Policy”) applies to the online game products and/or services we provide, including primarily all types of game client applications (including but not limited to PC, mobile, applet and other terminals, as well as beta versions), and official websites, as well as web pages, Software Development Kits (SDKs) and Application Programming Interfaces (APIs) used on third-party client applications and/or websites (collectively known as “Our Products and/or Services”) that we legally own, manage and operate. This Policy provides a clear description of how we deal with your personal data and what we offer to manage and protect such information when you use Our Products and/or Services. Provisions in this Policy that are (potentially) related to your rights and that prescribe the processing of sensitive personal data are shown in bold font, underlined or indicated in other reasonable ways to remind you to read them carefully. If you do not agree to this Policy, please do not proceed to the next step, use Our Products and/or Services, or confirm this Policy in any way (including but not limited to checking a box, clicking Agree or voluntarily filling in/submitting personal data). By proceeding to the next step or using Our Products and/or Services upon confirmation of this Policy, you are voluntarily accepting this Policy and complying with all the terms herein.
In addition to this Policy, we will inform you in specific contexts and in a timely and detailed manner of the purpose, manner, scope, and other rules for processing of your personal data, and your personal data will remain unprocessed until your authorization and consent (if applicable) is obtained (communication means include but are not limited to: update of this Policy, invitation to resign a document, prompt page, pop-up, private message, email, website announcement, among other practical means to keep you updated).
Contact Us
Our Products and/or Services are operated by Hongkong Skymoons Interactive Co., Ltd. and their affiliated companies. Basic information of primary operating companies is as follows:
Hongkong Skymoons Interactive Co., Ltd., founded on September 11, 2014 with registered domicile at FLAT/RM 505 5/F BEVERLEY COMMERCIAL CENTRE 87-105 CHATHAM ROAD SOUTH TSIM SHA TSUI KL.
“Affiliated Companies” refer to the companies and establishments that control, are controlled by, or are under joint control of Hongkong Skymoons Interactive Co., Ltd. “Control” refers to the ability to influence, directly or indirectly, the management/operation of the controlled object through ownership, voting shares, contracts, real associated operations, or other means as determined by law.
If you have any complaint, suggestion, or question about this Policy or our privacy protection efforts, you may contact our online customer service on the product feature page or submit feedback online. Alternatively, you may contact our Data Protection Officer. The contact information for our Data Protection Officer is as follows:
Name: Frank; E-mail: privacy@iq.com; Address: 2/F, Building 9, No. 365 Linhong Road, Changning District, Shanghai City, PRC.
After verifying your user identity, we will reply within the time limit required by applicable laws and regulations, for which we will not charge any service fee from you, under normal circumstances.
This Privacy Policy will help you understand:
I. What Types of Personal Data We Collect
II. How We Use Your Personal Data
III. Cookie Terms
IV. Protection of Children’s Personal Data
V. International Transmission of Personal Data
VI. How We Share and Disclose Your Personal Data
VII. How We Protect Your Personal Data
VIII. Retention of Personal Data
IX. Your Rights
X. Updates to This Policy
XI. Other Information
I. What Types of Personal Data We Collect
(I) The data that you voluntarily provide
1. When you maintain your game account information, you may choose to fill in or upload your nickname, profile picture, personality signature and other information voluntarily.
2. When you participate in our product surveys and questionnaire surveys, you may provide us with your name, gender, age range and other information.
3. When you use our customer services or other user response features, you may provide us with your account information, contact information (the phone number/email you use to contact us or other contact information you provide to us voluntarily), information about your interactions with us (including text/pictures/audios and videos/call history), and other necessary information associated with your needs.
(II) Information that we collect, record and summarize
When you use Our Products and/or Services, we will automatically collect some of your personal data, including but not limited to: (1) device information: including device identification information (Mac address, Android ID, Open UDID, IDFA, IDFV, GAID and other device identifiers composed of comprehensive device parameters and system information), mobile application list, network related information (IP address, network operator, network information, network status, and network type), device parameters and system information (device name, device model, operating system, version of the operating system, system language, mobile phone manufacturer, resolution, height, width and orientation of the screen, total disk space, total memory space of the system) in whole or in part; (2) game logs: including login log, operation log, in-game rights and assets log, in-game property log, level-up log, activity log, guild log, battle information, and in-game friendship history generated as you use Our Products and/or Services, as well as game progression and crash logs and information about overall game use.
