Closed Beta Test

Last Updated: [[  ] 2024]

Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Please note that this privacy policy (“Privacy Policy”) only applies to Happy Match (“Game”). If you use any other products or services, please refer to the privacy policy for that particular product or service.

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here.

For the purpose of data protection laws, the data controller of your personal information in relation to the Game is Proxima Beta Pte. Ltd.

SUMMARY

Here is a summary of the information contained in this Privacy Policy. You can find more detail by clicking ‘More Information’.

What information do we need to be able to provide the Game?	If you register an account to use the Game then we will need some information from you to set this up. This includes your identification Information (openID), Social Media Platform Information ( nickname, avatar, ticket, UserID). Depending on your use of the Game and the jurisdiction where you are based, you may also need to provide some additional information to help us set up your account. If you choose to set up your profile using a social media account, we collect information provided by your social media account service provider to automatically generate your profile. To maintain the smooth operation of the Game (which includes activities such from addressing bugs or malicious activity through to improving functionality), we will process customary device and network information. If you need to get in touch with us, we will retain some information (such as your email and any screenshots you send us) so that we can review and respond to your concerns.	More Information.
How will we use your information?	We use your information to set up your account, enable you to use the Game, localise the Game experience, enable interaction between users of the Game, save your progress, ensure the safe and secure operation of the Game, address bugs, optimise and improve the Game, protect users, enable transactions, resolve user queries, and to comply with our legal obligations and enforce our legal rights. We use your information to facilitate your communications with other players, and ensure a safe gaming environment.	More Information.
Who do we share your information with?	We use third parties and work with our affiliates to help us deliver the best possible experience. All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Game (i.e., to fulfil the purpose(s) described above). In some cases, we may be required by a court or be under a legal obligation (such as a valid search warrant or subpoena) to disclose certain information.	More Information.
Where do we process your information?	Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy. We have servers for the Game in Singapore. The servers applicable to your use of the Game will depend upon your location. We also have support, engineering and other teams who may support the Game, including from Singapore.	More Information.
How long do we keep your information?	Unless otherwise required or permissible by applicable laws, we retain your information for the period during which you maintain an account for the Game, or for so long as the information is needed to fulfil the purpose for which it was collected (as further described in this Privacy Policy). We then delete or anonymise such data, in accordance with applicable laws.	More Information.
How can I exercise my rights over my information?	Certain jurisdictions offer users specific rights with respect to their information, so you may have a right to access or receive a copy of your data, or to delete your data or restrict or object to our processing of your data.	More Information.
How will we notify you of changes?	Changes to this Privacy Policy will be posted here. We will also notify you of changes in accordance with relevant legal requirements.	More Information.

Welcome to Happy Match!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with Happy Match (the “Game”), and sets out your choices and rights in relation to that information. Please read it carefully – it will allow you to understand how we collect and use your information, and how you can control it.

Please note that this Privacy Policy only applies to the Game. If you use any other products or services please refer to the privacy policy for that particular product or service.

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Game. By using the Game, you are acknowledging how we process your personal information as described in this Privacy Policy.

For the purpose of data protection laws, the data controller of your personal information in relation to the Game is Proxima Beta Pte. Ltd. (“we”, “us”, “our”).

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here. You can also reach out to our data protection officer at Service_HappyMatch@proximabeta.com. We have representatives for data protection purposes listed here.

1. Children

Children must not use the Game for any purpose, except where their parent or guardian has provided lawful consent (to the extent this option is available in your jurisdiction).

By children, we mean users under the age of 18 years old; or in the case of a region where the minimum age for processing personal information differs, such different age. For users located in certain regions, we have listed the relevant minimum age as of the date of this policy in the table below. You should in any case refer to the laws in your jurisdiction to ensure you are above the relevant legal minimum age.

Other than as provided above, we do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without lawful consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us.

Region in which the user is located	Minimum age of the user
Indonesia	18
Mexico	18
Singapore	13
Hong Kong	18

