《秘密花园HD》隐私政策

该游戏由上海汇火网络科技有限公司负责开发。请务必认真阅读和理解本《用户服务协议》(以下简称《协议》)中规定的所有权利和限制。除非您接受本《协议》条款,否则您无权注册、登录或使用本协议所涉及的相关服务。您一旦注册、登录、使用或以任何方式使用本《协议》所涉及的相关服务的行为将视为对本《协议》的接受,即表示您同意接受本《协议》各项条款的约束。如果您不同意本《协议》中的条款,请不要注册、登录或使用本《协议》相关服务。本《协议》是用户与开发者之间的法律协议。

· 1. 服务内容
1.1 开发者,完全按照其发布的服务条款和操作规则提供基于互联网以及移动互联网的相关服务(以下简称网络服务),网络服务的具体内容由开发者根据实际情况提供,包括但不限于本开发者等。
1.2 您可以游客登陆,但如果由于删除app或切换手机造成原有数据丢失,您将承担全部责任。
1.3 您一旦注册成功成为用户,您将得到一个密码和帐号,您需要对自己在帐户中的所有活动和事件负全责。如果由于您的过失导致您的帐号和密码脱离您的控制,则由此导致的针对您、开发者或任何第三方造成的损害,您将承担全部责任。
1.4 用户理解并接受,开发者仅提供相关的网络服务,除此之外与相关网络服务有关的设备(如个人电脑、手机、及其他与接入互联网或移动互联网有关的装置)及所需的费用(如为接入互联网而支付的电话费及上网 费、为使用移动网而支付的手机费)均应由用户自行负担。

· 2. 用户使用规则
2.1 用户在申请使用开发者网络服务时,必须向开发者提供准确的个人资料,如个人资料有任何变动,必须及时更新。因用户提供个人资料不准确、不真实而引发的一切后果由用户承担。
2.2 用户不应将其帐号、密码转让、出借或以任何脱离用户控制的形式交由他人使用。如用户发现其帐号遭他人非法使用,应立即通知开发者。因黑客行为或用户的保管疏忽导致帐号、密码遭他人非法使用,开发者不承担任何责任。
2.3 用户应当为自身注册帐户下的一切行为负责,因用户行为而导致的用户自身或其他任何第三方的任何损失或损害,开发者不承担责任。
2.4 用户理解并接受我网提供的服务中可能包括广告,用户同意在使用过程中显示开发者和第三方供应商、合作伙伴提供的广告。
2.5 用户在使用开发者网络服务过程中,必须遵循以下原则:
2.5.1 遵守中国有关的法律和法规;
2.5.2 遵守所有与网络服务有关的网络协议、规定和程序;
2.5.3 不得为任何非法目的而使用网络服务系统;
2.5.4 不得利用开发者网络服务系统进行任何可能对互联网或移动网正常运转造成不利影响的行为;
2.5.5 不得利用开发者提供的网络服务上传、展示或传播任何虚假的、骚扰性的、中伤他人的、辱骂性的、恐吓性的、庸俗淫秽的或其他任何非法的信息资料;
2.5.6 不得侵犯开发者和其他任何第三方的专利权、著作权、商标权、名誉权或其他任何合法权益;
2.5.7 不得利用开发者网络服务系统进行任何不利于开发者的行为;
2.5.8 如发现任何非法使用用户帐号或帐号出现安全漏洞的情况,应立即通告开发者。
2.6 如用户在使用网络服务时违反任何上述规定,开发者或其授权的人有权要求用户改正或直接采取一切必要的措施(包括但不限于更改或删除用户收藏的内容等、暂停或终止用户使用网络服务的权利)以减轻用户不当行为造成的影响。

