1. Scope of this Policy

This Privacy Policy (“Policy”) applies to all game products and related services provided by us. The contents specified in it, including but not limited to user rights and information security measures, etc., are all applicable to the users of our game products and related services. 

2. What information do we collect?

The data that Merfolk Games collects is used solely for game optimization purposes. This is to give you the best experience while using our product.
While you are using our product or service, we will collect the information that you voluntarily provide when using the product or service or the information generated by your use of the product or service through the following ways, in order to provide and optimize our product or service to you. In accordance with the principles of legality, properness and necessity, we only collect the information necessary to realize the function of our product and service.

2.1 When you register or use our product or service, we will collect the information of your network identity and the personal device that you frequently use, in order to mark you as our users. In order to provide you with better services and improve your game experiences, we may use your information such as nicknames and avatars of your game account, and the related operation information, game information and other information in our product (hereinafter referred to as “Such Information”, including but not limited to, your log-in status, battle information/status, achievement information, etc.) and we may present Such Information to you or other users or your friends. Depending on the specific situations of a game product, we may provide you with the relevant permissions enabling you to adjust the settings as to whether or not to display Such Information.

2.2 In order to ensure your use of our service under normal conditions , to maintain the normal operation of basic functions of the game, to optimize the performance of the game product, to improve your gaming experience and protect the security of your game account, we will collect the information such as your device ID as well as the name, type and version of your device, the version of the system, IP address, MAC address, application ID, network type and other information.

2.3 When you use our product or service, we will collect your game log information, such as log-in data, item logs, game battle information, friends records, etc., so that you can view the records of your game history on your terminal and we can use the above information for analyzing game operation statistics, handling customer service complaints and other game security analyses. 

Please note that individual device information and log in information are information that cannot identify a specific individual. 

2.4 When you use the consumption function of our product, we will collect your recharge history, purchase records and other information, so that you can check your transaction records, and at the same time to protect your virtual items to the greatest extent possible. 

2.5 To protect the security of your game account and to create a fair, healthy and safe gaming environment, we will collect information such as your game identity information, hardware and operating system information, processes and breakdown records and other information, for the purposes of fighting against the behaviors that destroy the fair gaming environment or that interfere and disrupt normal game services (such as detecting counterfeits, scanning plug-ins, preventing cheating, etc.).

2.6 In the process of providing services, you have the option to enable some device access permissions, such as mobile phone contacts, WeChat contacts, Google contacts, Discord, Twitter, etc., to connect you to other services and to achieve the collection and use of the information involved in some functions. Merfolk Games will not use or distribute personal information for purposes other than gameplay. You can also choose to turn off some or all permissions at any time in the settings function of your device, thereby ending the collection of information for the game. Depending on the device, the permission display and closing methods may be different. For details, please refer to the device or system developer’s instructions or guidelines. Please note that when you turn on these permissions, you authorize us to collect and use these personal information to achieve the above functions. When you turn off permissions, you cancel these authorizations, and we will no longer continue to collect and use your personal information, and cannot provide you with the functions corresponding to these permissions. Your decision to close your permissions will not affect the processing of information previously based on your authorization.

2.7 When you interact with other players through text, images, voice, video and other means in the game, we may collect and store the above information sent by you, for the purpose of filtering out pornographic, violent, and abusive contents, malicious advertisements and other contents to improve the game environment and maintain a healthy Internet environment.

2.8 In accordance with relevant laws, regulations and national standards, we may collect and use your personal information in the following situations without obtaining your authorization:

1) where it is directly related to national interests such as national security and national defense security;
2) where it is directly related to major public interests such as public security, public health, and public knowledge;
3) where it is directly related to criminal investigations, prosecutions, trials and enforcement of judgments, etc.;
4) where it is for protecting the fundamental legal rights of you or other individuals, such as life, property and reputation, but it is also difficult to obtain consent from you or the related individual;
5) where those personal information we collected is disclosed to the public by yourself;
6) where it is necessary to sign and perform the contract according to your requests;
7) where it is necessary to maintain a safe and stable operation of the products or services provided by us, such as the discovering and treating of the malfunctions of such product or service;
8) other circumstances as stipulated by the laws and regulations.

2.9 To improve the security of your use of the services provided by us and our partners, protect the personal and property safety of you or other users or the public from damage, and better prevent security risks such as phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusions, to more accurately identify violations of laws and regulations or the relevant agreement rules of our services, we may collect, use or integrate your account information, transaction information, equipment information, log information to comprehensively judge the risks of your account and transaction, conduct identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis, and disposal measures in accordance with the law.

2.10 Some of our services may require you to provide specific personal information for specific functions. If you choose not to provide such information, you may not be able to use certain features in the service normally, but it will not affect your use of other features in the service. By proactively providing your personal sensitive information, you agree that we will process your personal sensitive information in accordance with the purposes and methods described in this Policy.

3. How we store and protect your personal information

3.1 We will only store your personal information for the shortest period necessary to achieve the purposes described in this Policy, where when a product provide by us as a data controller is off the shelves or you cancel your account, the data in the product (including behavior data, character data, etc.) will be deleted or anonymized. After the retention period expires, we will delete or anonymize your personal information, except as otherwise required by national laws, regulations, rules, regulatory documents or government policies, orders, etc. to fulfill our compliance obligations.

