Shenzhen Huanxi Huyu Network Technology Co.LTD Privacy Policy

Last Updated: June 24, 2024

Effective Date: June 24, 2024

[Shenzhen Huanxi Huyu Network Technology Co.LTD, Abbreviated as "Huanxi Game"] ("Company", "we", "us", or "our") respects your privacy and is committed to protecting your personal information. This Privacy Policy explains how we collect, use, store, disclose, and protect information when you use Shenzhen Huanxi Huyu Network Technology Co.LTD and related game services (collectively, the "Game" or the "Services").

Please read this Privacy Policy carefully before using the Services. If you do not agree with this Privacy Policy, please do not use the Services. If you are under the age of majority in your jurisdiction, you must read this Privacy Policy with your parent or legal guardian and use the Services only with their consent.

Table of Contents

  1. Information We Collect
  2. How We Use Information
  3. Device Permissions
  4. Cookies and Similar Technologies
  5. Third-Party SDKs and Services
  6. Sharing, Transfer, and Disclosure
  7. Data Storage and Security
  8. Your Rights and Choices
  9. Protection of Minors
  10. International Transfers
  11. Changes to This Privacy Policy
  12. Contact Us
  13. Governing Law and Dispute Resolution

1. Information We Collect

We collect only the information that is necessary for providing, securing, improving, and operating the Game, or information that you voluntarily provide to us.

1.1 Account and Login Information

When you register, log in, bind an account, recover an account, or use platform login features, we may collect account ID, username or nickname, password or authentication token, email address, phone number, verification code status, third-party platform account identifiers, and login records.

1.2 Device and Network Information

To operate the Game, maintain account security, prevent cheating, diagnose issues, and improve compatibility, we may collect device model, operating system type and version, device identifiers such as Android ID, IDFA, IDFV, IMEI, IMSI, OAID or similar advertising identifiers where permitted by law, IP address, MAC address where permitted by law, network type, carrier information, language settings, country or region settings, crash logs, performance logs, and device status information.

1.3 Gameplay and Log Information

When you use the Game, we may collect game character information, server information, role ID, level, in-game progress, virtual item records, virtual currency records, battle records, friend records, guild or team records, login logs, operation logs, payment logs, bug reports, anti-cheat logs, and other records generated through use of the Services.

1.4 Payment and Transaction Information

If you purchase virtual currency, virtual items, subscriptions, or other paid content, we may collect order number, product name, price, purchase time, payment status, channel information, transaction records, refund records, and customer support records related to the transaction. Payment processing may be completed by third-party payment providers such as app stores, Alipay, WeChat Pay, QQ Wallet, or other payment channels. We do not collect your full bank card number or full third-party payment account password.

1.5 Customer Support Information

When you contact customer support, submit feedback, report bugs, participate in events, request account recovery, or request account deletion, we may collect your contact information, account information, device information, screenshots, recordings, communication content, identity verification materials where required for account security, and other information you provide.

1.6 Voice, Chat, and Community Information

If the Game provides text chat, voice chat, friend, guild, customer service, or community features, we may process messages, voice content, profile information, report records, and moderation records. We use this information to provide communication features, maintain a healthy game environment, review harmful content, handle complaints, and enforce our rules.

1.7 Information from Third Parties

Where permitted by law, we may receive information from publishing partners, platform SDKs, payment providers, analytics providers, advertising providers, anti-cheat service providers, customer support tools, and social login providers. This may include account identifiers, payment status, campaign attribution, device information, and service usage information.

2. How We Use Your Information

We use the information we collect for the following purposes:

2.1 Processing of Your Personal Data

(I) General Rules for Personal Data Processing

  1. We process your personal data in compliance with this Privacy Policy to deliver the full functionality of our products and services.
  2. Upon collection, we will de-identify your personal data via technical measures so such data can no longer identify you as a natural person. You hereby consent that we may use de-identified data, and perform analytical or commercial processing on anonymized user datasets without disclosing your identifiable personal information.
  3. Your consent to the continuous processing of personal data provided during your use of our services remains valid unless you delete your data or disable relevant data collection permissions via device or in-app settings.
  4. We may generate anonymized aggregate usage statistics of our products and share such statistics with the public or third parties to demonstrate overall service usage trends. No identifiable personal data will be included within these statistical datasets.
  5. Where we need to display your personal data publicly, we will adopt content masking and anonymization techniques to minimize data sensitivity and protect your information security.
  6. If we intend to process your personal data for purposes not specified in this Policy, or repurpose data collected for a specific legitimate use for other objectives, we will obtain your explicit prior consent via an opt-in checkbox mechanism.

