DELAN PRIVACY POLICY

1. Introduction

1.1 HONGKONG DELAN CO., LIMITED and its affiliates (hereinafter referred to as "we", “us” or "DELAN") are dedicated to protecting the privacy rights of our users (hereinafter referred to as "users" or "you"). This Privacy Policy has been crafted to inform you as to the ways we collect, store, use, manage, and, in certain circumstances, share the information you provide in connection with any our games, applications, websites, stores, communities, or other related services (hereinafter referred to as "Services") and tells you about your privacy rights and how the law protects you.

1.2 We endeavor to ensure that all our ways of handling personal data are carried out in compliance with the Personal Data (Privacy) Ordinance, Cap 486 of the laws of the Hong Kong Special Administrative Region (the "PDPO") and other applicable data protection laws or regulations. By using the Services, you agree to the collection and use of your personal data in accordance with this Privacy Policy. We may amend the Privacy Policy from time to time, and we encourage you to consult the Privacy Policy regularly for changes. If you do not agree with this policy, do not access or use our Services or interact with any other aspect of our business.

2. Collecting and Using Your Personal Data

2.1 Data You Provide

In order to provide our Services for you, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you and we will try our best to keep the collection of personally identifiable information to the extent minimum that is necessary and appropriate. You may decline to provide us with the requested personal data, but in such case we may not be able to provide our Services to you. Depending on how you interact with us, we may ask you to provide one or more of the following kinds personally identifiable information:

(a) Contact information (including but not limited to mobile phone number, email address)；

(b) Name (including your Legal Name, Screen Name and User ID) or other similar unique identifier；

(c) Due to certain special reasons or compliance requirements in specific jurisdictions, your government-issued identification (which may include your passport and ID card) ；

(d) Billing & transaction data.

2.2 Data We Collect

When you access or use our Services, we may automatically collect data for various reasons, which may include:

(a) Location information such as Device's Internet Protocol address (e.g., IP address) and Wi-Fi Connection, etc;

(b) Device, network & technical information such as IP address, MAC address and other similar device identifier; device model, operating system, regional / language settings, and internet service provider; screen resolution, frame rate, and ping value; stack information (e.g., crash reports and core dumps), server health indicators(e.g., CPU and memory usage, I/O usage, and load average) and other diagnostic data; date and time stamps of actions and events; other network and technical information;

(c) Gameplay information such as data related to how you play and actions you take in our games, including character appearance and attributes, progression and results, virtual assets, currencies and items, tasks and rewards, social connections, chat logs, gameplay screen capture, game version, gamelogs, error report and other diagnostic data to locate bugs;

(d) When you access the Services by or through a mobile device, we may collect certain information automatically to complete the Services, such as data from Camera, Microphone, Photos, and read/write access to external storage, with additional consent from you.

2.3 Data from Third-Party

If you link any third party tool to our Services (such as your access to our Services via Facebook, Twitter, Game Center, Google Play or Apple, we will receive related data, which may include your name, email address, activities or contact list associated with that account, specifically depending on the third party. Besides, we would also receive your payment information when you choose to use a third-party payment processing service (such as hashed identifier, country / region from which your payment originated, and transaction details). If you choose to provide such information and Personal Data, during registration or otherwise, you are giving us permission to use, share, and store it in a manner consistent with this Privacy Policy.

2.4 How and for what purpose the collected data will be used

Our primary objective in collecting personal data is to provide and enhance the Services and to enable you to easily navigate and enjoy the Services. We use personal data only for the purposes for which the information was collected, including:

(a) enable you to set up an account / profile on the Services, allowing for a customizable and continuous experience, and to communicate with you about your account;

(b) to comply with legal obligations relating to our operation of the Services, such as implementing age assurance and verification measures, responding to a valid legal request and maintaining business books and records, etc;

(c) to troubleshoot and improve the Services and our business, such as system debugging, troubleshooting, and diagnostic testing, conducting performance analyses of our systems and Services, testing new system and Services features, system and log maintenance and providing you with technical support;

(d) to promote the safety, security, and integrity of the Services, such as identifying, preventing, and enforcing against fraud, cheats / hacks, and other prohibited behavior, administering community standards, moderating inappropriate content and responding to user reports;

(e) to provide location-based services and features you request, such as regional in-game events and matches;

(f) to fulfill the terms of uses and purchase agreement, comply with contractual and legal obligations, exercise our contractual and legal rights, including processing and shipping your order or providing you with access to digital content and defend our legal rights related to consumer purchases, such as administering complaints or refunds;

(g) to promote our Services and inform you about new releases, updates, offers, surveys, and other news about us unless you have opted not to receive such information;

(h) other purposes permitted by applicable law, for which we will notify you and obtain your consent.

3. Sharing and Disclosing Your Personal Data

3.1 We do not share your contact details (such as your name, phone number, email, or postal address) with independent third parties without your knowledge, except for limited purposes as described in this Privacy Policy (such as enforcing the DELAN TERMS OF SERVICE, securing the Services, or if we are required to do so by law or legal process). We do not sell your information.

