profunSG Privacy Protection Guidelines
Last
Updated on: [202
4
-
01
-
19
]
Became effective on: [2021-
0
6-16]
Summary
Thank you for your choice of
the Game
provided by
PROFUN PTE. LTD.
.
The Google Developer Name
of us is
"
profunSG
"
(hereafter referred to as "we" or "us"; in the
Guidelines; the
contact information regarding personal data protection is: [Name:
Liang
; Email:
profunsg@gmail.com
]).
This
Privacy Protection Guidelines
applies whenever you play the Game that link to this guidelines.
In addition to "
profunSG Privacy Policy
" and "
profunSG License and Service Agreement
", through the
profunSG Privacy Protection Guidelines
("Guidelines"), we will further elaborate on how we collect, use, store
and share your personal information when you are playing
the Game
, as well as the relevant rights you are entitled to. The Guidelines are part of
the "
profunSG License and Service Agreement
". The highlights are as follows:
Definition:
1.
the Game(s)
, refers to
the Game
provided by
PROFUN PTE. LTD.
, sometimes also refers to other games together provided by
PROFUN PTE. LTD.
in this agreement, including client-based PC games,
web games, HTML5 games (H5 games), mobile games, and other types of games; and
the Game
may be provided in the form of software, in which case
the Game
also includes the related software and
documents.
2.
the Game's S
ervice, refers to all the online operation services regarding
the Game
s provided by
PROFUN PTE. LTD.
to you.
3.
You, also referred to as "player(s)" or
"user(s)",
refers to any natural person who is authorized to use
the Game
and
the Game's Service
.
In order to provide you with game entertainment and to
support the related player interaction, consumption and other services, we need to collect
information such as your game history, device information, login data and others. You hereby consent to provide the following specific
information for the purpose:
•
your age or birthday;
•
your first and last names;
•
your e-mail address;
•
a password;
•
game username(s);
•
details about
the Game
s you play;
•
approximate location information;
•
your game history;
•
your device's operating system and version;
•
your mobile device's identifiers, like your MAC Address, Identifier for
Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI);
•
your login data;
•
other information that helps us make sure it's you accessing your account,
information necessary for us to provide the support you request, or information you provide to help us
improve our Service (such as answers to an online survey or a feedback form).
In order to better protect both the physical and the
mental health of minors and facilitate a healthy access to the internet by minors, we may implement
more stringent anti-addiction measures in addition to the relevant regulations on anti-addiction
policies of online games. At the same time, we have been constantly developing and testing various
new technologies to better protect the minors.
You can manage your personal information and the
relevant authorizations according to the provisions of the Guidelines.
We adopt a wide range of security measures to ensure
that your personal information is protected under a reasonably safe manner.
By reading the full version of "
profunSG Privacy Protection Guidelines
", you may learn more about the processing rules of personal information such as
the
correspondence between the types and the uses of personal information.
1. Information We Collect
While you are using
the Game's
Service,
PROFUN PTE. LTD.
will collect through the following ways the information that you
voluntarily provide when using the service or the information generated by your use of the service, in
order provide and optimize our services to you and to ensure your account in safe security:
1.1 When you register or use
the Game's
Service, we will collect the information of your network identity and the
personal device that you frequently use, in order to mark you as our users. If you use a Facebook and
(or) other account recognized by us (hereafter referred to as "Third-Party Account") as
the Game
account to login to
the Game
, we will collect your unique ID, avatar and user name of Facebook and
Third-Party Account to store your login information so that you can login on different
devices.
