PRIVACY POLICY

Thank you for reading our Privacy Policy. Cookie Entertainment Company Limited (“Cookie”, “we” or “us”) is the global publisher of this game. When you are playing our games, visiting our websites or using our other online services (collectively “Service”), this Privacy Policy shall apply.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. IT DESCRIBES DETAILS ABOUT HOW WE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION YOU SHARED WITH US.

IF YOU ARE UNDER 18, DO NOT PROVIDE ANY PERSONAL INFORMATION WITHOUT APPROPRIATE PERMISSION UNDER APPLICABLE LAW.

By using our Service and providing us with information, you consent to the storing, transferring and processing of your information in the manner described in this Policy.

1. What personal information do we collect?

We collect information that you voluntarily provide to us, information that we collect automatically through your use of the services, and certain information we obtain from third party sources. The sample of information shows as following:

a)        For the Moblie Game

1. Information You Voluntarily Provide
   1. When you are using the game or services within the game:

-   the chat log and message you communicated or posted in our Service, regardless of whether it is in the form of text, voice, image or video.

-   your purchase or transaction record in the Service through Apple Store, Google Play, PayPal, WeChat Payment, Alipay and other payment method

-   your phone number (if applicable)

2. Any information you submit to our support team by email or other means for any reason, for example, asking for customer support.

3. Other personal information you provide in connection with your voluntary participation in surveys, sweepstakes, contests, promotional offers, and other activities.

2. Information We Automatically Collect

- Internet Protocol (IP) address

- broad geographic location (e.g. country or city-level location) based on your IP address

- device information, including the device type, device model, device maker, device operating system and its language or other technical data like processor, or combination of this data available from a device for a developer for checking the device compatibility with a particular application

- device identifiers, such as a universally unique identifier (“UUID”), referring to the small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may convey information to us about how you browse and use the Service and may remain persistently on your device, to help you log in faster and enhance your navigation through the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.

- Advertising ID, i.e. Identifier for Advertisers (“IFA”) on Apple and Google Advertising Identity (“GAID”). These are unique identifiers for mobile device that advertisers use for personalized advertising. They are consistent across all mobile applications and thus allow cross-app tracking. On Apple, you can opt out of it by choosing the “limit ad tracking” option in your privacy settings. On Google Android, you can opt out of these ads by choosing “Opt-out of personalized ads”. Advertising IDs are non-permanent, non-personal identifiers, which are uniquely associated with your device.

Progress in the game:

-   log data (time and period)

-   in-game items and behaviors

-   achievements you have completed in the game

-   other users you referred

Some of the automatically collected information may be collected through cookies as explained further under the heading “Cookies and other tracking Technologies” below

3. Information We Obtain from Third Party Sources
   1. Third-Party Social Networks:

If you log in to our Service using social network accounts, such as Facebook, Google, Apple Game Center (“Third-Party Social Networks”), we may collect personal information you authorized the Third-Party Social Networks to share with us to pre-populate our sign up form. Exactly what information we receive from your social media will depend on your social media privacy settings, but it would typically include your basic public profile information such as

-   your username

-   profile picture

-   gender (with your option)

-   your friends playing the same Game

-   other information from Third-Party Social Networks that you have permitted the Third-Party Social Networks to share with us

-   any information you have made public on the Third-Party Social Networks.

You should always review, and if necessary, adjust your privacy settings on the Third-Party Social Networks before linking or connecting them to our Service.

2. Advertising partners:

From time to time, we may also receive personal information about you from other third-party sources. For example, if you click on an advertisement to direct you to one of our services or Games (such as an advert of one of our Games in other publisher’s game), we may receive the information that allows us to know which ad network and advertising campaign your installation was originated from.

b)        For the Website

1. Information You Voluntarily Provide

Cookies

2. Information We Automatically Collect

-   Internet Protocol (IP) address

-   device information, including the device type, operating system and version

We also use analytics tools on our Service to retrieve information from your device, including your preferred settings, which in-game adverts you may have viewed, and the means by which you were referred to our Service. We may also deliver advertisements and provide website analytics tools on non-Cookie sites and services, and we collect information about page views on these third party sites as well. We treat this information as personal information if we combine it with or link it to any of the identifying information mentioned above. Otherwise, it is used in the aggregate or in anonymized form only.

