Phoenix Ascent Privacy Policy

Welcome to our games provided by our company and its affiliates (hereinafter referred to as "our company" or "we"). Your trust is very important to us. We are fully aware of the importance of personal information to you and we attach great importance to your personal information and privacy security. When you use our services, we may collect and use your relevant personal information. We will explain to you through this Privacy Policy ("this Policy") how we collect, use, store and share your personal information when you use our games, as well as the relevant rights you enjoy. We will also take appropriate security measures to ensure that your personal information is secure and controllable.  
This Policy applies to the products and services provided by our company. If our affiliated companies' products and services incorporate our products and services but do not have independent legal statements and privacy policies, this Policy also applies to those products and services.  
It is important to note that this Policy does not apply to services provided to you by other third parties. If the third-party services you use through our company have separate privacy policies, those policies will apply.  
Before using any of our products or services, please carefully read and fully understand this Policy, especially the terms in bold/bold underlined. You should read these carefully and confirm your full understanding and agreement before using them. If you disagree with the terms of this Policy, your products may not function properly or provide related services, or your intended service results may not be achieved. You should immediately cease accessing or using our services. Your use or continued use of our services constitutes your consent to our collection, use, storage, sharing, transfer, and disclosure of your personal information in accordance with this Policy (including any updated versions).  
If you have any questions, comments, or suggestions regarding this Policy, you may contact us through the various contact methods provided by our company.

We provide adequate protections for personal data transferred from the UK, EU, or Switzerland, such as the use of standard contractual clauses.

1. Information Collection

We collect information from you when you use the Service, including when you use the Platform, play our games, use streaming services, register for an account, update your profile, access our content, sign up for a sign-up rewards program, make a purchase, participate in a promotion, or contact customer service.

A. Information You Provide to Us

The categories of information we collect when you use the Service include:

■ Contact Information: including your name, email address, phone number, and mailing address.

■ Account Information: includes your username, password, password hint, authentication, and account access information (e.g., PIN).

■ Payment Information: includes your guardian's email address, coupon code, mobile phone credentials, bank name, and credit card company.

■ Demographic Information: includes your date of birth, gender, and country.

■ Profile Information: includes your interests, comments, preferences, and favorites.

■ Commercial or Transactional Information: includes records of purchases, receipts of products or services, and consideration of purchases.

■ Content: includes the content of messages you send to us (such as feedback and customer support questions) or content you publicly post on the Service (such as product reviews or blog comments). We also collect the content of all messages you exchange with other users through the Service (for example, when using chat features).

■ Personal Contact Information: includes the first name, last name, email address, and mobile phone number of your personal contacts. With your consent, we may collect information about your contacts to fulfill your requests, which may include finding your contacts on the Service or inviting them to join. This feature is only available to residents of the United States. By using this feature, you acknowledge and agree that you and your contact are located in the United States and that you have obtained their consent for us to use their contact information to fulfill your request.

If you enter a promotion and are selected as a prize winner, depending on the prize, we may collect your driver's license number, passport number, or other similar identifiers, subject to the additional terms and conditions of the promotion.

We may collect the following information to provide prizes to the winners of the promotion.

Physical prizes: name, mailing address, telephone number, and email address.

Online prizes: name, mobile phone number, and email address.

You may voluntarily provide additional information not requested by us, but you assume full responsibility for this.

B. Automatically Collected Information

When you use the Services, we automatically collect information. The categories of information we automatically collect include:

Service Usage Information: the features you use, the pages you visit, the emails and ads you see, game data related to your interactions with our platform, games, and streaming services, misuse records and sanctions records, the products and services you view and purchase, the duration of your browsing, and referring and exit pages.

Device Data:The type of device or browser you use, your operator, software, internet service provider, your device's region and language settings, device identifiers (such as IP address), globally unique identifiers (GUIs), and advertising IDs.

