Infinity Nikki Personal Data and Privacy Policy

Last Updated:May 31,2024

Effective Date:May 31,2024

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/us/our”) whose registered office is at【6 Raffles Quay, #14-06, Singapore】.This Privacy Policy shall be legally binding to you.

Infold takes the protection of your personal data and privacy very seriously. To protect your legal rights when using the services we provide, including your interactions with us and/or your registration and use of our games and/or registration and use of other products or services we provide (hereafter referred to as "services"), we have made this Privacy Policy to explain to you how we collect, use, store, share and transfer such data when you use our products and services, and the ways we provide to you to access to, update, control and protect this data.

WE SUGGEST THAT YOU SHALL READ THIS PRIVACY POLICY CAREFULLY AND FULLY, ESPECIALLY THE TERMS MARKED IN BOLD, AND MAKE CHOICES YOU DEEM APPROPRIATE IN ACCORDANCE WITH THE GUIDELINES OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THE CONTENT OF THIS POLICY, WE MAY NOT BE ABLE TO PROVIDE OUR SERVICES PROPERLY OR TO DELIVER THE EXPECTED SERVICES.

PLEASE BE AWARE THAT WE DO NOT COLLECT PERSONAL DATA OF MINOR USERS 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 HIS/HER PERSONAL DATA, PLEASE INSTRUCT HIM/HER 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” hereof, and we will respond you as soon as possible.

Please note that this privacy policy applies only to the beta version of “Infinity Nikki”, and may be updated or changed according to the new game version. If we make a material change to this Privacy Policy, we will notify you via your registered contact information such as email (sent to the email address specified in your account), publish on our official websites, or notify you via mobile devices so that you can learn about the information.

This Privacy Policy will help you know about：

I. How we collect and use your personal data

II. How we use cookies and similar technologies

III. How we entrust the processing, share, transfer, disclose your personal data

IV. How we store and protect your personal data

V. Your rights to manage personal data

VI. Protection of minor data

VII. Updates

VIII. Miscellaneous

IX. Contact us

I. How we collect and use your personal data

According to the requirement of relevant laws and regulations or for the requirement of specific functions and services, we collect, store and use the following data about you. The collection, storage, and use according to the law is for the purpose of providing or optimizing our products, services or experience to you and to protect the security of your account.

You understand and agree: some individual services may require you to enable specific access permissions on your device to enable the collection and use of the data to which those permissions relate. You understand and agree: if you do not provide such data, you may not be able to register as a user or enjoy certain products/services provided by us, or achieve the intended results of using the relevant services.

If you need to use our game products, the game itself may not be available if you do not provide the necessary information for us to build a user profile and identify the user, depending on the operation of the game system.

If we use your data for purposes other than those described below, we will explain this to you again and obtain your consent.

1. Personal data you provide

When you register, log in and authenticate, you provide us with your Infold Account as your game account, creating your username and password. The data you provide when you register an account will be used to ascertain your age and provide you with better services. If you do not provide such real identity data or provide us with false data, you will not be able to use our services or be subject to corresponding restrictions in the process of using the services. You agree that we may collect your online identification information (including system account number, password, 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, software list, unique device identifiers, device name, network status, operator), which will be used to mark you as a user of Infold. Please be aware that when you log in to the system of Infold through a third-party account (Apple ID, Google, Facebook,PSN account), we may collect such data of your third-party account such as your unique identifier, account name, personal avatar and list of friends, which are used to store your login information, so that you can log in to our system on different devices. If you do not agree to authorize the collection of such data, you will not be able to log in to the system of our products/services using a third-party account. We need to remind you that you can only register as our user and access our services when you provide true and accurate data as described above, and if you do not provide such data, you will not be able to log in or use all or part of Infold Games' products or services.

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

(3) Data you share with other parties through our products or services, and data you provide to us and store when you use our products or services.

2. Your data shared by other parties

(1)Your data shared by other parties when they use our products or services.

