Privacy Policy

This policy is formulated by the products and services (hereinafter collectively referred to as "products and services") provided by the game and its affiliated companies and strategic partner companies' website platforms and mobile terminals.

This policy will help you understand the following:

1. How we collect and use your personal information

2. How we use cookies and similar technologies

3. How we share, transfer and publicly disclose your personal information

4. How we protect your personal information

5. Your rights

6. How we process personal information of minors

7. How your personal information is transferred globally

8. This policy may change

9. How to contact us

 

The game fully understands the importance of personal information to you and will do its best to protect the safety and reliability of your personal information. We are committed to maintaining your trust in us and abide by the following principles to protect your personal information: the principle of consistency of rights and responsibilities, the principle of clear purpose, the principle of choice and consent, the least sufficient principle, the principle of ensuring security, the principle of subject participation, the principle of openness and transparency, etc. .

Please note that the game may modify and update this Agreement from time to time, and you agree to check the latest version of this Agreement at any time. Please read and understand this Privacy Policy carefully before using our products (or services) to ensure that you are always aware of the latest version of this Privacy Policy.

 

1. How we collect and use your personal information

Personal information refers to various information recorded electronically or in other ways that can identify a specific natural person alone or in combination with other information or reflect the activities of a specific natural person. The game collects and uses your personal information based on the following purposes described in this policy. If you need to use your information beyond the following purposes, the game will obtain your consent in an appropriate manner:

(1) Provide you with the products and services provided by the game on its and/or its affiliates’ game platforms

1. Register as a user

Information filled in to complete account creation. For example: your mobile phone number, ID number, created user name.

2. Provide you with advertisements, information and product information that may be of interest to you

In order to provide you with advertisements that are more relevant to you to replace generally delivered advertisements, we may collect and use your operation records in the game and some necessary device information (for example: your unique device identification code), as well as when you use We browse or request other information and content details, game account transaction information, etc. when we provide services, extract your browsing, behavioral habits and other characteristics, and use feature tags to send emails, text messages or other methods to people with the same or similar tags as you. User groups send marketing information to provide or promote our products and services.

3. Payment and settlement

In order to facilitate you to comprehensively judge your account and transaction risks, conduct identity verification, detect and prevent security incidents when you pay for relevant orders, we may collect your personal virtual property information during the transaction process (only transaction records, virtual currency, Virtual property information such as virtual transactions, game redemption codes, etc.).

4. Security

We will use some of your personal commonly used device information for identity verification, security prevention, fraud monitoring, archive backup and other purposes. For example, unique device codes are used for security prevention and user identification, and personal Internet access records are used for security prevention and fraud monitoring.

When you use our customer service, we may save your communication/call records and content or the contact information you left and other information in order to contact you or help you solve problems, or record the solutions and results of related problems. .

5. Product development and service optimization

For example, in order to repair system failures and optimize our services, we may need to record and analyze the information generated when the system fails.

 

(2) Scope of application of the privacy policy

Except for some specific products and services, this Privacy Policy applies to all our products and services. Specific privacy policies will apply to these specific products and services. Specific Privacy Policies for certain products and services will more specifically describe how we collect and use your information in such products and services. If there is any inconsistency between the privacy policies of relevant specific products and services and this Privacy Policy, the Privacy Policy of the specific products and services shall apply.

(3) Applicable exceptions to this privacy policy

Our Services may include or link to social media or other services (including websites) provided by third parties. For example:

1. You use the "Share" button to share certain content with our services, or you use a third-party connection service to log in to our services. These functions may collect your relevant information (including your log information), and may install cookies on your computer to allow the above functions to function properly;

2. We provide you with links through advertisements or other means of our services so that you can access third-party services or websites. The third party collects and applies your information.

Such third-party social media or other services may be operated by third parties. Your use of such third-party social media services or other services (including any personal information you provide to such third parties) shall be governed by the third party’s terms of service and privacy policy (not this Privacy Policy). You need to read its terms carefully. This Privacy Policy only applies to the information we collect and does not apply to the services provided by any third party or the information use rules of the third party. We are not responsible for any third party's use of the information provided by you.

