PRIVACY POLICY
Last revised:
[March 2021]
Welcome to
ZHANGYIN GAMES. This Privacy Policy explains our privacy commitment to
our players and users of our Services (hereinafter "Users"). This
Privacy Policy is incorporated as part of the ZHANGYIN GAMES Terms of
Use, accessible at [www.99zgc.com].
At ZHANGYIN
GAMES, we collect personal data to support our products and services,
while respecting all applicable laws, including but not limited to the
Personal Information Protection and Electronic Documents Act (PIPEDA),
and regulation (EU) 2016/679 of the European Parliament and of the
Council of 27 April 2016, directly applicable from May, 25th, 2018
(hereinafter, "General Data Protection Regulation", or "GDPR"). As
defined in the GDPR, "personal data" means any information relating to
an identified or identifiable natural person, directly or indirectly, in
particular by reference to an identifier such as a name, an
identification number, location data, an online identifier or to one or
more factors specific to the physical, physiological, genetic, mental,
economic, cultural or social identity of that natural person.
By using ZHANGYIN
GAMES’s services, you authorize ZHANGYIN GAMES and its affiliated
companies (collectively, "ZHANGYIN GAMES" or "we"), to process your
personal data according to this Privacy Policy. If you do not accept the
terms of this Privacy Policy, please refrain from using our online games
or our games’ online functionalities, our websites, our mobile apps and
any other online ZHANGYIN GAMES products and services (hereinafter
"Services").
1. WHAT PERSONAL INFORMATION DOES
ZHANGYIN GAMES COLLECT?
1.1 When you use ZHANGYIN GAMES
services
1.1.1 While
Browsing ZHANGYIN GAMES websites
Cookies. ZHANGYIN
GAMES uses cookies on the Services. A "cookie" is a small bit of
record-keeping information that web sites often store on a user's
computer. Cookies are not intended to include people's names, or other
information that is directly identifiable; rather, they are typically
used to quickly identify a user's device and to "remember" things about
the user's visit. ZHANGYIN GAMES may set cookies for your web browser as
you visit our websites, use our products, or visit a website where
ZHANGYIN GAMES provides ads, content or analytics. For example, ZHANGYIN
GAMES uses cookies to keep track of selected items in your shopping cart
on our online store, and to remember your Account identifier. You can
disable cookies or set your browser to alert you when cookies are being
sent to your computer, although this may affect your ability to shop
online or to access certain features of our Services. Each browser is
different, so check the "Help" resources for your web browser to learn
how to change your cookie preferences. In addition to ZHANGYIN GAMES
using cookies on our network of websites, ZHANGYIN GAMES may allow
certain partners to set and access their cookies on your computer. These
companies’ use of cookies is subject to their own privacy policies, not
the ZHANGYIN GAMES Privacy Policy. Please review them carefully.
IP addresses.
ZHANGYIN GAMES also collects Internet Protocol (IP) addresses for safety
and security reasons. An IP address is a number that is used by
computers on the network to identify your computer every time you log on
to the Internet.
Other passively
collected information. While browsing our sites, ZHANGYIN GAMES may, on
its own, or with the help of third-party tools, collect non-personally
identifiable information concerning your gaming hardware, habits,
behaviors and use of our Services. ZHANGYIN GAMES collects such
information to better adapt our Services to users’ interests, and for a
better quality of our Services. The information collected may contain
the following, without limitation: device unique identity, including MAC
address, mobile, unique identifier or other device identifiers and
settings, internet provider, carrier, operating system, hardware
information, localization information, date and time spent on the
Services, game scores, game metrics, achievements, rankings, time played
and statistics, feature usage, advertising conversion rates,
monetization rate, purchase history and other similar information.
1.1.2
Registering on a ZHANGYIN GAMES service
When you use our
Services, you may give us information directly (like when you’re setting
up your account). Some games or parts of our Services may also let you
create a registration or account where you may be asked to give us
information like: your username, password, email address, date of birth
(or age) and country of origin. This information is mandatory to create
an Account. On other Services, ZHANGYIN GAMES may ask you additional
personal information relevant to the Service such as your phone number,
home address, or geo-location information (for example, you will be
asked your home address when purchasing a product within our online
shop, in order for ZHANGYIN GAMES to deliver the product to your home
address).
