BREAKOUT 13 Privacy Policy

Effective Date: July 11, 2023

To better protect your personal information, we recommend that you carefully read this "Privacy Policy". If you have any disagreements or questions about the terms of this privacy policy, you can communicate with us through the contact methods disclosed in the tenth clause "Contact Us" of this "Privacy Policy".

This privacy policy will help you understand the following:

Ⅰ. Introduction

Ⅱ. About Us

Ⅲ. Definitions

Ⅳ. How We Collect and Use Your Personal Information

Ⅴ. How We Share, Transfer, and Publicly Disclose Your Personal Information

Ⅵ. About the Use of Cookies and Similar Technologies

Ⅶ. Storage and Protection of Your Personal Information

Ⅷ. Your Rights to Manage Personal Information

Ⅸ. Protection for Minors

Ⅹ. Contact Us

Ⅺ. How This Policy is Updated

Ⅻ. Dispute Resolution

Ⅰ. Introduction

1. This "Privacy Policy" (hereinafter referred to as "this policy") applies only to the services related to this application that we provide to you. We will handle and protect your personal information in accordance with the provisions of this policy.

2. Before using this application, please carefully read and fully understand the entire content of this privacy policy. Once you agree to this privacy policy, or you continue to use this application's products/services, it means you agree to our use and processing of your relevant information in accordance with this privacy policy.

3. We may occasionally revise this privacy policy based on laws, regulations, or business adjustments. After changes to this privacy policy, we will display the updated content to you through conspicuous prompts, pop-ups, push notifications, messages, etc.

4. You need to understand that only after you confirm and agree to the updated "Privacy Policy", will we collect, use, process, and store your personal information based on the updated privacy policy. You have the right to refuse the updated privacy policy, but be aware that if you refuse, it may lead to you being unable or unable to fully use the related services and features of this application, or not achieve the service effect we intend.

Special Note for Minors:

If you are a minor under the age of 18 (especially children under 14), please notify your guardian to read this privacy policy together, especially the "Child Privacy Protection Policy". After obtaining your guardian's consent to all terms of this privacy policy, especially all terms of the "Child Privacy Protection Policy", you can use the games and services we provide. By clicking to agree to this privacy policy, or by using or continuing to use the games and services we provide, and submitting personal information, it means you have obtained the permission of your guardian, and your guardian also agrees to our use and processing of your relevant information according to this privacy policy.

Ⅱ. About Us

1. "BREAKOUT 13" (hereinafter referred to as "this application") is operated and provided by Beijing ZHUJUEHUYU Technology Co., Ltd. (hereinafter referred to as "the Company") and its affiliated companies.

2. Affiliated companies refer to companies, institutions that now or in the future control the company, are controlled by the company, or are under common control with the company. Control refers to the ability to influence the management/operation of the controlled subject directly or indirectly through ownership, shares with voting rights, contracts, actual operational associations, or other legally recognized methods.

Ⅲ. Definitions

Unless otherwise specified, the terms used in this Privacy Policy typically have the following definitions:

1. Personal Information (from the "Personal Information Protection Law"): Refers to any information relating to an identified or identifiable natural person that is recorded electronically or by other means, excluding information that has been anonymized.

2. Sensitive Personal Information (from the "Personal Information Protection Law"): Refers to information that, once leaked or unlawfully used, could harm an individual's dignity, or jeopardize their personal or property safety. This includes biometric information, religious beliefs, specific identity, medical health, financial accounts, tracking data, and the personal information of minors under fourteen years of age.

3. Device: Refers to a piece of equipment that can be used to access our products and/or services, such as desktop computers, laptops, tablets, or smartphones.

4. Unique Device Identifier (Exclusive ID or UUID): Refers to a string of characters embedded in a device by its manufacturer that uniquely identifies the device (e.g., a phone's IMEI number). Unique device identifiers can serve various purposes, including the provision of advertisements where cookies can't be used (like in mobile apps).

5. IP Address: A number assigned to every device connected to the internet, usually allocated based on geographic location. IP addresses often help identify the location from which a device is connecting to the internet.

6. SSL (Secure Socket Layer): A security protocol implemented on the communication protocol (TCP/IP). SSL supports various networks and provides three basic security services, all of which achieve confidentiality through the use of public and symmetric key technology.

7. Cookie: A small file containing a string of characters that's sent to and stored on your computer, mobile device, or other equipment when you log in and use a website or other online content (usually encrypted). Other technologies similar to cookies (for similar purposes) include Web Beacon, Proxy, Embedded scripts, etc.

