Last Updated: 26 March 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 only applies to Tencent Guandan (騰訊摜蛋) (the “Service”). 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 Service is Proxima Beta Pte. Limited

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 Service?	If you register an account to use the Service, then we will need some information from you to set this up, including your openID and WeChat account information. To provide you with the Service, we will process your gameplay data, such as your device information and level, score and battle information. To maintain the smooth operation of the Service (which includes activities such from addressing bugs or malicious activity through to improving functionality), we will process customary device and network information (such as IP address, connection information, device specifications, as well as app- and OS-generated identifiers). 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. If you made an in-app purchase via the App Store, we process your IP address, recharge records and consumption records to respond to related enquiries.	More Information.
How will we use your information?	We use your information to set up your account, enable you to use the Service, localise the Service experience, enable interaction between users of the Service, save your progress, ensure the safe and secure operation of the Service, address bugs, optimise and improve the Service, protect users, enable transactions, resolve user queries, and to comply with our legal obligations and enforce our legal rights.	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 (such as needed to back up your progress as well as for customer support and payment processing). 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 Service (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?	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 Service in Singapore. We also have support, engineering and other teams who may support the Service from Singapore. For EEA/UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses or taking into account adequacy assessments.	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 Service, 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 Tencent Guandan (騰訊摜蛋)!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with Tencent Guandan(騰訊摜蛋) (the “Service”), 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 Service. 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 Service. By using the Service 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 Service is Proxima Beta Pte. Limited (“we”, “us”, “our”). The registered address of Proxima Beta Pte. Limited is 10 Anson Road #21-07 International Plaza, Singapore.

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, please contact us to reach out data protection officer. We have representatives for data protection purposes listed here.

1. Children

Children must not use the Service 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 18 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
Algeria	19
Argentina	13
Australia	18
Bangladesh	18
Brazil	18
Cambodia	18
Canada	13
Colombia	18
Egypt	18
European Economic Area	16
Hong Kong	18
Indonesia	18
Kazakhstan	18
Kuwait	21
Macau	18
Malaysia	18
Mexico	18
Morocco	18
Myanmar	18
New Zealand	16
Nigeria	13
Philippines	18
Qatar	18
Saudi Arabia	18
Serbia	15
Singapore	13
South Africa	18
Sri Lanka	18
Switzerland	14
Thailand	20
Tunisia	18
Türkiye	18
United Arab Emirates	21
United Kingdom	13
United States	13

2. How We Process Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why. it also identifies the legal basis under which we process your data if required for your jurisdiction.

