Privacy Policy - Protofun Studio

Scope of this Privacy Policy

Please read this Privacy Policy carefully to understand our policies and practices regarding your Information (as defined below) and how we will treat it.

This Privacy Policy explains how your Information is collected, used, and disclosed by PROTOFUN STUDIO entities as listed in the controllers & contact section ("we" or "us"). It also tells you how you can access and update your Information and make certain choices about how your Information is used.

This Privacy Policy covers both our online and offline data collection activities, including information that we collect through our various channels such as websites, apps, console games, third party social networks, customer care centres, studios, attractions/exhibitions, points of sales and events. Please note that we can combine information that we collect via one method (e.g. a PROTOFUN STUDIO website) with information that we collect via another method (e.g. a PROTOFUN STUDIO video game). As part of this, we can combine information that was originally collected by different PROTOFUN STUDIO entities.

TABLE OF CONTENTS

_ THE INFORMATION WE COLLECT

_ HOW WE USE THE INFORMATION

_ INFORMATION SHARING AND DISCLOSURE

_ YOUR CHOICES

_ COOKIES AND OTHER TECHNICAL INFORMATION

_ DATA RETENTION

_ HOW YOU CAN ACCESS OR CORRECT INFORMATION

_ INTERNATIONAL TRANSFER

_ NOTIFICATION REGARDING UPDATES

_ JOINT CONTROLLERS & HOW TO CONTACT US

INFORMATION WE COLLECT

We collect and combine different types of information together, and collectively refer to all of this information in this Privacy Policy as “Information”. Such Information includes:

Registration, account, and sign-up information. We collect Information in the course of your use of, or registration with, us. For example, when you create an account, register for, or download an application, or sign-up for a product or service, you provide us with certain personal information. This type of personal information can include: name, postal address, telephone number or email address. We can also receive Information about your interest in and use of various products, programs, services, and content available.

Product/service purchase. Where you make a purchase on one of our sites, we will also collect certain payment information (e.g. credit/debit card, billing information and delivery address).

Information about others/inviting friends. In certain situations, we collect Information you submit about other people. For example, you can submit Information to invite a friend to participate in an offering, make recommendations, share content, or you have multiple players sharing the same video game session. By processing these requests, we can receive the other person¡¯s Information, including details such as his/her name, postal address, email address, telephone number, or information about the recipient¡¯s interest in and use of various products, programs, services, and content. In certain situations, we also allow you to invite your friends to participate in activities by providing their contact details or importing contacts from your address book or from Social Media Sites (as defined below).

Information from other sources. We, on occasion, combine Information we receive online with other information, including usage information from our other sites and our online advertising and media. We also supplement or combine Information with information from a variety of other sources or outside records, such as demographic, transaction history, or personal information, and we use that combined information in accordance with this Privacy Policy.

Social media. You can engage with some of our content and offerings, such as videos, games, applications, and other offerings on or through third party communities, forums, and social media sites, services, plug-ins, and applications (“Social Media Sites”). When you link to or interact with us or content through Social Media Sites, you allow us to receive certain Information from your social media account (e.g., name, user ID, email address, profile photo, photos and videos, gender, birthday, your list of friends and their contact details, people you follow and/or who follow you, the posts or the 'likes' you make). We also receive Information from your interaction with our content (e.g., content viewed, game performance, high scores, and information about advertisements you have been shown or have clicked on). Where permitted by law, by providing this Information or otherwise interacting with our Sites through Social Media Sites, you consent to our use of Information from the Social Media Site in accordance with this Privacy Policy.

Public forums. If you post or share Information or content, such as photos, letters, videos, or comments, while participating in online forums we operate, or when you interact with us through Social Media Sites, depending on your privacy settings this Information and your username can become public on the Internet or within a community of users. We cannot prevent further use of this Information once it is made public. For information about how you can customise your privacy settings on Social Media Sites, and how those Social Media Sites handle your personal information and content, please refer to their privacy help guides, privacy policies, and terms of use.

Location information. We have access to certain Information about your location, such as your country or address, when you provide it or via device information (such as an IP address). With your consent (where required by law), we can also collect Information about your device¡¯s precise location (e.g. geolocation via mobile devices).

Technical and usage information. We also collect certain technical and usage information such as the type of device, browser, and operating system you are using, your Internet service provider or mobile carrier, unique device identifier, IDFA or IDFV, MAC address, IP address, device and browser settings, the webpages and apps you use, advertisements you see and interact with, and certain site usage information. See our Cookies and Other Technical Information section for more information on how we may use these technologies to collect this Information.