In addition to the information we automatically collect as mentioned above, we also collect, record and summarize your personal data in the following scenarios:
1. When you log in as a visitor to use Our Products and/or Services, we will collect your device information (such as Android ID, IDFA, IDFV and GAID), or we will create a unique ID for you, and store it in your device (iOS terminal only); at the same time, we will create a game account ID for you.
2. When you make an order in one of our games, we will collect information on your game account ID, purchased goods and/or services, and transaction information (including order number, transaction amount, time of order placement, etc.);
3. When you make a payment, we will collect information about your mode of payment.
4. When you use virtual currency in a game to buy virtual property or other goods and/or services, we will collect the purchase record, and information such as the content and time of purchase.
5. When you communicate and interact with other players in games, we will collect the information (such as text) that you release.
6. When you give virtual property or other goods and/or services to your friends in games as gifts, we will record your gift information (such as the game account IDs and nicknames of the giver and the recipient and the gifts).
7. When you participate in our operating activities, such as lucky draws, we may collect your game account information, records of participation in activities, and information about the benefits you have claimed (recipient information, such as address and contact information, is required when the benefits are delivered offline).
8. When you share anything about one of our games (such as performance in a battle) to any third-party platform (such as Facebook), we may collect and calculate statistics regarding some of the game log information generated as you use Our Products and/or Services, such as the number of victories and defeats in battles, and rewards obtained.
(III) Your data that we are aware of indirectly from a third party
1. When you bind your account from a third-party platform to your account for our games, we will obtain your Open ID on the third-party platform.
2. When you make a payment, we will collect information about your payment status.
3. When you give virtual property or other goods and/or services in games to your friends registering with third-party platforms (such as Facebook) as gifts (which is supported by only some of our games), we will get a list of your recipient friends registering with third-party platforms who are also users of Our Products and/or Services. When you choose a recipient friend who receives a gift from you, we will get your Open ID and nickname as well as those of your chosen recipient friend on the third-party platforms.
II. How We Use Your Personal Data
(I) To provide you with our services
1. To mark your identity as a user, create a game account for you, and provide continuous services for you as a user;
2. To accept your orders and payments, as well as to provide support for order inquiries and management (which is supported by only some of our games);
3. To provide support for user inquiry and management of virtual currency purchase records (which is supported by only some of our games);
4. To ensure that you can use Our Products and/or Services normally as a user, maintain normal and stable operation of the basic functions of our games, and identify and address progression errors and crashes in our games;
5. To file the progression of our games and deliver consistent game experience;
6. To provide customer services, examine particular matters, and help users address problems.
(II) To improve your user experience and provide you with better services
1. To further improve your personal information and enhance your social experience within the scope of Our Products and/or Services;
2. To allow login and use of the same account on different devices;
3. To provide support for communications and interactions between game users;
4. To understand your actual experiences and suggestions for our games, and improve and optimize our services;
5. To provide you with a variety of operating activities to enrich your game experience;
6. To enable you to share information about our games on third-party platforms;
7. To enable you to interact with your friends registering through third-party platforms and enhance your social experience.
(III) To maintain a fair, healthy and safe game environment
1. To implement safety monitoring and control features (such as sensitive word recognition), and to monitor and censor some of your personal data (such as the content of your communications and interactions, and the profile pictures you upload) so as to prohibit the release and dissemination of illegal, undesirable, and malicious information as determined by applicable laws and regulations;
2. To ensure the safety of user accounts, systems and transactions, cracking down on behaviors that interfere with or disrupt the normal operation of our game services or that disrupt the fair game environment (such as by detecting piracy, scanning for plug-ins, and preventing cheating), and to enhance the safety and reliability of Our Products and/Services so as to prevent any behaviors that harm users, the corporate Group, and society.
