AVGLIFE PTE. LTD. respects and protects users’ personal information. In this policy, "I", "we" and "our party" refer to AVGLIFE PTE. LTD.
We are committed to protecting and respecting the personal information of everyone we deal with, it's important to us, and we know it's also important to you.
Since your personal information is necessary for providing our products or services, if you do not agree with any content of this policy, we will not be able to provide you with services normally, then you should stop using our services immediately. If you agree to use our services, that means, you agree that we will collect, store, protect, use, provide and disclose your relevant information in accordance with this policy.
When this policy is updated, we will release the latest version in a timely manner. If you do not agree to this policy, we will not be able to continue to provide you with any services.
If you have any questions about this policy or related matters, you can contact us by our customer service contact information or the following email address: email@example.com.
1.What Information We May Collect
We will only collect the information necessary to realize product functions and services according to the principles of legality, legitimacy and necessity.
When we provide the following functions and services, we may collect the following related information from you.
If you do not provide relevant information, you may not be able to register as our user or enjoy some of the products or services we provide, or you may not be able to achieve the intended effect while using relevant services.
1.1User Registration Function
First, you need to register an account to become our user. When you register the account, you need to provide us with your account password, mobile phone number, and email address (optional, for email verification), and we will verify your account by sending a SMS verification code or an email to see if the identity is valid or not. For real-name authentication to meet the regulatory requirements of certain regions, we also require you to provide your relevant certificate number, name and other information.
You can also use our products and/or services by logging in the relevant accounts of a third-party platforms that we cooperate with. Then we may obtain your relevant information under the accounts, such as account name, account nickname, social relations on the third-party platform, etc., please read the special tips on the relevant login interface carefully when you log in.
1.2Product And/Or Service Information Display And Search Function
In order for you to find the products and/or services you need quickly, we may collect the information of your personal commonly used devices while using our products and/or services, such as the model of the hardware, MAC address of the device, device identification code of the operating system type (Such as apple ID/android ID/IDFA/OPENUDID/GUID/IDFV, etc.) etc. to provide you with the best way to display the products and/or service information. We will also use your above personal information in order to continuously improve and optimize the above functions.
After you place an order, you can choose the payment services provided by us or the third-party payment institutions that cooperate with us (such as PayPal and other payment channels, hereinafter referred to as "payment institutions"). The payment function itself won’t collect your personal information, but we need to share your order number and transaction amount information with these payment institutions so that they can confirm your payment instruction and complete the payment.
1.4Delivering Product and/or Service Function
When you place an order and complete the payment online, we or the third-party payment institutions that we cooperate with will complete the delivery of the order for you. You know and agree that we or the third-party payment institutions that we cooperate with will use your order information in the above-mentioned steps to ensure that the products and/or services you ordered can be delivered safely.
1.5Customer Service Function
When you use our online customer service and/or telephone customer service, in order to communicate with you in a timely and effective manner, our online customer service and telephone customer service functions will use your account information and order information.
To ensure the security of your account, our customer service center and online customer service will use your account information to verify your identity with you. When you need us to provide customer service and after-sales service related to your order information, we will query your order information. You may provide other information than the above information when you communicate with our customer service staff, such as: when you request us to change your contact number, contact email, etc..
1.6Relevant Information Required To Participate In Activities
Information you submit to our customer service or the information you submit when you participate in our offline activities and research. For example, the questionnaire you fill out when you participate in our research activities may include your name, phone number, work industry and other information.
Personal information you provide to us proactively after you participate in our sweepstakes and win the prize, which is convenient for us to contact you to send you gifts, such as address, name, telephone number.
The information about your location will be collected when you turn on the device location function and use our location-based services, including:
1.7.1 When you use some of our geographic location-related services through a mobile device with positioning function, your geographic location information will be collected through GPS or WiFi.
1.7.2 Real-time information containing your geographic location provided by you or other users, such as the location information contained in the account information you provide, the sharing information uploaded by you or others showing your current or previous geographic location, geotagged information contained in photos shared by you or others.
