OneOneGames Privacy Policy

INTRODUCTION

If you use OneOneGames Applications , you acknowledge that you have read and understood this privacy policy. If you do not agree with this privacy policy (“this policy”), you must not use OneOneGames Services. If you change your mind in the future, you may withdraw your consent to use of your personal information in accordance with this policy. YOU AGREE THAT IF YOU ARE UNDER THE AGE OF 18 OR WHATEVER IS THE AGE OF LEGAL MAJORITY WHERE YOU ACCESS THE SERVICES, YOU REPRESENT THAT YOUR LEGAL GUARDIAN HAS READ, UNDERSTOOD, AND AGREED TO THIS POLICY.

At OneOneGames, we know your privacy is very important to you, so please take the time to carefully read our privacy policy. Our policy is designed to help you understand

1、What information do we collect about you;

2、How will we use the information about you;

3、Who do we share your information with;

4、How long do we keep hold of your information;

5、How can I exercise my rights over my information;

6、Dispute Resolution;

7、How will we notify you of changes;

8、Contact Information;

This privacy policy is an inseparable part of OneOneGames Terms of Service provided by OneOneGames Technology Hong Kong Limited. This policy applies to all OneOneGames services that directly reference or link to this policy but does not apply to OneOneGames services that have separate privacy policies that do not incorporate this policy.

SECTION 1： WHERE WE ARE A DATA CONTROLLER

1.The Types of Personal Information We Use

This section describes the different types of personal information we collect and how we collect it. We will collect and use the following information about you:

1.1. Information you provide us.

a) when you register for the Game (including your nominated nickname, or custom accounts and information we import from your connected social media account (WeChat, Facebook, Google) in order to set up your profile, including your name as it appears on your social media profile and your profile picture);
b) when you log-in as a ‘guest’ in order to use the Game (your nickname);
c) when you participate in a survey in the Game (in which case we will process the information you provide to us as part of the survey)
e) when you link your Account with Your Social Media Accounts (WeChat, Facebook, Google, etc.) or other external accounts or use other social media functions in accordance with Provider's policies.
f) when you use our Services or interact with other users and/or us through our Services. This includes, but is not limited to, the cookies that may be generated when you interact with us.

1.2. Information we collect about you.

a) Account Creation Information: Upon creating a OneOneGames Account, we may gather details such as username, birthdate, age, gender, email address, phone number, password, verification code, and open id, to assist in establishing and managing your account for our Services, offering game login Services, and for additional purposes outlined in this Policy.
b) Personal Profile Data: You have the option to create personalized profiles (where applicable) in our Services by selecting a nickname, crafting a personal signature, uploading an avatar, and providing other relevant details based on our service setup.
c) Chat Records: If you utilize chat functions in our Services (e.g., in-game chat), we may process the communication log and apply end-to-end encryption to safeguard your information.
d) Survey Responses: If you participate in our surveys, we will gather your responses.
e) Participation Information for Events and Promotions: If you choose to take part in any events or promotions organized by us (such as campaigns), we may collect information related to your participation, including your name, your user id, email address, mobile phone number, nickname, and country/region. In case you win any prizes, you may also need to provide us with your mailing address so that we can send you the prize. Your participation information may be added to your OneOneGames Account.
f) Game Data: We collect information about your in-game experience points, game progress, your level, score, and user statistics, and other similar data generated while using our Services. This information helps us understand your gaming preferences, provide personalized feedback, and enhance your overall experience with our Services.
g) IP Address, Location Information, and related Device Information: We collect information like IP address, location data such as geographical location, network status information, and device information such as device ID, device name, device type/model, MAC address, IMEI data, CPU data, graphics card model, OS version and language, time zone, screen DPI, device resolution, memory data, and graphics card model. Additionally, we gather information related to bugs, errors, crashes, and diagnostics, including registration/login time, game version, stack trace, crash reports, and abnormal process data to better understand your device, usage patterns, and location.
i) Transaction Information: If you choose to make purchases using your OneOneGames Account, we may need to collect your payment data and the data generated from such transaction information, such as points and membership level, to process the purchase(s) and related activities, which could include your name, bank/debit/credit card number, card expiration date, billing address (country, city, postal code, address), and CVV.
j) Customer Support Ticket ID & User Communications with Support: We collect information related to your support requests, including ticket ID and your communication history with our support team, to better assist you and improve our Services.
k) Marketing and Communication Data: We collect information about your preferences for receiving marketing materials, your communication preferences, and your communication history with us and our service providers, to tailor our communications with you and enhance your user experience.
l) Security-Related Information: We collect, and process data related to the security of your account and our Services, such as password changes and login history, to ensure the safety and integrity of our platform.
m) Other Information: We may collect additional information as required by specific Services or features within our platform. In such cases, we will provide separate privacy notices detailing the collection and usage of this information.

