Privacy Policy
I. Introduction
Welcome to use the products and services provided by [Guangzhou Chuhai Network Technology Co., Ltd.] and its affiliates (hereinafter referred to as "Chuhai", "we" or "us"). and its affiliates (hereinafter referred to as "Chuhai", "we" or "us"). In accordance with the regulations on the protection of personal data and privacy offered by local laws ("Privacy Law"), we meticulously fulfill data security-related responsibilities and are committed to respecting the privacy and interests of all users who use our products and services. Users refer to those who register accounts or use or access services provided by us (collectively referred to as "Users", "You", or "Your"). We recognize the importance of personal data entrusted by you to us and believe that it's our responsibility to properly manage, protect, and deal with your personal data. The Privacy Policy ("Privacy Policy") aims to help you understand how we collect, use, disclose, and/or deal with personal data provided by you to us or personal data about you kept by us, no matter at present or in the future, and help you make a wise decision before providing us with any of your personal data.
"Personal Data" refers to the data (no matter real or not) specific to individuals through which they can be identified or the data owned by or available to organizations can be identified by combining other information. Personal data generally includes names, national ID card numbers, and contact information.
By using our services, registering accounts at us, or accessing our website, you acknowledge and agree to be bounded by the methods, requirements, and/or policies described herein. And you hereby agree that we collect, use, disclose, and/or deal with your personal data described herein.
If you do not agree with the license that allows us to deal with your personal data described herein, please do not use our products or services. If we revise the Privacy Policy, we will release the revised version on our website. We reserve the right to revise the Privacy Policy at any time.
II. When Do We Collect Personal Data?
1. We will/may collect your personal data on the following occasions:
(1) When you register with and/or use our products or services, or enable an account at us;
(2) When you submit any form through online channels or by other means, including but not limited to any application or other forms related to any of our products or services;
(3) When you sign any agreement or provide other documents or information for the interaction between you and us, or when you use our products or services;
(4) When you interact with us, such as through telephone calls (which may be recorded), communications, fax, face-to-face meetings, emails, and social media platforms;
(5) When you use our electronic services or interact with us through our games, websites, or services, including but not limited to the cookie possibly deployed by us when you interact with our games or websites;
(6) When you make any deal through our games or websites;
(7) When you provide any feedback or complaint to us;
(8) When you register for any competition, game or game-based activity;
(9) When you're playing our games;
(10) When you submit your personal data to us due to any reason.
Above are some common occasions in which we collect your personal data but do not reflect all occasions in which your personal data will be collected.
III. Which Data Do We Collect?
1. The personal data we collect may include but is not limited to:
(1) Full name;
(2) Email;
(3) Date of Birth;
(4) Payment Address;
(5) Bank Account and Payment Information;
(6) Phone Number;
(7) Gender;
(8) Information sent by the devices through which the users access our services or other information relating to such devices.
2. Any other information provided when the users sign up and use our services, and the information on how the users use our services; and
3. Summary data related to the user contents.
4. You hereby agree not to provide us with any inaccurate or misleading information, and you agree to notify us immediately when you identify any inaccurate information or when there is any change in the information submitted previously. We reserve the right to request the provision of other necessary documents to verify the information provided by you.
5. If you become the users of our services by logging on to your social media accounts ("Social Media Accounts"), connecting accounts to any of your Social Media Accounts, or using any social media functions of our products or services, we have the right to access your personal data which have been voluntarily provided by you to your social media account service providers based on their relevant policies, and we will always manage and use your personal data in accordance with the Privacy Policy.
6. If you do not wish us to collect the above personal information/data, you may notify our Data Protection Officer at any time in writing to exit. However, please note that rejecting or revoking the license that allows us to collect, use, or deal with your personal data may affect your use of our products or services. For instance, if you do not allow our app to access your location, the location services will not be available.
IV. Other Data to be Collected
1. Just like most websites and other mobile apps, the information sent by your devices may include your personal data, which will be recorded by our network servers when you use our products or services. Such information generally includes but is not limited to your mobile devices' IP addresses, computer/mobile operating systems, browser types, mobile device types, mobile device characteristics, unique device identifier (UDID) or mobile equipment identifier (MEID), website addresses (if applicable), web pages you have accessed on the websites or on our mobile apps and the access time; sometimes, cookies are adopted for recording your last access, which may be disabled by setting up your browser preferences. If you log in, such information is correlated with your personal accounts. Such information is also included in the anonymized statistics to help us understand how the users use our games and websites.