If you use a Facebook and (or) Third-Party Account as
the Game
account to login to
the Game
, in order to provide you with better services and improve your game
experiences, we will collect and you hereby consent to provide the following
information for the purpose:
•
your first and last name;
•
your profile picture or its URL;
•
your user ID number (like your Facebook ID number), which may be linked to other
information like your name and profile photo, and your friends' identifiers;
•
the user ID number and other information of your friends, like their names and
profile photos;
•
the login e-mail you provided to the third-party account;
•
nicknames;
•
your log-in status, battle information/status, achievement information related
in
the Game
;
•
your physical location and that of the devices you use to access our
Service;
•
your gender;
•
your birthday and/or age range;
•
information about your activities on or through the third-party
account;
•
other information you have shared on the third-party account;
•
If you access our Service from a third-party account or connect our Service to a
third-party account, you should also read that third-party account's Terms of Service and Privacy
Notice.If you are unclear about what information a third-party application is sharing with us, please go
to the third-party application to find out more about their privacy practices.
and
the Game
may present it to you or other users or your friends. Depending on the specific
situations of a game product, we may provide you with the relevant permissions enabling you to adjust
the settings as to whether or not to display Such Information.
1.2 In order to comply with the relevant laws, regulations and policies and the
requirements of competent authorities, users may need to complete the real-name verification before
using and enjoying
the Game
. For the purpose, you hereby consent
that we may collect your real-name ID and other information,
including:
•
your first and last names;
•
your age or birthday;
•
ID number;
•
photos.
Your refusal to provide your real-name ID information may result in a failure to log into
the Game
or the corresponding restrictions to your use of
the Game
.
1.3 In order to ensure your use of our service under normal conditions, to
maintain the normal operation of basic functions of
the Game
, to optimize the performance of
the game product
, to improve your gaming experience and protect the security of your game
account, we will collect the information including:
•
your device ID as well as the name;
•
type and version of your device;
•
the version of the system;
•
IP address;
•
MAC address;
•
application ID;
•
network type.
1.4 When you use
the Game's
Service, we will collect your game log information, including:
•
log-in data;
•
item logs;
•
game battle information;
•
friends relation records.
so that you can view the records of your game history on your terminal and we
can use the above information for analyzing game operation statistics, handling customer service
complaints and other game security analyses. Also, to improve
the Game
experience for you, we may synchronize the afore-mentioned information
with the later versions of
the Game
or with other products you are using that are provided by us.
1.5 When you use the consumption function of
the Game
, we will collect your recharge history, purchase records and other information, so that you can check your transaction records, and
at the same time to protect your virtual items to the greatest extent possible. Recharge history and purchase records are sensitive information. It is necessary to collect the above
information in order to enable the consumption function of
the Game
, otherwise the transaction could not be completed.
1.6 To protect the security of your game account and to create a fair, healthy
and safe gaming environment, we will collect information such as your game identity information,
hardware and operating system information, processes and breakdown records and other information, for
the purposes of fighting against the behaviors that destroy the fair gaming environment or that
interfere and disrupt normal game services (such as detecting counterfeits, scanning plug-ins,
preventing cheating, etc.).
1.7 According to reports and targeting of keywords involving pornography,
violence, political and abusive content, terrorism, malicious advertising, and other legally prohibited
content, we may store temporarily and filter the information when you interact with other players
through text, images, voice, video and other means in
the Game
, for the purpose of purifying
the Game
environment and maintain a healthy Internet environment.
1.8 If you wish to interact with other game players through voice and video, and
to participate in live broadcasting, upon your authorization,
the Game
will access your microphone and camera to accommodate you with voice chatting,
interaction during live broadcasting and other functions. But we will never violate the privacy of your
voice and video. You can also revoke the authorization of the microphone and camera at any
time.
1.9 If you wish to interact with nearby game players, upon your authorization we
will collect the information of your geographic
location to search for nearby game players, so that you can match with them or team
up with them, etc. Geographic location information is a type of sensitive information. Your refusal to provide this
information will only result in your incapability to interact with nearby game players, and will not
affect your normal use of other functions provided by
the Game
. You can also withdraw your authorization for the geographic location
information at any time.
1.10 We have enabled a reminder function for moderate time
length of playing games. If you use a wearable device, we will, with your consent, collect
information such as your heartbeat when you are playing
the Game
, so as to issue a system reminder when you have spent
excessive time on
the Game
.