1.1.3
Contacting ZHANGYIN GAMES
ZHANGYIN GAMES
may ask for your first name, family name, e-mail address and your date
of birth to answer your demands to the ZHANGYIN GAMES Customer Support,
to confirm any information or transaction on your ZHANGYIN GAMES
account, and to give you information regarding the Services (for
instance, if you lose your password or if we make changes to the Terms
of Use).
1.1.4 Participating
to contests and sweepstakes
ZHANGYIN GAMES
may offer you the opportunity to participate in online surveys,
questionnaires. To participate, you may need to provide your first name,
your family name, e-mail address, date of birth, your address and
country of residence. If you choose to participate in surveys and
questionnaires, your personal data may be processed to allow you to
participate, and for internal statistical use.
1.1.5
Interacting on forums
Whenever you
participate or interact with other users on a forum, ZHANGYIN GAMES
collects the content of your communications, the time and the location
of your activities, as well as your online ID and your IP address.
1.1.6 Advertisements
ZHANGYIN GAMES
uses third party ad-serving technologies that may collect information to
provide behavioral and non-behavioral advertisements within our
Services. The information collected and used for the targeted
advertising may contain the following, without limitation: age and
gender, number of views of an advertisement, device unique identifier or
other device identifiers and settings, information about your use of the
products and Services, other sites (including third party web pages and
mobile Internet sites) you have viewed (as well as date and time
viewed), advertisement(s) served, the advertisement(s)’ in-game location
and length, and your response to the advertisement(s) (if any). The
analytics tools and ad serving technologies may use server log files,
web beacons, cookies, tracking pixels and other technologies to collect
this information, and may combine the information collected on other
ZHANGYIN GAMES Services with information collected from other
third-party websites, products and services and with demographic,
advertisement, market and other analytics surveys. Standing alone, this
information is not personal data; however, if ZHANGYIN GAMES combines
any of this information with personal data, ZHANGYIN GAMES will treat
this information as personal data pursuant to this Privacy Policy.
1.1.7 Social
media and other third parties’ platforms
We collect the
Data that you have agreed to share via the social media site or
third-party platform in question when you sign into our Services with a
social login or your credentials from a third-party platform (for
example, Facebook, Google).
ZHANGYIN GAMES
may also collect personal information on third party social networks,
platforms or services. By playing a ZHANGYIN GAMES game through a social
network or other third party platform, or by connecting to such a third
party network, platform or service via one of our products and/or
Services, you authorize ZHANGYIN GAMES to (1) collect, store, and use,
in accordance with this Privacy Policy, any and all personal information
that you agreed the social network or third party platform could provide
to ZHANGYIN GAMES based on your settings on the social network or
platform, and (2) share any and all of your personal information with
the social network or other third party platform, through the social
network/third party platform’s Application Programming Interface (API).
You agree to this sharing when you connect with the third-party network,
platform or service via our products and/or services, and/or when you
connect with, "accept" or "allow" (or similar terms) one of our
applications through a social network, or other third-party platform or
service.
If you access our
Services from a third-party application or connect our Services to a
third-party application, you should also read that third-party
application’s terms of service and privacy policy.
1.2 Whenever you play games of
ZHANGYIN GAMES
1.2.1
Creation of user generated content
Some Services
give you access to tools in order to allow you to create and/or share
unique content. This User-Generated Content may be collected by ZHANGYIN
GAMES; this content may also contain your personal information or the
personal information of others (for instance, your name, or a picture of
you). Please exercise caution: ZHANGYIN GAMES is not liable for any
negative consequences linked to your disclosure of User-generated
content.
1.2.2 In-game
data collection
Whenever you use
the Services, ZHANGYIN GAMES may collect, store and process your in-game
data, including but not limited to: your game scores, game metrics,
achievements, rankings, time played and statistics, feature usage,
advertising conversion rates, monetization rate, purchase history and
other similar information. ZHANGYIN GAMES will use this information to
improve the Services, to personalize them to your interests, and
otherwise upgrade your gaming experience. Any information collected by
ZHANGYIN GAMES in accordance with Article 1 of this Privacy Policy may
also be used in an aggregated form to identify specific patterns
regarding the use of our Services.
1.3 Online payment
For some
Services, you may make purchases, whether you shop on ZHANGYIN GAMES
websites or directly in-game.
When you do this,
you agree that ZHANGYIN GAMES may share your personal data with third
parties, companies, or organizations, which may collect and process your
personal data in order to effectuate online transactions, delivery,
discounts, and promotional gifts.