· 3. 服务变更、中断或终止
3.1 鉴于网络服务的特殊性,用户同意开发者有权根据业务发展情况随时变更、中断或终止部分或全部的网络服务而无需通知用户,也无需对任何用户或任何第三方承担任何责任;
3.2 用户理解,开发者需要定期或不定期地对提供网络服务的平台(如互联网网站、移动网络等)或相关的设备进行检修或者维护,如因此类情况而造成网络服务在合理时间内的中断,开发者无需为此承担任何责任,但开发者应尽可能事先进行通告。
3.3 如发生下列任何一种情形,开发者有权随时中断或终止向用户提供本《协议》项下的网络服务(包括收费网络服务)而无需对用户或任何第三方承担任何责任: 3.3.1 用户提供的个人资料不真实;
3.3.2 用户违反本《协议》中规定的使用规则。

· 4. 知识产权
4.1 开发者提供的网络服务中包含的任何文本、图片、图形、音频和/或视频资料均受版权、商标和/或其它财产所有权法律的保护,未经相关权利人同意,上述资料均不得用于任何商业目的。
4.2 开发者为提供网络服务而使用的任何软件(包括但不限于软件中所含的任何图象、照片、动画、录像、录音、音乐、文字和附加程序、随附的帮助材料)的一切权利均属于该软件的著作权人,未经该软件的著作权人许可,用户不得对该软件进行反向工程(reverseengineer)、反向编译(decompile)或反汇编(disassemble)。

· 5. 隐私保护
5.1 保护用户隐私是开发者的一项基本政策,开发者保证不对外公开或向第三方提供单个用户的注册资料及用户在使用网络服务时存储在开发者的非公开内容,但下列情况除外:
5.1.1 事先获得用户的明确授权;
5.1.2 根据有关的法律法规要求;
5.1.3 按照相关政府主管部门的要求;
5.1.4 为维护社会公众的利益;
5.1.5 为维护华毅亮点的合法权益。
5.2 开发者可能会与第三方合作向用户提供相关的网络服务,在此情况下,如该第三方同意承担与开发者同等的保护用户隐私的责任,则开发者有权将用户的注册资料等提供给该第三方。
5.3 在不透露单个用户隐私资料的前提下,开发者有权对整个用户数据库进行分析并对用户数据库进行商业上的利用。
5.4 开发者制定了以下四项隐私权保护原则,指导我们如何来处理产品中涉及到用户隐私权和用户信息等方面的问题:
(1)利用我们收集的信息为用户提供有价值的产品和服务。
(2)开发符合隐私权标准和隐私权惯例的产品。
(3)将个人信息的收集透明化,并由权威第三方监督。
(4)尽最大的努力保护我们掌握的信息。
您可通过开发者网站查看我们有关隐私保护的详细内容

· 6. 免责声明
6.1 开发者不担保网络服务一定能满足用户的要求,也不担保网络服务不会中断,对网络服务的及时性、安全性、准确性也都不作担保。
6.2 开发者不保证为向用户提供便利而设置的外部链接的准确性和完整性,同时,对于该等外部链接指向的不由开发者实际控制的任何网页上的内容,开发者不承担任何责任。
6.3 对于因电信系统或互联网网络故障、计算机故障或病毒、信息损坏或丢失、计算机系统问题或其它任何不可抗力原因而产生损失,开发者不承担任何责任,但将尽力减少因此而给用户造成的损失和影响。
6.4 开发者有权但无义务,改善或更正本服务任何部分之任何疏漏、错误。

· 7. 法律及争议解决
7.1 本协议适用中华人民共和国法律。
7.2 因本协议引起的或与本协议有关的任何争议,各方应友好协商解决;协商不成的,任何一方均可将有关争议提交至北京仲裁委员会并按照其届时有效的仲裁规则仲裁;仲裁裁决是终局的,对各方均有约束力。

· 8. 其他条款
8.1 如果本协议中的任何条款无论因何种原因完全或部分无效或不具有执行力,或违反任何适用的法律,则该条款被视为删除,但本协议的其余条款仍应有效并且有约束力。
8.2 开发者有权随时根据有关法律、法规的变化以及公司经营状况和经营策略的调整等修改本协议,而无需另行单独通知用户。修改后的协议会在开发者网站上公布。用户可随时通过开发者网站浏览最新服务协议条款。当发生有关争议时,以最新的协议文本为准。如果不同意开发者对本协议相关条款所做的修改,用户有权停止使用网络服务。如果用户继续使用网络服务,则视为用户接受开发者对本协议相关条款所做的修改。
8.3 用户对服务之任何部分或本服务条款的任何部分之意见及建议可通过客户服务部门与开发者联系,开发者保留本服务条款之解释权与修改权。
8.4 该游戏由上海汇火网络科技有限公司负责开发。

