Thank you for reading our Privacy Policy. Cookie Entertainment Company Limited (“Cookie”, “we” or “us”) is the global publisher and data controller of this game. When you are playing our games, visiting our websites or using our other online services (collectively “Service”), this Privacy Policy shall apply.
PLEASE READ THIS PRIVACY POLICY CAREFULLY. IT DESCRIBES DETAILS ABOUT HOW WE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION YOU SHARED WITH US.
IF YOU ARE UNDER 18, DO NOT PROVIDE ANY PERSONAL INFORMATION WITHOUT APPROPRIATE PERMISSION UNDER APPLICABLE LAW.
It is our policy to comply with applicable data protection laws.
1. Special Notice Regarding Game Status
Please note that this Game is currently in a pre-download phase. The Game is not yet operational and cannot be played at this time. During this phase, we do not collect any personal information directly within the Game. However, please be aware that certain third-party service providers (such as advertising attribution partners) may collect information in connection with your download or installation of the game, as permitted under their respective terms and privacy policies. During the current pre-download phase, we process information only for the following limited purposes: a) to facilitate and verify the successful download and installation of the game; to measure the effectiveness of advertising campaigns through third-party attribution services; and to comply with applicable legal and regulatory obligations.
2. What personal information do we collect?
We collect information that you voluntarily provide to us, information that we collect automatically through your use of the services, and certain information we obtain from third party sources. The sample of information shows as following:
ⅰ. Information You Voluntarily Provide
- the chat log and message you communicated or posted in our Service, regardless of whether it is in the form of text, voice, image or video.
- your purchase or transaction record in the Service through Apple Store, Google Play, PayPal, and other payment method
ⅱ. Information We Automatically Collect
- Internet Protocol (IP) address
- broad geographic location (e.g. country or city-level location) based on your IP address
- device information, including the device type, device model, device maker, device operating system and its language or other technical data like processor, or combination of this data available from a device for a developer for checking the device compatibility with a particular application
- device identifiers, such as a universally unique identifier (“UUID”), referring to the small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may convey information to us about how you browse and use the Service and may remain persistently on your device, to help you log in faster and enhance your navigation through the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.
- Advertising ID, i.e. Identifier for Advertisers (“IFA”) on Apple and Google Advertising Identity (“GAID”). These are unique identifiers for mobile device that advertisers use for personalized advertising. They are consistent across all mobile applications and thus allow cross-app tracking. On Apple, you can opt out of it by choosing the “limit ad tracking” option in your privacy settings. On Google Android, you can opt out of these ads by choosing “Opt-out of personalized ads”. Advertising IDs are non-permanent, non-personal identifiers, which are uniquely associated with your device.
- Progress in the game:
log data (time and period)
in-game items and behaviors
achievements you have completed in the game
other users you referred
- Some of the automatically collected information may be collected through cookies as explained further under the heading “Cookies and other tracking Technologies” below
ⅲ. Information We Obtain from Third Party Sources
If you log in to our Service using social network accounts, such as Facebook, Google, Apple Game Center (“Third-Party Social Networks”), we may collect personal information you authorized the Third-Party Social Networks to share with us to pre-populate our sign up form. Exactly what information we receive from your social media will depend on your social media privacy settings, but it would typically include your basic public profile information such as
- your username
- profile picture
- gender (with your option)
- your friends playing the same Game
- other information from Third-Party Social Networks that you have permitted the Third-Party Social Networks to share with us
- any information you have made public on the Third-Party Social Networks.
You should always review, and if necessary, adjust your privacy settings on the Third-Party Social Networks before linking or connecting them to our Service.
- Advertising Networks: We may receive information about your interaction with our advertisements from ad networks to track campaign effectiveness.
- Analytics Providers: Third-party analytics tools may share aggregated usage data to help us improve the Service.
- OS/Platform Providers: Operating systems and device platforms may provide technical data to ensure compatibility.
- Business Partners: If you participate in co-branded events or promotions with our business partners, we may receive relevant information from them with your consent.
ⅰ. Information You Voluntarily Provide
Cookies
ⅱ. Information We Automatically Collect
- Internet Protocol (IP) address
- device information, including the device type, operating system and version
We also use analytics tools on our Service to retrieve information from your device, including your preferred settings, which in-game adverts you may have viewed, and the means by which you were referred to our Service. We may also deliver advertisements and provide website analytics tools on non-Cookie sites and services, and we collect information about page views on these third party sites as well. We treat this information as personal information if we combine it with or link it to any of the identifying information mentioned above. Otherwise, it is used in the aggregate or in anonymized form only.
