Welcome to 欢乐斗地主 (Happy Poker)!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with 欢乐斗地主 (Happy Poker, the “Service”), and sets out your choices and rights in relation to that information. Please read it carefully – it will allow you to understand how we collect and use your information, and how you can control it.

Please note that this Privacy Policy only applies to the Service. If you use any other products or services please refer to the privacy policy for that particular product or service.

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Service. By using the Service you are acknowledging how we process your personal information as described in this Privacy Policy.

For the purpose of data protection laws, the data controller of your personal information in relation to the Service is Proxima Beta Pte. Limited (“we”, “us”, “our”).

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here. You can also reach out to our data protection officer at dpo_happypoker@levelinfinite.com. We have representatives for data protection purposes listed here.

1. Children

Children must not use the Service for any purpose. By children, we mean users under the age of 18 years old; or in the case of a region where the minimum age for processing personal information differs, such different age.

We do not knowingly collect personal information from children for any purpose. If you believe that we have personal information of a child under these ages without lawful consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us.

2. How We Process Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why.

To the extent required under applicable data protection law, it also identifies the legal basis under which we process your data.

Personal Information	Use	Legal Basis (where applicable)
Information you provide to us (either directly or through a third party)
Account registration information: · Identity information: OpenID, username · Device information: Screen resolution, CPU architecture, device system version, screen orientation · IP address · When you login with WeChat: WeChat profile picture and username / nickname information, device model information (e.g. iPhone 15)	We use identity information to: · create your account for the Service and for login purposes; and · conduct daily statistic analysis (e.g. on the number of active users) to improve the game.	Account registration: Necessary to perform our contract with you to provide the Service. Daily statistic analysis: It is in our legitimate interest to improve the Service.
	We use device information to maintain the smooth operation of the game, including debugging.	It is in our legitimate interest to ensure the security of our Service.
	We use IP address to monitor cheating and other malicious activities in the Service.	It is in our legitimate interest to use this information to detect and prevent cheating behaviours in the Service.
Information collected and generated as part of the Service
Game data: · Identity information: OpenID, game account (used by players when they log in to the game) · Device information: CPU usage rate, WiFi SSID, CPU model, GPU information, device system version, WIFI address · Other information: Application version, application package name, process name, IP address, network type, operator name, login channel ID, game log information (item log, operation information, game match information, dating information, etc.)	We use device information to: · ensure your normal use of the game, maintain the normal operation of the game functions; and	Necessary to perform our contract with you to provide the Service.
	· optimize the performance of this game product based on your device terminal and network status, improve your gaming experience, and ensure the security of your account.	It is in our legitimate interest to ensure the security of our Service and to optimize the gaming experience for you.
	We use identity information to locate bugs and potential problems in the Service to improve the Service and its functionality.	It is in our legitimate interest to ensure the security of our Service and to optimize the gaming experience for you.
	We use the other information to enable you to use the Service normally and to analyze game security and vulnerabilities.	Necessary to perform our contract with you to provide the Service.
Payment data (in-app via Midas, Google Play or App Store): · Identity information: OpenID · Other information: IP address, recharge records and consumption records from the last 30 days	If you make in-app purchases using Midas, Google Play or App Store, we collect your recharge and consumption information to: · answer your enquiries about your transactions; and	Necessary to perform our contract with you to faciliate in-app purchases.
	· monitor and combat illegal purchasing activities.	It is in our legitimate interests to ensure the integrity of the Service and protect users from prohibited conduct.
Customer support information (in app and email): · Identity information: OpenID, telephone number (optional), game account（used by players when they log in to the game） and username · Device information: device name, Whether it is running in the simulator · Other information: In-game screenshots, application package This will be processed momentarily but will not be stored on our servers.	We use this information to verify your identity and respond to your enquiries and resolve the issues identified.	Necessary to perform our contract with you to provide customer support for the Service.
Reporting information: · Identity information: OpenID · Other information: Game behaviour information, such as item ID, item number, game mode, game length, views and clicks of different modules of the game	We use this information to conduct data analysis in order to understand users’ gaming preferences, improve users’ game experience and to detect abnormalities.	It is in our legitimate interest to ensure the functioning of, and improve, the Service.
Performance optimisation data: · Identity information: OpenID · Device information: CPU model, CPU usage rate, device system version, screen orientation, screen resolution, RAM, ROM, device manufacturer, CPU architecture, device model, device standard · Other information: Network Type	We use this information to: · optimize the gaming experience; and	It is in our legitimate interest to ensure the functioning of, and improve, the Service.
	· to quickly locate problems and perform troubleshooting.	Necessary to perform our contract with you to provide the Service.
Game experience data: · Identity information: OpenID · Device information: Screen resolution, CPU model, CPU architecture, disk information, device model · Other information: Network type This information is processed momentarily but is not stored on our servers.	We use this information to improve users’ gaming experience and to improve the Service.	It is in our legitimate interest to ensure the functioning of, and improve, the Service.
Anti-cheating information: Information retrieved from game logs, such as Open ID, device information (e.g. CPU usage rate, WiFi SSID, CPU model, GPU information, device system version, WIFI address), gameplay data	We use this information to provide a fair environment, and ensure the security and safety of the services of the game (through anti-cheat functions like cheating countermeasure and detection based on game replay).	It is in our legitimate interest to use this information to detect and prevent cheating in the Service.
Game profile data: Nickname, userID, in-game currency amount and game play statistics (e.g. level, scores, match history)	If you enable this feature, we use this information to allow other players to view your game profile.	It is in our legitimate interest to allow players to access all features of the Service and provide an enjoyable gaming experience.

