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Infinity Nikki Personal Data and Privacy Policy


Last Updated: [2024-12-02]

Effective Date:[2024-12-02]

Preamble

Infinity Nikki Personal Data and Privacy Protection Policy (hereafter referred to as "Privacy Policy” or “Policy”) is made by and between you (hereafter referred to as “you/user”) and Infold Pte. Ltd. (hereafter referred to as “Infold” or “we”) whose registered office is at6 Raffles Quay, #14-06, Singapore.

Infold takes the protection of your personal data and privacy very seriously. To safeguard your legal rights when using the services we provide, including your interactions with us, registration, and use of our games as well as registration and use of other products or services we offer (hereafter referred to as "services"), we have created this Privacy Policy. It aims to explain how we collect, use, store, share and transfer such data when you use our services. Additionally, it outlines the ways we provide you to access to, update, control and protect this data. Specifically, if you use our services in South Korea, 인폴드 유한책임회사 개인정보 수집 및 이용 안내 shall apply; if you use our services in Japan, 『インフィニティニキ』プライバシーポリシー shall apply.

WE STRONGLY RECOMMEND THAT YOU READ THIS PRIVACY POLICY CAREFULLY AND IN ITS ENTIRETY, FULLY, PAYING PARTICULAR ATTENTION TO THE TERMS MARKED IN BOLD. PLEASE MAKE CHOICES THAT YOU DEEM APPROPRIATE IN ACCORDANCE WITH THE GUIDELINES OUTLINED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THE CONTENT OF THIS POLICY, IT MAY IMPACT OUR ABILITY TO PROVIDE OUR SERVICES EFFECTIVELY OR TO DELIVER THE EXPECTED SERVICES.

If you are a child (the specific age is determined according to the definition of “child” age in the laws of the country or region where you reside, for example, under 14 years old in South Korea, or under 13 years old in some other countries and regions) or do not meet the age requirement for using Infold game services in your country/region, you are not allowed to use our Services. If your age exceeds the age of a child stipulated in the laws of your country and region but you are a minor (the specific age is determined according to the definition of “adult” age in the laws of the country or region where you reside, for example, under 19 years old in South Korea, and under 18 years old in some countries and regions) or are otherwise ineligible as stated above,, you must read this Policy accompanied by your parents or legal guardians and use our Services only after obtaining the consent of your parents or guardians to all this Policy. These requirements also apply to all modifications or changes to this Privacy Policy.

PLEASE BE AWARE THAT WE DO NOT COLLECT PERSONAL DATA FROM MINOR USERSunder the age of 13 OR USERS WHO DO NOT MEET THE AGE REQUIREMENT SPECIFIED BY YOUR COUNTRY/REGION TO USE THE GAME SERVICE. IF YOU ARE THE GUARDIAN OF A RELEVANT MINOR AND YOU FIND THAT YOUR MINOR HAS USED OUR SERVICES AND SUBMITTED THEIR PERSONAL DATA, PLEASE INSTRUCT THEM TO STOP USING OUR SERVICES IMMEDIATELY AND INFORM US PROMPTLY SO THAT WE CAN TAKE APPROPRIATE MEASURES ACCORDINGLY. WE ALSO PROVIDE A REMINDER IN THE ANNEX OF THIS POLICY ACCORDING TO THE PERSONAL DATA PROTECTION REQUIREMENTS OF DIFFERENT COUNTRIES/REGIONS. IF YOUR COUNTRY/REGION IS LISTED IN THE ANNEX, PLEASE READ THE RELEVANT REGULATIONS IN DETAIL.

If you have any questions or concerns about this Privacy Policy or other relevant matters after reading the entire Policy, please contact us through the channels set in the Section “Contact Us” herein, and we will respond to you as soon as possible.

This Privacy Policy will provide you with information on:

I. How We Collect and Use Your Personal Information

II. How We Use Cookies and Similar Technologies

III. How We Process, Share, Transfer, and Disclose Your Personal Information

IV. How We Store and Protect Your Personal Information

V. Your Rights to Manage Personal Information

VI. Protection of Minor Information

VII. Update of the Privacy Policy

VIII. Miscellaneous

IX. Contact Us

I. How We Collect and Use Your Personal Information

According to the requirement of relevant laws and regulations or for the functionality of specific services, we collect, store and use the following information about you. The lawful collection, storage, and use serve the purpose of providing or optimizing our services, or user experience and ensuring the security of your account.

You understand and agree that: some individual services may necessitate enabling specific access permissions on your device to facilitate the collection and use of information related to those permissions. You also understand and agree that failing to provide such information may hinder your ability to register as a user, enjoy specific services provided by us, or achieve the intended results of using the relevant services.

For users of our game products, the game itself may be unavailable if the necessary information is not provided to build a user profile and identify the user, depending on the operation of the game system.

Should we use your information for purposes other than those described below, we will provide further explanation and seek your consent.

1. Personal Information You Provide

(1) When you register, log in, and undergo identity verification, you provide your Infold account (such as the email address or third-party account you used to register or log in to your Infold Account) as credentials for logging into the game, creating your username and password. The information you provide will be used to determine your age when using our services. Providing false information will result in the inability to use our services or may subject you to corresponding restrictions during service usage. You agree that we may collect your online identification information (including account number, password and IP address) and information on your commonly used personal device (including hardware serial number, hardware model, MAC address of the device, OS type, OS version, device name, carrier). This information will be used to identify you as our user and provide you with basic services. Please note that if you use an Infold Account registered or logged with third-party accounts (such as PlayStationNetwork account, Apple Account, Google Account, Facebook Account, etc.) to access Infold Games, subject to applicable laws and with your consent, we may obtain information generated or shared through your use of a third-party account to register/log in to your Infold Account, which may include  your unique identifier, account name, personal avatar and list of friends of such third-party account. This information is used to store your registration and login information, enabling you to log in to our system on different devices. If you do not consent to the authorization of such information, you will not be able to use your third-party account to register or log in to your Infold Account and thereby access our products and services. We need to remind you that you can only register as our user and access our services when you provide true and accurate information as described above. Failure to provide such information will result in the inability to log in or use all or part of our services.