· 9. 游戏账号注销协议
9.1您需按照我们的官方渠道提供的注销流程和操作指引,在相关功能设置页面进行注销操作。
9.2为保障您的账号安全和账号相关权益,请您核实并确认您申请注销的游戏账号已经同时具备以下条件:
(1)该账号是您本人注册及使用,且符合游戏用户协议及相关规范中有关游戏账号的规定。
(2)该账号无任何安全风险,包括但不限于:(1)该账号在申请注销期间无未处理完毕的(被)投诉、举报、调查、仲裁、诉讼等;(2)该账号在申请注销期间未处于非法的被检查、被调查、被限制的状态。
(3)该账号内无任何待结清的应付未付款项。
(4)该账号无任何未完成的订单或交易,包括但不限于游戏内未完成的如虚拟货币、虚拟道具、其他商品订单或交易。
(5)不存在任何由于该账号被注销而导致的与其他基于该账号的存在而产生的或维持的权利义务的纠纷,以及公司认为注销该账号会因此产生未了结的权利义务的纠纷的情况。
9.3注销游戏账号是不可恢复的操作,注销游戏账号后,将意味着放弃如下权益:
(1)注销后,您再次使用该账号登录和使用本游戏及服务,将视为新账号;
(2)注销后,您账号下的全部权益(包括但不限于玉石、金币等)将被清除;
(3)注销后,除根据法律法规及账号注销协议约定外,您账号下相关数据将进行删除或者匿名化处理,您无权要求我司找回;
(4)为保障其他消费者的权益、维护交易秩序,您申请注销将视为您委托公司沟通处理、下架您申请注销的账号下的物品或其他权益。
9.4为了避免给您带来不便,请您在注销游戏账号之前慎重考虑,如您经慎重考虑后仍然决定要注销此游戏账号,请您务必先行仔细阅读并充分理解《游戏账号注销协议》的全部内容,包括但不限于账号注销后您应承担的后果、注销账号应具备的条件及注销游戏账号操作流程及注意事项等。


Privacy Policy

Effective Date:  June 29, 2022

Swift Games Limited. ("Swift", "we", "our", or "us") greatly recognizes and values the privacy of people ("you" or "User") who visit our websites, use or access our games, whether played on mobile devices, PCs, our websites or other approved platforms ("Swift Game(s)"), and/or otherwise use or access any of our provided services, including but not limited to software systems, customer support, marketing and advertising, and community services (collectively the "Swift Services" or "our services").

There is no age limit to create an account. Insofar as certain countries or platforms apply a higher age of consent for the collection of personal data, Swift requires parental or guardian consent before an Account is created and personal data associated with it is collected.

This Privacy Policy applies to any and all of the Swift Services and describes why and how we collect, store, and use your personal data, and the choices and rights you have about the personal data you provide or we collect in connection with the Swift Services. By accessing our websites or otherwise using the Swift Services, you acknowledge that you have read, understood, and accepted the following terms. In the case you do not agree to any of the terms, some basic functions in the Swift Game(s) may not be able to run normally, which may prevent you from using them.

In the event of a merger, acquisition, reorganization, bankruptcy or other similar event, we will make an announcement in advance, disclose the details of the event and information about the successor, and with the express consent of you and/or your parent and/or guardian (if applicable) again, your personal data may transfer to the successor. Swift may periodically modify, adjust or revise the terms of this Privacy Policy. We will announce to you the updated terms and obtain your consent (and/or the consent of your parent/guardian, if applicable) again. You acknowledge and agree to check the updated terms regularly. If major clause changes are involved, we will make an announcement in advance.

1. What Data We Collect and Process

Personal data means data that may be used to identify an individual, such as email address, contact address, postal code, position data, title, occupation, personal interests, and other data that you choose to submit.

