Privacy Policy

2019-11-21 08:45:17   2510   2206

Privacy Policy

(Last Updated: November 15, 2019)

Beijing Elex Technology Co., Ltd. (“ELEX,” “we,” “our,” or “us”) is the operator and controller of various mobile applications and other online services and websites (collectively, the “Services”). We are dedicated to protecting the privacy rights of our online users (“you,” “users,” and “user”), and have adopted this Privacy Policy to explain how we collect, store, use, disclose, and manage your personal information and data. This Privacy Policy applies to the Services in which it is posted only. Unless otherwise stated at the time of collection, this Privacy Policy does not apply to information collected outside of the Services in which it is posted.

ELEX is a valid licensee and participating member of the Entertainment Software Rating Board’s Privacy Certified Program (“ESRB Privacy Certified”). To protect your privacy, we have voluntarily undertaken this privacy initiative and have had the Services that display an ESRB Privacy Certified Seal reviewed and certified by ESRB Privacy Certified to meet established online information, collection, use, and disclosure practices. As a licensee of this privacy program, we are subject to audits of the Services and other enforcement and accountability mechanisms administered independently by ESRB Privacy Certified.

If you do not agree with this Privacy Policy or our Terms of Service, please do not access or use our Services.

Note to Parents

The Services are intended for enjoyment by a broad audience. They are not directed to users under 13 years old (“Children” or “Child”). We do not knowingly collect or store personal information from Children. However, we do collect information, including personal information, from all users of the Services, as explained further in Section 1 below. If you believe we may have unintentionally collected personal information from your Child, please contact us using the information in the Contact Us section below.

In addition, we urge you to instruct your Children to never give out their real names, addresses, phone numbers, or other personal information when online, unless you have given them permission to do so. We also recommend you familiarize yourself with the parental controls available on the devices you provide to your Child (e.g., mobile phones and tablets) and keep a watchful eye on your Child’s online activity. If you have any concerns, please contact us immediately using the information in the Contact Us section below.

Parents/guardians are jointly and severally liable for all acts (including purchases and payments in the Services) and omissions of their Children when using the Services.

Table of Contents

1. Information We Collect About You

2. How We Use Information We Collect

3. When We Disclosure Your Information

4. Third-Party Links

5. Publicly Posted Information

6. Security

7. Your Privacy Rights

8. Data Retention Policy

9. International Data Transfer of Your Information

10. Changes to this Privacy Policy

11. Contact Us

1. Information We Collect About You

ELEX collects information you provide directly to us via the Services, certain technical information automatically when you use our Services, and when other sources (i.e., third parties) provide it to us. As explained below, some of the information we collect may identify you personally (whether alone or in combination). This is considered personal information.

A. Information You Provide To Us

There are several opportunities for you to provide or disclose personal information directly to us via the Services. The decision whether to provide the information to us belongs to you. If you prefer not to disclose the information, you will still be able to utilize the Services, but may not be able to utilize all aspects of them. The information you choose to provide to us will either be processed with your affirmative consent, pursuant to a contractual necessity or in furtherance of our legitimate business interests.

Profile Information: We collect information about you when you create or modify your profile, set preferences, and sign-up for or make purchases through the Services. For example, depending on the Service, you may have the option of adding a display name, profile photo, age, gender, geographic information and other details to your profile information to be displayed in the Service.

Content you provide through our products: We collect and store content that you send, receive and share when you use the Services. This content includes any information about you that you may choose to include. Examples of content we collect and store include but are not limited to: your email address, when you choose to give it to us; the messages you post, exchange or reply in message boards, forums or chat areas, including, in certain Services, voice messages you send to your friends; information you provide in connection with a survey or contest; and any feedback you provide to us. Content also includes the files and links you upload to the Services, including art you create and share with us and other users in our Services, and pictures and audio recording you upload.

Content you provide through our websites: We also collect content you submit to our websites, which include social media or social networking websites operated by us (e.g., our Facebook pages). For example, you provide content to us when you provide feedback or when you participate in any interactive features, surveys, contests, promotions, activities, or events.

Information you provide through our support channels: The Services also include our customer services and technical support, where you may choose to submit information regarding a problem you are experiencing with a Service. Whether you speak to one of our representatives directly or otherwise engage with our support team (or our third-party service providers), you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue. You may upload photos and voice messages to customer service. Whatever information you provide will be used solely to address your request for support.

Payment Information: We collect certain payment and billing information when you purchase certain paid Services. You might also provide payment information, such as payment card details, which we collect via secure payment processing services.

