INTRODUCTION
We recognize that persons who access and/or use
(“you” or “Users”) our games, whether played on our website, on mobile devices,
PCs or on other platforms, (“FUNSPIRIT
Games”) and other related services, including but not limited to customer
supporting, marketing and advertising, (collectively, the “Services”) value
their privacy.
This Privacy Policy provides important
information regarding:
i) the data collected from you and the ways we
collect your data,
ii) the reasons why we collect your data,
iii) to whom we disclose your data, and
iv) the options you have about your personal
data.
Unless stated otherwise, this Privacy Policy
applies to the Services and all data that we collect from you. We therefore
provide this Privacy Policy to help you make an informed choice about whether
to use or continue using our Services. We may periodically update this Privacy
Policy by posting a new version on our website. Your continued use of the
Services after the effective date will be subject to the new version of Privacy
Policy.
This Privacy Policy is incorporated into, forms
part of and is subject to the Terms of Service. Your use of the Services and
any personal information you provide on the Site is subject to the terms of
this Privacy Policy and the Agreement.
Any terms not defined herein but defined in the
Terms of Service shall have the meaning ascribed thereto in the Terms of
Service.
I. THE DATA COLLECTED FROM
YOU AND THE WAYS WE COLLECT YOUR DATA
To use the Services, you may directly provide
certain personally identifiable information to us, such as:
· Contact
information (e.g. your name, personal identification number, postal or e-mail
address, telephone numbers)
·
Registered user name and password
· Character
Information (e.g. Account ID, character name, profile picture. Please be
reminded that such information may be disclosed to other users in connection
with the use of the Services and may also be made available to your connections
or the public on third party services)
· Personal
content preferences
· Profile
information (e.g. profile photo)
· Messages
to the Services (e.g. chat logs, your support tickets)
· Billing
and financial information (Please be reminded that the use of any merchant
service provider and/or third party platforms for the payment of the Admission
Fee is subject to the privacy policy of the relevant merchant service providers
and/or third party platforms)
· Other
data that you voluntarily provide (e.g. data to identify a lost account)
When you access our Website or use the
Services, we may use cookies and/or other similar technologies. Cookies are small
text files stored by browser(s) on your desktop computer or mobile device. Most
web browsers automatically accept cookies, but you can usually modify browser
setting to decline cookies. If you choose to decline cookies, you may not be
able to access certain Services and may experience technical problems receiving
current information from the cookie-disabled services. The use of cookies
and/or other similar technologies is to identify your browsers and to collect
data from your device such as:
· Data
about your Account
· Internet
Protocol (IP) address, web request, domain name, URLs, referring/exit pages,
platform type and mobile device identifiers (e.g. your device ID, advertising
ID, MAC address, IMEI)
· Data
about your device (e.g. device name, operating system, browser type and
language)
· Data we
collect with cookies and similar technologies
·
Monitoring of aggregate metrics (e.g. total number of visitors, pages viewed,
usage of the Services)
· General
location data
· Precise
geo-location data (i.e. GPS)
· Data
about your use of the Services (e.g. number of clicks, landing pages, pages
viewed and order of those pages, the amount of time spent on particular pages,
the date and time of your request, your game play and activity, your game
progress, your interactions with other players inside the Services)
· Other
pieces of information in connection with your various activities within or
through the Services or otherwise that are sent by your browser, device or
computer system when you access the Services, which are automatically tracked
and recorded by our servers
When you access the Services through any third
party services such as social networking sites (e.g. Facebook, WeChat, Google)
or from any mobile devices, you allow us access to certain information stored
on these third party services or mobile devices such as:
·
Demographic data (e.g. determination of your IP address)
· Data to
fight against fraud (e.g. refund abuse in games or click fraud in advertising)
· Data from
platforms that the games run on (e.g. verification of payment)
· Data
associated with your device (e.g. device type, technological information,
telephone number, country, contacts)
· Data to
do advertising, marketing and analysis
II. THE REASON WHY WE COLLECT YOUR DATA
To provider the Services, we process data
necessary to
· Create
Accounts
· Allow you
to play FUNSPIRIT
Games and use the Services
· Operate
the Services
· Verify
and confirm payments
· Provide
and deliver products and services that you request
· Send
service-related communications to you
To provide better Services to you, we have a
legitimate interest to collect and process necessary data to
· Update
and develop the Services
· Manage
and update your Account
· Develop
and improve your experience
· Manage
the relationship with you
· Provide
social features to you
· Customize
your service experience
· Respond
to your comments and questions and provide support to you
· Provide
offers in the Services as well as in other websites and services
· Send related
information (e.g. updates, security alerts, support messages) to you
· Enable
you to communicate with other users
To send you personalized advertising and
marketing materials, we may use the information collected from you such as ad
identifiers, age, country, region, gender, language, games played by you,
information related to the interaction of you with the Services and with other
users, and so forth.