1.11 We may analyze your game data to understand your preference, and we may
share your such preference and relevant necessary information to other products and services within the
PROFUN PTE. LTD.
Group, in order to better show you what you may be of interest within
the Game
and other products and services within
PROFUN PTE. LTD.
Group.
1.12 In accordance with relevant laws, regulations and standards, we may collect
and use your personal information in the following situations without obtaining your
authorization:
1.
where it is directly related to national interests such as national security and
national defense security; and directly related to major public interests such as public security,
public health, and public knowledge;
2.
where it is directly related to criminal investigations, prosecutions, trials
and enforcement of judgments, etc.;
3.
where it is for protecting the fundamental legal rights of you or other
individuals, such as life, property and reputation, but it is also difficult to obtain consent from you
or the related individual;
4.
where the personal information we collected is disclosed to the public by
yourself;
5.
where the personal information is collected through legitimate and public
channels, such as legitimate news reports, government information disclosure, etc.;
6.
where it is necessary to sign and perform the contract according to your
requests;
7.
where it is necessary to maintain a safe and stable operation of the
products or services provided by us, such as the discovering and treating of the malfunctions of
such product or service. But we will continue to protect the security of your personal
information and ensure that it will not be used for other purposes;
8.
where it is necessary to conduct statistical or academic research for
public interests; and when externally providing the results of academic research or description,
applying de-identification method to the personal information contained in the results. In
addition, it will not be used for any other purposes and activities; or
9.
other circumstances as stipulated by the laws and regulations.
1.13 Please understand that the functions and services we provide to you are
constantly updated and developed. If a certain function or service is not included in the above
descriptions herein but your information is collected there, we will separately explain to you the
content, scope and purpose of such collection through prompts, interaction process, website announcement
and other ways in order to obtain your consent.
At present, aside from collecting game research information from third-party
research organizations to help us upgrade our game products and provide personalized services, and aside
from your use of Third-Party Account to login in
the Game
prescribed in Section 1.1 herein, we do not take the initiative to obtain your
personal information from any third party outside of
PROFUN PTE. LTD.
Group. In the future, if
the Game
needs to obtain your personal information indirectly from a third party outside
of
PROFUN PTE. LTD.
Group and process such personal information, we will strictly comply with
the relevant laws and regulations, and we will require the said third party to obtain your consent and
to guarantee the legality of the information it provides.
2.Storage of Information
2.1 Manner and Term of Storing
Information
We will store your information in a secure manner, including storing it locally
(such as data caching via APP), using database and server logs.
In general, we will only store your information for a necessary period for
achieving the purpose of providing our services or as required by laws and regulations.
2.2 Territory of Storing Information
Personal information collected would be stored within [Amazon servers located in
Singapore] pursuant to the laws and regulations.
2.3 Termination Notice of the Product or
Service
In the event the operation of a product or service is terminated, we will make
an announcement in accordance with the relevant laws and regulations, and will protect your legitimate
rights and interests.
3.Information Security
3.1 Security Measurements
We strive to protect information security of the users to avoid any information
leakage, loss, improper usage, unauthorized access and disclosure, etc. We employ multiple security
measures, including technical protection solutions, management system controlling, security system
guarantee and others to make sure the user's personal information is protected in a reasonably
secured
manner.
To avoid any kind of doubt, it is neccessary to specify to you that all
the game product
s of us have nothing to do with money, all golds and props in our game products
are only for purpose of entertainment in
the Game
.
We adopt leading technical protection measures in the industry. The measures we
take include but not limited to firewall, encryption (such as SSL), de-identification or anonymization,
access controlling, etc. Further, we will constantly strengthen the security capacity of the software
installed in your devices. For example, we will implement part of the encryption work in your devices
locally to consolidate a secured transmission; we will collect the information of the applications
installed in your devices and its processing information during operation to avoid malicious programs
such as virus and Trojan.