B. Information Collected Automatically

We collect certain information automatically from and about the device(s) you utilize to access the Services and your use of the Services. Specifically, we and/or our third-party service providers collect your Internet Protocol (IP) address, type of device, operating system, browser type, language settings, device IDs, mobile advertising IDs (e.g., for Android users, the GPS ADID also known as the “Google Play Services ID for Android”), MAC address, GSSF ID, usage data (including the features of the Services you use, and when and how often you use the Services), URLs of referring/exit pages, and crash data. We use your IP address and/or country preference to approximate your location (i.e., country and, at times, city) to provide you with a better experience, and in some of our Services, we also collect precise geolocation data from your device (i.e., street-level).

Some of the Services use cookies and similar tracking technologies, such as pixel tags, to automatically collect information from and about your device(s) and your use of the Services. A “cookie” is a small file that is saved on your computer or mobile device, which uniquely identifies your browser and provides information to the cookie sender. Pixel tags are small blocks of code on a webpage that allow websites to do things like read and place cookies. We also use third-party software development kits (also known as SDKs) in our mobile apps, which collect information about your device(s) and use of the Services. These trackers help us to deliver the Services to you, to improve your user experience and to analyze traffic on and use of the Services. In addition, they are used for marketing and advertising, including to help us to measure the effectiveness of our marketing campaigns and potentially for interest-based advertising by third parties.

Third parties that provide support for internal operations, as well as marketing partners and analytics providers include the following:

Third Party

Category

Privacy Statements and Opt-out Options

Adbert

Advertising

http://www.adbertech.com/privacy

http://www.adbertech.com/gdprprivacy

http://www.adbertech.com/setgdprcookie

Adjust

Analytics

https://www.adjust.com/terms/privacy-policy/

AIhelp

Customer Support

https://aihelp.net/privacypolicy/

Alipay

Payment Processing

https://render.alipay.com/p/f/agreementpages/alipayglobalprivacypolicy.html

Apple (Search Ads)

Analytics; Advertising

https://searchads.apple.com/privacy/

AppsFlyer

Analytics; Advertising

https://www.appsflyer.com/services-privacy-policy

https://www.appsflyer.com/optout

Amazon (AWS)

Cloud Provider

https://aws.amazon.com/privacy/

Branch

Analytics; Advertising

https://branch.io/policies/#privacy

Chartboost

Advertising

https://answers.chartboost.com/en-us/articles/200780269

Facebook (Sign-in)

Functional; Advertising; Social

https://www.facebook.com/privacy/explanation

Google (APIs, Analytics, DoubleClick, Firebase, Sign-in, Voice, Video/YouTube, etc.)

Sign-in; Analytics; Advertising; Functional

https://policies.google.com/privacy

https://firebase.google.com/support/privacy

https://support.google.com/ads/answer/2662922?hl=en-GB

https://tools.google.com/dlpage/gaoptout

InMobi

Analytics; Advertising

https://www.inmobi.com/privacy-policy/

https://www.inmobi.com/page/opt-out/

Kingsoft

Cloud Provider

https://docs.ksyun.com/documents/2753

Liftoff

Advertising

https://liftoff.io/privacy-policy/

https://liftoff.io/opt-out/

Nanigans

Advertising

https://www.nanigans.com/privacy-policy/

http://www.nanigans.com/AndroidDoNotTrack.apk

Parse

Messaging Service

https://community.parseplatform.org/privacy

Ping++

Payment Processing

https://www.pingxx.com/terms

TalkingData

Analytics; Advertising

http://www.talkingdata.com/privacy.jsp?languagetype=zh_en

http://www.talkingdata.com/optout.jsp?languagetype=en_us

Tencent (Bugly and WeChat)

Crash Reporting; Social

https://privacy.qq.com/yszc-en.htm

Twitter

Social

https://twitter.com/en/privacy

Unity (IAP and Analytics)

Analytics; Functional

https://unity3d.com/legal/privacy-policy

We also utilize certain third parties in China and Russia only. For more information on those third parties, please contact us.

C. Information We Receive From Other Sources

We receive information about you from other Service users, from third-party services, from our related companies, and from our business and channel partners.

Other services you link to your account: We receive information about you when you integrate or link a third-party service with our Services. For example, if you log into the Services using your Google credentials, we receive your name and email address as permitted by your Google profile settings in order to authenticate you. If you log into the Services using your Facebook credentials, we receive your Facebook username, profile picture, and email address, and you will have the option to share your friends list . The information we receive when you link or integrate our Services with a third-party service depends on the settings, permissions and privacy policy controlled by that third-party service. You should always check the privacy settings and notices in these third-party services to understand what data may be disclosed to us or shared with our Services.