1.3. Data we collect from our partners.

b) Demographic data (such as to determine the coarse location of your Ip address)
c) Data to fight fraud (such as refund abuse in games or click fraud in advertising)
d) Data from platforms that the games run on (such as to verify payment)
e) Data for advertising and analytics purposes, so we can provide you a better Service

1.4. Cookies.

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

2. How we use your personal information

2.1 We will use the information in the following ways:

2.1.1 to create your account for the Game in accordance with your request;
2.1.2 Generated username and open id: to store your Game data (including level and progress) with your profile;
2.1.3 To contact or communicate with you by telephone, SMS and/or fax messages, email and/or postal mail or other means to manage and/or administer your relationship with us or your use of our services;
2.1.4 to maintain a record of your transaction history;
2.1.5 to manage, operate, provide and/or administer your use of and/or access to our Services (including, without limitation, your preferences), as well as your relationship and Account with us;
2.1.6 for identification and/or verification; (where applicable)
2.1.7 to conduct research, analysis and development activities (including, but not limited to, data analytics, surveys, product and service development and/or profiling), to analyze how you use our Services, to improve our Services or products and/or to enhance your customer experience;
2.1.8 If you enable chat services (audio or text) then we will process such data in order to deliver your messages to other users;
2.1.9 for security and verification purposes; identify and address bugs and assess game function for optimize action; solve game crashes and optimize compatibility of devices with the game; and to combat users registering for multiple accounts;
2.1.10 to allow other users to interact, communicate, or connect with you, including to inform you when another user has sent you a private message or posted a comment for you via the Game or Services;
2.1.11 to store, host, back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside of your jurisdiction;
2.1.12 to carry out due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;
2.1.13 to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on us or related corporations or affiliates;
2.1.14 for marketing and, advertising for any marketing activities where permissible under applicable law, and in this regard, to recommend products and/or services relevant to your interests, to send you by various mediums and modes (including email or SMS) of communication marketing and promotional information and materials relating to products and/or services (including, without limitation, products and/or services of third parties whom We may collaborate or tie up with) that We (and/or its affiliates or related corporations) may be selling, marketing or promoting, whether such products or services exist now or are created in the future. You can unsubscribe from receiving marketing information at any time by using the unsubscribe function within the electronic marketing material. We may use your contact information to send newsletters or marketing materials from us and from our related companies;
2.1.15 other purposes which are permissible under applicable law and which we notify you of at the time of obtaining your consent.

Such purposes may not be the case because the purposes for which we will collect/may collect, use, disclose or process your personal data depend on the circumstances at hand. However, unless Privacy Laws permit processing of applicable data without your consent, we will notify you of other purposes at the time we obtain your consent.

2.2 analyze, profile, and segment.

In all of the above cases and purposes, we may analyze, profile and segment all collected data.

