Privacy Policy

Last Updated: 【】 2024

1(referred to as "we," "us," or "our") is dedicated to safeguarding the privacy rights of our users (referred to as "you," "user," or "users"). This commitment extends to all individuals who visit our websites, engage with our games on various platforms such as mobile devices, personal computers, or through our websites, and utilize any services we provide. These services encompass a range of offerings, including but not limited to technology support, customer service, competitive gaming events, and marketing and advertising initiatives (collectively termed "our Services").


This Privacy Policy (the "Policy") aims to clarify how we handle personal data. It outlines our practices concerning the gathering, utilization, preservation, and sharing of information that we obtain from you or concerning you during your interactions with us. The Policy also details your rights in relation to the data you share with us and the measures we take to ensure the security and proper transfer of such information.


Please read this Policy diligently to understand how we manage your Personal Data (as defined below) and access it frequently to understand the updates to this Policy. By downloading, accessing, using and/or interacting with our Services, you agree and expressly consent to our collection, use and disclosure of the information that you provide as described in this Privacy Policy. You can find this Privacy Policy from the TERMS OF SERVICE (“Terms of Service”) and is subject to the provisions of the Terms of Service. If you have any concerns about providing information to us or the use of that information as described in this Policy, you should consider not using our Services. 

We will inform you of any changes to this Policy through notifications in our Games. These updates will explain the modifications and seek your renewed consent. If you continue using our Services after such a notification, it implies you have accepted the revised Policy. You can check the "last updated" date at the beginning of this Policy to see when it was last modified. We will provide additional notice or request your consent if necessary, as mandated by data protection laws. The revised Policy will replace all previous versions.

This Privacy Policy outlines the following key topics to help you understand our practices:

I. Key Definitions

II. The Data We Collect and Utilize

III. Marketing Communications

IV. Use of Your Personal Data and the Reason

V. Data Storage and Security Measures

VI. Data Sharing, Transfer, and Disclosure Practices

VII. International Data Transfers

VIII. Children's Data Protection

IX. Your Rights Regarding Data Privacy

X. How to Exercise Your Data Rights

XI. Use of Cookies and Tracking Technologies

XII. Third-Party Services and Providers

XIII. Contacting Us for Further Assistance

XIV. Additional Support Information

I. Key Definitions

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

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

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

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

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

II. The Data We Collect and Utilize

1. Overviews

To enhance your experience with our services, we may seek Personal Data from you. We gather Personal Data through these channels:

(1) Information you directly provide to us (such as your nickname, profile picture and phone number you provide to us when you register or login to your account);

(2) Information we obtain automatically during your use of our Services (such as Device Information and Usage Data); or

(3) Information we obtain from other sources.

We collect and utilize your Personal Data solely for the objectives outlined in this policy. Below is a summary of the personal data we collect and its intended use."

2. Data Collection and Purposes

 

 

No.

Categories

Details

Purposes

Additional information

1

Login Information

 

some of your Personal Data, such as e-mail address, verification code by email or SMS, and password

Enable you to sign up with your e-mail/mobile phone number

 

N/A

the information you authorized the Social Networks to share with us to sign up for our Services.

Exactly what information we receive from the Social Networks may vary due to your privacy settings on such Social Network, but it would typically include your basic public profile information such as your nickname, username and profile picture.

Enable you to register via social network accounts, such as Apple ID, Facebook or Google Play (“Social Networks”) and sign up for our Services

 

If you refuse to provide information of your Social Networks accounts, you may not have the option to register and log in by your Social Networks accounts.

 

date of birth

verify that you are eligible to access or use our Services

Applicable to certain regions

2

Account Information

profile picture, nickname, gender, date of birth and location.

 

Enable you to use our Services based on your own choices and have more popularity

 

Please do not post or add additional information to your profile that you would not want to be publicly available.

3

Payment Information

purchase and transaction record in the Services：

device information : Open ID, Internet Protocol (IP) address, OS version, type of device, internet connection)；

transaction details : time and date, cost, product purchased, currency, order ID

transaction records : including player ID, time of transaction, country, email, phone number, purchase history and payment card details

enable you to purchase virtual currency or virtual items in our Services, and perform our contract with you to facilitate your payment and provide you with details of your transactions.

All purchases and withdrawals are processed by payment processing companies.

We do not process the payments for any payment nor do we have any access to your credit card information or billing information.