Customer enquiries. Where you contact us through one of our customer helpdesks or customer call centres, we can have access to the application, or product/service that you have purchased, your purchase history, your previous correspondence with us or your contact details. Calls to customer call centres may be recorded.

HOW WE USE THE INFORMATION

We use Information for the purposes described in this Privacy Policy or disclosed at the time of collection.

Providing and marketing products and services. We use the Information we collect about you, to fulfill your purchase, or to fulfill your requests for, and otherwise provide or analyse your use of our products, application, services, video games and content, to facilitate sharing and other interactions with Social Media Sites, and to provide, develop, maintain, personalise, protect, and improve your experience and our offerings. For example, we use Information collected on our sites to enable you to do things like (i) watch trailers and video clips, (ii) get entertainment news and updates, (iii) get information about our products, services, and content, (iv) locate and access personalised information, ads or functionality based on your interests and location (e.g., find stores, theaters, or show times), (v) buy digital content, products/services or movie tickets, (vi) play games, (vii) engage with interactive features, activities, and Social Media Sites, (viii) read and post comments, content, and reviews, or (ix) enter promotions, contests, and sweepstakes. We also use Information for your payment of any products/services you purchase, to prevent fraud or to offer, market, and advertise products, programs, and services from us and our affiliates, trusted partners, and select third parties that we believe can be of interest to you.

Our reasons

_ Fulfilling contractual obligations

_ Legal obligations

_ With your consent (where required)

_ Our legitimate interests:

o Improving and developing new products and services

o Being more efficient

o Fighting fraud

o Retaining your shopping history and use details of the products you have previously purchased to make suggestions to you for other products which we believe you will also be interested in

Communicating with you and others. We use Information about you to communicate with you, such as (i) to notify you when you win one of our contests or sweepstakes, or when we make changes to our policies or user agreements, (ii) to respond to your inquiries, (iii) to communicate with you about your purchases or transactions, (iv) to contact you about your account, or (v) to send you information about promotions, offerings, and our features. You can also choose to receive push notifications from us on your mobile device. If you choose to submit content for publication online or in other forums, we can publish your screen name and other Information you have provided to us, the Internet, or elsewhere. If you choose to contact one of our call centres we can record such calls. We use Information that you provide about others to enable us to send them invitations, promotions, or other content on your behalf or through our sites. From time to time, where permitted by law, we also use this Information to offer, market, or advertise products, programs, or services to them from us and our affiliates, business partners, and select third parties.

Our reasons

_ Fulfilling contractual obligations

_ Legal obligations

_ With your consent (where required)

_ Our legitimate interests

o Communicating important information

o Improving and developing new products and services

o Being more efficient

o Compiling statistics

Third party social networks. We use your Information when you interact with third party social networking features to serve you with advertisements and engage with you on third party social networks. You can learn more about how these features work, the profile data that we obtain about you, and find out how to opt out by reviewing the privacy notices of the relevant third party social networks.

Our reasons

_ With your consent (where required)

_ Our legitimate interests:

o Retaining and evaluating information on your recent visits to our mobile apps, and video games, and how you move around for analytics purposes in order to understand how people use our mobile apps, and video games so that we can make them more intuitive

o Defining types of customers for new products or services

o Developing a profile of you and your interactions with us so that we can provide tailored offers, opportunities and services that may be of interest to you

Use of technical and usage information. We use technical and usage information to improve our design, functionality and content and to enable us to personalise your experience with our content and offerings. We use this Information (i) to provide, develop, maintain, personalise, protect, and improve our products, applications, services and video games, and to operate our business, (ii) to perform analytics, including to analyse and report on usage and performance, (iii) to protect against, identify, and prevent fraud and other unlawful activity, (iv) to create aggregate data about groups or categories of our users, and (iv) for us and our affiliates, business partners, and select third parties to target, offer, market, or advertise products, programs, or services.

Compliance. We use Information we collect to detect, investigate, and prevent activities that violate our terms of use, could be fraudulent, violate copyright, or other rules or that can be otherwise illegal, to comply with legal requirements, and to protect our rights and the rights and safety of our users and others.

Our reasons

_ Legal obligations

_ Our legitimate interests:

o Protecting our business interests and rights, privacy, safety and property, or that of the public

o Sharing your Information with third parties in order to permit us to pursue available remedies or limit damage that we may sustain

Note: We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this Privacy Policy.

INFORMATION SHARING AND DISCLOSURE

We share and disclose Information in the following ways or for any other purpose disclosed at the time of collection:

Law enforcement bodies and courts. We disclose Information in response to legal process, for example in response to a court order or a subpoena, or in response to a law enforcement body's request. We also disclose such Information to third parties: (i) in connection with fraud prevention activities, (ii) where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, (iii) in situations that can involve violations of our terms of use or other rules, (iv) to protect our rights and the rights and safety of others, and (v) as otherwise required by law.

