This Privacy Policy was last updated on April 1st, 2024

This Privacy Policy (“Policy”) explains the ways Ten Percent Games (Shenzhen) Consulting Co., LTD (referred to “we”, “us”, or “our” in this Policy) collects, stores, uses, or otherwise processes personal data of end users of our Services as defined below (referred to as “you” or “your” in this Policy), and why we collect it, how we use that information, and how you can exercise your privacy rights.

In this Policy, “Services“ refers to our Website, and any related services or properties we directly control.

BY USING, REGISTERING TO OR OTHERWISE ACCESSING THE SERVICES, YOU AGREE TO THIS PRIVACY POLICY AND GIVE AN EXPLICIT AND INFORMED CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, PLEASE DO NOT USE, REGISTER TO OR OTHERWISE ACCESS THE SERVICES.

Ten Percent Games (Shenzhen) Consulting Co., LTD reserves the right to modify and update this Privacy Policy periodically, so please make sure to check back this page from time to time to review this Policy. Changes to this Privacy Policy will come into effect immediately upon such changes being uploaded on our websites. Your continued use of Services will signify your acceptance of the changes to this Privacy Policy.

By “data controller”, we mean an entity that determines how and why personal data is processed. Your personal data will be held by us in accordance with applicable data protection laws. For the purposes of data protection laws, the data controller will be Ten Percent Games (Shenzhen) Consulting Co., LTD While operating the Services, we may share your data with partners we work with. Some of these partners are data controllers independently of us and, therefore, independently determine how and why they process your data. For more information on these partners and the ways in which they may process your data, please refer to section 6 of this Policy.

When you access our products and Services, we won’t collect your legally-sensitive data (i.e. race, ethnicity, religious or philosophical beliefs, trade union membership, genetics, biometrics, health, sexuality and/or criminality) and other sensitive data (i.e. child data, social security numbers, bank account or payment card details). Please do not provide this kind of information to us or use the Services to make it available to others.

We may collect and receive information which may be considered personal data according to applicable laws in a variety of ways. More specifically: — directly from you when you submit it to us. Providing data to us is not mandatory. However, we are unable to provide the Services, or some parts or features of the Services, without processing your data. If you use our Services, we will collect data relating to you for some or all of the purposes described in this Policy, depending on the Services you decide to use and your choices when using them.

When we process or collect your data, we ensure that we have a legal basis to do so. Below, you can find examples of the different purposes for which we process your data and the legal basis we have for each of those reasons:

We may share your data with third parties to achieve the purposes described in this Policy. This may include sharing data with the following types of recipients:

Your personal data will be used by us and disclosed to our group companies, including Ten Percent Games (Shenzhen) Consulting Co., LTD and all of its subsidiaries.

Your personal data will be disclosed by us to our partners we work with while providing the Services (who may process your data independently of us), including advertising partners, IP licensors, and others listed here.

We may disclose your personal data: to regulators and law enforcement agencies (including those responsible for enforcing anti-money laundering legislations); or in response to an enquiry from a government agency.

We may disclose your personal data to third party service providers (including our professional advisors, data analysis processors and data storage service providers) who require access to such information for the purpose of providing specific services to us. These third parties will generally only be able to access your data in order to provide us with their services and will not be able to use it for their own purposes.

If the management and operation of Ten Percent Games (Shenzhen) Consulting Co., LTD and its affiliates are transferred from us to another company, we may disclose your personal data to the other company so the products and services can continue to be provided to you. In the event that we sell or buy any business assets, we may disclose your personal data to the prospective seller or buyer of such business or assets. If Ten Percent Games (Shenzhen) Consulting Co., LTD or substantially all of its assets are acquired by a third party, personal data held by us about our customers will be one of the transferred assets.

We will keep your data for as long as necessary to achieve the purpose(s) for which it was collected, including to provide you with the Services or to comply with any legal, accounting, or reporting requirements.

We take the security of your Personal Data very seriously. We implement the appropriate technical and physical safeguards to ensure that your Personal Data is protected against accidental or unlawful loss, destruction, alteration, unauthorized access or disclosure, or any other use or unlawful processing of Personal Data you have provided to us. Our security mechanisms for Personal Data are similar to those of other game developers. Please keep in mind, though, that the Internet is not 100% secure and any access, disclosure, alteration or destruction of the Personal Data you have provided through our games due to breach of our safeguards cannot be guaranteed.

You have various rights in relation to the data which we hold about you. We have set these out below. To get in touch with us about any of these rights, please find the contact details described in Section 14 below. We will seek to deal with your request without undue delay. Please note that we may keep a record of your communications to help us resolve any issues which you raise.

You have a right to know what Personal Data we hold about you, how and why we handle your Personal Data. You can ask us for a copy of your Personal Data and in some cases to have the information communicated to you. If you would like to exercise your right of access please contact us as described below and let us know what information in particular you would like to receive. We reserve the right to ask for reasonable evidence to verify your identity before we provide you with any information. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will endeavour to tell you why.

You have a right to request an update or correction to any of your Personal Data which is out of date, incomplete or incorrect.

In certain specific circumstances, you have a right to ask us to delete your Personal Data which we are holding about you. We will pass your request onto other recipients of your personal information unless that is impossible or involves disproportionate effort. If you would like to ask us for further information on the specific circumstances, and who the other recipients are, and/or exercise your right to erasure please contact us. Please note some things can only be deleted when you delete our games from your mobile devices and clear our cookies from any device that you have used for our Services. In that case you will permanently lose all your game progress, Virtual Currency and Virtual Goods without the right to data recovery or refund. Where we delete Personal Data about you, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity. We may also retain your information in an anonymised form. In some instances, personal information about you that is visible through gameplay such as username, avatar, your high scores and any chat messages may be cached on other players’ devices and we may not be able to remove or update that data from those devices, for example if that device is not connected to a network. You can ask us for further information on the specific circumstances and who the other recipients are, using the contact details described in Section 12 below.

In certain specific circumstances you have a right to object to the processing of personal data about you which is processed on the grounds of legitimate interests. You can ask us for further information on the specific circumstances using the contact details described in Section 12 below.

Please note that even if you use your right to opt-out it you will still receive advertising, but not direct or target interest. On Apple you can opt-out this by going to Settings > Privacy > Advertising and turning on “Limit Ad Tracking”. On Android you can opt-out by going to Settings > Google services > Ads and turning on choosing “Opt out of Ads Personalization”.

In some circumstances, you may have the right to request that data which you have provided to us is provided to you, so you can transfer this to another data controller.

For more information, please contact your local data protection authority.

Automated decisions mean that a decision concerning you is made automatically on the basis of a computer determination (using software algorithms), without our human review. For example, we use automated decisions to provide direct or targeted interest-based advertising on our Services. You can opt out of direct or targeted interest-based advertising by following the instructions in Section 9.6. above.

Our Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal data between our group companies and third party service providers and partners, which require all group companies to protect personal data they process from the EEA in accordance with European Union data protection law. It also includes transferring personal data to third party service providers and partners which are certified under the EU-US and Swiss-US Privacy Shield.

We may update this Policy from time to time, for example due to changes in our operations or the legal obligations that apply to us. Updates will be made available here. Therefore, we encourage you to check this page periodically. We may also inform you of any changes by other means that are appropriate to the significance of the changes.

If you have any questions or concerns about this Privacy Policy or any other issue with your personal information while using our Services, please feel free to contact us by email address: [email protected]