Other Partners: We receive information about you and your activities on and off the Services from third-party partners, such as advertising and market research partners who provide us with information about your interest in and engagement with our Services and online advertisements.

Depending on the Services that you are using, some of the information listed above may not be collected. However, when this information is collected, we consider it to be in furtherance of our legitimate business interests.

2. How We Use Information We Collect

We process your personal information for the following purposes under a range of legal bases:

Purpose

Legal Basis

To improve, operate, manage, and provide you with the Services

Contract; Legitimate interests

To perform services requested by you, including to fulfill your orders, respond to your support requests, and send messages to your friends

Legitimate interests

To send you technical notices, updates, security alerts, information regarding changes to our policies, and support and administrative messages

Legitimate interests

To protect our legal rights, interests and the interest of others, including to prevent and address fraud, breach of policies or terms, or threats of harm

Legitimate interests, Legal obligation, or Vital interests

To monitor and analyze trends, usage and activities

Legitimate interests

For internal marketing, profiling and demographic purposes, so we can constantly improve the Services; adapt our Services to better suit your needs; and better understand and serve you

Legitimate interests

To send you messages or personalized information about our games, your scores, new features, contests, special offers, and more, including for marketing and promotional purposes

Legitimate interests or consent

To provide you with advertisements about the Services and to measure the effectiveness of the advertisements

Legitimate interests or consent

To fulfill other purposes that may be disclosed to you and for which you provide affirmative consent.

Consent

3. When We Disclose Your Information

ELEX discloses information about you to the below third parties. We do so to further our legitimate business interests.

· Affiliates. ELEX may share your information, including personal information, with its related entities, including its parent, subsidiary and sister companies. For example, we may share your information with our affiliates for customer support, marketing, technical operations, or to offer affiliated services to you. If we share your personal information with our affiliates, it is on the condition they have agreed to be bound by the terms of this Privacy Policy as it relates to their handling of your personal information.

· Application Providers. ELEX shares your information, including personal information, with our third-party service providers, which may include agents, vendors, developers, and consultants, among others. Service providers assist us with operating the Services and provide us with other services, including marketing and promotional services. Some of these third-party service providers are necessary to provide you with the Services, perform services requested by you, and prevent and address fraud, in which case we also share information with them to fulfill our contractual obligations.

· Advertising Partners. We may share your information, including advertising IDs, with third parties who help us market the Services, including to provide you with advertisements.

· Other Partners. Depending on the Service, we may share your information, including personal information, with our partners in connection with offering you co-branded services, selling or distributing our products or the products of our partners, or engaging in joint marketing activities.

· Mergers or Acquisition. In the event of, or during negotiations of, an actual or proposed merger, acquisition, reorganization, bankruptcy, sale of a line of business, or other similar event, your information may be shared with or transferred to ELEX’s successors or assigns or other third parties involved in the event.

· Security and Compelled Disclosure. We may share your information, including your personal data, to comply with the law or other legal process, and where required, in response to requests by public authorities, including to meet national security or law enforcement requests. We may also share your information in connection with an investigation of fraud, harassment, intellectual property infringements, or other activity that is illegal, a violation of our policies, or may expose you or us to legal liability. We may also share your information to protect the rights, property, life, health, security, and safety of us, the Services or a third party. We may share this information pursuant to a legal and/or contractual obligation, or a vital interest.

Except as set forth above and in this Privacy Policy, ELEX does not disclose, sell or rent your personal information to any third parties. However, we may share aggregated information that does not identify you or de-identified information about you with third parties or affiliates for any purpose, except as prohibited by law.

4. Third-Party Links

The Services may contain links to third-party websites or other online services. ELEX is not responsible for the content or the privacy policies or practices of any other websites or online services, or for the actions of the companies responsible for those websites and online services. Please review the privacy policies of those websites or online services before providing them with any personal information.

5. Publicly Posted Information

Whenever you publicly post personal information online (for example on message boards, public profiles, and in chat areas), that information is stored by us and becomes publicly available, subject to the collection and use of third parties (e.g., other users). ELEX is not responsible for the subsequent use of that information by third parties. Please take caution whenever you disclose personal information in a public manner. If you encounter any ELEX user who is improperly collecting or using information about you or other users, please contact us using the information in the Contact Us section below.

For certain forums, you may post or reply to a post using your full first and last name with the option to also display your primary in-game character. If your personal information is posted on one of our forums, you may contact us to request removal using the information in the Contact Us section below. If we are unable to remove your personal information, we will notify you and explain the reason.

