Privacy Policy
UPDATE DATE：August 16, 2024
Beijing Topjoy Technology Co., Ltd. (hereinafter referred to as
“we”) has formulated this "Privacy Policy" to ensure the security of
your personal data and to protect your privacy. The purpose of this policy is
to help you understand our respect for and protection of your privacy, and to
inform you about relevant information concerning your personal data. This
statement explains how we collect and use your personal information when you
use our games ("Games" or "Products") and outlines your
associated rights.
Privacy Policy
1. Scope of
Application
This Privacy Policy applies to the collection, processing, utilization,
transfer, and protection of personal data when you participate in activities
within our games and affiliated websites.
2. Purpose and
Categories of Data Collection
Depending on the services we provide, we may collect your personal data in the
following situations and categories:
(1) Game
Participation
When you apply to join a game, your personal data, including your name,
nickname, and other necessary information, will be collected. After becoming a
member, you will receive a membership account and password, which you can use
to access various membership services.
Additionally, data related to your computer hardware, software, and mobile
devices, including your browser type, login time, and website addresses, may be
collected. We use this data to help maintain the operation of the game and
ensure service quality.
(2) Online
Transactions
If you use online transaction services within the game, we will verify the
order information you submit based on the type of transaction requested,
ensuring that you can complete payments, recharge, and other related
consumption services.
(3) Online Events
When you participate in our online events or surveys, your personal data will
be directly verified through our membership database. However, if the event
requires you to provide additional information, you will need to fill in the
necessary data accordingly. This supplementary data is also protected under
this Privacy Policy.
(4) Browsing Products
and Websites
When you browse our websites or affiliated sites, our servers will
automatically record your connection time and browsing history. This
information is used solely to enhance and optimize our online services and
improve service quality. The data is only used for aggregated analysis and is
not linked to any specific individual.
(5) Others
With your consent or for the purpose of fulfilling a contract, your personal
data may be provided to us. This data will only be used and processed within
the agreed scope of services and will not be used for other purposes.
3. Duration, Region,
Recipients, and Methods of Data Usage
(1) Duration of Use
Unless otherwise stipulated by law, your personal data will be used until the
services within the game and its affiliated websites are completed or until you
request to cease using the services.
(2) Region of Use
Your data will be used in regions where we and our affiliated websites provide
services, as well as in the locations of other partner companies that you have
agreed to under the privacy policy.
(3) Recipients of Use
Unless otherwise stipulated by law, your personal data will only be used for
the agreed-upon service purposes and within our internal operations and
relevant connected scopes. We will not arbitrarily transfer your personal data
to third parties or use it for other purposes.
(4) Methods of Use
A. User
Information
When you access game services, we may collect relevant information about
your device as follows:
Information you
provide to us (directly or through third parties).
When you provide information about yourself, such as when you register for the
game (including your chosen nickname and information imported from connected
social media accounts), we may collect details like your social media profile,
device ID, and other user information. In certain regions, you may be asked to
provide additional information stored locally on your device to verify your age
or manage game systems.
In some regions, you may be required to provide an email address to verify
parental or guardian consent if you are below the relevant minimum age. You may
also need to provide information such as location data to customize gameplay or
services.
Once your game account is set up, we may access your phone number or email
address to verify your identity, ensuring you enter a code or password upon
each login.
Where applicable in your region, you may opt to receive promotional emails
related to our games. Additionally, you may provide information through
customer service interactions, including contact details, submitted queries,
and social media platform information. For data subject requests, we may
collect information like your country/region, email address, user ID, and
linked social media accounts to verify your identity and process requests.
B. Online
Transactions
If you choose to use online transaction services, we will confirm the relevant
order data you submit to ensure that you can complete payments, recharge, or
logistics-related consumption services.
C. Online
Events and Surveys
The personal data you provide when participating in our online events or
surveys will be used solely for the purposes of that event or survey.
D. Statistics
and Analysis
We periodically analyze and statistically process the data collected from your
game account registration and browsing activities on our website. This analysis
is only conducted at an aggregate level, not targeting individual behaviors.
