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PRIVACY POLICY


Last Updated: Sep 1st, 2014


This Privacy Policy governs the Websites and Services made available online by 37Games for use on mobile devices, tablets, personal computers and other devices. By accessing or using any of the Websites or Services, you are consenting to this Privacy Policy. This Privacy Policy describes what information 37Games collects from users; how such information is used and stored; when such information may be disclosed to third parties; how users, parents, and guardians can control the use and disclosure of collected information; and how information is protected. PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE YOU USE OUR SERVICES OR WEBSITES.


If you have any questions or complaints regarding this Privacy Policy, please contact us at help@37.com.


1.Scope of this Privacy Policy


37Games publishes and operates games both on web and mobile devices. 37Games, including its affiliates, subsidiaries or other entities that control, are controlled by or are under common control with 37Games will be referred to as “37Games”, “we”, “our” or “us” in this Privacy Policy.


Your personal data will be controlled by 37Games Entertainment Co., Limited, incorporated in ROOM 702 KOWLOON BULIDING 555 NATHAN ROAD KOWLOON HONG KONG.


This Privacy Policy shall apply when you access and use our Services and Websites, including any websites, games, applications, domains owned or controlled by 37Games.


2.Information we collect from you


Information we collect directly from you


While using and accessing the Websites and Services, you may be required to provide some of your personal information to us. The personal information will be used for the purpose as described in this Privacy Policy.


If you are required to register an Account for the use and access of our Websites and Services, you may be required to provide information like:


• your age or birthday;
• your first and last names;
• your e-mail address;
• a password; and
• other information that helps us make sure it’s you accessing your account or helps us improve our services.


Sometimes you may want to create some personal features in the Websites or Services, in this situation, you may need to provide information like:


• a profile photo;
• game user name(s);
• your gender;
• biographic details (like your age or age range);
• approximate location information that you provide;
• links to your profiles on various social network;
• details about the games you play; and
• a player ID number that is created by 37Games and used to identify your profile.


Some of the information will be publicly accessible in default on the Websites and Services if you choose to create the personal features, including without limitation:


• Your player ID;
• Your first and last names; and
• Your player profile photo.


You can go to the privacy setting page of each Websites and Services for more information on the privacy settings.


Information we collect from social network operators or any third party platform


If you access or use our Websites or Services via social network operators or a third party, we may receive some information about you automatically depending on (1) the Websites or Services you are accessing or using; (2) the policy and terms of the social network operators and such third party platform; (3) your privacy settings; and (4) your friend’s privacy settings.


Examples of information that may be collected:
• your first and last name;
• your profile picture or its URL;
• your social network ID number or the ID number on the third party platform;
• the social network ID numbers or the ID number on the third party platform and other public data for your friends;
• the login e-mail you provided to that social network or the third party platform when you registered with it;
• your physical location and that of the devices you use to access our Services or Websites;
• your gender;
• your birthday and/or age range;
• other publicly-available information on the social network or the third party platform; and/or
• any other information that you or the social networks or the ID number on the third party platform shared with 37Games.


You can go to the social network or the third party platforms for more information on the privacy settings.


Technical information and automated information


Sometimes we will collect some technical information if you access or use our Websites and Services. Information collected, for example:


Cookies:


We may use cookies for the purpose including (1) keeping you in the log-in session or ensuring your transactions proceed successfully; (2) analyzing how customers use the Websites and Services, the performance of the Websites and Services (on an anonymous basis); (3) promoting our Services and Websites.


Other automated information:


• IP addresses;
• the type of computer or mobile device you are using;
• your operating system version;
• your mobile device’s identifiers, like your MAC Address, Identifier For Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI);
• your browser types;
• your browser language;
• referring and exit pages, and URLs;
• platform type;
• the number of clicks on a page or feature;
• domain names;
• landing pages;
• pages viewed and the order of those pages;
• the amount of time spent on particular pages; and
• game state and the date and time of activity on our websites or games.


The above information may be associated with your social network ID, your ID on third party platform or your ID in the Services and Websites.


Information from your mobile devices


If you access the Websites and Services via a mobile device, we may also collect information like:


• Your telephone number;
• Your country;
• Your location;
• Your contact list.


Information generated during your access and use of the Websites and Services


By using our Websites and Services, you may be provided ability to communicate with other players, including:


• participating in forums and message boards;
• posting public comments to other players or game boards;
• sending private messages or invitations to other players, either directly on our websites or to their e-mail accounts;
• chatting with other players; and/or
• posting photos or drawings.


The communication and information you generated by using the above functions will be stored and maintained by us for the safety and well-being of you and the rights and interests of us.


If you communicate with our customer services team, we may also record information including your ID, your in-game activities, your communication with us and anything else that you share with us.


If you submit your mobile telephone number or other identifier associated with your communication devices for us to provide you services like text messages, the information you provided will be recorded.