(II) Specific Legitimate Uses of Your Personal Data

  1. Service Provision: We rely on collected personal data to deliver all product features and services, including core gameplay and in-app purchase functions.
  2. Security Assurance: Your data may be used for identity verification, account security protection, anti-fraud monitoring, data backup, anti-cheating enforcement and customer service support.
  3. Business Analytics: We may process user data for internal audits, statistical research, operational impact analysis and market performance measurement.
  4. Service Update Notifications: With your explicit consent, we will push notifications for application upgrades and version releases. Should you withdraw this consent, certain product functions may no longer be available to you.
  5. Legal Compliance: We process personal data to abide by applicable local laws, regulatory rules and recognized industry standards.

Should we seek to process your personal data for unlisted purposes or collect additional categories of personal data not covered in this Policy, we will obtain your explicit consent through in-page prompts, interactive consent workflows, official announcements or other valid notification channels. Once you provide consent, such supplementary data processing terms shall form an integral part of this Privacy Policy and be subject to all provisions contained herein.

3. Device Permissions

The Game may request device permissions only when they are needed for specific features. You can manage permissions through your device settings. Refusing or disabling a permission may prevent the related feature from working, but it will not normally affect unrelated core gameplay.

4. Cookies and Similar Technologies

The Game and related websites may use cookies, local storage, device identifiers, SDK storage, log files, and similar technologies. These technologies help us remember preferences, maintain login status, secure accounts, analyze service usage, attribute advertising campaigns, and improve service quality. You may disable cookies in your browser or reset advertising identifiers in your device settings, but some functions may become unavailable.

5. Third-Party SDKs and Services

The Game may integrate third-party SDKs and services for login, payment, analytics, advertising, voice chat, notifications, anti-cheat, crash reporting, and customer support. Based on the project components, these may include Unity Ads, Unity Analytics, Unity services, Windplay SDK, Tencent or QQ-related services, WeChat-related services, Alipay-related services, GCloud Voice or similar voice services, local notification plugins, and other publishing or platform SDKs.

Third-party SDKs may collect device information, network information, advertising identifiers, account identifiers, payment status, interaction logs, crash logs, and feature-specific information. Their processing activities are governed by their own privacy policies. We require third parties to process information only for lawful, legitimate, necessary, specific, and disclosed purposes, and to protect information using appropriate security measures.

6. Sharing, Transfer, and Disclosure

6.1 Sharing

  1. Under normal circumstances, we will not share your personal information with any third party outside of Huanxi Game without your consent or authorization, except in the following situations:
    1. Prior explicit consent or authorization from you;
    2. According to the requirements of applicable laws and regulations, legal procedures, mandatory administrative or judicial requirements, it is necessary to provide;
    3. Within the limits permitted by laws and regulations, it is necessary to provide in order to maintain the interests, property or safety of Huanxi Game, its affiliates or partners, you or other players or the public from being damaged;
    4. Only by sharing your personal information can we realize the core functions of our products and/or services or provide the services you need;
    5. Process any disputes or disagreements you have with others upon your request.
    6. In accordance with relevant agreements (including electronic agreements signed online and corresponding platform rules) or other legal documents signed with you;
    7. Based on academic research for use;
    8. Used based on laws and regulations for the public interest.
  2. When using Huanxi Game services, you will also use SDKs that provide part of the services for us. The aforementioned SDKs may collect your personal information for the purpose of providing the above services. The list of SDKs can be found in the 'Huanxi Game Third-Party SDK Integration Directory'. For specific legal responsibilities and other details of third-party SDKs, please refer to the privacy policies of the SDK operators.
  3. If you obtain the software and access the Huanxi Game services via a third-party game distribution channel (such as branded mobile phones or third-party app stores), some channels may integrate a distribution channel SDK into the software for logging into our game products, pre-paying, and real-name authentication functions. To ensure you can successfully log into the game products and use related services, you need to authorize the channel SDK to provide corresponding services; after you grant authorization, the channel will collect your relevant personal information.
  4. To fulfill our obligations and exercise our rights in this policy or other agreements we have reached with you.

6.2 Transfer

We will not transfer your personal informatio n to any company, organization, or individual, except in the following situations:

  1. Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;
  2. In the event of mergers, acquisitions, or bankruptcy liquidation, if personal information is involved in the transfer, we will notify you of the relevant circumstances through the publication of notices, announcements, or other means, and continue to protect your personal information in accordance with the standards required by laws and regulations, or require the new managers to continue to protect your personal information in accordance with this policy.

6.3 Public Disclosure

We will only disclose your information under the following circumstances and only when we have taken security measures:

  1. According to your request, disclose the information you specified in the manner you explicitly agree to;
  2. Based on mandatory requirements from laws and regulations, judicial authorities, or administrative departments, we may disclose your personal information;
  3. If we are involved in restructuring, mergers, or bankruptcy and liquidation proceedings, your personal information may also be disclosed to transaction parties.