8. Account: When you register an account and provide some personal information, you can better use our services. When you log into the application, the system uses this account information to verify your identity to prevent unauthorized access.

9. De-identification/Anonymization: A technical process that renders personal information unidentifiable without additional information and ensures that the de-identified information can't be reversed.

10. Game Logs: Detailed records of how you use our products/services. These are saved as relevant web logs.

11. Server Logs: Typically, our servers automatically record the web requests you make when visiting our site. These "server logs" often include your web requests, IP address, browser type, browser language, the date and time of your request, and one or more cookies that can uniquely identify your browser.

12. Information Posting Logs: Refers to the records of information you actively upload or disclose in the game, such as in-game postings (chat channels and other places where information can be posted), group chat records, app session records, and system session records. These logs record user accounts and communication group names, nicknames, profiles, notes, identifiers, information postings, reposts, comments, and communication group services.

13. Operational Information: Records of your actions within the game, such as changes to user accounts, operation times, operation types, and operation content (e.g., login times, login locations, IP addresses, recharge times, etc.).

Ⅳ. How We Collect and Use Your Personal Information

1. We collect and use your personal information in accordance with laws and regulations and following the principles of legitimacy, lawfulness, and necessity. This is based on the information you actively provide during the service or generated due to the requirements of the product and/or service. If we wish to use your personal information for purposes not specified in this Privacy Policy, or use information collected for specific purposes for other purposes, we will inform you in a reasonable manner and seek your consent again before using it.

2. The types of personal information we collect and use include two categories: The first category: information necessary for the core functions of our products and/or services. Such information is indispensable for the regular operation of products and/or services, and you must authorize us to collect it. If you refuse, you won't be able to use our products and/or services normally. The second category: information potentially needed for additional business functions. This is non-essential information, and you can choose whether to authorize us to collect it. If you refuse, the additional business functions might not be available or might not achieve the intended effects, but it won't affect your normal use of the core functions.

3. You understand and agree that we strive to provide you with comprehensive and secure products and services. Therefore, we continuously improve our products and services, including the technology behind them. This means that we might often introduce new business functions, which may require collecting new personal information or altering the purpose or manner in which personal information is used (e.g., for product development and service optimization, when our system encounters malfunctions, we will record and analyze the information generated during such system failures to enhance our services. For security reasons, we will use your information for identity verification, security precautions, anti-fraud monitoring, data backup, customer security services, etc. For instance, the security software you download or install may scan for malicious programs or viruses, or identify scam messages). If a function or product/service that requires your personal information is not specified in this privacy policy, we will inform you separately by updating this privacy policy, page prompts, pop-ups, website announcements, etc., and provide you with a way to give consent. If you have any doubts regarding these matters, you can contact us through the methods provided in Article 10 of this privacy policy, and we will respond promptly.

4. Typically, we will collect and use your personal information in the following scenarios:

4.1 Account login and registration

(1) When you register, log in, and use this application, we will collect your account and login information as online identity identification, marking you as a user of this application. You can also register and link to log in to this app using other accounts recognized by us (hereinafter referred to as "third-party accounts").

(2) Please understand that the matching result of your phone number and verification code is considered sensitive personal information. We collect this type of information based on legal requirements. If you refuse to provide it, you might not be able to register an account and use related product features. Please consider this carefully before deciding whether to provide it.

(3) Furthermore, to meet the requirements of relevant laws, regulations, and regulatory authorities, you need to provide us with personal identification information (including ID card numbers) for real-name verification to use this application. We will collect your personal identification information with your consent or when you voluntarily provide it. If you refuse to provide your real-name identification, you might be unable to register or use this application, or your use may be limited.

(4) If you download this application from other Android app stores (including but not limited to Huawei App Store, OPPO App Store, etc.), you might be required to register a third-party account and use that account to log into this application. During this process, please refer to the privacy policy provided by the respective third-party for information on their data collection and handling practices.

4.2 Using the application

4.2.1 While downloading and using this application, to offer you the best gaming experience, we might collect the following personal information:

(1) When registering or using this application, we will collect your online identity and common device information to mark you as a user of this application.

