Privacy
Policy and User Agreement
Privacy
Policy
INTRODUCTION
This privacy policy
informs you of your choices and our practices regarding any personal
information you provide to us. Your use of the mobile game (“Game”) and website for the Game (“Community
Website”) distributed by Hainan Puli Network Technology
Co. Ltd. (“Puligame”, “we” or “us”) involves the collection and use of your personal information. It
is important for you to understand how this happens and how you may control it.
When you contract
to use the Game or use the Community Website (the “Game Services” or “Services”), you
accept our rules and policies regarding your personal information and you
expressly consent to us collecting, processing, using and storing your personal
information, as described in this policy.
You
acknowledge that you have read and understood this privacy policy. If you do
not agree with this privacy policy, you must not use the Game Services. If you
change your mind in the future, you may withdraw your consent to use of your
personal information in accordance with this policy.
If you have any
comments, questions or complaints regarding the processing of your personal
information, you can contact us at support@puligame.com.
The
Types of Personal Information We Use
This section
describes the different types of personal information we collect and how we
collect it. We will collect and use the following information about you:
•
Information you give us. You give us information about you:
o when you register
for the Game (including your nominated nickname, and information we import from
your connected social media account (e.g. Facebook, Twitter or Apple sign-in
account) in order to set up your profile, including your name as it appears on
your social media profile and your profile picture;
o when you set up your
profile for the Game (including information you voluntarily elect to provide in
order to customise gameplay, such as gender);
o when you submit
your contact details to us (including your name, email address and physical
address) as part of promotional activities for the Game; and
o when you make
purchases in the Game (in which case we will process the information you
provide to us to facilitate the payment).
•
Information we collect about you. We automatically collect certain data from
you when you use the Game and/or the Community Website, including your IP
address, physical location and device information (such as device type, network
data, OS) and information regarding your use of the Game and/or the Community
Website, such as date and time stamps of actions. We also collect and store
your data each time you interact with us, for example, when you use in-app
support to communicate with us.
•
Information you generate and display in the course of using the Game Services.
You may provide additional information as part of your profile (such as
gender). You may also provide or generate information when you communicate with
other users in the Game (e.g., chat log data, chat content).
Cookies
We use cookies and
other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Services. Cookies are small
files which, when placed on your device, enable us to provide certain features
and functionality.
You have the option
to permit installation of such Cookies or subsequently disable them. You may
accept all cookies, or instruct the device (in the case of the Game) or web
browser (in the case of the Community Website) to provide notice at the time of
installation of cookies, or refuse to accept all cookies by adjusting the
relevant cookie retention function in your device. However, in the event of
your refusal to install cookies, the Game may be unable to operate as designed.
Children
Our Service is not
intended for children. If you are located in the European Economic Area and
under the age of 13, you must not use the Service for any purpose.
How
We Use Your Personal Information
We will use the
information in the following ways and in accordance with the following legal
bases:
Registration
Information (ID on social media accounts like Facebook, Twitter, Game Center,
Google Play, Apple (collectively, “Social ID”), Open ID, nick name,
email address, avatar): We use Registration Information to set-up user
accounts, allow users to log-in to the Game and provide Services to users. We
use this information with your consent to this Privacy Policy.
Device Information
(Device ID, Device Type, Operating System, CPU, RAM, IP address, MAC address):
We use this information to provide and improve the Game Services such as: to
allow users to download and install the Game on their devices; to record and
keep track of requests from users of the Game; to detect the user network and
device status when the user is playing the Game; and to correct bugs or errors
that occur when the user is playing the Game. Use of Device Information is
necessary to perform our contract with you to provide the Game.
Contact Information
(Name, Email, Address, Phone Number, Instant Messaging Account): We use this
information to send notifications to users to inform them of our promotional
activities and any rewards they are entitled to. We use this information with
your consent to this Privacy Policy.
Physical Location:
We use this information to provide some Location Based Services such as forming
a team with people nearby. We use this information with your consent to this
Privacy Policy.
Social ID: We use
this information to share certain content on social media. We use this
information with your consent to this Privacy Policy.
User Profile
(gender, age, photo and etc): We use this information to provide customized
services to users such as personal information page. We use this information
with your consent to this Privacy Policy.