(2) When you set to customize your character information, you may submit or edit your nicknames, personal taglines, and avatars.

(3) Information you submit through our customer service or for participating in the activities or questionnaire surveys held or conducted by us, including your name, gender, mobile phone number, telephone number, address, educational attainment, occupation, and personal income. We would like to remind you in particular that the submission and modification of the above information may be subject to special rules of the relevant interface If the aforementioned rules are inconsistent with the rules of this Privacy Policy, we will obtain your consent separately. If you choose not to participate in such activities or questionnaire surveys, or not to provide the above information to our customer service personnel, your access to other services will not be affected.

(4) In certain services, to facilitate the delivery of goods or services to you, you are required to provide the personal information of the recipient, including name, delivery address, postal code, contact number, and payment status. Specifically, we may share some of your information with third-party logistics or delivery parties during the shipping and delivery process in order to ensure safe, smooth, and accurate delivery of goods or services to you. Failure to provide such information will prevent the completion of the relevant delivery service. However, this will not affect your normal use of other features within our services.

(5) information you share with other parties through our services, and information you provide to us and store when you use our services.

2.Your information Shared by Other Parties

(1) Your information shared by other parties when they use our services.

(2) We may obtain information generated or shared by you when you use a third-party partner’s products or services. Please read the user agreement or privacy policy of the third-party partner’s product or service carefully.

3.  Your Information We Obtain

When you use our services, we may collect the following information based on the following usage patterns:

(1) In order to ensure your normal use of our services, maintain the proper functioning of the game’s basic features, optimize product, performance, enhance your gaming experience, and protect your account security, we may collect information related to your device or software. This includes the device identifier provided by your mobile device, web browser or other programs used to access our services (for example, Android ID, GAID for Android; IDFV, IDFA for iOS; motherboard serial number, CPUID, product ID, hard drive serial number, Machine GUID for PC; DUIDs for PlayStation; the validity, reset availability by the user, and acquisition method may vary for different identifiers). The unique device identification information is used solely during your use of the services we provide and is essential for service provision. Additionally, we collect device MAC address, device name, device settings and environment, device manufacturer, device time zone, device type, device model, device version, device serial number, OS type and version, system start up time (mobile device only), system activation time (iOS only), IP address, carrier information, mntID (iOS only), network type (Wi-Fi/5g/4g/3g/2g; wired network for PC), Wi-Fi status, Wi-Fi MAC address, Log information (Network diagnostic logs), application ID, client version, installer name, hardware and software feature information, hardware model, hardware serial number (SN), SD card data (internal/external SD card capacity, list of file names in SD card application cache directory), application name and version, SDK version, screen resolution and size (or device resolution), language region and country, battery and power status (mobile device only), CPU architecture information, timestamp, whether root/jailbreak, memory size and remaining memory, Google Advertising ID (Android only), emulator information (Android only), device landscape and vertical screen information, memory module information (PC only), graphics card information (PC only), whether to enable auxiliary functions (Android only), Baseband version (mobile device only), screen brightness (mobile device only), analog positioning switch (mobile device only), whether to enable ADB (Android only), SIM card status (mobile device only), acceleration sensor.

(2) When you interact with other players in the game through text, pictures, and other means, we will collect and store the information you send. This is done for the purpose of filtering pornographic, violent, political, or abusive content, as well as malicious advertisements and other inappropriate materials. The aim is to create a clean and safe gaming environment.

(3) When you use our services, we may collect your game log data, including your login logs, item logs, game battle logs, purchase logs, activity logs, upgrade logs and friend logs. This allows you to review your gaming history in the client, and the data will be used for statistical analysis in-game operations, addressing customer complaints, conducting anti-cheat analyses aimed at optimizing the gaming experience. Moreover, to enhance your gaming experience, we may synchronize the aforementioned data with the subsequent versions of the game or our other products you use.

(4) When you make purchases within the services provided by Infold, we will collect your top-up records and your transaction records. This is done to facilitate your review of transaction records and maximize the protection of your virtual property. Top-up records and transaction records are considered sensitive information. The collection of this information is necessary for us to provide consumption services, and transactions cannot be completed without such information.

(5) When you contact us, we may collect your communication or call records, including the contents or the contact information you leave. This is done to facilitate communication with you, help you resolve a problem, or record the resolution and outcome of the relevant issue.

(6) When you copy information from our products for sharing or receive shared information within our products, we need to locally access your device’s clipboard to read the information for the purposes of benefits, event participation, and sharing. We will only read information relevant to our services for verification and will not store such information. We will not collect any unrelated information from your clipboard.

(7) In order to ensure the security of your game account and create a fair, sound and safe gaming environment, we will collect your information from your device (such as ID, serial number, manufacturer, device name, type and version, model, and style of the device), device identifier [for example, board ID (motherboard UUID), CPUID, product ID, hard drive serial number, Machine GUID , for PC], memory module information (PC only), graphics card information (PC only), online identification information, network type, carrier information, game channel sources, battery and power status (mobile device only), whether to enable auxiliary functions (Android only), Baseband version (mobile device only), system activation time (mobile device only), screen brightness (mobile device only), analog positioning switch (Android only), whether to enable adb (Android only), and SIM card status (mobile device only). This information will be used to combat activities that may undermine the fair gaming environment or interfere with the normal operation of our game services (for example, such information may be used to detect piracy, screen plugins, and anti-cheat).

