Privacy Policy

I. How We Collect and Use Information

We collect only the information necessary for the realization of product functions in accordance with the principles of legality, propriety and necessity.

(I) How We Collect Your Information

In the course of your use of our services, we will collect information that you proactively provide or that is generated as a result of your use of the services in the following ways, so as to provide and optimize our services and protect the security of your account:

• Assisting you in creating an account. To facilitate your registration and login, we may collect your email address, contact information, created username and account password with your consent or when you proactively provide such information. To meet the requirements of relevant laws, regulations and competent authorities, we will collect your real-name identity information for real-name authentication with your consent or when you proactively provide such information. Real-name identity information is sensitive information. If you refuse to provide such information, we may be unable to provide you with relevant products or services, and may also be unable to respond to or solve the problems you encounter.
• Fulfilling your requests for consumption functions. We will collect your recharge records, consumption records and other information so that you can query your transaction records. Recharge records and consumption records are sensitive information. The collection of the above information is necessary for the realization of the consumption function of our products; otherwise, the recharge cannot be completed.
• To ensure your normal use of our services, maintain the normal operation of the basic functions of the application, optimize the performance of application products, improve your application experience and protect the security of your account, we will collect your IP address, device ID, device model, operating system type, operating system version, device MAC address, unique device identifiers in the software list (such as IMEI, android ID, IDFA, IDFV and other information describing the basic situation of commonly used personal devices), network type, device language and other information.
• When you use our services, we will collect your application log information, including login logs, item logs, binding information change logs, etc., so that you can view your application history, and at the same time for application operation statistical analysis, customer service complaint handling and other application security analysis. In addition, to improve your application experience, we may synchronize the aforementioned information to subsequent versions of the application.
• When you interact with other players in the application through text, pictures, voice, video and other methods, we may collect and store the content of the above information you send to filter inappropriate content such as pornography, violence, political content, insults and malicious advertisements, so as to purify the application environment and maintain a healthy online environment.
• To protect the security of your application account and create a fair, healthy and safe application environment, we will collect your application identification information, operating system information, application crash records and other information, which will be used to combat behaviors that undermine the fair environment of the application or interfere with or disrupt the normal operation of application services (such as detecting unauthorized auxiliary programs and preventing cheating).
• Information submitted by you through our customer service or when participating in our activities. We may collect information you provide to our customer service or submit when participating in activities, including your name, contact information, recipient address and other information.

Please understand that the functions and services we provide to you are constantly updated and developed. If a certain function or service is not described in the foregoing statement but collects your information, we will separately explain the content, scope and purpose of information collection to you through page prompts, website announcements and other methods to obtain your consent.

(II) How We Use Your Information

• Providing services to you. We will provide you with various functions and services based on the information we collect, including basic application functions, consumption functions, etc.
• Security assurance. We will use your information for identity verification, security prevention, anti-fraud monitoring, archiving and backup, customer security services and other purposes.
• Product development and service optimization.
• When our system fails, we may record and analyze the information generated during the system failure to optimize our services.
• We may use the collected information for internal audits, data analysis and research, analysis of business operation efficiency and measurement of market share, improvement of our products or services and other situations.
• We may send you information about products and services that may be of interest to you; invite you to participate in our activities (including promotional activities), market research or satisfaction surveys; or send you marketing information. If you do not want to receive such information, you can unsubscribe at any time.
• With your consent, we will send you notifications of operating system or application updates and installations. If you do not agree, we may be unable to provide you with relevant products or services.
• We may use your information to comply with and enforce applicable legal requirements, relevant industry standards, etc.

(III) Third-Party Providers and Their Services

To ensure a smooth experience, you may receive content or network links provided by third parties outside us (hereinafter referred to as "third parties"). We have no control over such third parties. You may choose whether to access the links, content, products and services provided by third parties.

We cannot control the privacy and data protection policies of third parties, and such third parties are not bound by this Policy. Before submitting personal information to a third party, please refer to the privacy protection policies of these third parties. We will not be liable for any third party's use of the information provided by you.

(IV) In accordance with relevant laws, regulations and national standards, the collection and use of your information in the following circumstances does not require your authorization and consent:

1. Directly related to national interests such as national security and national defense security;
2. Directly related to major public interests such as public security, public health and the public's right to know;
3. Directly related to criminal investigation, prosecution, trial and judgment enforcement;
4. Necessary for protecting the life, property and other major legitimate rights and interests of you or other individuals but it is difficult to obtain your consent;
5. The information collected is information that you have disclosed to the public on your own initiative;
6. Collecting information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
7. Necessary for concluding a contract in accordance with your requirements;
8. Necessary for maintaining the safe and stable operation of the provided products or services, such as discovering and disposing of product or service failures;
9. Necessary for legitimate news reporting;
10. Necessary for statistical or academic research carried out by academic research institutions based on public interests, and when providing the results of academic research or descriptions to the public, the information contained in the results is de-identified;
11. Other circumstances stipulated by laws and regulations.