(2) To meet the requirements of relevant laws, regulations, and regulatory authorities, we implement a real-name registration system for online game users, comprehensively integrating the real-name authentication system of the National Press and Publication Administration. Users of this application need to complete real-name authentication to continue using and enjoying the services of this application. To complete the real-name authentication, you need to provide personal identification and biometric information, including name and ID card number (sensitive personal information), as required by the National Press and Publication Administration's real-name authentication system. We promise that the aforementioned information is only used for real-name authentication purposes. However, to complete the authentication and fulfill our obligation to store registration information, we will store your provided name (sensitive personal information) and ID card number (sensitive personal information). If you refuse to provide real-name identity information, you might not be able to log into this application, or your use might be restricted.

(3) To ensure that you can use our services normally, maintain the stable operation of the game's basic functions, ensure the security of your game account, recognize account anomalies, understand product adaptability, maintain the stable operation of basic functions, and also to create a healthy and safe gaming environment, we will collect your device information: including game application information, device information (Device ID, device serial number, device manufacturer, device name, device type and version, device model, device style, device identifiers like IDFA, IMEI, IMSI, MAC address), network type, system version, IP address, online identity identification, operating system and process information, network environment information, and game crash record information.

(4) When using this application's services, we will collect your game log information, such as login logs, for game operation statistical analysis, customer service complaint handling, and other game security analyses. We will synchronize the aforementioned information with subsequent versions of this game or other products you use that we provide.

(5) When you use the spending functions of this app, we collect information such as your recharge and consumption records to enable you to view your transaction history and ensure the security of your virtual goods to the greatest extent possible. Recharge and consumption records are sensitive information. The collection of the said information is essential to achieve the spending functionality of this app; without it, the transaction cannot be completed.

(6) When you interact with other players in the game through text, images, voice, and video, we may collect and store the content of the text, images, voice, and video you send. This is done to filter out inappropriate content such as pornography, violence, politics, insults, and malicious advertisements, thus purifying the gaming environment and maintaining a healthy online environment.

4.2.2 To collect the aforementioned information, we will request the following permissions to access your device information:

(1) Local storage and read/write permissions: During the app's operation, we will obtain your local storage and read/write permissions for data caching and reading.

(2) External storage and read/write permissions: When using functions that require reading, caching, uploading photos, albums, and files, we need access to your album and game save files. Also, to cache and read game crash logs and ensure you can log in and use the game normally, we require your authorization to access external storage and read/write permissions, reading and storing videos, audios, files, etc., for upload and share functionalities. If you decline to provide the aforementioned permissions, you will only be unable to use that function. It won't affect the use of other features in the app. You can also revoke these permissions at any time.

(3) Internet access permissions: To connect online and use game services, we need your network access permissions.

(4) Phone access permissions: While using the app, to ensure your game account's security, identify abnormal account statuses, understand product compatibility, maintain the basic function's operation, and create a healthy and safe gaming environment, we require your phone permissions. If you decline these permissions, you can also revoke them anytime.

(5) Microphone permissions: When using the in-game voice function, we need to access your device's microphone to collect voice data to provide voice-based social features. If you decline, it will only disable that specific function, without affecting other features. You can revoke this at any time.

(6) Bluetooth permissions: When using voice functions or other features requiring Bluetooth in the app, you need to grant us access and permissions to Bluetooth information. If declined, you will be unable to use that specific function but can still access other features. You can also revoke this permission at any time.

(7) Clipboard: Access to retrieve passwords, redemption codes, and other related information for benefits acquisition, event participation, and sharing.

(8) Sensor List: Identifies device status, assists in location functionality, determines operational actions, screen orientation, and checks if the device is genuine.

We request the above permissions to provide the mentioned functionalities. If you decline any, you may be unable to access specific product features and services. After updating the app version, without your explicit consent, we won't change your previously set permission statuses. Please understand that standalone device information, log info, etc., cannot identify a specific individual. If we combine such non-personal information with personal info for identification, during this combined use, the non-personal data will be considered personal and will be anonymized/de-identified unless authorized by you or required by law.

4.3 Customer Service

When you lodge complaints, appeals, or consultations regarding the app, for your account and system security, we might need you to provide account information first and match it with your existing personal information to verify your identity. To contact you or assist with your concerns, we may also require your name, phone number, email, and other contact details (sensitive personal info). Furthermore, we will collect your communication details with us (in the form of text, images, audio, video, call logs) and other necessary information related to your needs. We gather this information to investigate facts and assist you. If you decline to provide the necessary details, we may not be able to provide timely feedback on your complaints, appeals, or inquiries.

