Demihumans Game Privacy Policy

Last updated: July 8, 2022

The Data Controller under this Privacy Policy is AUTHOR KURT LLC, an Indiana limited liability company having a place of business in Indianapolis, Indiana, doing business as Demihumans™ (“Demihumans”, “we”, “our”, or “us,” as appropriate).

We recognize and value the privacy of people (“you” or “User”) who visit our website(s), use or access our game(s), whether played on mobile devices, PCs, our website(s) or other approved platforms (“Game(s)”), and/or otherwise use or access any of our provided services (“Game Services,” or “Services”).

The Policy describes why and how we collect, store, and use your personal data, and the choices and rights you have about the personal data you provide or that we collect in connection with the Game. By accessing our website(s), using our Services, or otherwise using the Game, you acknowledge that you have read, understood, and accepted the following terms. In the event that you do not agree to these terms, the basic functions of the Game may not work, which may prevent you from using them.

The minimum age to create an Account (“Account”) with Demihumans is 13 years old. Insofar as certain countries apply a higher age of consent for the collection of personal data, we require parental or guardian consent before an Account is created and personal data associated with it is collected.

Demihumans may periodically amend the Policy. We will announce to you by revising the date at the top of this Privacy Policy, and may obtain your consent (and/or the consent of your parent/guardian, if applicable) a subsequent time, if we make any material changes to the Policy. You acknowledge and agree to check the updated terms regularly. If you do not agree to the processing of your personal data in the way that this Policy describes, please do not provide your information (when we request) and stop using our Services.

1. What Data We Collect and Process:

We collect or receive Data in three ways: (a) you directly provide Data to us, such as by creating an account by email, (b) we collect Data on an ongoing basis, such as through cookies and related technologies, and (c) we receive Data from third party with your consent, such as social media platforms.

 

1.1 Data You Directly Provide to Us

1.1.1 Account Data: including email address, password (if you choose to use our services by email), username, nickname, and profile picture. We collect such information on the legal basis of performing our contract with you to provide our services, and use this information to create the account for your usage of our services as you request, and enable you to enjoy certain game features.

1.1.2 Customer Support Information. We use AIHelp customer supporting system to provide customer service. We will collect your purchase information (including purchase time, product, currency, cost), device information, user ID, and your chat data or game data associated with customer service. We use such information to help identify your account to enable us to troubleshoot problems with your account or game, as well as to communicate with you and respond to your specific requests or questions. It is necessary for us to be able to communicate with you and resolve problems.

1.1.3 Other data you provide to us:

(a) When you participate in online discussions, such as Discord, or otherwise interact with us.

(b) When you voluntarily complete a customer survey or provide feedback/requests on any of our message boards, surveys, chats, or via email.

(c) When you choose to share the live video content in game, we may collect the same.

(d) If you get the prize(s) for participating in any game-based events, we may collect your name, ID number or passport ID, delivery address, postal code, telephone number, in-game account ID and zone ID, to deliver the physical prize(s) to you, and we may collect your email address to send the digital prize(s) to you. We collect such data with your consent.

 

1.2 Data We Collect on an Ongoing Basis

We may also collect Data and other information through technologies from you when you use our services. We use this information for purposes such as modifying or improving features, managing advertising, addressing technical issues, preventing fraud, and conducting data analytics, all of which is necessary for the provision of our services. The type of information that we collect includes:

1.2.1 Internet Protocol (IP) Address. We will collect your IP Address to determine the country or regions you are in, and may lock the Services region to that, to allow you to connect to the services. We may also use your IP address to help to solve disputes concerning your account, all of which serves a legitimate legal basis for resolving issues.