We may also use various third party advertising
and marketing partners to assist us on our behalf and may share information
collected from you with such third parties for this purpose.
Hence, we have a legitimate interest to process
necessary data to
· Track the
content you access in connection with the Services and your online behavior
· Deliver,
target and improve our advertising and marketing materials
· Pass the
information collected from you to third party advertising and marketing
partners
By accepting this Privacy Policy and
downloading or continuing to use the Services, you consent to us and our
advertising and marketing partners collecting and using information about you
to personalize advertising and marketing materials and to improve your
experience unless you opt out of receiving this service.
We encourage you to review the privacy policies
of our third party advertising and marketing partners so that you can
understand how these third parties collect, use and share your information. We
are not responsible for the privacy policies of any third party whether
accessed through the Services or otherwise.
For information on how to opt-out from
receiving personalized advertising and marketing materials, see section 'The
options you have about your personal data” below.
Ensuring the security in the course of
performing the Services is a top priority for us. We take appropriate security
and technical measures to protect your information from unauthorized access,
loss and misuse. To achieve this purpose, we also request our suppliers who
process personal information on our behalf to take appropriate security
measures.
In order to keep the Service and its social
features safe and fair, to fight fraud and to ensure acceptable use otherwise,
we have a legitimate interest to process necessary data to
· Analyze
and monitor use of the Services and its social features
· Moderate
and monitor chats
· Prevent
cheating, crime or fraud
· Take
action against fraudulent or misbehaving users
· Pass your
information to agencies or organizations in charge of crime and fraud
prevention and repression
Despite
our efforts, we cannot guarantee the absolute security of your personal data,
nor can we ensure the security of any of the communication facilities provided
by us. We recommend that you exercise caution when disclosing any information
through the Services. In particular, please note that any personally
identifiable information or personally sensitive data that you communicate or
disclose to any user in connection with the Services may be collected and used
by others. As such, you should take care of the information shared online.
Please also be reminded that any questions answers, comments, submissions that
you post in the forum will be publicly available.
In all of the above cases and purposes, we may
use analytic tools, which may include third party’s analytic tools, to carry
out research, surveys and analysis, to create reports for use, to track
potential problems of the Services or to test out new game features and
content.
With your consent, we may process personal data
for additional purposes.
III. TO WHOM WE DISCLOSE YOUR DATA
1. Our personnel, related or affiliated
companies
We may provide your personally identifiable
information and non-personally-identifiable information to our personnel, our
related or affiliated companies for our legitimate business purposes. We may
also provide your personally identifiable information and
non-personally-identifiable information to other businesses or persons for the
purpose of processing such information or otherwise assist us in performing any
services on our behalf including in any advertising and marketing activities.
We require that these parties agree to process such information in compliance
with our Privacy Policy contained herein, and we will use reasonable efforts to
limit their use of such information and to use other appropriate
confidentiality and security measures.
2. Other users
As social features are a core element of our
games, other users may see your profile data, in-game activities and read the
messages you have posted.
Any user who receives any information including
personally identifiable information, from another user shall not disclose or
use such information, save where expressly permitted by that user or save where
such information has ceased to be of a confidential nature. In any event, we
shall not be liable for any unauthorized disclosure or use by another user or
other person of any content.
3. Partners working for us
To strengthen functions of our Services and
your experience of use, some of our Services maybe provided by partners in
charge of advertising, payment, analysis, marketing, social media partners,
personalized services, and/or personalized push notifications and
recommendations. To the extent of law and for the purposes of advertising,
payment, statistic analysis, marketing, personalized services and/or
personalized push notifications and recommendations, we may share with these
partners your data, including but not limited to your device information such
as its device brand, device manufacturer, device platform and device ID number,
your applications list, internet information and GPS location information, that
you have consented to our collection. In addition, these partners may also
access your data when you use their services and operate under their own
privacy policies. We encourage you to check their privacy policies to learn more
about their data processing practices. You may click here to
know the details of the data disclosing.
We may release personally identifiable
information and/or non-personally-identifiable information to, exchange such
information with companies and organizations or provide such information to
public authorities if required to do so by law, or in the good faith belief
that such action is necessary to comply with all and any applicable laws, or
where it is pursuant to or we are required to respond to a governmental,
regulatory, administrative or court order or directive, a subpoena or a search
warrant, or to combat fraud and illegal activity.
We also reserve the right to disclose personally
identifiable information and/or non-personally-identifiable information that we
believe, in good faith, is appropriate or necessary to enforce the Agreement,
take precautions against liability, to investigate and defend against any
third-party claims or allegations, to assist government authorities and
enforcement agencies, to protect the security or integrity of the Services, and
to protect the rights, property, or personal safety of ourselves, our users or
others.