(8) Device permissions: During your use of our services, we will request permissions to access your system in specific business scenarios (the specific permissions may vary depending on the model and system version of the device you are using). This is to facilitate the collection and use of the corresponding information and enable the corresponding product functions and business scenarios. We will seek your consent before obtaining permission, and you can choose whether to authorize it or not. These system permissions include:

n Android

a.  Notification permissions: Notifications may include alerts, sounds, and icons and these settings can be configured in the app settings. We will use your notification permissions when you enable push notifications (for activities like energy recovery, event notifications, weekly missions, and background playback). Specifically, in some versions of the operating system, you may need to enable the precise alarm clock permission, otherwise, you may not be able to use the push function normally.

b. External storage rights: We will read and write your external storage rights when you use the in-game photo function (such as saving pictures and screenshots to your device), and send photos to customer service.

c. Camera permissions: We will use your camera permissions when you use QR code, and send photos to customer service.

d. Front-end service permissions: We will obtain your front-end service permissions when you use the download feature.

n iOS

a.  Notification permissions: Notifications may include alerts, sounds, and icons and these settings can be configured in the app settings. We may use your notification permissions when you enable push notifications (for activities like energy recovery, event notifications, weekly missions, and background playback).

b. Album access: we may use your album access when you use the in-game photo function (such as saving pictures and screenshots to your device), and send photos to customer service.

c. Camera access: We may use your camera access when you send photos to customer service.

d. Device network access: we may use your device network access during login, updates, service usage, network environment security checks, network connection status, and network speed measurement.

e. Microphone permissions: We may use your microphone permissions when recording with the camera during your interaction with customer service.

You may manage (enable/disable) the aforementioned permissions at any time on the System Settings page of your device.

Please note that: by enabling any permission, you authorize us to collect and use the relevant information to provide you with the corresponding services. Disabling any permission withdraws, the corresponding authorization, and as a result, we will no longer collect and use the relevant information based on such permission, making it impossible to provide you with the services corresponding to such permission. However, your decision to disable any permission will not affect our previous collection and use of information based on your authorization.

Please be aware that the access names may differ from one terminal to another due to variations in terminal devices and different operating systems. If you need to disable the permission enabled for using the above specific functions, most mobile devices will support your requirement. Refer to or contact the service provider of your mobile device for specific methods (for example, if your terminal device supports it, you may manage the aforementioned permission on the System Settings page of your terminal device at any time). If you have any questions, feel free to contact us through the channels set forth in the“Contact Us” section of this Privacy Policy.

4. We May Send Notifications to You

(1) When you use our services, we may contact you by phone or sending you emails, text messages, information or push notifications. You can follow our relevant prompts on your device, and we will send you the information described in this paragraph with your prior consent. If you no longer wish to receive this information you may choose to unsubscribe by following our relevant prompts on your device.

(2) We may send services-related announcements to you when necessary (for example, when a given service will be suspended due to system maintenance). You may not unsubscribe from any services-related announcements which are not advertisements.

(3) We will push your account updates, etc. to you through the system notifications of your device. You can choose to turn off our notifications on your device or select the information you wish to receive through the notification settings function we provide.

5. We may collect and use certain personal information without your authorization and consent in compliance with the relevant laws, regulations, and national standards in the country where you use our services, as well as to meet the request of judicial authorities and law enforcement agencies.

6. Notice regarding When You Disclose and Share Information

A number of our services allow you to disclose or share information about yourself not only within the game you used but also with all users of the service. For example, information you upload or post on our services (including your publicly available personal information and lists you create), your responses to information uploaded or posted by others and log data related to such data (such as friend’s relationships, level, ranking). Other users of our services may also share information about you (including log data). In particular, our sharing feature is designed to make it easy for you to share information about the game with other users, and you can make that shared information available as you like. As long as you do not delete the shared information, it will remain in the public domain. Even if you delete the shared information, it may still be independently cached, copied, or stored by other users or third parties not under our control, or kept in the public domain by other users or such third parties.

Therefore, please carefully consider the content of the information that you make public, upload, post and communicate through our services. In some cases, you may control the range of users entitled to view the information you share through the privacy settings of some of our services. If you want to remove your information from our services, please contact us to confirm how to do so, and any such removal will require verification of your identity.

II. How We Use Cookies and Similar Technologies

We, or our third-party partners, may collect and use your information through cookies, web beacons and other similar technologies, and store such information. We use our own cookies, web beacons and other similar technologies for the following purposes:

1. Remember your identity. For example, cookies and web beacons help us to identify you as our registered user or store other information you provide about yourself.

2. Analyze your use of our products or services. We may use cookies and web beacons to understand the activities you engage in while using our services.

3. Our products and services may contain cookies, web beacons and other similar technologies placed by our third-party partners. These technologies may collect non-personally identifiable information about you to analyze how users use those services or evaluate the effectiveness of advertising services. We strictly require our third-party partners to adhere to the provisions of this Privacy Policy. You can refuse or manage cookies, web beacons, or similar technologies through your browser settings. However, please note that disabling cookies, web beacons, or other similar technologies, may not impact your ability to enjoy the corresponding service experience, and some services may not function properly.

III.  How We Share, Transfer, and Disclose Your Personal Information

1. To ensure the stable operation of Infold Game Services or to achieve related functionalities, we may integrate features provided by third parties or collaborate through other means to fulfill the aforementioned purposes. The purpose, categories or use of the third party’s collection and processing of personal information, along with rules for personal information protection and exit mechanism, are governed by the third party’s privacy policies or relevant statement. We recommend checking the applicable third party’s privacy policies before use to understand how, why and to what extent the third party collects and uses users’ information, as well as its legal responsibilities. If the third party does not provide a dedicated privacy policy, we may provide a link to their official website to assist you in understanding their specific practices. Please note that third-party content may alter their personal information processing practices due to version upgrades, policy changes, or other reasons. You should refer to the official announcements of the third party for the most accurate and up-to-date information.

