微暢有限公司(以下簡稱「微暢」或「我們」)非常重視您的隱私權，在此載明我們如何蒐集、處理及利用您的個人資料。當您完成註冊、使用本公司會員服務時，即視為您已閱讀、瞭解並同意接受本公司隱私權政策（「本政策」）。如您不同意本政策的全部或任何一部份，請您立即停止使用本服務。如您為未成年人，確認您的法定代理人已全部瞭解並同意本政策之內容後，再繼續使用本服務。於您使用本服務時，就本合約約定之內容，即視為已取得法定代理人之允許或同意。
請您詳細閱讀以下有關隱私權保護政策的更多內容。
微暢所蒐集的資訊及如何處理利用
在您註冊及/或進行微暢旗下手機遊戲後，微暢將會蒐集您於進行遊戲各項行為，包括但不限於您註冊帳號時提供的個人資料（如電子郵件、性別、電話）、帳號名稱、遊戲操作行為、每次登入遊戲或消費時的裝置資料（包括裝置唯一識別碼和廣告識別碼、系統語言、型號、系統版本號、是否root或越獄、解析度）、消費行為（包括消費時間與品項、支付數據如訂單編號、支付時網路IP位址）、Google/Apple/Facebook授權資訊、登入狀態，及其他為提供您會員服務及/或遊戲遊玩服務所必須蒐集的各種相關資料，利用於提供會員服務及/或遊玩遊戲之目的，包括提供您遊戲相關訊息、相關產品或服務的行銷資訊等。此外，為提供您更好的服務，可能針對全體使用者的人數、偏好和行為進行內部研究；此研究是根據全體使用者行為總和進行分析，並不會對個別使用者進行分析。
若您瀏覽微暢網頁或某些合作夥伴（以下稱「第三方」）的網頁以及參加某些宣傳活動或贈獎遊戲時，微暢會蒐集您所輸入的個人資料，包含但不限於您註冊會員服務所提供之資料。這些資料可能將會使用在寄送活動贈品或是通知中獎使用，或您在使用微暢相關會員服務時，微暢會詢問包括您的姓名、地址、出生日期、身分證號、聯絡電話等資料，以方便微暢辨別您的身分，為您提供更為精準及有效的服務內容。您應瞭解並注意，第三方可能於此類活動中與微暢共同或獨立蒐集您的個人資料，於此種情形，您與第三方間的法律關係，將不屬於本政策的規範範圍，您應自行確認第三方的隱私權政策內容，微暢亦無法保證第三方關於隱私保護的完整性及合法性。
除依本政策、您的明確同意，以及下列情形外，微暢不會將資料提供給第三人、或超出本政策之特定目的必要範圍使用：
1.受司法、警察或其他有權機關基於之要求時。
2.於維護公益或保護微暢或他人權益時。
3.因會員之行為違反法令或您與微暢間的契約規定時
4.在緊急情況下為維護其他會員或第三人之人身、交易內容、遊戲歷程、個人資料之完整安全時。
5.或其他為提供您遊戲服務之必要而提供予微暢之合作夥伴。但此合作夥伴不得就所取得之資料做超出合約範圍外之用途。
6.其他合法途徑。
資料安全
微暢盡力以符合當時科技的合理之技術及程序，保障所有個人資料之安全。
其他相關注意事項
請妥善保管您的密碼及或任何個人資料，不要將任何個人資料，尤其是密碼提供給任何人。在您欲離開電腦前或不再使用微暢的服務時，務必記得登出帳號，若您是與他人共享電腦或使用公共電腦，切記要關閉瀏覽器視窗，以防止他人讀取您的個人資料或信件。
您自願在線上透露的各種個人資料，如在討論區、聊天室等處公佈您的個人資料如電子郵件以及生日等，該資料均可能會被他人蒐集和使用。如果您於線上公佈可被他人讀取的個人資料時，您可能會收到其它團體主動提供的郵件。基本上，您的密碼或任何會員帳戶資料的保密性必須由您單獨負責，請小心並保管您的會員資料。
隱私權保護政策修訂
微暢保有依實際況狀修改修訂本政策之權利，當我們有任何重大變更時將會於我們的網站上公佈，或以微暢認為適當的方法對您通知，煩請定期查閱，如您不能接受變更後內容的全部或一部，請您立即停止使用本服務，並通知我們終止本合約。
This privacy policy informs you of your choices and our practices regarding any personal data you provide to us. Your use of the mobile game (“Game”) distributed by 【Playbest. Ltd.】 ( “we”,“us”or “our”) involves the collection and use of your personal data. It is important for you to understand how this happens and how you may control it.