The types of tracking technologies we use to automatically collect information include:

Log Files:Records of events associated with the use of the Service

Cookies:are small data files stored on your device that uniquely identify your browser. We use two types of cookies: session cookies and persistent cookies. Session cookies make browsing our website easier and expire when you close your browser. Persistent cookies help personalize your experience, remember your preferences, and support security features. Persistent cookies also allow us to serve advertising to you both on and off the Service. Persistent cookies can remain on your device for an extended period of time and can generally be controlled through your browser settings.

Pixels, also known as web beacons, are pieces of code embedded in websites, videos, emails, or advertisements that send information about your use of our services to our servers. There are different types of pixels, including image pixels (small graphic images) and JavaScript pixels (which contain JavaScript code). When you visit a website, video, email, or advertisement containing a pixel, the pixel may allow us or another entity to delete or read cookies from your browser. Pixels are used in conjunction with cookies to track activity on a specific browser on a specific device. We integrate pixels from other entities (such as the Facebook SDK) to track conversions, serve advertising on and off our Services, and provide additional features, such as the ability to connect our Services with your social media accounts.

Device Fingerprinting: This is the process of analyzing and combining data elements from your device browser, such as JavaScript objects and installed fonts, to create a device "fingerprint" that uniquely identifies your browser and device.

Application Technology: This refers to technology within our applications. It is not a browser-based technology like cookies and cannot be controlled through browser settings. For example, our applications may include SDKs (such as the Facebook SDK) that send information about your usage to servers. These SDKs may provide additional functionality, such as tracking conversions, serving ads on and off the Service, and linking the Service with social media accounts.

Storage Permission:When you save information or add a new device, you can choose to enable this permission to read or write information and image data used by the app.

Microphone Permission:When you use your device to issue voice commands, some devices require microphone access.

SMS Permission:SMS Permission: When you register an account using your mobile phone, some devices require SMS permission to obtain verification codes.

Additional Services for Photo Album (Photo Library) Image Access and Upload:After enabling photo album permissions, you can use this feature to upload your own photos/image files. This ensures that local images can be uploaded to your profile picture, allowing you to change your profile picture, post and comment, or provide support for issues you encounter when communicating with customer service. We may use your uploaded photos/images to identify links to events you wish to participate in, or use comments containing your uploaded photos/images to facilitate link sharing with friends, event promotions, and more.

For more information on our use of tracking technologies for analytics and advertising, and your rights and choices in this regard, please see the "Analytics and Advertising" and "Your Rights and Choices" sections below.

C. Information from Other Sources

We also collect information from other sources. The sources we collect information from include:

Data brokersWe purchase information from to supplement the information we collect.

■Social networks you interact with or use to access platforms, games, or streaming services.

■Partners who provide co-branded services, sell or distribute our products, or participate in joint marketing activities.

■ Publicly available resources, including information in the public domain.

2. Data Security

We implement and maintain reasonable administrative, physical, and technical security measures to protect your information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction. However, Internet transmission is not completely secure, so we cannot guarantee the security of your information.

3. Data Sharing

We share the information we collect as described in this Personal Data Protection Policy. The parties with whom we share information are as follows:

Service Providers: We share information with service providers who process information on our behalf. Service providers provide services such as payment processing, data analysis, marketing and advertising, website hosting, and technical support. We contractually prohibit our service providers from retaining, using, or disclosing your information for any purpose other than to provide us with the Service. However, we may allow the use of information that does not personally identify you (including aggregated or de-identified information) for any purpose unless prohibited.

Vendors and Other Parties: We share information with vendors and other parties for analytics and advertising-related purposes. These parties may act as service providers for us or, in certain circumstances, independently determine how to process your information. For more information about advertising and analytics, see the "Analytics and Advertising" section below.

Affiliates: We share information with affiliates and related entities, either as service providers or for our own internal purposes.

Partners: We share information with partners in connection with the provision of co-branded services, the sale or distribution of products, and participation in joint marketing activities.

