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PRIVACY POLIC

Introduction

This Privacy Policy governs the Websites and Services made available online by 37Games (collectively "37Games" or "We") 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.

For matters not covered herein, you may refer to our Electronic User License Agreement (https://support.37.com/about/privacypolicy).If you have any questions or complaints regarding this Privacy Policy, please contact us at help@37.com.

Please kindly be noted that this Privacy Policy does not apply to such online activities outside 37Games‘websites and games, and meanwhile we cannot control the activities on other websites. Also, we highly recommend that you read the privacy policy of any third party website you may be directed to before providing any personally identifiable information.

If you are a user from outside the European countries, the personal information you provide may be transferred to, stored, and processed within the European countries or other countries where 37Games maintains facilities or business operations.

Your using of 37Games‘online products or services, indicates that you assent to this Privacy Policy. If you do not agree to this Privacy Policy, please do not use our websites or other 37Games‘products or services. This Privacy Policy may change from time to time, so please check back periodically to ensure that you are aware of any changes. If we make a material change to this Privacy Policy, we will notify you by posting the change on our websites or in this Privacy Policy and, if necessary, give you additional choices regarding such change prior to the change becoming effective. Your continued use of the websites or other 37Games‘products or services will signify your acceptance of these changes.

Please kindly be noted that you are free to decide whether to provide your personal information to us or not, but disagreement on your side, to some degree, may adversely affect your user experience of our service.

 

Content


1. What is the 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. What information do we collect directly from you?

A: 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 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; 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.

 

3.  Where do we collect information from you?

A: We may collect, process and store users‘personal information globally, but mainly from countries and regions where our important business target places fall in, including Taiwan, Hong Kong, Macau, Singapore, Malaysia, Thailand, Indonesia, the Republic of Korea, and European countries and regions.

 

When you use our service, depends on what the specific service scenario (such as when you register the user account for our platforms and/games, to subscribe our new games, etc.) is, we may require your email address, telephone/mobile phone number, reference number of your personal identity (ID and/or passport, etc.), your address, gender, etc. In avoidance of doubts, we may only collect your phone/mobile number, reference number of your personal identity (ID and/or passport, etc.), address, gender in some places such as Taiwan, users who locates in European and American countries or regions may not need to provide phone/mobile number, reference number of your personal identity (ID and/or passport, etc.), or address information to us. For all users we may collect your IP address while you are using our service, but please be assured that we will not use your personal information that we received from you without your prior consent or beyond the scope that you consent to, or to utilize your personal information in combination with other information.

 

4.  What type of information do we collect from you?

A: According to information categories, we may collect the following information from you:

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

ü  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.

As the above mentioned, we may need cookies to provide our service to you. Though closing cookies cannot prevent you from utilizing our service, but please kindly be noted that you may found that you cannot use certain functions, such as automatic login and language settings.

ü  Some 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.

When you register, login, top-up or open a ticket in HLEP, your IP address may be collected by us, and we will only use it for statistical analysis, such as to determine whether certain channel is cheating in user numbers, or to analyze the source of users. 

ü  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.

ü  Other information:

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


• Your country;and,
• Your location.

 

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.

 

5. What Information do we collect from social network operators or any third party platform?

A: 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.

 

When you use our services via third party accounts, we may collect you third party account name and/or head portrait of such third party account. As for your friends list and/or email address etc., which are linked with such third party account, will subject to your decision to privacy policy of such third party platform.

 

6.  What if you are not agree to provide certain information to us, or you do not consent to our processing, transmitting and/or storing of your personal information?

A: Please kindly be noted that, in provision of service, we will need some of your personal information to proceed our service, and absence or delay in providing such information may prevent you from using part or all of our service, or adversely affects the user experience of our service. For example, when you subscribe our new games, we may need your mobile phone number to make such subscription, otherwise you might not subscribe the new game successfully; and you may need to provide your personal identity reference number and/or mobile phone number to us when you file an account appeal due to that you have forgot your password or other reasons, absence or delay in provision of such information may prolong our handling time of your account appeal. To learn more scenarios where we will require your information, we strongly recommend that you read this Privacy Policy carefully and comprehensively.