The data elements in the above chart are examples only. From time to time we may change the information requested upon registration or with respect to certain features or services, so this may not be a complete list.
You can access certain portions of our Service without providing us with any personal information. However, you will not be able to utilize certain features that require registration or receive materials unless certain information is provided. The processing of this personal information is lawful as it is necessary for the performance of our Service. Where processing is not necessary for the performance of the Service, your consent to such processing will be requested where required under applicable law.
For users in certain jurisdictions, please refer to the Special Section for Certain Jurisdictions for further information about how we collect and process your personal information and your related rights.
c) No special categories of information
We do not initiatively request or intend to collect any “special categories of information” as defined in Art.9 of the General Data Protection Regulation (“GDPR”), such as any information on health, race, religion, political opinions or philosophical beliefs, sexual preferences or orientation. We also want to kindly remind you to be cautious when sharing this information about yourself (or others) in our forums.
Our Games enable in-app purchases and we collect your purchase or transaction record in the Service. However, we do not process payments for in-app purchases nor have access to your credit card information.
Payment transactions for in-app purchases are mostly completed through the app store via your App Store account or Google Play account, or platforms, or through the payment method you choose such as VISA, or PayPal, etc. Any post-purchase processes are controlled by the Apple and Google stores and other payment providers and are subject to those payment providers’ specific terms of service. Please review the privacy policies and terms of service of your Apple and Google stores and the payment providers you choose.
e) Cookies and other tracking technologies
Our Services and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies (collectively, “Tracking Technologies”) which help us provide and improve our Services, as well as the usage of our Apps, Games and Services as a whole. Cookies are small text files (composed only of letters and numbers) that a web server places on your computer or mobile device when you visit a webpage. When used, the cookie can help make our Services more user-friendly, for example by remembering your language preferences and settings. You can find more information about cookies at www.allaboutcookies.org.
For the purpose of providing Service, we use following cookies:
- Strictly necessary cookies: These cookies are necessary for the function of our Services and cannot be rejected if you are going to use our Services.
- Performance cookies: These cookies allow us to collect information about your online activity (e.g. the duration of your use of the Services). This helps us to improve the features of our Services through traffic analysis by collecting information on how you and other visitors use and move around our Services.
- Analytics cookies: These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site.
You can manage cookies through your browser settings:
- For most web browsers, you can adjust settings to block or delete cookies, or receive notifications when cookies are placed.
- On mobile devices, you can control advertising IDs via device privacy settings (e.g., “Limit Ad Tracking” on iOS, “Opt-out of personalized ads” on Android).
If a browser or mobile device is set not to accept cookies or if a user rejects a cookie, some portions of the Website or Service may not function properly. For example, you may not be able to sign in and may not be able to access certain Website or Service features or services.
f) Data collected to prevent cheating and unauthorized software
When you run our Game software or receive our Service, this may involve software functions designed to detect cheating or unauthorized and malicious programs. In this context, we may access, collect, monitor and/or remotely store screenshots of game play, information relating to hardware capacity, modifications related to our Game software, signatures, profiles or names of known or suspected unauthorized or malicious third party programs, files or processes that enable or facilitate cheating, unfair advantage or hacking of the Games or Service. If circumstances suggesting unauthorized or malicious programs are detected, the Game software may also communicate to us the users account and User ID and information about the unauthorized or malicious program or its use.
We see this processing as necessary for the purposes of the legitimate interests pursued by us, where legitimate interest is not sufficient for the collection, your consent to such processing will be requested where required under applicable laws.
3. For which purposes do we use your personal information?
We use your personal information to provide products and services you ask for, to communicate with you, to improve our services, and for other purposes including those set out in the chart below.