Promotions and Merchandise: Our promotions and merchandise may be co-sponsored or co-provided by other parties. If you voluntarily enter a promotion or win a prize, we will share your information in accordance with the official rules or additional terms and conditions applicable to the promotion or prize, and for administrative purposes and legal purposes (e.g., winners' lists). By entering a promotion or accepting a prize, you agree to the official rules or additional terms and conditions applicable to that promotion or prize, and, except where prohibited by law, you consent to the use of your name, voice, and/or likeness by the sponsor and/or other entities in advertising or marketing content.

Public Forums:We share information you make public through the Service, such as your self-introduction or messages posted on bulletin boards. You are responsible for all information you disclose, so please consider carefully before disclosing it. Once a message is posted, it cannot be edited or deleted, subject to the additional permissions provided in the "Your Rights and Choices" section below.

Mergers or Acquisitions:We may provide information regarding, or negotiations of, a proposed or actual merger, purchase, sale, or other acquisition, business combination, or transfer of all or part of our business to another entity.

Security and Compulsory Disclosure:We share information as necessary to comply with the law or other legal process, including to meet national security or law enforcement requirements, and in response to lawful requests from state agencies. We also share information to protect the rights, property, life, health, security, and safety of our company, our services, or others.

Fulfilling Requests:We share information based on your request or instructions.

Consent:We will notify you and obtain your consent to share information.

Without limitation, the Company may use information that does not personally identify you (including aggregated or de-identified information) for a variety of purposes, except where prohibited by applicable law. For information about your rights and choices regarding how we share your information, please see the "Your Rights and Choices" section.

4. Other Parties

The Company provides some of its services through websites, platforms, and services operated or controlled by other parties. Furthermore, the Company may integrate technologies operated or controlled by other parties as part of its services.

For example:

Links:Our Services include hyperlinks to websites, platforms, and other services that are not operated or controlled by us.

Login: We may allow you to log in or create an account through social media or other platforms (e.g., Google, Facebook, Apple, Twitter, Line, or TikTok). If you choose to participate in these integrated logins, you may receive information on these approved platforms that you agree to share with us, such as your public self-introduction name, email address, and internal identifying information.

Brand Pages: We may provide content through social media. All information you provide to us when engaging with our content (e.g., through our Brand Pages) will be processed in accordance with this Personal Data Protection Policy. Furthermore, if you publicly mention our services on social media (e.g., by using a hashtag or our services on Twitter or in a post), we may use that information for reference within the relevant service.

Linked Platforms. We may offer the ability to link your account to other services within the relevant service to search for specific information about your account. For example, if you link your account to gaming platforms like Steam or Twitch, we may obtain information such as your gaming username, email address, photo, gaming performance, and highest scores through the link. For more information about how these platforms handle your information, please refer to their personal information protection policies and terms of use.

When you interact with other parties, including when you leave our services, those parties may independently collect your information and request information from you. The information collected and stored by those parties, including information shared with us, your rights and choices regarding services and devices, and whether information is stored in the United States or elsewhere, is subject to their own policies and practices. We recommend familiarizing yourself with and referring to the personal information protection policies and terms of use of those parties.

5. Advertising and Analytics

We use analytics services to help us understand how users access and use the Services. We also work with agencies, advertisers, ad networks, and other technology services to advertise our products and services on other websites and services. For example, we use Google and Facebook to show you ads, and you may see these ads on their platforms as well as on other websites and services.

As part of this process, we may incorporate tracking technologies into our own services (including websites, apps, and emails) and in ads displayed on other websites and services. Some of these tracking technologies may track your activity over time and across services in order to connect the devices you use and deliver relevant ads and/or other content to you ("Interest-Based Ads").

We also use prospect matching services (a type of interest-based advertising) to reach people (or similar people) who have visited our Services or who have been identified in one or more databases ("Matched Ads"). This is done by providing advertising partners with hashed lists of email addresses or by incorporating advertising partners' pixels into our services, where the advertising partners match common elements between our data and the corresponding data. For example, we may integrate a Facebook pixel into our services and share your email address with Facebook as part of their use of Facebook Matched Audiences.