We have established special management regulations, procedures and organizations
to safeguard the security of the personal information we collected. For example, we will apply strict
limitation on the scope of people authorized to access the information, requiring them to obey
confidential obligations and conducting audits. Those who violates such obligations will be punished in
accordance with the regulations. We will also review the management regulations, procedures and
organizations to prevent unauthorized access, use or disclosure of the users' information by those
people that are without authorization.
We suggest you give full attention to the protection of personal information
when using the products and services, and we will also provide multiple security methods to assist you
to protect the security of your personal information.
3.2 Dealing with Security Incident
If any security incident such as the leak of personal information occurs, we
will initiate the emergency plan to prevent it from expanding, and ensure to inform your of what we know
within 72 hours upon knowledge, or when there is reasonable belief, that a personal data breach has
occurred. Upon the occurrence of such incident, we will inform you the basic situation of the security
incident, the treatment measures and remedies we will take or have taken as well as our advices for you,
via announcements, push notifications or emails, etc. If it is difficult to inform every user, we will issue the warning through
public announcements or other reasonable means.
4. How We Use the Information
We will strictly obey the laws, regulations and the agreement with our users,
and we will make use of the collected information in accordance with the Guidelines, "
profunSG License and Service Agreement
" and "
profunSG Privacy Policy
" so as to provide you with better service.
4.1 Rules for Using Information
We will use the collected information in accordance with the following
rules:
1.
based on the information we collected, we will provide you with multiple
functions and services, including the general gaming functions, interactive functions between players,
live broadcasting functions as well as consumption functions;
2.
we will analyze the operation of our products based on the frequency and
situations of your use of
the Game
, malfunction information and performance information, etc., so as to ensure a
safe provision of our services, and to optimize our products and improve the quality of our services. We
will not combine your personal information with the information we stored in the analysis
software.
4.2 The Way to Seek Consent after Informing the
Purpose of Changing
We will use the collected information within the scope included in the
Guidelines. If we use your personal information beyond the scope and a direct or reasonably relevant
scope, of purpose we claimed when collecting the information we will again inform you and seek your
express consent before using your personal information.
5.Provide to Other Entities
Currently, except for the conditions provided in the Guidelines and
"
profunSG License and Service Agreement
", we will not actively share, provide or transfer your personal information to
any
other third party outside of
PROFUN PTE. LTD.
Group. In the event we share, provide or transfer your personal
information or you need us to share, provide or transfer your personal information to a third party
outside of
PROFUN PTE. LTD.
Group, we will directly ask for your prior express approval or confirm that the third party has obtained your express
approval.
Notwithstanding the above paragraph, we might provide your log-in information
and relevant information (such as log-in data, item logs, etc.) generated in
the Game
to the overseas developer entities or relevant third parties for the
purpose of conducting security analysis, and helping to improve game services and further optimize
users' experience in game.
We
integrates Bugly SDK products and/or services into our applications.
In order to keep abreast of our product operation dynamics and quickly discover and resolve your
abnormal feedback, we may need to collect relevant personal and sensitive user data from you,
including: Installed Application, crashes information, Android ID/IDFV, and provided to the
Bugly SDK operator in a de-identified or anonymous manner.
The following privacy policy linked provide you information about Bugly
's processing of your personal information.
（
https://privacy.qq.com/policy/tencent-privacypolicy
）
PROFUN PTE. LTD.
Group's product integrates with Umeng+SDK. Umeng+SDK needs to collect
your device's Mac address, unique device identification code (IMEI/android
ID/IDFA/OPENUDID/GUID, SIM card IMSI information) to provide statistical analysis services, and
through Geographically calibrate the accuracy of report data and provide basic anti-fraud
capabilities.
The following privacy policy linked provide you information about Umeng
's processing of your personal information.