When you play
ZHANGYIN GAMES’s games or access any of our other Services on connected
third-party applications or platforms (like Apple, Google), any
purchases you make will be processed by that third-party application and
subject to that third-party application’s terms of service and privacy
policy. For these purchases, ZHANGYIN GAMES does not receive your
financial information, but may receive non-financial information related
to your purchases, like the items purchased.
1.2.2 In-game
data collection
Whenever you use
the Services, ZHANGYIN GAMES may collect, store and process your in-game
data, including but not limited to: your game scores, game metrics,
achievements, rankings, time played and statistics, feature usage,
advertising conversion rates, monetization rate, purchase history and
other similar information. ZHANGYIN GAMES will use this information to
improve the Services, to personalize them to your interests, and
otherwise upgrade your gaming experience. Any information collected by
ZHANGYIN GAMES in accordance with Article 1 of this Privacy Policy may
also be used in an aggregated form to identify specific patterns
regarding the use of our Services.
1.3 Online payment
For some
Services, you may make purchases, whether you shop on ZHANGYIN GAMES
websites or directly in-game.
When you do this,
you agree that ZHANGYIN GAMES may share your personal data with third
parties, companies, or organizations, which may collect and process your
personal data in order to effectuate online transactions, delivery,
discounts, and promotional gifts.
When you play
ZHANGYIN GAMES’s games or access any of our other Services on connected
third-party applications or platforms (like Apple, Google), any
purchases you make will be processed by that third-party application and
subject to that third-party application’s terms of service and privacy
policy. For these purchases, ZHANGYIN GAMES does not receive your
financial information, but may receive non-financial information related
to your purchases, like the items purchased.
2. HOW DOES ZHANGYIN GAMES USE MY
PERSONAL DATA?
The information
you submit to our Services is collected and used by ZHANGYIN GAMES as
set out in this Privacy Policy. ZHANGYIN GAMES collects and processes
your personal information at different times when you interact with our
Services. Generally, personal information is collected when:
a. you use a
Service,
b. you create an
Account,
c. you make a
purchase within our Services,
d. you create
user generated content,
e. you watch
advertisements within our Services,
f. you sign up
for a newsletter,
g. you contact
ZHANGYIN GAMES customer service and during technical support sessions,
h. you chat with
other users of the Services,
i. you
participate in a beta or otherwise download a patch or a demo, or
j. you share or
otherwise contribute to our social media channels or other community
websites.
In addition,
ZHANGYIN GAMES may use the submitted information to answer your demands,
to send your order confirmations and other information regarding your
ZHANGYIN GAMES Account, to send you advertising or promotional
materials, including information about special rebates, promotional
offers and other events of interest, based on your preferences.
We also may use
your personal information for our internal marketing and demographic
studies, so we can constantly improve the Services we provide you and to
better meet your needs.
ZHANGYIN GAMES
processes your personal data, wherever necessary:
- To provide you
with the Services (creation of your ZHANGYIN GAMES account, bug
detection, fighting fraud, online payment, etc.)
- To offer the
best possible experience to users, and improve the Services (in-game
data analytics, etc). It is in ZHANGYIN GAMES’s legitimate interest to
process your data for these purposes.
- To provide you
with supplementary services (custom content, etc.). In such case,
ZHANGYIN GAMES will ask for your consent before processing your personal
data for this purpose.
Whatever the
activity may be, we will only collect personal information to the extent
necessary to provide you with the Services and fulfil your requests.
3. Security of Your DATA
We take your
privacy and the security of your personal information very seriously. To
protect your personal information, ZHANGYIN GAMES maintains appropriate
safeguards to ensure the security, integrity and privacy of the
information you have provided. We use robust security measures to
protect personal information from loss, misuse and alteration. We use
industry-standard practices such as encrypted communications, physically
secured rooms, firewalls and password protection systems to safeguard
the confidentiality of your personal information. In addition, we take
reasonable steps to assure that third parties who collect personal
information on our behalf provide sufficient protection of personal
information, in addition to requiring their compliance with this Privacy
Policy at all times. Please note, we will notify Users of a data breach
pursuant to applicable law.