4. Data Sharing
A. Regulatory
Authorities, Judicial Bodies, Law Enforcement Agencies, and Other Third Parties
We may disclose your information to relevant authorities when legally required,
such as for compliance with legal obligations or procedures, addressing safety
or fraud-related issues, or protecting our users.
B. Third-Party
Service Sharing
To ensure the stable and secure operation of the game and enable specific
functions, certain services in our game are provided by our affiliates or other
third parties. We carefully select these third parties and services and require
them to collect and use your personal information in accordance with this
Privacy Policy or other agreements made with you. We also ensure that they
implement appropriate technical and management measures to protect your
personal information. However, the usage of disclosed information by these
third parties is not bound by this Privacy Policy. If you have concerns about
how these third parties handle your information, please review their privacy
policies. Our services may include advertisements. When advertisers or ad
intermediaries place ads within our services, they may collect and share the
following types of data:
Collected information
may be used to:
Below are links to
the privacy policies of some of these third parties:
C. Statistical Data
To improve our security management, technical research capabilities, and
service quality, we may share de-identified or anonymized data with research
institutions. This is done within a reasonably necessary scope, ensuring the
data is shared for legitimate purposes and remains secure. We will not share
information that can identify you personally without your explicit
authorization.
D. Other
Except as outlined in this policy or in the user agreement, we will not
actively share your personal information with third parties without your
consent. We will only share your personal information with third parties as
described in this Privacy Policy. We do not sell your personal information to
third parties. However, we may share non-personal, aggregated, and/or public
information with third parties. Additionally, we may share your game data,
customer service data, and/or unique device identifiers for the purpose of
personalizing, adjusting, and improving our services. We require all such
third-party service providers to keep the information confidential and not use
it for any purpose other than providing services related to our products.
E. You have the right to know whether your personal data is sold. We do not sell
your personal information to third parties.
Data Retention Policy
|
Personal Information |
Retention Strategy |
|
Game |
|
|
Nickname, User
ID, IP Address |
Stored for the
entire lifecycle of your use of the game (i.e., until the account is deleted
at your request), then deleted within 30 days. If you do not request account
deletion, this data will be retained for 3 months after the game is
discontinued, and then deleted. |
|
Social Contact
Information |
Stored for the
entire lifecycle of your use of the game (i.e., until the account is deleted at
your request), then deleted within 30 days. If you do not request account
deletion, this data will be retained for 3 months after the game is
discontinued, and then deleted. |
|
Gender
Information |
Stored for the
entire lifecycle of your use of the game (i.e., until the account is deleted
at your request), then deleted within 30 days. If you do not request account
deletion, this data will be retained for 3 months after the game is
discontinued, and then deleted. |
|
Email Address
(used for parental or guardian consent verification) |
Stored for the
entire lifecycle of your use of the game (i.e., until the account is deleted
at your request), then deleted within 30 days. If you do not request account
deletion, this data will be retained for 1 year after the game is
discontinued, and then deleted. |
|
Region/Location
(manually selected by you) |
Stored for the
entire lifecycle of your use of the game (i.e., until the account is deleted
at your request), then deleted within 30 days. If you do not request account
deletion, this data will be retained for 1 year after the game is
discontinued, and then deleted. |
|
Game Statistics
(levels, heroes, scores), Date and Timestamp Information |
Stored for the
entire lifecycle of your use of the game (i.e., until the account is deleted
at your request), then deleted within 30 days. If you do not request account
deletion, this data will be retained for 1 year after the game is
discontinued, and then deleted. |
|
Location
Information (province and city manually selected by you), Nickname |
Stored for the
entire lifecycle of your use of the game (i.e., until the account is deleted
at your request), then deleted within 30 days. If you do not request account
deletion, this data will be retained for 90 days after the game is
discontinued, and then deleted. |
|
Birthday Feature
Information |
Stored for the
entire lifecycle of your use of the game (i.e., until the account is deleted
at your request), then deleted within 30 days. If you do not request account
deletion, this data will be retained for 90 days after the game is
discontinued, and then deleted. |
|
Activity-Based
Information (e.g., Digital Rewards) |
Retained for 1
year after the activity ends. |
|
Phone Card
Information |
Stored for the
entire lifecycle of your use of the game unless you request the deletion of
your game account or data, in which case the data will be deleted within 30
days. If you do not request account or data deletion, this data will be
retained for 3 months after the game is discontinued, and then deleted. |
|
Chat Communications
(Text) - In and Out of Combat |
Stored on our
servers for 7 days and automatically deleted after that period. |
|
Device ID,
Device Information, Registration Time, and Login Time |
Device ID,
Device Information (excluding VPN status), Registration Time, and Login Time:
Stored for the entire lifecycle of your use of the game (i.e., until the
account is deleted at your request), then deleted within 30 days (or within 7
days if the user requests deletion of the account or data). If you do not
request account deletion, this data will be retained for 3 months after the
game is discontinued, and then deleted.VPN Status:
Not stored. It is processed only on the device side and is not transferred to
us. |
5. Your Rights and How to Exercise Them
(1) You have the
right to make a written request to us regarding your personal data and exercise
the following rights:
Right to be Informed: In certain
situations, you have the right to be informed whether your personal data is
being or has been processed, including the existence of automated
decision-making and profiling. You also have the right to know the details of
data sharing as outlined in the "Data Sharing" section of this policy
(Section 4, point 5).