Personal Information | Purpose | Legal basis relied on according to GDPR (only users located in the European Economic Area (“EEA”) and UK) |
Mobile Games | ||
Registration information: ● User name; ● User ID; Facebook (with your authorization): ● Facebook ID ● Profile picture ● Gender (with your option) ● Your friends playing the same Game ● Information you have made public on Facebook ● Other information you give permission to Facebook to share with us Google Play (with your authorization): ● Gmail address ● Nickname ● Profile picture ● Information you have made public on Google ● Other information you give permission to Google to share with us X (Twitter) ● User ID on X ● Other information you give permission to share with us (e.g., nicknames, etc.). LINE ● User ID on LINE ● Other information you give permission to share with us (e.g., nicknames, etc.). Guest ● User ID on Guest ● Other information you give permission to share with us (e.g., nicknames, etc.).
| To create your account for the Mobile Games per your request and phone number may be also used for pre-registration | Necessary for the performance of the contract for the provision of the mobile game App between us, in line with art. 6.1(b) of the GDPR Our legitimate interests to provide an effective and functional Service, in line with art. 6.1(f) of the GDPR |
The chat log and message you communicated or posted in our Service, regardless whether it is in the form of text, voice, image or video | To deliver the Games and/or the in-game service to you | Necessary for the performance of our Service, specifically, the chat function within the game, in line with art. 6.1(b) of the GDPR Our legitimate interests to provide an effective and functional Service, in line with art. 6.1(f) of the GDPR |
Your purchase or transaction record in the Service through Apple Store, Google Play, and other payment method: ● User ID ● Cost ● Purchased product | To keep the record of your transaction history and to deliver the product you purchased to you | Necessary for the performance of our Service, specifically, the in-game purchase, in line with art. 6.1(b) of the GDPR Our legitimate interests to provide an effective and functional Service, in line with art. 6.1(f) of the GDPR |
Any information you submit to our support team by email or other means for any reason, for example, asking for customer support | To provide technical support, customer service and ensure the continued smooth operation of our Service | Necessary for the performance of our customer service, in line with art. 6.1(b) of the GDPR Our legitimate interests to provide an effective and functional Service, in line with art. 6.1(f) of the GDPR |
Progress in the game:
| To keep the record of your account, to collect and anonymize usage data and to improve the functionality of our Games and Service (including anti-cheat measures) | Our legitimate interests in reviewing the performance of, and preventing the misuse of, our Service and improving its functionality, in line with art. 6.1(f) of the GDPR |
| To improve our games and services and to make our application compatible with your device | Our legitimate interests in performing and improving our Service, in line with art. 6.1(f) of the GDPR |
Screenshots of game play, information relating to hardware capacity, modifications related to our Game software, signatures, profiles or names of known unauthorized or malicious third party programs, files or processes that enable or facilitate cheating, unfair advantage or hacking of the Games or Service | To prevent or investigate actual or suspected fraud, hacking, infringement, or other misconduct in any of our products and services | Our legitimate interests in detecting and preventing fraud, other crimes and the misuse of our Service, in line with art. 6.1(f) of the GDPR |
Information from advertising partners. E.g. if you click on an advertisement to direct you to one of our services or games (such as an advert of one of our Games in other publisher’s game), we may receive the information. | To know which ad network and advertising campaign your installation was originated from and to pay that advertiser | Our legitimate interests in promoting our Service, in line with art. 6.1(f) of the GDPR |
Other personal information you provide in connection with your voluntary participation in surveys, sweepstakes, contests, promotional offers, and other activities | To request feedback, perform research and analysis and to enable us to operate, develop, customize and improve the Service and our publications, products and services | Our legitimate interests in performing research and improving our Service, in line with art. 6.1(f) of the GDPR |
All Games | ||
● Date of birth ● Country/region
| To determine whether an individual can use the games and certain features | Necessary for us to assess whether to enter into a contract, in line with art. 6.1(b) of the GDPR Our legitimate interests to provide an effective and age-appropriate Service, in line with art. 6.1(f) of the GDPR |
Websites | ||
● Internet Protocol (IP) address ●Device information, including the device type, operating system and version | To improve our games and services and to make our application compatible with your device | Our legitimate interests in performing and improving our Service pursued by us, in line with art. 6.1(f) of the GDPR |
Legal Basis for Data Processing
For all users, our data processing activities are based on the following legal grounds (as applicable under local laws):
Where processing is not necessary for the performance of the Service or we cannot rely on legitimate interests in a particular case (because for example your privacy rights and freedoms in that case outweigh the legitimate interests), your consent to such processing will be requested as appropriate under applicable law.
a) Compliance with our legal obligations
We may use your information when we are required to do so by law, or pursuant to valid legal requests.
b) For purposes for which you give us consent
We may also collect and use personal information for specified purposes when you give us your consent to do so.