4.4 Payment

When you use value-added services in the app, you will need to use the payment function. During payment, we might collect your third-party payment channel's user ID (such as WeChat's openid, transaction_id, Alipay's trade_no, buyer_id, buyer_logon_id, PayPal's payer_id, address_street, first_name, last_name, payer_email, txn_id) (sensitive personal info). This information is essential for us to provide the in-game value-added services you purchase. We cannot obtain your personal financial details based solely on this information, nor can we identify specific individuals.

4.5 Storage

When you download and use this app, we may request storage permissions related to your device. If you refuse, it may prevent you from using this app. Meanwhile, you can activate/deactivate this permission anytime via your device's system settings. Activating this permission is considered as your consent for us to access, obtain, collect, and use such personal information. However, once you withdraw this consent, we will no longer collect this information and will not be able to provide the corresponding services. Your withdrawal action will not affect our previous handling and storage of your personal data, unless you delete your personal information according to the law.

4.6 Personal Information Collected from Third Parties

(1) Please be aware that the personal information you provide to external third parties (excluding affiliated companies involved in development and operations) or that external third parties collect, cannot be obtained by us. We will not use unconventional methods (e.g., malicious interference with other apps' data) to obtain your personal information. If our app needs to indirectly collect your personal information from third parties for business development (like sharing), and either we or jointly with third parties provide products or services to you, we (or the third party) will notify you about the source, type, purpose, method of the shared personal information, and the scope of consent. If our use exceeds the scope of your original consent given to the third party, we will seek your approval again. Some of our products or services might be provided jointly with third-party business partners. For necessary and reasonable business operations, we might collect part of your information indirectly or obtain information about you when others use our products and/or services. For information types, purposes, rules for personal information protection, and opt-out mechanisms collected by these channels, please refer to the privacy policy of the corresponding SDK based on where you obtained the software. For instance, if you get the software from the Xiaomi App Store, the corresponding channel SDK is Xiaomi SDK, and so on. Please note that due to updates or policy adjustments, the third-party SDK might change how it handles personal data. Always refer to their official announcements. These SDKs include:

WeChat SDK

Third-party company name: Shenzhen Tencent Computer Systems Company Limited

Personal data involved: Installed app information

Sensitive permissions: Internet access, network status

Usage: Sharing content to WeChat and Moments

Purpose: Assisting users in sharing content to WeChat and Moments

Sharing method: Local SDK collection

Third-party link:https://privacy.qq.com/
QQ Connect SDK

Third-party company name: Shenzhen Tencent Computer Systems Company Limited

Personal data involved: Installed app information

Sensitive permissions: Internet access, network status

Usage: Sharing content to QQ and Qzone

Purpose: Assisting users in sharing content to QQ and Qzone

Sharing method: Local SDK collection

Third-party link:https://wiki.connect.qq.com/qq
Weibo SDK

Third-party company name: Beijing Weimeng Chuangke Network Technology Co., Ltd

Personal data involved: Android ID, OAID, installed app package name

Sensitive permissions: Storage permission

Usage: Used when users share content to Weibo

Purpose: Assisting users in sharing content to third-party apps

Sharing method: Local SDK collection

Third-party link:https://weibo.com/signup/v5/privacy
Bilibili SDK (Only for Bilibili channel package)

Third-party company name: Shanghai Kuanyu Digital Technology Co., Ltd

Personal data involved: Common personal device information (including device model, hardware serial number, device MAC address, operating system type, software list, unique device ID)

Sensitive permissions: None

Usage: Used for Bilibili channel account login, payment, and real-name verification

Purpose: Providing Bilibili account login, payment, and real-name verification

Sharing method: Local SDK collection

Third-party link:https://www.bilibili.com/blackboard/privacy-pc.html
Xiaomi SDK (Only for Xiaomi channel package)

Third-party company name: Beijing Walli Network Technology Co., Ltd

Personal data involved: Common personal device information (including hardware serial number, hardware model, device MAC address, operating system type, software list, unique device ID)

Sensitive permissions: None

Usage: Used for Xiaomi channel account login, payment, and real-name verification

Purpose: Providing account login, payment, and real-name verification

Sharing method: Local SDK collection

Third-party link: https://privacy.mi.com/xiaomigame-sdk/zh_CN/
Huawei SDK (only for Huawei channel packages)

Third-party company name: Huawei Software Technologies Co., Ltd.

Type of personal information involved: Common personal device information (including hardware serial number, hardware model, device MAC address, operating system type, software list, unique device identifier)

Sensitive permissions involved: None

Usage scenario: Huawei channels provide Huawei account login, payment, and real-name services.