4

Any Information You Submit to Our Support Team

the content of your enquiry, your device information, contact details or other contact information you leave with us

Enable you to contact us and seek assistance through our technical and/or customer service and we may help you resolve the problem, or record the problem and its solution.

If you choose not to provide such information, we may not be able to provide you with this service, but your use of other features of our Services will not be affected.

5

Advertising Information

Android ADID and Apple IDFA information and device information with your profile

 

to track the success of our advertising if you click on advertisements in our Services

 

We may also use the information you provide to send you deliver advertisements, market surveys or research by email. If you don’t want to receive such messages from us, you may opt-out of receiving such messages (see “Promotional Communications” below).

 

Please note that when you opt out of receiving interest-based or targeted advertising, you will still see advertisements from us or on our online services, but that advertising will not be targeted using your Personal Data.

 

If we know that you are a registered user under the legal age of majority in accordance with the applicable laws of some jurisdictions from which you access or use our Services, we will not target you with advertising or send you such messages.

age, gender, e-mail address, geographical location, device type, in-game information (such as your habits and preferences in our Games) and other information you choose to provide to us in any surveys or inquiries

In order to provide you with personalized advertisements, promotional activities and marketing communications if you

6

Data We Automatically Collect

Internet Protocol (IP) address.

 

We collect and process this information to allow you to access or restrict your access to our Services.

Please note that some of the above-mentioned information alone cannot be used to identify a specific natural person, thus cannot be considered as Personal Data. Only when such non-Personal Data is used in combination with other information to identify a specific natural person, or when it is used in combination with Personal Data, will this information be regarded as Personal Data during such combination. In this case, we will anonymize and de-identify this type of information, unless with your consent or otherwise according to laws and regulations. The above-mentioned information is essential as to the provision of the Service. If you choose not to provide them, we may not be able to provide you with our Services.

Device information. Such as UUID, IMEI, MAC address, IDFA, your device model, operating system and version, APK name, App version, device display resolution, device setting, CPU information, storage information, battery usage status, time zone settings and device location information (Internet Protocol (IP) address, GPS location and WLAN connection, Bluetooth and cell site information that provides location information).

We will collect information about the mobile device you are using to ensure service security, manage registrations and improve our Services.

Usage Data. Including login account, IP address, provider information, internet connection environment, WIFI status information, and other Usage Data generated when you use our Services.

For the purposes of performing our Terms of Service, we will collect details of your use of our services and keep them as Usage Data when you use our services.

7

Survey Information

Any feedback you provide when you contact customer service and any questionnaire you send back to us when you participate in a survey.

We may also collect other information about you that we reasonably need to improve our products or services

We may combine information from one service with information from others in order to provide you with better service.

8

Other Situations in Which Your Information May Be Collected

To the extent permitted by law, we may obtain your Personal Data from other individuals, business entities, public sources or other third parties acting at your direction, our partners who work with us to provide our products and services and assist us in information security and fraud prevention, and from other lawful sources. We will explain it to you at the time of such collection and obtain your consent.

We may also use other methods to collect other information about you, your device or your use of services, which will be explained to you at the time of collection prior to obtaining your consent.

 

 

III. Marketing Communications

We might utilize your Personal Data to inform you about updates to our Services, like special deals, promotions, or new offerings. We have a legitimate business interest in using your data for these updates, so we typically don't require your consent for promotional messages. However, if consent is necessary, we will request it explicitly. We promise to handle your Personal Data with respect and will never sell it to other entities for marketing.

You have the option to opt-out of promotional messages at any time by:

Reaching out to us (refer to the "How to Contact Us" section); or

Using the "unsubscribe" link in our emails or the "STOP" number in text messages.

We may reach out to confirm or update your marketing preferences if you request additional services in the future, or if there are updates to the law, regulations, or our business structure.

IV. Use of Your Personal Data and the Reason

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

· To comply with legal and regulatory obligations;

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

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

· Where you have given consent.

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

We may use your Personal Data for:  

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

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

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

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

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

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

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

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

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

V. Data Storage and Security Measures

Personal Data may be held at our and our third-party providers' offices. Your data is stored in compliance with laws and regulations on the personal privacy data protection of the countries concerned. You consent to your data being processed on our servers, which may be outside your country, and accessed by our global support and engineering teams or affiliates. Your collected information may be processed in places like Hong Kong, Singapore, or other Company, subsidiary, or agent locations, as outlined in this Privacy Policy. Regardless of server location, we ensure robust measures to protect your rights, in line with this Policy and relevant laws.