You can stop the collection of your geographic location information by turning off the location feature on your mobile device.
1.8To Improve Our Products And/Or Services
In addition to the above information, we may also collect other information from you as reasonably necessary to provide services and improve the quality of services, including relevant information provided when you contact our customer service team, and relevant information collected by us or our affiliates when you interact with us and our affiliates.
1.8.1 Ensure Transaction Security
In order to improve the security of your use of our services, and to prevent phishing website fraud and Trojan horse viruses more accurately, we may judge your account risks by checking your network usage habits, your commonly used software information and other means, and may log some links ("URLs") that we consider risky.
1.9Device Permission Call
In the process of providing products and/or services, we may require you to enable some device access rights, such as camera (camera), photo album (picture library), microphone, mobile phone address book and other access rights, in order to realize the information collection and use involved in these functions. You can also choose to turn off some or all of the permissions at any time in the device's settings, thereby refusing us to collect the corresponding personal information. In different devices, the display method and closing method of permissions may be different. For details, please refer to the instructions or guidelines of the device and system developers. Please note that if you turn on these permissions, it means that you authorize us to collect and use these personal information to achieve the above functions. If you turn off these permissions, it means that you cancel these authorizations, and we will no longer continue to collect and use your personal information, nor can we provide you with the above-mentioned functions corresponding to these authorizations. Your decision to turn off the permissions will not affect the processing of your personal information previously based on your authorization.
1.10Third-party Account ID
We may collect your third-party account IDs such as your ID of Facebook, Xbox, Game Center, VK, WeChat, Google, Steam or PSN, so that you can use these accounts to log in to your game account or use certain Third-party features (such as achievement unlocks, etc.).
1.11Your Game User Account/Role ID
We may collect the specific ID/UID generated for you by our game server, your avatar, player introduction text, and other information required for the operation of the game. In order to facilitate us to identify your player identity and character information, and provide you with related services. We may also use this to combat malicious and fraudulent data (such as false refund/collection information, fraudulent information, advertising information edited by individual players in the game) to create a better game experience environment for you. In addition, some of our services may require you to provide certain personal sensitive information to achieve certain functions. If you choose not to provide such information, you may not be able to use certain functions in the service normally, but it will not affect your use of other functions in the service. If you voluntarily provide your personal sensitive information, that means you agree that we will process your personal sensitive information in accordance with the purposes and methods described in this policy.
2.Personal Information You Shared
2.1Our products and/or services allow you to publicly share your relevant information not only with your own social network, but also with other users who use our products and/or services, for example, information you uploaded or posted in our products and/or services (including your publicly available personal information), your responses to the information uploaded or posted by others, and the location data and log information related to such information. Other users of our products and/or services may also share information related to you (including location data and log information).
2.2Some personal information may be considered as personal sensitive information due to its particularity, such as your race, religion, personal physical health and medical information, etc.. Please note that the content and information (such as photos and other information about your social activities) that you voluntarily provide, upload or post when using our products and/or services may reveal your sensitive personal information. You need to carefully consider whether to voluntarily disclose relevant personal sensitive information when using our products and/or services. If you voluntarily disclose your personal sensitive information, that means you agree that we will process your personal sensitive information in accordance with the purposes and methods described in this policy.
2.3You can delete the information you share publicly through the settings in the service or the guidelines we provide. However, please note that this information may still be independently cached, copied or stored by other users or unaffiliated third parties not controlled by us, or stored in the public domain by other users or such third parties.
2.4We may also use the collected personal profiles, logs, chat data and other information you edited to resist malicious fraudulent data and related malicious behaviors (such as false refund/payment information, scam information, advertising information edited by any individual players in the game) in our products, in order to create a better gaming experience environment for you.
3.How To Collect And Store Your Personal Information
We collect this information in various ways depending on how we interact with you. For example, you may provide us with your identity, contact details or other information by filling out an online form, or by communicating with us by post, telephone, email or other means, or some other action within the application.