As described above, vendors and other parties may act as service providers for us or independently determine how your information is processed in specific circumstances. We recommend familiarizing yourself with and referring to their personal data protection policies and terms of use.

Please refer to the "Information Collected Automatically" and "Your Rights and Choices" sections for more information on the types of tracking technologies and analytics we use on our services, as well as your rights and choices regarding interest-based and targeted advertising.

6. Changes to This Personal Data Protection Policy

We reserve the right to modify this Personal Data Protection Policy at any time. All changes will take effect immediately upon posting of the revised Personal Data Protection Policy. Continued use of our Services constitutes your acceptance of the posted Personal Data Protection Policy. We may notify you of material changes by email. ... To make a request, please send an email to the email address specified in "Contact Us" with "California Under 18 Content Removal Request" in the subject line to let us know the content you wish to remove. We will make every effort to remove content that is visible in the public eye. While we cannot guarantee complete or comprehensive removal of content, we may retain some content to comply with legal obligations, resolve disputes, and enforce contracts.

8. Data Use

We collect and use data for business and commercial purposes in accordance with this Personal Data Protection Policy. The purposes for data collection and use are as follows:

Operation and management of this service.

Perform the services you request, including responding to your comments, questions, and requests, processing refunds, and providing customer service.

Send technical announcements, updates, security alerts, information about changes to our policies, support, and administrative information.

Prevent and address fraud or violations of our policies or regulations, and prevent and address threats or harm.

Conduct research, including focus groups and surveys.

■Conduct research, including focus groups and surveys.

■Improve the Service and other websites, applications, marketing campaigns, products, and services.

■ Develop and send advertising, direct marketing, and communications about our and other individuals' products, offers, promotions, incentives, events, and services. ■ Implement marketing campaigns, including confirming your eligibility and delivering prizes related to your participation. ■ Fulfill any other purpose at your direction. ■ With your prior notice and consent.

Without limitation to the foregoing, the Company may use information that does not personally identify you (including aggregated or de-identified information) for a variety of purposes, except where prohibited by applicable law. For information about how we use your information and your rights and choices, please see the "Your Rights and Choices" section below.

9. International Transfers

Please note that information collected through this service may be transferred from your country of residence to, and processed, stored, and used in, other jurisdictions, including but not limited to the United States, Japan, South Korea, Singapore, Hong Kong, Thailand, the Philippines, Indonesia, Europe, and Russia. The data protection laws in other jurisdictions may differ from those in your country/region. Therefore, by using this service or providing information, you consent to the transfer, processing, use, sharing, and storage of your information in other jurisdictions as described in this Personal Data Protection Policy. For personal data originating from Europe, the United Kingdom, or Switzerland, we will provide comprehensive protection measures based on standard contractual clauses.

10. Your Choices and Rights

A. Account Information

You can access, update, or delete certain information you provide to us through your account by going to your account settings or emailing the email address specified in the "Contact Us" section below. We may require additional information to verify your identity. Please note that we will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our contracts.

B. Choices Regarding Tracking Technologies

Cookies and Pixels:Most browsers are defaulted to accept cookies. You can set your browser to reject or delete cookies by changing your settings. If you use multiple browsers on your device, you must change the settings for each browser separately. Limiting the functionality of cookies depends on your browser settings and restrictions.

Do Not Track:Your browser settings may allow you to automatically send "Do Not Track" signals to online services you visit. However, please note that there is no industry consensus on the actions website and app operators should take in response to these signals. Therefore, we do not monitor or act upon Do Not Track signals unless we are required by law to do so. For more information about Do Not Track, please visit http://www.allaboutdnt.com. ...

C. Analytics and Interest-Based Advertising

Google offers tools to opt out of the use of data from Google Analytics ( https://tools.google.com/dlpage/gaoptout ) and Google Analytics for Display Advertising or the Google Display Network ( https://www.google.com/settings/ads/onweb/ ).

