First Fun Hong Kong Limited and its affiliates (collectively “First Fun”, “we”, “our”, or “us”) greatly recognizes and values the privacy of people (“you”) who visit our websites, use or access our games, whether played on mobile devices, PCs, our websites or other approved platforms, and/or otherwise use or access any of our provided services (collectively the “Services”).

This Privacy Policy (“Policy”) describes why and how we collect, store, and use your personal information, and the choices and rights you have about the personal information you provide or we collect in connection with the Services.

This Policy applies to all our Services. Certain Services may have different, Service-specific privacy polices posted, or may require you to agree with and accept such additional policies. If there is a conflict between this Policy and specific policies, the applicable policies will take precedence with respect to your use of, or access to, such Service.

By accessing our websites or otherwise using the Services, you acknowledge that you have read, understood and accepted the following terms and that you voluntarily and explicitly agree that we process your relevant information in accordance with this Policy. If you do not agree to any of the terms hereunder, some basic functions in the Services may not be able to run normally, which may prevent you from using them. If you do not agree to the processing of your personal information in the way this Policy describes, please do not provide your information when requested and stop using the Services. If you change your mind in the future, you may withdraw your consent to use of your personal information in accordance with this Policy.

1. Types of Personal Information We Use

1.1 Information you provide us.

Ÿ When you register for the Services (such as username, telephone number, email address, password, verification code, profile information, and your nominated nickname, or custom accounts and information we import from your connected social media account (e.g., WeChat, Facebook, Google, Twitter, iTunes) in order to save your account from being lost);

Ÿ When you log in as a ‘guest’ in order to use the Services (such as your nickname);

Ÿ When you participate in a survey in the Services (in which case we will process the information you provide to us as part of the survey);

Ÿ Information you provide when seeking help from us (such as records of the issues you experience);

Ÿ Billing information (such as your name, payment card number, and payment account details).

1.2 Information we collect about you.

We automatically collect certain data from you when you use our Services, including your IP address and device information (such as application version, network type, operating system, browser type and language) and information regarding your use of the Services, such as date and time stamps of actions. We also collect and store your data each time you interact with us, for example, when you use in-app support to communicate with us.

1.3 Information you generate and display in the course of using the Services.

You may provide additional information as part of your profile (such as gender). You may also provide or generate information when you communicate with other users in the Services (e.g., chat log data, chat content).

1.4 Data we collect from our partners.

Ÿ Data we receive if you link a third party tool with the Service (such as WeChat, Facebook, Google, Twitter, iTunes);

Ÿ Demographic data (such as to determine the coarse location of your IP address);

Ÿ Data to fight fraud (such as refund abuse in games or click fraud in advertising);

Ÿ Data from platforms that the games run on or data from payment service providers (such as to verify payment);

Ÿ Data for advertising and analytics purposes, so we can provide you a better service;

Ÿ Data that you have made available to us from a third party service (such as WeChat, Facebook, Google, Twitter, iTunes) via your privacy settings.

1.5 Cookies.

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) to enhance your experience using the Services. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality. You have the option to permit the installation of such cookies or subsequently disable them. You may accept all cookies, or instruct the device to provide notice at the time of installation of cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event of your refusal to install cookies, Services may be unable to operate as designed.

1.6 Exceptions to obtaining authorization and consent.

In accordance with relevant laws and regulations, we may collect and use some necessary personal information without your authorization and consent under the following conditions:

Ÿ if it is directly related to national security and national defense security;

Ÿ if it is directly related to public security, public health and major public interests;

Ÿ if it is directly related to criminal investigation, prosecution, trial, and execution of judgment;

Ÿ if this information aims to safeguard your or others' personal life, property, and other important legitimate rights and interests, but it is very difficult to obtain your consent;

Ÿ if the personal information involved is open to the public on your own;

Ÿ if this information is necessary to sign and fulfil a contract according to your requirements;

Ÿ if your personal information is collected from lawfully and publicly disclosed information such as legal news reports, government information disclosure, and other channels;

Ÿ if this information is necessary to maintain the safe and stable operation of the Services such as detecting and handling product or service faults;

Ÿ other conditions prescribed by applicable laws and regulations.

