COLOCESS GAMES HK LIMITED Privacy Policy

Introduction

If you use the version of COLOCESS GAMES HK LIMITED ("COLOCESS GAMES") application that is not distributed in specific countries/regions such as mainland China, Japan, and South Korea, you acknowledge that you have read and understood this Privacy Policy. If you do not agree to this Privacy Policy ("this Policy"), you may not use the COLOCESS GAMES Terms of Service. If you change your mind in the future, you may withdraw your consent to the use of your personal information in accordance with this Policy. You agree that if you are under 18 years of age or the legal age of majority to obtain the service, you represent that your legal guardian has read, understood, and agreed to this Policy.

At COLOCESS GAMES, we know your privacy is important to you, so please take the time to carefully read our Privacy Policy. Our policy is designed to help you understand:

1. What information we collect about you;

2. How we will use information about you;

3. Who we share your information with;

4. How long we hold your information;

5. How to exercise your rights;

6. Dispute resolution;

7. How we will notify you of changes;

8. Contact information;

This Privacy Policy is an integral part of the COLOCESS GAMES Terms of Service provided by Chengdu COLOCESS GAMES Digital Entertainment Co., Ltd. This Policy applies to all COLOCESS GAMES Terms of Service that directly reference or link to this Policy, but does not apply to COLOCESS GAMES Terms of Service that have a separate Privacy Policy that does not include this Policy.

Section 1: Data Collection

1. Types of personal information we use

This section describes the different types of personal information we collect and how we collect it. During your use of COLOCESS GAMES games and services, we generally collect and use your personal information in the following scenarios:

1. Account registration and identity verification:

1.1 When you register and log in to a COLOCESS GAMES user account or use COLOCESS GAMES game products and services, you need to complete a series of registration procedures under our guidance. During this process, you need to provide us with the following information: account nickname, user avatar, phone number, and email address. Collecting the above information is used to mark and identify you as a COLOCESS GAMES user and save your login information. The above information is essential information for you to register and log in to the COLOCESS GAMES user account or use the core business of COLOCESS GAMES game products and services. If you choose not to provide it, you may not be able to use COLOCESS GAMES game products and services.

1.2 Some of our game products and services allow you to log in with accounts from third-party platforms (FaceBook accounts). If you log in using a third-party platform account, we will obtain relevant information under such third-party account with your authorization (including the third-party account ID, username, nickname, avatar, and other information you authorize, subject to what is displayed on the authorization page of the relevant third-party account). The aforementioned information is collected to provide you with account login services, protect the security of your account, and guard against security risks. If you refuse to authorize such information, you will not be able to log in to our platform via third-party platform accounts, yet this will not affect the normal use of other products and services we provide.

1.3 In accordance with laws, regulations, policies and requirements of relevant regulatory authorities, you need to register with your real name to use COLOCESS GAMES games and services. We will collect your personal identity information (including name, ID card number) with your consent or when you voluntarily provide it. If you use a third-party account to link to and log in to COLOCESS GAMES services, after your authorization, we may obtain your personal identity information (including name, ID card number) from that third party. Collecting the above information is used to complete real-name verification. The real-name identity information you provide will be compared with the authoritative data platform data source. If the comparison information is consistent, the verification is successful. The above information belongs to personal sensitive information. Refusing to provide the above information may result in your inability to log in to COLOCESS GAMES games and services.To meet the requirements of verifying the authenticity of user identity, we may need you to provide true identity information (including name, ID card number) to complete identity verification. If you do not provide the above information, we will not be able to provide you with relevant functions and services.

Please note that your identity information and other information belongs to personal sensitive information. Please provide it with caution. If you refuse to provide it, you may not be able to obtain relevant services, but it will not affect the normal use of other functions and services.

2. We will collect and use the following information about you:

2.1 Information you provide to us.

a) When you register for the game (including your specified nickname, or custom accounts and information we import from your connected social media accounts to set up your profile);

b) When you log in as a "guest" to use the game (your nickname);

c) When you participate in surveys in the game (in this case, we will process the information you provide as part of the survey);

d) When you conduct transactions through our services (where applicable) or with third-party payment service providers authorized by us;

e) When you link your account to your social media account or other external accounts or use other social media features according to the provider's policy;

f) When you use our services or interact with other users and us through our services. This includes but is not limited to cookies that may be generated when you interact with us.

