Privacy Policy
NETDRAGON WEBSOFT (HONG KONG) LIMITED (herein "we" or "us"", “ours”), including its subsidiaries and affiliates, understands the importance of protecting your personal information (the "Personal Information"). We have adopted this privacy policy (the "Policy") to explain how we collect, use, process, store and share the Personal Information that provide to us or we collect when you use our websites, software applications, games or any other services provided by us (the "Services").
We collect, use, process, store and transfer your Personal Information in accordance with applicable data protection legislation, including but not limited to the (EU) General Data Protection Regulation ("GDPR") and applicable national data protection legislation ("Applicable Laws"). Wherever we talk about Personal Information below, we mean any information that can either by itself identify you as an individual or that can be connected to you indirectly by linking it to your Personal Information. We also collect, use, process, store and transfer de-identified data, whether aggregated or not, to analyse and generate reports related to usage patterns, spending habits, demographics of users, etc. As a person is not or no longer identifiable from such anonymous data, the use of such data will not be governed by this Policy.
You agree that we will engage other third parties and may transfer your Personal Information to such third parties in order to fulfil our purposes and obligations as set out in this Policy. You acknowledge that some of these third parties may be located outside the country of your residence where there may not have as strict privacy legislation as yours. We will only transfer your Personal Information to such countries if we are allowed to do so, please see section D for more information.
By downloading, accessing and/or using our Services, you consent to our collection and use of your Personal Information in accordance with this Policy, including consenting to our advertising partner’s use of your data for targeted advertising purposes as set forth in section B of this Policy. IF YOU DO NOT AGREE TO THE POLICY OR OTHERWISE HAVE ANY CONCERNS ABOUT THIS POLICY, YOU SHOULD CONTACT US FOR ASSISTANCE AND SHOULD REFRAIN FROM USING OUR SERVICES.
A. COLLECTION OF YOUR PERSONAL INFORMATION
We collect Personal Information about you to provide you with our Services, including improving and optimising our Services, detecting unlawful use of our Services, personalising offers and processing and verifying transactions.
Depending on the type of Services you are using, we may collect the following types of information from you:
(i) Personal data
Ÿ Identification information, including but not limited to your surname and first name, date of birth, external or internal identification code, identification code associated with the platform used, gender, age, country of residence.
Ÿ Contact information, including but not limited to your email address, and mobile application id.
(ii) Data that may be collected automatically concerning how you use our Services
Ÿ Data about your connection and device, including but not limited to your IP address, mobile device identifier, advertising ID, MAC address, IMEI device name, operating system, browser type, hardware information and language.
Ÿ Data about your use of our website, including but not limited to browsing time, click-activity, referring website, date/time stamp for your visit and/or data we collect with cookies and similar technologies (Please see Section B for further information).
Ÿ Data about your location, including general and precise geo-location data such as GPS location.
Ÿ Data about your use of the Services, including but not limited to account history, usage/session time, preferences, audio or video recordings, gameplay data, game progress, crashes or bugs data, social media sharing and interactions, purchase history and billing history
Ÿ Data required to be collected for detection, investigation and prevention of fraud, cheating, misuse of our Services or other violations to our End User Agreement or Applicable Laws.
(iii) Data that you may provide to us
Ÿ Contact information (such as name and email address)
Ÿ Player name and password
Ÿ Profile information (such as profile photo)
Ÿ Your messages to the Service (such as chat logs and player support tickets)
Ÿ Other data you choose to give us (such as data to identify a lost account ,Account number, email, upload photos, security questions and answers you created)
Ÿ Bank card information【In-game Store】
Ÿ User address 【In-game ReChargeCenter】
Ÿ Data we collect automatically
Ÿ Data about your account and game progress
Ÿ Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI)
Ÿ Data about your device, such as device name and operating system, browser type and language
Ÿ Data we collect with cookies and similar technologies (see more below)
Ÿ General location data
Ÿ Precise geo-location data (GPS, with your consent)Data about your use of the Service, such as gameplay data and your interactions with other players inside the Service
(iv) Personal Information You Authrize Us to Gather and Use
(1) Device Permission
To access specific services or improve your experience with this app, you need to provide us with the information required and allow us to ask for device permission if necessary. Permissions may be different on Android and iOS devices.
Permission requests on Android:
Storage
Services/Functions Applied: Unzip resources and install the app for the first time, download updates, save abnormal\crash logs, collect game problems, improve gaming experience, save audio files for voice chat, save screenshot for sharing, other storage permissions for sharing, Google Pay and Apple Pay.