3. How We Store and Share Your Personal Information

We may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy.

We have servers for the Service in Singapore. The servers applicable to your use of the Service will depend upon your choice of server and/or location. We also have support, engineering and other teams who may support the Service, including from Singapore.

For EEA/UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses, or taking into account adequacy assessments.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

· Third parties that provide services in support of the Service, including providers of services that process information identified in this policy for the purpose of providing the Service. All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Service (i.e., for the purpose(s) described above).

· Companies within our corporate group who process your personal information solely for the purpose of providing the Service to you, which may include facilitating purchases and for customer support purposes. All such group companies may only use your personal information in accordance with this Privacy Policy.

Regulators, judicial authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you, such as to comply with legal obligations or processes. In complying with the terms of valid legal processes, such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in advance of such disclosure.
Third parties to ensure safety, security, or compliance with laws. We may disclose your information to:

enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
detect, prevent or otherwise address security, fraud or technical issues; or
protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (such as exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

4. The Security of Your Personal Information

We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Service or otherwise via the Internet; any transmission is at your own risk.

5. Data Retention

We do not keep your data for longer than is necessary to fulfil the relevant purpose described above unless we are required or permitted to do so under law. If we retain your information beyond the retention periods set out below, for example to comply with applicable laws, we will store it separately from other types of personal information.

For further details on how long we keep your data, please refer to the time periods set out below.

Personal Information	Retention Policy
In relation to the Service
Account registration information Game data Payment data Reporting data Performance optimisation data Anti-cheating information Game profile data	Stored for the lifetime of your use of the Service and then deleted within 30 days thereafter or deleted manually within 30 days from our receipt of your account deletion request (whichever is earlier).
Customer support information Game experience data	We do not store this data.

6. Your Rights

Some jurisdictions’ laws grant specific rights to users of the Service. Please refer to the Supplemental Jurisdiction-Specific Terms, or the applicable laws in your jurisdiction, for an overview of specific rights that apply to persons subject to data protection laws in the listed jurisdictions and how these can be exercised.

You may have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). You can exercise some of these rights directly by accessing and updating the information in your account. If you believe we hold any other personal information about you, please contact us.

Access

You may have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account.

Portability

You may have the right to receive a copy of certain personal information we process about you. For example, in certain jurisdictions this can comprise personal information we process pursuant to our contract with you (e.g., username), as described above in the section “How We Use Your Personal Information”. We will provide further information to you about transferring this data if you make such a request.

Correction

You may have the right to correct personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account.