(2)We may obtain data 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 data we obtain

We may collect the following data based on the following usage patterns when you use Infold games products or services:

(1) In order to ensure your normal use of our services, maintain the normal operation of the basic functions of the game, optimize the performance of the product, enhance your gaming experience and protect your account security, we may collect your device or software data, i.e. the device identifier provided by your mobile device, web browser or other programs used to access our products or services (Android such as Android ID, OAID, GAID, iOS such as IDFV, IDFA, PC such as motherboard serial number,CPUID,product id, hard drive serial number,Machine GUID; different identifiers may vary in terms of validity, whether can be reset by the user and the way to obtain. The unique device identification data is used only in the course of your use of the services we provide, and this data is the basic data that must be collected in order to provide the services.) , device MAC address, device name, device settings and environment, device manufacturer, device time zone, device type (device model), device model and version, device serial number, OS type and version,system start up time (IOS only), system activation time (IOS only),IP address, operator information, mntID (IOS only), network type (Wi-Fi/5g/4g/3g/2g), Wi-Fi status, Wi-Fi MAC address, 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), system startup time, language region and country, CPU architecture information, timestamp, host file ,whether root/jailbreak, acceleration sensors, memory size and remaining memory, 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),analog positioning switch (Android only),whether to enable adb (Android only), Baseband version (Android and IOS), screen brightness (Android and IOS), SIM card status (Android and IOS), battery and power status (Android and IOS).

(2)When you interact with other players in the game through text, pictures, voice, video and other means, we will collect and store the information you send for the purpose of filtering pornographic, violent, political or abusive information, malicious advertisements and other inappropriate contents, so as to create a clean and safe gaming environment.

(3)When you use Infold game services, we may collect your game log data, including your login logs, item logs, matches information, purchase logs, activity logs, upgrade logs and social networking records, so that you can view your gaming history in the client, and the data will be used for statistical analysis in game operations, handling of customer complaints, anti-cheat analysis and other analysis for optimization of gaming experience. Moreover, in order 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, in order to enable you to complete payment and top-up, to show you the transaction data of your account, to ensure transaction security, to facilitate your checking of transaction records and protect your virtual property to the maximum extent. The collection of the above data is necessary for Infold to deliver the consumption services, and it will be impossible to complete transactions without such data.

(5) In some services, in order to facilitate the delivery of goods or services to you, you should provide the consignee's personal identification information, name, shipping address, postal code, consignee, contact number, and payment status. In particular, we may share some of your data with third party logistics/delivery parties during the shipping and delivery process in order to deliver goods or services to you safely, smoothly and accurately. If you do not provide such data, we will not be able to complete the relevant delivery service, but it will not affect your normal use of other functions of Infold game service.

(6) When you contact us, we may collect your communication/call records and contents or the contact you leave in order to contact you or help you resolve a problem, or to record the resolution and outcome of the relevant issue.

(7)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.

(8) Device permissions: During your use of our services, we will ask for 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), in order to realize the collection and use of the corresponding data and realize the corresponding product functions and business scenarios. We will seek your consent before getting the 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. These can be set in the settings. We will use your notification permissions when you use the function of push notification and drip note background playback;

b. External storage rights: we will read and write your external storage rights when you use the in-game photo function (when saving pictures and downloading pictures), hot update, save screenshots to your device, give feedback on network detection problems, and send photos to customer service;

c. Camera Permissions: we will use your camera permissions when you send photos to customer service.

n iOS

a.  Notification permissions: Notifications may include alerts, sounds, and icons. These can be set in the settings. We will use your notification permissions when you use the function of push notification and drip note background playback;

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

c. Camera Access: we will use your camera access when you send photos to customer service.

d. Device network access: we will use your device network access when you log in, update, use our services, check the security of your network environment, network connection status and network speed measurement.

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 data to provide you with the corresponding services. By disabling any permission, you withdraw the corresponding authorization, and we will no longer collect and use the relevant data based on such permission and therefore become unable 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 data based on your authorization.

In particular, please know and understand that the access names may differ from terminal to terminal due to different terminal devices and different operating systems.

(9) In order to ensure the security of your game account and create a fair, sound and safe gaming environment, we will collect your gaming application information, device information (such as ID, serial number, manufacturer, device name, type and version, model, and style of the device), hardware and OS information, network type, and data on the operator, process and game crash records and game channel sources, which will be used to combat activities that may undermine the fair gaming environment or interferes with the normal operation of our game services (for example, such information may be used to detect piracy, screen plug-ins, and anti-cheat).

5. We may send notification to you

(1)  When you use our services, we may contact you by phone or send you emails, text messages, information or push notifications. 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 advertisement.