When you contract to use the Game (the “Game Services” or “Services”), you accept our rules and policies regarding your personal data and you expressly consent to us collecting, processing, using and storing your personal data, as described in this policy.
You acknowledge that you have read and understood this privacy policy. If you do not agree with this privacy policy, you must not use the Game Services. If you change your mind in the future, you may withdraw your consent to use of your personal data in accordance with this policy.
1. The Types of Personal data We Collect and Use
This section describes the different types of personal data we collect and how we collect it.
We will collect and use the following data about you:
1.1 data you give us. You give us data about you:
1.1.1 When you register for the Game (including your nominated nickname, and information we import from your connected social media account,e.g. Facebook, Twitter or Apple sign-in account) in order to set up your profile, including your name as it appears on your social media profile and your profile picture;
1.1.2 When you set up your profile for the Game (including information you voluntarily elect to provide in order to customize gameplay, such as gender);
1.1.3 When you submit your contact details to us (including your name, email address and physical address) as part of promotional activities for the Game; and
1.1.4 When you make purchases in the Game (in which case we will process the information you provide to us to facilitate the payment);
1.1.5 When you want to see the regional leaderboards (in this case, we will use your geo-location information);
1.1.6 When you want to use features such as voice chat interaction (including microphone permissions on your mobile device).
1.2 Data we collect about you.
We automatically collect certain data from you when you use the Game，including your IP address, physical location and device information (such as device type, network data, OS) and information regarding your use of the Game, such as date and time stamps of actions. We also collect and store your data each time you interact with us, for example, when you use in-app support to communicate with us.
1.3 Data you generate and display in the course of using the Game Services.
You may provide additional information as part of your profile (such as gender). You may also provide or generate information when you communicate with other users in the Game (e.g., chat log data, chat content).
2. Cookies
2.1 We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Services. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.
2.2 You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies, or instruct the device (in the case of the Game) or web browser (in the case of the Community Website) to provide notice at the time of installation of cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event of your refusal to install cookies, the Game may be unable to operate as designed.
3. External Websites
Our services may contains links to external websites. We make no representations as to the quality, suitability, functionality or legality of the material on external websites that are linked to, or to any goods and services available from, such websites. The material is only provided for your interest and convenience. We do not monitor or investigate such external websites and we accept no responsibility or liability for any loss arising from the content or accuracy of the material and any opinion expressed in the material should not be taken as our endorsement, recommendation or opinion. This Policy does not extend to your use of such external websites. You are advised to read the privacy policy or statement of such external websites before using them.
4. How We Use Your Personal data
We will use the data in the following ways and in accordance with the following legal bases:
4.1 Registration Information (ID on social media accounts like Facebook, Twitter, Game Center, Google Play, Apple (collectively, “Social ID”), Open ID, nick name, email address, avatar): We use Registration Information to set-up your accounts, allow you to log-in to the Game and provide Services to you. We use this information with your consent to this Privacy Policy.
4.2 Device Information (Device ID, Device Type, Operating System, CPU, RAM, IP address, MAC address): We use this information to provide and improve the Game Services such as: to allow you to download and install the Game on their devices; to record and keep track of requests from you of the Game; to detect your network and device status when you is playing the Game; and to correct bugs or errors that occur when you are playing the Game. Use of Device Information is necessary to provide the Game.