Payment Information


You may be provided the opportunity to purchase Virtual Currency or Virtual Items in our Websites and Services. To complete purchase transactions, our third-party payment processors may collect payment information from you, including your postal address, e-mail address and financial information (i.e. card number, passwords). We will not store your financial information, but we may get some non-financial information to complete the purchase, i.e. your name, billing address and the items purchased in order to fulfill your order (Non-financial Information). If you conduct the transaction on a third party platform, the Non-financial Information may also be collected by us to complete the purchase, you need to read the privacy policy of such third party carefully because your payment through such third party may be governed by such policies.


Information from Third Party


We may get information from third parties to better the operation of the Services and Websites.


3.How your information will be used


Our objective in storing and collecting your information is to provide players with a better gaming experience to the players by allowing us:


• to operate, improve and optimize our Services, Websites and our players’ experiences;
• to create your game accounts and allow you to play our games;
• to identify and suggest connections with other players and personalize our Services to you;
• to enable players to communicate with each other;
• to provide technical support and respond to player inquiries;
• to help prevent fraud or potentially illegal activities, and enforcing our Terms of Services;
• to manage and deliver contextual and behavioral advertising;
• to notify players of in-game updates, new products or promotional offers;
• to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners;
• to comply with our legal obligations, resolve any disputes we may have with you or other players, and to enforce our agreements with third parties; and
• to conduct research.


We may send you promotional information to the email address you provided us. If you have left your mobile numbers or identifiers of your communication device, we may send some promotional information to the mobile phone or other communication device.


4.How we share your information with third parties


We may collect and disclose to third parties aggregated, anonymized information that does not identify any single user for analysis, marketing advertising or other commercial purposes.


We may also disclose your information to a third party under the following circumstances:


• If you provide your consent;
• If you interact with players in our Websites or Services, your ID, a description of your game activity, your posts, your communication and your photo may be disclosed to those players;
• In case we engage in any advertisement or promotion, we may disclose information such as performance information, aggregated information (which does not identify individual users), certain technical information, or other information regarding your use and access of the Websites and Services. Tracking technologies such as cookies and beacons may be used in the advertisement or promotion.
• In the event that a proceeding, investigation, or litigation requires disclosure of your information under applicable laws or regulations.
• In case we believe, at our sole discretion, there is a threat to any rights of a third party, the public or us or the possibility of breach of any laws, regulations.


For the operation of our Websites and Services, we may need to engage third parties to provide hosting, payment, analysis, email or other services, to help us improve and provide our Websites and Services, therefore we may disclose your information with such contractors. We will contractually bind the contractors to keep your information confidential and to use the information solely on our behalf.


5.Manage and update your information


To manage and update information we collect from a social network operator or any third party, please refer to the setting page of such social network operator or third party.


To manage and update information you send directly to us, visit the setting pages in the Websites or Services.


If you want to manage or update the information 37Games has about you or have additional questions, e-mail us at help@37.com. We will respond to your request within thirty days.


If you want to stop us from actively using your information, please send a mail to help@37.com. We will respond to your request within thirty days.


If you want to stop us from using your dynamic location data, you can go to the settings on your mobile or communication device for the relevant application.


If you want to stop receiving promotional emails, any SMS or pushed information, please e-mail us at help@37.com. Please note your request may take up to 3 work days to be processed in our system during which time you may continue to receive emails.


If you want to stop us from using your cookies, you can go to the setting pages of the browser or go to the setting page of flash player. Please note if you stop us from using cookies, you will not be able to enjoy some of the features on the Websites or Services.


6.Do not tracking signals


Since there is no consensus on how to respond to do not tracking signals (DNS), we do not respond to (DNS) now.


7.Third party links


There may be third party links contained in the Websites or Services. The use of such links and the content linked will be governed by the privacy policy of such third parties. Thus if you have any questions, you need to consult with such third parties.


8.Policies for Children


37Games does not offer products for purchase by children, and we do not knowingly collect personal information from children. If you are under 13, you may use and access 37Games Websites and Services only with the permission of a parent or guardian.


37Games respects the privacy of parents and children and is committed to complying with the Children's Online Privacy Protection Act. If a parent believes that his or her child has submitted personal information to 37Games, he or she can contact us via email at help@37.com. We will promptly delete the information upon learning that it relates to a child under the age of 13. We recognize the importance of safeguarding the privacy of children and encourage parents to check and monitor their children's use of online activities regularly.


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10.The length of time we keep your information


We will keep your information as long as reasonable and necessary for the operation of our business.


11.Change of the policy


We may from time to time make changes to our Privacy Policy, we will tell you and other players by placing a notice on 37.com, or by sending you a notice to the e-mail address we have on file for you prior to the change becoming effective. We may supplement this process by placing notices on game blogs, social network pages, and/or forums and on other Websites. You should periodically check 37.com and this privacy page for updates.


12.Contact


If you have any questions, comments or concerns regarding our Privacy Policy and/or practices, please send an e-mail to 37Games.


37GAMES NETWORK TECHNOLOGY CO., LIMITED
Dated: Sep 1st, 2014