Request Purpose: Read and write to files from external storage, and download files.
Network
Services/Functions Applied: Update, and all functions for interaction.
Request Purpose: Match to right services based on the network connection.
Device Information
Services/Functions Applied: Account security, user account binding, and other services based on the device version.
Request Purpose: Match to the information of user devices.
Microphone
Services/Functions Applied: Voice chat.
Request Purpose: Voice input.
Permission requests on iOS:
Microphone
Services/Functions Applied: Voice chat.
Request Purpose: Voice input.
Album
Services/Functions Applied: Wardrobe, and share event posters.
Request Purpose: Save screenshots to the album.
Withdrawal does not affect how we process your personal data based on your consent before the withdrawal is made. If you refuse our request for access to the personal data above, we may not be able to continue providing the services based on such data. Failure to provide the data necessary for any of our services may make all services unavailable to you.
(2) Third-Party Information
To complete transactions and provide better services, we will collect necessary trade information from the direct target and third-party organizations that you choose to process your transactions.
(v) Data that may be provided to us by third parties
Ÿ Data we receive if you link a third party tool with the Service (such as FACEBOOK ,TWITTER)
Ÿ Demographic data (such as to determine the coarse location of your IP address)
Ÿ Data to fight fraud (such as refund abuse in games or click fraud in advertising)
Ÿ Data from platforms that the games run on (such as to verify payment)
Ÿ Data for advertising and analytics purposes, so we can provide you a better Service
B. Use of Data
We may use your Personal Information for the following purposes:
Ÿ Provide and operate the Services, including for the purposes of providing online leaderboards;
Ÿ Customize and improve the Services;
Ÿ Analyze and provide statistics of the use of the Services;
Ÿ Manage clearly unlawful conduct and misuse of the Services;
Ÿ Send newsletters and promotions;
Ÿ Treat job applications.
any other purposes described in the Policy, such as the pursuit of other legitimate commercial interests related to the Services or when we collect your Personal Information with your consent for specific purposes made known to you at the time of collection.
Our Legitimate interest
We may also use your Personal Information for our legitimate interests, such as for the purposes of our compliance with Applicable Laws, to ensure information security, to prevent fraud, etc.
When we rely on a legitimate interest, we have concluded that our interests do not override your interests or fundamental rights and freedoms. You are welcomed to contact us to learn more about how we reach this conclusion.
Analytics and optimisation
We use internal analytics technologies and other automatic tracking and analytic technologies provided by third parties to collect information through automated means, such as cookies, web beacons, web sever logs, JavaScript or other similar technologies in order to adapt our content to your interests as well as to provide and manage the use of the Services.
(i) Cookies
Cookies, or similar technologies, are small computer files stored on your hard drive via your web browser. Various types of cookies may be used for a number of purposes and they are placed on our websites either by us or by other third parties permitted by us. The information collected by cookies enable us to monitor site traffics and users’ interactions with other services. We may also use certain cookies that can only collect generic information in relation to browser configurations and personalize the appearance of our websites. We also use anti-cheat technologies that also use cookies as described below.
You may decline the storage of cookies by changing the configuration of your web browser. However, if you decline, the Services and/or our websites and/or certain features may not work properly. For more information on cookies, please refer to the following website: http://www.allaboutcookies.org.
(ii) Third-party analytics tools
Third-party analytics tools (including, but not limited to, AppsFlyer) may use cookies or visitor action pixels to track your behaviors while you are using our Services. These tools may associate the information they collected in connection with the Services with personal information that they had independently collected on other services, as governed by their respective privacy policies. We do not collect or access any data that may be independently collected by these third parties.
We use the following third-party analytics providers and you may refer to their privacy policy at the links provided below:
Ÿ AppsFlyer: https://www.appsflyer.com/privacy-policy/
(iii) About the usage of third-party codes and plug-ins
Scenario: Login with Facebook and share content through Facebook.
Use third-party codes and plug-ins to transfer personal data: Yes
Field for personal data shared: Facebook Account Authorization
Third-Party Name: Facebook
De-identify data when transferred: Yes
Scenario: Login with Google and Google payment service
Use third-party codes and plug-ins to transfer personal data: Yes
Field for personal data shared: Google Account Authorization
Third-Party Name: Google
De-identify data when transferred: Yes
Scenario: Appsflyer
Use third-party codes and plug-ins to transfer personal data: Yes
Field for personal data shared: User Behavior
Third-Party Name: Appsflye
De-identify data when transferred: Yes
Ads Serving Technologies
Ads serving technologies, including for interest-based ads, from our suppliers (including, but not limited to, Unity Ads) involve the use of pixels and/or other similar technologies to collect data in order to determine what kinds of advertising you would prefer to see.