2.3 Legal Basis for Processing

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

3. How We Share Your Personal Information

3.1 Share. We value the protection of your personal information, which is an important basis and part of the products and services we provide to you. We will only collect and use your personal information for the purposes and within the scope of this Policy or as required by law and regulations and will keep it strictly confidential. In general, we will not share your personal information with any company, organization or individual, except in the following cases:

(a) with your prior consent;
(b) where the sharing of your personal information is required by applicable law, regulation, legal process, governmental compulsion or judicial decision;
(c) to the extent required or permitted by law, it is necessary to provide your personal information to third parties in order to protect us, its users or the public from harm to their interests, property or safety;
(d) your personal information may be shared among our affiliated companies. We will only share personal information that is necessary and such sharing is subject to the stated purposes of this Policy. If an affiliate wishes to change the purpose of processing personal information, it will again seek your authorized consent;
(e) in order to provide you with improved, quality products and services, some of our Services will be provided by authorized partners. We may share some of your personal information with our partners in order to provide better customer service and user experience. We will only share your personal information for purposes that are legal, legitimate, necessary, specific, and explicit, and only as much personal information as is necessary to provide the services. We also require our partners to handle your personal information in accordance with our instructions, this Policy, and any other relevant confidentiality and security measures. Our partners are not authorized to use the personal information shared for any other purpose. If you refuse to allow our partners to collect the personal information necessary to provide the service, you may not be able to use that third party service on our platform.

3.2 Transfer. We will not transfer your personal information to any company, organization or individual, except for the following:

a) Transferring with obtaining explicit consent: after obtaining your explicit consent, we will transfer your personal information to other parties;
b) Provision in accordance with applicable laws and regulations, requirements of legal proceedings, and mandatory administrative or judicial requirements as may be necessary;
c) In the event of a merger, acquisition, transfer of assets, bankruptcy and liquidation or similar transaction involving the transfer of personal information, we will require the new company or organization holding your personal information to continue to be bound by this Policy before we require the company or organization to seek your authorized consent again.

3.3 Disclosure. We will only disclose your personal information publicly when:

a) After obtaining your express consent;
b) Disclosure based on law: We may disclose your personal information publicly if compelled to do so by law, legal process, litigation or governmental authority.

3.4 Without Your Prior Consent. In accordance with relevant laws and regulations and national standards, we may share, transfer, and publicly disclose personal information without obtaining your prior authorized consent in the following cases:

a) In connection with the performance of our obligations under laws and regulations;
b) Directly related to national security and national defense security;
c) Directly related to public safety, public health, and significant public interests;
d) Directly related to crime investigation, prosecution, trial and execution of judgments, etc.;
e) For the purpose of safeguarding the life, property and other significant legitimate rights and interests of the subject of personal information or other individuals but where it is difficult to obtain his or her consent;
f) Personal information disclosed to the public by the subject of the personal information himself/herself;
g) Personal information collected from information that is legally and publicly disclosed, such as legal news reports, government information disclosure and other channels.

In accordance with the law, sharing, transferring or publicly disclosing personal information that has been de-identified to the extent that the data recipient is unable to recover and re-identify the information subject shall not be deemed as sharing, transferring or publicly disclosing personal information, and such data shall be stored and processed without notice to or consent from you.

4. Data Retention

4.1 We will retain your personal information as described below (except if otherwise required to be retained by applicable law).

Personal Information	Retention Policy
Nickname	Stored for the lifetime of your use of the Game (i.e., until account deletion in accordance with your request) and then deleted within 30 days.
Social Connect Information: WeChat	Stored for the lifetime of your use of the Game (i.e., until account deletion in accordance with your request or you revoke access to your social media account) and then deleted within 30 days.
Social Connect Information:Facebook	Stored for the lifetime of your use of the Game until the account is deleted at your request, after which it will be deleted within 15days. If you do not request account deletion, this data will be deleted within 120 days after the Game is shut down or such data is no longer used by us.
Game Play Statistics (Level, Score/s)	Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 30 days. Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.
Chat Communications (Audio message)	Stored for 30 days on our servers and deleted automatically upon expiry of such period.
Chat Communications (Text)	Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 7 days. Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.
OpenID	Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 15 days. Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.
IP Address	Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 15 days. Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.
Device ID, Device Information	Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 30 days.Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.
Advertising ID	Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 15 days. Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.
Transaction Records	Stored for the lifetime of your use of the Game (i.e., until account deletion in accordance with your request) and then for the duration of any retention periods for which such data must be retained in order to comply with our legal obligations.
Customer Support Ticket ID & User Communications with Support	Support data is deleted within 30 days of a lawful request from you for the erasure of such data (see the Erasure section of this privacy policy).
Security-Related Information	Stored for the lifetime of your use of the Game, until account deletion in accordance with your request, upon which it will be deleted within 30 days.
Survey Information and content of survey responses	Stored for: (a) if you provide your email as part of the survey, up to 6 months (in order for us to follow up with you) and then the data is anonymized; or (b) if you do not provide your email as part of the survey, up to 1 month and then the data is anonymized.