Companies that serve targeted advertising are required to offer an option to opt out of receiving targeted advertising. Many of these companies are members of the Digital Advertising Alliance ("DAA") and/or the Network Advertising Initiative ("NAI"). To learn more about targeted advertising provided by these companies and to opt out of receiving specific targeted advertising, please visit the following websites. (i) For information on online targeted advertising by DAA members, please refer to https://www.aboutads.info/choices; (ii) For information on app targeted advertising by DAA members, please refer to https://www.aboutads.info/appchoices; (iii) For information on targeted advertising by NAI members, please refer to https://www.networkadvertising.org/choices/.

Opting out means that the member you choose will no longer serve you specific targeted ads. However, it does not mean that you will no longer receive targeted content and/or ads (e.g., related to the member's other customers or from other technology services). For Matched Ads, if you would like to opt out of our use of hashed email addresses for Matched Ads, please contact us as described in the "Contact Us" guide below and indicate your desire to opt out of Matched Ads. We will then stop sharing Matched Ads. Please note that if you opt out using one of these methods, your opt-out will only apply to the specific browser or device for which you opted out. We are not responsible for the effectiveness or compliance of any opt-out options or programs, or the accuracy of any statements made by any other entity regarding opt-out options or programs.

D. Communications

Emails:You may opt out of receiving active emails at any time by following the instructions provided in the email, clicking the unsubscribe link, or by sending an email with the text "unsubscribe" to the email address under "Contact Us." You cannot unsubscribe from inactive emails, such as emails about your account, transactions, services, or our ongoing business relationship.

Push Notifications:If you have chosen to receive push notifications on your device, you may opt out at any time by adjusting your device permissions or uninstalling the app.

Text Messages and Phone Calls:You can opt out of receiving text messages or phone calls at any time by using the following methods: (i) For text messages, you can text "STOP" to any text message we send you, or contact us via the "Contact Us" section below to indicate that you wish to opt out. (ii) For phone calls, you can opt out from any phone call we make, or contact us via the "Contact Us" section below to indicate that you wish to opt out.

Please note that your opt-out is limited to the email address, device, and phone number you use and will not affect subsequent subscriptions.

11. Contact Us

If you have any questions or comments about this Personal Data Protection Policy, data management, or legal compliance, please contact us through the following methods:

Email:herofille@gmail.com

This Personal Data Protection Policy is designed to be accessible to individuals with disabilities. If you encounter any difficulties understanding this document, please contact us throughherofille@gmail.com

12. Additional Disclosures for Nevada Residents

Nevada law (NRS 603A.340) requires each business to establish a designated address where Nevada consumers can submit requests directing them to request that a business not sell certain categories of personal information that has been or will be collected about them. "Sale," as defined under Nevada law, means the licensing or sale of personal information to another third party by a business in exchange for monetary consideration. If you are a Nevada consumer and would like to submit a request regarding compliance with Nevada law, please contact us at herofille@gmail.com

13. Additional Disclosures for California Residents

This additional disclosure applies only to California residents. The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights, including the right to know, the right to delete, and the right to opt out, and requires businesses that collect or disclose personal information to provide notice and an opportunity to exercise those rights.

A. Notice of Collection

In the past 12 months, we collected the following categories of Personal Data listed in the CCPA:

■ Identifiers:Including name, mailing address, email, phone number, online identifier (such as IP address), driver's license number, passport number, or other similar identifiers.

■ Customer Records.

■ Characteristics of protected classifications under California or federal law:Including gender, date of birth, and country of residence.

■ Commercial or Transactional Data: This includes records of any rewards, promotions, products, or services entered, purchased, received, or considered.

■ Internet Activity: This includes browsing history, queries, and interactions with websites, emails, applications, or advertisements.

■ Geolocation Data.

Inferring your predicted characteristics and preferences from the above information.

