User Privacy Policy EN AS

FunPlus Account Privacy Policy

Last updated on: February 11, 2022

FunPlus (the “Company”, or “we”, “us” and “our”) respects your privacy rights and takes the protection of your personal information seriously. This Privacy Policy is designed to inform you about how we collect and process your personal information in connection with FunPlus account services provided by the Company and how you can manage your personal information. Please read this Privacy Policy carefully before using our FunPlus account services (the “FunPlus Account Services”), especially those parts that are in bold.

This Privacy Policy does not apply to the collection and processing of information by third parties in connection with products or services (including any third-party websites) offered in the FunPlus Account Services, which may include other products or services linked to the FunPlus Account Services. If you use these third-party services (including any personal information you provide to such third parties), you will be subject to the terms of service and privacy policies of those third parties (but not this Privacy Policy), as specified in the relevant terms of those third parties.

We protect the personal information of minors as per the relevant laws and regulations of the issuing region. If you are a minor under the age of 14, or under the age of majority as defined by the relevant personal information protection laws of the issuing region, you shall read and agree to this Privacy Policy under the supervision and guidance of your parents or other guardians before using the FunPlus account services.

If it is found that the personal information of minors has been collected without prior legal consent, we will try to delete the relevant information as soon as possible. If you are the guardian of a minor, please contact us through the contact information provided in this Privacy Policy when you have questions about the personal information of the minor under your guardianship or if you would like to request correction or deletion of the minor’s personal information.

This Privacy Policy is established in accordance with the laws and regulations for the protection of personal information in the issuing region. The term “personal information” in this Privacy Policy refers to any kind of information that relates to identified or identifiable natural persons recorded electronically or otherwise (excluding anonymized information).

This Privacy Policy will help you understand the following:

The types of personal information we collect and the purposes for which we collect it
How we collect and process personal information from minors
Notification of Cookies and related technologies
How we entrust the processing and sharing of your personal information
How we protect your personal information
How we store your personal information
Your rights as a subject of personal information
Updates to this Privacy Policy
How to contact us

1 Types of Personal Information We Collect and the Purposes for Which We Collect Them

When you register and login to your account, you must complete a series of registration or login procedures as per our instructions, in which you need to provide us with a cell phone number or e-mail address to receive a verification code matching your personal identity in order to complete the registration/login.
In order to meet the relevant laws, regulations and policies in certain issuing regions and the real-name requirements of certain competent authorities, you will need to provide us with your name, phone number, and proof of identity when registering for an account or using the FunPlus Account Services in those issuing regions. Such information is sensitive, and refusal to provide real-name authentication information may result in you being unable to log in or have certain restrictions imposed upon you in the game.
When you access the FunPlus Account Services to set up your player profile, you are free to change your player name and set up your avatar by taking a photo or uploading from the photo album. When setting up your avatar in the aforementioned way, you will need to grant us access to your device’s photo album or turn on the camera.
When you contact us via online customer service, we will record your communication with us so that we can better answer your questions.
To protect the FunPlus account services and your account security, as well as ensure the quality and efficiency of service operations, we will automatically collect information about your device, including: Hardware model, OS version number, device name, device configuration, international mobile device identifier, unique device identifier, network device hardware address, IP address, WLAN access point, Bluetooth, base station, software version number, network access method, type and status, network quality data, operation, usage, and service logs.
In order to prevent malicious programs and secure the FunPlus Account Services, we will also automatically collect information about installed applications or running processes, overall operation, usage and frequency of applications, application crashes, overall installation and usage, performance data, and application sources.
Your location information. We will get your consent before obtaining your geographic location information. If you agree and turn on the device’s location services, we may collect your geographic location. You can turn off the location services in [Settings] – [Application Name] – [Location] of your phone, and we will stop collecting your geographic location information.

We may share, transfer, and publicly disclose personal information without your prior authorization and consent, in accordance with the relevant laws and regulations of the issuing region, in the following cases

(1) For those relating to national security and national defense;

(2) For those relating to public safety, public health, and significant public interest;

(3) For those relating to, among others, crime investigation, prosecution, trial, and execution of judgments.

(4) For the protection of your or other individuals’ life, property, and other significant legitimate rights and interests but for which it is difficult to obtain your consent;

(5) Where needed for academic research institutions to conduct a statistical or academic research in the public interest, and where the results of the academic research or description are made available to the public and the information contained in the results is de-anonymized;

(6) For the reporting of news and the monitoring of public opinion in the public interest;

(7) Where necessary to enter into and execute relevant agreements or other written documents with you;

(8) Where the personal information collected has been disclosed by you to the public at your own discretion;

(9) In other cases as stipulated by laws and regulations.
Please understand that we will generally only use your personal information for the purposes listed in this Privacy Policy or as otherwise communicated to you at the time we collect personal information from you. However, in order to protect the legitimate rights and interests of you or others and the public interests, we may also use your personal information for purposes related to the aforementioned purposes or for other purposes permitted by law and regulations.