The data deletion time listed in the above is only based on the information collected by the client of our Game itself, and if we obtain information from other partners (such as App Store, Google Play, Facebook, etc.), the corresponding time may be changed, and the specific time shall be subject to the disclosed partner's privacy policy.

4.2 Personal Information is kept until the end of its life cycle (as set out in the retention policy above). When destroying personal information, measures will be taken to make the personal information irrecoverable or irreproducible, and electronic files which contain personal information will be deleted permanently using a technical method which makes the files irreproducible.

4.3 In the event that the processing and retention period have terminated, but personal information is required to be retained continuously for other reasons including for the purposes as prescribed under applicable laws, the relevant personal information will be stored and maintained separately from other types of personal information. If you require us to destroy your personal information before the end of its life cycle (as set out in the retention policy above), we will destroy your personal information in accordance with local laws.

5. WITHDRAWING YOUR CONSENT AND DELETION OF PERSONAL DATA

5.1 The consent that you provide for the collection, use, and disclosure of your personal data will remain valid until such time it is withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using, and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing via email as described in Clause 12, by contacting our online customer service, or by initiating a process online through our designated portal.

5.2 In addition to withdrawing consent, you have the right to request the deletion of your personal data. This right is granted to all users, subject to applicable laws and regulations. If you wish to delete your personal data, you may submit your request via email as described in Clause 12, by contacting our online customer service, or by initiating a process online through our designated portal.

5.3 Upon receipt of your request to withdraw your consent or delete your personal data, we may require reasonable time for your request to be processed, usually within fifteen (15) calendar days. We will inform you of the consequences of acceding to the request, including any legal consequences which may affect your rights and liabilities to us.

5.4 Please note that depending on the nature and scope of your request, we may not be in a position to continue providing our Services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent or request for deletion, please inform us in writing in the manner described in Clause 12.

5.5 Please note that withdrawing consent or requesting deletion does not affect our right to continue to collect, use, and disclose personal data where such collection, use, and disclosure without consent is permitted or required under Applicable Laws.

5.6 From time to time, there may be additional processes and rules for the deletion of personal data, which will be communicated to you as necessary.

6. ACCESS TO, CORRECTION OF, AND DELETION OF PERSONAL DATA

6.1 If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below, or (c) a deletion request to delete any of your personal data which we hold about you, you may submit your request via email as described in Clause 12, by contacting our online customer service, or by initiating a process online through our designated portal.

6.2 Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

6.3 We will respond to your request as soon as reasonably possible, usually within fifteen (15) calendar days. Should we not be able to respond to your request within fifteen (15) calendar days after receiving it, we will inform you in writing within fifteen (15) calendar days of the time by which we will be able to respond. If we are unable to provide you with any personal data, to make a correction, or to delete your data as requested, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the Privacy Laws).

6.4 Children’s Privacy:
If you are under the age of 13, or under the minimum age required in your country, you must not use OneOneGames Services unless your parent or legal guardian has reviewed and agreed to this policy. We are committed to protecting the privacy of children. We do not knowingly collect personal data from children under 13 years old without verifiable parental consent. Parents or guardians may contact us at [insert contact email] to request the deletion of their child’s data.

SECTION 2：YOUR RIGHTS UNDER GDPR

This section applies to users located in the European Economic Area (EEA) and outlines your rights under the General Data Protection Regulation (GDPR).