However, please
note that no existing data transmission method on the web, or electronic
storage, can guarantee the absolute security of your personal data. If
your ZHANGYIN GAMES accounts and personal data are protected by a
password, you are responsible for ensuring this password’s
confidentiality. Please do not disclose this password. If you share a
computer with other people, please consider disconnecting from your
accounts before allowing others to use your computer. Services may
contain links leading to third party websites, such as but not limited
to social media sites. Whenever you click on a link leading to a third
party’s website, you agree to leave ZHANGYIN GAMES Services as governed
by this Privacy Policy, and you understand and agree that ZHANGYIN GAMES
does not control such third party’s website. ZHANGYIN GAMES cannot
guarantee that third parties’ websites will be governed by the same
security and confidentiality obligations. ZHANGYIN GAMES is not liable
for the use of your personal data by these third parties. Please
consider checking privacy policies of any service provider you transfer
your personal data to.
DESPITE OUR
REASONABLE EFFORTS TO KEEP YOUR PERSONAL INFORMATION SECURE, NO COMPANY
CAN GUARANTEE THE SECURITY AND PRIVACY OF ITS SERVICES, INFORMATION AND
OTHER DATA.
4. FOR HOW LONG DOES ZHANGYIN
GAMES KEEP MY PERSONAL DATA?
Unless relevant
legal provisions mandate a different data retention period, ZHANGYIN
GAMES will store your personal data only as long as necessary to process
it according to this Privacy Policy. For instance, we may retain certain
information after you close your account for a period of time needed to
protect ZHANGYIN GAMES from legal claims. In this case, we will archive
your personal data during the relevant statutory period of limitations.
5. WITH WHOM DOES ZHANGYIN GAMES
SHARE YOUR PERSONAL DATA?
ZHANGYIN GAMES
does not disclose your personal data to any third party without your
prior consent.
5.1 Sharing your personal data
with ZHANGYIN GAMES affiliated companies
ZHANGYIN GAMES
may share your personal information among the ZHANGYIN GAMES group of
companies. To the extent that our corporate affiliates and/or technical
partners have access to your information, they will follow practices
that are at least as restrictive as the practices described in this
Privacy Policy.
5.2 Sharing your personal data
with third parties
While browsing on
ZHANGYIN GAMES websites, or while using ZHANGYIN GAMES Services,
external providers may collect your personal data for and on behalf of
ZHANGYIN GAMES, and ZHANGYIN GAMES may share some of your personal data
with these partners to allow the functioning of the Services (such as
Facebook, Google, Twitter, Appsflyer, Firebase). For example, these
third parties may help deliver your purchases, provide discounts or
offer products, promote the Services, perform electronic payment
processing, and any other service that may be required by ZHANGYIN
GAMES. External providers must comply with this Privacy Policy when
collecting your personal data. These external providers will share your
personal data with no one other than ZHANGYIN GAMES, and they may not
use your data for their own independent marketing purposes, unless you
consent to their privacy policy and terms directly.
5.3 Sharing your personal data
with government authorities
In accordance
with relevant laws, ZHANGYIN GAMES may have to disclose your personal
data to a judiciary or administrative entity, whenever such disclosure
is deemed necessary for protecting or enforcing the legal rights of
ZHANGYIN GAMES, its Users, or third parties. Unless required by law,
ZHANGYIN GAMES will not be required to notify you of any such
disclosure.
5.4 Sharing your personal data in
case of mergers
In the unlikely
event ZHANGYIN GAMES’s business activities or shares are transferred
partly or totally to any third party, such third parties may access your
personal data. In this case, ZHANGYIN GAMES may also allow your personal
data to be transferred to the acquiring third party.
5.5 Transfers of personal data to
third countries or outside the European Union
The information
we collect from you may be stored on a server located in the United
States outside of the country where you live. We maintain major servers
around the world to bring you our services globally and continuously. No
matter where our servers are located, we take appropriate measures to
safeguard your rights in accordance with this privacy policy. When we
process personal information collected in the UK or European Countries
outside of the UK or European Countries (as applicable), we comply with
our legal obligations and ensure that your personal information is
subject to suitable safeguards or transferred to “approved” territories.
5.6 Friends and Other ZHANGYIN
GAMES Players
ZHANGYIN GAMES
Services may offer a public profile feature ("Public Profile") that
allows you to publish information, including personal information, to
the public Internet. Those aspects of the Public Profile that are
designated as "public" will be visible to everyone, potentially
including people not registered within the ZHANGYIN GAMES environment,
and may be indexed and displayed through public search engines when
someone searches for you. If you post your personal information to a
Public Profile, including a video, image or photo, you should be aware
that these may be viewed, collected, copied and/or used by other users
without your consent.
We are not
responsible for disclosure by other users of your Personal Information,
including without limitation, videos, images or photos that you choose
to make public on the ZHANGYIN GAMES Services. Also, please remember
that the Personal Information you provide to us as part of your Public
Profile may reveal or allow others to identify aspects of your life that
you may not choose to state on your Public Profile directly (for
example, your picture may reveal your gender).