2.2 Information we collect about you.

a) Name;

b) Generated username and ID;

c) Address, email address, phone number ("contact information");

d) Transaction information;

e) Age, gender, date of birth;

f) Photos;

g) Usage data and transaction data;

h) Location-related information, including geographic location and IP address;

i) Survey content and responses;

j) Advertising ID;

k) Customer support ticket IDs and your communications with support;

l) Game statistics (levels, scores);

m) Device information (such as application version, network type, operating system);

n) Marketing and communication data, such as your preferences for receiving marketing materials, your communication preferences, and your communication history with us;

o) Chat data;

p) Security-related information.

2.3 Data we collect from partners.

a) If you link third-party tools and services, we will receive data. If you use your social media account to register as a user of our service and link your account to your social media account, we may access information you voluntarily provide to that provider according to the social media account provider's policy. We will manage and use this personal data according to this policy;

b) Demographic data (such as determining rough location from IP address);

c) Anti-fraud data (such as abuse of refunds in games or click fraud in advertisements);

d) Data from game operation platforms (such as verifying payment);

e) Data for advertising and analysis purposes, so we can provide you with better services.

2.4 Cookies and similar technologies.

To improve related services, COLOCESS GAMES may use Cookies and similar technologies to store and track relevant user data at certain times. Such use is limited to: estimating traffic volume, counting user preferences for commercial, market analysis or academic purposes. Cookies and similar technologies may be used by third parties, for example, advertising services need identifiable data and information as evaluation metrics and evidence, making this information available only for analysis to evaluate the effectiveness of promotion and marketing activities and improve them.

3. How we use your personal information

3.1 We will use this information in the following ways:

3.1.1 Create your account for the game at your request;

3.1.2 Generate username and open ID: store your game data (including levels and progress) together with your profile;

3.1.3 Contact or communicate with you by phone, SMS, fax, email or other means to manage your relationship with us or your use of our services;

3.1.4 Save your transaction history records;

3.1.5 Manage, operate, provide and manage your use of and access to our services (including but not limited to your preferences), as well as your relationship with us and your account;

3.1.6 For identification and verification (if applicable);

3.1.7 Conduct research, analysis and development activities (including but not limited to data analysis, surveys, product and service development and analysis), analyze how you use our services, improve our services or products and enhance your customer experience;

3.1.8 If you enable chat services (audio or text), we will process this data to deliver your messages to other users;

3.1.9 For security and verification purposes; identify and resolve vulnerabilities, evaluate game features to optimize operations, resolve game crashes and optimize device and game compatibility, combat user registration of multiple accounts;

3.1.10 Allow other users to interact, communicate or connect with you, including notifying you when other users send you private messages or post comments through the game or services;

3.1.11 Store, host, and backup your personal data within or outside your jurisdiction (whether for disaster recovery or other purposes);

3.1.12 Conduct due diligence or other screening activities (including but not limited to background checks) in accordance with legal or regulatory obligations or our risk management procedures, which may be required by law or that we have implemented;

3.1.13 Respond to legal proceedings or comply with any applicable laws, government or regulatory requirements of any relevant jurisdiction, including but not limited to meeting disclosure requirements under any legal requirements binding on us or related companies or affiliates;

3.1.14 Where permitted by applicable law, conduct marketing and advertising campaigns for any marketing activities, and in this regard recommend products and services relevant to your interests, send communications, marketing and promotional information and materials related to products and services that we (and its affiliates or related companies) may be selling, marketing or promoting (including but not limited to products and services of third parties with whom we may cooperate or collaborate) through various media and modes (including email or SMS), whether such products or services exist now or are created in the future. You can use the unsubscribe function to unsubscribe from receiving marketing information at any time. We may use your contact information to send our newsletters or marketing materials from us and related companies;

3.1.15 Other purposes permitted by applicable law, and we will notify you when we obtain your consent. Such purposes may not be as such, as the purposes for which we may collect, use, disclose or process your personal data depend on the current situation. However, unless privacy law allows processing of applicable data without your consent, we will notify you of other purposes when we obtain your consent.

3.2 Analytics, profiling and segmentation.

In all the above cases and purposes, we may analyze, profile and segment all collected data.