(V) Rules for Targeted Push of Information

We may send you activity information, marketing information, promotion information, information inviting you to participate in market research or satisfaction surveys, etc. If you do not wish to continue receiving the information pushed by us, you may request us to stop pushing.

II. How We Use Cookies and Similar Technologies

To improve your user experience, we will use Cookies or similar technologies (such as web beacons, log files, scripts, eTags) (hereinafter collectively referred to as "Cookies technologies"). A Cookie is a plain text file stored by a web server on a computer or mobile device. The content of a Cookie can only be retrieved or read by the server that created it. Each Cookie is unique to your web browser or mobile application. Cookies usually contain identifiers, site names, and some numbers and characters. With the help of Cookies technologies, we store data such as your product preferences on your device and generate small files to enable us to provide specific functions. You have the right to enable or disable Cookies technologies through your device or browser settings. For details, please refer to AboutCookies.org. However, when you choose to disable Cookies technologies, you may be unable to experience some functions of our application services.

III. Information We May Share, Transfer or Disclose

(I) Sharing

In general, we will not share your personal information with any company, organization or individual, except in the following circumstances:

• Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.
• We may share your personal information externally in accordance with the provisions of laws and regulations or the mandatory requirements of government competent authorities.
• Within the scope required or permitted by law, it is necessary to provide your personal information to a third party to protect the interests, property or security of us, our users or the public from damage.
• Sharing with our affiliated companies: We may share personal information among our affiliated companies.
• Sharing with authorized partners: Only for the purposes 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. For example, companies we hire to provide third-party data statistics and analysis services may need to collect and access personal data for data statistics and analysis. In this case, these companies must comply with our data privacy and security requirements. We will only share your personal information for legal, proper, necessary, specific and clear purposes, and will only share the personal information necessary for providing services.
• We will sign strict confidentiality agreements with companies, organizations and individuals with whom we share personal information, requiring them to process personal information in accordance with our instructions, this Policy and any other relevant confidentiality and security measures.
• Fulfilling our obligations and exercising our rights under this Privacy Policy or other agreements reached between us and you.

(II) Transfer

In general, we will not transfer your personal information to any company, organization or individual, except in the following circumstances:

• Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;
• In the event of merger, acquisition or bankruptcy liquidation, if personal information transfer is involved, we will require the new company or organization holding your personal information to continue to be bound by this Policy; otherwise, we will require the company or organization to re-seek your authorization and consent.

(III) Disclosure

We will only disclose your information under the following circumstances and on the premise of adopting security protection measures:

• Disclosing the information you specify in the manner of disclosure you explicitly agree to, at your request;
• We may disclose your personal information based on the mandatory requirements of laws and regulations, judicial organs or administrative competent authorities;
• If we are involved in restructuring, merger or bankruptcy and liquidation proceedings, your personal information may also be disclosed to the transaction parties.

(IV) Exceptions to Prior Authorization and Consent When Sharing, Transferring or Disclosing Information

In accordance with the provisions of relevant laws and regulations, we may collect, share and publicly disclose your personal information without your authorization and consent in the following circumstances:

1. Directly related to national interests such as national security and national defense security;
2. Directly related to major public interests such as public security, public health and the public's right to know;
3. Directly related to criminal investigation, prosecution, trial and judgment enforcement;
4. Necessary for protecting the life, property and other major legitimate rights and interests of you or other individuals but it is difficult to obtain your consent;
5. Collecting information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
6. Necessary for concluding a contract in accordance with your requirements;
7. Necessary for maintaining the safe and stable operation of the provided products or services, such as discovering and disposing of product or service failures;
8. Necessary for legitimate news reporting;
9. Necessary for statistical or academic research carried out by academic research institutions based on public interests, and when providing the results of academic research or descriptions to the public, the information contained in the results is de-identified;
10. Other circumstances stipulated by laws and regulations.

IV. How We Retain, Store and Protect Information

(I) Retention of Information

We will retain your personal information for the period necessary to achieve the purposes described in this Policy, unless the retention period is extended or permitted by law as required or permitted by law. Due to different scenarios and different products and services, the storage period of information may vary. The criteria we use to determine the retention period include: the time required to retain personal information to complete the business purpose, including providing products and services, maintaining corresponding transaction and business records, managing and improving the performance and quality of products and services, ensuring the security of systems, products and services, responding to possible user inquiries or complaints, and locating problems; whether the user agrees to a longer retention period; whether there are special requirements for data retention under laws, contracts, etc. As long as your account is necessary for providing you with services, we will retain your registration information.