Purpose of use: Provide account login, payment, and real-name services.

Sharing method: Local collection by SDK

Third-party link: https://developer.huawei.com/consumer/cn/doc/development/HMSCore-Guides/sdk-data-security-0000001050121546
TapSDK (only for TAPTAP channel packages)

Third-party company name: Yiwan (Shanghai) Network Technology Co., Ltd.

Type of personal information involved: Device version, phone style, system version.

Sensitive permissions involved: None

Usage scenario: When using TapTap third-party authorized login.

Purpose of use: Provide account login, payment, and real-name services.

Sharing method: Local collection by SDK

Third-party link: https://developer.taptap.cn/docs/sdk/start/agreement/
Bugly SDK

Third-party company name: Tencent Computer Systems Co., Ltd., Shenzhen

Type of personal information involved: IMEI, IMSI, device model, log information, Android ID, network information, system name, system version, MAC address.

Sensitive permissions involved: Access to storage permissions.

Usage scenario: When identifying crashes.

Purpose of use: Collect crash information.

Sharing method: Local collection by SDK

Third-party link:https://privacy.qq.com/document/preview/fc748b3d96224fdb825ea79e132c1a56

(2) Our professional security team will strengthen the security of personal information (including reporting sensitive information, encrypted storage of sensitive information, access control, etc.). We will protect indirectly obtained personal information using measures no less stringent than those we apply to our own user's personal information.

4.7 For other reasonable and necessary purposes:

(1) As previously stated, if a feature or product/service that requires collecting your personal information is not explained in this privacy policy, or if we go beyond the purpose claimed when collecting your personal information and its directly or reasonably associated scope, we will separately explain to you by updating this privacy policy, page prompts, pop-ups, private messages, website announcements, or other means that make it easy for you to know. We will provide you with a way to actively choose to agree and will collect and use your personal information only after obtaining your explicit consent.

(2) You understand and agree that, in the following cases, we can collect and use your personal information without obtaining your authorization:

a) Related to national security or defense security.

b) Related to public safety, public health, and significant public interests.

c) Directly related to criminal investigations, prosecutions, trials, and execution of judgments.

d) For the protection of significant legal rights and interests of you or other individuals when it's difficult to obtain your consent.

e) Information that you've made public or collected from legally open channels (e.g., legal news reports, government information disclosure).

f) Necessary according to agreements or other written documents signed and performed with you.

g) Necessary to maintain the safe and stable operation of our products and/or services, such as finding and handling failures.

h) Requirements from authoritative agencies, or other scenarios stipulated by laws and regulations.

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

1. Sharing:

We value the protection of your personal information. Your personal information is an essential basis and part of the products and/or services we provide for you. For your personal information, we will collect and use it only for the purposes and scope described in this privacy policy or as required by laws and regulations, and we strictly keep it confidential. Generally, we will not share your personal information with any company, organization, or individual, except in the following cases:

1.1 When we've already obtained your clear authorization or consent.

1.2 To share your personal information based on applicable laws, legal procedures, government's mandatory orders, or judicial decisions.

1.3 To share your personal information with third parties, within the scope permitted or required by law, to protect our users or the public's interests, property, or safety.

1.4 Your personal information may be shared among our affiliated companies. We'll only share necessary personal information, and such sharing is constrained by the purposes declared in this privacy policy. If affiliated companies want to change the processing purpose of personal information, they will seek your consent again.

1.5 To offer you more comprehensive and better-quality products and services, some of our services will be provided by authorized partners. You can refer to the "Third-party Cooperation Directory" for third-party SDK services included in our games. We may share some of your personal information with our partners to provide better customer service and user experience. We will share your personal information only for lawful, legitimate, necessary, specific, and clear purposes. We will take measures like encryption and anonymization to protect your information. We will also sign strict confidentiality agreements with our partners, requiring them to process your personal information according to our instructions, this privacy policy, and any other relevant confidentiality and security measures. Our partners are not allowed to use the shared personal information for any other purpose. If you refuse our partners to collect necessary personal information for providing services, you might not be able to use that third-party service in this app.

Our products may contain third-party SDKs or similar applications. When you use services provided by third parties within this application, you agree that they will directly collect and process your information (e.g., in the form of embedded code, plugins, etc.). The aforementioned service providers collect and process information in compliance with their own privacy terms, which do not apply to this privacy policy. To maximize the protection of your information, we recommend that you review the privacy terms of any third-party SDKs before using them. To protect your rights and interests, if you find risks associated with such SDKs or similar applications, we advise you to stop the relevant operations immediately and contact us promptly.