Erasure

You may be able to delete your account, or remove certain personal information that we hold about you. We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Service and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only

You may have a right to require that we stop processing the personal information we hold about you (other than for storage purposes in certain circumstances). Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). Where we agree to stop processing the personal information, we will take steps to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You may have the right to object to our processing of your personal information. If you wish to do so, please contact us using the contact details at Section 7 (Contact), and we will consider your request.

Consent Withdrawal

To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us at Section 7 (Contact). Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the Service for maintenance, or security, privacy or administrative-related communications). These are essential system and service-related announcements and you are not able to opt-out of these notifications, which are not promotional in nature.

7. Contact

Please get in touch with us if you have any questions. You can reach us in the first instance at:

Email: dpo_happypoker@levelinfinite.com

Mailing Address:

Tencent International Privacy & Data Protection Centre

30 Raffles Place #19-01

Singapore

048622

We will endeavour to deal with your request as soon as possible. This is without prejudice to any right you may have to launch a claim with a data protection authority in the region in which you live or work where you think we have infringed data protection laws.

8. Changes

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy.

9. Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this Privacy Policy, the English version shall prevail.

Our Representatives in Certain Jurisdictions

Jurisdiction	Representative	Address	Contact details
EU	Proxima Beta Europe B.V.	Buitenveldertselaan 1-5, 1082 VA, Amsterdam, the Netherlands	dpo_happypoker@levelinfinite.com
UK	Image Frame Investment (UK) Limited	4th Floor 80 Strand, London, United Kingdom WC2R 0RL	dpo_happypoker@levelinfinite.com
Thailand	Tencent (Thailand) Company Limited	8 T-One Building, Floor 10th, 11th & 12th (Unit 3-5), Soi Sukhumvit 40, Sukhumvit Road, Khwaeng Phra Khanong, Khet Khlong Toei, Bangkok 10110, Thailand	dpo_happypoker@levelinfinite.com
Türkiye	Özdağıstanli Ekici Avukatlık Ortaklığı.	Nidakule Ataşehir Kuzey Begonya Sok. No:3 Kat. 17 D: 162 34746 Ataşehir / İstanbul, Türkiye Özdağıstanli Ekici Avukatlık Ortaklığı is our data controller representative and its authority is limited to the authorities stipulated under the Law on Protection of Personal Data w. no 6698. Özdağıstanli Ekici Avukatlık Ortaklığı is not authorised for any other matters such as in-game conduct, suspensions, investigations, civil or criminal complaints.	turkeydatarep_proximabeta@iptech-legal.com
Serbia	Karanovic & Partners o.a.d. Beograd	Resavska 23, Belgrade, 11000, Serbia	local.representative@karanovicpartners.com

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Service, which are set out in this section. If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.

Indonesia

By accepting and consenting to this Privacy Policy, you agree that we may collect, use and share your personal information in accordance with this Privacy Policy, as revised from time to time. If you do not agree to this Privacy Policy, you must not access or use our services and we have the right to not provide you with access to our services.

In the event we fail to maintain the confidentiality of your personal information in the Service , we will notify you through the contact information provided by you or via the Service, to the extent required by local laws and regulations.

You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

Malaysia

Right of access: You have the right to request access to and obtain a copy of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law. When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

Right of correction: You may request for the correction of your personal information. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.

Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details provided above. However, this may affect our provision of the Service to you.

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

Our data protection officer, responsible for the management and safety of your personal information

Telephone: +603-22872388
Email: dpo_happypoker@levelinfinite.com

Philippines

You are entitled to the following rights:

Right to be informed. You may in certain circumstances have the right to be informed whether personal data pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.
Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for automated processing or profiling.
Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.
Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.
Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.

By consenting to this Privacy Policy, you consent to us:

· collecting and processing your personal information as described in Section 2 (How We Process Your Personal Information);

· sharing your personal information with third parties, companies within our corporate group, and a third party that acquires substantially all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and

· transferring or storing your personal information in destinations outside the Philippines as described in Section 3 (How We Store and Share Your Personal Information)

Serbia

Our designated local representative in Serbia is Karanovic & Partners for the purposes of compliance with the Law on Personal Data Protection, and can be contacted at local.representative@karanovicpartners.com. Please include the word “Serbia” in the subject line of your email.