Right to Object: In certain
circumstances, you have the right to object to the processing of your personal
information, including for direct marketing, automated processing, or
profiling.
Right of Access: In certain
situations, you have the right to request reasonable access to your personal
information.
Right to
Rectification: In certain circumstances, you may have the right to
ask us to correct inaccurate or incorrect personal information, unless the
request is unreasonable or otherwise unjustifiable.
Right to Erasure or
Restriction: In certain situations, you may have the right to
pause, withdraw, or request the blocking, deletion, or destruction of your
personal information.
Right to Data
Portability: In certain circumstances, you may have the right to
request a copy of your personal information.
By agreeing to this
privacy policy, you consent to:
The sharing of your
data with third parties, companies within our corporate group, and third
parties acquiring all or most of our business.
The processing of
your data as described in this privacy policy and for the purposes outlined
herein.
Knowing whether your
personal data has been processed.
Understanding the
purposes for processing your personal data and whether they have been
appropriately used.
Knowing if your data
has been transferred to domestic or foreign third parties.
You have the right to
opt-out of the “sale” of your personal data. You can contact us within a
reasonable time frame via the channels listed in the product notice if such an
event occurs.
Right to Account
Deletion: You can request account deletion through the settings page of the
game product or other specified channels within the product. When you request
account deletion, we will verify the conditions of your request. After account
deletion, unless otherwise stipulated by laws, regulations, or this agreement,
your personal information associated with the game account will be deleted or
anonymized. Once the game account is deleted, it cannot be restored.
Right to Opt-Out: If you are a
resident protected by opt-out regulations like the VCDPA, you can request that
we no longer "sell" or provide your personal information in the
future. Some information may be exempt from such requests based on applicable
laws. To exercise your right to opt-out of the “sale” of your personal
information, please do the following:
Identification
Information: To opt-out, you need to provide the following
identifying information so that we can process your request:
Note: Any personal
information you submit related to your request will only be used to fulfill
your request. We may need to contact you to verify your identity and process
your opt-out request.
Contact Us via Email: Submit your
opt-out request to:
Email: lixiaoning@topjoy.com
Recipient: DPO-XIAONING
(2) Limitations on
Rights These rights may be limited if you do not meet our application
procedures or if there are legal requirements that restrict them.
(3) Costs. If you
request access to or copies of your personal data, we may charge a necessary
fee for the associated costs.
(4) Method of
Exercising Rights.To exercise these
rights, you must complete an application form, and we may ask you to provide
proof of identity.
(5) Consequences of
Incomplete Information If you cannot provide complete and
accurate personal information, it may affect our ability to contact you,
complete transactions, provide services, verify your identity, or address
complaints, transactions, or customer service issues.
If you wish to file a
complaint about how we handle your personal information, please first contact
us at [lixiaoning@topjoy.com]. We will do our best to address your request as
soon as possible. This does not affect your right to file a complaint with the
data protection authority in the region where you live or work.
6. GDPR Policy and Personal Data
Security
（1）Compliance with GDPR Regulations: We adhere to GDPR
regulations to ensure the protection of your personal data. We implement
appropriate security measures and utilize reasonable technology and processes
to maintain data security in compliance with relevant laws.