(IV) To support advertising services
1. To target advertisements: showing personalized advertisements for you within Our Products and/or Services;
2. To carry out advertising statistical analysis and optimization: supporting advertising monitoring and attribution, analyzing and measuring the effectiveness of advertising and related services, making advertising or decision-making recommendations, and improving the effective reach rate of advertising.
(V) To carry out data analysis
Your relevant information, after being de-identified or anonymized, may be used for our internal research, statistical analysis and forecasting, to improve the contents and layouts of our platform and services, to provide product or service support for our business decision-making, and to improve our products and services.
(VI) Other
Your data will be processed in other ways with your authorization and consent.
III. Cookie Terms
Cookies are small files containing strings that are sent to and stored on your computer, mobile device or other device (usually encrypted), when you log in and use a website or other web contents. Cookie-like technologies are other technologies that can be used for purposes similar to those of cookies, such as Web Beacons, Proxies, and embedded scripts.
Currently, we use cookies primarily to collect your personal data. You acknowledge and agree that we may also use cookie-like technologies as technology evolves and Our Products and Services are further improved.
When you use Our Products and/or Services, we or our partners may use cookies and cookie-like technologies to collect some of your personal data, including: your website access habits, the information you have browsed, and your login information. This is done in order to simplify operating processes (such as login services) for you, record your preferences, keep our services safe, enhance the product experience of our users, and improve our services. We may also strictly require third parties to use cookies and cookie-like technologies for only the purposes described in this Policy.
When allowed by your browser, you may manage cookies and cookie-like technologies through the settings of your browser. You understand and acknowledge that some of Our Products and/or Services can only be implemented through the use of cookies or cookie-like technologies and that if you refuse to use or delete them, you may not be able to enjoy the best service experience with Our Products and/or Services, and this may affect the protection of your data and the security of your account.
IV. Protection of Children’s Personal Data
As a general rule, Our Products and/or Services are intended for adult users only, unless the laws and regulations in your jurisdiction allow children to use Our Products and/or Services, or if the child uses them with the authorization and consent or under the direction of their guardian. The specific criteria for determining the age of children are subject to the provisions of local laws and regulations. For example, in the mainland of the People’s Republic of China (for the purposes of this Privacy Policy only and excluding Hong Kong, Macau and Taiwan, China), children are defined as minors under the age of 14; in the European Economic Area/Switzerland, children are considered natural persons under the age of 16; in Singapore and the United States, children are all minors under the age of 13.
Clearly, in most cases we are unable to identify the specific person using Our Products and/or Services as a child. For example, we are not able to determine whether the not clearly age-identifiable personal data that we collect and process belongs to children. However, please rest assured that once we identify such relevant data as belonging to a child, we will restrict and stop the use of Our Products and/or Services by the user identified as a child user and delete or anonymize the relevant child data (if applicable) according to applicable laws and regulations. We will also take technical and administrative measures to comply with or exceed the legal standards to ensure compliance when we process children’s data in order to provide safe storage for it.
You understand that protection of children’s personal data requires concerted efforts between their guardians and us. We expect guardians to assist us in protecting their child’s personal data. Please note that guardians shall treat their child’s personal data with care and shall ensure that their child’s related operations (such as authorization and provision of information) comply with the laws and regulations in your jurisdiction and occur under your authorization and consent or direction (if applicable).
We will only collect, use, and share children’s personal data as permitted by the applicable laws and regulations, with the explicit consent of their guardians, or as necessary to protect minors, and guardians may contact us at any time to inquire about, modify, or delete their child’s personal data to the extent permitted by laws and regulations.
V. International Transmission of Personal Data
You understand and agree that your information may be stored/transmitted outside of the jurisdiction where you are located because we are a large global business group that maintains servers around the world. Different countries/regions have different personal data protection laws. We will also take appropriate measures to fully protect your personal data as required by the applicable laws and regulations according to what is specified in this Policy. At the same time, we will comply with provisions required under some legal frameworks, such as the Standard Contractual Clauses approved by the European Commission.