 

7. Do we share your information we collected from you with third parties platforms?

A: No, in most cases we do not provide your personal information to third parties. But if there is, we will obtain your consent prior to the provision, and we will enter into a separate agreement or include the confidential clause to make sure the confidentiality of your personal information. 

 

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.

 

8. How and in what purpose do we use your personal information?

A: In fact, we will only collect your personal information for provision of our service and to improve our service quality for better user experience, for example, we may use your phone/mobile phone number in promoting activities (to send push notifications, to send gifts, etc.). In most cases, we will not share your personal information we collected from you. But your prior approval will be obtained if we need to share your personal information to other third parties beyond the scope that you have consented to.

 

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.

 

9.     Do we use your personal information for analytical purposes?

A: We will only use your personal information within the purpose of improving our service quality, and we mainly conduct internal and analytical analysis with your personal information (excluding your personal sensitive information) , including statistical analysis and thematic activities analysis.

 

10.  Are the push notifications optional?

A: In provision of our service, especially when we promoting our games during certain period, we may send push notifications to your mobile via the mobile number you have provided to us, or through the platform messages to you. You may refuse to receive such mobile notifications through the instructions in each notification content, and you may refuse to receive the platform message from us via settings in our platform. But please kindly be noted that we may inform you of the sever maintenance time of our games, refusing to receive the platform messages may affect your game experience and time arrangement.

 

11.  How do we provide user support service to you?

A: In some cases, we may send emails, or to respond to the HELP TICKET you have opened in platform to support you in our service; and only in some regions/countries we may approach you by platform messages or phone/mobile phone. Please be assured that all the information you provide to us for our support, such as through the HELP TICKET system (where you can report bugs or feedback your suggestions), will only be utilized within the scope of addressing your problems and improving our service quality.

 

12.  What personal information do we store?

A: The information you provide to us in the user profile and in your account appeals will be stored.

 

13.   Do we use third parties to process your personal information?

A: No, in most cases we do not need third parties to process personal information. But if there is, we will obtain your consent prior to the processing and enter into a Data Processing Agreement with such third party processor so as to ensure the safety of your personal information. 

 

14.  How can you control the content you have disclosed to our platforms publicly?

A: Please kindly noted that we may offer BBS, chat rooms and/or in-game chat system in our service, and those are public place that all your disclosed content will be accessible by all users, which may entail risks to some extent. So, in avoidance of any risky activities, we hereby respectively remind you that you might want to think twice when you decided to disclose personal information, especially the personal insensitive information in the public place. As the service provider, we hereby inform you that it is optional to disclose your personal information to the public or not, and you can delete your disclosed content by contacting help@37.com.

    

15.  How to reach us if you have any questions or concerns regarding this Privacy Policy?

A: You can reach us by help@37.com and we will respond to you within thirty (30) days after successfully receipt of your email.

 

16. What safety measures and schemes have we adopted to assure your information and data protection?

A: To better protect your personal information and data, we have adopted a series of measures internally and externally, such as the following:

1) user password encryption processing when storage;

2) access control of internal data;

3) data is transmitted through the Intranet special line;

4) fortress mechanism;

5) data processing agreement when cooperated with third parties with users‘prior consent.

17.  How do we manage and update your information?

A: 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.


18. Do we track signals?


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


19. What are our suggestions regarding third party links?


A: 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.


20. What are our policies for children?


A: 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.

 

21.How long do we keep your information?
A: We will keep your information as long as reasonable and necessary for the operation of our business.


22. How to notice the change of our Privacy Policy?

A: We may from time to time make changes to our Privacy Policy, we will tell you and other players by placing a notice on https://support.37.com/en/about/privacypolicy 

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 https://support.37.com/en/about/privacypolicy and this Privacy Policy for updates.


23. How can you contact us?


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


37GAMES NETWORK TECHNOLOGY CO., LIMITED

This Privacy Policy was last updated on [2018.5.18] .