4. Do we share personal information? If so, how we share your information?
We may share your personal information with certain third parties subject to the ways that are described in this Privacy Policy or as otherwise required by law. We do not sell or trade any personal information about our visitors and users to any third parties.
Please note that nothing herein restricts the sharing of aggregated or anonymized information, which may be shared with third parties without your consent.
We may share personal information with our vendors, consultants and other service providers (“Service Providers”) such as Appsflyer, Google as our analytic service provides and our vendors who are engaged by or working with us in connection with the operation of the Service and who need access to such information to carry out their work for us. We may also share personal information with auditors, accountants, lawyers, financial or professional advisers. We provide access to the information they may need to perform our services under reasonable confidentiality terms. In some cases, the Service Provider may directly collect the information from you on our behalf. We inform Service Providers that they are not permitted to use personal information they obtain from you other than to provide the services for us. However, we are not responsible for any additional information you provide directly to these Service Providers and we encourage you to become familiar with their practices before disclosing any personal information directly to such Service Providers.
We may share your personal information with our affiliated companies (entities that directly or indirectly control, are controlled by, or are under common control with Cookie) for the purposes stated in this Privacy Policy. Affiliates are required to comply with the terms of this Policy and may not use your information for independent marketing purposes.
If you participate in co-branded events, promotions or collaborations with our business partners, we may share relevant personal information with such partners to facilitate the activity (e.g., prize delivery, event participation verification). We will ensure such partners are bound by confidentiality obligations.
d) Sharing when you give us consent
From time to time, we may also share personal information with third parties when you give us your consent to do so.
e) Sharing in response to legal obligations
We reserve the right to disclose your information (including personally identifiable information) in response to law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may access, disclose or preserve personal information, including the content of your communications, in the good faith belief that we are lawfully authorized by public authorities or required to do so, including to meet national security or law enforcement requirements or that doing so is reasonably necessary or appropriate to comply with the law or with legal process or authorities, respond to any claims, or to protect the rights, property or safety of Cookie, our users, our employees or the public, including without limitation to protect Cookie or our users from fraudulent, abusive, inappropriate or unlawful use of our Service.
f) Sharing due to merger, acquisition and similar situations of the transfer of company assets
Information we collect, including personal information, may also be disclosed or transferred as part of, or during negotiations of, any merger, sale, divestiture, or transfer of all or a portion of the company assets, financing or acquisition or in any other situation where personal information may be transferred as one of the business assets of Cookie. You will be notified via email and/or a notice of any change in ownership, uses of your personal information, and choices you may have regarding your personal information.
Your personal information will be transferred and shared among Cookie Entertainment Company Limited and its affiliated companies as necessary. Your information will be accessible from and processed in servers located globally. Your personal information will be stored in services located in the United States of America and your in-game data will be stored in servers located in Japan to ensure the proper operation of our services and your experience. We also have support, technical and other teams who may support the service, including from China.
As we are a global company, your personal information may be transferred to and processed in countries other than the country in which you reside. Although these countries may have data protection laws that are different to the laws of the country in which you reside, we ensure appropriate safeguards in place so that your personal information will remain protected in accordance with this Policy. The information relating to you and your use of our Games may be transferred internationally, among our affiliated companies.
You acknowledge and understand that the laws regarding personal information in the country or region to which the data is transferred may be less stringent than the laws of your country and may not offer the same protections or rights as the laws of your country. If you object to your personal information being transferred or used as described in this Policy, please do not use the Service.
h) Push notifications and local notifications
We may, with your consent, send push notifications to your mobile device to provide game updates and other relevant messages. You can manage push notifications from your mobile device’s settings page for the relevant game and/or from the settings page within the relevant mobile game. We may also send local notifications to your mobile device to provide game updates and other relevant information. To manage local notifications, you should consult your mobile device’s settings page for the relevant game and/or from the settings page within the relevant mobile game.
When you communicate with other players within a game or utilize any interactive features available on the Service, such as instant text messaging, forums or chat rooms, such communications and postings are transmitted through our servers, and we monitor such communications and postings (e.g. via profanity filters), including those that are designated as “private,” to the degree that laws and regulations enable us to do this, for purposes of protecting the rights and safety of us and our users, including identifying and removing content that violates our policies. Therefore, as the abovementioned performance monitoring might involve access to these communications and postings, you should not use these communication channels for private or confidential messages.
j) Functionality Currently Unavailable
Please be advised that the following game features are not available while the game remains in pre-download status:
- In-game chat, messaging, or social features;
- Push notifications or in-game alerts;
- Customer support services via in-game channels;
- Anti-cheat or unauthorized software detection systems;
- In-app purchases or any payment processing.