2. Transfer

Unless we obtain your explicit consent, we will not transfer your personal information to any company, organization, or individual. In cases of mergers, acquisitions, or bankruptcy liquidations that involve the transfer of personal information, we will require the new entity holding your personal information to be bound by this privacy policy. If there are any changes to the collection and processing methods of personal information stipulated in this privacy policy, the company or organization will seek your authorization and consent again.

3. Public Disclosure

3.1 Public disclosure refers to the act of releasing information to the public or unspecified groups. We will not publicly disclose your personal information, except for necessary disclosures, such as announcing penalties for accounts that violate regulations, fraudulent activities, and displaying winners' lists in a de-identified manner. If there's a legitimate reason for public disclosure, we will inform you in advance about the purpose and type of information disclosed (if it involves your sensitive personal information, we will also inform you about the content) and will only disclose it with your authorization and consent, unless otherwise stipulated by laws or regulations.

3.2 For your publicly disclosed personal information, we will promptly and carefully review the legitimacy, reasonableness, and legality of disclosure requests. We will adopt the strictest personal information security measures to protect it during and after the disclosure.

4. Exceptions to Sharing, Transferring, and Publicly Disclosing Your Personal Information

Please note that, as stipulated by laws and regulations, sharing, transferring, and publicly disclosing your personal information does not require your prior authorization and consent under the following circumstances:

4.1 Directly related to national security or defense;

4.2 Directly related to public safety, public health, and significant public interests;

4.3 Directly related to crime investigations, prosecutions, trials, verdict implementations, or as required by laws, regulations, or authorized administrative or judicial bodies;

4.4 To protect major legal rights and interests, such as life or property, of you or others when it's difficult to obtain your consent;

4.5 Personal information that you have publicly disclosed or collected from legally public sources (like legal news reports, government information disclosure);

4.6 Necessary for signing and fulfilling agreements or other written documents with you;

4.7 Other situations as stipulated by laws and regulations.

Ⅵ. Regarding the Use of Cookies and Similar Technologies

1. When you use our products and/or services, we might use cookies and similar technologies to collect some of your personal information, including login data. This collection is essential for simplifying repetitive tasks (like registration, login), facilitating browsing history, ensuring the safety of your information and account, and enhancing our products and services.

2. Please understand that certain functionalities of our products/services can only be achieved by using cookies or similar technologies. If you refuse or delete them, you may not be able to use our relevant products/services properly or have the best user experience. It might also affect the protection and security of your information and account.

Ⅶ. Storage and Protection of Your Personal Information

1. Storage of Information

1.1 Storage Location: According to regulations, we only store the personal information we collect from you within the People's Republic of China. Currently, we do not store your personal information outside China or provide it to overseas entities. If there's a need for cross-border data transfer, we will explicitly inform you (including the purpose, recipient, usage methods and scope, content, security measures, risks, etc.) and seek your consent. We will ensure the recipient has adequate data protection capabilities.

1.2 Storage Duration: We retain your personal information for the minimum period necessary to achieve the purpose of the product and service. For example, when using our registration feature, we need your phone number and will keep it as long as you use that feature to provide the service and ensure account and system security. Additionally, we may retain your information for the period required by applicable laws.

1.3 After exceeding the above storage duration, we will delete or anonymize your personal information.

2. Information Protection

2.1 The security of your personal information is of utmost importance to us. We will strictly adhere to relevant laws and regulations, adopt measures recognized as reasonable and feasible within the industry, and protect your personal information. We strive to prevent unauthorized access, disclosure, use, modification of your information, and avoid data damage or loss.

2.2 We use security measures that meet industry standards to protect the personal information you provide. This is to prevent unauthorized access, public disclosure, use, or modification of your data, and to prevent data from being damaged or lost. We will take all reasonably possible measures to protect your personal information. For example, we use SSL to encrypt data. We have established access control mechanisms to ensure that only authorized personnel can access personal information. We periodically hold security and privacy protection training sessions to enhance our employees' awareness of the importance of protecting personal information.

2.3 To prevent security incidents, we have established a dedicated data security department and developed appropriate early warning mechanisms and emergency plans. In the event of a personal information security incident, we will notify you promptly in accordance with the requirements of laws and regulations. This will include information about the basic situation of the security incident and its possible impact, the measures we have taken or will take, recommendations for you to independently prevent and reduce risks, and remedies for you. We will promptly notify you of the incident through methods such as phone calls or push notifications.