Name: Karanovic & Partners o.a.d. Beograd
Address: Resavska 23, Belgrade, 11000, Serbia
Telephone Number: +381 11 3094 200

E-mail: local.representative@karanovicpartners.com

Singapore

By accepting this Privacy Policy, you consent to the collection, use and disclosure of personal data as set out in this Privacy Policy, including cross-border transfer of your information to any country or region where we have databases or affiliates and, in particular, the locations specified in Section 3 (How We Store and Share Your Personal Information). In situations where consent is not obtained, Proxima Beta collects, uses, or discloses personal data in accordance with an exception under the Personal Data Protection Act 2012 or as required or authorized by any other applicable law.

You have the right to access your personal information, how we use it, and who we share it with. You have the right to correct any of your personal information that is inaccurate.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted here.

Thailand

By accepting this Privacy Policy, you acknowledge that you have read, understood, and agree to the Privacy Policy. If you do not agree with the Privacy Policy, you must not use the Service.

To the extent provided for by the Thai Personal Data Protection Act (PDPA), you may:

· withdraw your consent to the processing of your personal data (only where the legal basis for our processing is consent); however, please note that where consent is required to process your personal data, we may not be able to deliver the expected service without it;

· request us to provide you access to, make any correction to, cease any automated processing or profiling (if applicable), discontinue, restrict the use or provision of and/or erase your personal data;

· request us to provide you or a third party with your personal data which is stored by us in a machine readable format; and/or

· lodge a complaint to a relevant authority.

Where you wish to make such requests, please contact us.

The contact details of our designated local representative in Thailand for the purposes of compliance with the PDPA is as set out in Section 7 (Contact) and can be contacted via email. Please include the word “Thailand” in the subject line of your email.

Türkiye

You have legal rights, which are set forth in Article 11 of the Turkish Law on Personal Data Protection Law (“DPL”), in relation to the personal information data we hold about you. As a Turkish data subject, you may have the right to apply to the data controller and (to the extent permitted under applicable laws and regulations):

learn whether or not your personal data has been processed;
request information about processing if your personal data has been processed;
learn the purpose of processing of your personal data and whether they have been used accordingly;
know the third parties in the country or abroad to whom personal data has been transferred;
request rectification in the event personal data is incomplete or inaccurate and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the DPL and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
object the occurrence of any consequence that is to your detriment by means of analysis of personal data solely through automated systems; and
demand compensation for the damages that you have suffered as a result of unlawful processing of your personal data.

In accordance with Article 9 of the DPL, your personal data may be transferred abroad as follows:

Identity of the overseas recipient

Location of the recipient (or as otherwise stated in the recipient’s privacy policy)

Purposes of use of Personal Information by the recipient

Items of Personal Information to be provided

Tencent Cloud

(cloudlegalnotices@tencent.com)

Singapore

Storage of personal information

All personal information collected

Midas

Singapore

In-app purchases

Payment data

United States

For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”), and respectively include the terms “personal data” and “sensitive data” as defined in the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”), (collectively, “US State Laws”).

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed for a business purpose the following categories of personal information from or about you or your device:

Identifiers, such as your username, Open ID / role ID, IP address. This information is collected directly from you and your device.
Personal information categories listed in the California Customer Records statute, including information covered by other categories such as you phone number. This information is collected directly from you.
Internet or other electronic network activity information, such as your information regarding your use of the Service and game behaviour information. This information is collected directly from you and your device.
Commercial information about any transactions within the Service such as what products were purchased and how much they cost. This information is collected directly from you and your device.
Account log-in information, including the username used to access your Service account.

We collect and disclose your personal information for the following purposes:

To provide you with the Service, maintain your account, provide customer service, provide consumption records.
To improve our services, including the functionality of the Service.
For security and verification purposes, including to prevent and detect fraudulent activity.
To address and remediate technical issues and bugs.

For additional information about what each type of personal information is used for, see Section 2 (How We Process Your Personal Information).

We disclose each of the categories of personal information that we collect to the following types of entities as described in Section 3 (How We Store and Share Your Personal Information).

In the past 12 months, we have not sold or shared personal information of California residents within the meaning of “sold” and “Share” in the CCPA. And we have no knowledge of any sale or sharing of personal information of users under 16 years of age.