7.1 Overview of Your Rights

Under the GDPR, you have the following rights:

- Right to Access

- Right to Rectification

- Right to Erasure ('Right to be Forgotten')

- Right to Restrict Processing

- Right to Data Portability

- Right to Object

- Rights Related to Automated Decision-making and Profiling

- Right to Withdraw Consent

7.2 Exercising Your Rights

To exercise any of these rights, you may:

a) Send an email to us as provided in Clause 12;

b) Contact our online customer service; or

c) Submit a request through our designated portal

We will respond to your request without undue delay and generally within 15 (fifteen) calendar days. However, we may extend this period or request additional information as needed. For more details on the process and potential extensions, please refer to Clause 5 of this Policy.

7.3 Detailed Explanation of Your Rights

7.3.1 Right to Access

You have the right to obtain confirmation about whether we process your personal data and, if so, to access this data and information about how we process it.

7.3.2 Right to Rectification

You have the right to have inaccurate personal data corrected or incomplete data completed.

7.3.3 Right to Erasure ('Right to be Forgotten')

You have the right to request the deletion of your personal data, subject to applicable laws and regulations. You can make this request using any of the methods outlined in Section 13.2.

7.3.4 Right to Restrict Processing

You can request that we restrict the processing of your personal data in certain cases, for example, if you contest the accuracy of the data.

7.3.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit this data to another controller.

7.3.6 Right to Object

You have the right to object to the processing of your personal data in certain circumstances, particularly regarding processing for direct marketing purposes.

7.3.7 Rights Related to Automated Decision-making and Profiling

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly affects you.

7.3.8 Right to Withdraw Consent

Where we process your data based on consent, you have the right to withdraw this consent at any time.

7.4 Limitations and Responses

We may need to retain certain information for legal or legitimate business purposes. If we cannot comply with your request, we will explain the reasons within the response timeframe mentioned in Clause 4.1.

7.5 Complaints

If you believe that our processing of your personal data infringes data protection laws, you have the right to lodge a complaint with a supervisory authority responsible for data protection.

7.6 No Fee Usually Required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.

7.7 Data Sharing Under the Digital Markets Act ("DMA")

7.7.1 This clause is dedicated to outlining our data sharing practices in compliance with the European Union's Digital Markets Act ("DMA") and is specifically relevant to Users located in the European Economic Area.

7.7.3 Additional Consent: In line with DMA, we will seek explicit additional consent from our users in the European Economic Area before any data sharing occurs. An in-app Consent Banner ("Consent Banner") will be displayed to obtain this consent, which is essential for utilizing your data in collaboration with Gatekeepers to enhance your service experience.

7.7.4 Impact of Non-Consent: If you choose not to agree to the Consent Banner, please be advised that your services within the Game will be affected. This may impact the personalization and overall quality of the Services we provide to you.

SECTION 3：MISCELLANEOUS

8. Information security

We have implemented administrative, physical and technical security measures that are designed to protect your information from loss, theft, misuse, unauthorized access, disclosure, alteration and destruction. You should understand though that, despite our efforts, no security can be guaranteed as impenetrable.

9. Links to Sites and Service Operated by Others

OneOneGames Service may contain links to other sites, applications, and services. Because OneOneGames does not operate those other sites, applications, and services, we cannot take responsibility for the privacy practices of the entities that operate them. We recommend that you consistently check privacy policies to understand an operator’s practices. As a reminder, this policy describes OneOneGames’s practices.

10. Changes

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

11. International Transfer

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

12. Contact & Complaints

Questions, comments and requests regarding this policy are welcomed. Please contact us via email at cs@oneonegames.com.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at cs@oneonegames.com and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws.

13. Jurisdiction

This policy and any action related thereto will be governed by the laws of People’s Republic of China without regard to its conflict of law’s provisions. Any dispute arising from or in connection with this Policy shall be submitted to Shanghai International Economic and Trade Arbitration Commission/Shanghai International Arbitration Center ("SHIAC") for arbitration, which shall be conducted in accordance with SHIAC's arbitration rules in effect at the time of applying for arbitration. The seat of arbitration shall be Shanghai, China. The language to be used in the arbitral proceedings shall be Chinese. The arbitral award is final and binding upon both parties.