(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 in your device or select the information you wish to receive through the notification settings function we provide.

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

7.Notice on when you disclose and share information

A number of our services allow you to disclose/ share information about yourself not only with your online game but also with all users of the service, for example, information you upload or post on our services (including your publicly available personal data, lists you create), your responses to information uploaded or posted by others, and including location data and log data related to such information (e.g., friends relationship, level, ranking), other users of our services may also share information about you (including location data and log information). In particular, our social media services are designed to enable you to share information with users around the world, and you can make that shared information available in real time and on a wide scale. 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 consider carefully the content of the information that you make public, upload, post and communicate through our services. In some cases, you may be able to control the range of users who are entitled to view the information you share through the privacy settings of some of our services. If you want to remove your information out of 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 data through cookies, web beacons and other similar technologies, and store such data. 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 to store other data you provide to us about yourself.

2. Analyze your use of our products or services. We may use cookies and web beacons to know in which activities you participate with our services.

3. Our products and services may contain cookies, web beacons and other similar technologies placed by our third party partners. These cookies, web beacons and other similar technologies may collect non-personally identifiable information about you for the purpose of analyzing how users use those services or for evaluating the effectiveness of advertising services. We strictly require our third party partners to comply with the provisions of this policy. You may refuse or manage cookies, web beacons or other similar technologies through your browser settings. However, please note that if you disable cookies, web beacons or other similar technologies, you may not be able to enjoy the corresponding service experience, and some services may not work properly.

III.  How we entrust the processing, share, transfer, disclose your personal data

1.Sharing.Without your consent, we and our affiliates will not share your personal data with any third parties, except:

(1) Access to Third-Party SDKs and APIs: When you use our products or services, we may utilize a third party’s Software Development Kit (SDK) and Application Programming Interface (API) or share your personal information with a third party through other collaborative means to achieve the specified purpose. The purpose/categories/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 terms before or relevant statement. We recommend checking the applicable third party's privacy terms before use to understand how, why, and to what extent the third party collects and uses users' information, as well as its legal responsibilities.

The information we currently share with third parties is shown in the table below.

(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 may be shared between us and our affiliates as required. In such cases, we will only share the necessary personal information for the purposes and within the scope outlined in this Privacy Policy. If we intend to share sensitive personal information or if the recipients intend to alter the purpose or processing of the personal information, we will seek your authorization once again. For instance, after registering your Infold Account, you can efficiently manage information about our products and services through your Infold Account to save time and simplify your workflow.

(3)for the purpose as described in the section “How do we collect and use personal data” ;

(4) 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;

(5) for the purpose of understanding, maintaining and improving our products or services;

(6) on the basis of a legal request from you or your guardians;

(7) required by laws and regulations or relevant authorities.

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

2. Transfer. We will transfer your personal data only when:

(1) you expressly consent;

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

(3) we and our affiliates merge, consolidate, transfer assets or carry out any other similar transactions as our business continues to grow, we may transfer your personal data as a part of such transactions. We will inform you of that by push notifications, announcements or otherwise, and continue to protect, or request the new managers to continue to protect your personal data in accordance with the relevant laws and regulations which go no less than the standard described in this Policy.

3. Disclosure. We will disclose your personal data 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 data without your consent in compliance with the relevant laws, regulations, national standards of the territory where you use our products and services, and the writs of execution issued by the administrative or judicial authorities.

(2)You acknowledge and agree that the data we collect may be de-identified and used for big data analysis. We may disclose to the public and share with our partners information that has been statistically processed without identifying content. Such information will be used to know how users use our products or services or to inform the public about the general usage trends of our products or services. According to relevant law and regulations, sharing or transferring de-identified information and ensuring that the recipient of the data cannot recover and re-identify the subject of the information is not an act of sharing, transferring or publicly disclosing the information to the public, and the storage and processing of such data will not require separate notification to you or your consent.

IV. How we store and protect your personal information

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

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

(2) for reasonable and necessary purpose to safeguard the public interest or to protect the personal rights, property safety or other legitimate interests of our customers, we 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. As per 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 strive to enhance our products and services. In the course of these efforts, the server locations mentioned above may be adjusted and changed to further optimize our services.