Data collected by these third parties may include, without limitation, (i) your age and/or sex, (ii) your IP address and/or country, (iii) the advertisements placed and their location in the Services, (iv) the duration of visibility of an advertisement as well as the number of views, (v) the identifiers and settings of your device, (vi) your use of the Services, products, and/or other websites (including third party websites) you have viewed (as well as the date and the time of such viewing), and/or (vii) your responses to the advertisements, if any, to allow our suppliers to calculate the number of views of the advertisements or to present ads in a format that best suits your device. Advertisements may be tailored to your interests, for example, you could view an offer for a game or product that might interest you.
Third-party advertising service providers may associate the Personal Information with data that they have collected independently from other services in accordance with their own privacy policies. We do not collect or access data that may be independently collected by these third parties. To learn more about some of these ad network practices, you can visit www.networkadvertising.org, www.aboutads.info/choices, or www.youronlinechoices.com.
The technologies deployed by us as described above are fundamental to our Services. If you do not consent with the use of the abovementioned technologies, you should refrain from using or accessing our Services
Anti-cheating services
We may use anti-cheating tools ("Anti-Cheating Tools") that are provided or operated by third parties (including, EasyAntiCheat and Battleye) in form of a software (the "Software") that has been integrated into our Services, in particular, in our games.
When you start a new game session, the Software may automatically load and install its latest version on your device. When using the game, the Anti-Cheating Tools may scan the game's binary files and the device's memory to detect and prevent cheating in the game (the "Objective"). By installing or accessing any of our games, you agree that the Anti-Cheat Services may collect, store and disclose to us Personal Information for the sole purpose of fulfilling the Objective and also to identify players who cheat in games and prohibit them from doing so. This Objective is necessary to pursue our legitimate interests and to ensure the safety of you and other users of our Services.
The collection of data by such Anti-Cheat Service providers will be governed by their privacy polices. You may refer to their privacy policies at the links provided below:
Ÿ Easy Anti-Cheat: https://www.easy.ac/r/privacy/statement/21/
Ÿ Battleeye: https://www.battleye.com/privacy-policy/
If you think that your access to our Services has been blocked by mistake by the Anti-Cheating Tools, please contact us at service@eudemonsm.com.
Social Media Features
You will be able to use our social media features for logging into our Services, find out if your friends play our services, and invite them to join you in these services. If you choose to use social media features in some of our Services, especially games or mobile games, or to create account with us using your account with certain social media platform, the social media platform will provide us with some of your Personal Information, such as, your social media platform user ID, your profile picture (to create your avatar in certain games) and the user IDs and profile pictures of your followers, friends or contacts on such social media platform. You may determine the scope and extent of Personal Information that will be provided to us by modifying your sharing settings.
Public data, including user-generated content, online forums, blogs, chat and profiles
You may communicate Personal Information when you provide or otherwise create contents by using or accessing our Services, whether as part of games, online forums, blogs, discussion platforms, public user profiles or other similar forums available as part of our Services (collectively, the "Forums"). Any Personal Information you disclose in the Forums would become public data and may be read or used by other users without your consent. If you decide to disclose Personal Information on the Forums, you will do so at your own risk and we shall not be responsible for held liable for any unauthorised use of such Personal Information by any third parties.
You may choose not to provide certain Personal Information. However, you may not be able to use certain or all features of our Services.
C. Personal Data Shared with Third Parties
We may, from time to time, engage independent subcontractors to provide us with certain services, such as sending e-mails, processing of payments, hosting of data, and providing customer support. We take reasonable contractual measures to ensure that these third parties adequately protect the Personal Information.
We do not share Personal Information with other third-parties, except as necessary for provide the Services, for our legitimate business needs, for carrying out your requests, and/or as may be required or permitted by Applicable Laws.