VI. How We Share and Disclose Your Personal Data
(I) How we share your personal data
When sharing your personal data, we will take various measures to protect it, including but not limited to: (1) If your authorization and consent is needed again, we will inform you of the purpose, type, and method, as well as the recipient of the data, before we share it, and the data will not be shared until your authorization and consent is obtained; (2) We will enter into an agreement to strictly prescribe the obligations and legal liabilities of the recipient for the protection of your personal data; (3) Our security team will take effective technical measures for data protection in terms of the output form, flow and use of your personal data, and anonymize it whenever possible.
1. To provide services
(1) Payment services: In order to keep every transaction safe and settle payments for goods/services, we will provide information about your orders and payments to our payment service partners (such as Apple Pay and Google Pay).
(2) Delivery services: In order to deliver to you any physical rewards that you may have won in games, we will submit your relevant information (such as your delivery address and contact information) to our logistics partners to the extent necessary.
(3) Problem solving and dispute resolution: In order to help users solve problems and resolve disputes, we will share your relevant information, including the problems that you have submitted online and other personal data necessary for solving problems and resolving disputes, with our partners who may provide services alongside us.
(4) Distribution of products as an agent: If you use the game products that we distribute as an agent, we may share your game logs and related information (such as crash logs) generated in the games with the game developers or relevant third parties for the purposes of carrying out security analysis on the games, improving our game services, and further optimizing your game experience.
(5) Statistical analysis and optimization for advertising: In order to analyze and measure the effectiveness of advertising and related services, we may use your device information (such as CAID, IDFA, and IMEI), IP address and other information to support advertising monitoring and attribution in a way that optimizes our advertisements or decision-making and improves the effective reach rate of advertising.
(6) Professional consulting services: When we engage professional consultancies (such as audit firms) for their services, we may provide them with your relevant information to the extent necessary.
(7) Under the premise of ensuring the safety of your personal data and its use for proper purposes, we may provide your personal data that has been de-identified or anonymized to research institutes, universities and other institutions with which we cooperate, for the purpose of scientific research in related fields to promote scientific and technological development.
(8) Third-party SDK service providers: In order to keep our clients operating stably and implementing their functions, we may embed third-party SDKs or other similar applications in our products. If you use such third-party services provided on our platform, you agree that your data will be collected and processed directly by such third parties. The collection and processing of your personal data by such service providers is subject to their own privacy policy and is not bound by this Policy. However, we will try to review the business access qualifications of such third parties and require legal compliance and security commitments from such service providers. In order to protect your legal rights and interests, if you become aware of any risks associated with the third-party SDKs or other similar applications that we have embedded in our products, you are encouraged to discontinue related operations immediately and contact us in a timely manner. Please refer to the List of Third-Party Software Development Kit (SDK) Service Providers.
(9) Service support providers: Some of our services are provided by service support providers, such as: 1) cloud server: we entrust a third-party cloud service provider (Amazon Web Services, Inc.) to provide information storage services; 2) online customer services: we entrust a third-party customer service agency (ShareFun Network Limited) to provide online customer services for our users; 3) security risk control: we may entrust a third-party agency to provide security risk control, anti-cheating services, etc.; 4) other cases in which we engage service support providers. Please rest assured that if we engage a service support provider to process your personal data, we will agree with them on the purpose, terms, and methods of data processing, the type of personal data to be processed, and protection measures, as well as the rights and obligations of both parties, and we will also supervise the entrusted service support provider as they process your personal data.
(10) Other circumstances necessary for the implementation of our services/functions.
2. To carry out internal sharing inside the Group
You understand that your data may be shared within our Group to the extent necessary because we are a large global business group in which some of our services provided by other internal entities. However, please rest assured that these relevant entities will only process your personal data in accordance with this Privacy Policy.