6. Security

ELEX takes reasonable steps to help protect the security and integrity of any personal information you provide to us. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your personal information through the Services. If we learn that your personal information has been compromised by a data breach, we will notify you consistent with applicable laws.

Please also keep in mind that you are responsible for maintaining the secrecy of your passwords and account information. Please be careful and responsible whenever you are online.

7. Your Privacy Rights

You may have the right to know how your personal information will be collected, processed, stored, and used; access, update, and request the deletion of information you have previously provided to us; request a portable copy of your personal information; withdraw previously provided consent; and object to our processing of your personal information, including for direct marketing and profiling purposes. In addition, you have the right to opt-out of our use of your personal information for purposes of targeted or interest-based advertising at any time. For more information on interest-based advertising and opt-out options, see https://youradchoices.com/learn. You may exercise or find out more about these rights by using the information in the Contact Us section below. Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask us to delete information that we are permitted by law or have an overriding legitimate ground to keep.

You also have the right to complain to a data protection authority about our collection and use of your personal information.

CALIFORNIA RESIDENTS

If you are a resident of California, section 1798.83 of the California Civil Code allows you to request information about the disclosure of your personal information to third parties for their direct marketing purposes. You may submit such a request in writing to:

ELEX

97 E. Brokaw Road, Suite 310, Room M

San Jose, CA 95112

ATTN: Privacy

DO NOT TRACK

Your browser may allow you to set a "do not track" (DNT) signal indicating that you do not wish your online activity to be tracked. Currently, our system does not support DNT signal headers that we may receive. However, the choices that we provide you concerning collection and use of your personal information will continue to operate as described in this Privacy Policy.

8. Data Retention Policy

How long we keep information we collect about you depends on the type of information, as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible (for example, because the information has been stored in backup archives), then we will securely store your information and isolate it from any further use until deletion is possible.

We retain your information for as long as your account is active and a reasonable period thereafter in case you decide to re-activate the Services. We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Service improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you. We retain the information you share on the chatting areas for 24 hours. If you private chat with other users, we will retain only 800 messages.

Any personal information you provide in connection with a customer service request or inquiry will be deleted by our third-party service provider one year from the date of your request or inquiry.

9. International Transfer of Your Information

Personal data may be transferred to, and stored in, a country operating outside the European Economic Area (EEA). Under Regulation (EU) 2016/679, the transfer of personal data to a country outside the EEA may take place where the European Commission has decided that the country ensures an adequate level of protection. In the absence of an adequacy decision, we may transfer personal data provided appropriate safeguards are in place.

Personal data collected from individuals, including those in the EEA, is stored on servers located in the United States and the Netherlands. We have verified that our Cloud Service Provider and data processors (where applicable) are certified under the EU-U.S. Privacy Shield Framework. For additional information, please click here.

10. Changes to this Privacy Policy

We may revise this Privacy Policy from time to time. Please check the Privacy Policy each time you use one of the Services to ensure you are aware of any changes in our privacy practices. The Privacy Policy will indicate the date it was last updated. If we make a material change in the way we handle your personal information, we will provide you with additional notice by sending you an email at the last email address we have for you, if any, or by prominently posting notice of the change on the Services. If you do not agree with any changes we make to the Privacy Policy, please stop using the Services.

11. Contact Us

If you have any comments, questions or complaints regarding this Privacy Policy or our privacy practices, please contact us using any of the following methods:

ELEX

97 E. Brokaw Road, Suite 310, Room M

San Jose, CA 95112

cok@elex.com

EU/EEA Representative

The nominated Representative for data protection matters within the EEA, pursuant to Article 27 of Regulation (EU) 2016/679 (the General Data Protection Regulation, or GDPR) is:

Adaptant Solutions AG

Rosenheimer Str. 139

81671 Munich

German

compliance-elex@adaptant.io

The nominated Representative for data protection matters in the United Kingdom is:

Adaptant Services Ltd

Kemp House, 160 City Road

London EC1V 2NX

United Kingdom

compliance-elex@adaptant.io

Inquiries may also be submitted through Adaptant’s contact form at https://www.adaptant.io/contacts-locations/.

ESRB Privacy Certified

As previously mentioned, ELEX is a licensee of the ESRB’s Privacy Certified Program. If you believe we have not adequately responded to your privacy-related inquiry or complaint, you may contact ESRB Privacy Certified at:

ESRB

Attn.: Privacy Certified Program

420 Lexington Avenue, Suite 2240

New York, NY 10170

privacy@esrb.org