6.4 Exceptions to obtaining authorized consent before sharing, transferring, or publicly disclosing information

  1. Related to the obligations that the personal information controller must fulfill according to laws and regulations;
  2. Related to national security and national defense security;
  3. Directly related to public safety, public health, and major public interests;
  4. Directly related to criminal investigation, prosecution, trial, and execution of judgments;
  5. To protect the life, property, or other major legal rights and interests of the personal information subject or other individuals, when it is difficult to obtain the本人's authorization consent;
  6. Personal information that the subject of personal information voluntarily discloses to the public;
  7. Collecting personal information from legally disclosed information, such as legitimate news reports, government information disclosure, and other channels.

7. Data Storage and Security

We will store your personal information only for the necessary period described in this policy and for the shortest time required by laws and regulations. If we terminate our services or operations, we will immediately stop collecting your personal information and will notify you in advance as required by relevant laws and regulations. After terminating services or operations, we will delete or anonymize your personal information, unless otherwise required by laws and regulations or regulatory authorities.

7.1 Storage of information

(1) The method and duration of information storage

We may share children's order information, account information, device information, and location information with partners and other third parties to ensure the smooth provision of services for children. However, we will only share children's personal information for legal, legitimate, necessary, specific, and clear purposes, and only share the necessary personal information of children for providing services. Our partners are not entitled to use the shared children's personal information for any other purposes. For example, companies we hire to provide third-party data statistics and analysis services may need to collect and access children's personal data for data statistics and analysis. In such cases, these companies must comply with our data privacy and security requirements.

Under normal circumstances, we will only store your personal information for as long as necessary to achieve service purposes or as required by laws and regulations. After the storage period expires, we will delete or anonymize your personal information. However, this does not apply if you exercise your right to deletion,注销 account, or if there are other provisions in laws and regulations.

(2) The geographical area where information is stored

We will store the collected and/or generated user personal information on servers in accordance with legal regulations, except where legal regulations explicitly provide otherwise.

(3) Notification upon the cessation of product or service operations

When our products or services cease to operate, we will notify according to relevant laws and regulations, and legally protect your legitimate rights and interests.

7.2 Protection of Information

(1) Technical Measures

We will adopt security measures that meet industry standards, including establishing reasonable system regulations and security technologies to prevent unauthorized access, use, modification of your personal information, and to avoid data damage or loss.

(2) Institutional Measures

We conduct comprehensive security control over data through a confidentiality agreement for information contacts, monitoring, and auditing mechanisms. We also hold security and privacy protection training courses to strengthen our employees' security awareness and their understanding of the importance of protecting information.

(3) Response and Disposal of Security Incidents

Please be aware that the internet is not an absolutely secure environment, and communication methods such as email, instant messaging, social software, or other service software with other users cannot be determined to be fully encrypted. We recommend that you use complex passwords when using these tools and pay attention to protecting your information security. We will do our best to ensure or guarantee the security of the personal information you send to us. At the same time, you need to understand that due to technological limitations and the limitations of risk prevention, no security measures can be perfect. The systems and communication networks you use to access Huanxi Game services may experience problems due to situations beyond our control.

In the event of an information security incident, we will notify you in accordance with legal and regulatory requirements: the basic situation of the security incident and the potential impact, the measures we have taken or will take to address it, suggestions for you to independently prevent and reduce risks, and the remedial measures for you. We will also promptly notify you of the relevant situation through emails, letters, telephone calls, notifications, etc. When it is difficult to notify each information subject individually, we will announce the incident through reasonable and effective means. At the same time, we will also report the handling of the information security incident to regulatory authorities as required.

8. Your Rights and Choices

8.1 You have the right to request that we delete your personal information

Under the following circumstances, you may request the deletion of your personal information:

  1. If our handling of personal information violates laws and regulations;
  2. If we collect and use your personal information without obtaining your consent;
  3. If our handling of your personal information violates this policy;
  4. If you no longer use Huanxi Game services, or you have cancelled your account;
  5. If we no longer provide Huanxi Games services to you.

You may exercise these rights through in-game settings, platform settings, customer service, or by contacting us at the email address listed below. If we decide to respond to your request for deletion, we will also notify third parties from whom we have obtained your personal information to request timely deletion, unless otherwise stipulated by laws and regulations, or the third party has obtained your separate authorization. When you delete information from our service, we may not immediately delete the corresponding information from backup systems, but we will delete this information when the backup is updated.

8.2 You have the right to cancel your account at any time

After canceling your account, we will stop providing you with products or services, and the content, information, data, records, etc. under the account will be deleted or anonymized (unless otherwise required by laws and regulations or required by regulatory authorities); at the same time, once the Huanxi Game account is canceled, it cannot be recovered.