We may share your personal information with third parties, specifically including:

(1) Cloud service providers: Support data storage and basic maintenance;

(2) Security and Basic Function Service Providers: In order to implement engine services, push notifications, customer service, risk identification, anomaly detection, performance data collection, reporting, and analysis, we collaborate with third-party service providers and share necessary information. You can visit the privacy policies or official websites of these providers through the following links to learn more:

Google LLC: https://policies.google.com/privacy , https://firebase.google.com/terms

ShareFun Network Limited: https://aihelp.net/privacypolicy/

Aceville Pte Ltd.:

https://intl.anticheatexpert.com/#/doc-center/8fc4c1195346a2c74e472881bca42c4010698921

Alibaba Cloud (Singapore) Private Limited:

https://www.alibabacloud.com/help/en/sls/?spm=a2c63.p38356.0.0.6fee2222HNy36r  

(3) Third-party platform partners: When you log in using a third-party platform account, In turn, we may share certain details with the social network, such as your app ID, access token, and referring URL. The links to the privacy policies of such partners are as follows:

Apple, Inc.: https://www.apple.com/legal/privacy/en-ww/

Google LLC: https://policies.google.com/privacy#infocollect

Meta Platforms, Inc.:

https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0

Sony Interactive Entertainment Inc.:

https://www.playstation.com/en-sg/legal/psn-terms-of-service/?country-selector=true

(4) Data analysis and advertising service providers: We may share your device identifiers, device information, and other relevant data with our partners for purposes including data analysis, advertising placements, attribution, and similar activities. However, we will not provide personalized advertisements. For further details, please refer to the privacy policies of our partners, accessible via the following links:

AppsFlyer Ltd.: https://www.appsflyer.com/legal/privacy-policy/

(5) Payment Service Providers: When you purchase game currency or virtual items, we will share order numbers and order details with the relevant payment service providers to facilitate the transaction. Your financial account information will be collected and processed by the payment service provider in accordance with their privacy policy, and we do not collect your financial account information. For further details, please refer to the privacy policies of our partners, accessible via the following links:

Google LLC: https://policies.google.com/privacy#infocollect

Apple, Inc.: https://www.apple.com/legal/privacy/en-ww/

Sony Interactive Entertainment Inc.:

https://www.playstation.com/en-sg/legal/psn-terms-of-service/?country-selector=true

Adyen N.V.: https://www.adyen.com/privacy-policy

Checkout APAC Pte.Ltd: https://www.checkout.com/legal/privacy-policy

PayPal Hong Kong Limited: https://www.paypal.com/hk/legalhub/paypal/privacy-full

(6) Information Sharing Based on Infold Game Services: The sharing of information is initiated by you. Our services allow you to share your information not only within the game you are using but also with all other users using the service. When you choose to use these features, the content you share, including your avatar, nickname, etc., will be shared with third-party platforms or with the recipients of the shared information.

X Corp.: https://twitter.com/en/privacy#twitter-privacy-9.1

Meta Platforms, Inc.:

https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0

TikTok Pte. Ltd.: https://www.tiktok.com/legal/page/global/partner-privacy-policy/en

(7) For the purpose described in the section “How do we collect and use personal information”;

(8) For the purpose of fulfilling obligations and exercising rights as described in this Privacy Policy or other agreements made by and between you and Infold;

(9) For the purpose of understanding, maintaining and improving our products or services;

(10) On the basis of a legal request from you or your guardian;

(11) Required by laws and regulations or relevant authorities.

2. Necessary Sharing with Our Affiliates: To enable us to provide integrated services through the unified Infold account system and assist you in logging in and managing various products and services, your personal information of Infold Account (such as the email address or third-party account you used to register or log in to your Infold Account, avatar, nickname and personal profile) may be shared between us and our affiliates as required. Some of the Infold Game Services may be supported by our affiliates. To provide and optimize these services, we may share your personal information with our affiliates to achieve the data processing purposes stated in this Privacy Policy. In such cases, we will only share the necessary personal information for the purposes and within the scope outlined in this Privacy Policy.

Specifically, we will share your information only for lawful, legitimate, necessary, specific, and explicit purposes. If we or our affiliates share your personal information with third parties, we will ensure that these third parties use your information in compliance with this Privacy Policy and other appropriate confidentiality and security measures, or we will require them to re-seek your authorized consent.

3. Transfer. We will transfer your personal information only when:

(1) you expressly consent;

(2) required by laws and regulations or relevant authorities;

(3) in the event of a merger, consolidation, asset transfer, or any other similar transactions as our business continues to grow, we may transfer your personal information as a part of such transactions. We will inform you through push notifications, announcements or other means, and ensure that your personal information continues to be protected, or request the new managers to continue protecting your personal information in accordance with relevant laws and regulations, meeting the standard described in this Privacy Policy.

3. Disclosure. We will disclose your personal information only when:

(1) you expressly consent;

(2) required by the laws and regulations or relevant authorities.

4. Cases in which your prior consent is not required, including when:

(1) We may share, transfer or disclose your personal information without your consent in compliance with the relevant laws, regulations, and national standards of the territory where you use our products and services, as well as the writs of execution issued by administrative or judicial authorities.

(2) You acknowledge and agree that the information we collect may be de-identified and used for big data analysis. “De-identify” means that the information has been stripped of elements relevant to you, rendering it impossible to identify or restore to your personal information. We may publicly disclose and share with our partners information that has undergone statistical processing, ensuring information anonymity. This information will be used to understand how users interact with our services and to communicate general usage trends to the public.