 

2. How we use cookies and similar technologies

(1) Cookies

Cookies usually contain an identifier, the site name, and some numbers and characters. To ensure the normal operation of the website and to help us identify you as our registered user, we will store a small data file called Cookie on your computer or mobile device. We will not use Cookies for any purpose other than those stated in this policy. You can manage or delete cookies through browser or other means according to your preferences.

(2) Do Not Track (Do Not Track)

Many web browsers have a Do Not Track feature that issues a Do Not Track request to a website. Currently, the major Internet standards organizations have no policies in place that govern how websites should respond to such requests. However, if your browser has Do Not Track enabled, all of our sites will respect your choice. However, please note that this may affect your experience of using the products and services provided by the game.

 

3. How we share, transfer and publicly disclose your personal information

(1) Sharing

You understand and agree that we will provide it to third parties through sharing on the premise that the data recipient cannot re-identify the subject of personal information. We may share your personal information with any company, organization and individual outside the game under the following circumstances:

1. Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.

2. We may share your personal information externally in accordance with laws and regulations, or in accordance with the mandatory requirements of administrative departments.

3. Sharing with our affiliated companies: Your personal information may be shared with the game’s affiliated companies. We will only share personal information that is necessary and subject to the purposes stated in this Privacy Policy. If affiliated companies want to change the purpose of processing personal information, they will ask for your authorization and consent again.

4. Sharing with authorized partners: Only to achieve the purpose stated in this policy, some of our services will be provided by authorized partners. We may share some of your personal information with partners to provide better customer service and user experience. We will only share your personal information for legal, legitimate, necessary, specific, and clear purposes, and we will only share personal information necessary to provide services. Our partners have no right to use the shared personal information for any other purpose.

Currently, our authorized partners include the following two types:

1) Authorized partners in advertising and analysis services. Unless we have your permission, we will not use your personally identifiable information (information that is sufficient to identify you, such as name or email address, through which you can be contacted or identified) to provide advertising and analysis services. shared by partners.

2) Suppliers, service providers and other partners. We send information to vendors, service providers and other partners who support our business, such as communications service providers who send push notifications on our behalf. This support includes providing technical infrastructure services, analyzing how our services are used, measuring the effectiveness of advertising and services, providing customer service, payment facilitation and other support for gaming products and services.

(2) Transfer

We will not transfer users' personal information to any company, organization or individual, except for transfers that must be made in accordance with the laws and regulations of the country where the user is located, and we will continue to protect or require new management in accordance with the standards required by the laws and regulations of the country where the user is located. We will continue to protect users' personal information in accordance with this policy.

(3) Public disclosure

We will only publicly disclose your personal information under the following circumstances:

1. After obtaining your explicit consent;

2. Related to national security and national defense security;

3. Relevant to public safety, public health, and major public interests;

4. Related to criminal investigation, prosecution, trial and execution of judgments;

5. To protect the life, property and other major legitimate rights and interests of the information subject or other individuals but it is difficult to obtain your consent;

6. The information collected is disclosed to the public by you;

7. Collect information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;

8. Necessary to sign a contract according to your requirements;

9. Necessary to maintain the safe and stable operation of game services, such as discovering and handling product or service failures;

10. Necessary for legitimate news reporting;

11. When it is necessary for an academic research institution to conduct statistical or academic research based on public interests, and when providing the results of academic research or description to the outside world, the information contained in the results shall be de-identified;

12. Other situations stipulated by laws and regulations.

 

4. How we protect your personal information

(1) We will take reasonable and feasible measures to protect your personal information

We have a dedicated security team responsible for handling data protection related matters. At the same time, we have also set up specific processes and security procedures for specific user data collection and processing to ensure that the storage and use of data comply with our expectations and legal and regulatory requirements. For example, we use TLS/SSL encryption technology for data transmission, and use the SHA256/AES encryption algorithm for stored sensitive data to ensure its security. In addition, we regularly conduct risk assessments on security policies and data protection measures to ensure that our products are not threatened by risks such as data leaks or privacy violations.