2 How We Collect and Handle Personal Information from Minors

If you are the guardian of a minor, we will collect personal information (including name, ID number, address, and proof of guardianship) about you and the minor under your guardianship when you submit a parental guardianship application to us in order to verify the guardianship relationship between you and the minor and the minor’s account affiliation. If a third party objects to the ownership of the FunPlus account under application control, you agree and authorize us to provide your and the minor’s personal information to that third party or to the competent authorities.

3 Notification of Cookies and Related Technologies

To ensure the proper functioning of the website or mobile application, we store small data files called Cookies on your computer or mobile device. Cookies usually contain an identifier, the name of the website, and some numbers and characters. We will store your character information with the help of Cookies. Cookies and related technologies help websites identify and count the number of registered users, and are often used by websites to determine whether a user who has completed registration has logged in. We use Cookies and related technologies primarily for the following functions or services:

Ensuring the safe and efficient operation of products or services. We may set Cookies for authentication and security purposes to confirm that you are securely logged in to the service or whether you have experienced theft, fraud, or other wrongdoings. These technologies also help us improve the efficiency of our services and speed up the login and response process.
Simplify your operating procedures. These technologies can help you eliminate the need to repeatedly fill out personal information and enter search content, allowing you to have an easier access experience.
We do not use Cookies for any purposes other than those described in this statement. You may manage or delete Cookies as preferred. However, if you do so, in some cases it may affect your ability to access our website or application securely, and it may require you to manually change your user settings each time you visit our website or mobile application.

4 How We Entrust the Processing and Sharing of Your Personal Information

In order to improve the efficiency of information processing and better provide you with our services, we may share your personal information with our partners or within group companies, and we will enter into strict confidentiality agreements with them, requiring them to handle the personal information in accordance with our requirements, this Privacy Policy, and confidentiality and security measures required by laws and regulations.

We may share your personal information with third parties in the following circumstances:

If the relevant laws, regulations, and policies of certain issuing regions and relevant authorities contain special provisions for real-name requirements, we may provide your name and ID number to the anti-addiction system of such regions so that they can provide us with real-name authentication services in order to achieve the information handling purposes described in this Privacy Policy.
To relevant law enforcement agencies, regulators, governments, courts, or other third parties where such disclosure is deemed necessary by us to (i) comply with an applicable law or regulation; (ii) exercise, establish, or defend our legal rights; and (iii) protect the important legal interests of you or any other person.
In the event of a change in us or a proceeding involving a merger, separation, dissolution, or declaration of bankruptcy that involves the transfer of personal information, we will notify you of the name and contact information of the recipient. The Company or organization that receives your personal information will continue to handle your personal information in accordance with the contents disclosed in this Privacy Policy. If a new Company or organization holding your personal information needs to use your personal information for a purpose not described in this Privacy Policy, the new Company or organization shall obtain your consent in accordance with applicable laws and regulations.
With your consent to other third parties for the purposes we have informed you about.

Besides these circumstances, we will not share your personal information with any third party other than the parties mentioned above without your consent (except where otherwise provided by applicable law). We will enter into strict confidentiality agreements with companies, organizations, and individuals who share your personal information, requiring them to handle your personal information in accordance with our instructions and any other relevant confidentiality and security measures.

5 How We Protect Your Personal Information

We will take appropriate technical and administrative measures to protect the personal information we collect and process from unauthorized access, public disclosure, use, modification, damage, or loss. For example, we will regularly de-identify and anonymize unused FunPlus accounts and unnecessary data.

Please be aware and understand that the Internet is not an absolutely secure environment. If you discover that your personal information has been compromised, please contact us immediately via the contact information in the “How to Contact Us” section of this Privacy Policy so that we can take appropriate measures.

In the event that your personal information is leaked due to an accident or force majeure, we will make every effort to control the situation and promptly inform you of the cause of the incident, the security measures we have taken, the security measures you can take on your own accord, and other relevant information. In the event of a security incident related to personal information, we will report it to the relevant competent authority for the record, promptly investigate the cause and take emergency measures in accordance with the requirements of relevant laws and regulations.

6 How We Store Your Personal Information

We will store your personal information collected within the issuing region in accordance with the requirements of the applicable laws and regulations of the issuing region. If we need to transfer your personal information abroad, we will explain the details to you, obtain your consent, and complete the corresponding security assessment and authentication in accordance with the requirements of the laws and regulations of the issuing region.