You may provide us with your personal data in the following situations:
When you are,
3.1Using our products or services
3.2Creating a game account in our game or on our website
3.3Interacting with our customer service or related staff
3.4Choosing to subscribe to our email notification service
3.5Participating in contests, promotions or surveys
3.6Actively giving us feedback
3.7Associating a third-party ID
3.8Clicking or viewing advertisements within the app
3.9Actively entering information and saving it successfully in other text boxes in the application (such as the text box of the personal introduction interface, etc.)
We will only retain your personal information for the shortest period necessary to achieve the purposes described in this policy or required by national laws and regulations. When we, as a personal information processor, stop a certain product and/or service or you exercise the account cancellation right comply with the provisions of Article 7 of this policy, the data (including behavioral data, role data, etc.) in the product and/or service will be deleted or anonymized. After the storage period has expired, we will delete or anonymize your personal information, but except for where your personal information is retained in some national laws, regulations, regulations, normative documents or government policies and orders, etc. as otherwise required or to meet our compliance obligations.
We may use your anonymized personal data for research or statistical purposes (so that you are no longer directly associated with it, to further protect your personal privacy), in which case we may use it indefinitely without further notice to you.
In principle, the personal information we collect and generate within the territory of the People's Republic of China will be stored within the territory of the People's Republic of China, except for the following circumstances:
a)Clearly stipulated by laws and regulations, government regulations, departmental regulations or administrative and judicial orders;
b)Obtained your express authorization.
In response to the above situations, we will ensure that your personal information is protected in accordance with laws and regulations and this policy.
4.How To Use Your Personal Information
4.1We may use the information collected in the process of providing products and/or services to you for the following purposes:
4.1.1To provide you with our services;
4.1.2To help us design new products and/or services and improve our existing products or services;
4.1.3When we provide services, it will be used for identity verification, parental supervision, customer service, security prevention, fraud monitoring, archiving and backup to ensure the security of the products and services we provide to you;
4.1.4To send you service status notifications and other information in order to make you aware of your use of the service or understand our related services;
4.1.5To let us better understand how you access and use our products and/or services, so as to respond to your personalized needs, such as language settings, location settings, personalized help services and instructions;
4.1.6To provide you with advertisements about our products and/or services;
4.1.7To evaluate the effectiveness of advertising and other promotions and promotional activities in our products and/or services and to improve them;
4.1.8To allow you to participate in surveys about our products and/or services, or promotions and promotions;
4.1.9To do software certification or management software upgrade;
4.1.10To prevent or prohibit illegal activities;
4.1.11Other uses with your consent.
4.2On the premise of not disclosing the private information of an individual user, we may conduct an overall analysis and utilization of the user database. We will take necessary security measures for relevant information following laws and regulations and the principles of legality, legitimacy and necessity, such as de-identification or anonymization of data through technical means.
5.How To Provide And Disclose Your Personal Information
We strictly limit the provision of information in accordance with laws and regulations. We will not share your personal information with any third party except in the following circumstances:
5.1.1To obtain your consent or authorization (including the authorization of the user or the user's guardian);
5.1.2To provide your personal information upon the legally request of your guardian (if you are a minor);
5.1.4With the continuous development of our business, we may need to transfer your personal information due to merger, division, dissolution, bankruptcy, etc. We will inform you of the relevant situation and the recipient's name or contact information through notices, announcements, etc., and require the recipient to continue to perform obligations in accordance with laws and regulations and standards not lower than those required by this policy, otherwise we will require the recipient to ask for your authorization again.
If we provide your information to the above-mentioned third parties, in addition to providing complete personal information for processing purposes, we will use encryption, de-identification and other means to ensure the security of your information.
We will only provide your personal information to the above third parties for legitimate, justified and necessary purposes, and will only provide personal information necessary for related products and/or services. We will endeavour to ensure that such third parties use your personal information in compliance with this Policy and other appropriate confidentiality and security measures that we require them to comply with, and expressly require such third parties to only use the shared personal information with the specific uses related to our products and/or services.
If you want to change the purpose of processing personal information, these third parties will seek your authorization and consent again.