4. Your data 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. In addition, your data can be accessed from outside of where you live by our support, engineering and other teams around the world, including Singapore.

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

6. We will delete or anonymize your personal data if you request to delete your account, voluntarily delete your data or after a certain necessary period of time, unless otherwise a certain retention period is required by laws and regulations.

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

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

9.When a personal data security incident occurred, we will promptly inform you of the following in accordance with the relevant laws and regulations: the basic information and possible impact of the security incident, measures we have taken or will take to handle it, recommendations on what you can do to prevent and reduce risks, remedies available to you, etc. In addition, we will promptly notify you of the relevant information of the incident by email, letter, phone, push notification or otherwise. If it is difficult to give notice to the personal data subjects individually, we will publish announcements in a reasonable and effective way. We will also take the initiative to report our handling of the personal data security incident as required by the regulatory authorities.

V. Your rights to manage personal data

We understand your concerns about your personal data and make every effort to ensure that you have the right to access, correct, delete, and revoke authorization of your personal data so that you have the full ability to safeguard your privacy and security. Your rights include:

1. Right of access

You have the right to access the personal data you have provided to us, including, if any, avatar, nickname, player number, motto and rankings, according to the relevant instructions (or settings) of the products or services we provide. If you have any problems when accessing, and intend to access other unavailable personal data described above, you may contact us through the contact information provided in this Privacy Policy.

2. Right to correct/modify

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

(1) For some of your personal data, we provide you with operation settings on the relevant function pages of the product, and you can make correction/modification directly, for example: the “avatar/nickname” shall be corrected/modified in the game client in the following way: click on the nickname - click the Edit button/the area corresponding to the content to be modified.

(2) If you have any difficulties in exercising the above rights, or if online correction/modification services are currently unavailable to you, you shall have the right to correct or amend the inaccurate or incomplete data, provided that your identity has been verified and the correction/modification will not affect the objectivity and accuracy of the data; or in certain circumstances, especially when the data is inaccurate, you have the right to request us to correct or modify your data by submitting a correction/modification request to us via our feedback/error reporting/customer service and other channels published by us, unless otherwise required by laws and regulations. However, for security and identification reasons, you may not be able to modify certain initial registration data submitted during registration.

3. Right to delete

You may directly request that we delete your personal data unless your personal data has been anonymized or required by laws and regulations, including when:

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

(2) our handling of your personal data violates any laws or regulations;

(3) we collect or use your personal data without your consent;

(4) our handling of your personal data violates the agreement with you;

(5) you delete your game account;

(6) we terminate the services and operations.

If we decide to respond to your request for deletion, we will also notify the entities that have obtained your personal data 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 data from our service system, we may not delete the corresponding data from the backup system immediately, but will delete such data at the time when the backup is updated.

4.Right to revoke all/part of your authorization

As previously mentioned, some of the functions of the products and services we offer require permission for you to use your device (including: camera, microphone, etc., as set forth in Section I of this Privacy Policy). You may withdraw (or stop) your continued authorization of such permissions at any time after your authorization. After you update the version, we will not change the status of your previously set permissions without your expressly consent. You may also permanently withdraw in full the authorization granted to us for collecting your personal data by delete your account. When the authorization is withdrawn, we will no longer be able to provide you with the corresponding products and/or services. However, your decision to withdraw such authorization will not affect our previous handling of your data based on your authorization.

5. Right to delete your account

You may request to delete your account through our customer service staff or other means we have publicized. Once you delete your account, you will no longer be able to use our products and services with that account; and all rights and interests that have accrued but not consumed of the account during your use of all products and services, as well as all future overdue benefits and other rights and interests will be erased; contents, information, data and records of the account will be deleted or anonymized; once your game account is deleted, it cannot be restored. For more information on the process and conditions of deleting Infold accounts, please contact our customer service.

6. Right to make copies

You have the right to request copies of your personal data by contacting us at any time via the contact information provided in this Privacy Policy. We will respond to your request within 15 working days.

7. Right to constrain the automated decision-making power of the information systems

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

8. How we respond to your requests for the rights above

We will respond to your requests as soon as possible within 15 working days while verifying your identity as a user. If you have any doubts when processing your personal data, you may contact us via the contact information provided in Section IX “Contact us” hereof. However, we will not be able to respond to your requests if we are prohibited by any writs of execution issued by administrative or judicial authorities in the territory where you use our products and services.