2. How We Process Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why.

Personal Information	Use	Legal Basis
Information you provide to us (either directly or through a third party)
Social Media Information (if you choose to log in via your social media account with these networks) that such social media companies provide: Facebook: Identification Information (openID), Social Media Platform Information (facebook nickname, avatar, ticket, UserID) Google: Identification Information (openID), Social Media Platform Information (google nickname, avatar, ticket, UserID)	We use this information to allow you to register and create your account for the Game (including by linking your game account to another account of an eligible platform) in accordance with your request, log in to the Game and participate in game activities and receive notifications of the Game.	Necessary to perform our contract with you to provide the Game.
Information generated as part of the Game
(Dolphin SDK) Identity Information (open id), login channel id	We use this information to check App and Resource versions, provide update prompts/notifications, and provide any version updates.	Necessary to perform our contract with you to provide the Game.
(GCloudCore SDK) Identity Information (open id), login channel id	We use this information to provide Game configuration downloads, and to provide SDK management function and configuration distribution capabilities.	Necessary to perform our contract with you to provide the Game
(Crashsight SDK) Diagnostic logs and crash related information such as user IDs, device identifiers, cpu, storage, network status, crash exception and ANR (application not responding)	We use this information to: Locate and solve crash issues; Solve Game crashes and improve the Game by capturing any irregular errors or crash which users experience in-game.	Necessary to perform our contract with you to provide the Game.
Data analytics/profiling information (Appsflyer):  Technical Information (such as: browser type, device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier) Technical Identifiers (such as: clicks on Customer ads, ad impressions viewed, audiences or segments to which an ad campaign is attributed, type of ads and the webpage or Application from which such ads were displayed, the webpages/ website visited, the URL from the referring website, downloads and installations of Applications, events and actions players choose to measure and analyze within their Application or website (e.g. add to cart, in-app purchases made, clicks, engagement time etc.)) Engagement Information (such as: clicks on Customer ads, ad impressions viewed, audiences or segments to which an ad campaign is attributed, type of ads and the webpage or Application from which such ads were displayed, webpages on Customer’s website visited by an End User, URL from the referring website, downloads and installations of Applications, and other interactions, events and actions Customers choose to measure and analyze within their Application or website (e.g. add to cart, in-app purchases made, clicks, engagement time etc.)) (For more information as to the information that will be processed from use of Appsflyer, please see https://www.appsflyer.com/legal/privacy-policy/)	We use this information for： Data analytics and profiling for ad attribution purposes to understand how Game players interact with advertisements.	It is in our legitimate interest to use this information to provide a better gaming experience.
Data analytics/profiling information (Firebase):  Remote notifications: Device Token and FCM (Firebase Cloud Message) Token (For more information as to the information that will be processed from use of Firebase, please see https://firebase.google.com/support/privacy#data_protection)	We use this information for system notifications (i.e., for user to receive notifications (notification bars) on device screen - home screen and / or notification board (both local & remote)).	It is in our legitimate interest to use this information to provide a better gaming experience.
(TDM SDK) Device information (AndroidID, Phone memory, Device brand, Device system version, Device manufacturer, ROM, Screen resolution, RAM, System time, Device model, device name, CPU model, CPU architecture), SDK version, IP address, Mobile network code, Network Type, , Application package name, Application version	We use this information for recording data generated during player gameplay, and for data analytics.	We collect this information with your consent.
MSDK Information (”minor’ label, “not minor” label, openid, email address)	We use this information to: Verify your identity and enable logging in; Generate your game account; Verify your age if you are a user in certain regions Send emails for parental or guardian confirmation/ verification.	Necessary to perform our contract with you to provide the Game.
MSDK Automatic Login Query User Information(OpenID, email address, telephone number, Country code) (The email address, telephone number, country code will be collected only when user using email is used to do automatic login.)	We use this information to: Verify your identity Enable logging in Generate your Game Account	Necessary to perform our contract with you to provide the Game.
Survey Information: Gender (voluntary), age range (voluntary)， ratings, feedback (game content and gameplay)	We use this information to further improve our Game and develop new services.	We collect this information with your consent.

3. How We Store and Share Your Personal Information

Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy.

We have servers for the Game in Singapore. The servers applicable to your use of the Game will depend upon your location. We also have support, engineering and other teams who may support the Game, including in Singapore.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

Third parties that provide services in support of the Game, including providers of services that process information identified in this policy for the purpose of providing the Game (eg. Rebellion Interactive Limited, in connection with the development of the Game). All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Game (i.e., for the purpose(s) described above).
Companies within our corporate group who process your personal information solely for the purpose of providing the Game to you. All such group companies may only use your personal information in accordance with this Privacy Policy.

Regulators, judicial authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you, such as to comply with legal obligations or processes. In complying with the terms of valid legal processes, such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in advance of such disclosure.
Third parties to ensure safety, security, or compliance with laws. We may disclose your information to:
- enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
- detect, prevent or otherwise address security, fraud or technical issues; or
- protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (such as exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

4. The Security of Your Personal Information

We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Game or otherwise via the Internet; any transmission is at your own risk.

5. Data Retention

We do not keep your data for longer than is necessary to fulfil the relevant purpose described above unless we are required or permitted to do so under law. If we retain your information beyond the retention periods set out below, for example to comply with applicable laws, we will store it separately from other types of personal information.

For further details on how long we keep your data, please refer to the time periods set out below.

Personal Information	Retention Policy
All personal data mentioned in Section 2 (‘How We Process Your Personal Information’)	Stored for the duration of the CBT and deleted 30 days thereafter. You may also request for your data to be deleted at any time and we will do so within 30 days of the request.