 

(2) Other security measures we take to protect information

We manage the storage and use of standardized information by establishing data classification and classification systems, data security management specifications, and data security development specifications.

We implement comprehensive security controls on data through information contact confidentiality agreements, monitoring and auditing mechanisms.

(3) We only allow game employees who need to know this information to access your information, and require all personnel who may have access to your information to fulfill corresponding confidentiality obligations. Failure to fulfill these obligations may result in legal liability or suspension of the partnership with the game.

(4) We will take all reasonable and feasible measures to ensure that no irrelevant personal information is collected. We will only retain your personal information for as long as is reasonably necessary, unless an extension of the retention period is required or permitted by law.

(5) The Internet is not an absolutely secure environment, and emails, instant messaging, and communication with other game users are not encrypted. We strongly recommend that you do not send personal information through such methods. Please use a complex password to help us keep your account secure.

(6) The Internet environment is not 100% safe, and we will try our best to ensure or guarantee the security of any information you send us. If our physical, technical, or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of information, resulting in damage to your legitimate rights and interests, we will bear corresponding legal liability.

(7) After an unfortunate personal information security incident occurs, we will take necessary measures to prevent the expansion of the security incident and inform you in the form of push notifications, announcements, etc.

 

5. Your rights

In accordance with the laws, regulations, and standards of the region where the user is located, as well as the common practices of other countries and regions, we guarantee that you can exercise the following rights with respect to your personal information:

(1) Access your personal information

You have the right to access your personal information, except for exceptions provided by laws and regulations.

(2) Control your personal information

You can query and manage your personal information under your account. Your game account name and ID number are your important online identities. For security and identification reasons, they cannot be changed after registration.

(3) Delete your personal information

We will only collect and use your information in accordance with this policy to implement the functions of our products or services. If you find that we collect and use your personal information in violation of laws, administrative regulations or the agreement between the two parties, you can ask us to delete it. If you find that there are errors in your personal information that we collect and store, you can also ask us to correct it. Please contact email: cs@sofungames.com to apply to delete your personal information

(4) Respond to your above request

For security reasons, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request. We will respond within a reasonable time frame. If you are not satisfied, you can contact the game customer service or handle it in accordance with the "User Registration Service Agreement".

In principle, we do not charge fees for your reasonable requests, but for repeated requests that exceed reasonable limits, we will charge a certain cost depending on the situation. For those that are gratuitously repetitive, require excessive technical means (for example, require the development of new systems or fundamentally change existing practices), pose risks to the legitimate rights and interests of others, or are very impractical (for example, involving information stored on backup tapes) request, we may deny it.

In the following circumstances, we will not be able to respond to your request in accordance with legal and regulatory requirements:

1. Directly related to national security and national defense security;

2. Directly related to public safety, public health, and major public interests;

3. Directly related to criminal investigation, prosecution, trial and judgment execution;

4. There is sufficient evidence to show that you have subjective malice or abused your rights;

5. Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;

6. Involving business secrets;

7. Other situations where we have reasonable grounds to refuse.

 

6. How we handle minors’ personal information

For the collection of personal information from minors, we will only use or publicly disclose this information when permitted by law, with the explicit consent of parents or guardians, or when necessary to protect minors.

 

7. This policy may change

We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any changes to this policy on this page.

For major changes, we will also provide more prominent notices. If you do not agree with the changed content, you can choose to stop using our services; if you continue to use our services, you agree to be bound by the revised terms. Subject to the Privacy Policy.

 

8. How to contact us

If you have any questions, comments or suggestions about this privacy policy, you can contact the game customer service for feedback. If you are not satisfied with our response, especially if our personal information processing behavior damages your legitimate rights and interests, you can also handle it in accordance with the "User Service Agreement".

It is our purpose to create a comfortable, fair and humane gaming environment for users. The gaming platform pays attention to user needs and is always open to accepting users from different regions, ages and cultural backgrounds. Whether it is game staff performing their own missions in their respective jobs, or tens of thousands of users playing different roles in game platform games, they all have many expectations and dreams for online games. We are full of gratitude and respect for users who respect the rules of the game and respect others. Let us work together to create a green gaming environment!

July 1, 2019