2. How We Use Your Personal Information

We will use the information in the following ways:

Ÿ User Nickname: We use this information to create your account for the Services in accordance with your request;

Ÿ Social Connect Information: We use this information to create your account for the Services in accordance with your request; share in-game photos on Facebook at your request;

Ÿ Generated Open ID: We generate this and use this to store your Services data (including level and progress) with your profile;

Ÿ Game Play Statistics (Level, Score/s): We use this information to provide you with feedback and information about your gameplay and progress;

Ÿ IP Address: We use this information to improve our Services, including the functionality of the Services;

Ÿ Device ID, Device Information: We use this information to improve our Services, including the functionality of the Services; for security and verification purposes; identify and address bugs and assess game function for optimization; and to combat users registering for multiple accounts;

Ÿ Advertising ID: If you click on a link that advertises the Services, we store the Advertising ID for that advertisement with your profile;

Ÿ Chat Data: If you enable chat services then we will process such data in order to deliver your messages to other users;

Ÿ Transaction Records: We use this information to maintain a record of your transaction history;

Ÿ Customer Support: We use this information to improve our Services; provide troubleshooting such as addressing and remediating technical issues and bugs;

Ÿ Security-Related Information: We use this information for security and verification purposes; identify and address bugs and assess game function for optimize action; solve game crashes and optimize compatibility of devices with the game; and to combat users registering for multiple accounts;

Ÿ Survey Information and Content of Survey Responses: We use this information to improve our Services;

Ÿ Malicious Content Information: We collect this information to avoid some words that may offend or distress others via your signature, nickname, or chat data within our Services.

If you are a resident of the European Union, we rely on a number of legal grounds to process information about you. For example, we will process information about you where we have your consent, where we have a legitimate interest to do so, where the processing is necessary for the performance of a contract with you, and where we have a legal obligation to process your information. To learn more about the legal grounds on which we rely to process your information for any particular purpose, please contact us via email listed in Contact & Complaints below.

3. Why We Collect and Process Your Personal Information

In order to provide Services, perform the Terms and/or any other agreements between you and First Fun, and/or perform the legal liabilities under the applicable laws and regulations, we collect and process your personal information to:

Ÿ allow you to access or restrict your access to our Services;

Ÿ analyze and manage our Services for system administration, user service, security, fraud-detection, checking the authenticity of an account owner, archival and/or backup purposes;

Ÿ correct bugs or errors, improve our Services and respond to customer desires and preferences, including language and location customization, personalized support and instructions, and other responses;

Ÿ develop new services or products that user(s) request and improve the user experience;

Ÿ verify and confirm payment; however, we will not deal with any payment made for any purchase within the application and access your credit card information. Payment transactions for any purchase within the application are typically done at the application store through your App Store or Google Play account. Any post-purchase processing is controlled by the Apple and Google stores and other payment service providers and is subject to specific service terms of such payment service providers. Please review the privacy policies and service terms of the Apple and Google stores and other payment service providers chosen by you;

Ÿ deliver advertising that may be relevant to your interests, if applicable;

Ÿ communicate with other users and take action against violations;

Ÿ personalize your experience, keep you up to date with the latest product announcements, provide software verification, upgrades and administration, notify of special events, offer to participate in our surveys or activities, and provide other information pertaining to our Services;

Ÿ protect the integrity, safety, and security of our Services or users, comply with legal obligations, and enforce compliance with the Terms or other restrictions placed on your use of our Services; and/or

Ÿ track your process across our websites and applications to verify that you are not a bot and to optimize our Services.

For the purposes set forth above, our affiliates may be commissioned to process your information, provided that such affiliates comply with the terms and conditions hereunder.

In all of the above cases and purposes, you acknowledge and confirm that we may analyze, profile, segment, merge and/or update all collected data (regardless of an aggregated or individualized manner) for the purposes of improving service quality and providing a better experience.

In specific cases, we may collect other personal information apart from the categories stated herein based on your consent. When this occurs, we will, upon requiring your additional consent, provide more information about any change to the way or purpose of our collection or processing which might be different from or not clarified in the details in this Policy.