3.3 Legal basis for processing.

If you are a resident of the European Union, we will process information about you based on many legal bases. For example, we will process your information with your consent, where we have legitimate interests, where necessary to perform a contract with you, and where we have legal obligations to process your information. For example, we rely on our legitimate interests to serve targeted marketing and process information when you create an account due to contract necessity. To learn more about the legal basis on which we process your information for any specific purpose, please contact us using the options in Contact and Complaints below.

4. How we share, transfer, and publicly disclose your personal information

4.1 Sharing.

We attach importance to the protection of your personal information, which is an important foundation and component of providing products and services to you. We will only collect and use your personal information for the purposes and scope of this Policy or as required by laws and regulations, and keep it strictly confidential. In general, we will not share your personal information with any company, organization or individual, except in the following cases:

(a) With your prior consent;

(b) Applicable laws, regulations, legal proceedings, government coercion or judicial decisions require sharing of personal information;

(c) Where necessary to provide your personal information to a third party to protect us, its users or the public from harm to their interests, property or safety to the extent required or permitted by law;

(d) Your personal information may be shared between our affiliates. We will only share necessary personal information, and such sharing is subject to the purposes described in this Policy. If an affiliate wishes to change the purpose of processing personal information, it will seek your authorization and consent again;

(e) To provide you with improved, high-quality products and services, some of our services are provided by authorized partners. We may share some of your personal information with partners to provide better customer service and user experience. We will only share your personal information for legitimate, necessary, specific and clear purposes, and will only share personal information necessary to provide the service. We also require our partners to process your personal information in accordance with our instructions, this Policy and any other relevant confidentiality and security measures. Our partners have no right to use shared personal information for any other purpose. If you refuse to allow our partners to collect personal information necessary to provide the service, you may not be able to use that third-party service on our platform.

4.2 Transfer.

We will not transfer your personal information to any company, organization or individual, except in the following cases:

a) Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;

b) Provided according to applicable laws and regulations, litigation requirements and necessary mandatory administrative or judicial requirements;

c) In the event of a merger, acquisition, asset transfer, bankruptcy or liquidation or similar transaction involving the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this Policy, and then require that company or organization to seek your authorization and consent again.

4.3 Public disclosure.

We will only publicly disclose your personal information in the following cases:

a) After obtaining your explicit consent;

b) Disclosure based on law: If required by law, legal proceedings, litigation or government authorities, we may publicly disclose your personal information.

4.4 Without your prior consent.

According to relevant laws and regulations and national standards, in the following cases, we may share, transfer and publicly disclose personal information without your prior authorization and consent:

a) Related to our fulfillment of obligations stipulated by laws and regulations;

b) Directly related to national security and national defense security;

c) Directly related to public safety, public health and major public interests;

d) Directly related to criminal investigation, prosecution, trial, execution of judgments, etc.;

e) To protect the life, property and other major legitimate rights and interests of personal information subjects or other individuals, but it is difficult to obtain their consent;

f) Personal information voluntarily disclosed by the personal information subject to the public;

g) Personal information collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.

According to laws and regulations, where the data recipient cannot restore and re-identify the information subject, sharing, transfer or public disclosure of personal information that has been de-identified should not be deemed to be sharing, transfer and public disclosure of personal information, and such data should be stored and processed without notifying you or obtaining your consent.

5. Data Retention

5.1 We will retain your personal information as described below (unless otherwise required by applicable law).

The data deletion times listed above are based only on information collected by our game client itself. If we obtain information from other partners, the corresponding time may change. The specific time shall be subject to the privacy policy disclosed by the partner.

5.2 Personal information will be retained until the end of its lifecycle (as described in the above retention policy).When destroying personal information, measures will be taken to make personal information unrecoverable or uncopyable, and technical methods that make files unrecoverable will be used to permanently delete electronic files containing personal information.

5.3 If the processing and retention period terminates, but for other reasons, including purposes stipulated by applicable laws, personal information needs to continue to be retained, relevant personal information will be stored and maintained separately from other types of personal information. If you require us to destroy your personal information before the end of its lifecycle (as described in the above retention policy), we will destroy your private information in accordance with local law.