Accordingly, no personal information is collected or processed in relation to these features at this time.
5. What steps do we take to protect your personal information?
We use physical, technical, and administrative measures to safeguard information in our possession against loss, theft and unauthorized use, disclosure, or modification. These measures include:
- Technical safeguards: Encryption of data in transit and at rest, firewalls, access control systems, and regular security audits.
- Administrative safeguards: Employee training on data protection, access restrictions to personal information, and data protection policies.
- Physical safeguards: Secure storage facilities for servers and physical records.
Please note, however, that no data transmission or storage can be guaranteed to be 100% secure. As a result, although we strive to protect the information we maintain, we cannot ensure or warrant the security of any information that you transmit to us.
You should note that our Service Providers may be responsible for processing, handling or storing some of the personal information that we receive. They are not authorized to market to you independently. These Service Providers are contractually required to safeguard and secure the personal information they received from us. Although we strive to protect your personal information, you should be aware, however, that information sent over the Internet is not necessarily secure and may be intercepted or accessed by third parties. Therefore, we cannot guarantee the security of such information, and we are not responsible or liable for any such interception or unauthorized access.
6. How long do we retain your personal information?
Generally, we delete the information as soon as we do not need it for the purposes described in this Policy. The retention periods are as follows:
- Account information and game data: Retained for as long as your account remains active, or until the game/platform is discontinued.
- Log data, chat data, and in-game activity data: Retained for several minutes to several days, unless longer retention is required for legal or security purposes.
- Transaction records: Retained for the duration of your account activity plus the period required by applicable tax and commercial laws.
- Survey responses and event participation data: Retained for the purpose of the survey/event plus 12 months, unless you consent to longer retention.
However, we may continue to retain certain data to the maximum extent permitted by applicable laws, such as:
- To comply with legal obligations (e.g., tax, audit requirements).
- To resolve disputes or enforce our agreements.
- To protect the rights, property or safety of Cookie, users or the public.
7. What choices do you have regarding the use of your personal information?
As the subject of the personal information, you are entitled to have the rights provided by the privacy laws in your jurisdiction. Your rights may include part or all of those described underneath. You can exercise your rights entitled by the privacy laws in your jurisdiction at any time by sending us relevant requests to our DPO at chenlixhk@gmail.com. To verify your identity, we may request you to provide information such as your account details, registered email address, or other identifying information. We will respond to all valid requests within thirty days.
You have the right to access personal information we hold about you, how we use it, and who we share it with.
You have the right to correct any personal information held about you that is inaccurate. For example, you can contact us if your email address has been changed and we should replace your old email address.
c) Right to have your data deleted
You can delete your account (i.e. the account on our Service, excluding any account on the third party platforms, such as Apple Store and Google Play), or remove certain personal information that we have stored about you. However, please note that we may need to retain personal information if there are valid grounds under data protection laws for us to do so (e.g., for the defense of legal claims or freedom of expression) but we will respond to you and let you know if that is the case.
d) Right to restrict processing and withdraw your consent
You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. You may withdraw your consent at any time by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds other than your consent, for example, when the processing is necessary to fulfil the obligations of a contract, processing is necessary to protect the vital interest of you or another natural person, or other legitimate reasons under data protection laws.
e) Right to take your data with you
You have the right to receive a copy of certain personal information we process about you in a structured, commonly used and machine-readable format. For example, you can contact us to receive your data if you want to upload it to another service. However, please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (e.g. where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).
f) Right to object to how your data is handled
You have the right to object to our processing of personal information about you. In particular you have the right to object to being profiled for the purposes of direct marketing (for example where we collect information about you in order to decide what marketing to send you, based on your preferences or personal characteristics).
g) Right to lodge complaints to the supervisory authority
You have the right to lodge complaints about the data processing activities carried out by us before the competent data protection authorities.
If we refuse to take action on your request, you may appeal the decision by submitting a written appeal to the contact email provided above. We will review the appeal and respond within thirty days of receipt.
8. How do we protect children?
The minimum age for using our Service varies by jurisdiction:
- United States: 13 years old (18 years old in certain states such as Texas).
- European Union/UK: 16 years old (or the age of consent under local law, if higher).
- Japan: 14 years old (or as required by local law).