6. MINORS
If you are a
minor in your country of residence, you should read these Terms with the
help of your parent or guardian. If you are a parent or legal guardian
and you give your permission for your child to register for the
Services, you thereby agree to the Terms relating to use of the Services
by your child.
Protecting
children's privacy online is extremely important to us. We do not
directly serve children under the age of 13. We also do not
intentionally collect data from children or minors through the Service.
If you are the parent or guardian of a child and you believe that we
have inadvertently received data about that child, please contact us. we
will take reasonable measures to promptly remove that information from
our records.
7. WHAT ARE YOUR RIGHTS?
You can access
and update the contact information you gave us during registration (that
is, your e-mail address or any other information that would directly
enable us to contact you), by logging in and clicking the Edit Profile
section. Additionally, you have a right to access, rectify, erase,
object, or restrict processing for all your personal data processed by
ZHANGYIN GAMES, as well as the right of data portability. You can
exercise these rights or terminate your ZHANGYIN GAMES account by
writing to ZHANGYIN GAMES customer support, via the following website:
[www.99zgc.com] or send an e-mail to [274811635@qq.com]. ZHANGYIN GAMES
will answer your request within a month following the receipt of your
demand. ZHANGYIN GAMES reserves the right to extend this delay up to
three months if it necessary regarding the complexity of your demand, or
based on the number of demands we receive. In such case, we will inform
you of this extension within a month following the receipt of your
demand. For any data processing activity requiring your consent
(cookies, behavioral advertising, etc), you may withdraw your consent at
any time. This withdrawal does not affect the lawfulness of any previous
processing.
You can also
adjust your browser settings to understand when these Cookies are stored
on your device or to disable the Cookies by consulting your browser’s
“Help” menu. Please note that these settings may affect your ability to
access certain features of our Services whenever these Cookies are
needed for the operation of our Services.
Opting Out of Third-Party
Behavioral Advertising
If you are
interested in more information about behavioral advertising and your
choices to prevent behavioral web and mobile web advertising from third
parties, you may visit the following websites:
• Network
Advertising Initiative Consumer Opt-Out Page or the Digital Advertising
Alliance Opt-Out Page for U.S.-based advertising
• If you do not
want to receive behavioral in-application advertisements from third
parties that relate to your interests on your mobile device, you may
adjust the ad tracking settings on your device (such as turning on
“Limit Ad Tracking”). You can also reset the “Advertising Identifier”
(such as an IDFA) from your mobile device’s settings page, which will
prevent continued use of existing behavioral data tied to your previous
“Advertising Identifier.”
All of the
opt-out tools described in this subsection are provided by third
parties, not by ZHANGYIN GAMES. ZHANGYIN GAMES does not control or
operate these tools or the choices that advertisers and others provide
through these tools.
Please note that
you may still receive third-party advertisements in ZHANGYIN GAMES’s
Services after using these opt-out tools, but the advertising you see
may be less relevant to your interests.
Opting Out of Promotional
Communications from ZHANGYIN GAMES
You can
unsubscribe from promotional emails by by following the unsubscribe
instructions included in these emails. You can opt out of mobile push
notifications in your device’s settings page. You can opt out of SMS
text communications by texting STOP. You also may contact us at
[274811635@qq.com].
Please note that
if you opt out of receiving promotional communications from us, we may
still communicate with you from time to time if we need to provide you
with information about the Services you are using from us, if we need to
request information from you with respect to a transaction initiated by
you, or for other legitimate non-marketing reasons, for example, if we
are required under applicable laws to notify you of updates to this
Privacy Policy or our Terms of Service.
8. PRIVACY POLICY CHANGES
ZHANGYIN GAMES
reserves the right to modify this Privacy Policy at any time. As a
result, please consider checking this Privacy Policy from time to time.
Your use of the Services after ZHANGYIN GAMES changed this Privacy
Policy shall signify that you agree with these changes. If you do not
accept changes made to this Privacy Policy, please refrain from using
the Services.
9. CONTACTS
For any question
related to your personal data processing and this Privacy Policy, please
contact ZHANGYIN GAMES data protection officer at the following address:
[274811635@qq.com]. Please be assured that any Personal Information that
you provide in communications to the above email and postal mail
addresses will not be used to send you promotional materials, unless you
request it.
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