4.3 Contact Information (Name, Email, Address, Phone Number, and Instant Messaging Account): We use this information to send notifications to you to inform you of our promotional activities and any rewards you are entitled to. We use this information with your consent to this Privacy Policy.
4.4 Physical Location: We use this information to provide some Location Based Services such as forming a team with people nearby and seeing regional leaderboards. We use this information with your consent to this Privacy Policy.
4.5 Social ID: We use this information to share certain content on social media. We use this information with your consent to this Privacy Policy.
4.6 User Profile (gender, age, photo and etc.): We use this information to provide customized Services to you such as personal data page. We use this information with your consent to this Privacy Policy.
4.7 Game Data (Level, Heroes, Score, chat log and etc.): We use this information to provide Services to you as it is the basis of our Game. Use of Game Data is necessary to provide the Game.
5. How We Store Your Personal data
5.1 Data storage mode
We will store your data in a secure way, including local storage (such as game caching), databases, and server logs.
5.2 Where data is stored
We store your personal data collected on our servers in Singapore.
5.3 Duration of data storage
In general, we store your personal data only for such period of time as may be necessary for the purpose of the service or under such conditions as may be required by laws and regulations. We promise that your personal data will always be stored for a reasonable and necessary period of time. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
6. How do we share, transfer and disclose your personal data
6.1 Share with trusted authorized partners.
6.1.1 Authorized partners of advertising and analysis Services. We will not share your personally identifiable data (such as your name or email address, through which you can be contacted or identified) with partners providing advertising and analytics Services unless we have your consent. We provide these partners with data about the coverage and effectiveness of their ads without providing personally identifiable data about you, or we aggregate that data so that it does not identify you personally.
6.1.2 Suppliers, service providers, and other partners. We send the data to support our business in the global scope of the suppliers, service providers and other partners, including but not limited to provide these data supporting technology infrastructure Services, analysis of the use of our service, to measure the effectiveness of advertisement and Services, to provide convenient customer service, payment or academic research and investigation.
6.2 We will not transfer your personal data to any company, organization or individual without your express consent.
In addition, in the event of a merger, acquisition or liquidation, the transfer of personal data may be involved, in which case we will require the new company or organization holding your personal data to continue to be bound by this privacy policy, otherwise we will require the company or organization to seek your authorization again.
6.3 Public disclosure
We will not publicly disclose your personal data unless we obtain your express consent. In addition, we may disclose your personal data to competent authorities on the basis of laws, legal procedures, lawsuits or mandatory requirements of government authorities. However, we guarantee that in the event of such occurrence, we will verify the authenticity of the disclosure requester and the disclosure request, and if necessary, require the disclosure requester to issue corresponding valid legal documents and take security measures in accordance with legal and industry standards for the disclosed data.
7. The Security of Your Personal data
7.2 Unfortunately, the transmission of data via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of the data transmitted to our Services; any transmission of your data is at your own risk.
Please use complex password to help us ensure the security of your Game account. We will do our best to ensure the security of your personal data that you send to us. If our physical, technical or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering or destruction of data, resulting in damage to your legitimate rights and interests, we will take appropriate remedial measures.
We will update and make public security risk, personal data security impact assessment report and other relevant contents from time to time, which can be obtained by 【www.romancesamkok.com】.
In the event of an unfortunate personal data security incident, we will inform you according to the requirements of laws and regulations: the basic situation and possible impact of the security incident, the measures we have ta-ken or will take to deal with it, the Suggestions you can take to prevent and reduce risks, the remedial measures for you, etc. We will inform you of relevant information by email, letter, phone call, push notification, etc. When it is difficult to inform the subject of personal data one by one, we will take a reasonable and effective way to release an announcement.
8. Data Transfers, Storage, and Processing Globally
We generally do not transfer your personal data to countries outside of Hong Kong where the personal data is stored. However, if we do so, we will take reasonable steps to safeguard the privacy of your personal data. These steps may include implementing standard contractual clauses where recognized by law, obtaining your consent, or other lawful means of transferring personal data.