(1) Data We Collect (either directly or through a third party)

i. Account Registration Information:Account information, namely, username, email address, password, and verification code. We use this information to create the account for your use of our services as you requested, to provide game login services, to store your game data and gameplay progress, to analyze and manage our services for system administration, and to provide great services in accordance with Article 2(2) and 2(9) in "Why We Collect and Process Your Personal Data" ("Article 2") of this Privacy Policy on the legal basis of performing our contract with you to provide our services ("Service Provision").

ii.  User Generated Content: nickname, chat data (solely in the form of text), and text content in the clipboard. We use this information to enable you to use the clipboard function, deliver your messages to other users for social interaction in-game and facilitate your communication with them in accordance with Article 2(7), 2(11) on the legal basis of Service Provision.

iii. User Service Information. Any information that you provide in communications with our support team when you seek our technical and/or customer service support and/or exercise any of your legal rights as the data subject; in case of receiving your request for support, we use such information to provide relevant support as you request and further improve our services in accordance with Article 2(10) on the legal basis of Service Provision; in case of receiving your request for data access as the data subject, we use such information to verify the requestor’s identity to ensure that he/she is the person legally entitled to make the data access request in accordance with Article 2(9) on the legal basis that it is necessary to perform our legitimate obligations as the data controller ("Obligation Performance"). iv.Survey Information. The content of your survey responses. If you agree to participate in such surveys, we use this information to improve our services in accordance with Article 2(8) with consent.

vii. Sweepstakes Participation Information: name, email address, telephone number, mailing address, UID, nickname, and country/region. If you agree to participate in such sweepstakes and win any prizes, we use your UID, address and other information as necessary to provide digital prizes and/or deliver physical prizes, as well as announce your UID and/or nickname in a partially-redacted format in accordance with Article 2(4) with consent. For users who have not won any prizes, we will not announce or display the above information in any form.

v.Internet Protocol (IP) Address. We use this information to allow you to connect to our servers in accordance with Article 2(1).

vi. Connected Social Media Account Information (Third Party). Your social media account information (if you choose to log in to our services via your social media account(s) with the corresponding network(s)); in the case of Facebook, this refers to the username of your Facebook account; we use such information to create your account for using our services in accordance with your request, and to ensure that you may share in-game photos on the corresponding network(s) in accordance with Article 2(9) on the legal basis of Service Provision.

viii. Advertising Information. Advertising ID and select device information, we store the Advertising ID for that advertisement and the other device information with your profile to track the success of our advertising and marketing programs in accordance with Article 2(6) and 2(10) on the legal basis that it is in our legitimate interests to monitor the success of our advertising and marketing programs.

ix. When you use or interact with third-party services that may be available on our services, such as third-party social media widgets, share buttons, and/or login mechanisms, this Privacy Policy does not and will not extend to such features, which shall be subject to the respective third-party privacy policies.

Unless obtaining your express and additional consent in advance and for specific circumstances, we will not collect personally identifiable information (PII) or sensitive personal information (SPI), such as real name, address, and/or fax number. You acknowledge and agree that if you elect to submit any personal data, such personal data would be subject to this Privacy Policy and you agree with all the terms therein. Please note that any personal data submitted in business transactions will not be subject to this Privacy Policy, including but not limited to job applications, participation in events, and contract signings.

(2) Data We Collect Only for System Functions

i. Generated Open ID. We generate and use this information to store your game data (including level and progress) with your profile, and to allow you to connect to our servers in accordance with Article 2(1) on the legal basis of Service Provision.

ii. IP Address. We use this information to allow you to connect to our servers in accordance with Article 2(1) on the legal basis of Service Provision.

iii. Game Data. We use this information to provide you with feedback and information about your gameplay and progress in accordance with Article 2(4) and 2(9) on the legal basis that it is necessary to perform the Terms of Service.

iv. Device Related Information. Device ID, device information (device name, device type, MAC address, IMEI, CPU, graphics card model, OS version and language, time zone, screen DPI, device resolution), registration time and login time; we use such information to improve our services including the functionality of our services in accordance with Article 2(9) and 2(10) on the legal basis that it is our legitimate interest to ensure service security, manage registrations and improve our services.