Please see the "Information Collection" section above for more information about the information we collect, including the sources of that information. We collect and use these categories of Personal Data for the business purposes described in the "Use of Information" section above, including for the administration of our services.

If "sale" under the CCPA is interpreted to include activities set forth in this Personal Data Protection Policy, such as those disclosed in the "Analytics and Advertising" section above, we will comply with applicable laws regarding such activities. We disclose the following categories of Personal Data for business purposes: identifiers, characteristics, commercial or transaction data, internet activity, geolocation data, and comments. Please see the "Information Sharing" section above for information about the categories of parties with whom we share information.

B. Right to Information and Right to Deletion

You have the right to receive certain details about our data management over the past 12 months. In particular, you may request:

The categories of personal data we collected about you;

The categories of sources from which the personal data was collected;

The categories of your personal data disclosed or sold for a business purpose;

The categories of third parties to whom the personal data was disclosed or sold for a business purpose;

The business or commercial purpose for which we collected or sold the personal data;

The personal data we collected about you.

In addition, you have the right to request the deletion of any personal data we have collected from you.

To exercise these rights, please submit a request to herofille@gmail.com. In your request, please specify the right you wish to exercise and the scope of your request. We will confirm your request within 10 days. We may need certain information to verify your identity and process your request. If we cannot verify your identity, we may deny your request for information or deletion. ...

D. Designating an Agent

You may designate an agent who is authorized to submit a request on your behalf. However, we will require written verification from your agent and verify your identity directly with you.

E. Right to Non-Discrimination

You have the right not to be discriminated against by us for exercising your rights.

F. Shine the Light

If you are a California customer, you may request (i) a list of the categories of personal information we disclosed to third parties for their direct marketing purposes during the preceding calendar year; and (ii) a list of the categories of third parties to whom we disclosed such information. To fulfill your request, please email us through the "Contact Us" section above, or send us a mailing address indicating that you are making a "California Shine the Light Request." We may request additional information to verify your identity, and we are obligated to respond to your request only once per year.

14. Additional Disclosures for European Data Subjects

A. Roles

European data protection law distinguishes between organizations that process personal data for their own purposes (also known as "controllers") and organizations that process personal data on behalf of other organizations (also known as "processors"). We act as the controller of the personal data collected when you interact with our websites, emails, and advertisements.

B. Legal Basis for Processing

European data protection law requires a "lawful basis" for processing personal data. Our lawful bases include: (a) you have consented to our or our service providers or partners processing for one or more specific purposes; (b) processing is necessary for the performance of our contract with you; (c) processing is necessary to comply with a legal obligation; or (d) processing is necessary for the purposes of the legitimate interests pursued by us or a third party and your interests and fundamental rights and freedoms are not overridden by those interests. Where applicable, we transfer your personal data to a third country that has appropriate safeguards in place (such as standard contractual clauses).

C. Your Data Subject Rights

You have the right to access, correct, or delete any personal data we collect about you. You also have the right to data portability and the right to restrict or object to the processing of your personal data. In addition, you have the right to request that we not process your personal information for marketing purposes (or provide it to a third party for processing) or for any purpose that is materially different from the purpose for which it was originally collected or for which you subsequently authorized. You may withdraw your consent at any time to any processing we perform based on the consent you have given us.

To exercise these rights, please contact us and specify the right you wish to exercise in the "Contact Us" section above. We will respond to your request within 30 days. We may request certain information to help us verify your identity and process your request.

Please note that we retain information for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, prevent disputes, prevent fraud, and enforce contracts.

If you have any questions about our compliance with laws, you may contact us as described in the "Contact Us" section above. You also have the right to lodge a complaint with the data protection regulator in your jurisdiction.

15. Additional Disclosures for Taiwan Citizens or Taiwan Data Subjects This additional disclosure applies only to Taiwan citizens or data subjects as defined under Taiwanese law.