The data elements in the above chart are examples only. From time to time we may change the information requested upon registration or with respect to certain features or services, so this may not be a complete list.

You can access certain portions of our Service without providing us with any personal information. However, you will not be able to utilize certain features that require registration or receive materials unless certain information is provided. The processing of this personal information is lawful as it is necessary for the performance of our Service. Where processing is not necessary for the performance of the Service, your consent to such processing will be requested where required under applicable law.

For users in certain jurisdictions, please refer to the Special Section for Certain Jurisdictions for further information about how we collect and process your personal information and your related rights.

c)        No special categories of information

We do not initiatively request or intend to collect any “special categories of information” as defined in Art.9 of the General Data Protection Regulation (“GDPR”), such as any information on health, race, religion, political opinions or philosophical beliefs, sexual preferences or orientation. We also want to kindly remind you to be cautious when sharing this information about yourself (or others) in our forums.

d)        No credit card information

Our Games enable in-app purchases and we collect your purchase or transaction record in the Service. However, we do not process payments for in-app purchases nor have access to your credit card information.

Payment transactions for in-app purchases are mostly completed through the app store via your App Store account or Google Play account, or platforms, or through the payment method you choose such as VISA, PayPal, WeChat Payment or Alipay, etc. Any post-purchase processes are controlled by the Apple and Google stores and other payment providers and are subject to those payment providers’ specific terms of service. Please review the privacy policies and terms of service of your Apple and Google stores and the payment providers you choose.

e)        Cookies and other tracking technologies

Our Services and some of our Service Providers utilize “cookies”, anonymous identifiers and other tracking technologies (collectively, “Tracking Technologies”) which help us provide and improve our Services, as well as the usage of our Apps, Games and Services as a whole. Cookies are small text files (composed only of letters and numbers) that a web server places on your computer or mobile device when you visit a webpage. When used, the cookie can help make our Services more user-friendly, for example by remembering your language preferences and settings. You can find more information about cookies at www.allaboutcookies.org.

For the purpose of providing Service, we use following cookies:

-strictly necessary cookies. These cookies are necessary for the function of our Services and cannot be rejected if you are going to use our Services.

-analytics cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site.

If a browser or mobile device is set not to accept cookies or if a user rejects a cookie, some portions of the Website or Service may not function properly. For example, you may not be able to sign in and may not be able to access certain Website or Service features or services.

f)          Data collected to prevent cheating and unauthorized software

When you run our Game software or receive our Service, this may involve software functions designed to detect cheating or unauthorized and malicious programs. In this context, we may access, collect, monitor and/or remotely store screenshots of game play, information relating to hardware capacity, modifications related to our Game software, signatures, profiles or names of known or suspected unauthorized or malicious third party programs, files or processes that enable or facilitate cheating, unfair advantage or hacking of the Games or Service. If circumstances suggesting unauthorized or malicious programs are detected, the Game software may also communicate to us the users account and User ID and information about the unauthorized or malicious program or its use.

We see this processing as necessary for the purposes of the legitimate interests pursued by us, where legitimate interest is not sufficient for the collection, your consent to such processing will be requested where required under applicable laws.

2. For which purposes do we use your personal information?

We use your personal information to provide products and services you ask for, to communicate with you, to improve our services, and for other purposes including those set out in the chart below.

Where processing is not necessary for the performance of the Service or we cannot rely on legitimate interests in a particular case (because for example your privacy rights and freedoms in that case outweigh the legitimate interests), your consent to such processing will be requested as appropriate under applicable law.

a)        Compliance with our legal obligations

We may use your information when we are required to do so by law, or pursuant to valid legal requests.

b)        For purposes for which you give us consent

We may also collect and use personal information for specified purposes when you give us your consent to do so.