3.2 Player data is stored on a password-protected physical computer.
In view of the above, we will ensure that your personal information is protected in accordance with laws and regulations and this Policy.

4. How we use your personal information

4.1 We will use the collected information in accordance with the following rules:
1) based on the information we collected, we will provide you with multiple functions and services, including the general gaming functions, interactive functions between users as well as consumption functions;
2) we will analyze the operation of our products based on the frequency and situations of your use of our product or service, malfunction information and performance information, etc., so as to ensure a safe provision of our products and services, and to optimize our products and improve the quality of our services.

4.2 We will use the collected information within the scope included in this Policy. If we use your personal information beyond the scope of purpose we claimed when collecting those information or a direct or reasonably relevant scope, we will again inform you and seek your express consent before using your personal information.

5. How we share, transfer, and disclose your personal information

5.1 We strictly follow the laws and regulations to restrict the sharing of information. We will not share your personal information with any third party.

1) We may work with our affiliates, third-party partners (third-party service providers such as Firebase, contractors, agents, advertising partners, application developers, etc.), share your player data, and let them follow our instructions, Privacy Policy, and other relevant confidentiality and security measures for processing the above information and use it for the purposes described in this Policy.
If we share your player data with the above third parties, in addition to providing complete personal information for processing purposes, we will use encryption, de-identification and other means to ensure the security of your information.
We will only provide your player data to such third parties for legitimate, proper, and necessary purposes, and we will only provide personal information necessary for related products and/or services. We will work to ensure that these third parties use your personal information in compliance with this Policy and other appropriate confidentiality and security measures that we require them to comply with, and we explicitly require these third parties to use shared personal information only with our products and/or services for specific uses. If you change the purpose of processing personal information, these third parties will seek your authorization again.

5.2 As our business continuously develops, we are likely to conduct transactions such as mergers, acquisitions and asset transfers, etc. We will inform you of the information and continue or require the new controllers to continue to protect your personal information in accordance with the laws and regulations and the standards no lower than the requirements of this Policy.

5.3 We may, in accordance with laws and regulations, the need for litigation and dispute resolution, or in accordance with the requirements of administrative and judicial authorities in accordance with the law, or to protect the public interest, or protect the lives of our customers, us or our affiliates, other users or employees or for purposes reasonably necessary for property security or other legitimate interests, to disclose your player data.

6. Information Security

6.1 In order to ensure the security of your information, we will endeavor to take reasonable and necessary physical, technical and administrative security measures to protect your information at the current level of technology to prevent your information from being lost, misused, and unauthorized access, disclosure and changes, including but not limited to encrypted storage of information, access control for data centers, dedicated network channels and agents. The Internet environment is not 100% secure, and we will do our best to ensure or guarantee the security of any information you send to us.

6.2 We establish special management systems, processes, organizations and take corresponding measures to ensure information security. For example, we strictly manage employees or outsourced personnel who may have access to your information, including but not limited to adopting different authority controls based on different positions, signing confidentiality agreements with them, monitoring their operations, and other measures.

6.3 If we confirm that a security incident such as personal information leakage has occurred, we will launch an emergency plan to prevent the expansion of the security incident and notify you in the form of push notifications, announcements, etc. At the same time, we will also report the handling of personal information security incidents in accordance with the requirements of regulatory authorities.

7. How to manage your personal information

7.1 You can log into your account at any time to view or modify account settings and information. If you wish to change or update your personal information held in our system, you can log into the account, operate your account information or contact us through the contact details listed in this Policy to modify it.

7.2 If you find that we have collected or used your personal information in violation of laws, administrative regulations or the agreement of both parties, you can ask us to delete it. If you find that your personal information we have collected and stored is incorrect, you can also ask us to correct it. Please contact us using the contact details listed in this Policy.

7.3 You may also contact us via the contact details set out in this Policy to request the cancellation of your account. After you actively cancel your account, we will stop providing you with products or services, and your personal information will remain irretrievable, inaccessible, or anonymized, except as otherwise required by laws, regulations or administrative regulations, and government regulatory documents. We do not take any responsibility for the adverse impact of your application to cancel your account.

7.4 When you access, update, correct, or delete the foregoing information, we may require you to verify your account to ensure account security. We may also prompt you to meet certain conditions in order to cancel your account. Although we will not set unreasonable conditions to prevent you from canceling your account, if the cancellation of your account will affect the legal rights of you or others, we will determine and advise whether we support your logout request.

7.5 We provide access, update, correction, and deletion services for free, but reserve the right to charge a reasonable fee for your data access requests.

8. Amendments of this Policy

In order to provide you with better services, we may modify the terms of this Policy in a timely manner according to the update of our products and/or services and relevant requirements of laws and regulations. If these updates cause a substantial reduction or major change in your rights under this Policy, we will notify you through a website announcement, push notification, or other means before this Policy takes effect. If you do not agree to these changes, you can choose to stop using our products and services; if you continue to use our products or services, it means that you have fully read, understood and agreed to be bound by this revised Policy.

9. Contact us

When you have other complaints, suggestions, or questions regarding personal information, please contact us via email. You can send your questions to dev@merfolkgames.com or mail to the following address:
A-B, 6/F, Lin Fook House, No. 1-3 Jardine Crescent, Causeway Bay, Hong Kong
We will review the relevant questions as soon as possible, and will respond within 30 days upon verifying your user identity.
Merfolk Games Co., Ltd.
Date: 1/14/2020