Under any circumstance where our collection or processing of your personal information is based on your consent, you may withdraw such consent at any time with no impact on the validity and lawfulness of collection or processing based on the consent made before its withdrawal.

4. How We Share Your Personal Information

In addition to us and our affiliates, other parties may also access your personal information in the following situations. You acknowledge that you have foreseen and agreed to the occurrence of such disclosure when you provide your personal information:

Ÿ Other players and users. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted.

Ÿ Partners working for First Fun. First Fun has partners to perform services for us. These partners process your data at and according to First Fun’s instructions to provide the Services, such as hosting, player support, advertising, analytics and fraud prevention.

Ÿ Other companies and public authorities. In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests. We may also disclose your data based on your consent, to comply with the laws and regulations or to protect the rights, property or safety of us, our players or others.

Ÿ Law enforcement agencies, public authorities or other judicial bodies and organizations.

Ÿ Third party that acquires all or substantially all of us or our business. We will disclose information to a third party in the event that we sell or buy any business or undergo a merger, in which case we will disclose your data to the prospective buyer of such business. We will also disclose information to a third party if we sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.

5. Data Retention

We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or where the applicable laws or regulations provides for longer storage and retention period. Upon the expiration of such period, your personal information will be deleted, blocked or anonymized, as provided by applicable laws and regulations.

You acknowledge and agree that your data will be processed on our servers which may not be located in your country of residence and can be accessed by our support, engineering and/or our affiliates around the world. No matter where our servers are located, we will make great efforts to take the appropriate safeguards to guarantee your rights in conformity with this Policy and any applicable laws and regulations.

In the case you request to remove or delete your personal information, we will retain your data as long as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and/or enforce the agreements between you and us. Please note that the removal or deletion of any of your data may result in the termination of some of our applicable Services.

6. Your Rights

You have legal rights in relation to the personal information we hold about you (to the extent permitted under applicable laws and regulations). To exercise any of your rights, please contact us via email listed in Contact & Complaints below.

6.1 Access.

You have the right to access personal information we hold about you. You can access the personal information you have made available as part of your account by logging into your account in the Services. If you believe we hold any other personal information about you, please contact us via email listed in Contact & Complaints below.

6.2 Portability.

You have the right to receive a copy of certain personal information we process about you. You also have the right to request that we transfer that personal information to another party.

If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (e.g., where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

6.3 Correction.

You have the right to correct any personal information held about you that is inaccurate. You can access the personal information you have made available as part of your account by logging into your account in the Services. If you believe we hold any other personal information about you and that information is inaccurate, please contact us via email listed in Contact & Complaints below.

6.4 Erasure.

You can delete your account, or remove certain personal information, by logging into your account in the Services. If there is any other personal information you believe we process that you would like us to erase, please contact us via email listed in Contact & Complaints below.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (e.g., for the defense 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 Services 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.

6.5 Restriction of Processing to Storage Only.

You have the right to require us to 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 (e.g., for the defense of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

6.6 Objection.

You have the right to object to our processing of personal information about you. We will consider your request by contacting us via email listed in Contact & Complaints below.

6.7 Announcements.

We may from time to time send you announcements when we consider it necessary to do so (such as when we temporarily suspend Services access for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.

Respond to your above-mentioned request

To ensure security, you may need to provide a written request or otherwise prove your identity. We may ask you to verify your identity and then process your request. We will reply within a reasonable time limit. We do not charge any fee in principle for your reasonable request, but we will charge a certain cost for repeated requests that exceed a reasonable limit. We may refuse requests that are repeated for no reason, need excessive technical means (for example, needing to develop new systems or fundamentally changing the existing practices), pose a risk to others’ legitimate rights and interests, or are highly impractical (for example, involving information that is stored on backup tapes).

We will not be able to respond to your request under the following conditions, as required by applicable laws and regulations:

Ÿ if it is directly related to national security and national defense security;

Ÿ if it is directly related to public security, public health and major public interests;

Ÿ if it is directly related to criminal investigation, prosecution, trial, and execution of judgment;

Ÿ if there is sufficient evidence to show that you have subjective malicious intent or abuse rights;

Ÿ if responding to your request will result in serious damage to the legitimate rights and interests of you or any other person or organization;

Ÿ if business secrets are involved;

Ÿ other cases where we have reasonable grounds to refuse.