6. Your Rights

Some jurisdictions’ laws grant specific rights to users of the Game. Please refer to the Supplemental Jurisdiction-Specific Terms, or the applicable laws in your jurisdiction, for an overview of specific rights that apply to persons subject to data protection laws in the listed jurisdictions and how these can be exercised.

You may have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). You can exercise some of these rights directly by accessing and updating the information in your account. If you believe we hold any other personal information about you, please contact us.

Access

You may have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account.

Portability

You may have the right to receive a copy of certain personal information we process about you. For example, in certain jurisdictions this can comprise personal information we process on the basis of your consent (e.g., survey information) or pursuant to our contract with you (e.g., account name), as described above in the section “How We Use Your Personal Information”. We will provide further information to you about transferring this data if you make such a request.

Correction

You may have the right to correct personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your Game account (“Settings” interface).

Erasure

You may be able to delete your account, or remove certain personal information, by logging into your Game account. We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Game and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only

You may have a right to require that we stop processing the personal information we hold about you (other than for storage purposes in certain circumstances). Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). Where we agree to stop processing the personal information, we will take steps to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You may have the right to object to our processing of your personal information. If you wish to do so, please contact us at Service_HappyMatch@proximabeta.com or using the contact details set out below, and we will consider your request.

Consent Withdrawal

To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us at Service_HappyMatch@proximabeta.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the Game for maintenance, or security, privacy or administrative-related communications). These are essential system and service-related announcements and you are not able to opt-out of these notifications, which are not promotional in nature.

7. Contact

Please get in touch with us if you have any questions. You can reach us in the first instance at:

Email: Service_HappyMatch@proximabeta.com

Mailing Address:

International Privacy & Data Protection Centre

30 Raffles Place #18-01

Singapore 048622

We will endeavour to deal with your request as soon as possible. This is without prejudice to any right you may have to launch a claim with a data protection authority in the region in which you live or work where you think we have infringed data protection laws.

8. Changes

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here and notify you in accordance with relevant legal requirements.

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Game, 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.

Hong Kong

As a Hong Kong data subject you have legal rights in relation to the personal information we hold about you (to the extent permitted under applicable laws and regulations).

You are entitled to make a subject access request to receive a copy of the data we process about you, a data correction request as well as a right to reject to the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.

Indonesia

Consent

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

Parental and Guardian Consent

If you are under the age of 21, you undertake that you have the consent of your parent or legal guardian to register an account on the Game and use the Game.

Data Subject Rights

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

Data Breach

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

Data Retention

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

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 information, we may also verify the information 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 information (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).

Mexico

Age Restrictions

Please do not use the Game Services unless you are 18 years old or you have obtained parental/guardian agreement to this Privacy Policy (both for themselves and on your behalf).

Types of Personal Information We Use

For clarification purposes, in section "The Types of Personal Information We Use” and section “How We Use Your Personal Information” you can find full details about the personal data we use. Therefore, we are providing you with complete information about the personal data we use, in terms of the Federal Law on Protection of Personal Data held by Private Parties and other applicable regulations.

Purposes of Processing

Some of the purposes of processing stated above are for voluntary purposes, including to show you personalised recommendations. We may also use your personal data for the voluntary purpose of sending information to your email that we may consider relevant to you. You may object to the processing of your personal data for voluntary purposes as stated in the section “Your Rights”.

Please be informed that we may also use your personal data to comply with legal obligations or requests from competent authorities, assert or defend our rights before the competent authorities / courts, respond to requests you send us in relation to your personal data and carry out the transfer of personal data detailed in section “How We Store and Share Your Personal Information”.

Data Transfer Consent

In general, we do not require your consent to carry out the transfers detailed in section “How We Store and Share Your Personal Information”. However, we require your consent to transfer your personal data to a third party that acquires all or substantially all of us or our business.

By using the Game Services and providing us with your personal data, you agree to the data transfers detailed above that require your consent. You may exercise your rights in connection with your personal data as stated in the section “Your Rights”.

Your Rights

The sub-sections entitled “Access”, “Correction”, “Erasure”, “Objection”, “Restriction of Processing to Storage Only”, which include limitation to the use and disclosure of your personal data, and “Email Opt-Out” and “SMS Opt-Out” included in Section “Your Rights” above also apply to users that are located in Mexico.

You also have the right to revoke the consent that you have provided us to process your personal data.

To exercise any of your rights, contact our Data Protection Officer at Service_HappyMatch@proximabeta.com.

To know more about your rights, as well as the applicable means, procedures and requirements to exercise any of your rights, please contact our Data Protection Officer at Service_HappyMatch@proximabeta.com.

Singapore

By clicking the button to proceed, you consent to the cross-border transfer of your information to any country where we have databases or affiliates. Presently, our servers are only in Singapore.

Access

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

Correction

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

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