v. Bugs, Errors, and Other Data About Crashes and Diagnosis Thereof (if the occasional system crash occurs in our services). Device information (name, model, memory size, and graphics card model) and in-game information (game version, user's UID, stacktrace); we use such information to conduct identity verification for security purposes, to identify and address bugs, and to evaluate and improve the functionality of our services in accordance with Article 2(3) and 2(4) on the legal basis that it is in our legitimate interest to ensure the security of our services, and to improve our services.

vi. Security-Related Information. For the Android version: application information (APK name, version, startup time, process name), user account, device information (model, OS version, brand, CPU structure, root status, the unique identifier of ROM, screen resolution, system startup time, whether an emulator is being operated, the installed APK information, MAC address, network type, names of the running applications, list of file names in the cache directory of SD card application, and Wi-Fi name); for the iOS version: application information (module and signature), root status of device; in accordance with Article 2(9) on the legal basis that it is our legitimate interest to ensure the security of our services. You know and understand that since there are multiple versions of the game, the above information is collected for the purpose of adapting, developing and updating for devices of different versions.

vii. Malicious Content Information. Nickname, signature, chat data (solely in the form of text); in order to ensure a harmonious and healthy online environment in the game, we collect the above information to avoid some words that may offend or distress others (which breaches the Terms of Service, e.g. pornographic content) via your signature, nickname, or chat data within our services in accordance with Article 2(9) on the legal basis that it is in our legitimate interest to ensure the security of our services and a harmonious online environment within our services.

2. Why We Collect and Process Your Personal Data

In order to provide services, perform the Terms of Service and/or any other agreements between you and Swift, and/or perform the legal liabilities under the applicable laws, we collect and process your personal data to:

(1) allow you to access or restrict your access to our services;

(2) analyze and manage our services for system administration, user service, security, fraud-detection, checking the authenticity of an account owner, archival and/or backup purposes;

(3) correct bugs or errors, improve our services and respond to customer desires and preferences, including language and location customization, personalized support and instructions, and other responses;

(4) develop new services or products that user(s) request and improve the user experience;

(5) verify and confirm payment;

(6) deliver advertising that may be relevant to your interests (you can choose to turn this feature on or off in the device settings as stated hereunder);

(7) communicate with other users and take action against violations;

(8) personalize your experience, keep you up to date with the latest product announcements, provide software verification, upgrades and administration, notify of special events, offer to participate in our surveys or activities, and provide other information pertaining to our services;

(9) protect the integrity, safety, and security of our services or users, comply with legal obligations, and enforce compliance with the Terms of Service or other restrictions placed on your use of our services; and/or

(10) track your process across our websites and applications to verify that you are not a bot and to optimize our services;

(11) enable you to use the clipboard function.

For the purposes set forth above, our affiliates may be commissioned to process your information, provided that such affiliates comply with the terms and conditions hereunder. Affiliates in this Privacy Policy shall mean an entity that directly or indirectly controls, is controlled by or is under common control with Swift Games Limited. hereto. In all of the above cases and purposes, you acknowledge and confirm that we may analyze, profile, segment, merge and/or update all collected data (regardless of an aggregated or individualized manner) for the purposes of improving service quality and providing a better experience. In specific cases, we may collect other personal data apart from the categories stated herein based on your consent. When this occurs, we will, upon requiring your additional consent, provide more information about any change to the way or purpose of our collection or processing which might be different from or not clarified in the details in this Privacy Policy. Under any circumstance where our collection or processing of your personal data is based on your consent, you may withdraw such consent at any time with no impact on the validity and lawfulness of collection or processing based on the consent made before its withdrawal.

3. Advertisements and Your Choices

For the purpose of providing personalized advertisements, you acknowledge and agree that based on your consent we may collect and process the data to:

(1) deliver, target and improve our advertising; and/or

(2) improve advertising and other marketing and promotional activities. We may also use the data you provide to send you, or have our authorized contractors to deliver advertisements, market research or surveys. If you do not wish to receive any marketing or advertising information from us or our contractors, please do not provide your personal information.