3. Do we share personal information? If so, how we share your information?

We may share your personal information with certain third parties subject to the ways that are described in this Privacy Policy or as otherwise required by law. We do not sell or trade any personal information about our visitors and users to any third parties.

Please note that nothing herein restricts the sharing of aggregated or anonymized information, which may be shared with third parties without your consent.

a)        Our service providers

We may share personal information with our vendors, consultants and other service providers (“Service Providers”) such as Appsflyer, Google as our analytic service provides and our vendors who are engaged by or working with us in connection with the operation of the Service and who need access to such information to carry out their work for us. We may also share personal information with auditors, accountants, lawyers, financial or professional advisers. We provide access to the information they may need to perform our services under reasonable confidentiality terms. In some cases, the Service Provider may directly collect the information from you on our behalf. We inform Service Providers that they are not permitted to use personal information they obtain from you other than to provide the services for us. However, we are not responsible for any additional information you provide directly to these Service Providers and we encourage you to become familiar with their practices before disclosing any personal information directly to such Service Providers.

b)        Sharing when you give us consent

From time to time, we may also share personal information with third parties when you give us your consent to do so.

c)        Sharing in response to legal obligations

We reserve the right to disclose your information (including personally identifiable information) in response to law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may access, disclose or preserve personal information, including the content of your communications, in the good faith belief that we are lawfully authorized by public authorities or required to do so, including to meet national security or law enforcement requirements or that doing so is reasonably necessary or appropriate to comply with the law or with legal process or authorities, respond to any claims, or to protect the rights, property or safety of Cookie, our users, our employees or the public, including without limitation to protect Cookie or our users from fraudulent, abusive, inappropriate or unlawful use of our Service.

d)        Sharing due to merger, acquisition and similar situations of the transfer of company assets

Information we collect, including personal information, may also be disclosed or transferred as part of, or during negotiations of, any merger, sale, divestiture, or transfer of all or a portion of the company assets, financing or acquisition or in any other situation where personal information may be transferred as one of the business assets of Cookie. You will be notified via email and/or a notice of any change in ownership, uses of your personal information, and choices you may have regarding your personal information.

e)        International transfer

In order to perform our contract with you, your personal information will be transferred and shared globally, among Cookie and its service providers and business partners who are shared your personal Information as described in this Privacy Policy. Your personal information will be accessible from and processed in servers located globally.

As Cookie is a global company, your personal information may be transferred to and processed in countries other than the country in which you reside. Although these countries may have data protection laws that are different to the laws of the country you reside in, we ensure appropriate safeguards in place so that your personal information will remain protected in accordance with this Policy. The information relating to your account and use of our games may be transferred internationally.

You acknowledge and understand that the laws regarding personal information in the country or region to which the data is transferred may be less stringent than the laws of your country and may not offer the same protections or rights as those laws. If you object to your personal information being transferred or used as described in this Policy, please do not use the Service.

f)          Game updates

When we update or “patch” any of our game applications or other software, we may utilize a patch routine to verify whether the most recent version is installed on your computer. If not, the most recent version may automatically be uploaded to your device, and you hereby consent to, and waive any further notice of, such upload.

g)        Push notifications and local notifications

We may, with your consent, send push notifications to your mobile device to provide game updates and other relevant messages. You can manage push notifications from your mobile device’s settings page for the relevant game and/or from the settings page within the relevant mobile game. We may also send local notifications to your mobile device to provide game updates and other relevant information. To manage local notifications, you should consult your mobile device’s settings page for the relevant game and/or from the settings page within the relevant mobile game.

h)        Performance monitoring

You understand and agree that when you communicate with other players within a game or utilize any interactive features available on the Service, such as instant text, voice or image messaging, forums or chat rooms, such communications and postings are transmitted through our servers, and we may, but are not obligated to, monitor all such communications and postings for purposes such as protecting the rights and safety of Cookie and our users, including those that are designated as “private,” to the degree that laws and regulations enable us to do this. Therefore, as the abovementioned performance monitoring might involve access to these communications and postings, please do not use these communication channels for private or confidential messages.