3. To comply with laws and regulations or regulatory requirements
1. In some cases, we may share your personal data with third parties (such as judicial authorities, law enforcement agencies, government agencies and their entrusted professional consultancies or other third parties) as required by laws and regulatory authorities and in order to protect your and our legitimate interests and rights or the public interest, property or safety from harm;
2. In some cases, we may provide your relevant information to relevant dispute resolution institutions in order to resolve disputes or controversies related to you;
3. In other circumstances required by laws and regulations and regulatory authorities.
4. With third parties involved in some capital transactions
If we enter into a merger, acquisition, restructuring, separation, bankruptcy, transfer of assets or similar transaction and your personal data may be transferred as part of such transaction, we will notify you and request the new owner to continue to comply with and fulfill the Privacy Policy (including the purpose and method of use of your personal data, security measures, etc.) in its entirety. We will require the recipient to obtain your consent again if the new owner intends to change the original purpose for the use of your personal data or the method of processing it.
(II) How we disclose your personal data
1. Disclosure in games
You understand that Our Products and/or Services have social attributes and that other players and users may see your profile (such as nickname and profile picture), activities that you have participated within the games, and messages that you have posted.
2. Disclosure of violations
Please note that if you are held liable for violating our Service Agreement or any laws and regulations while playing our games, we may disclose the punishment results along with your relevant account information.
Other than in the above situations, we will not disclose your personal data that you have not disclosed or that has not been legally disclosed except in accordance with laws and regulations or with your consent. Moreover, we will take safety precautions that meet industry standards to process such personal data according to applicable laws and regulations under the premise of complying with the relevant legal procedures and fulfilling our relevant legal obligations.
VII. How We Protect Your Personal Data
We take safety technical measures that meet industry standards, along with supporting protection measures at different levels, including organizational structure and management system, to protect your personal data from leakage, destruction, misuse, unauthorized access, unauthorized disclosure and alteration, to the fullest extent.
1. Technical measures for data safety
Our specific protection measures include: successfully applying for ISO/IEC 27001, ISO/IEC 29151, and ISO/IEC 27701 certification for our information safety management systems with respect to Our Products and/or Services; using safe channels and other security and encryption technologies to transmit our users’ personal data and to ensure the confidentiality and integrity of such data during the transmission process; storing our users’ personal data with security and encryption technologies, building a data security isolation domain, and implementing a sound data backup and recovery mechanism; monitoring and auditing the whole life cycle of our users’ personal data to prevent unauthorized access, public disclosure, use, modification, and artificial or accidental damage or loss.
2. Organizational and management measures for data safety
We have set up a dedicated department responsible for personal data protection and have formulated internal control and management systems such as specifications for safe use of business data and the management system of data cooperation. We organize our employees to participate in training related to information safety protection on a regular basis in order to enhance their awareness and skills towards personal data safety compliance. We take safety storage measures such as data classification and rating. We strictly control the data access permission system, adopt multi-factor identity authentication technology, and monitor data processing behaviors to avoid unauthorized access to or use of our users’ personal data.
3. Handling of security incidents
We operate a security emergency response center and have formulated a number of security management systems and emergency response plans which clarify the reporting process and the emergency response process in case of security incidents. When a security incident regarding personal data unfortunately occurs, we will activate emergency response plans to prevent the security incident from getting worse and notify you by pushing a notice, making an announcement, etc.
Please acknowledge and understand that the Internet is not an absolutely secure environment and that we cannot fully guarantee or warrant the security of our services per se or any information that you provide for us even though we have taken the protection measures set forth above. If your personal data is leaked, your personal and property safety may be affected. Therefore, we strongly recommend that you enhance your security consciousness and take security measures to assist us in keeping your account safe. If you find that your personal data has been leaked, please contact us immediately so that we can take appropriate measures to protect the security of your data.