1.2.2 Transaction Information. Our services enable in-app purchases and we collect your purchase or transaction record. However, we do not process payments for in-app purchases, nor do we 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 such as PayPal, or through the payment method you choose. Any post-purchase processes are controlled by the payment providers. If you make any payments in using our services, we will collect transaction information of payment platform, such as Google Play or iOS App Store (including purchase time, order number, in-game product purchased, cost, etc.). We also may collect Purchase history in-game, (including order number, User ID, purchase method, purchase amount, currency, product ID, purchase quantity, order creation time, purchase time, transaction completion time, username, role ID, role name, game server ID, game server name, SDK version number, application store version number, client IP, device Id, IDFA, device model, network operator, network type, system version number, root or jailbreak, resolution, platform, language, excluding financial information).

1.2.3 Data of Use of the Service.

(a) Gameplay data: including game setting, level, companions, stats/scores, User ID (Game ID), operating system, region ID, game server ID, player nickname, character ID, character level, player balance, account status, account binding status, registration time, latest login time, player type, and other such gameplay data;

(b) Game behavior data: including your match information in Games, your online time, click record (battle record, mall record, activity record, social category), your in-game interactions (such as friends list);

(c) Game log information and game statistics: including character ID, game account, user nickname, country code, device system version, device brand, IDFV, device model, device manufacturer, device name, screen resolution, screen orientation, CPU model, GPU information, RAM, client exported IP, phone memory, login channel ID, operator name, network type, signal strength, etc.

We collect such information for the purpose of analyzing the usage of Game features, optimizing and improving user experience, recording your game behavior and providing the Services and provide troubleshooting such as addressing and remediating technical issues and bugs. We process such data on the legal basis of Service Provision.

1.2.4 Device Data. When you use our services on a mobile platform, we may collect your device data (including application version, unique device identifier, advertisement identifier, system language, device name and model, the version of your operating system, system and its version number, MAC address), every time you log in to the Services or make an in-game purchase or use customer service, for the purpose of ensuring game security and verification, identifying and addressing bugs, assessing function for optimization, and monitoring the success of our advertising and marketing programs (if any). It is necessary for us to provide our Services and to ensure data security.

1.2.5 Security-Related Information. We may collect Security-Related Information including your SDK log data, server IP, Open ID, system information, such as system version, brand, CPU architecture, country language, as well as root status, application version, device information, including device type, IDFA, network type, brand, language region, and also jailbreak status (iOS) for security purposes, in order to detect offensive and sensitive wording to provide a fair and secure online environment. It is our legitimate interest to ensure the security of our Services. You know and understand that since there may be multiple versions of the game, the above information may be collected for the purpose of adapting, developing, and updating for devices of different versions.

1.2.6 Advertising Information. This includes Advertising ID and select device information (such as device ID, device name, device type, system and version, MAC address, IDFA), registration time and login time. We may store an Advertising ID for an advertisement, and associated device information with your profile, to track the success of our advertising and ensure security of our services. This information may be collected on the legal basis that it is our legitimate interest to ensure service security and to monitor the success of our advertising and marketing programs.

 

1.3 Data We Collect from Third-Parties

1.3.1 Connected Social Media Account Information. Most of our services support you logging in with your social media account (e.g. Google, Facebook). We may collect personal information you authorized the third-party social media to share with us, in order to pre-populate our sign up form. We will collect your information as follows:

(a) Google: We may collect your authorization ID, name (or nickname), profile picture (if any), email address, location, and whether the email address is authenticated from Google.

(b) Facebook: We may collect your authorization ID, name (or nickname), profile picture (if any), email address, location, and whether the email address is authenticated from Facebook.

We use such data to enable you to link, connect, or login to your account with a third-party service. We process such data on the legal basis of Service Provision.

The exact information that we receive from your social media will depend on your social media privacy settings. 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.

1.3.2 Other Information from Third-Party Sources. From time-to-time, we may receive personal information about you from third-party sources. For example, 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 another publisher’s game), we may receive the information that allows us to know which ad network and advertising campaign your installation originated from.