IV. How We store and Protect your Personal Information

1. We will store your information only as long as necessary to fulfill the purpose described in this Privacy Policy, except:

(1) when required by the laws, regulations or regulatory authorities in the location where you use our services;

(2) for reasonable and necessary purposes to safeguard the public interest or to protect the personal rights, property safety, or other legitimate interests of our customers, ourselves, our group companies, our users or employees.

2. To provide you with the highest quality of service possible, our group adheres to diversification and globalization strategies, with subsidiaries located around the world. According to the service contract between you and us, your personal information may be processed on servers located outside your place of residence when necessary. Regardless of the server’s location, we will take appropriate measures to protect your rights in accordance with this Privacy Policy. The servers for these services are located in:

Frankfurt, Germany

Singapore

Virginia, USA

Tokyo, Japan

3.We will continually work to enhance our services. During these efforts, the server locations mentioned above may be adjusted and changed to further optimize our services.

4. Infold operates globally in the gaming business, and we have suppliers all over the world. We may access some of your information from anywhere, adhering to the principles of necessity, minimization, and anonymization. You acknowledge and agree that our support team, engineering team, and other teams around the world may access and process your information from locations other than your place of residence. The information we collect or share with third-party partners may also be stored and processed on our third-party SDK servers located in the United States, Germany, Japan and Singapore. Additionally, your information can be accessed from outside your location by our support, engineering and other teams worldwide, including Singapore.

5. If we terminate the services or operations, we will promptly cease the collection of your personal information promptly. We will notify you in advance, as required by the relevant laws and regulations. Following the termination, we will delete or anonymize your personal information unless otherwise required by relevant laws, regulations and regulatory authorities.

6. We will delete or anonymize your personal information if you request to delete your account, voluntarily delete your information or after a certain necessary period of time, unless a specific retention period is required by the laws and regulations where the server of your registered account is located.

7. If the information we collect needs to be transferred across borders within our group, we will ensure that such transfer is complies with laws, regulations and the requirements of the country where the information originates. This will be done and in accordance with the stipulations of relevant regulatory authorities to provide adequate protection for your personal information. We will de-identify and anonymize your personal information to ensure security and confidentiality. Additionally, we ensure that the region where the information is received has the same level of information protection capability as your region.

8. We will take reasonable and necessary security protection measures conforming to industry standards, to reduce the risk of loss, misuse, unauthorized access or disclosure of information. For example, in some products or services, we will use encryption technology (such as SSL) to protect your personal information. However, you understand that, due to technical limitations and various malicious means that may exist, we cannot guarantee 100% security of your information, even if we have done our utmost to strengthen our security measures. Moreover, you understand that the system and communications network you use to access our services may experience issues beyond our control.

9. When a personal information security incident occurs, we will promptly inform you in accordance with relevant laws and regulations. This notification will include the basic information about the incident, its possible impact, the measures we have taken or will take to address it, recommendations on what you can do to prevent and reduce risks, available remedies, etc. Additionally, we will notify you promptly about the incident by email, letter, phone calls, push notifications, or other suitable means. If individual notices to personal information subjects are challenging, we will publish announcements in a reasonable and effective manner. We will also proactively report our handling of the personal information security incident as required by the regulatory authorities.

V. Your Rights to Manage Personal Information

We understand your concerns regarding your personal information and make every effort to ensure that you have the right to access, correct, delete, and revoke authorization for your personal information. This ensures you have full control to safeguard your privacy and security. Your rights include:

1. Right of Access

You have the right to access the personal information you have provided to us, such as avatar, nickname, player number, motto and rankings, according to the relevant instructions (or settings) of our services. If you encounter any issues accessing or intend to access other unavailable personal information described above, you may contact us through the contact information provided in this Privacy Policy.

2. Right to Correct or Modify

When you find the personal information you provide is inaccurate, incomplete or update needed, you may correct/modify your personal information when using our services.

(1) For certain personal information, we offer operational settings on the relevant function pages of the game.  You can directly make corrections or modifications. For instance, to correct or modify your avatar in the game, please follow these steps: Pear-Pal→click on the avatar→click the Edit button.

(2) If you encounter difficulties while exercising the aforementioned rights, or if online correction or modification services are currently inaccessible, you have the right to correct or modify the inaccurate or incomplete information. This is subject to identify verification, and the correction or modification should not compromise the objectivity and accuracy of the information. In certain circumstances, particularly when the information is inaccurate, you can request us to correct or modify your information via our feedback, error reporting or customer service, unless otherwise required by laws and regulations. However, for security and identification reasons, certain initial registration information submitted during registration may not be modifiable.

3. Right to Delete

You may request the deletion of your personal information directly unless it has been anonymized or is required by laws and regulations, including in cases where:

(1) The purpose of processing personal information has been achieved or no longer exists, or there is another legal ground;

(2) Our handling of your personal information violates any laws or regulations;

(3) We collect or use your personal information without your consent;

(4) Our handling of your personal information violates the agreement with you;

(5) You delete your game account;

(6) We terminate services and operations.

If we decide to respond to your request for deletion, we will also notify the entities that have obtained your personal information from us and request their prompt deletion, unless otherwise required by the laws and regulations, or if these entities are independently authorized by you. When you delete your information from our service system, we may not delete the corresponding information from the backup system immediately but will do so at the time when the backup is updated.

4. Right to Revoke All or Part of Your Authorization

As mentioned above, certain functions of our services require your device permissions, including notification, camera, etc., as set forth in Section I “How We Collect and Use Your Personal information ”. You have the option to withdraw or cease your ongoing authorization for these permissions at any time. Updating the version will not alter the status of previously set permissions without your explicit consent. Additionally, you can permanently revoke the authorization for us to collect your personal information by deleting your account. Upon withdrawal of authorization, we will no longer be able to provide you with the corresponding services. However, please note that your decision to withdraw such authorization will not affect our prior handling of your information based on your initial authorization.