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

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

· Show that we treated you fairly; or

· To keep records required by law.

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

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

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

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

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

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

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

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

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

If your account is canceled or terminated pursuant to the Terms of Service, we will delete or anonymize your Personal Data. The security of your Personal Data is important to us and we implement security safeguards designed to protect your Personal Data and regularly monitor our systems for possible vulnerabilities and attack. We are constantly working to improve on these safeguards to keep your Personal Data secure.

We strive to use commercially acceptable means to protect your Personal Data. However, we need to remind you that that no method of transmission over the internet, or method of electronic storage, is one hundred percent secure.

VI. Data Sharing, Transfer, and Disclosure Practices

When it comes to sharing, transferring, or disclosing your Personal Data, we adhere to principles of minimalism, necessity, and legality. We don't typically share, transfer, or disclose your data outside the following instances:

1. How We Share Your Personal Data

We will share your Personal Data with only where necessary. We may share your Personal Data under these situations:

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

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

WE DO NOT SELL ANY PERSONAL DATA TO THIRD PARTIES.

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

2. How We Transfer Your Personal Data

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

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

· Where we have obtained your explicit consent.

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

3.  We Disclose Your Personal Data

We may need to disclose data about you when required by law, subpoena, or other legal process or if we have a good faith belief that the disclosure is reasonably necessary to (1) enforce our agreements with you; (2) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services; or (5) exercise or protect the rights and safety of our Services, our users, personnel or others. We aim to inform users about legal requests for their Personal Data when we deem it appropriate, unless it's against the law, a court order forbids it, or there's an emergency. We might contest these requests if we think they're too broad, unclear, or lack proper authority, but we don't guarantee to challenge every one.

Additionally, we may share your data with: Our attorneys, lawyers, accountants, auditors, or similar consultants when we request them to provide professional advice; investors and other relevant third parties, if actual or potential sales or other company transactions occur and are related to entities within our group; other third parties, for example, the disclosure of specific information with your authorization.

VII. International Data Transfers

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

We will comply with relevant applicable laws in the circumstance that we transfer Personal Data outside of your jurisdiction, whether it is transferred to our affiliates or third-party service providers.

VIII. Children's Data Protection

Children should not use or attempt to use our Services.

Our Services aren't for children under 13 or the minimum age in the relevant territory if that age is older than thirteen (13) (the “Child” or “Children”, or see the Supplemental Terms below). We do not knowingly collect any personal information from such Children.

If we find we've mistakenly collected a child's Personal Data, we'll delete it. Parents who believe that we might have gathered any information from or about a Child may submit a request to delete such information to our email address listed in Section XIII below.

IX. Your Rights Regarding Data Privacy

You possess certain rights concerning your personal data, detailed in this section. You or an authorized agent acting on your behalf may exercise your personal information rights by submitting a verifiable request or through our platform (see “How To Exercise Your Rights” below). When an authorized agent makes a request for knowledge or deletion of your data, we require that you:

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

· Verify your identity directly with us; and

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

You have the following data protection rights (including but not limited to):

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

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

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

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

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

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

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

X. How to Exercise Your Data Rights

For easy access, viewing, updating, correcting, deleting, or transferring your Personal Data, or to change subscription preferences, log into your account and go to "Account Settings" or get in touch with customer service. If consent is our basis for collecting and using your info, you can withdraw it anytime. If you request deletion of data needed for Services you've bought, we'll honor it only when it's no longer needed for those Services or for our business, legal, or record-keeping needs.

To exercise the access, data portability, correction, and deletion rights described above please submit a verifiable request to us by emailing us at 1.

Some jurisdictions’ laws contain additional terms for users of the Service, which are set out in the final section of Supplemental Terms. If you are a user located in one of the jurisdictions, the terms set out under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.

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

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

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

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

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

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

We endeavour to respond to any verifiable request within one (1) month of its receipt. If we require more time, we will inform you of the reason and extension period required in writing. We will send you confirmation of receipt of any verifiable request within ten (10) business days of its receipt.

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

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

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

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

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

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

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

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

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

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

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

· Where trade secrets are involved;

· Other conditions stipulated by laws and regulations.

XI. Use of Cookies and Tracking Technologies

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

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

XII. Third-Party Services and Providers

You might get links to third-party sites or services and use third-party offerings, like SDKs, for features like logins, notifications, and analytics (known as "Third-Party Services"). It's up to you to decide whether to visit or use these services, and we suggest checking their privacy policies.