In addition, we do not use or disclose sensitive personal information for purposes other than to perform the services reasonably expected by an average consumer who requests those services or as otherwise permitted by US State Laws.

Retention of Your Personal Information

The retention period varies among the different categories of data collected. For detailed information about the retention period for any specific category of data, see this chart in the main portion of the Privacy Policy.

Rights under US State Laws

Depending on where you live, you may have some or all of the rights listed below in relation to information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law:

Right to Access/Know. Request we confirm whether we process information about you and give you access to that information. You may also request to receive that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment. If you are a California resident, you may request the following information about our collection, use and disclosure of your information:

the categories of personal information about you that we collected;
the categories of sources from which the personal information was collected;
the business or commercial purposes for collecting personal information about you;
the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
the specific pieces of personal information we collected about you;

Request to Delete. Request we delete personal information we collected from you;
Request to Correct. Request we correct inaccurate personal information that we maintain about you; and
Right to Non-Discrimination. Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the US State Laws.

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. Depending on where you live, you may also exercise your rights, you may also exercise your rights, if any, regarding other data by contacting us as specified in Section 7 (Contact). We may take steps to verify your identity before complying with your request to protect your privacy and security, and may decline your request if we are unable to verify your identity. To verify your identity, we may need the following information from you: your first name, last name, address, phone number, date of birth and email address.

Depending on where you live, you may exercise these rights yourself or you may also designate an authorized agent to make these requests on your behalf. In order for us to process the request, you must provide the authorized agent with signed written permission. We reserve the request to require the agent to verify their own identity and to confirm directly with you that you have provided the authorized agent permission to submit the request.

In addition, where applicable, we will provide you with more information about our appeal process. When you submit a request or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfil your request or process your appeal. We will not require you or your authorized agent to pay a fee for the verification of your request or appeal.

Questions

If you have questions or concerns regarding this Privacy Policy, please contact us as set out in Section 7 (Contact).

*What information do we need to be able to provide the Service?*	In relation to the Service: · If you register an account to use the Service then we will need some information from you to set this up. This includes your username, IP address and your device information. We will also generate an Open ID, which is an internal ID for your account. · To maintain the smooth operation of the Service (which includes activities such as from addressing bugs or malicious activity through to improving functionality), we will process customary device and network information (such as IP address and device specifications, as well as app- and OS-generated identifiers). · To enable you to enquire about in-app purchase records, we will collect your recharge and consumption records from the last 30 days. · If you need to get in touch with us, we will retain some information (such as your player identity information, device information and interactions with our help services) so that we can review and respond to your concerns.	More Information.
*How will we use your information?*	· We use your information to set up your account, enable you to use the Service, improve your game experience, facilitate in-app purchases, ensure the safe and secure operation of the Service, address bugs, optimise and improve the Service, protect users, resolve user queries, and allow us to get in touch with you. · We also use your information to comply with our legal obligations and enforce our legal rights.	More Information.
*Who do we share your information with?*	· We use third parties and work with our affiliates to help us deliver the best possible experience (such as for data analytics purposes as well as for facilitating in-app purchases and customer support). · All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Service (i.e., to fulfil the purpose(s) described above). · In some cases we may be required by a court or be under a legal obligation (such as a valid search warrant or subpoena) to disclose certain information.	More Information.
*Where do we process your information?*	· We may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy. · We have servers for the Service in Singapore. We also have support, engineering and other teams who may support the Service, including from Singapore. · For EEA/UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses, or taking into account adequacy assessments.	More Information.
*How long do we keep your information?*	· Unless otherwise required or permissible by applicable laws, we retain your information for the period during which you maintain an account for the Service, or for so long as the information is needed to fulfil the purpose for which it was collected (as further described in this Privacy Policy). We then delete or anonymise such data, in accordance with applicable laws.	More Information.
*How can I exercise my rights over my information?*	· Certain jurisdictions offer users specific rights with respect to their information, so you may have a right to access or receive a copy of your data, or to delete your data or restrict or object to our processing of your data.	More Information.
*How will we notify you of changes?*	· Changes to this Privacy Policy will be posted here. We will also notify you of changes in accordance with relevant legal requirements.	More Information.