Game Data (Level,
Score, chat log and etc): We use this information to provide Services to users
as it is the basis of our Game. Use of Game Data is necessary to perform our
contract with you to provide the Game.
How
We Store and Share Your Personal Information
In order to perform
our contract with you, your personal information will be accessible from and
will be processed on our servers (depending upon your location and the game
server you select). Our servers are located in:
•
the United States; and
•
the European Union
We share your
personal information with selected third parties in and outside your country,
including:
•
third parties that provide services in support of the Game and the Community
Website, including:
o Amazon Web Services (“AWS”), located in the United States, that processes download and
instalment information, account set-up and log-in information, user log
information, purchase information, notification push information, social
sharing information, on the basis of Privacy-Shield certified, for the purpose
of hosting the Game;
o Appsflyer, whose
data center is located in Ireland, that processes Device ID and some of in-app
activities, on the basis of your consent to this Privacy Policy, for the
purpose of the evaluation of its marketing services;
o Facebook, located
in the United States, that processes Device ID and some of in-app activities,
on the basis of Privacy-Shield certified, for the purpose of the evaluation of
its marketing services;
o Amap, located in
the United States, that processes physical locations, on the basis of the
performance of our contract with you, for the purpose of providing in-app
Location-Based Service;
o Apple, located in
the United States, that processes of purchase information, on the basis of the
performance of our contract with you, for the purpose of sign-in function and
providing in-app purchase;
o Google, located
in the United States, that processes of purchase information, on the basis of
Privacy-Shield certified, for the purpose of providing in-app purchase;
o Helpshift,
located in the United States, that processes of Registration Information and
Device Information, on the basis of Privacy-Shield certified, for the purpose
of providing in-app customer support;
•
related group companies, with whom we share all of your personal information to
operate the Game Services. The transfers contemplated above are made pursuant
to our contract with you.
•
law enforcement agencies, public authorities or other judicial bodies and
organisations. We disclose information if we are legally required to do so, or
if we have a good faith belief that such use is reasonably necessary to:
o comply with a
legal obligation, process or request;
o enforce our terms
of service and other agreements, policies, and standards, including
investigation of any potential violation thereof;
o detect, prevent
or otherwise address security, fraud or technical issues; or
o protect the
rights, property or safety of us, our users, a third party or the public as
required or permitted by law (including exchanging information with other
companies and organisations for the purposes of fraud protection); and
•
a third party that acquires all or substantially all of us or our business. We
will disclose information to a third party in the event that we sell or buy any
business or undergo a merger, in which case we will disclose your data to the
prospective buyer of such business. We will also disclose information to a
third party if we sell, buy, merge or partner with other companies or businesses,
or sell some or all of our assets. In such transactions, user information may
be among the transferred assets.
The
Security of Your Personal Information
We are committed to
maintaining the privacy and integrity of your personal information no matter
where it is stored. Our company has information security and access policies
that limit access to our systems and technology. We also protect data through
the use of technological protection measures such as encryption. Your personal
information will remain subject to our technical and organisational controls
and our policies and procedures (including this Privacy Policy).
Unfortunately, the transmission
of information via the internet is not completely secure. Although we will do
our best to protect your personal information, we cannot guarantee the security
of the information transmitted to our services; any transmission of your
information is at your own risk.
Data
Retention
We will retain most
of your personal information for the lifetime of your use of the Services (i.e.
until account deletion in accordance with your request) except that: Contact
Information obtained from promotional activities will be retained during the
lifetime of such activities and Contact Information obtained from customer
services will be retained within two years of the date you provide.
When destroying
personal information, measures will be taken to make the personal information
irrecoverable or irreproducible, and electronic files which contain personal
information will be deleted permanently using a technical method which makes
the files irreproducible.
In the event that
the processing and retention period have terminated, but personal information
is required to be retained continuously for other reasons including for the
purposes as prescribed under applicable laws, the relevant personal information
will be stored and maintained separately from other types of personal
information. If you require us to destroy your personal information before the
end of its life cycle (as set out in the retention policy above), we will
destroy your personal information in accordance with local laws).