4. What steps do we take to protect your personal information?

We use physical, technical, and administrative measures to safeguard information in our possession against loss, theft and unauthorized use, disclosure, or modification. Please note, however, that no data transmission or storage can be guaranteed to be 100% secure. As a result, although we strive to protect the information we maintain, we cannot ensure or warrant the security of any information that you transmit to us.

You should note that our Service Providers may be responsible for processing, handling or storing some of the personal information that we receive. They are not authorized to market to you independently. These Service Providers are contractually required to safeguard and secure the personal information they received from us. Although we strive to protect your personal information, you should be aware, however, that information sent over the Internet is not necessarily secure and may be intercepted or accessed by third parties. Therefore, we cannot guarantee the security of such information, and we are not responsible or liable for any such interception or unauthorized access.

5. How long do we retain your personal information?

Generally, we delete the information as soon as we do not need it for the purposes described in this Policy. Your registration information and any game data generated from your account's activity will be held for as long as your account remains active, or until the game or platform expires. We may store certain data only for several minutes or several days, such as your log data, chat data, in-game activity data.

However, we may continue to retain certain data to the maximum extent permitted by applicable laws.

6. What choices do you have regarding the use of your personal information?

As the subject of the personal information, you are entitled to have the rights provided by the privacy laws in your jurisdiction. Your rights may include part or all of those described underneath. You can exercise your rights entitled by the privacy laws in your jurisdiction at any time by sending us relevant requests to privacyhelpcookie@gmail.com. Your rights may include:

a)        Right to access your data

You have the right to access personal information we hold about you, how we use it, and who we share it with.

b)        Right to correct your data

You have the right to correct any personal information held about you that is inaccurate. For example, you can contact us if your email address has been changed and we should replace your old email address.

c)        Right to have your data deleted

You can delete your account (i.e. the account on our Service, excluding any account on the third party platforms, such as Apple Store and Google Play), or remove certain personal information that we have stored about you by contacting privacyhelpcookie@gmail.com. However, please note that we may need to retain personal information if there are valid grounds under data protection laws for us to do so (e.g., for the defense of legal claims or freedom of expression) but we will respond to you and let you know if that is the case.

d)        Right to restrict processing and withdraw your consent

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. You may withdraw your consent at any time by sending a communication to us specifying which consent you are withdrawing. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.

Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds other than your consent, for example, when the processing is necessary to fulfil the obligations of a contract, processing is necessary to protect the vital interest of you or another natural person, or other legitimate reasons under data protection laws.

e)        Right to take your data with you

You have the right to receive a copy of certain personal information we process about you. For example, you can contact us to receive your data if you want to upload it to another service. However, please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (e.g. where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

f)          Right to object to how your data is handled

You have the right to object to our processing of personal information about you. In particular you have the right to object to being profiled for the purposes of direct marketing (for example where we collect information about you in order to decide what marketing to send you, based on your preferences or personal characteristics).

g)        Right to lodge complaints to the supervisory authority

You have the right to lodge complaints about the data processing activities carried out by us before the competent data protection authorities.

To help us verify that you are the subject of the personal information and realize your rights above, we may require you to provide sufficient proof of identification as we request, and we reserve the right to deny access to any user if we believe there is a question about your identity. We will respond to all access requests within thirty days.

7. How do we protect children?

The minimum age of children who are eligible to use our Service will differ depending upon the settings or notices in our Service provided in different jurisdictions. The Service is NOT directed to children under such minimum age. If we discover that we have inadvertently collected information from children under such minimum age, we will delete the children’s information from our systems in accordance with applicable law. If you become aware that personal information about a person under such minimum age has been provided to us, please immediately contact us at: privacyhelpcookie@gmail.com .