2. Our mobile app may use GPS, Wi-Fi, and other technologies to collect accurate information related to the addresses of your mobile devices. We collect, use, disclose, and/or deal with such information for one or several purpose(s), including but not limited to location-based services; you may request, transmit or allow the sharing of your locations as a part of the services provided by our mobile apps. For most mobile devices, you can revoke through your devices the license that allows us to collect such information based on your locations. If you have any doubt about disabling the location services on mobile devices, please contact us.
V. Cookies
1. Our authorized service providers and ad partners or we may use "cookies" or other functions to enable us or third parties to collect or share the information regarding your use of our services from time to time. These functions will help us improve our websites, games, or services, recommend new services or functions, and/or enable our ad partners and us to deliver products or services in accordance with relevant laws. "Cookie" refers to the identifier transmitted by us to your computer or mobile device, including the recorded data about your computer or device, the way and duration you use or access our services or websites, how many people you have met, or how many activities you have attended during the games. We may correlate the cookie with your personal data. The cookie may also link with the information regarding the items you choose to buy, the web pages you have browsed, or the games you have played. Based on the services involved, such information may be used for tracking your shopping cart to provide contents that cater to your interests, so that we or our third-party ad partners can advertise with third parties through our services or websites and monitor the use of services. The web pages you have browsed, or the games you have played. Based on the services involved, such information may be used for tracking your shopping cart to provide contents that cater to your interests, so that we or our third-party ad partners can advertise with third parties through our services or websites and monitor the use of services. The web pages you have browsed, or the games you have played. Based on the services involved, such information may be used for tracking your shopping cart to provide contents that cater to your interests, so that we or our third-party ad partners can advertise with third parties through our services or websites and monitor the use of services.
2. You may reject cookies or web beacons by selecting appropriate settings or adjusting your preferences on the browser or device. But please note that if you do so, it may be impossible for you to use the full functionality of our websites, games or services.
VI. How Do We Use the Information Provided by You?
1. We may collect, use, disclose, and/or deal with your personal data for one or several of the following purpose(s):
(1) Review and/or process your application/transaction made with us or with third parties through our services;
(2) Manage, operate, provide, and/or control your use of and/or access (including but not limited to your preferences) to our services, websites, and games, as well as your relationship with us and the user accounts;
(3) Respond to, deal with, settle or complete relevant transactions, and/or respond to your request for some products and services, and inform you of service problems and abnormal account activities;
(4) Perform our service terms or any applicable end user license agreement;
(5) Protect personal security and the rights, property or security of others;
(6) Identify and/or verify relevant information;
(7) Maintain, manage, and improve any software updates or other updates to support services, including troubleshooting, reporting, and solving any issues (such as error feedback or crash reporting) from time to time, so as to ensure our smooth operation of games and/or services;
(8) Deal with or promote customer services, follow your instructions, solve or respond to any inquiry made by you, or submit (or plan to submit) any inquiry on behalf of you;
(9) Contact or communicate with you through telephone, SMS, fax, email, or other means to manage your relationship with us or your use of our services, for example, including but not limited to conveying the management information related to our services. You hereby acknowledge and agree that we may communicate with you by sending an email, a file, or a notice, including disclosing some of your personal data on the parcel or envelop to deliver relevant files；
(10) Allow other users to interact, exchange or communicate with you, including notifying you when other users send private messages to you or release a comment about you through our game or platform.
(11) Engage in research, analysis, and development activities (including but not limited to data analysis, survey, product and service development, and/or characterization), analyze how you use our services, enhance our products or services, and/or improve your customer experience;
(12) Enable ads, other tests, and survey activities (through online and offline channels, including third-party platforms (such as Google Sheet)), verify the scale and composition of our target audience, and gain an understanding of their experience;
(13) Achieve any marketing and promotion goals together with any ad in accordance with applicable laws, recommend products or services that cater to your interests (through email or SMS), and send you marketing or promotional materials related to the products or services sold or marketed by us (and/or our affiliates) (including but not limited to the products or services of third parties with whom we may establish cooperation), no matter these products or services are offered at the moment or in the future. You may unsubscribe from our electronic marketing materials by enabling the "Unsubscribe" function in such materials.