VI. Protection of minor information

Please be aware that we do not collect personal information of minor users 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 his/her personal data, please instruct him/her to stop using our services immediately and inform us promptly so that we can take appropriate measures accordingly. Please refer to the section【V. Your rights to manage personal information】. Our custom service may verify and confirm your relationship with the minor to the extent necessary. After such confirmation, we will assist you in deleting such data and deleting of the corresponding account.

VII. Updates

We may update this Policy from time to time, and such modifications shall form a part of this Privacy Policy. If such revisions result in a material reduction of your rights under this Privacy Policy, we will notify you by prominently displaying the revisions on our homepage or by sending you an e-mail or otherwise notifying you before the revisions become effective. In such event, your continued use of our services means that you agree to be bound by the changed Privacy Policy.

VIII. Miscellaneous

1. Except for certain specifically expressed services, this Privacy Policy applies to all our services. These specific services will be subject to specific personal data protection statements or rules. The specific personal data protection statements or rules for certain specific services will more specifically describe how we use your data in those services. The personal data protection statements or rules for the specific services form part of this Privacy Policy. In the event of any discrepancy between any personal data 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 clauses made by Infold.

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

4. This Agreement 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) ,and that if a solution to the dispute cannot be effectively reached after thirty (30) 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 30 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 for 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. In case of any discrepancy between the English version and another language version, the local language version shall prevail, subject to applicable laws and regulations.

10. 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/region of residence, the local laws will take precedence.

IX. Contact us

1. We set up a dedicated department for personal data protection in compliance with this Policy. If you have any questions, comments or suggestions about this Policy, about our privacy measures or matters relating to your personal data, you may contact us in any of the following ways or send an email to【dpo@infoldgames.com】.

2. Generally, we will respond to your questions, comments or suggestions within 15 working days while verifying your user identity, unless otherwise required by the laws and regulations of the territory where you use our products and services.

3.Contact Your Local Data Protection Authority

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

Correction

You have the right to correct any of your personal data we hold that is inaccurate. You can access the personal data we hold about you by logging into your game account. If you believe we hold any other personal data about you and that data 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 data, 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 dadta 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:

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

o the categories of personal data about you that we collected;

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

o the purpose for collecting personal data about you;

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

o the specific pieces of personal data we collected about you;

· Request we delete personal data we collected from you, unless CCPA recognizes an exception; and

· 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 fulfil 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 data from there. If you are a California resident to whom the CCPA applies, you may also exercise your rights, if any, regarding other data 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【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 data by our service providers.

Where we use service providers who might have access to your personal data, 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 data and to prevent it from being used for any purpose other than as provided in this privacy policy.

France

Your Rights

Instructions for the processing of your personal data after your death

You have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal data 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 at dpo【dpo@infoldgames.com】.

Indonesia

Consent

By accepting and consenting to this Privacy Policy, you agree that we may collect, use and share your personal data 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 data 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 data 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 (14) 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 current. 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 in order for a minor to access and use the game services, you hereby consent to the provision of personal data 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 data 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 data in the amounts as permitted under law.

When handling a data access request, we are permitted to request for 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 data. When handling a data 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 data correction request.

Right to limit processing of your personal data: You may request to limit the processing of your personal data by using the contact details provided above. However this may affect our provision of the game services to you.

Contact

To protect your personal data and handle complaints relating to your personal data, we have appointed the following department responsible for managing and protecting your personal data.

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

Correction

You have the right to request the correction of any of your personal data we hold that is inaccurate. You can access the personal data we hold about you by logging into your account. If you believe we hold any other personal data 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 data or your privacy complaint in respect of your personal data, 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 data 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:

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

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

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

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

· 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 data.

Consent

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

collecting and processing your personal data as described in the section “I. How we collect and use your personal data” above;

sharing your personal data 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 data in destinations outside the Philippines as described in the section “How we store and protect your personal data” above.

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

Correction

You have the right to correct any of your personal data that is inaccurate. You can access the personal data we hold about you by logging into your account. If you believe we hold any other personal data about you and that data 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 data 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 data, including disclosing to third parties and transferring to countries other than Thailand, to the extent and for the purpose provided by this Privacy Policy.