If you are under such minimum age, do not provide any personal information unless you have obtained your parent’s or guardian’s permission previously.

Depending on the applicable laws, verified consent from your parent or guardian may be required. Since the settings or notices in our Service provided in your jurisdiction does not specify a minimum age, persons under the age of 18 are not eligible to use our Service.

8. How can you contact us?

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily or any questions, comments on this Policy or wish to realize your rights described in this Policy, please contact us at: privacyhelpcookie@gmail.com .

9. Changes to this Policy

From time to time, we may revise this Policy to reflect changes to the scope of the Services or for other reasons. Therefore, it is important to check the effective date of this Policy posted here each time you use the Services. By continuing to use the Services after we make changes, you indicate your consent to those changes.

10. Special Section for Certain Jurisdictions

a)        European Union

When you are in the European Union, the European Regulation (EU) 2016/679, also referred to as the GDPR, applies to the collection and processing of your personal data by Cookie.

Cookie is a multinational group with companies registered outside the EU. Our servers and main business operations are located globally. By using our Service and providing us with information, you acknowledge and understand the transferring, storing and processing of your information on computers located in China in the manner described in this Policy. If you object to your personal information being transferred or used as described in this Policy, please do not use this Service.

If you have any thoughts or questions about this Policy, or if you wish to exercise any of your data subject rights, you may contact us at: privacyhelpcookie@gmail.com.

b)        Korea

This Policy is that membership is available only to persons who are 18 years of age or older, and that persons under the age of 18 are not eligible to use our services. Cookie will comply with the relevant laws and regulations should there be a need to collect personal information on children under the age of 14.

We delete the information as soon as we do not need it for the purposes described in this Policy and also will keep your data in the games for the period of time set forth in relevant Korea laws.

Generally, we do not share your personal data with third parties except for sharing with outsourced providers (Processors) listed as below when providing Services.

c)        United States

Minimum Age. In the United States, the minimum age for users of our Service is 18. Especially, we therefore do not knowingly collect any personal information from children under the age of 13 in the United States without parental consent, unless permitted by law. If we learn that a child under the age of 13 has provided us with personal information, we will delete it in accordance with applicable law.

California Consumer Privacy Act. While we have tried to fully describe our data practices elsewhere in this Privacy Policy, this section supplements the description of our information collection and sharing practices elsewhere in this Policy to provide certain disclosures to certain California residents whose personal information Cookie processes pursuant to the California Consumer Privacy Act (“CCPA”).

During the preceding 12 months, Cookie has collected, used, and shared the categories of personal information described in the section of our Privacy Policy entitled, “What Personal Information Do We Collect?” For example, depending on the Services you use, this may include your identifiers (e.g., IP addresses and mobile device identifiers), commercial information, audio and visual information (e.g., photos of yourself if you upload them), and Internet and other electronic activity information. This may also include demographic information and inferences we draw from the other information we collect.

As described in our Privacy Policy, we disclose personal information to third parties for various business purposes, including without limitation, for purposes of advertising, marketing, and other services performed on our behalf, to protect against fraud and malicious activity, and for other business purposes described in this Policy. In addition, your information may be accessible to third parties with whom you interact or direct us to share your information through our services, and information about your choices for third-party advertising cookies and similar technologies is described in the “Cookies and other tracking technologies” section of this Policy. While your information is shared in these ways, we do not share information in a manner that we consider a “sale” of personal information for purposes of state law.

We provide you certain of the rights described in the section, “What choices do you have regarding the use of your personal information?” above in accordance with state law. We will not charge you different prices or provide different quality of services unless those differences are related to your information or otherwise permitted by law. Please submit your request by sending an email to privacyhelpcookie@gmail.com . Once we receive your request, we may verify it by requesting information sufficient to confirm your identity, including by asking you to verify information about your use of the Service. If you would like to use an agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.

Updated on 1, January, 2020