Change of control. We transfer Information in the event of a business transaction, such as if we or one of our business units or our relevant assets are acquired by, sold to, or merged with another company or as part of a bankruptcy proceeding or a business reorganisation.

Service providers. Our agents and contractors have access to Information to help carry out the services they are performing for us, such as, but not limited to, fulfilment, creation, maintenance, hosting, and delivery of products and services, conduct marketing, handle payments, email and order fulfillment, administer contests, conduct research and analytics, or customer service.

Linked sites. Some of our sites contain links to other sites, including Social Media Sites, whose information practices can be different from ours. You should consult the other sites' privacy disclosures and terms before submitting any Information, as we have no control over Information that is submitted to, or collected by, these third parties.

Sponsors and co-promotions. We sometimes offer content or programs (e.g., contests, sweepstakes, promotions, games, applications or Social Media Site integrations) that are sponsored by or co-branded with identified third parties. By virtue of these relationships, the third parties collect or obtain Information from you when participating in the activity. We have no control over these third parties' use of this Information. We encourage you to look at the privacy disclosure of any such third party to learn about their data practices.

Advertising networks. We share certain Information with third parties to provide advertising to you based on your interests. For more information, please see our (i) Cookies and Other Technical Information and (ii) Ad Choices sections below.

YOUR CHOICES

Marketing communications and sharing with third parties. We provide you with an opportunity to express your preferences with respect to receiving certain marketing communications from us, and our sharing of Information with trusted partners for their direct marketing purposes. If you ever decide in the future that you would like to update these preferences, you can send us an email at protofundev@gmail.com. If you previously chose to receive push notifications on your mobile device from us, but no longer wish to receive them, you can manage your preferences through your device or app settings, depending on the type of device.

Ad Choices. We work with reputable third parties to present advertisements, and engage in data collection, reporting, ad delivery and response measurement, and site analytics on our sites and on third party websites across the Internet and applications over time. These third parties use cookies, web beacons, pixels, or similar technologies to perform this activity. They also obtain information about applications you use, websites you visit, and other information from across your devices and browsers in order to help serve advertising that will be more relevant to your interests on and off our sites and across your devices and browsers. This type of advertising is known as interest-based advertising. They also use this information to associate various browsers and devices together for the purpose of interest-based advertising and other purposes like analytics.

For more information about interest-based advertising on your desktop or mobile browser, and your ability to opt out of this type of advertising by third parties that participate in self-regulatory programs, please visit Your Online Choice and/or the EDAA Self-Regulatory Initiative for Online Behavioral Advertising. Please note that any opt-out choice you exercise through these programs will apply to interest-based advertising by the third parties you select, but will still allow the collection of data for other purposes, including research, analytics, and internal operations. You can continue to receive advertising, but that advertising will be less relevant to your interests.

You can have more options depending on your mobile device and operating system. For example, most device operating systems (e.g., iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices) provide their own instructions on how to limit or prevent the delivery of tailored in-application advertisements. You can review the support materials and/or the privacy settings for the respective operating systems to learn more about these features and how they apply to tailored in-app advertisements.

Precise location information. To disable the collection of precise location information from your mobile device through our mobile apps, you can access your mobile device settings and choose to limit that collection.

See also Cookies and Other Technical Information for more choices about managing other technical and usage information.

COOKIES AND OTHER TECHNICAL INFORMATION

Cookies and other technologies. We, and our affiliates, third party service providers, and trusted partners send "cookies" to your device or use similar technologies to understand and enhance your online experience with us and through our advertising and media across the Internet including Social Media Sites, mobile apps, and video games.

Cookies are small text files placed in your browser. We also use pixels or "web beacons" that monitor your use of our sites. Web beacons are small strings of code that provide a method for delivering a graphic image on a webpage for the purpose of transferring data, such as the IP address of the device that downloaded the page on which the web beacon appears, the URL of the page on which the web beacon appears, the time the page containing the web beacon was viewed, the type of browser that fetched the web beacon, and the identification number of any cookie on the device previously placed by that server. We also integrate “Software Development Kits” (“SDKs”), javascripts or portions of code into our applications/video games to perform similar functions as cookies and web beacons. For example, SDKs collect technical and usage information such as mobile device identifiers and your interactions with our app. Some of our sites use locally stored objects (“LSOs”) to provide certain content, such as video on demand, video clips, or animation, and a better user experience.