（
https://www.umeng.com/page/policy
）
PROFUN PTE. LTD.
cooperates with reputational ad exchange platforms including
Mintegral. When you install and use our product after you view and click an ad served by
Mintegral Service, they may collect information about your downloading, installation, activation
of an app or other activities about you within the app. Where Mintegral acts as Demand Side
Platform ("DSP") serving ads, in order to analyze and display advertising including
personalized or behavioral advertising on your device, we may collect and share your personal
information with them including the following: screen size & orientation, device make, model,
operating system, operating system version, device type, version and characteristic of the app
used by you when you interact with the Mintegral Services, carrier information, network
connection type, IP address, user-agent; country, time zone and locale settings (country and
preferred language) and mobile advertising identifier (e.g. Apple IDFA or Google advertising
ID).
The following privacy policy linked provide you information about Mintegral
's processing of your personal information.
（
https://www.mintegral.com/en/privacy/
）
In addition, we will try to contact the parent or legal guardian after a person that is suspected to be a minor has made
consumption, and inform the parent or legal guardian of the consumption records and other information to
remind the parent or legal guardian to confirm and handle this issue.
Except as otherwise provided in the Guidelines, "
profunSG License and Service Agreement
" and "
profunSG Privacy Policy
", we will not publicly disclose the information we collect. If a disclosure is
necessary, we will inform you about the purpose of the disclosure, the type of the disclosed
information and the sensitive information that may be involved, and we will also obtain your express
approval.
As our business continuously develops, we are likely to conduct transactions
such as mergers, acquisitions and asset transfers, etc. We will inform you of the information and
continue or require the new controllers to continue to protect your personal information in accordance
with the laws and regulations and the standards no lower than the requirements of the
Guidelines.
In addition, in accordance with relevant laws, regulations and standards, we may
share, transfer, or publicly disclose personal information without your prior authorization and approval
in the following situations:
1.
where it is directly related to the national security and national defense
security;
2.
where it is directly related to public security, public health or major public
interests;
3.
where it is directly related to criminal investigation, prosecution, trial and
enforcement of judgments;
4.
where it is for protecting the material legal rights and interests such as life,
property and others of the personal information holder or other individuals but it is also difficult to
obtain consent from the involved person;
5.
where the personal information holder publicly discloses personal information by
himself/herself; or
6.
where the personal information is collected through legitimate and publicly
channels, such as legitimate news reports, government information disclosure, etc.
6. Data Retention and Deletion
6.1 Data Retention
How long we retain your personal information depends on why we collected it and
how we use it, but we will not retain your personal information for longer than is necessary for our
business purposes or for legal requirements.
As a general rule, we retain your personal information only as long as required
to perform the Services or other purpose that was the reason for the collection of the information. We
will retain most of your personal information as long as you use the Services (i.e., until account
deletion in accordance with your request) with the following exceptions: Contact Information that is
obtained as a result of you participating in our promotional activities will be retained during such
activities as expressly designated in the corresponding activities.
We will retain personal information about you and connected with your account
and/or the Services you use from us for as long as you have an active account with us. We will take
reasonable measures to delete this personal information if you delete your account. However, you
acknowledge that we will keep certain records (e.g., personal information relating to payments or
customer service matters) where we need (and have rights) to, such as for legal or accounting purposes.
We'll also keep information in order to exercise, defend, or establish our rights.
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 archiving
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).
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
profunsg@gmail.com
. You may ask us to delete or remove your Personal Date.Please state your
account ID and deletion request in your email clearly. We will usually process your request within 48
hours of receiving your email.
When you remove our app and request to delete your data, the system will call
the data deletion callback. You can do this simply by going to your Facebook profile and navigating to
the Settings & Privacy > Settings > Apps & Websites page and clicking the Send Request
button.
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) while 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 defense 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 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.
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.
7.If you believe you have discovered a security
vulnerability affecting
PROFUN PTE. LTD.
products and services, please report it to us
immediately. We welcome anyone reporting to us and will investigate all reports and do our best to
fix reasonable vulnerabilities as soon as possible.