In particular, we engage third parties to collect and process your Personal Information on our behalf and for our benefits in order to provide the Services, including but not limited to:
Ÿ Our holding companies, subsidiaries or affiliated companies in and/or outside of Hong Kong
Ÿ Independent contractors and/or service providers for them to provide their services to us, including information technology system providers, hosting services providers, data storage and management providers, customer relationship providers, marketing research and profiling services providers, advertising partners (you may refer to Section B for information on marketing and advertising), payment processing services providers
Ÿ Potential investors, valuers or such professionals in connection with any potential merger, acquisition, sale, assignment, financing or transfer of our business
Ÿ Insurance companies
We may share Personal Information that does not identify you directly, which is anonymized or aggregated, with third parties, for example to analyze trends in the use of the Services. In addition, we do not control the data sent by your web browser to third parties who receive this information in your normal course of activity on the Internet.
D. Location and Transfer of Your Personal Information
The Personal Information may be hosted and processed, for the purposes of the Policy, on servers operated by trusted partners in the United States (in accordance with the Privacy Shield mechanism recognized by the European Commission), such as Amazon Web Services, as well as on our servers or our partners’ servers in Canada (which is a jurisdiction with an adequate level of protection recognized by the European Commission) or in Europe.
Some of our subcontractors described in Section C may be located in other countries, including outside the European Economic Area. By using the Services and the games, you agree that your Personal Information may be processed by such subcontractors in countries that may not offer the same degree of data protection as your country. We will, however, only transfer the Personal Data in compliance with Applicable Laws.
We have taken reasonable contractual measures to ensure that our subcontractors would process your Personal Information in accordance with our directions and for our purposes as set forth in this Policy. Our subcontractors are prohibited from using your Personal Information for any other purposes without your consent.
E. Retention Period of Personal Information
We keep your Personal Information for a period not exceeding what is required for the purposes for which the Personal Information is collected and in accordance with Applicable Laws.
Your data will be kept in our active database:
- for the time as long as necessary to provide the Services; or
- for the duration necessary to solve your technical problems or your request; or
- for the time needed to compile game statistics; and
- for 30 days for IP addresses and logs.
At the end of this period, your Personal Information will be deleted or anonymized by us, or archived in an intermediate database, if necessary, for legal, operational, or legitimate reasons, and for the legally prescribed period. The retention period may be changed upon your cancellation of or re-enrollment in the Services, or in accordance with Applicable Laws.
F. Safeguards of your Personal Information
We take different measures to secure your Personal Information. We follow generally accepted rules in the video game industry, as well as Applicable Laws, to protect any loss, destruction, alteration, or unauthorized, unlawful or abusive use of the Personal Information. We strive to use appropriate organizational and technical means to protect your Personal Information. For example, we will use encryption technologies (such as TLS, SSL), anonymization and other means to protect your personal information.
We have established a specialized management, process and organization system to ensure information security. For example, we strictly restrict the scope of personnel who can access information and require them to comply with their contractual confidentiality obligations and subject to regular audits. In the event of a data breach or other security incident of Personal Information, we will activate emergency response plan to prevent the expansion of such security incident and notify you in the form of push notifications, public announcements, etc.
However, you acknowledge that no security measures are 100% effective. To the extent permitted by Applicable Laws, we shall not be held liable for any direct or indirect loss, damages or costs sustained or incurred by you in the event of data breach or if the Personal Information is subject to unauthorized use or access.
If you have any questions regarding the security of your Personal Information, please contact us by email at service@eudemonsm.com.
G. Your Rights and Choices on Your Personal Information
For Services which you have created an account with us, you can access, modify, update and delete any Personal Information at any time by logging into the relevant Service and adjusting your account settings.
If you wish to contact us regarding the processing of your Personal Information, or to have access to it in an electronic format, correct it, erase it, change how we process it (if applicable), or withdraw your consent (if applicable), or transfer them to another online provider (where technically possible), you may email us at service@eudemonsm.com. Please note that the withdrawal of your consent shall not affect the lawfulness of how we have used or processed your Personal Information before your withdrawal.
In the case of an email request, you agree to provide us with your contact information, the subject of the request and the Personal Information in question for our further action. We reserve the right to ask you for any information about you to confirm your identity.
Please note that if you choose to delete your Personal Information, you will no longer have access to the Services associated with your internal and/or external identifier.
We reserve the right to reject deletion requests if there is a legal obligation on us to retain the Personal Information due to legal claims or as required by any Applicable Laws.
Your request will be processed within thirty (30) days of receipt, with the understanding that we reserve the right as permitted by Applicable Laws to extend this period to two months due to the complexity and number of requests.
You may also contact your local data protection authority for any questions relating to the collection and use of your Personal Information.