3.2 We may share your personal data in the following situations:

(a) With Service Providers: We may share your personal data with Third-Party SDK service providers to monitor, analyze and improve the use of our Services;

(b) For business transfers: We may share or transfer your personal data in connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company;

(c) With Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any other subsidiaries, joint venture partners or other companies that we control or that are under common control with us;

(d) With business partners: We may share your information with our business partners to offer you certain products, services or promotions;

(e) With other users: when you share personal data or otherwise interact in the public areas with other users, such information may be viewed by all users and may be publicly distributed outside. If you interact with other users or register through a third-party social media service, your contacts on the third-party social media service may see your name, profile, pictures and description of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you and view your profile;

(f) With your consent: We may disclose your personal data for any other purpose with your consent.

3.3 We may disclose your personal data in the following situations:

(a) If we are involved in a merger, acquisition or asset sale, your personal data may be transferred. We will provide notice before your personal data is transferred and becomes subject to a different Privacy Policy;

(b) Under certain circumstances, we may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency);

(i) Comply with a legal obligation;

(ii) Protect and defend our rights or property;

(iii) Prevent or investigate possible wrongdoing in connection with the Services;

(iv) Protect the personal safety of Users of the Services or the public;

(v) Protect against legal liability.

4. Cookies and Similar Technologies

4.1 We use Cookies and similar tracking technologies to track the activity on our Services and store certain information. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our Services. The technologies We use may include:

(a) Cookies or Browser Cookies. A cookie is a small file placed on your device. You can instruct your browser to refuse all Cookies or to indicate when a Cookie is being sent. However, if you do not accept Cookies, you may not be able to use some parts of our Services. Unless you have adjusted your browser setting so that it will refuse Cookies, our Services may use Cookies.

(b) Web Beacons. Certain sections of our Services and our emails may contain small electronic files known as web beacons that permit us, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

4.2 Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on Your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close Your web browser.

5. Retention of Your Personal Data

5.1 We will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your personal data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

5.2 We may also retain Data for internal analysis purposes. These Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Services, or we are legally obligated to retain this data for longer time periods.

6. Transfer of Your Personal Data

6.1 Your information, including personal data, may be processed at our operating offices and in any other places where the parties involved in the processing are located. If necessary, we may transfer the personal data to places outside the Hong Kong Special Administrative Region for carrying out the purposes, or the directly related purposes, for which the personal data were collected. It means that this information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction. However we will endeavor that all the transfer of those personal data will be carried out in compliance with the requirements of the HongKong PDPO.

6.2 Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

6.3 We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your personal data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal data.

7. Exercising Your Rights of Personal Data

7.1 You have the following rights with respect to your personal data:

(a) Right of access to personal data provided；

(b) Right to correct incomplete, inaccurate, or to update outdated data；

(d) Right to withdraw or revoke consent；

(e) Right not to be subject to a decision based solely on automated processing, or profiling, which produces legal effects or negatively affects the individual；

(f) Right to have data deleted or erased；

(g) Right to either opt out of or object to certain processing；

(h) Right to have the data ported (transferred) to a different third-party provider；

(i) Right not to be subject to discrimination；

(j) Right to restriction of processing – this will only apply in certain circumstances；

(k) Right to data portability – this will only apply in certain circumstances；

(l) Right to object – this will only apply in certain circumstances；

(m) Existence of the right to lodge a complaint with a local data protection authority.

7.2 You may send us an email at DPO@delanhk.com to request access to, correct, or delete personal data that you have provided to us. We may not accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or negatively impact the information's accuracy.

8. Protection of Your Personal Data

8.1 The security of your personal data is very important to us. We use physical, electronic, and administrative safeguards designed to protect your personal data from loss, misuse, and unauthorized access, use, alteration, or disclosure.

8.2 The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

8.3 Unfortunately, the transmission of information via the internet is not 100% secure. While We strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security. Any transmission of personal data is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained in the Services.

9. Our Policy Concerning Children

We only provide services to natural persons who have reached the age of 18 (or the age of majority applicable to your residence). We do not knowingly collect personal data from children or minors under 18 years of age or as defined by local legal requirements. If we learn we have mistakenly or unintentionally collected or received personal data from a child without appropriate consent, we will delete it. If you believe we mistakenly or unintentionally collected any information from or about a child, please contact us at DPO@delanhk.com.

10. Links to Other Websites

10.1 Our Services may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

10.2 We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

11. Contact Us

If you have any questions about this Privacy Policy, you can contact us by email: DPO@delanhk.com or writing to the following address:

HONGKONG DELAN CO., LIMITED

Room 1911, Lee Garden One, 33 Hysan Avenue, Causeway Bay, Hong Kong

We reserve the right to charge you a reasonable fee for complying with a data access request as permitted by applicable laws and regulations. We keep this Privacy Policy under regular review and place updates on our website from time to time.