5. Right to Delete Your Account

You can request the deletion of your game account through our customer service personnel or other means we have publicized. Once your game account is deleted,  you will no longer be able to use our services with that account. All accumulated but unconsumed rights and interests of the game account, as well as all future overdue benefits and other rights and interests, will be erased. Contents, information, data and records associated with the game account will be deleted or anonymized. Please note that once your game account is deleted, it cannot be restored. For more information on the process and conditions of deleting “Infinity Nikki” game accounts, please contact our customer service.

6. Right to Request Copies of Your Personal Information

You have the right to request copies of your personal information by contacting us at any time via the contact information provided in this Privacy Policy. We will respond to your request within fifteen working days.

7. Right to Constrain Automated Decision-making in Information Systems

In certain business functions, we may rely on non-human automated decision-making mechanisms, including information systems, algorithms, etc. If these decisions significantly impact your legitimate rights, you have the right to request an explanation, and we will provide appropriate remedies.

8. How We Address Your Requests for the aforementioned Rights

We will respond to your requests within fifteen working days while verifying your identity as a user. If you have any concerns during the process of your personal information, you may contact us via the contact information provided in “Contact us”. However, we may be unable to respond to your requests if prohibited by legal writs issued by administrative or judicial authorities in the territory where you use our services.

VI. Protection of Minor Information

Please note that we do not collect personal information of child (the specific age is determined according to the definition of “child” age in the laws of the country or region where you reside, for example, under 14 years old in South Korea, or under 13 years old in some other countries and regions). If you are the guardian of a relevant minor who has used our services and submitted their personal information, please instruct them to stop using our services immediately and inform us promptly so that we can take appropriate measures accordingly. Please refer to “Your Rights to Manage Personal Information”. Our customer service personnel may verify your relationship with the minor as needed. After such verification, we will assist you in deleting such information and corresponding game account.

If we are notified that we have collected personal information of a child without the consent of a guardian, we will promptly impose restrictions on the account and delete the relevant personal information.

VII. Update of the Privacy Policy

We may update this Privacy Policy periodically, and such updates shall be considered as a part of this Privacy Policy. If these revisions lead to a significant reduction of your rights under this Privacy Policy, we will notify you by prominently displaying the revisions on our homepage, sending you an e-mail, or providing other forms of notification. In such case, your continued use of our services implies your agreement to be bound by the updated terms.

VIII. Miscellaneous

1. This Privacy Policy applies to all our services, except for certain specifically expressed services. These specific services will be governed by distinct personal information protection statements or rules. The personal information protection statements or rules for these certain services will provide more detailed information on how we use your information in those services. They form an integral part of this Privacy Policy. If there is any inconsistency between any personal information protection statements or rules and this Privacy Policy, the former shall prevail.

2. Except as otherwise provided in this Privacy Policy, the terms used herein shall have the same meanings as those defined in other publicly available documents published by us.

3. The headings of this Privacy Policy are for convenience and readability purposes only, and do not affect the meaning or interpretation of any provisions in the text.

4. This Privacy Policy shall be governed by and construed under the laws of Singapore excluding its conflict of law principles. The Convention on Contracts for the International Sale of Goods will not apply. You agree and acknowledge that all disputes relating to this Agreement or Infold shall first be resolved by peaceful negotiation between the parties (any dispute requiring negotiation shall be notified to Infold in writing in accordance with the contact information provided in this Agreement) . If a solution to the dispute cannot be effectively reached after thirty days of negotiation, any claims or legal actions between you and Infold shall be referred to Singapore International Arbitration Centre (SIAC) for arbitration which shall be conducted in accordance with such commission’s arbitration rules. The arbitral award is final and binding upon both parties. If the above arbitration terms are not enforceable on any dispute, both parties agree that such dispute shall be brought to a court in Singapore. You hereby consent to, and waive all defenses of lack of personal jurisdiction and/or forum non-convenience with respect to venue and jurisdiction, whether by arbitration or judicial judgment. Subject to applicable laws and regulations, both parties confirm that any dispute resolution proceedings, whether in arbitration or court, will be conducted only on an individual basis and not a class or representative action. If you do not accept these terms, please terminate your use of our services or send us a written notice of your desire to opt out of arbitration within thirty days.

5. Severability

If any provision herein is held to be invalid or declared illegal, or unenforceable for any reason, such provision shall be severed and deleted from this Privacy Policy. The remainder of this Privacy Policy shall remain unaffected and continue in force and effect. However, if a class action or arbitration waiver is held to be invalid, unenforceable, or illegal, you agree that such waiver may be inseverable. In other words, under no circumstances may any litigation proceeding be conducted on a class basis without our prior express written consent.

6. No Assignment

You may not assign, transfer, charge, or subcontract, whether by operation of law or otherwise, all or any of your rights or obligations hereunder without our express prior written consent. Otherwise, we may, at our sole discretion, terminate our provision of any services to you without further notice. If such a restriction on assignment is unenforceable under the laws of your country/region of residence or place of residence, this Privacy Policy shall remain binding upon you and your successors. Notwithstanding the foregoing, we reserve the right to assign, charge, or subcontract all or any of our rights or obligations hereunder at any time.

7. Infold’s failure to exercise, delay in exercising or partial exercise of any right under this Privacy Policy or applicable laws shall not be deemed a waiver of such right, nor shall it prevent Infold from exercising such right in the future.

8. The term “affiliate” as used herein, refers to any entity that directly or indirectly controls, is controlled by, or is under common control with Infold.