9. Accuracy of Personal Data
We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
10. Your Rights
10.1 Opt-out of marketing emails and other direct marketing.
You may opt-out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications.
10.2 Opt-out of targeted advertising.
You can opt-out of interest-based advertising on mobile applications. For personalized in-game offers opt-out, you can use the options provided in the game settings.
10.3 inquire, correct and supplement your information
You have the right to inquire, correct or supplement your information. You can do this by yourself in the following ways: csdh@playbest.net.
10.4 Delete your information
You may delete part of your information in the way listed in “7.3 query, correct and supplement your information”.
You may request removal of personal data from us in the following situations:
10.4.1. If our handling of personal data violates laws and regulation;
10.4.2. If we collect and use your personal data without your express consent;
10.4.3. If our handling of personal data seriously violates our agreement with you;
10.4.4. If you no longer use our products or Services, or you take the initiative to cancel your account;
If we decide to respond to your removal request, we will also notify, as far as possible, the subjects who received your personal data from us and request that it be removed in a timely manner (unless otherwise provided by laws and regulations or if such subjects have independently obtained your authorization).
When you or we assist you in removing the information, we may not be able to immediately remove the information from the backup system due to applicable laws and security techniques, and we will securely store your personal data and isolate it from any further processing until the backup can be erased or anonymous.
10.5 Change the scope of your authorization
Each business function requires some basic personal data to complete. In addition, you can give or take back your authorization consent by setting or contacting customer service in【csdh@playbest.net】or changing the Settings of your smart mobile device.
When you withdraw your consent, we will no longer process the appropriate personal data. However, your decision to withdraw your consent will not affect the processing of personal data previously carried out on the basis of your authorization.
10.6 Cancel your account
You can apply for cancellation of your account by the following means: 【csdh@playbest.net】. After you voluntarily cancel your account, we will stop providing Services for you, delete your personal data as required by applicable law, or make it anonymous.
10.7 In response to your request
For the above to security, you may need to provide a written request, or otherwise we may ask you to prove your identity to verify their identity, and then we will process your request within 15 days to respond, if you are not satisfied, you can also lodge a complaint by 【csdh@playbest.net】.
We do not charge a fee for your reasonable request in principle, but we will charge a fee for requests that are repeated more than once and beyond reasonable limits. We may reject information that is not directly related to your identity, unwarranted duplication of information, or requests that require too much technology (for example, the need to develop a new system or radically change existing practices), that pose a risk to the legitimate interests of others, or that are unrealistic.
10.8 Under the following circumstances, we will not be able to respond to your request as required by laws and regulations:
(a) National security;
(b) Defence;
(c) Public safety;
(d) Prevention of criminal offences, investigation, investigation, prosecution or enforcement of criminal penalties, including prevention and prevention of threats to public security;
(e) Other important objectives of the general public interest of the union or of a member state, in particular the important economic or financial interests of the union or member state, including matters of currency, budget and taxation, public health and social security;
(f) Independence of the judiciary and protection of judicial procedures;
(g) Prevention, investigation, investigation and prosecution of breaches of professional ethics;
(h) Supervisory, inspection or related regulatory functions and even the occasional exercise of official authority in cases involving subparagraphs (a) (b) (c) (d) (e) (f) and (g).
(I) Protection of the rights and freedoms of the data subject or other person.
(j) Enforcement of compensation in civil proceedings.
11. Children's privacy
If you are children(a minor and under the age of 13), you are not allowed to use our Services , and we do not knowingly collect personal data from children in connection with our Services.
12. Data Protection Officer
You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Contact No.: +8618916310814
Email Address: qiyusgp@gmail.com
Address: 18 HOWARD ROAD #06-01 NOVELTY BIZCENTRE SINGAPORE(369585)
13. Changes
If we make any material changes to this policy, we will post the updated policy here and notify you. Please check this page frequently to see any updates or changes to this policy. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
14. Other