（2）International Data Transfers: If your personal data is transferred
from the UK or the European Economic Area (EEA) to other countries, we
guarantee that at least one of the following safeguards is implemented to
provide protection equivalent to the level in the UK or EEA (if applicable):
（3）Adequacy of Data Protection in Transfer Countries: The country to
which your personal data is transferred has been deemed by the European
Commission (or the UK government, if you are in the UK) to have adequate data
protection standards similar to those in the UK or EEA (if applicable).
（4）Contracts with Service Providers: When collaborating
with service providers, we sign specific contracts approved by the European
Commission (or the UK Information Commissioner’s Office if you are in the UK).
These contracts ensure that your personal data receives the same level of
protection as it would within the UK or EEA (if applicable).
（5）Your Rights Regarding Personal Data: You have specific
rights concerning your personal data, and you can exercise them as follows:
Access: You can email
the address provided at the end of this policy to request access to your
personal data held by us.
Correction or
Deletion: You can request the correction or deletion
of your personal data. The simplest way to update your account information is
by emailing the address at the end of this policy.
Request to Stop
Processing: You can request that we stop processing
your personal data, including for direct marketing purposes, personalized
rewards, promotions, and other offers. However, please note that in some cases,
we may still need to use your data to provide specific services.
Data Portability: You can request
to transfer your personal data to another organization (where technically
feasible).
Exceptions to these rights
may apply under certain legal circumstances. If your rights are restricted due
to such exceptions, we will explain the reasons.
We provide you with
choices regarding the collection, use, and sharing of your personal data, and
we respect your preferences. Please note that if you choose not to provide
certain personal data, this may affect our ability to provide you with all our
services.
After contacting us,
you may receive a verification email to confirm your request. We are committed
to providing the relevant information or fulfilling your request within the
shortest legal time frame applicable in your jurisdiction.
7. Child Protection
（1）No Intentional Data Collection from Children: We do not
intentionally collect data from children. Children are not allowed to use our
products or services. Guardians have the right to request the deletion of any
personal information that may have been collected from their child (if any). To
protect children's personal information, both children and their guardians should
carefully review the Product Privacy Protection Guidelines before
using our products. Only after obtaining the guardian's consent to these
guidelines can the child use our products.
（2）Guardian's Rights: Guardians have the right to review their
child's personal information (if any). We do not intentionally collect data
from children.
（3）Request for Data Deletion: Guardians have the right to request the
deletion of any personal information collected from their child (if any).
Please contact the Data Protection Officer's email provided on the last page or
through the customer service page within the product. We do not intentionally
use children's data.
（4）Right to Inquire and Access: Parents, guardians, or caretakers can
access the information collected from their child (if any) through the in-game
customer service settings interface.
（5）Right to Stop Data Collection: Guardians can request to stop the
collection and/or use of any personal information collected from their child
(if any) via the customer service settings page within the product.
（6）Restricted Disclosure of Children's Information: Generally, we
prohibit the disclosure of children's personal information. However, exceptions
apply in the following situations:
Compliance with applicable
laws and regulations.
Adherence to court
orders, judgments, or other legal processes.
Fulfillment of
requests from relevant government agencies or other legally authorized
organizations.
Where we have
reason to believe that complying with legal regulations is necessary.
（7）Prohibition of Public Disclosure: We strictly
prohibit the public disclosure of children's personal information (if any). We
do not intentionally collect children's data.
（8）Definition of "Children": We define "children"
according to the following age thresholds:
United States,
United Kingdom residents: Under 13 years old.
Residents of the
European Economic Area: Under 16 years old or under the age defined by local
laws for consent.
South Korean
residents: Under 14 years old.
Residents of other
regions: Under 13 years old or under the age defined by local laws for consent.
If you have any
questions regarding our child privacy practices, please reach out via the email
provided on the last page.
8.Rights under CCPA (California Consumer
Privacy Act)
If you are a
California resident and CCPA applies to you without any recognized exceptions,
you have the following rights:
Right to Know: You can request
the following information covering the previous 12 months at no cost:
The categories of
personal information we have collected about you.
The categories of
sources from which the personal information was collected.