2. Why We Collect and Process Your Personal Data


2.1 We collect, use, store, and process your personal data based on:

(a) The principle of lawfulness, fairness, and transparency in relation to gaming and sales;

(b) Your consent that we may take from you time-to-time;

(c) Specified, explicit, and legitimate purposes;

(d) The extent that is adequate, relevant, and limited to what is necessary, in relation to legitimate purposes;

(e) The manner that ensures appropriate security of personal data;

(f) Performing all obligations under appropriate User Agreements / Terms of Service, and providing our Services;

(g) Your and our legitimate interests;

(h) Other legal reasons, including if required under any law, or required by governmental and regulatory bodies.

 

2.2 We collect and process your personal data to:

(a) allow you to access, or restrict your access, to our services;

(b) analyze and manage our services for system administration, user service, security, fraud-detection, checking the authenticity of an account owner, archival and/or backup purposes;

(c) correct bugs or errors, improve our services and respond to customer desires and preferences, including language and location customization, personalized support and instructions, and other responses;

(d) develop new services or products that a user(s) request and to improve the user experience;

(e) verify and confirm payment;

(f) communicate with other users and take action against violations;

(g) personalize your experience, keep you up to date with the latest product announcements, provide software verification, upgrades and administration, notify of special events, offer to participate in our surveys or activities, and provide other information pertaining to our services;

(h) protect the integrity, safety, and security of our services or users, comply with legal obligations, and enforce compliance with our User Agreement / Terms of Service, or other restrictions placed on your use of our services;

(i) track your process across our website(s) and applications to verify that you are not a bot and to optimize our services;

(j) investigate claims and/or legal actions, violations of our policies and procedures, and compliance with relevant applicable laws and legal process;

(k) comply with applicable laws, regulations, or legal process as well as industry standards and our company policies; and/or

(l) prevent, investigate, identify, or take any other action with regard to suspected or actual fraudulent or illegal activity, or any activity that violates our policies.

3. Advertisements and Your Choices

For the purpose of providing personalized advertisements (if any), you acknowledge and agree that based on your consent we may collect and process the data to:

(a) deliver, target, and improve our advertising; and/or

(b) improve advertising and other marketing and promotional activities.

We may also use the data you provide to send you (or have our authorized contractors deliver) advertisements, market research, and surveys.

Pertaining to the marketing or promotional communications, you may opt-out of receiving such communications in accordance with the instructions therein, such as email, online communication channels, or other contact methods provided by us. For example, you may opt-out of the out-of-game push notifications on mobile applications by checking the settings and turning off the “allow notifications” (iOS/Android).

Without your consent, we ensure that we will not use your data for marketing purposes, and after granting permission, you may also withdraw such consent at any time without impact on the validity and lawfulness of such data usage prior to such withdrawal. If we know that you are a registered user under the age of majority in your jurisdiction, we will not target you with advertising.

4. Sharing Your Personal Data


4.1 We do not share personal data that directly identifies you (such as your name, e-mail) with independent third-parties unless:

(a) your prior authorization or consent is obtained;

(b) if we are required to do so by law, legal process, or a reasonable request from law enforcement authorities or other government officials;

(c) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual illegal activity;

(d) if necessary, to protect the vital interests of us and any of its users (such as to prevent death, bodily harm, or serious damage to property), public security and public interests; or

(e) if we sell part or all of our assets to the third parties, we may share your Data with the buyer. In the event of this circumstance, the buyer will comply with this Privacy Policy, as well as related laws and regulations.


4.2 We may share anonymous or aggregated data, or other data that does not directly identify you with other parties. You acknowledge that you have foreseen and agreed to the occurrence of such disclosure when you provide your personal data.

4.2.1 Other In-Game Users. We support and often encourage you to interact with other players, including outside of the game, such as on Discord. In most games, other players will see your name, user profile, in-game activities, and read messages you have posted, depending on the setting adopted by you. Any data you post to any communication area is publicly viewable. We strongly recommend that all users avoid posting personal or sensitive data at any time on, or through, our services, including on Discord.

4.2.2 Competent Authorities. We may provide a certain portion of your personal data to judicial or administrative authorities as so requested. We may also disclose certain portion of your personal data within a strictly limited scope of recipients when we reasonably think it is necessary to protect us, our users, or a portion of the public.