Unless otherwise required by law or regulation, we will store your personal information for the minimum period necessary to meet our legitimate business needs and for the period of time required by the relevant laws, regulations, and supervision requirements, such as to provide services to you, to meet appropriate legal requirements, or for dispute resolution purposes. After the storage period has expired, we will either delete your personal information or anonymize it.

7 Your Rights as a Subject of Personal Information

You have the right to exercise your statutory rights as a subject of personal information under the laws of the issuing regions, such as the right to request access to, correct, update, copy, or delete your personal information collected and processed by us, or to restrict or refuse such collection and processing. You may do so by:

Accessing and updating your personal information: You can view your account information by clicking on your avatar – Settings – Account within your FunPlus account.

You may make a request to delete your personal information in the event that:

Our handling of your personal information violates laws and regulations.
We handle your personal information without your consent.
Our handling of your personal information violates our Agreement with you.
You no longer use our services, or you have canceled your account.
We terminate the operation and services of your FunPlus account or the storage period for your personal information expires.

If difficulties arise in accessing, correcting, updating, or deleting your personal information directly within the FunPlus Account Services, you may exercise your rights by contacting us via the contact information in the “How to Contact Us” section of this Privacy Policy.
Certain business functions within the FunPlus Account Services will require your information or the device access you have granted to work. You have the right to withdraw your consent by changing the settings of your mobile device, turning off the corresponding business function or deleting your personal information. When you withdraw your consent, we will not be able to continue providing you with the corresponding functions and will no longer process your personal information. However, your decision to withdraw your consent will not affect the processing of your personal information that we have previously carried out based on your authorization.
You can contact us for assistance in copying or transferring your personal information.
You may request to cancel your account at any time by contacting our Customer Services. After you cancel your account, we will stop providing you with services and no longer process the personal information associated with that account.
You can click on the “Unsubscribe” link at the bottom of the email you have received. If you do not wish to receive text messages from us, you can follow the instructions in the text message and select “Unsubscribe”.
We will respond to all requests we receive from our users to exercise the rights of the subject of personal information in accordance with the requirements of applicable personal information protection laws in a timely manner. In principle, we do not charge a fee for your reasonable requests, but we will charge a fee for repeated requests that exceed reasonable limits, depending on the circumstances.

As per the relevant laws and regulations, we may not be able to respond to your request for exercise of rights in the following cases:

If your request is contrary to our obligations under laws and regulations;
If the requested information is directly related to the security of the issuing region or national defense;
If the requested information is directly related to public safety, public health, or significant public interest;
If the requested information is directly related to a criminal investigation, prosecution, trial, and enforcement of judgments;
If we have sufficient evidence of subjective malice or abuse of rights on your part;
If it is necessary to protect the significant legitimate rights and interests of yourself or others such as life and property, but for which it is difficult to obtain your authorization and consent;
If responding to your request to exercise your rights would result in serious damage to the legitimate interests of you or other individuals or organizations;
If the requested information involves trade secrets;

If we terminate our services or operations, we will notify you at least thirty (30) days in advance, and we will delete, anonymize, or de-identify your personal information after the termination of services or operations.

8 Updates to this Privacy Policy

We will update this Privacy Policy from time to time to keep up with legal, technical, and commercial changes. When we make updates to this Privacy Policy, we will notify you in a manner appropriate to the significance of those changes. We will obtain your consent to any material changes to this Privacy Policy as required by applicable personal information protection laws.

We will issue the most current version of this Privacy Policy throughout the FunPlus Account Services. You can find out when this Privacy Policy was updated by checking “Last Updated on” at the beginning of this Privacy Policy. If you continue to use our products or services, you agree to accept this Privacy Policy as updated.

9 How to Contact Us

If you have any questions or concerns about how we use your personal information or this Privacy Policy, and in particular if you believe that our handling of your personal information has harmed your legal rights and interests, you may contact us using the contact information below or have a live session with us through “Live Chat” in the FunPlus Account Services. We will review the issue as soon as possible and respond in a timely manner in accordance with legal requirements and deadlines.

Email: [support@funplus.com]
Personal Information Protection Officer: If you have any complaints or reports about personal information security issues, please send an email to support@funplus.com. Contact our Personal Information Protection Officer, and we will receive and handle the query within 15 working days.

The providers of the FunPlus account services include: FunPlus International AG (Bahnhofstrasse 2, 6300 Zug, Switzerland); and FunPlus Group and its affiliates. Please refer to the account description for the specific service provider of the account.