- Other regions: 18 years old, unless local law specifies a lower minimum age.
Our Service is not directed to children under the applicable minimum age. If we discover that we have inadvertently collected information from children under such age, we will delete the child’s information from our systems in accordance with applicable law.
- For children below the minimum age, verifiable parental or guardian consent is required to use the Service.
- We may use third-party verification services (e.g., Kids Web Services) to confirm parental consent.
- Parents/guardians may access, correct, or delete their child’s personal information, or revoke consent, by contacting us.
If you become aware that personal information about a child under the applicable minimum age has been provided to us, please immediately contact us at: chenlixhk@gmail.com.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily or any questions, comments on this Policy or wish to realize your rights described in this Policy, please contact us via:
- Email: chenlixhk@gmail.com
- Data Protection Officer: Contact via the above email with the subject line “Attention: Data Protection Officer”
From time to time, we may revise this Policy to reflect changes to the scope of the Services or for other reasons. Therefore, it is important to check the effective date of this Policy posted here each time you use the Services. By continuing to use the Services after we make changes, you indicate your consent to those changes.
If the changes are material (e.g., significant changes to data collection or sharing practices), we will notify you via email, in-game notification, or a prominent notice on our website at least thirty days before the changes take effect.
11. Special Section for Certain Jurisdictions
If you are located in the EEA or UK, the European Union General Data Protection Regulation (“EU GDPR”) or UK Data Protection Regulation (the “UK GDPR” and, together with the EU GDPR, the “GDPR”) apply to the collection and processing of your personal data by us.
For the purpose of the GDPR, the data controller is Cookie Entertainment Company Limited. This means that Cookie Entertainment Company Limited is responsible for determining how and why your personal data is processed.
As outlined in the “Data collected to prevent cheating and unauthorized software” section of the Policy, we may also process your personal information to detect cheating or unauthorized and malicious programs. We see this processing as necessary for the performance of our Services, pursuant to art. 6.1(b) of the GDPR and for our legitimate interests to ensure the functionality of, and prevent the misuse of, our Service, in line with art. 6.1(f) of the GDPR.
Where processing is not necessary for the performance of the Service or where we cannot rely on legitimate interests in a particular case (e.g. because your privacy rights and freedoms in that case outweigh the legitimate interests), your consent to such processing will be requested as appropriate under the applicable law.
For complementary information regarding the purposes for which we use your personal information, please see the “For which purposes do we use your personal information?” section of this Policy.
Please note that we have implemented software development kits (“SDK”) in our Service. SDK providers may collect limited technical data to enable functionality (e.g., analytics, advertising). We ensure SDK providers comply with GDPR requirements.
We are a multinational group with companies registered outside the EEA and UK. Our servers and main business operations are located globally and some of our businesses are primarily in China or the United States of America, as described in the “International transfer” section of this Policy. By using our Service and providing us with information, you acknowledge and understand the transferring, storing and processing of your information on computers located in China and the United States of America in the manner described in this Policy. If you object to your personal information being transferred or used as described in this Policy, please do not use this Service.
For any transfers of data outside the EEA or the UK, the data transfer will be under the European Commission’s standard contractual clauses for the transfer of personal data to third countries (specifically, module one (controller to controller transfer) and module two (controller to processor transfer), as relevant), or the UK Information Commissioner’s international data transfer addendum to the EU standard contractual clauses, as relevant, unless the data transfer is to a country that has been determined by the European Commission or the relevant UK authorities, as applicable, to provide an adequate level of protection for individuals’ rights and freedoms for their personal data. Please contact us at chenlixhk@gmail.com should you wish to examine a copy of the EU standard contractual clauses or UK international data transfer addendum.
This section provides additional detail for residents of California and certain other U.S. states on how we collect, use and disclose Personal Information, and the rights such residents may have with respect to that Personal Information. For the purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (the “CCPA”), as well the meaning given to “personal data” under other U.S. state privacy laws. Unless otherwise specified, Personal Information includes “sensitive personal information” as defined by the CCPA and “sensitive data” as defined by other U.S. state privacy laws.
Processing of Personal Information
We collect, use and disclose, and have during the past 12 months collected, used and disclosed, the following categories of Personal Information. In the past 12 months, we have disclosed such categories to our Service Providers and Subsidiaries, as described further in the “Do we share personal information? If so, how we share your information?” section above.