The purposes for
which the personal information was collected.
The categories of
third parties with whom we share personal information, the specific personal
information categories shared, and the purpose of sharing.
Specific pieces of
personal information we have collected about you.
Right to Delete: You can request
that we delete the personal information we have collected from you, except
where CCPA recognizes specific exceptions.
Right to Correct: You can request
that we correct inaccurate personal information that we maintain about you.
Right to
Non-Discrimination: You are protected from discrimination for exercising
your CCPA rights. This includes not being subjected to different levels or
quality of services or being denied goods or services when exercising your CCPA
rights.
Our goal is to
complete all verified requests within 45 days as required by CCPA. If an
extension is necessary, we will provide an explanation for any delay.
Right to know whether your personal data is sold:
We do not sell your
personal information to third parties.
How to Exercise Your Rights
Manage Your Data: Log in to your account
to manage your data directly. If you are a California resident covered by CCPA,
you can also exercise your rights related to other data by contacting us. We
may need to verify your identity before complying with your request to protect
your privacy and security. If we cannot verify your identity, we may deny your
request.
Authorized Agents: Under CCPA, you
can designate an authorized agent to make requests on your behalf. To process
such a request, you must provide the agent with signed written permission. We
reserve the right to verify the agent’s identity and directly confirm your
authorization for the request.
Right to Opt-Out of
the Sale or Sharing of Personal Information: If you are a
California resident:
You have the right
at any time to direct businesses that sell or share your personal information
to stop doing so. This right is also known as the "right to opt-out"
of the sale or sharing of personal information.
Upon receiving
your notification, we will inform you whether your personal information can be
sold or shared, and you can opt out.
If we have actual
knowledge that you are under 16, we will not sell or share your personal
information without your (if you are between 13 and 16 years old) or your
parent’s/guardian’s (if you are under 13) explicit consent.
If we have
received your opt-out request, we are prohibited from selling or sharing your
personal information without your permission.
Rights under VCDPA (Virginia Consumer Data
Protection Act)
This section applies
to Virginia residents protected by VCDPA. If VCDPA applies to you and does not
recognize exceptions related to your data, you have the following rights:
Right to Access
Information: You can request that we disclose the
information we collect, use, or share and provide details about our data
practices.
Right to Delete: You can request
that we delete personal data collected from you unless specific legal
exceptions apply.
Right to Correct: You can request
that we correct inaccurate personal data we maintain about you.
Right to
Non-Discrimination: You cannot be discriminated against for
exercising your VCDPA rights, such as being denied goods or services or
subjected to different levels or quality of services.
We do not collect
sensitive personal data, nor do we process personal data for targeted
advertising, sales, or profiling decisions that have legal or similar effects
on consumers.
How to Exercise Your Rights under VCDPA
Manage Your Data: Log in to your
account to manage your data directly. If you are a Virginia resident covered by
VCDPA, you can exercise your rights related to other data by contacting us via
the email provided on the last page of this policy.
Appeals: If you want to
appeal a decision regarding your request to exercise your rights under VCDPA, please
contact us using the email provided at the end of this policy.
9. Updates to Privacy Policy
We reserve the right
to amend our Privacy Policy at any time. Any changes will be posted on our
website, and you are encouraged to review these changes to protect your
personal rights. Continued use of our website and associated services after any
modifications to the Privacy Policy constitutes your acceptance of the revised
terms. Significant changes will be communicated to you with reasonable notice.
It is your responsibility to ensure that we have your current, valid email
address and to periodically review our Privacy Policy for any updates.
The most recent
update to the Privacy Policy is indicated on the homepage.
10. Data Controller Information
The data controller
is:
TOPJOY GLOBAL LIMITED
6/F (No.101, 1-14/F), Building 3 Courtyard 8, Bei Chen West Road, Chao Yang
District, Beijing, PRC.
Contact email: lixiaoning@topjoy.com
11. Suggestions and Contact
For any questions or
concerns regarding our Privacy Policy or matters related to personal data
protection, please contact our Data Protection Officer (DPO) at:
DPO Contact
Information:
Email: lixiaoning@topjoy.com
Feel free to reach
out with any comments or inquiries you may have about our privacy practices.