When you choose to cancel your Huanxi game account, or under circumstances stipulated by relevant national laws and regulations, your Huanxi game account will be canceled. After the account is canceled, we will delete your personal information upon your request, unless otherwise stipulated by laws and regulations.

Please note that when querying, copying, correcting, updating, changing, deleting the aforementioned information, or cancelling your account, we may require you to provide personal sensitive information such as your phone number and identity card number for verification with the real-name authentication information of the account, to determine your true identity; the aforementioned sensitive information is only used for verification purposes and will not be retained by customer service. At the same time, please understand that due to technical limitations, legal or regulatory requirements, if we have reasonable grounds to believe that these requests are fraudulent, impossible to implement, or infringe on others' privacy rights, we will refuse to process the requests.

If you have logged in to Huanxi Game Service through a game co-operation channel (such as a brand phone or a third-party app store) and request to cancel your account, then you need to apply for account cancellation or revoke the authorization to log in to our services with that channel. Cancelling the account means that you will no longer be able to log in to Huanxi Game Service through that channel account, and once the channel account is cancelled, it cannot be restored. Please back up all related information and data before you proceed.

8.3 Restrict the automatic decision-making of information systems

In certain business functions, we may make decisions based solely on non-human automatic decision-making mechanisms such as information systems and algorithms. If these decisions significantly affect your legal rights and interests, you have the right to request an explanation from us, and we will also provide appropriate remedies.

8.4 Respond to your above request

To ensure safety, you may need to provide a written request, or otherwise prove your identity. We may first require you to verify your identity before processing your request. If you have any questions or other requests, you can also contact us through the contact information published in Article 10 of this policy. We do not charge fees in principle for your reasonable requests, but for repeated, excessive requests beyond reasonable limits, we will charge certain costs at our discretion. For those requests that are needlessly repetitive, require excessive technical means (e.g., require the development of new systems or fundamentally change current practices), pose risks to the legal rights of others, or are very impractical (e.g., involving information stored on backup tapes), we may refuse.

8.5 In the following cases, we will be unable to respond to your request

  1. Related to the obligations that the personal information controller must fulfill in accordance with laws and regulations;
  2. Directly related to national security and defense security;
  3. Directly related to public safety, public health, major public interests;
  4. Directly related to the exercise of investigation, prosecution, trial, and execution of judgments, etc.;
  5. The personal information controller has sufficient evidence to show that the personal information subject has subjective malice or abuse of rights;
  6. For the purpose of maintaining the major legitimate rights and interests of the personal information subject or other individuals, such as life and property, which are difficult to obtain consent from the person concerned;
  7. Fulfilling the request of the personal information subject would result in serious harm to the lawful rights and interests of the personal information subject or other individuals or organizations;
  8. Involving business secrets.

9. Protection of Minors

We attach importance to the protection of minors. If you are a minor under applicable law, you must obtain consent from your parent or legal guardian before using the Services. Parents and guardians should supervise minors' use of the Game and contact us if they believe a minor has provided personal information without appropriate consent.

Where required by applicable law, we may collect guardian contact information, identity verification information, anti-addiction or real-name verification information, and other information necessary to protect minors and comply with legal obligations. We do not knowingly collect more information from minors than is necessary for the Services, safety, compliance, and guardian-requested support.

10. International Transfers

Depending on your location, our servers, service providers, SDK providers, and publishing partners may process information in different countries or regions. When personal information is transferred across borders, we will take measures required by applicable law to protect your information, such as contractual safeguards, security assessments, consent mechanisms, or other lawful transfer mechanisms.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in the Services, technologies, SDKs, legal requirements, or business practices. When we make material changes, we will provide notice through in-game notices, website announcements, pop-ups, platform notices, or other appropriate methods. The updated Privacy Policy will become effective on the effective date stated above unless otherwise required by law.

12. Contact Us

If you have any complaints or reports about network information security, or if you have any questions, opinions, or suggestions about this Privacy Policy or our handling of personal information, please contact us in a timely manner. You may contact game customer service through in-game feedback, or send an email to dev@joyship.cn.

We will review your request as soon as possible, verify your identity where necessary, and respond within a reasonable period or within the period required by applicable law.

13. Governing Law and Dispute Resolution

This Privacy Policy shall be governed by the laws applicable to the operator of the Services, unless otherwise required by mandatory laws in your jurisdiction. Any dispute arising from this Privacy Policy should first be resolved through friendly negotiation. If negotiation fails, the dispute may be submitted to the competent court or dispute resolution body as permitted by applicable law.

[Shenzhen Huanxi Huyu Network Technology Co.LTD]

June 24, 2024