XIII. Contacting Us for Further Assistance

We've appointed a Data Protection Officer ("DPO") responsible for overseeing our data protection strategy and ensuring compliance with legal requirements. For any feedback or inquiries about our Privacy Policy or data practices, contact our DPO at 1 (mark emails "Privacy Policy request").

XIV. Additional Support Information

If you would like this Policy in another format (for example: audio, large print, braille) please contact us.

 

 

 

 

 

 

 

 

 

 

 

Jurisdiction Specific Supplemental Terms

Some jurisdictions’ laws contain additional terms for users of the Service, which are set out in this section. If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above. In case of any conflict between the following supplemental terms and the provisions of general terms above, those following terms will take precedence over the general terms of this policy.

Indonesia

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

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

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

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

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

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

You may request 1 to (i) disclose the history of personal data that  we have collected; and/or (ii) erase and dispose of your personal data that we have collected on our server. Please note that by requesting us to erase and dispose of your personal data, you may not be able to use some features and functionality of the Services. To exercise any of your rights, contact us at the information listed in the XIII.How to Contact Us.

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

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

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

Singapore

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

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

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted as set out in XIII.How to Contact Us.

Vietnam

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

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

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

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

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

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

Thailand

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

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

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

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

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

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

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

·lodge a complaint to a relevant authority.

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

Egypt

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

1. Age, Parental and Guardian Consent

You must confirm that you are over 18 years old. If you are under 18, you should review this document with a parent(s) or legal guardian(s). If you are a parent or legal guardian reading these terms on behalf of a minor under 18, you must affirm that the minor is at least 13 years old, and that you have reviewed and accepted 1 Privacy Policy and Terms of Use, consenting to your child’s use of our Services.

If you consider that we have personal data about or collected from a child under the relevant age, please contact us at as set out in XIII.How to Contact Us. and we will ensure that it is deleted.

2. By clicking “accept” or by proceeding with the sign up process, you acknowledge that you have read, understood, and consented to this Privacy Policy. You are acknowledging your consent to the processing, storage, and cross-border transfer of your personal data. The cross border transfer may be to any country in which we have databases or affiliates.

You also acknowledge your consent to receiving marketing messages from us, whether through e-mails or pop-ups or other such means.

If you are a new user, you have seven days to inform us of any objection you may have to this Privacy Policy.

As an Egyptian data subject, you have certain rights under the Egyptian Personal Data Protection Law.

South Africa

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

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

United States

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

1.Your Rights

Depending on where you live, you may be entitled to certain rights with respect to your personal information, as described below:

·Request to Know. You may have the right to know what personal information we  have collected about you, including the categories of personal information, the categories of sources from which it is collected, the business or commercial purposes for collecting, selling, or sharing it, and the categories of third parties to whom we disclose it.

·Request to Access. Subject to certain exceptions, you may have the right to request a copy of the personal information that we collected about you.

·Request to Delete. You may have the right to request that we delete information that we collected from or about you, subject to certain exceptions.

·Request to Correct. You may have the right to request that we correct inaccuracies in the personal information we maintain about you.

In the past 12 months, we have not sold or shared personal information of California residents within the meaning of “sold” and “share” in the CCPA. And we have no knowledge of any sale or sharing of personal information of users under 16 years of age.

In addition, we do not use or disclose sensitive personal information for purposes other than to perform the services reasonably expected by an average consumer who requests those services or as otherwise permitted by US State Laws.

Although  some of the information we collect may be considered sensitive personal  information, we only process such information in order to provide the  Services and within other exemptions under applicable law, such as when we process your sensitive personal information in order to perform the  services or provide the goods you request from us.

California residents. Any California residents under the age of eighteen (18) who have registered to use the Service and who have posted content or information on the Service can request that such information be removed from the Service by contacting us as specified in XIII.How to Contact Us. Such request must state that they personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the resident cannot be individually identified. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished the post, and archived copies of it may be stored by search engines and other parties that we do not control.

2.How to Exercise Your Rights.

You may contact us to exercise these rights via the information listed in the XIII.How to Contact Us above.

You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise rights on your behalf, please provide evidence that you have given such agent power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your  behalf.

We will respond to your request consistent with applicable law and subject to proper verification. We will verify your request by asking you to send it from the email address associated with your account or to provide information necessary to verify your account.

You may appeal any decision we have made about your request by replying to the communication you receive from us communicating your decision. We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available on this Services may change or no longer be available to you.