Pertaining to the marketing or promotional communications, you may opt-out of receiving such communications in accordance with the instructions therein, such as SMS, email, online communication channels, or other contact methods provided by us. For example, you may opt-out of the out-of-game push notifications on mobile applications by checking the settings and turning off the "allow notifications" (iOS/Android).

Without your consent, we ensure that we will not use your data for marketing purposes, and after granting permission, you may also withdraw such consent at any time while without impact on the validity and lawfulness of data usage prior to such withdrawal.

4. Cookies or Similar Technologies

In order to measure the effectiveness of our services, we may use cookies, which are small text files for added functionality or for tracking site usage. We may use cookies and/or authorize a third-party’s tracking-utility, from time to time, (a) to log your IP address in determining the path that users take on our sites and identifying repeated users of our sites, (b) to collect the websites or sources that linked or referred you to our services, and/or (c) to collect technical data about the devices and software you use to access our services, the operating system of your devices, and other similar technical data. Notwithstanding the foregoing, we do not link your IP address to your personal data. If you do not wish to accept cookies or want to be notified of when they are placed, you may set your web browser to do so, if your browser permits.

We use the cookies, web beacons and similar technologies to personalize your experiences on our services and for various other purposes, including:

(1) remembering you: cookies, web beacons and similar technologies help us identify you as a registered user and keep the preferences or data that you have previously provided;

(2) analyzing how you use our services: cookies, web beacons and similar technologies help us understand what visitors (including users) are doing on our services, or what pages or sections are most popular;

(3) deliver advertising: cookies, web beacons and similar technologies help us provide you with advertising that we believe is relevant to you or of interest to you, on the basis of the data you provide; and/or

(4) other related functions or purposes mentioned in Article 2 herein. We or our authorized contractors may use cookies and similar technologies to provide and personalize services, prevent fraud and fulfil other purposes mentioned above. Please note you can disable cookies in your browser settings, while some parts of our services may then not function properly.

5. Who May Access Your Personal Data

In addition to Swift and/or its affiliates, other parties may also access your personal data in the following situations. You acknowledge that you have foreseen and agreed to the occurrence of such disclosure when you provide your personal data.

(1) Other In-Game Users of Our Services

Other users may, for example, in a group challenge, access your in-game activities in the process of such group challenge. Other users may also see your displayed data and read the messages you have posted on or through our services. You acknowledge and agree that our services may also include message boards, communities, forums, and/or other chat areas, where users may exchange ideas or communicate with other users, and that any data you post to any communication area is publicly viewable. We strongly recommend that all users avoid posting personal or sensitive data at any time on or through our services.

(2) Competent Authorities

We may provide a certain portion of your personal data to judicial or administrative authorities as so requested. Besides, we may disclose certain portion of your personal data within a strictly limited scope of recipients when we reasonably think it is necessary to protect us, our users or a portion of the public.

In addition to be required by applicable laws, we reserve the right to disclose your personal data in the cases if we, in our good faith, believe that disclosing such data is necessary to identify, contact, or bring legal action against you, if (a) you are violating any other agreement(s) between you and us, such as the Terms of Service, this Privacy Policy or otherwise damage us; (b) you are infringing third-parties’ rights and interests (including but not limited to intellectual property rights); and/or (c) we believe that it is necessary to prevent fraud or other illegal activities.

(3) Third-Party Contractors

Swift works with a number of (if any) third parties on or through our services to help us provide services and functionalities to you. We do not sell your personal data and only share data that is non-personally identifiable on its own, aggregated, or public with third parties under the following necessary circumstances, and such third-parties thereof are prevented from processing (including but not limited to accessing, storing, using, or disclosing) your personal data except for achieving the purpose of their cooperation with us:

i. Social networking portals who provide login and/or content-sharing service to and in our services;

ii. Logistics service providers who provide shipping services such as delivering physical prizes to users;

iii. Information communication service providers who provide SMS-messaging services;

iv. Payment service providers who provide payment services, such as assisting our services to run on, facilitating users’ payment, and maintaining a record of the users’ transaction history;

v. Advertising service contractors who provide marketing and advertising activities, including conducting the programs, tracking the success, and analyzing the effect thereof; and

vi. Other contractors if any for the purpose of providing our services to you.