Personal Information	Use	Legal Basis (where applicable)
Information you provide to us (either directly or through a third party)
Login data: When you login with WeChat: User ID, WeChat profile picture and username / nickname information, whether WeChat is installed on your device’s operating system, device model information (e.g. iPhone 15) When you login as guest: OpenID, (Android only) UUID	We use this information to: create your account for the Service; and enable you to login either using your WeChat login or a guest login and to do so in a secure manner.	Necessary to perform our contract with you to provide the Service.
Age information: Date of birth - we only process this momentarily to confirm your age status (adult / minor) and do not store this on our servers. Age status – whether you are a minor / adult	We use this information to verify your age if you are a user in certain regions.	To comply with our legal obligations under applicable laws.
Sharing data: If you choose to share via WeChat: Clipboard information (i.e. what is copied/pasted on the device) and images or content actively selected by you in third-party applications.	We use this information so that you can share game activities with your friends on WeChat.	Necessary to perform our contract with you to provide the Service.
Location information: IP address – we only process this momentariliy to identify your location and do not store this on our servers. Country – as selected by the user during account registration	We use this information to: suggest your country / region when you input your location during account registration; ensure the correct version of the Service is shown to you; and verify whether the Service is available in your country / region.	Necessary to perform our contract with you to provide the Service.
Information generated or processed by us as part of the Service
Customer support data: Identity information: User ID and email address (if you choose to contact us via email) Device information: Device name Other: Network type, application version, game account and contact information (including your nickname, profile picture, whether your login was successful Game data: Game character information (including your role name and role ID, game data and records, frequency of playtime, game history), and in-game data (including items, purchase and top-up information, penalties, activities, game match data, in-game friends) Log data: Customer service log data (including user ID, ticket date, type of request) Any other details/information (including any documents/media) that you choose to provide to us as part of your ticket, query or review	We use this information to: verify your identity before providing customer support; respond to your communications; and provide troubleshooting, such as addressing and remediating technical issues and bugs.	Necessary to perform our contract with you to provide and support the Service.
Bug reporting data: Identity information: User ID Game behaviour information: gameplay mode information, date and time stamps of actions, level, score, battle information, error code	We use this information to: fix any operational issues with the Service; provide troubleshooting, such as addressing and remediating technical issues and bugs; ensure the security of the Service, solve and locate problems; and optimize our services and improve the quality of the Service.	It is in our legitimate interest to ensure the security of our services, to maintain a fair gaming environment in the Service and to improve our Service.
Performance and analytics data: Identity information: User ID Device information: Device model, CPU model, CPU usage rate phone memory, screen orientation and resolution, RAM, ROM, device manufacturer, CPU architecture and device standard Other: Mobile network code, network Type, login channel ID, application version, application package name Game behaviour information: Gameplay mode information, date and time stamps of actions, level, score, battle information, error code, date, game ID, game account, operation button, operation button response time, error code, currency amount, level card information, game time, multiplier information, victory and defeat information	We use this information to: provide you with feedback and information about your gameplay and progress; optimize our services and improve the quality of our Service; and help us understand user behaviour and how to best support users.	It is in our legitimate interest to ensure the security of our services, to maintain a fair gaming environment in the Service and to improve our Service.
Game data: Identity information: User ID Device information: CPU usage rate, WiFi SSID, CPU model, GPU information, device system version, WIFI address Other: Application version, application package name, process name, IP address, network type, operator name, login channel ID, game log information (Item log, operation information, game match information, date information, etc)	We use this information to enable you to use the Service and to ensure the smooth running of the Service.	Necessary to perform our contract with you to provide and support the Service.
Transaction data: User ID, IP address and recharge records and consumption records	We use this information to: allow you to submit enquiries regarding your transaction records if you made in-app purchases via the App Store’s payment function; maintain a record of your transaction history; and	Necessary to perform our contract with you to provide and support the Service.
	detect and combat fraud or suspicious transactions on the Service.	It is in our legitimate interest to ensure the security of transactions within our Service.

3. How We Store and Share Your Personal Information

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 Service in Singapore. We also have support, engineering and other teams who may support the Service, including in Singapore.

For EEA/UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses or taking into account adequacy assessments.

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 Service, including social media platforms (WeChat) if you choose to login to the Service via such platform. 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 Service (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 Service 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 Service 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
Login data Age status Sharing data Bug reporting data Performance and analytics data Game data Transaction data Location information (Country)	Stored for the lifetime of the Service until (i) an account deletion request, in which case data is deleted within 30 days after the request; or (ii) after 30 days upon cessation of the product operation cycle (whichever is earlier).
Customer support data	Stored for 365 days and deleted within 30 days upon an account deletion request. Customer service log data is deleted automatically after 30 days
Date of birth	We do not store this information.
Location information (IP address)	We do not store this information. We process this momentarily and it is deleted automatically after a user’s location is identified.

6. Your Rights

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.

You have legal rights in relation to your personal information (to the extent permitted under applicable laws and regulations). You are entitled to request a copy of the personal data we process about you, request us to correct personal data that we hold about you that is inaccurate, and you have the right to object to the use of your personal data for marketing or any other form of commercial prospecting, or on any grounds of personal nature. A fee may be chargeable by us for complying with a data access request.

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 Section 2 (How We Process 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 Service account.

Erasure

You may be able to delete your account, or remove certain personal information, by logging into your Service 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 Service 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.

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. 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 Service 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: dpo_guandan@proximabeta.com

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.

9. Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this Privacy Policy, the English version shall prevail.