We can use cookies and other technologies to help recognise your browser or device, maintain your preferences, provide certain features, and collect Information about your online interactions with us, our content, and our communications. For example, when corresponding with you via HTML capable email, web beacons and other technologies let us know about your activity, including whether you received and opened our email, clicked through a link, or otherwise interacted with our content, and this information can be associated with Information previously collected.

We also use cookies and other technologies (i) to provide, develop, maintain, personalise, protect, and improve our sites, products, apps, services and video games, and to operate our business, (ii) to perform analytics, including to analyse and report on usage and performance of our content and marketing materials, (iii) to protect against, identify, and prevent fraud and other unlawful activity, (iv) to create aggregate data about groups or categories of our users, (v) to synchronise users across devices, affiliates, and trusted partners, and (vi) for us and our affiliates, and trusted partners to target, offer, market, or advertise products, apps, services or video games. Cookies and other technologies also facilitate, manage, and measure the performance of advertisements displayed on or delivered by or through us.

Managing cookies and other technologies.

Websites and mobile applications

Details

Strictly necessary cookies or similar technologies: They are essential in order to enable you to move around our sites or apps and use its features, such as accessing secure areas. Without them, services like enabling appropriate content based on your type of device cannot be provided.

Performance cookies or similar technologies: They collect information about how you use our sites or apps, so that we can analyse traffic and understand users' interactions. We may use third party service providers such as Google Analytics for this purpose who may use their own cookies or similar technologies. The information is used to improve our site or app.

Functionality cookies or similar technologies: They allow our sites or apps to remember choices you make (such as your user name, or the region you are in) and provide enhanced, more personal features. They can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog.

Social media cookies or similar technologies: They are used when you share information using a social media sharing button or “like” button on our sites or apps, or when you link your account or engage with our content on or through a social media site such as Facebook, Twitter or Google+. The social network will record that you have done this. This information may be linked to targeting/advertising activities.

Advertising cookies or similar technologies: Some of our sites or apps may use a third party advertising network, to deliver targeted advertising. They may also have the capability to track your browsing across sites, apps and Social Media Sites.

We do not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.

See the Your Choices section to learn how to control data collection for certain purposes.

DATA RETENTION

In broad terms, we will only retain your personal information for as long as is necessary for the purposes described in this Privacy Policy. This means that the retention periods will vary according to the type of personal information and the reason that we have the personal information in the first place. For example, some personal information related to the provision of services to you or by you will be kept for a number of years in order to comply with various finance and tax related legal obligations. Other service related personal information may be kept for a different period because it is in our legitimate interests to do so in order to provide or receive appropriate follow up service.

We have a detailed internal retention policy that sets out varying retention periods for different categories of personal information depending on our legal obligations and whether there is a commercial need. After a retention period has elapsed, the personal information is securely deleted.

HOW YOU CAN ACCESS OR CORRECT INFORMATION

Under conditions, you have the right to ask us for a copy of your Information, to correct it, erase it or restrict its processing, and to obtain the Information you provide in a structured, machine readable format. You also have the right to ask us to transfer some of this Information to other organisations.

You have the right to object to the processing of personal information on the basis of our legitimate interests. Where we have asked for your consent to process Information, you have the right to withdraw this consent at any time.

If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.

We reserve the right not to allow access to your Information or to limit your rights (e.g. if such disclosure is prohibited by law or if the rights of another individual might be violated). In some instances, this may mean that we are able to retain your Information even if you withdraw your consent.

INTERNATIONAL TRANSFER

We operate internationally, and many of our systems are currently based in the United States, this means Information we collect will be processed by us in the U.S. where data protection and privacy regulations will not offer the same level of protection as in other parts of the world, such as the European Union.

When we transfer your Information to our United States group members outside the European Economic Area (EEA), we make use of standard contractual clauses which have been approved by the European Commission. We also use these clauses when we transfer your Information to third parties outside the EEA or we may adopt other means to ensure that adequate safeguards are applied to your Information (e.g. Privacy Shield, BCR, etc). You may obtain a copy of the documents we use to protect your Information when it is transferred outside the EEA by contacting us via email at protofundev@gmail.com.

NOTIFICATION REGARDING UPDATES

From time to time, we can update this Privacy Policy. We will notify you about changes to this Privacy Policy by placing a notice on our sites. We encourage you to periodically check back and review this policy so that you always know our current privacy practices.

HOW TO CONTACT US

For any questions, comments or concerns about our Privacy Policy or any other issue please contact PROTOFUN STUDIO at: protofundev@gmail.com or submit a ticket via the applicable support channel of the game. All notices given by you or required from you under this Privacy Policy shall be in writing and addressed to: PROTOFUN STUDIO, Room 104, 8th Gate, Building 1, HePingli 3, Dongcheng District, Beijing, 100000, China.