- Device information
- Internet/Network Information, such as information regarding a consumer’s interaction with an internet website application, or advertisement
- General Location Data, such as IP address
The purposes for which we use these categories of Personal Information are described further in the “For which purposes do we use your personal information?” section of our Privacy Policy. Our relevant data retention practices are addressed in the “How long do we retain your personal information?” section of our Privacy Policy.
We do not and have not in the past 12 months “sold” or “shared” your Personal Information, and we do not knowingly sell or share (as defined by the CCPA) the Personal Information of minors under 16 years of age. We also do not process Personal Information for targeted advertising purposes.
Sensitive Personal Information and Deidentified Data
We do not use or disclose Sensitive Personal Information (as defined by the CCPA) for purposes other than those expressly permitted under the CCPA. Additionally, we will not attempt to re-identify de-identified information that we derive from Personal Information, except for the purpose of determining whether our de-identification process satisfies legal requirements.
Depending on where you live, you may have the rights listed below in relation to Personal Information that we collect about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
- Right to Know/Access: The right to request information about the categories of Personal Information we collect, the categories of sources from which we collect it, the purposes for which we process it, and the categories of third parties, or a list of specific third parties, to whom we disclose it.
- Right to Delete: The right to request that we delete Personal Information we collected from you.
- Right to Correct: The right to request that we correct inaccurate Personal Information we maintain about you.
- Right to Opt Out of Sale/Share: To the extent we sell or share your personal information as the term “sell” or “share” is defined under California, Colorado, Connecticut, Nevada and Virginia Privacy Laws, you have the right to opt out of the sale of sharing your Personal Information and sharing your Personal Information for targeted advertising.
We will not unlawfully discriminate against you for exercising your rights. Please submit your request by sending an email to chenlixhk@gmail.com. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity, including by asking you to verify information about your use of the Services. If you would like to use an authorized agent to exercise your rights, we may request evidence that you have provided such agent with the power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.
We recognize the Global Privacy Control opt-out preference as a valid request for residents of certain states to opt-out of the sale and sharing of the personal information processed through the browser you are using. This controls whether your browser sets third-party cookies on our websites that are used for targeted advertising. This is only based on browser settings and not your device settings. Please see the list of browsers that support GPC and instructions on how to enable it.
If we refuse to take action on your request, you may be entitled to appeal this refusal within a reasonable period after you have received notice of the refusal. You may file an appeal by contacting us at chenlixhk@gmail.com.
In the United States, the minimum age for users is 13. With the exception of specific states, such as Texas, where the minimum age shall be 18. We therefore do not knowingly collect any personal information online from children under the minimum age in the United States without parental consent, unless permitted by law. If we learn that a child under the minimum age has provided us with personal information without parental consent, we will delete it in accordance with applicable law.
Some web browsers may transmit “do not track” signals to the websites and other online services with which the browser communicates. Unless otherwise specified, we currently do not take action in response to these signals and we do not process your Personal Information in a manner that would require us to respond to similar opt-out preference signals.
Pursuant to Article 28(2) of the Japanese Act on the Protection of Personal Information, we provide the following information regarding international data transfers:
- Countries where data recipients are located: United States, Japan, China.
- Personal information protection systems of foreign countries: For more details, refer to the website of the Personal Information Protection Commission of Japan: https://www.ppc.go.jp/personalinfo/legal/kaiseihogohou/#gaikoku.
- Measures taken by data recipients: We ensure that third parties receiving your personal data implement measures corresponding to the OECD Privacy Guidelines.
The minimum age for using the Service in Japan is 14 years old. We do not knowingly collect personal information from children under 14 without verifiable parental consent.
12. Test Features and Pre-Download Phase Notes
You may have the opportunity to use “test” features for a limited time (e.g., alpha, beta, test mode). These features are made available to test new ideas and improvements for the Service. By participating in such tests, you acknowledge that we may process data related to these features to ensure functionality, evaluate whether to modify or roll out the features, and collect your feedback. We will only process such personal data for as long as necessary to fulfil these purposes, and thereafter will take steps to delete or de-identify the information (including any feedback you provide).
During the pre-download phase, as specified in Section 1, we do not collect any personal information directly within the Game. Third-party service providers may collect limited information in connection with download/installation, as permitted by their own privacy policies. We only process information during this phase to facilitate download/installation verification, measure advertising effectiveness, and comply with legal obligations.
Updated on December 29th, 2025