Our Representatives in Certain Jurisdictions

Jurisdiction	Representative	Address	Contact details
EU	Proxima Beta Europe B.V.	Buitenveldertselaan 1-5, 1082 VA, Amsterdam, the Netherlands	dpo_guandan@proximabeta.com
UK	Image Frame Investment (UK) Limited	4th Floor 80 Strand, London, United Kingdom WC2R 0RL	dpo_guandan@proximabeta.com
Republic of Korea	Kite Bird Korea Yuhan Hoesa	25F, 55, Sejong-daero, Jung-gu, Seoul (Taepyeongro 2-ga), Korea	dpo_guandan@proximabeta.com
Serbia	Karanovic & Partners o.a.d. Beograd	Resavska 23, Belgrade, 11000, Serbia	local.representative@karanovicpartners.com
Thailand	Tencent (Thailand) Company Limited	8 T-One Building, Floor 10th, 11th & 12th (Unit 3-5), Soi Sukhumvit 40, Sukhumvit Road, Khwaeng Phra Khanong, Khet Khlong Toei, Bangkok 10110, Thailand	dpo_guandan@proximabeta.com
Türkiye	Özdağıstanli Ekici Avukatlık Ortaklığı.	Nidakule Ataşehir Kuzey Begonya Sok. No:3 Kat. 17 D: 162 34746 Ataşehir / İstanbul, Türkiye Özdağıstanli Ekici Avukatlık Ortaklığı is our data controller representative and its authority is limited to the authorities stipulated under the Law on Protection of Personal Data w. no 6698. Özdağıstanli Ekici Avukatlık Ortaklığı is not authorised for any other matters such as in-Service conduct, suspensions, investigations, civil or criminal complaints.	turkeydatarep_proximabeta@iptech-legal.com

SUPPLEMENTAL JURISDICTION-SPECIFIC TERMS

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

Algeria

By using the Service, you give your consent to the collection, storage, treatment and use of your personal information, and transfer of your personal information to third parties or our affiliates to help us deliver the Service, in each case location in the jurisdictions specified in Section 3 (How We Store and Share Your Personal Information).

Argentina

If you are dissatisfied with our response to your request for access to, correction, or erasure of your personal information or your privacy complaint in respect of your personal information, you may contact the Agency for Access to Public Information at: Av. Pte. Gral. Julio A. Roca 710, Piso 2°, Ciudad de Buenos Aires (Telephone: +5411 3988-3968 or email: datospersonales@aaip.gob.ar). While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, by providing your personal information and by using the Service, you consent to the transfer of your personal information to a jurisdiction where privacy laws may not offer the same level of protection as the laws that may apply in Argentina.

Australia

We take reasonable steps to ensure that third party recipients of your personal information located outside Australia handle your personal information in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients. You have the right to access personal information we hold about you, how we use it, and who we share it with. You have the right to correct any of your personal information we hold that is inaccurate.

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

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the Australian Information Commissioner (Telephone: +61 1300 363 992 or email: enquiries@oaic.gov.au).

Bangladesh

By acknowledging the Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data, including disclosing to third parties, to the extent provided by the Privacy Policy. You also consent to the cross-border transfer of your information to any country or region where we have databases or affiliates and, in particular, to the jurisdictions specified in Section 3 (How We Store and Share Your Personal Information).

Brazil

Whenever we use your personal information based on your consent, you may revoke the consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account or you can contact us. This may affect our provision of the Service to you.

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORISE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

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

Colombia

Your authorization to process personal information for the Service may be expressed (i) in writing, (ii) orally or (iii) through unequivocal conduct that allows us to reasonably conclude that your authorization has been granted, such as the act of accepting the Privacy Policy. We may keep evidence of said authorizations, while respecting the principles of confidentiality and privacy of information.

As a data subject you have certain rights, including (i) to access, update and rectify your personal data; (ii) to request a copy of the consent you have given us; (iii) to be informed about how we have processed your personal data; (iv) to file claims before your country’s data protection authority; (v) to revoke the consent you have given us to process your personal data, unless the processing is based on compelling legitimate grounds or is needed for legal reasons; (vi) to ask for the suppression of your personal data (right to erasure); and (vii) to freely access your information. You can contact us to exercise any of these rights.

Egypt

By accepting the privacy policy or by proceeding with the sign up process, you acknowledge that you have read, understood, and consented to this Privacy Policy. You are acknowledging your consent to the processing, storage, and cross-border transfer of your personal data. The cross border transfer may be to any country or region in which we have databases or affiliates, in particular to the jurisdictions specified in Section 3 (How We Store and Share Your Personal Information).