7. Securing Your Data

Pertaining to your use of our Services, we have endeavored to take reasonable measures to prevent unauthorized access to or improper use of your personal information.

Unfortunately, the transmission of information via the internet is not completely secure. While we strive to protect your personal information, we also remind you to be aware of hacking, cyber-attacks, and other risks on the Internet.

Therefore, we strongly urge you to take every possible precaution to protect your personal information when using our Services, including but not limited to changing your passwords from time to time, not reflecting your real name or other personal information in registration, using a combination of letters and numbers when creating passwords, using a secure browser and/or taking other possible security measures.

Please be aware that advertisers or websites with links to and/or from our websites may collect personal information about you and this Policy does not apply to, and cannot control the activities of, those other advertisers or websites. We highly recommend that you read the privacy policy of such third-party websites which you may be directed to before providing any personal information.

8. Age Limits and Children Protection

You agree that if you are under the age of legal majority where you access the Services, you represent that your parent or guardian has read, understood, and agreed to this Policy.

If you are a parent or guardian and wish to review personal information collected from your child, or have that information modified or deleted, you may contact us as by contacting us via email listed in Contact & Complaints below.

In cases where child’s personal information is collected with the consent of their parents or guardians, we will use or publicly disclose this information only with the permission of the applicable laws and regulations, the express consent of their parents or guardians or the protection on children. If we become aware that a child has provided us with personal information not permitted under applicable laws and regulations, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account and/or revert them to the underage experience, as applicable.

9. Special Disclosure for California Residents

This section is adopted to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and supplements the information contained in our Policy with regard to the processing of personal information of users who reside in the State of California.

Ÿ In the past 12 months, we collected, used and shared personal information pursuant to the Section 1, 2, 3 and 4 of this Policy. For example, such information may include your identifier such as IP address and mobile device identifier, depending on Services you use;

Ÿ You have the right to opt-out of the sale of your personal information. Within the last twelve (12) months, none of your personal information has been sold to a third party, but in such case, we will promptly notify you and you may submit your request to opt-out of the sale of your personal information. If you wish to submit your request to opt-out of any potential sales, please contact us via email listed in Contact & Complaints below;

Ÿ The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. To exercise the right, please contact us via email listed in Contact & Complaints below;

Ÿ You have the right not to receive discriminatory treatment for the exercise of the privacy rights conferred by the CCPA. We do not charge different prices from you or provide services in different quality unless such a difference is related to your information or permitted by law. Upon receipt of your request made via email listed in Contact & Complaints below, we may require you to provide sufficient information to confirm your identity and thus verify the request, including requesting you to verify information about your use of Services.

10. Links to Sites and Services Operated by Others

Services may contain links to other sites, applications, and services, including functions that enable you to share our Services or access our Services using a third-party online service. These functions may collect your relevant information (including your log information) and install cookies on your computer to run the above-mentioned functions properly. Because we do not operate those other sites, applications, and services, we cannot take responsibility for the privacy practices of the entities that operate them. We recommend that you consistently check privacy policies to understand an operator’s practices. As a reminder, this policy describes First Fun’s practices.

11. Changes

We may update this Policy from time to time. If we make material changes in the way we collect, use, retain or share your personal information, we will notify you by posting modification to the Policy or notice of the changes on the Services covered by this Policy. By continuing to access or use our Services after we have posted a modification to this Policy or have provided you with notice of a modification, you are indicating that you agree to be bound by the modified terms. If the modified terms are not acceptable to you, your only recourse is to cease using our Services.

12. International Transfer

To the maximum extent permitted by the applicable laws and regulations, we may transfer information that we collect about you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, and we take steps to ensure adequate safeguards are in place to enable transfer of information and the use and disclosure of information about you, including personal information, as described in this Policy.

13. Contact & Complaints

Questions, comments and requests regarding this Policy are welcomed. Please contact us via email listed below.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at [[email protected]] and we will endeavor to deal with your request as soon as possible.