Besides, such contractors may use cookies, web beacons, and/or other tracking technologies to collect or receive data about you and might claim the data controller rights over your personal data. For example, users purchasing and/or subscribing products or services will be required to provide additional data to third-party payment contractors, such as a valid credit card number and expiration date. Such third-party payment contractors may collect, process and retain your data to process payments and resolve subsequent payment disputes and inquiries. We may also receive, process and store the provided information from you and/or such third-party payment contractors to confirm payment, record purchase history and/or protect our legitimate interest when resolving subsequent payment disputes and inquiries. Each third-party has its own privacy policy and security measures for processing data and information, so when specific third parties are involved in collecting data and information, please participate in their privacy policies. Since those contractors may access, collect, or process your data as the data controller and operate under their own privacy policies, please refer directly to their privacy policies on their official websites and learn more about their data processing practices.

6. Data Retention

We will keep your data only for as long as your account is active or only for as needed to provide you the game services unless deleted in accordance with your request or as otherwise required by law.

You acknowledge and agree that your data will be processed on our servers which may not be located in your country of residence and can be accessed by our support, engineering and/or our affiliates around the world. No matter where our servers are located, we will make great efforts to take the appropriate safeguards to guarantee your rights in conformity with this Privacy Policy and any applicable laws.

In the case you request to remove or delete your personal data, we will retain your data as long as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and/or enforce the agreements between you and us. Please note that the removal or deletion of any of your data may result in the termination of some of our applicable services.

We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or where the applicable law provides for longer storage and retention period. Upon the expiration of such period, your personal data will be deleted, blocked or anonymized, as provided by applicable law.

7. Your Rights

(1) Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to access your personal data that we hold about you, i.e. the right to require free of charge, (i) information whether your personal data is collected, used, disclosed, or sold, (ii) categories of your personal data which has been collected, (iii) categories of sources from which your personal data is collected, (iv) business or commercial purpose for collecting or selling your personal data (if any), (v) disclosure of sale of your personal data (if any): i.e. the categories of your personal data which has been disclosed or sold (if any) to third parties, the categories of third parties to whom your personal data was disclosed or sold (if any), statement regarding whether we have actual knowledge that we sell your personal data if you are under 16 years of age; and you have the right to require us to provide a duplicate of your personal data undergoing processing, subject to submitting a verifiable request in the form of email to our DPO’s email address as agreed in Article 10. You can also exercise the right to access your personal data through the privacy dashboard. According to our reasonable and unilateral judgement, if your verifiable request affects or will affect the rights or freedom of other users or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs arising therefrom) or refuse to act on the request.

(2) Right to Rectify

If we process your personal data, we shall endeavor to ensure by implementing suitable measures that your personal data is accurate and up to date for the purposes for which it was collected. If your personal data is inaccurate or incomplete, you have the right to obtain rectification of your inaccurate personal data without undue delay according to Article 16 of the GDPR and you can modify the information you provided via the privacy dashboard.

(3) Right to Request Deletion of Personal Information

You have the right to obtain deletion of your personal data, if the reason as stated in Article 2 of this Privacy Policy does not exist anymore, or if there is another legal ground for its deletion, subject to submitting a verifiable request in the form of sending an email to our DPO’s email address as agreed in Article 10.

You acknowledge and agree that as a result of deleting your Game Account, you will lose access to game related services, including the account information, subscriptions and game-related information linked to such Game Account and lose the possibility to access other services through the Game Account.

(4) Right to Object

When our processing of your personal data is based on legitimate interests according to Article 6(1)(f) of the GDPR and/or Article 2 of this Privacy Policy or any other applicable laws in your country of residence, you have the right to object to our processing. If you object, we will no longer process your personal data unless there are compelling and prevailing legitimate grounds of processing as described in Article 21 of the GDPR or any other applicable laws in your country of residence; in particular, if the data is necessary for the establishment, exercise or defense of legal claims. You also have the right to lodge a complaint at a supervisory authority.