If you are a new user, you have seven days to inform us of any objection you may have to this Privacy Policy.

As an Egyptian data subject, you have certain rights under the Egyptian Personal Data Protection Law.

France

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, your heirs, 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.

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 object 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

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.

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

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).

Kazakhstan

By accepting the Privacy Policy, you consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws), sharing and storage of your personal information as described in this Privacy Policy. The transfer of your personal information to third parties, which may include the cross-border transfer of your information to any country or region where we have databases or affiliates and, in particular, to the jurisdictions specified in Section 3 (How We Store and Share Your Personal Information).

In the event of any discrepancy or inconsistency between the English version and the Kazakh version of this Privacy Policy, the Kazakh version shall prevail.

Your Rights

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

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

Right to correction: You may request for the correction of your personal information or deletion of such personal information if it is impossible to correct it. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.
Right to blocking / de-blocking: You have the right to request the blocking of personal information related to you, if you become aware of a violation regarding the collection and processing of your data. If the violation has not been proved, you may request to de-block your data.
Right to deletion: You have the right to request deletion of your personal data if the collection and processing of your data has been conducted in violation of Kazakh laws.
Processing of your personal information in public sources of personal data: You may request to limit or provide your consent to the processing of your personal information in public sources of personal data.

Kingdom of Saudi Arabia

You consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws) and storage of your personal information as described in this Privacy Policy.

Kuwait

By accepting this Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data and to disclose this data to third parties whether inside or outside of Kuwait, in line with the provisions of this Privacy Policy.

Macau

You have the right not to provide your personal information. However, as a result, we may not be able to provide the Service to you. As a Macau data subject you have legal rights in relation to your personal information (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to request a copy of the data we process about you, to make a data correction request, and have the right to oppose the use of your personal information for marketing or any other form of commercial prospecting, or on any grounds of personal nature. A fee may be chargeable by us for complying with a data access request.

Malaysia

Right of access: You have the right to request access to and obtain a copy of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law. When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

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

Right to limit processing of your personal information: You may request to limit the processing of your personal information by contacting us. However, this may affect our provision of the Service to you.

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

Our data protection officer, responsible for the management and safety of your personal information
- Telephone: +603-22872388
- Email: as set out in Section 7 (Contact)

Mexico

Some of the purposes of processing specified in Section 2 (How We Process Your Personal Information) are voluntary, which may include to show you personalised recommendations or advertising.

In general, we do not require your consent to carry out the transfers detailed in Section 3 (How We Store and Share Your Personal Information). In any case, by using the Service and providing us with your personal data, you agree to the data transfers detailed therein that require your consent.

To understand more about and exercise your rights to “Access”, “Correction”, “Erasure”, “Objection”, “Restriction of Processing to Storage Only “, which includes limitation to the use and disclosure of your personal data, as well as the applicable means, procedures and requirements to exercise any of your rights, please contact us.

Morocco

We collect information for purposes strictly necessary for the proper use of the Service. By accepting this Privacy Policy, you explicitly accept that your personal data may be subject to processing by the Service.

Kindly note:

the identity of the Data Controller is set out at the beginning of this Privacy Policy
the purposes of processing personal data are set out in Section 2 (How We Process Your Personal Information)
recipients or categories of recipients are set out in Section 3 (How We Store and Share Your Personal Information)
whether the answer to the questions is compulsory or optional, as well as the possible consequences of a lack of answer: please refer to Section 2 (How We Process Your Personal Information) and Section 6 (Your Rights)

New Zealand

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

You have the right to access personal information we hold about you, how we use it, and who we share it with. You have the right to request the correction of any of your personal information we hold that is inaccurate.

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

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

Peru

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, pursuant to the Personal Data Protection Law (the “Law”). You may also exercise these rights through your legal guardian or someone who has been authorised by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Law.

You can also withdraw your consent or demand a suspension of the personal information processing at any time.

If you consider that your request has not been met you may file a claim with the Peruvian National Authority of Personal Data Protection.

Data Protection Team, responsible for the management and safety of your personal information
Contact: as set out in Section 7 (Contact)

Philippines

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 information, 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 information.
Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.
Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.