IV. THE OPTIONS YOU HAVE ABOUT YOUR PERSONAL
DATA
You may opt out of receiving advertising and/or
marketing communications by following the instructions in such communications
or by using options provided in the settings in the game or on your devices.
You have the right to access and correct your
personal data.
You also have the right to have your personal
data deleted, object how we use or share your personal data, and restrict how
we use or share your personal data. You can always withdraw your consent.
If you have questions about data protection, or
any requests for resolving issues with your personal data, we encourage you to
primarily contact us through the game so we can reply to you more quickly. We
will respond to all requests within a reasonable time frame.
V. INTERNATIONAL DATA TRANSFERS
By accepting this Privacy Policy, Users
understand and agree that your data may be collected, stored, used in any
country and/or transferred to any country in the world. Because different
countries may have different data protection laws than Users’ own country, we
will try to ensure that adequate safeguards are in place to protect Users’
data.
VI. SPECIAL NOTE TO INTERNATIONAL USERS
The use of the Website and Services and this
Agreement is governed by and shall be construed and enforced under the laws of
Singapore, without applying any conflicts of law principles that would require
application of the law of any other jurisdiction. You agree to submit to the
personal non-exclusive jurisdiction in Singapore and any other court of
competent jurisdiction chosen by us.
In the event of any dispute arising out of or
in connection with this Agreement, including any question regarding its
existence, validity or termination, (a “Dispute”), we strongly encourage that a
resolution first be sought through our Customer Support service.
You agree that in the event that a resolution
is not obtained through our Customer Support service, such Dispute shall be
referred by you and may be referred by us to and finally resolved by
arbitration in Singapore in accordance with the Arbitration Rules of the
Singapore International Arbitration Centre ("SIAC Rules") for the
time being in force, which rules are deemed to be incorporated by reference in
this clause. The Tribunal shall consist of three (3) arbitrators, with you
appointing one (1) arbitrator and us appointing one (1) arbitrator and the
third arbitrator to be selected by the two (2) arbitrators so appointed. The
language of the arbitration shall be English.
Notwithstanding any of the foregoing, you agree
that we are entitled to submit such Dispute for resolution through any other
dispute resolution mechanism including the courts of any jurisdiction and we
shall further be entitled to seek any injunctive or other equitable relief in
the event of any breach or anticipatory breach by you, without any obligations
of providing any bond or surety or proof of damages.
You irrevocably waive all rights to seek any
injunctive or other equitable relief or to enjoin or restrain the operation or
exploitation of the Services or any part thereof. You further irrevocably waive
all rights to a class or representative action or as a named or unnamed member
in a class, consolidated, representative or private attorney general action.
VII. DATA SECURITY
We use commercially reasonable physical,
managerial, and technical safeguards to preserve the integrity and security of
your personal information. We cannot, however, ensure or warrant the security
of any information you disclose on, through or within the Services and you do
so entirely at your own risk. Please note that we cannot guarantee that such
information may not be accessed, disclosed, altered, or destroyed by breach of
any of our physical, technical, or managerial safeguards.
If we learn of a security systems breach, we
may attempt to notify you electronically so that you can take appropriate
protective steps. We may post a notice on the Website if a security breach
occurs.
If you create an Account with the FUNSPIRIT
Platform, you will be required to select a password that can be changed at any
time after you first log into the Account by using your current password. You
are solely responsible for maintaining the confidentiality of your password and
are fully responsible for all activities that occur under your Account and
password or your account with any other third party service. Users agree to (i)
notify us immediately if you are aware or reasonably suspect of any
unauthorized use of your Account or password or of any unauthorized access of
the Services through your Account, and (ii) ensure that you exit from your
Account at the end of each session.
VIII. MERGER, ACQUISITION, SALE OR INSOLVENCY
1. In the event that we are acquired by or
merged with another entity, we reserve the right, in any of these
circumstances, to transfer the information or assign our rights to the
information that we have collected from our Users as part of such merger,
acquisition, sale, or other change of control.
2. In the event of our insolvency,
reorganization, receivership, winding-up or assignment for the benefit of
creditors, or the application of laws or equitable principles affecting
creditors' rights generally, we may not be able to control how your personal
information is treated, transferred, or used.
IX. CHANGES AND UPDATES TO THIS PRIVACY POLICY
1. This Privacy Policy may be revised, amended
or modified periodically. Please re-visit this page to stay in touch with any
changes. Your access of the Services signifies your acceptance and agreement to
this Privacy Policy (as may be amended or revised from time to time).
If you have any questions or concerns about any
of the matters in relation to this Privacy Policy, including to exercise any of
your rights, then there are several ways of contacting us:
1.
via email to office.funspirit@gmail.com
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