We may disclose your personal information to the public in accordance with the provisions of laws and regulations, the need for litigation and dispute resolution, or as required by administrative and judicial authorities, or to safeguard social and public interests, or to protect the personal lives or property safety of our customers, us or our affiliates, or other purposes reasonably necessary for legitimate interests.
6.How To Protect Your Personal Information
6.1In order to ensure the security of your personal information, we will strive to take reasonable and necessary physical, technical and administrative security measures to protect your information under the existing technical level, so as to prevent your information from being lost, misused, unauthorized access, disclosure and alteration, including but not limited to encrypted storage of information, access control in data centers, dedicated network channels and proxies. In addition, out of consideration for your information security, we do not recommend that you share your account and password with other users.
6.2We establish a special management system, process, organization and take corresponding measures to ensure information security. For example, we strictly manage employees or outsourced personnel who may have access to your information, including but not limited to adopting different permission controls according to different positions, signing non-disclosure agreements with them, and monitoring their operations, organizing data security or compliance training for them, etc.
6.3If we confirm that a security incident such as personal information leakage occurs, we will activate an emergency plan to prevent the expansion of the security incident, and notify you in the form of pop-up notifications, announcements, etc. At the same time, we will also report the handling of personal information security incidents in accordance with the requirements of regulatory authorities.
7.How To Manage Your Personal Information By Yourself
7.1You can log in to your account to view or modify your account settings and personal information at any time. If you want to change or update your personal information retained in our system, you can log in to your account, operate it under your account information, or contact us via our official customer service to make changes.
7.2If you find that we collect and use your personal information in violation of laws, administrative regulations or the agreement of both parties, you can ask us to delete it. If you find that your personal information collected and stored by us is inaccurate, you can also ask us to correct it. Please contact us via our official customer service.
7.3You can also contact us via our official customer service to request to cancel your account. After you voluntarily cancel your account, we will stop providing you with products or services, and your personal information will remain in a state that cannot be retrieved, accessed or anonymized, unless otherwise stipulated by laws, regulations, administrative regulations, and government regulatory documents .
7.4We hereby remind you that you should choose to cancel your account carefully, because canceling your account will affect your normal use of the service or bring a lot of inconvenience to your subsequent use. Once your account is canceled, it will not be restored. Please back up your all information and data related to the account before doing any operation. We are not responsible for any adverse impact caused by your application for cancellation of your account.
If you log in quickly via a third-party account, you will need to contact the third party to cancel the account.
7.5When you access, update, correct or delete the aforementioned information, we may require you to perform identity verification to ensure account security. We may also prompt you that certain conditions must be met to cancel your account. Although we will not set unreasonable conditions to prevent you from canceling your account, if canceling your account will affect the legitimate rights and interests of you or others, such as if you have any recharged unused virtual currency, etc., we will combine your use of the service to determine and inform whether your logout request is supported.
7.6Please understand that due to technical limitations, legal or regulatory requirements, we may not be able to meet all your requirements, and we will reply to your request within 30 days after verifying your identity.
7.7We usually provide access, update, correction, deletion services for free, but reserve the right to charge a reasonable fee for your data access requests.
If you are an EU user, you have the following rights with respect to your personal data under EU data protection law. We respect these rights and will help you exercise them within our power.
You have the right to:
Request access to or copy any personal data information we hold about you;
If you believe that the information we hold is inaccurate, you can make a request to us to assist you in correcting the inaccurate information in your personal data;
If you believe that we do not have the right to hold the information, you may request us to clear them;
Withdraw the consent to our processing of your personal data (provided that we have obtained consent from you before);
Ask us to stop or start sending you marketing communications;
Restrict our processing of your personal data information;
Data portability in certain circumstances (moving some of your personal data elsewhere);
Object to the processing of your personal privacy information in certain circumstances
Analysis based on your personal data without the influence of the results of automatic processing of the program, as well as taking safeguards
If you are a user in the EU, please also note that these rights are not absolute, in some cases they do not apply to you. With exceptions (for example, if we have to comply with our legal obligations to process certain data), upon your request, we will let you know via email or an in-app notification that your request cannot be fulfilled for some reason. Where your relevant request must be in writing, we will endeavour to respond within a reasonable period of time within one month. We will comply with our legal obligations regarding your rights as a data subject.