Your
Rights
This section (“Your Rights”) applies to users that are located in the European Economic Area
only. For users located in other territories, please refer to the privacy
clauses in our User Agreement.
You have certain
rights in relation to the personal information we hold about you. Some of these
only apply in certain circumstances (as set out in more detail below). We must
respond to a request by you to exercise those rights without undue delay and at
least within one month (though this may be extended by a further two months in
certain circumstances). To exercise any of your rights, please contact us at support@puligame.com.
Access
You have the right
to access personal information we hold about you, how we use it, and who we
share it with. If you believe we hold any other personal information about you,
please contact us and complete the corresponding request form.
Portability
You have the right
to receive a copy of certain personal information we process about you. This
comprises any personal information we process on the basis of your consent
(e.g., gender information) or pursuant to our contract with you (e.g., game
play statistics), as described in the section “How We Use Your Personal Information”. You have the right to receive this information in a structured, commonly
used and machine-readable format. You also have the right to request that we
transfer that personal information to another party.
If you wish for us
to transfer such personal information to a third party, please ensure you
detail that party in your request. Note that we can only do so where it is
technically feasible. Please note that we may not be able to provide you with
personal information if providing it would interfere with another’s rights (e.g., where
providing the personal information we hold about you would reveal information
about another person or our trade secrets or intellectual property).
Correction
You have the right
to correct any personal information held about you that is inaccurate. If you
believe we hold any other personal information about you and that information
is inaccurate, please contact us and complete the request form.
The right to delete your data
You can delete your account, or remove certain personal information. If there is any other personal information you believe we process that you would like us to erase, please contact us at support@puligame.com.
Once you choose to delete your account, you will not be able to reactivate your account or retrieve any of the content or information you have added.
You may request
that we erase the personal information we hold about you in the following
circumstances:
•
you believe that it is no longer necessary for us to hold such personal
information; or
•
you believe the personal information we hold about you is being unlawfully
processed by us.
You can also
exercise your right to restrict our processing of your personal information (as
described below) whilst we consider your request.
We may need to
retain personal information if there are valid grounds under data protection
laws for us to do so (e.g., for the defence of legal claims or freedom of
expression) but we will let you know if that is the case. Where you have
requested that we erase personal information that has been made available
publicly on the Game Services and there are grounds for erasure, we will use
reasonable steps to try to tell others that are displaying the personal
information or providing links to the personal information to erase it too.
Restriction
of Processing to Storage Only
You have a right to
require us to stop processing the personal information we hold about you other
than for storage purposes in certain circumstances. Please note, however, that
if we stop processing the personal information, we may use it again if there
are valid grounds under data protection laws for us to do so (e.g., for the
defence of legal claims or for another’s protection). As above, where we agree
to stop processing the personal information, we will try to tell any third
party to whom we have disclosed the relevant personal information so that they
can stop processing it too.
You may request we
stop processing and just store the personal information we hold about you
where:
•
you believe the personal information is not accurate for the period it takes
for us to verify whether it is accurate;
•
you wish to erase the personal information as the processing we are doing is
unlawful but you want us to retain the personal information but just store it
instead; or
•
you wish to erase the personal information as it is no longer necessary for our
purposes but you require it to be stored for the establishment, exercise or
defence of legal claims.
Objection
You have the right
to object to our processing of personal information about you. We will consider
your request in other circumstances as detailed below by contact us and
completing the request form.
Announcements
We may from time to
time send you announcements when we consider it necessary to do so (such as
when we temporarily suspend Game access for maintenance, or security, privacy
or administrative-related communications). You may not opt-out of these
service-related announcements, which are not promotional in nature.
Contact
& Complaints
For the purposes of
European Data Protection Law, the Data Controller is Hainan Puli Network
Technology Co. Ltd..
In the event that you wish to make a complaint
about how we process your personal information, please contact us in the first
instance.
--Contact
Information--
Name: Hainan Puli
Network Technology Co. Ltd.
Mail:【邮箱】 support@puligame.com
This is without
prejudice to your right to launch a claim with the data protection authority in
the country in which you live or work where you think we have infringed data
protection laws.
Changes
If we make any
material changes to this policy, we will post the updated policy here and
notify our users. Please check this page frequently to see any updates or
changes to this policy.