(II) Storage of Information

Methods and period of information storage

We will store your information in a secure manner, including local storage, database, etc.

In general, we will only store your personal information for the time necessary to achieve the purpose of the service or under the conditions stipulated by laws and regulations.

Notification when products or services cease operation

When our products or services cease operation, we will issue an announcement in accordance with relevant laws and regulations, and protect your legitimate rights and interests in accordance with the law.

(III) Protection of Information

We attach importance to the security of personal information. We adopt appropriate physical, administrative and technical safeguard measures to protect your personal information from unauthorized access, disclosure, use, modification, damage or loss. For example, we use encryption technology to ensure the confidentiality of data; we use protection mechanisms to prevent data from being maliciously attacked; we deploy access control mechanisms to ensure that only authorized personnel can access personal data; and we hold security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal data.

You should be fully aware that the Internet is not an absolutely secure environment, and communication methods such as email and instant messaging cannot be confirmed to be fully encrypted. We strongly recommend that you do not send personal information through such methods. You must be obliged to keep your account and password information confidential. In any case, please keep them carefully and properly. If you find that your personal information has been leaked, especially your account and password have been leaked, please contact our customer service immediately so that we can take corresponding measures. Please use a complex password and pay attention to protecting your information security.

We will do our best to protect your personal information, but please note that due to technical limitations and the limitations of risk prevention, no security measures can be flawless. You need to understand that the system and communication network you use to access our services may have problems due to circumstances beyond our control.

In the unfortunate event of an information security incident, we will promptly inform you of the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you in accordance with the requirements of laws and regulations. At the same time, we will promptly inform you of the relevant situation of the incident by email, letter, telephone, push notification and other methods. When it is difficult to inform the information subjects one by one, we will issue an announcement in a reasonable and effective manner. At the same time, we will also take the initiative to report the disposal of the personal information security incident in accordance with the requirements of the regulatory authorities.

V. How to Manage Your Information

You shall ensure that all personal information submitted is accurate. We will strive to maintain the accuracy and completeness of personal information and update these data in a timely manner.

Where required by applicable law, you may:

1. have the right to access specific personal information about you held by us;
2. require us to update or correct your inaccurate personal information;
3. refuse or restrict our use of your personal information;
4. require us to delete your personal information;
5. withdraw your authorization.

If you need to do so, you can contact nguyenanhtu8600@icloud.com. To ensure security, you may need to provide a written request. When you access, modify, delete or withdraw relevant information, we will require you to undergo identity verification to ensure the security of your account. Please understand that due to technical limitations, legal or regulatory requirements, we may not be able to meet all your requirements, and we will reply to your request within a reasonable period. If we have reasonable grounds to believe that these requests are deceptive, impracticable or infringe on the privacy rights of others, we will refuse to process the requests.

Where required by applicable law, when we process your personal information based on your consent, you also have the right to withdraw your consent at any time. However, withdrawal of consent will not affect the legality and validity of our processing of your personal information based on your consent before the withdrawal, nor will it affect our processing of your personal information based on other appropriate legitimate grounds.

VI. How We Handle Personal Information of Minors

If you are a minor under the age of 18, before using our products and/or services, you should read this Policy accompanied by your guardian, and ensure that you use our services and provide your information only after obtaining the consent of your guardian.

If your guardian does not agree with your use of our services or provision of information in accordance with this Policy, please immediately terminate the use of our services and notify us in a timely manner.

For the collection of minors' personal information with the consent of parents or legal guardians, we will only use or publicly disclose such information to the extent permitted by law, explicitly agreed by parents or guardians, or necessary for the protection of minors.

If you are the guardian of a minor, and you have any questions about the use of our services by the minor under your guardianship or the user information provided to us by the minor, please contact us in a timely manner. We will protect the confidentiality and security of minor users' information in accordance with relevant national laws and regulations and the provisions of this Policy. If we find that we have collected minors' personal information without prior verifiable consent from parents or legal guardians, we will delete the relevant data as soon as possible.

VII. Notice and Revision

We may revise this Privacy Policy from time to time. When the terms of this Privacy Policy change, we will prompt you of the revised privacy policy in an appropriate manner when the version is updated. Please read the revised privacy policy carefully. Your continued use of our services indicates that you agree to our collection, processing or use of your personal information in accordance with the updated privacy policy.

VIII. How to Contact Us

The entity of ours that processes your personal information pursuant to this Policy, responds to your requests, contacts you, provides you with products or services, or has concluded or is about to conclude a contract with you shall be the controller of the relevant personal data.

If you have any questions, comments or suggestions, please contact us by email at nguyenanhtu8600@icloud.com.

We will reply to you within fifteen working days after receiving your questions, comments or suggestions and verifying your user identity.