4.2.3 Related Entities. We may share your information with our related entities, including our parent and sister companies. For example, we may share your information with our affiliates for customer support, marketing, or technical operations. If we share your personal information with our affiliates or related companies, they will handle your personal information in accordance with this Policy.

4.2.4 A Third-Party that Acquires All, or Substantially All, of Our Business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organize any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

4.2.5 Providers of Analytic Services. Such providers process information identified in this Privacy Policy on their servers for the purposes of assisting us with acquiring users for the Game and analytics purposes to improve your gameplay. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.

(a) Microsoft Azure PlayFab

https://playfab.com/privacy-terms/

Technical information, technical identifiers, engagement information, user information, contact information, event data, etc.

(b) Microsoft Azure

https://azure.microsoft.com/en-us/overview/trusted-cloud/privacy/

Technical information, technical identifiers, engagement information, user information, contact information, event data, etc.

(c) Google Data Analytics

In accordance with the Google Developer License Agreement and privacy policy visit:

https://adssettings.google.com

4.2.6 Logistics Service Providers. We may share your personal data, such as your address and phone number, with logistics service providers who provide shipping services, for purposes such as delivering physical prizes to users.

4.2.7 Other third-party service providers:

(a) Social networking portals who provide login and/or content-sharing service to and in our services;

(b) Payment service providers who provide payment services, such as assisting our services to run on, facilitating users’ payment, and maintaining a record of the users’ transaction history;

(c) AIHelp service provider. We will share your device information, your chat data and/or game data associated with customer service, for the purposes of providing customer service;

(d) Our cloud service providers;

(e) Other contractors or freelancers (if any) for the purpose of providing our services to you.

Since those contractors or freelancers may access, collect, or process your data as the data controller and operate under their own privacy policies, please refer directly to their privacy policies on their official website(s) and learn more about their data processing practices.


5. Cookies or Similar Technologies

By using the Service, you agree that we may automatically collect certain information through the use of “cookies” or other similar tracking technologies to analyze trends and administer the Service.

Many browsers enable you to control the use of cookies at the individual browser level. Cookies are small data files that are stored on a user’s hard drive at the request of a Website or the Service to enable the Website or the Service to recognize users who have previously visited them and retain certain information such as customer preferences and history. If we combine cookies with, or link them to, any personally identifying information, we would treat this information as personal information. If you wish to block, erase, or be warned of cookies, please refer to your browser or mobile device’s instructions or help screen to learn about these functions. You may not be able to delete or disable cookies on certain mobile devices and/or certain browsers.

Remember, 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.

6. International data transfers

Our company operates and resides in the United States of America. Pursuant to our contract with you to allow you to participate in our Games, your personal information may be transferred to, and processed in, countries other than the country in which you are resident, and can be accessed by our support, engineering and/or our affiliates around the world (including but not limited to Canada, India, and the United States). These countries may have data protection laws that are different from the laws of your country. We have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy. Internally, we also require affiliates, service providers, and/or business partners to protect your personal information when processing your personal information to provide Services to you.

7. Data Retention

We will store your personal information for as long as is necessary for the performance of our obligations, or to achieve the purposes for which the information was collected, or as may be required or permitted under applicable law. Upon the expiration of such period, your personal data may be deleted, blocked or anonymized, as provided by applicable law.

In the case you request to remove or delete your personal data, we will assess whether such data is necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and/or enforce the agreements between you and us. If so, we will retain your data until it is not necessary. Please note that the removal or deletion of any of your data may result in the termination of some of our applicable services.

8. Your Rights

You may exercise any of the rights described in this section by using any functionality available while using our services and/or sending an email to

or by using our Contact Form.

We will respond within 30 days, though this may be extended by a further two months in certain circumstances. Please note that we may ask you to verify your identity before taking further action on your request.