Ⅷ. Your Rights to Manage Personal Information

We understand your concern about personal information and do our best to ensure that you have the right to access, correct, delete, and revoke the authorization of your personal information, giving you ample ability to protect your privacy and security.

1. You have the right to inquire about your personal informations

You can refer to the relevant instructions (or settings) of our products and services to review the personal information you have provided to us, including:

1.1 Account Information: You can log into your personal profile page through the relevant game page at any time to access personal information in your account, including your avatar, nickname, etc.

1.2 Other Information: If you encounter operational problems during access and need to obtain other previously unknown personal information, you can contact us through the contact information disclosed in Article 10 "Contact Us" of this privacy policy.

2. You have the right to correct/modify your personal information

If you find that the personal information you have provided to us is incorrect, incomplete, or updated, you can submit a correction/modification application by contacting us through the contact information disclosed in Article 10 "Contact Us" of this privacy policy.

2.1 For some of your personal information, we provide operation settings on the relevant product pages where you can directly correct/modify them, such as "Avatar/Nickname."

2.2 If you encounter difficulties in exercising the above rights or for other possible reasons that we currently cannot provide you with online self-correction/modification services, you can contact us using the contact details in Article 10 "Contact Us" of this privacy policy. After verifying your identity and ensuring that the correction/modification does not affect the objectivity and accuracy of the information, we can correct/modify incorrect or incomplete information, except as otherwise provided by laws and regulations. However, for security and identification reasons, you may not be able to modify some of the initial registration information submitted at the time of registration.

3. You have the right to delete your personal information

3.1 For your personal information, you can apply for deletion by contacting us through the contact information disclosed in Article 10 "Contact Us" of this privacy policy. Once the application for deletion of personal information is approved, we will delete or anonymize such information unless otherwise stipulated by laws and regulations.

3.2 In the following circumstances, you can directly request us to delete your personal information, except for information that has been anonymized or as otherwise provided by laws and regulations:

(1) When our processing of personal information violates laws and regulations;

(2) When we collect and use your personal information without your consent;

(3) When our processing of personal information violates our agreement with you;

(4) When you cancel your account;

(5) When we terminate our services and operations.

4. You have the right to revoke your authorization for personal information.

As mentioned earlier, some functions of the products and services we offer require access permissions to your device (the permissions you have authorized us to use are detailed in Section 4, specifically based on the actual functions acquired by the product). You can withdraw (or stop) this authorization at any time after granting it. If you wish to revoke our collection, use, and disclosure of your other personal information or want us to delete your personal information, you can contact us using the contact information provided in this privacy policy. For example, you can revoke your permission for the camera and album via "Settings-Apps and Notifications-Permission Management" on Android devices.

You can also permanently withdraw all authorizations for us to continue collecting your personal information by logging out of your account. Please understand that after you withdraw your authorization, we cannot continue to provide you with the specific functions and/or services corresponding to the revoked authorization. However, your decision to withdraw authorization will not affect the processing of personal information carried out based on your previous authorizations.

5. You have the right to cancel your account.

(1) You can apply for account cancellation online, contact customer service, or use other methods we announce. Once you cancel your account, you can't log in and use this app with that account; any unused rights, benefits, and future due benefits related to that account will be cleared. Contents, information, data, records, game props, levels, etc., related to that account will be deleted or anonymized, except as otherwise provided by law or required by regulatory authorities. For example, according to the "Cybersecurity Law of the People's Republic of China," your online operation logs will be retained for at least six months. Once account cancellation is complete, it cannot be restored.

If you still decide to cancel your account after careful consideration, you can submit a cancellation request via the relevant function settings page of our product and/or service or follow the operation guide. For instance, the account cancellation path on the iOS app is: "My-Settings-Privacy Permission Settings-Account Cancellation."

If you have any questions regarding the handling of your personal information, you can communicate and resolve them with us through the contact details displayed in the tenth section "Contact Us" of this privacy policy. Upon receiving the information, we will respond to your request within 15 working days.

(2) If you log into this app with a third-party account and choose to cancel your account, we remind you to go to the third-party platform to revoke the authorization for using that third-party account to log into this app. The procedure and conditions for revoking authorization are based on the requirements of that third-party platform.