Section 2: Rights

6. This section ("Your Rights") applies only to users located in the European Economic Area.

For users located in other regions, please refer to the privacy clauses in this Policy and the COLOCESS GAMES Terms of Service. You have certain rights regarding the personal information we hold about you. Some of these apply only in certain circumstances (as described below). We must respond to your request and exercise these rights within at least one month without undue delay (although in some cases it may be extended by another two months). To exercise any of your rights, please send an email to kf@colocess.com.

6.1 Access

You have the right to access personal information we hold about you, how we use that information, and with whom we share that information. You can access personal information you provide as part of your account by logging into your game account and linking. If you believe we have any other personal information about you, please send an email to kf@colocess.com.

6.2 Portability

You have the right to receive a copy of certain personal information about you that we process. This includes any personal information we process based on your consent or under our contract with you (for example, certain survey information), as described in the "How we use your personal information" section. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party. If you wish us to transfer such personal information to a third party, please specify that party in detail in your request. Please note that we can only do so if it is technically feasible. Please note that if providing personal information would interfere with the rights of others (for example, providing personal information we hold about you would reveal information about others or our trade secrets or intellectual property), we may not be able to provide you with personal information.

6.3 Rectification

You have the right to correct any inaccurate personal information. You can access personal information you provide as part of your account by logging into your game account. If you believe we have any other personal information about you and that information is inaccurate, please send an email to kf@colocess.com.

6.4 Deletion

You can delete your account or delete certain personal information by logging into your game account. If you believe we process any other personal information and wish us to delete it, please send an email to kf@colocess.com. You may request that we delete your personal information in the following cases:

a) You believe we no longer need to hold such personal information;

b) You believe the personal information we hold about you is being processed by us illegally.

While we consider your request, you may also exercise your right to restrict our processing of your personal information (as described below). If there is a legitimate reason under data protection law (for example, to protect legal claims or freedom of speech), we may need to retain personal information, but if so, we will notify you. If you request us to delete personal information publicly available on our game service and there is reason to delete it, we will take reasonable measures to try to tell others who display personal information or provide links to personal information to also delete this information.

7. Processing restricted to storage

In some cases, you have the right to require us to stop processing personal information we hold about you, except for the purpose of storage. However, please note that if we stop processing personal information, we may use it again if there is a legitimate reason under data protection law (for example, to defend legal claims or protection of others). As described above, if we agree to stop processing personal information, we will try our best to inform any third parties to whom we have disclosed relevant personal information so that they can also stop processing. You may request us to stop processing and only store personal information we hold about you:

a) You believe personal information is inaccurate for the time we need to verify whether it is accurate;

b) You wish to delete personal information because our ongoing processing is illegal, but you wish us to retain personal information and only store it;

c) You wish to delete personal information because it is no longer necessary for our purpose, but you request it be stored to establish, exercise or defend legal claims.

8. Objection

You have the right to object to our processing of your personal information. In other cases, we will consider your request as follows, please send an email to kf@colocess.com.

9. Public notices

When we deem it necessary, we may send you notices from time to time (for example, when we temporarily suspend game access for maintenance, security, privacy or administration-related communication purposes). You cannot opt out of these service-related notices, which are not promotional in nature.

Section 3: Other Options

10. Information Security

We have implemented management, physical and technical security measures designed to protect your information from loss, theft, misuse, unauthorized access, disclosure, alteration and destruction. However, despite our efforts, no security can be guaranteed to be completely foolproof.

11. Links to websites and services operated by others

COLOCESS GAMES Terms of Service may contain links to other websites, applications and services. Since COLOCESS GAMES does not operate these other websites, applications and services, we cannot be responsible for the privacy practices of the entities that operate these websites, applications and services. We recommend that you always check privacy policies to understand the operators' practices. As a reminder, this Policy describes COLOCESS GAMES' practices.

12. Changes

COLOCESS GAMES may update this Privacy Policy from time to time. If we make material changes to the way we collect, use, retain or share your personal information, we will notify you by sending an email to the last email address you provided or posting a notice of changes to the services covered by this Privacy Policy. Continuing to access or use our services after we post modifications to this Policy or provide you with notice of modifications indicates that you agree to be bound by the modified terms. If you cannot accept the modified terms, your only recourse is to stop using our services.

13. Contact and Complaints

We welcome questions, comments and requests regarding this Policy. Please contact us by email at: kf@colocess.com. If you wish to complain about how we process your personal information, please contact us by email at: kf@colocess.com, and we will try our best to process your request as soon as possible.