8.1 Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to access your personal data that we hold about you. In some jurisdictions, applicable law may entitle you to request copies of your Data held by us. You may also be entitled to request copies of Data that you have provided to us in a structured, commonly used, and machine-readable format, and should you have such requirement, please contact us. According to our reasonable and unilateral judgement, if your verifiable request affects or will affect the rights or freedom of other users or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs arising therein) or refuse to act on the request.


8.2 Right to Rectify

If we process your personal data, we shall endeavor to ensure by implementing suitable measures that your personal data is accurate and up-to-date for the purposes for which it was collected. If your personal data is inaccurate or incomplete, you have the right to obtain rectification of your inaccurate personal data without undue delay.


8.3 Right to Request Deletion of Personal Information

You have the right to obtain deletion of your personal data, if the reason as stated in Article 2 of this Privacy Policy does not exist anymore, or if there is another legal ground for its deletion, subject to submitting a verifiable request in the form of sending an email.

We provide you with the service of account cancellation. You can delete your account by clicking – Settings > Account > User Center > Delete your account – in most of our Games, or you can contact us to exercise your right. Please read the instructions of the cancellation page carefully. Should you choose to cancel the Game account, we will delete or anonymize all relevant personal data generated by you in the Game in a timely manner in accordance with relevant laws and regulations, unless otherwise required by laws and regulations.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defense of legal claims or freedom of expression) but we will let you know if that is the case.


8.4 Right to Withdraw Consent

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities. Where consent is required to process your personal information, if you do not consent to the processing, or if you withdraw your consent, we may not be able to deliver the expected service. Should you withdraw your consent or authorization, we may no longer continue to provide you with the services related to the withdrawal of the consent or authorization, and will no longer process your related personal data. However, your decision to withdraw your consent or authorization will not affect the processing of personal data previously carried out based on your authorization.


8.5 Right to Object

When our processing of your personal data is based on legitimate interests according to Article 6(1)(f) of the GDPR, or any other applicable laws in your country of residence, you have the right to object to our processing. If you object, we will no longer process your personal data unless there are compelling and prevailing legitimate grounds of processing as described in Article 21 of the GDPR or any other applicable laws in your country of residence; in particular, if the data is necessary for the establishment, exercise or defense of legal claims. You also have the right to lodge a complaint to a supervisory authority.

Where your personal information is processed for direct marketing purposes, you may, at any time, ask us to cease processing your data for these direct marketing purposes.


8.6 Right to Restrict Processing

You have a limited right to restrict the processing of your personal data under the conditions set out in Article 18 of the GDPR or any other applicable laws in your country of residence, in particular where:

(a) you object to the processing of your data under Article 21 of the GDPR;

(b) you contest the accuracy of your Data;

(c) the processing is unlawful, but you oppose the deletion of your Data;

(d) we no longer need your Data for the purposes of the processing, but you require the Data for the establishment, exercise or defense of legal claims.

Should you have any above requirements, please contact us.


8.7 Right to Personal Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller under the conditions set out in Article 20 of the GDPR or any other applicable laws in your country of residence.


8.8 Right to Complain to a Data Protection Authority

If you think we have infringed data protection laws, you can lodge a complaint with or report to a supervisory authority within your jurisdiction, or file a lawsuit to a judicial authority within your jurisdiction.

Notwithstanding the foregoing, if the applicable laws in your country of residence provide otherwise, the corresponding laws shall govern.

9. Data Security and Responsibility


9.1 How We Secure Data

Security of our users’ Data is a priority at us, which is why we rely on Microsoft Azure and Azure PlayFab to secure your user data.

Unfortunately, the transmission of information via the internet is not completely secure. While we strive to protect your personal data, we also remind you to be aware of hacking, cyber-attacks, and other risks on the Internet.

We strongly urge you to take every possible precaution to protect your personal data when using our services, including but not limited to changing your passwords from time-to-time, not reflecting your real name or other personal data in registration, using a combination of letters and numbers when creating passwords, using a secure browser and/or taking other possible security measures.