(14) Respond to legal procedures, or meet the requirements of any applicable laws or competent agencies;
(15) Conduct statistics and research to meet reporting requirements or maintain internal or regulatory records;
(16) Identify and verify relevant information or organize other screening activities (including but not limited to background checks) for risk control in accordance with regulatory obligations or auditing procedures, which may be required by applicable laws or may be applied by us;
(17) Check our services or operations;
(18) Prevent or investigate any actual or suspected behavior, fraud, illegal activity, omission, or improper act that violates our terms of service, no matter in relation to the use of our services or any problem arising in your relationship with us;
(19) Store, keep, or back up your personal data (no matter for disaster recovery or for other purposes);
(20) Process and/or promote potential commercial asset transactions in which we or our affiliates serve as a party and any party may engage a third party in such transactions. Commercial Asset Transaction refers to any purchase, sale, rental, merger, acquisition, liquidation, or financing of any business or property of any entity or part of the entity; and/or
(21) Verify your qualifications or submit your application/request when you enroll for specific competitions, activities, or tournaments, and reward you if applicable; and
(22) Achieve the purpose of any applicable law or notify you when permission has been obtained from you (collectively referred to as "Purposes")
2. You hereby acknowledge, authorize, and agree that, if any applicable law or court order or any competent governmental or regulatory agency requires or we believe it necessary and reasonable, we can access, keep, or disclose such information for the following purposes: (a) Observe legal procedures; (b) Observe the requirements of any governmental or regulatory agency which has jurisdiction over us or our affiliates; (c) Perform our terms of service or the Privacy Policy; (d) Respond to any general or actual claim against us or our affiliates, or other claims against any content that infringes the rights of a third party; (e) Respond to your service requests; (f) Protect the rights, property or personal safety of us or our affiliates, users, and/or the public.
3. Since our collection, use, disclosing, or dealing with your personal data depends on the situation, the above purpose may not occur. However, we will notify you of other purposes after obtaining your consent, unless personal information privacy protection laws allow us to deal with applicable data without obtaining your consent.
VII. How Do We Protect and Store User Information
1. We implement various security measures and operational controls to ensure the security of your personal data in our system. Users' personal data can only be accessed by certain employees with special access to our systems after being stored on our safe network. However, absolute security cannot be guaranteed.
2. We will maintain personal data in accordance with personal information privacy protection laws or other applicable laws. That is to say, we will destroy or delete the identified information from your personal data when we determine with good cause that (i) retaining such information no longer satisfies the purpose for which it is collected; (ii) such retention is no longer necessary due to any legitimate or commercial concerns, and (iii) there is no longer any other legitimate interest in the retaining of such information. If you stop using our products or services, or if your rights of using our websites, games, or services are terminated or revoked, we may continue to store, use, and/or disclose your personal data in accordance with the Privacy Policy and our legal obligations of protecting the confidentiality of personal data. In accordance with applicable laws, we may safely destroy your personal data without prior notice to you.
VIII. Do We Collect Disclosure Information from the Attachments?
1. During business operations, we will/may need to use, deal with, disclose, and/or transmit your personal data to third-party service providers, agents, our affiliates and associated companies, and/or other third parties for one or several of the above purposes. Such third-party service providers, agents, our affiliates and associated companies, and other third parties may deal with your personal data on behalf of us or other parties for one or several of the above purposes. Such third-parties include:
(1) Our subsidiaries, affiliates, and associated companies;
(2) Other users served by us who're related to your use of our services for one or several of the above purposes;
(3) Contractors, agents, service providers, and other third parties employed by us to support or add up to our business. These parties include but are not limited to those providing administrative or other services to us, such as postal corporations, game development partners, service providers, payment, finance, ad, and marketing partners, IT companies, and data centers;
(4) Governmental or regulatory agencies who have jurisdiction over us or who have been authorized under Article VI (2);
(5) The personal data we hold about the users are part of the transferred assets when part or all of our assets are under the merger, divestment, reorganization, restructuring, dissolution, sale, or transfer, whether in an ongoing matter or in bankruptcy, liquidation or similar proceedings, in which we or our affiliates or associated companies are a party to the commercial asset transaction; and
(6) A third party to which we disclose your personal data for a certain purpose, and such party will collect and deal with your personal data out of one or several purpose(s);
2. Among other things, we may disclose your gaming history and/or the records showing which games are viewed or accessed using which IP addresses. We may also share statistical and demographic information about our users and their use of the Services with advertising partners and third-party advertising, remarketing and other service providers. Other programs under applicable laws.
3. In addition, you may choose to export your activity information as an RSS feed other users can subscribe to, which may include your gameplay, game settings, connections with other users, and other information about your account activities, which can be released on the website or in the game as a feed.
4. For the avoidance of doubt, to the extent that privacy laws or other applicable laws permit organizations such as us to collect, use, or disclose data in person without your consent, such legal permission shall continue to apply.
5. Personal data submitted or contained on the website may be intercepted or accessed by third parties without authorization, and technologies may fail to work or not work as expected, or the information may be accessed or misused by others, which are not faults of our own. However, we will implement reasonable security measures to protect your personal data in accordance with the provisions of the Personal Data Protection Law; nevertheless, absolute security cannot be guaranteed, such as but not limited to unauthorized disclosure resulting from malicious intent or complicated malicious content caused by hacking activities, which are not faults on our own.