IX. Our Protection for Minors

1. Minors should obtain the consent of their guardians before using our products and/or services. If you are a minor, you should read this privacy policy under the supervision and guidance of your guardian and use our products and/or services and provide personal information under the explicit agreement and guidance of your guardian. We protect minors' personal information in accordance with relevant national laws and regulations and only collect, use, or disclose minors' personal information when allowed by law, with the guardian's explicit consent, or when necessary to protect your rights and interests.

2. If you are a guardian of a minor, you understand and agree that we will collect, use, store, and share your child's personal information:

2.1 When your child uses this app, we will only collect the personal information about your child that you have agreed for us to collect or that you and your child actively provide. This is to offer and optimize our services and ensure your child's account security.

2.2 We will store any collected information about your child within the People's Republic of China in accordance with legal regulations. Generally, we will store your child's personal information only for the duration necessary to achieve the purpose of the service or as stipulated by laws and regulations. After this period or if not in compliance with laws or regulatory requirements, we will anonymize your child's personal information as required by law.

2.3 We use industry-standard security measures to protect the personal information your child provides to prevent unauthorized access, disclosure, use, modification, damage, or loss. We will take all reasonably feasible measures to protect your child's personal information.

2.4 Unless legally required or pre-agreed with you that we can disclose your child's personal information, we will not disclose it.

3. We implement a real-name registration system for online game users, fully integrate with the National Press and Publication Administration's real-name authentication system, and use an anti-addiction system to protect minors' legal rights and interests. We will verify the real-name information of the account to determine whether the user is a minor and then decide whether to include the account in the anti-addiction system. We will collect your login time, game duration, etc., and use system-level interventions to limit minors' gaming time, activate mandatory offline features, and other anti-addiction measures to guide minors to game reasonably.

4. We strictly comply with legal regulations and agreements with users and use, store, and collect information as described in this privacy policy. If you have any questions about the personal information of the minor you are guarding, you can communicate and resolve them with us through the contact details displayed in the tenth section "Contact Us" of this privacy policy. If we discover that we have collected a minor's personal information without prior verifiable guardian consent, we will delete the data as soon as possible.

X. Contact Us

1. If you have any questions, concerns, or complaints about this Privacy Policy, or if you encounter any issues related to privacy protection while using the application, you can contact us through the following means:

1.1. You can email our customer service at alt-lab@hotmail.com

1.2. You can contact us by adding our online customer service QQ: 650163012;

2. After receiving your feedback and suggestions, and upon verifying your user identity, we will respond to you as soon as possible within 15 working days. However, please understand that in the following situations related to personal information, we might not be able to respond to your requests:

2.1. Matters related to national security or defense;

2.2. Matters related to public safety, public health, or significant public interest;

2.3. Matters related to criminal investigations, prosecutions, and judicial proceedings;

2.4. If there is sufficient evidence showing malicious intent or abuse of rights on your part;

2.5. Responding to your request would seriously harm the legitimate rights and interests of you or other individuals or organizations;

2.6. Matters involving trade secrets;

2.7. Other circumstances as stipulated by laws and regulations.

XI. How This Policy Is Updated

1. To better serve you, based on product updates and legal requirements, we may amend the terms of this Privacy Policy. Such amendments form part of this Privacy Policy. Without your explicit consent, we will not reduce the rights you enjoy under this policy. If any amendment results in a substantial reduction in your rights under this policy or significantly alters it, we will notify you in a prominent place or by push notification or other means and seek your consent again before implementing the updated policy.

2. Significant changes include, but are not limited to:

2.1. Major changes in our service model, such as the purpose of processing personal information, types of personal information processed, and ways of using personal information;

2.2. Major changes in our ownership structure or organizational structure, such as changes in ownership due to business adjustments, bankruptcies, or mergers and acquisitions;

2.3. Changes in the primary parties with whom we share, transfer, or publicly disclose personal information;

2.4. Major changes in your rights regarding the processing of personal information and the way you exercise those rights;

2.5. Changes in the department responsible for the security of personal information, their contact information, and complaint channels;

2.6. When a personal information security impact assessment indicates a high risk.

XII. Dispute Resolution

1. The interpretation and dispute resolution of this Privacy Policy shall be governed by the laws of the mainland of the People's Republic of China. Any disputes arising from this Privacy Policy and our processing of your personal information shall be arbitrated by the Beijing Arbitration Commission. The decision of such arbitration shall be final and binding on both parties.

2. If you believe that our processing of personal information has harmed your legal rights and interests, you can also file a complaint with the relevant government department.

3. The headings in this Privacy Policy are for convenience and reading purposes only and do not affect the meaning or interpretation of any provision within the text.