If we learn of a security systems breach, not directly associated with Microsoft Azure or Azure PlayFab, we may attempt to notify you electronically so that you can take appropriate protective steps. If a security breach occurs, we may also post a notice.


9.2 Notification of Amendment of this Privacy Policy

Except where required by law, if you fail to explicitly express your objection to any amended version of this privacy policy within fourteen (14) days of the date the relevant amended version of this privacy policy is made available, you will be considered as having accepted the changes and agreed to the new privacy policy. However, you may stop using or accessing our Service by unsubscribing or ceasing your use of the Game Services at any time, if you cease to agree with the amended privacy policy.


9.3 Data Accuracy and Third-Party Consent

Except where allowed by law, you are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).


9.4 Limitation of Liability

Except where required by law, you agree to not hold AUTHOR KURT LLC dba Demihumans, or its affiliates, legally responsible for any damages or liabilities associated with or arising out of data security or use of our Games or Services.

10. Age Limits and Children Protection

You represent that you are at least the age of majority in your jurisdiction when using our services. If you are under the age of majority in your jurisdiction, you shall not play our Game without the consent of your parent or guardian.

We do not, and will not, knowingly collect personal data from children without consent from their parents or guardians. We strongly urge parents and guardians to instruct their children never to disclose or give out their personal data when using our services without the prior permission of their parent/guardian. If we learn that we have collected personal data about a child, we will delete that data as quickly as possible. Also, if you believe that we might have any data from, or about a child, please contact us.

11. Contact and Complaints

If you have any questions about this Privacy Policy or have any requests for resolving issues with your personal data while using our services, please contact us as soon as possible by emailing us at

or by using our Contact Form.


AUTHOR KURT LLC dba DEMIHUMANS

SUPPLEMENTAL JURISDICTION-SPECIFIC TERMS

Some jurisdictions’ laws contain additional terms for users of the Game Services, which are set out in this section.

If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our privacy policy above.

 

A. California

This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).

A.1 Collection and Disclosure of Personal Information.

Over the past 12 months, we have collected and disclosed the following categories of personal information from, or about you, or your device:

(a) Identifiers, such as your username, User ID (Game ID), name/nickname, IP address, device ID, operating system, device type and other device information, email address, your social media profile;

(b) Data of Use of the Service, such as gameplay data (such as game setting), in-game interactions, geolocation information;

(c) Commercial information about any transactions in our services, or via a third-party such as what products were purchased and how much they cost;

(d) Customer Support Information and security-related information;

(e) Other information described in Section 1;

(f) In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sale” in the CCPA.

A.2 California Residents’ Rights.

California law grants California residents’ certain rights and imposes restrictions on particular business practices as set forth below.

(a) Do-Not-Sell. California residents have the right to opt-out of our sale of their personal information. We do not sell personal information about residents who we know are younger than 16 years old.

(b) Initial Notice. We are required to notify California residents, at or before the point of collection of their personal information, the categories of personal information collected and the purposes for which such information is used. We will make this Privacy Policy available to Users online, and in-game when first prompted to accept the Terms of Service, in order to satisfy this requirement.

(c) Requests to Delete. Subject to certain exceptions, California residents have the right to, at no charge, request deletion of their personal information that we have collected about them and to have such personal information deleted, except where an exemption applies. To send the request, please email to

or by using our Contact Form, and we will process the request within 30 days.

 

(d) Request to Know.

California residents have the right to request and subject to certain exemptions, receive a copy of the specific pieces of personal information that we have collected about them in the prior 12 months and to have this delivered, free of charge by email, in a readily useable format that allows the individual to transmit this information to another entity without hindrance. To send the request, please email to

or by using our Contact Form, and we will process the request within 30 days.

California residents also have the right to request that we provide them certain information about how we have handled their personal information in the prior 12 months, including the:

(i) categories of personal information collected;

(ii) categories of sources of personal information;

(iii) business and/or commercial purposes for collecting and selling their personal information;

(iv) categories of third parties/with whom we have disclosed or shared their personal information;

(v) categories of personal information that we have disclosed or shared with a third party for a business purpose; and

(vi) categories of third parties to whom the residents’ personal information has been sold and the specific categories of personal information sold to each category of third party.