IX. Children-related Information
These products and services are not intended for use by children below 13 years old. We will not knowingly collect or retain any personal data or non-personal identity information from anyone below 13 years old, or collect or retain any part of our platform, games, or services. Another situation does not work for them either. Parents or guardians should not permit their children to release personal data to us. Please refer to our terms of service for more information. If parents or guardians provide us with personal data of children below 13 years old, parents or guardians shall agree with our dealing with relevant children's information, and be bounded by the Privacy Policy. If parents or guardians do not allow us to deal with the personal data of children below 13 years old, please contact our Data Protection Officer. We will lock any accounts used solely by such children, and/or delete any personal data we believe has been sent by such children without the consent of parents or guardians. Similar situations with which parents or guardians agree or applicable laws require.
X. Information Collected by a Third Party
We or third parties may provide you with updated software apps for your download and use on or through the Services. These apps may privately access and allow third parties to view your identity information, such as your name, user ID, IP address of your device, or other information, including the games you play during any particular session, or any cookie already set up by yourself or by software apps or third-party websites. Moreover, these apps may request you to directly provide additional information to third parties. Third-party products or services offered through these apps are not owned or controlled by us.
XI. Security Obligations and Disclaimer from Third Party Websites
1. We do not guarantee the security of personal data and/or other information you provide on third-party websites. We implement various security measures to protect and maintain the security of your personal data we hold or control. After being stored in our secure network, your personal data can only be accessed by a limited number of individuals who have special access to our system and promise to ensure the security of such data. We recommend the use of safe servers when you place an order or access your personal data. All personal data or information you provide will be encrypted in our database and can only be accessed as described above.
2. In order to provide you with added value, we may choose various third-party websites to link to our website or games. We may also establish co-marketing and other relationships to provide our visitors with e-commerce and other services. These linked websites own separate privacy policies and security measures. Even if such third parties are affiliated with us, we have no control over these linked websites, and each of them has separate and independent data collection and privacy practices.
3. As a result, we're not liable for the contents, security practices (or lack thereof), and other practices of these linked websites. These linked websites are for your convenience only, so you're solely responsible for accessing them. However, we seek to protect our website and games and the integrity of each website link, so we welcome any feedback on the linked websites. This includes but is not limited to XXX, if a specific website is closed).
XII. Will We Transmit Your Information to the Outside World?
Your personal data or information may be transferred abroad or stored or processed outside your country. We will only transfer your personal data abroad in accordance with the Personal Data Protection Law and the Privacy Policy. By accepting the Privacy Policy, you agree to transfer your personal data to any country/region where our affiliates, developers, servers, and/or databases are located. In most cases, your personal data will be processed in the region where our data centers and servers are located. As different jurisdictions may raise different data protection requirements, we will take appropriate protection measures to protect your data.
XIII. How Do You Revoke, Delete, Request Access to or Revise the Information Provided by You?
1. Revoke consent
(1) You may send an email to our Personal Data Protection Department (guangzhouchuguang@gmail.com) to revoke your consent that allows us to collect, use, and/or disclose your personal data held or controlled by us. We will deal with these requests in accordance with the Privacy Policy and our obligations under the Personal Data Protection Law.
(2) However, by revoking the consent, we may not be able to provide you with the Services, and we may need to terminate the relationship or contract between you and us.
2. Request access to or revision of personal data
(1) If you have registered an account with us, you may access or revise your personal data held or controlled by us through the account settings page or our platform, or the game label. If you have not registered an account with us, you may request access to or revision of your personal data held or controlled by us by submitting a written request to us. We need you to provide sufficient information to determine your identity and the nature of the request to better process such request. Please submit your written request to our Data Manager by email. Moreover, if required by applicable laws, we will take measures to notify any third parties who have received or used your personal data of such revision.
(2) Where permitted by applicable laws, we reserve the right to reject some requests, and/or may charge reasonable fees for processing the request to access your personal data. In this case, we will notify you and provide you with written the estimation of any fees that may apply. As required by applicable laws, we will provide you with the required personal data within a reasonable period of time after you pay such fees.
(3) Please email your request to our Data Protection Officer in writing. As required by applicable laws, we reserve the right to respond only to the request submitted in accordance with the Privacy Policy.
XIV. Contact Information
If you have any doubts or complaints about our privacy policies, please contact our Data Protection Officer via email guangzhouchuguang@gmail.com.
Date of Last Update: June 14, 2022