(5) Right to Restrict Processing

You have the right to restrict the processing of your personal data under the conditions set out in Article 18 of the GDPR or any other applicable laws in your country of residence.

(6) Right to Personal Data Portability

You have the right to receive your personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller under the conditions set out in Article 20 of the GDPR or any other applicable laws in your country of residence.

(7) Right to Opt-Out of the Sale of Personal Information (if any)

You have the right to opt-out of the sale of your personal data (if any) and require us to make a statement regarding whether or not we sell your personal data and provide an opt-out mechanism or link to it except as otherwise stipulated in the CCPA.

(8) Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

You have the right not to receive discriminatory treatment by us for the privacy rights conferred by the CCPA, namely that we shall not offer a financial incentive or a price or service difference due to your exercise of any of your rights under the CCPA unless such difference is reasonably related to the value of your personal data. Notwithstanding the foregoing, we have the right to deny your request to know, request to delete, or request to opt-out for reasons permitted by the CCPA or those regulations thereof, and such denial shall not be considered discriminatory.

(9) Right to Authorize an Agent to Make a Request on Your Behalf

You have the right to authorize an agent on your behalf to make a request to know, delete, or opt-out under the CCPA. When you use an authorized agent to submit any request provided above, we may require you to provide signed permission to authorize your agent to do so for the purpose of verifying your own identity, and the official permission by your agent to submit this request. In the case of failure to provide any of the requested materials, to protect the user’s information and data security, we are entitled to denying such request. Notwithstanding the foregoing, if the applicable laws in your country of residence provide otherwise, the corresponding laws shall govern.

8. Securing Your Data

Pertaining to your use of our services, we have endeavored to take reasonable measures to prevent unauthorized access to or improper use of your personal data, such as organizational controls, technical protection, and other protection measures.

Unfortunately, the transmission of information via the internet is not completely secure. While we strive to protect your personal data, we also remind you to be aware of hacking, cyber-attacks, and other risks on the Internet.

Therefore, we strongly urge you to take every possible precaution to protect your personal data when using our services, including but not limited to changing your passwords from time to time, not reflecting your real name or other personal data in registration, using a combination of letters and numbers when creating passwords, using a secure browser and/or taking other possible security measures. Please note that for security reasons, we store passwords in encrypted form.

Please be aware that advertisers or websites with links to and/or from our websites may collect personal data about you and this Privacy Policy does not apply to, and cannot control the activities of, those other advertisers or websites. We highly recommend that you read the privacy policy of such third-party websites which you may be directed to before providing any personal data.

9. Age Limits and Children Protection

You represent that you are an adult or older in your country of residence (or at other age in your jurisdiction where you are classified as a majority) when using our services. If you are a minor child or under the legal age of majority ("Minor" or "Child"), please do not send any personal data about yourself to us, including your name, address, telephone number, or email address.

Notwithstanding the foregoing, we recognize that we have a special obligation to protect children in regard to the collection and processing of personal data, and we do not and will not knowingly collect personal data from children without consent from their parents or guardians. We strongly urge parents and guardians to instruct their children never to disclose or give out their personal data when using our services without the prior permission of their parent/guardian. If we learn that we have collected personal data about a child, we will delete that data as quickly as possible. Also, if you believe that we might have any data from or about a child, please contact us at our DPO’s email.

10. Contact and Complaints

For the purpose of establishing the personal data protection in a better and more efficient way, we, as the Data Controller, designate a Data Protection Officer (in short, "DPO") who is responsible for the oversight and implementation of the personal data protection strategy and ensures our processing of personal data in compliance with necessary legal requirements stipulated in the applicable laws. If you have any questions about this Privacy Policy or have any requests for resolving issues with your personal data while using our services, please contact us as soon as possible by emailing our DPO at zyoperation.01@gmail.com


Swift Games Limited.

Last Updated: June 30, 2022

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