We encourage you to send an encrypted email to
profunsg@gmail.com
by using your PGP key with the following
information:
1.
The specific products and software versions you
believe to be affected;
2.
A description of the behavior you observed and the
behavior you expected;
3.
A numbered list of steps to reproduce the problem or a
video demonstration (if the steps may be difficult to complete).
You will receive an automatic response from
PROFUN PTE. LTD.
confirming that we have received your report. If
we need more information, we will contact you.
8.Your Rights
During the time you use
the Game's
Service, we may provide you with the corresponding operation settings
based on the specific situation of
the game product
s, so that you can search, delete, change or withdraw your relevant personal
information. You can refer to the specific instructions of the corresponding game products to guide your
operation. In addition, we have set up the channel to receive complaints and reports, and your opinion
will be dealt with in a timely manner. To exercise any of your rights regarding personal information,
please contact us at
profunsg@gmail.com
.
9.Amendments
We may amend the Guidelines as appropriate. When the provisions of the
Guidelines have been amended, we will inform you of the amended Guidelines in a proper way at the time
of version update. Please read the amended Guidelines or the content carefully. Your continuous use of
the Game
would be deemed as your approval for us to collect, deal with or use your
personal information in accordance with the updated Guidelines.
10.Protection of Minors
We attach great importance to the protection of
minors' personal information, and we will keep exploring new ways to protect minors'
personal
information.
We will protect the legitimate rights and interests of
minors by initiating anti-addiction system in accordance with relevant regulations on online game
anti-addiction policies. We will make a judgment on whether the real name information of an account
belongs to a minor via the identification result of information such as real-name identity, based on
which we decide whether the account shall be included in the anti-addiction system. In addition, we
will collect information such as your login time, length of playing games, etc., and guide the
minors to play games rationally through ways such as automatically intervening and limiting
the Game
duration of the minors in our system, enabling
the function of mandatorily exiting
the Game
, etc. When the consumption is conducted by a person
suspected to be a minor, we will then try to contact his or her parent or legal guardian for
reminders, confirmations and deposition, so as to help the minors have a healthy access to the
Internet.
At the same time, in order to better protect both the
physical and mental health of minors and facilitate a healthy access to the Internet for them, we
may employ stricter anti-addiction measures on the basis of relevant anti-addiction policies related
to online games. Further, we will keep conducting researches and testing various technologies to
protect the minors. For example, in order to further improve the accuracy of real-name verification
on identities and to try best to prevent minors from impersonating the identity of others, we may
enable face-recognition verifications in some games or for some users (subject to specific game
strategies) under specific situations (for example, when you log into a game, or when you top up,
purchase or make transactions during
the Game
).
Besides, we may also collect your game behavior data
generated during
the Game
(for example, the data such as the click
pressure and radius, the relative position of the click, the acceleration direction, and the
direction of gravity formed when you operate
the Game
on the terminal device, and the voice data
generated when you interact with other players through online voice in
the Game
) to preliminarily determine whether the user is a
minor (regarding the voice data, the system will only randomly use some of your online voice to
judge whether it is from a child or an adult). If the preliminary determination shows you are a
minor, we may enable the face-recognition verification in accordance with the foregoing
prescriptions.
If you are the parent or legal guardian of a minor,
please pay attention to whether the minor uses
the Game's
Service or provides his or her personal
information after obtaining your authorization and approval. If you have questions about the
personal information of the minor under your guardian, please contact us through the contact details
provided in Section 9 herein.
11.Disclaimer of Warranties
This game has nothing to do with money, all hold or props are only
for entertainment
in
the Game
.
1
2
. Contact Us
When you have other complaints, suggestions, or questions regarding personal
information of minors, please send your questions to [Name:
Liang
; Email:
profunsg@gmail.com
] .
We will review the relevant questions as soon as possible, and will respond
within 15 days upon verifying your user identity.