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

collecting and processing your personal information as described in Section 2 (How We Process Your Personal Information);
sharing your personal information with third parties, companies within our corporate group, and a third party that acquires all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and
transferring or storing your personal information in destinations outside the Philippines as described in Section 3 (How We Store and Share Your Personal Information)

Qatar

If you are using the Service in Qatar, you consent (for the purposes of Law No. 13 of 2016 on the Protection of Personal Data, as may amended from time to time) to the processing of your information in accordance with this Privacy Policy.

Serbia

Our designated local representative in Serbia is Karanovic & Partners for the purposes of compliance with the Law on Personal Data Protection, and can be contacted at local.representative@karanovicpartners.com. Please include the word “Serbia” in the subject line of your email.

Name: Karanovic & Partners o.a.d. Beograd
Address: Resavska 23, Belgrade, 11000, Serbia
Telephone Number: +381 11 3094 200

E-mail: local.representative@karanovicpartners.com

Singapore

By accepting this Privacy Policy, you consent to the collection, use and disclosure of personal data as set out in this Privacy Policy, including cross-border transfer of your information to any country or region where we have databases or affiliates and, in particular, the locations specified in Section 3 (How We Store and Share Your Personal Information). In situations where consent is not obtained, Proxima Beta collects, uses, or discloses personal data in accordance with an exception under the Personal Data Protection Act 2012 or as required or authorized by any other applicable law.

You have the right to access your personal information, how we use it, and who we share it with. You have the right to correct any of your personal information that is inaccurate.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted here.

South Africa

You have the right to lodge a complaint with the Information Regulator (South Africa) by emailing it at inforeg@justice.gov.za. The Information Regulator (South Africa)’s physical address is 33 Hoofd Street Forum III, 3rd Floor Braampark, Braamfontein, Johannesburg, South Africa.

Sri Lanka

By accepting this Privacy Policy, you consent to the Privacy Policy and permit the collection, use and disclosure of your personal information. Thailand

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

To the extent provided for by the Thai Personal Data Protection Act (PDPA), you may:

withdraw your consent to the processing of your personal data (only where the legal basis for our processing is consent); however, please note that where consent is required to process your personal data, we may not be able to deliver the expected service without it;
request us to provide you access to, make any correction to, cease any automated processing or profiling (if applicable), discontinue, restrict the use or provision of and/or erase your personal data;
request us to provide you or a third party with your personal data which is stored by us in a machine readable format; and/or
lodge a complaint to a relevant authority.

Where you wish to make such requests, please contact us.

The contact details of our designated local representative in Thailand for the purposes of compliance with the PDPA is as set out in Section 7 (Contact) and can be contacted via email. Please include the word “Thailand” in the subject line of your email.

Türkiye

You have legal rights, which are set forth in Article 11 of the Turkish Law on Personal Data Protection Law (“DPL”), in relation to the personal information data we hold about you. As a Turkish data subject, you may have the right to apply to the data controller and (to the extent permitted under applicable laws and regulations):

learn whether or not your personal data has been processed;
request information about processing if your personal data has been processed;
learn the purpose of processing of your personal data and whether they have been used accordingly;
know the third parties in the country or abroad to whom personal data has been transferred;
request rectification in the event personal data is incomplete or inaccurate and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the DPL and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
object the occurrence of any consequence that is to your detriment by means of analysis of personal data solely through automated systems; and
demand compensation for the damages that you have suffered as a result of unlawful processing of your personal data.

In accordance with Article 9 of the DPL, your personal data may be transferred abroad as follows:

Identity of the overseas recipient

Location of the recipient (or as otherwise stated in the recipient’s privacy policy)

Purposes of use of Personal Information by the recipient

Items of Personal Information to be provided

Aceville Pte. Limited

(cloudlegalnotices@tencent.com)

Singapore

Storage of personal information

All personal information collected

Ukraine

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 or regions other than Ukraine, to the extent and for the purposes provided in this Privacy Policy.

United Arab Emirates

You consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws), sharing and storage of your personal information, as described in the Privacy Policy.