A. Your Data Subject Rights

The Taiwan Personal Data Protection Act ("PDPA") provides Taiwanese citizens and Taiwanese data subjects with the following rights:

Right to access or request access to your personal data

Right to request a copy of your personal data

Right to correct or supplement your personal data

The right to request that we stop collecting, processing, or using your personal data;

The right to have your personal data erased

We may charge a fee for providing access to your personal data. To exercise these rights, please contact us at herofille@gmail.com

B. Retention Period of Personal Data

We process and use the data we collect in the manner set out in the "Data Collection" section above for as long as necessary to achieve the purposes set out in the "Data Use" section.

C. Where Your Personal Data Will Be Used

We process and use the data we collect in the manner set out in the "Data Sharing" section above, in the necessary areas, and for the purposes set out in the "Data Use" section.

D. Consequences of Not Providing Your Personal Data

If you choose not to provide us with your Personal Data, you may not be able to use some or all of the features of the Service. Additionally, you may not be able to receive or use some or all of the products, services, or promotional offers we offer through the Service.

16. Additional Terms for Japanese Residents

A. Parental Consent

If you are under 15 years of age, please obtain the consent of your parent or legal representative before agreeing to this Personal Data Protection Policy.

B. Sensitive Information

Without your consent, we will not collect or provide to third parties any "personal information of concern" (personal information requiring special attention), such as race, religion, social status, medical history, criminal record, criminal victimization, physical, intellectual, or mental disability, medical examination or other examination results, guidance or treatment for physical or mental improvement, arrests, searches, seizures, detentions, prosecutions, and other proceedings related to criminal cases, or investigations related to the protection of minors; observation and protective measures; hearings and decisions, protective measures, and other proceedings.

C. International Transfers

When we share your information pursuant to Section 4, your information may be transferred to, processed, stored, and used by third parties in jurisdictions outside of Japan, including the United States, South Korea, Singapore, Hong Kong, Thailand, the Philippines, Indonesia, and Russia. By using the Service or providing information, you consent to the transfer, processing, use, sharing, and storage of your information by third parties in other jurisdictions. If you do not consent to the transfer, processing, use, sharing, and storage of your personal information to third parties in other jurisdictions, please refrain from using the Service or providing any information about yourself.

17. Purpose of Collecting Personal Data

When using our game platform, you may be required to provide some personal information in order to continue to use our game platform's membership-related services. The main purposes of collecting personal information are as follows:

(1) Verify your membership identity - Therefore, we need to collect information such as your name, ID number, address, and email address when registering.

(2) Provide services and support for our game platform - This information includes contact information (address or email address, etc.), and in order to meet your requested services or support, this information will also be used to provide you with the latest information on products and services.

(3) Post comments in the discussion forum or answer surveys - Our company will collect email addresses or names.

(4) Collect data statistics to provide quality services - The usage information of the services may be used to aggregate statistics and conduct analysis, which will help our company develop the most suitable and user-friendly content for users.

(5) Marketing purposes – including contacting you directly or notifying you of the latest news through other channels. We strive to follow our strict guidelines and select reputable partners to provide services. However, our privacy protection does not cover information you provide directly to third parties (buyers/sellers in online auctions, online stores, or other linked websites). We recommend that you consult the relevant parties' codes and guidelines before providing any personal information.

18. Categories of Information Collected

(1) Basic Information: such as name, gender, date of birth, ID card number, passport number, telephone number, address, email address, marital status, family status, name of legal guardian, or other information that can directly or indirectly identify you; and if necessary, we will ask you to provide the original or a copy for verification.

(2) Account Information: such as financial institution account number, credit card number, transaction information, and other financial information; and if necessary, we will ask you to provide the original or a copy for verification.

19. Personal Data Usage Areas

The Company uses your personal data globally.

20. Disclosure of Collected Information

You acknowledge and authorize the Company to retain and store all information you provide and place it in one or more of the Company's databases. We will maintain full control and protection of all information in these databases in accordance with strict security and confidentiality standards and will not disclose it to third parties, except for the following individuals or organizations:

(1) Employees of the Company who have received formal training and authorization to handle customer information.