VIII. Retention of Personal Data
As a general rule, we store your personal data only for the purpose of providing our services and for the shortest period of time. We will delete or anonymize your personal data according to relevant laws and regulations when you voluntarily delete your personal data or when our promised storage period has expired. However, we may change our promised storage period in order to comply with legal requirements under the following conditions:
(1) To comply with applicable laws and regulations;
(2) To comply with court decisions or rulings or other legal proceedings;
(3) To comply with the requirements of relevant governmental organs or legally authorized organizations;
(4) When we reasonably believe that compliance with relevant laws, regulations and other provisions is required;
(5) For purposes reasonably necessary for enforcing relevant service agreements or this Policy, protecting the public interest, or protecting our personal or property safety or other legitimate rights and interests as well as those of our affiliated companies, our partners, our other users or our employees.
In particular, if we use your personal data to make a decision that directly affects you as a Canadian user, we will retain that data for at least one year after it is used so that you have a reasonable opportunity to access it. Even if you change or cancel your consent to our collection, use, sharing or disclosure of your personal data, we may still retain such data if there are legal grounds.
When Our Products or Services are discontinued, we will notify you by pushing a notice, making an announcement, etc., and we will delete or anonymize your personal data within a reasonable period of time.
IX. Your Rights
You have legal rights to your personal data as provided by applicable laws and regulations and are allowed to make choices freely. Your rights and choices may include but not limited to:
1. The right to access to your personal data
You have the right to inquire about or access your personal data related to Our Products and/or Services, either by contacting us directly or by inquiring about or accessing your personal data directly within Our Products and/or Services. The inquiry and access features provided in Our Products and/or Services include:
Inquiry about/access to your account information: You can log in to your personal account at any time from the relevant pages to access your personal data in your account, including: profile picture, nickname, personality signature, etc.;
Inquiry about/access to your user information: You can access part of your user information at any time from the relevant pages, including: battle status, order information, etc.
2. There right to correct/modify your personal data
You have the right to correct/modify your personal data in Our Products and/or Services, either by contacting us directly or by making corrections or modifications directly within the Products and/or Services.
3. The right to delete your personal data
You have the right to delete all or part of your personal data in Our Products and/or Services, either by contacting us directly or by making deletions directly within the Products and/or Services.
If we have collected, used, shared or otherwise processed your personal data in violation of laws or your agreement with us, you may directly request us to delete your personal data and ask us to notify the third-party recipient to delete your personal data, unless the data has been anonymized or otherwise processed according to laws and regulations.
You understand and agree that after you or we have assisted you to delete your relevant data in Our Products and/or Services, we may not be able to delete the corresponding data from our backup system immediately due to restrictions of the security technology that we adopt. In this case, we will store your personal data safely and isolate it from any further data processing until it is deleted or anonymized when the backup system is updated.
4. The right to withdraw consent
If you intend to change the scope of authorization for relevant permissions and data, you may do so through your hardware device or on the relevant function settings page in Our Products and/or Services. For example, on iOS terminal, you may click on “Settings - Privacy” to withdraw the system permissions.
5. Other rights
In addition to the rights listed above, if applicable laws and regulations grant you other rights in connection to your personal data, such as the right to restrict/reject processing of your personal data, we will do our best to ensure the realization of such rights according to such laws and regulations.
X. Update of This Policy
Because of the continuous innovation and development of our business model and technical features, we may update the terms of the Privacy Policy from time to time and notify you of such updates according to applicable laws and regulations through one or more ways, such as posting notices, pushing messages, adding pop-ups, and sending emails, so that you can review the updated Privacy Policy before you choose to continue using our services. We will not compromise or infringe upon your personal rights and interests as described in this Policy without your explicit consent.
XI. Other information
If any dispute arises from the execution or performance of this Policy, both parties shall resolve it through friendly negotiations whenever possible. If negotiations fail, either party may submit the dispute for arbitration to the Hong Kong International Arbitration Centre in accordance with the Administered Arbitration Rules of Hong Kong International Arbitration Centre valid at the time of submission. This arbitration provision shall be carried out in accordance with the laws of the Hong Kong Special Administrative Region to the fullest extent permitted by law. The arbitration award shall be final and binding on both parties. The place of arbitration shall be Hong Kong, and the language of arbitration shall be Chinese.
Hongkong Skymoons Interactive Co., Ltd.