9. Infold may translate this Privacy Policy into other languages.

10. In addition to any other restrictions set forth herein, Infold shall not be liable for any delay in performance or non-performance caused by events beyond Infold’s reasonable control, such as acts of government authorities, acts of nature or other events not reasonably controllable by herein.

11. You acknowledge that you have voluntarily read and accepted this Privacy Policy, and you do not anticipate receiving any compensation beyond what is explicitly provided herein.

12. If this Privacy Policy conflicts with local laws in your country or region of residence, the local laws will take precedence.

IX. Contact Us

1. We have established a dedicated department for personal information protection in compliance with this Privacy Policy. If you have any questions, comments or suggestions about this Privacy Policy, our privacy measures, or matters relating to your personal information, you may contact us by sending an email to dpo@infoldgames.com.

2. In general, we will respond to your questions, comments, or suggestions within fifteen working days after receiving them and verifying your user identity, unless otherwise required by the laws and regulations of the territory where you use our services.

3.Contact Your Local Information Protection Authority

If you have concerns about how we use your information, you have the right to lodge a complaint with the information protection authority in your country of residence, as required by applicable laws.

EU:

For more information please visit:

https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en

UK:

If you have any concerns about our use of your information, you also have the right to lodge a complaint with the Information Commissioner’s Office, which oversees the use of personal information in the UK. You can contact them via the following helpline:

Tel: 0303 123 1113

SUPPLEMENTAL JURISDICTION-SPECIFIC TERMS

Some jurisdictions’ laws contain additional terms for users of the game services, which are set out in this section.

If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.

Australia

Overseas Recipients

We take reasonable steps to ensure that third party recipients of your personal information located outside Australia handle your personal information in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at dpo@infoldgames.com.

Correction

You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your game account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at dpo@infoldgames.com.

Children

If you are under the age of 13, you will not be able to use our services.

Transacting Anonymously

Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the game services. You acknowledge that if you do not provide us with your personal information, we may be unable to provide you with access to certain features or sections of the game services, including social media integration and in-game purchases.

Data Transfers

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.

California

This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).

Rights under the CCPA

If you are a California resident, you have the right to:

1. Request we disclose to you free of charge the following information covering the 12 months preceding your request:

(1) the categories of personal information about you that we collected;

(2) the categories of sources from which the personal information was collected;

(3) the purpose for collecting personal information about you;

(4) the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and

(5) the specific pieces of personal information we collected about you;

2. Request we delete personal information we collected from you, unless CCPA recognizes an exception; and

3. Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.  

We will acknowledge receipt of your request within 10 business days of receiving it and provide information on how we will likely handle the request. We aim to fulfill all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

How to Exercise Your Rights

First, you may wish to log into your account and manage your information from there. If you are a California resident to whom the CCPA applies, you may also exercise your rights, if any, regarding other information by contacting us at dpo@infoldgames.com.

Canada

If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us at dpo@infoldgames.com. Our privacy experts who monitor this email address are also able to answer any questions users may have about the collection, use, disclosure or storage of personal information by our service providers.

Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.

EEA, UK and Switzerland

If you are located in the European Economic Area (EEA), United Kingdom (UK) or Switzerland, the following section applies to you in addition to the Privacy Policy set out above.

Information Subject Rights

In addition to the information set out in section “Your rights to manage personal information”, you have the right to:

1. restrict the processing of your personal information;

2. object to the processing of your personal information.

Legal basis for processing your personal information

We may only use your personal information when we have a “legal basis” to do so. Our legal bases for collecting and using the personal information for the purposes of our Privacy Policy above is:

1. To establish and perform our contract with you (i.e. our “User Agreement”) and to provide our services;

2. To achieve our or our partners’ legitimate interests, where those interests are not overridden by your information protection interests of fundamental rights and freedoms, e.g. to protect our legal rights, to pursue or defend legal claims, to improve our services;

3. Consent to collect or use your personal information for specific purposes;

4. To comply with our legal obligations under applicable laws and regulations;

5. To protect our or your vital interests or those of another person (for example, another player), e.g. against fraud and violations of our terms;

6. While we typically do not collect sensitive or special category personal information, where we do this, it will be on the grounds of consent or other applicable lawful basis.

Data Transfers

By accepting and consenting to this Privacy Policy, you consent to the transfer of your personal information to third parties (if any), which may include the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to the jurisdictions as described in Section IV “How we store and protect your personal information”.

Where we transfer your personal information to countries and territories outside of the EEA, UK or Switzerland, which have been formally recognized as providing an adequate level of protection for personal information, we rely on the relevant “adequacy decisions” from the European Commission, where applicable.

Where the transfer is not subject to an adequacy decision, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy. The safeguards we use are the European Commission’s Standard Contractual Clauses as issued on 4 June 2021, including the UK Addendum, the UK International Data Transfer Agreement permitted under Article 46 of the UK GDPR, and/or their approved equivalent for Switzerland. This is how transfers of personal information between us and other companies will be safeguarded. All companies are required to protect personal information that they process from Europe in accordance with European Union data protection law. Transferred personal information includes basic information such as your name or contact information such as your email address.

Children

Our services are not marketed to, or intended for, children. Children for the purposes of our services are (a) under the age of 13 years old or, if older (b) between 13 and 18 years old but under the age at which they can give valid digital consent to processing of their personal information under applicable data privacy laws. We strive to follow the different minimum age guidelines set by the laws of individual regions when determining the age which children can access certain features of our services.

Children are not permitted to use our services, and we do not knowingly collect any personal information from children. Though our services are not intended for children as the primary audience, we may collect age information before allowing a user to proceed for certain services. If we learn that we have inadvertently gathered personal information about a child that is not subject to an exemption under applicable privacy law, we will take measures to promptly remove that information from our records.