(2) Third-party service providers who provide support services. These providers are contractually bound to comply with the privacy standards set forth herein.

(3) Any person to whom the Company is required to disclose information in accordance with applicable laws, government or regulatory requirements.

(4) Any trustee or assignee of the Company's interests in the event of a restructuring, reorganization or similar event.

(5) Persons or institutions with whom you transact through the Company's platform services, such as financial services, banks, financial institutions or other institutions.

(6) The Company reserves the right to disclose your personal information to specific individuals in the following circumstances:

(a) The Company has sufficient reason to believe that disclosure of the information is necessary to identify or contact you.

(b) If you violate the terms of use of our website or products; or if your actions damage or interfere with our website, rights, products, or other users; or if the person who suffered the damage or interference takes legal action against you.

(c) If our company has sufficient reason to believe that you are involved in fraud, or other illegal or breach of contract behavior.

(7) Any advertisers or other websites you find linked to our website may also collect your personal information. This privacy policy does not apply to such advertisers or other websites, nor can it control their behavior.

21. Period of use of personal information

The Company may use your information during the operation period.

22. Consequences of not providing information or providing false information

(1) When joining the Company's website or applying for other services, and you are required to fill in your personal information, if the information you provide is reported by others or the Company finds that it is insufficient to confirm the authenticity of your identity, the Company may suspend your service. If the authenticity of your identity can be confirmed after you make corrections, the Company will resume your service. If the authenticity of your identity cannot be confirmed, the Company will not be able to process your request.

(2) When you join our website or apply for other services, you are free to choose whether to provide personal information. However, you may not be able to use services or specific products that require registration or relevant information (such as newsletter subscription, birthday discounts, etc.). In addition, if your account is used fraudulently or your information is stolen, if you do not provide or provide false information, your identity cannot be verified and the company will not be able to process your request.

23. Change Policy

We reserve the right to amend and update this policy from time to time. When the terms of this policy change, we will notify you through push notifications and pop-up windows when the version is updated so that you can keep up to date with the latest version of this privacy policy. Please carefully review any changes to this Privacy Policy. If you disagree with the revised or updated Privacy Policy, you have the right and should immediately cease using our products/services. Your continued use of our services constitutes your agreement to the revised Policy, and we will collect, process, or use children's personal information in accordance with the updated Privacy Policy.

Users should exercise extreme caution if you choose to disclose personal information in publicly accessible areas.

24. Data Security We are concerned about the security of collected information and have implemented measures to prevent unauthorized access or use. Our systems utilize appropriate security protocols for authentication and authorization to ensure the security of electronic communications. However, we assume no responsibility for any breach of security measures or unauthorized disclosure or use of information.

25. ​​User Choice: From time to time, we may email you to provide you with updates or unsolicited communications. If you no longer wish to receive unsolicited communications, you may contact our customer relations staff by email, who will remove you from the contact list for such communications. We will only retain your contact details for customer service purposes, such as to notify you of new offers and changes to our membership services.

26. Notice on Collection and Removal of Facebook Information (1) When users log in to the app using Facebook authorization, we will collect the user's email address and personal public information, mainly for account creation and providing personalized services. (2) If the user deletes the game app or removes the app authorization in Facebook settings and privacy, we will delete all the user's information. (3) If the user no longer uses Facebook authorization to log in, they can contact us to delete the Facebook authorization data content information of the app. Once deleted, it cannot be restored.

27. Other Rights

You may request the following matters with respect to your personal data after the Company confirms that you are the owner of the data:

(1) Check whether the Company holds any of your personal data,

(2) Review your data held by the Company,

(3) Request correction or deletion of your data, or contact customer service at herofille@gmail.com for deletion,

(4) Find out the Company’s policies and practices from time to time regarding the data and types of data held,

(5) Prohibit access to or use of your information and request to be informed of the actions taken by the Company in response to any such request. The Company reserves the right to charge a reasonable fee for complying with such request.