H. Children
Most of our Services (including some of our games) are not directed to children under the age of 12 (“Controlled Services”). WE DO NOT KNOWINGLY COLLECT, SOLICIT, MARKET TO OR REQUIRE THE PERSONAL INFORMATION BELONGING TO CHILDREN. IF YOU ARE 13 YEARS OLD AND LESS, OR BELOW THE MINIMUM APPLICABLE AGE IN COUNTRIES WHERE THIS AGE IS GREATER THAN 12 YEARS, DO NOT SEND YOUR PERSONAL INFORMATION TO US AND DO NOT USE SUCH CONTROLLED SERVICES. If we obtain actual knowledge that we have collected data from a Children, we will promptly delete it, unless we are legally obligated to retain such data.
We strongly recommend the parents and/or legal guardians of the Children, to read this Policy thoroughly to understand how we will collect, use, store, share and protect Children’s data in connection with the Children’s use of our Unrestricted Services.
We may require the parents’ and/or legal guardians’ personal information to create any user accounts for their Children to access to our Unrestricted Services. Such information may include full name and email address. We may also require the parent’s and/or legal guardian’s separate consent and acknowledgement to this Policy before allowing the creation of account and/or access to our Unrestricted Services.
We collect information as detailed in this Policy for the purpose of providing Unrestricted Services and other purposes as described in this Policy. We shall obtain the parents’ and/or legal guardians’ separate consent each time when Children voluntarily provide, upload, and publish content and information, which may or may not contain images, videos, and Personal Information of the Children by contacting or emailing the parents and/or legal guardians from time to time.
We strongly recommend parents and/or legal guardians to instruct their Children not to upload, share or disclose any Personal Information while using our Services or provide the same to other users of the Services. Parents or legal guardians are liable for all activities of their Children.
Parents or legal guardians who are concerned about our use of data are welcomed to contact us at service@eudemonsm.com.
I. Third party services
Our Services may contain advertisements or links to third-party websites such as Twitter, Facebook and/or YouTube. The presence of these links on our Services does not constitute an approval, an authorization or an affiliation with the websites in question. If you click on these links or use the services of a third party, you will leave our Services and you must consult the privacy policy of the website in question before sharing your Personal Information.
Certain products and/or services are offered to you as part of our Services in partnership with third parties and you may be required to provide Personal Information to them in order to register and access their products or services. The identity of these third parties will be indicated at the time of registration. If you choose to register, you will transmit your Personal Information to these third parties and their use of your Personal Information will be subject to their privacy policies.
We are not responsible for the use of your Personal Information by such third parties and we cannot guarantee that they have the same level of data protection policy as us.
J. Conditions of use of our Services
The terms of this Policy are incorporated into our End User Agreement which you may refer to at the following link: https://www.eudemonsm.com/en/m/eua.shtml
K. Changes to the Policy
We reserve the right to change the Policy at any time. If we change the Policy, we will communicate the changes to you through the landing page or other similar page under the Services, or any other appropriate means, for example, by email or with a pop-up notice in our games or on your account page, so that you will be fully informed of such changes. Any changes to the Policy will take effect thirty (30) days after such changes have been communicated to you. Your continued use of our Services will be deemed as an acceptance of the changes to the Policy.
L. Severance
If any part or provision of this Policy is prohibited or deemed to be void or unenforceable, that part or provision shall be ineffective to the extent of such prohibition or unenforceability without invalidating the remaining provisions hereof.
M. Governing Law
This Policy shall be governed by, and construed in accordance with, the laws of Hong Kong Special Administrative Region (“Hong Kong”). Any dispute, controversy, difference or claim arising out of or relating to these Terms and Conditions, including the existence, validity, interpretation, performance, breach or termination thereof or any dispute regarding non-contractual obligations arising out of or relating to it shall be referred to and finally resolved by arbitration administered by the Hong Kong International Arbitration Centre (HKIAC) under the HKIAC Administered Arbitration Rules in force when the Notice of Arbitration is submitted. The seat of arbitration shall be Hong Kong. The number of arbitrators shall be one. The arbitration proceedings shall be conducted in English.
N. Communicate with Us
If you have any questions or concerns regarding this Policy, please contact us using information as follows:
Name: NETDRAGON WEBSOFT (HONG KONG) LIMITED
Address: Units 2001-05 & 11, 20th Floor, Harbour Centre, 25 Harbour Road, Wan Chai, Hong Kong
Email Address: service@eudemonsm.com
Telephone Number: 852 2850 7215