Contact

If you have questions, need further information about the legal bases for processing your personal information, or want to withdraw your consent, please contact us as set out in “Contact us”.

Data Protection Supervisory Authority

To lodge a complaint with your national or regional data protection supervisory authority, please contact the competent authority.

France

Your Rights

Instructions for the processing of your personal information after your death

You have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal information after your death.

The specific instructions are only valid for the processing activities mentioned therein and the processing of these instructions is subject to your specific consent.

You may amend or revoke your instructions at any time.

You may designate a person responsible for the implementation of your instructions. This person will be informed of your instructions in the event of your death, and be entitled to request their implementation from us. In the absence of designation or, unless otherwise provided for, in the event of the death of the designated person, their heirs will have the right to be informed of your instructions and to request their implementation from us.

When you wish to make such instructions, please contact us atdpo@infoldgames.com.

Indonesia

Consent

By accepting and consenting to this Privacy Policy, you agree that we may collect, use and share your personal information in accordance with this Privacy Policy, as revised from time to time. If you do not agree to this Privacy Policy, you must not access or use our services and we have the right to not provide you with access to our services.

Parental and Guardian Consent

If you are under the age of 13, you undertake that you have the consent of your parent or legal guardian to register an account on the game and use the game services.

Data Subject Rights

You have the right to access your personal information stored in our game from time to time in accordance with applicable data privacy laws and regulations in Indonesia.

Data Breach

In the event we fail to maintain the confidentiality of your personal information in the game, we will notify you through the contact information provided by you or via the game, to the extent required by local laws and regulations.

Data Retention

We will retain your personal information in line with legal requirements.

Notification to Amendment of this Privacy Policy

If you fail to explicitly express your objection to any amended version of this Privacy Policy within fourteen days of the date the relevant amended version of this Privacy Policy is made available, you will be considered as having accepted the changes and agreed to the new Privacy Policy. However, you may stop using or accessing our service by unsubscribing or ceasing your use of the game services at any time, if you cease to agree with the amended Privacy Policy.

Data Accuracy and Third Party Consent

You are responsible for making sure that any personal details which you provide to us are accurate and valid. In order to confirm the accuracy of the data, we may also verify the data provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal data (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

Malaysia

Parental and Guardian Consent

If you are under the age of 13, you undertake that you have the consent of your parent or legal guardian to register an account on and use the game.

In the event you are agreeing to this Privacy Policy to allow a minor to access and use the game services, you hereby consent to the provision of personal information of the minor to be processed in accordance with this Privacy Policy and you personally accept and agree to be bound by the terms in this Privacy Policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor’s compliance with this Privacy Policy.

Your Rights

Right of access: You have the right to request access to and obtain a copy of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law.

When handling a data access request, we are permitted to request certain data to verify the identity of the requestor to ensure that he/she is the person legally entitled to make the data access request.

Right of correction: You may request for the correction of your personal information. When handling a information correction request, we are permitted to request for certain information to verify the identity of the requestor to ensure that he/she is the person legally entitled to make the information correction request.

Right to limit processing of your personal information: You may request to limit the processing of your personal information by sending an email to dpo@infoldgames.com. However, this may affect our provision of the game services to you.

Contact

To protect your personal information and handle complaints relating to your personal information, we have appointed the department responsible for managing and protecting your personal information, you may contact us by sending an email to dpo@infoldgames.com..

New Zealand

This section applies to users located in New Zealand:

Overseas Recipients

We take reasonable steps to ensure that third party recipients of your personal information located outside New Zealand handle your personal information in a manner that is consistent with New Zealand privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at dpo@infoldgames.com.

Correction

You have the right to request the correction of any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at dpo@infoldgames.com.

Children

If you are under the age of 13, you undertake that you have the consent of your parent or legal guardian to register an account on and use the game.

Your Rights

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the New Zealand Privacy Commissioner (www.privacy.org.nz).

Data Transfers

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.

Philippines

Minimum Age

You must be at least 18 years of age to be able to use the game services.

Your Rights

You are entitled to the following rights:

1. Right to be informed. You may in certain circumstances have the right to be informed whether personal information pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.

2. Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for direct marketing, automated processing or profiling.

3. Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.

4. Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.

5. Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.

Consent

By consenting to this Privacy Policy, you consent to us:

Collecting and processing your personal information as described in the section “How We Collect And Use Your Personal Information” above;

Sharing your personal information with third parties, companies within our corporate group, and a third party that acquires all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and transferring or storing your personal information in destinations outside the Philippines as described in “How We Store and Protect Your Personal Information”.

Singapore

By clicking the button to proceed, you consent to the cross-border transfer of your data to any country where we have databases or affiliates and, in particular, Indonesia, the People’s Republic of China and the United States.

Access

You have the right to access your personal information, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at dpo@infoldgames.com.

Correction

You have the right to correct any of your personal information that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact  dpo@infoldgames.com.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted at dpo@infoldgames.com.

Thailand

By accepting this Privacy Policy, you acknowledge that you have read, understood, and agree to this Privacy Policy. If you do not agree with this Privacy Policy, you must not use the game services.

You may request us to discontinue, to restrict the use or provision of, and/or to request for data portability of any and all of your personal information which is stored by us, to the extent provided by the act on the applicable data privacy laws and regulations in Thailand, including the Thai Personal Data Protection Act. When you wish to make such requests, please contact us at dpo@infoldgames.com.

We will give you notice of any material changes to this Privacy Policy, and give you an opportunity to reject such changes, failing which the changes will become effective as stated in the notice.

By accepting this Privacy Policy, you expressly authorize us to collect, use, store, and process your personal information, including disclosing to third parties and transferring to countries other than Thailand, to the extent and for the purpose provided by this Privacy Policy.