We may voluntarily report a cyber-security incident where it constitutes a crime under UAE law (e.g. under the UAE Cybercrime Law). The incident can be reported to the relevant authorities for the purpose of investigations. Please note that voluntary reporting of a cyber-security incident can also be made to the UAE Computer Emergency Response Team (“CERT”). CERT is a security awareness organisation that provides a process for logging incidents and advising on known cyber security threats in the UAE.

United States

For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”), and respectively include the terms “personal data” and “sensitive data” as defined in the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”), (collectively, “US State Laws”). The terms do not include information excluded from the scope of US State Laws.

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed for a business purpose the following categories of personal information, including sensitive personal information (denoted by *), from or about you or your device:

Identifiers, such as your name as it appears on your social media profile, your Open ID / user ID, IP address and device model. This information is collected directly from you and your device and from social media platforms if you choose to sign up using a social media account.
Internet or other electronic network activity information, such as your information regarding your use of the Service, including level, score, date and time stamps of actions, log-in and clickstream data and other Device Information as described in the main Privacy Policy. This information is collected directly from you and your device.
Commercial information about any transactions within the Service such as what products were purchased and how much they cost. This information is collected directly from you and your device and the Google Play or Apple iOS store.
Geolocation information such as your region location when you set up your profile and choose to provide this information for the Service. This information is collected directly from you.
Audio and visual information such as your social media profile picture, photos shared in the Service and any other game content that you wish to share with friends. This information is collected directly from you and from social media platforms if you choose to sign up using a social media account.
Account log-in information, including the userID used to access your Service account.*

We collect and disclose your personal information, including sensitive personal information, for the following purposes:

To provide you with the Service, maintain your account, provide customer service and maintain a record of your transactions in-Servive.
To improve our services, including the functionality of the Service.
For security and verification purposes, including to prevent and detect fraudulent activity.
To address and remediate technical issues and bugs.

For additional information about what each type of personal information is used for, see Section 2 (How We Process Your Personal Information).

We disclose each of the categories of personal information that we collect as described in Section 3 (How We Store and Share Your Personal Information).

In the past 12 months, we have not sold or shared personal information of California residents within the meaning of “sold” and “share” in the CCPA. And we have no knowledge of any sale or sharing of personal information of users under 16 years of age.

In addition, we do not use or disclose sensitive personal information for purposes other than to perform the services reasonably expected by an average consumer who requests those services or as otherwise permitted by US State Laws.

Retention of Your Personal Information

The retention period varies among the different categories of data collected. For detailed information about the retention period for any specific category of data, see this chart in the main portion of the Privacy Policy.

Rights under US State Laws:

Depending on where you live, you may have some or all of the rights listed below in relation to information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

Right to Access/Know. Request we confirm whether we process information about you and give you access to that information. You may also request to receive that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment. If you are a California resident, you may request the following information about our collection, use and disclosure of your information:
- the categories of personal information about you that we collected;
- the categories of sources from which the personal information was collected;
- the business or commercial purposes for collecting personal information about you;
- the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
- the specific pieces of personal information we collected about you;
Request to Delete. Request we delete personal information we collected about you;
Request to Correct. Request we correct inaccurate personal information that we maintain about you;
Right to Opt out of Targeted Advertising or Profiling. Request to opt-out of the processing of your information for the purposes of targeted advertising or the profiling of your information in furtherance of decisions that produce legal or similarly significant effects; and
Right to Non-Discrimination. 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 US State Laws.

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. Depending on where you live, you may also exercise your rights, if any, regarding other data by contacting us. We may take steps to verify your identity before complying with your request to protect your privacy and security, and may decline your request if we are unable to verify your identity. To verify your identity, we may need the following information from you: your first name, last name, address, phone number, date of birth and email address.

Depending on where you live, you may exercise these rights yourself or you may also designate an authorized agent to make these requests on your behalf. In order for us to process the request, you must provide the authorized agent with signed written permission. We reserve the request to require the agent to verify their own identity and to confirm directly with you that you have provided the authorized agent permission to submit the request.

In addition, where applicable, we will provide you with more information about our appeal process. When you submit a request or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfil your request or process your appeal. We will not require you or your authorized agent to pay a fee for the verification of your request or appeal.

Questions

If you have questions or concerns regarding this Privacy Policy, please contact us.