If you have an unresolved privacy or data usage issue that we have not resolved satisfactorily, please contact us at firstname.lastname@example.org or other valid contact details, you may also try to contact your local data protection authority in the European Economic Area to get help.
8.1We may use your relevant information to provide you with more relevant advertisements on relevant websites, apps or other channels.
8.2We may also use your information to send you marketing communications via our products and/or services, email or otherwise, to offer or promote our products and/or services, the products of our affiliates and partners and / or service.
8.3If you do not want us to use your personal information for the above-mentioned advertising purposes, you can ask us to stop using your personal information for the above-mentioned purposes through the relevant prompts we provide in advertisements or the guidelines provided in specific products and/or services. In some cases, if you choose not to allow the use of your personal information in accordance with article 8.1, you may still see our advertisements, but we will not be able to use your personal information to serve you more relevant advertisements.
9.Information We May Send To You
When you use our products and/or services, we may send emails, text messages, WeChat or pop-up notifications to your device. If you do not wish to receive this information, you can follow our relevant prompts, choose to unsubscribe on your device, or ask us to stop using your personal information for the above purposes.
9.2Announcements Related To Products And/Or Services
We may issue service-related announcements to you when necessary (for example, when a service is suspended due to system maintenance). You may not be able to cancel these service-related announcements that are not advertising in nature.
10.Protection Of Minors
We attach great importance to the protection of minors' personal information. Our websites and apps do not knowingly collect data about children under the age of 13.
For applications that are not aimed at children but may appeal to them, we may limit some of the services available to players based on their age.
We encourage parents or guardians to instruct minors in the use of our products and/or services. We recommend that minors shall encourage their parents or guardians to read this policy and advise minors to seek parental or guardian consent and guidance before submitting personal information.
If you are a minor, please submit your personal information and use our services with the consent of your parents or guardians.
If you are the parent or guardian of a minor, when you have questions about the personal information and related information of the minor under your guardianship, please contact us via our official customer service.
11.Applicable Scope Of This Policy
11.2.1Information collected by third-party services (including any third-party websites and applications) accessed through our products and/or services. This Policy applies only to the information we collect, and does not apply to the services provided by any third party or the rules of use of the third party's information, and we are not responsible for the collection and use of your personal information by these third parties;
11.2.2Information collected by other companies or agencies that advertise on our services
Please note: if you provide your personal information to a third party when you browse a third-party website or use a third-party's products and/or services, your information shall be subject to the third-party's privacy statement or similar policy, and you need to read the content of its policy carefully. We are not legally responsible for any third party's improper use or disclosure of the information provided by you, regardless of whether you log in or browse the above-mentioned websites, software, or use their products and/or services based on our links or guidance.
Some of our products may contain certain social features. For example, other players and users may see your profile data, in-game activity status, read information you've posted, and more.
13.International Data Transfers
Our services are global in nature, so your data can be transferred anywhere in the world. As different countries may have different data protection laws compared to your own country, we will take steps to ensure that there are appropriate safeguards in place to protect your data, as explained in this policy. Our relevant group entities and partners will use adequate safeguards.
14.Links To Other Websites
Our website or app may contain links to other websites, including the link buttons/URLs to our social media. While we meant to only link to sites that share the same high standards and respect for privacy as ours, we are not responsible for the content, security or privacy practices used by other sites. Once you link to another website from our website, you are bound by the terms and policies of the owner of that website/app, including but not limited to their internet privacy policies and practices. Please review these policies and read them carefully before you submit any data to these sites.
15.Changes To This Document
We may revise this document to a certain extent in the future and update or publish the revised document. We welcome you to consult this document at any time.
Effective Date Of This Version: February 1, 2022