California residents may make a ‘Request to Know’ up to twice every 12 months.

We will respond to verifiable requests received from California residents as required by law.

(e) Right to Non-Discrimination. The CCPA prohibits discrimination against California residents for exercising their rights under the CCPA. Discrimination may exist where a business denies or provides a different level or quality of goods or services, or charges (or suggests that it will charge) different prices, rates, or penalties on residents who exercise their CCPA rights, unless doing so is reasonably related to the value provided to the business by the residents’ data.

(f) Financial Incentives. A business may offer financial incentives for the collection, sale or deletion of California residents' personal information, provided it is not unjust, unreasonable, coercive or usurious, and is made available in compliance with applicable transparency, informed consent, and opt-out requirements. California residents have the right to be notified of any financial incentives offers and their material terms, the right to opt-out of such incentives at any time, and may not be included in such incentives without their prior informed opt-in consent; we do not offer any such incentives at this time.

(g) Your Rights Under California’s Shine-the-Light Law. We do not share personal information collected online with unaffiliated third parties for their own direct marketing purposes and will not do so unless you agree to such disclosure. If you are a California resident and you still believe your information has been shared or you have general questions about how your information may have been shared, you may contact us by requesting a list of the third parties to which we have disclosed personally identifiable information about you for their own direct marketing purposes. You may make one request per year. In your request, please attest to the fact that you are a California resident and provide a current California address (your legal domicile) for your response.

 

B. Indonesia

B.1 Consent

By accepting and consenting to this privacy policy, you agree that we may collect, use, and share your personal information in accordance with this privacy policy, as revised from time-to-time. If you do not agree to this privacy policy, you must not access or use our services and we have the right to not provide you with access to our services.

B.2 Parental and Guardian Consent

If you are under the age of 21, you undertake that you have the consent of your parent or legal guardian to register an account on the Game and use the Game Services.

B.3 Data Subject Rights

You have the right to access your personal information stored in our Game from time-to-time in accordance with applicable data privacy laws and regulations in Indonesia.

B.4 Data Breach

In the event we fail to maintain the confidentiality of your personal information in the Game, we will notify you through the contact information provided by you or via the Game, to the extent required by local laws and regulations.

B.5 Notification to Amendment of this Privacy Policy

If you fail to explicitly express your objection to any amended version of this privacy policy within fourteen (14) days of the date the relevant amended version of this privacy policy is made available, you will be considered as having accepted the changes and agreed to the new privacy policy. However, you may stop using or accessing our Service by unsubscribing or ceasing your use of the Game Services at any time, if you cease to agree with the amended privacy policy.

B.6 Data Accuracy and Third-Party Consent

You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

 

C. Malaysia

C.1 Parental and Guardian Consent

If you are under the age of 18, please do not use our services except where your parent or guardian has provided consent

In the event you are agreeing to this privacy policy in order for a minor to access and use the Game Services, you hereby consent to the provision of personal information of the minor to be processed in accordance with this privacy policy and you personally accept and agree to be bound by the terms in this privacy policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor’s compliance with this privacy policy.

C.2 Your Rights

(a) Right of access: You have the right to request access to and obtain a copy of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law.

When handling a data access request, we are permitted to request for certain information to verify the identity of the requestor to ensure that he/she is the person legally entitled to make the data access request.

(b) Right of correction: You may request for the correction of your personal information. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requestor to ensure that he/she is the person legally entitled to make the data correction request.

(c) Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details provided above. However this may affect our provision of the Game Services to you.

 

D. Singapore

By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates.

 

E. Thailand

By accepting this privacy policy, you acknowledge that you have read, understood, and agree to this privacy policy. If you do not agree with this privacy policy, you must not use our services.

If you are under the age of 20, please do not use our services except where your parent or guardian has provided consent.


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