Privacy Policy
UPDATE DATE：August 16, 2025
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.