Privacy Policy
Privacy Policy
This policy will help you understand the following:
1.What information do we collect about you?
2.How do we use your information?
3.Legal basis for processing;
4.Sharing your information;
5.Your rights to manage your personal information;
6.How to contact us.
This Player Privacy Policy (hereinafter referred to as "this Policy") applies to personal data we hold about players ("you" or "your"). This Policy is drafted in English and will be translated into other languages. In case of any conflict or inconsistency requiring clarification, the English version of this Policy shall prevail.
This Policy applies where we act as a "data controller" under data protection regulations: this essentially means we are responsible for deciding what personal data is collected and how it is used. We may also operate as a "data processor", i.e., processing personal data on behalf of another entity (e.g., the publisher of one of our games). When we refer to "personal data" in this Policy, we mean "personal" information relating to or capable of identifying you. Certain information mentioned in this Policy may not constitute "personal data" under data protection regulations, but we mention it to help you understand our practices.
We are committed to protecting and respecting the personal data of every individual we come into contact with – it is important to us, and we know it is important to you too.
In this Policy, you will learn what types of personal data we hold about you, how and why we collect it, how we use it, and how we keep it secure. You will also learn about your rights and how to exercise them.
If you are under 18 years old, you must review this Policy with your parent or guardian, who must agree to these terms on your behalf and assume full responsibility for your compliance.
Please read this Policy carefully. If you need to contact us regarding any content in this Policy or any other matter related to your personal data, you can reach us via email atContact@ kithmatt.com.
You will learn the following information in this Policy:
1. What information do we collect about you?
We will collect some information about you. The types of personal data we collect about you depend on how you use our Services. Generally, we collect the following information:
A. Personal data you provide directly to us:
- Your contact information, such as email address;
- Your player username and password;
- Data you provide to us for account verification;
- Other data you choose to provide to us, such as data for identifying lost or invalid accounts, or answers to special questions we may ask you to allow unlocking or recovering lost or invalid accounts;
- Information about your purchases and payments (in addition, your payment details are collected specifically by our payment service provider when you make any purchase through our web store);
- Personal data you provide when participating in surveys, promotions, lotteries, contests, events, and other happenings; and other personal data potentially collected based on your explicit consent or our specific legitimate business interests.
B. Personal data we collect automatically when you use our Services:
- Your game profile, including your avatar picture and any information required for game operation, such as in-game item inventory;
- Your game user account or character ID – a specific ID generated for you by our game servers;
- Analytics ID – a randomly generated anonymous identifier used to distinguish the activities of different game accounts in our analytics data;
- Your Internet Protocol (IP) address and mobile device identifiers (e.g., your Device ID, Advertising ID, MAC address, IMEI);
- Data used to combat fraudulent activities (e.g., refund abuse in games or click fraud in advertising);Usage data, including information about how you use our websites, products, and services, and your game progress;
- Data about your device, such as device name and operating system, browser type and language; and Marketing and communications data, including your preferences for receiving marketing messages from us and third parties, and your communication preferences. You have full autonomy and discretion to adjust settings on your device to turn off relevant features.
2. How do we use your information
- To send you communications related to our Services and games, respond to your inquiries, or handle your complaints;
- To provide, manage, and customize our Services, including our games;
- To enable you to purchase virtual items and complete related payment transactions;
- For account verification and write-offs;
- For technical and usage information/analytics to help us develop games players want to play and make improvements, and to detect cheating and activities that disrupt the player experience, security risks, fraud, and other illegal activities;
3. Legal basis for processing
There are several different legal bases for processing personal data. Which one applies depends on how and for what purpose we use your information. In most cases, the basis will be one of the following:
- You have consented to our use of your personal data in that way (e.g., you consented to us sending you marketing communications about our products and services);
- Our use of your personal data is necessary for the legitimate interests of operating as a commercial organization, provided such use is always proportionate and respects your privacy rights;
- Our use of your personal data is necessary for the performance of a contract with you or to take steps at your request to enter into a contract (e.g., managing your account);
- Our use of your personal data is necessary to comply with relevant legal or regulatory obligations.
We generally do not collect or process any "special categories" of personal data (including information about your health, religious or political beliefs, racial background, sex life, and sexual orientation). If it is indeed involved, unless there is a legal requirement or other legitimate reason for processing such information, we will typically rely on obtaining your additional specific consent at the time of collection.
4. Sharing your information
To achieve the purposes described in this Policy, including providing services to you or responding to your inquiries, we may share the personal data you provide to us with third-party companies, agents, contractors, service providers, or our affiliated companies. This may include:
- Our business partners and vendors;
- Payment service providers. For the purpose of enabling payments on our web store, your payment data may be transmitted to our cooperating payment service providers. For more information on how payment service providers handle your personal data, please read their privacy policies;
- Sub-processors who store or process information on our behalf, particularly data analytics providers and data storage providers. Information shared with such providers is provided in an anonymized format, making the data incapable of being associated with any specific individual, and therefore is not considered "personal data";
- Our auditors, insurers, lawyers, and other professional advisors;
- Provision to law enforcement agencies, other government agencies, or third parties if we are legally required to do so;
- Provision to another business entity if we plan to merge with or be acquired by that entity, or if we undergo a restructuring with that entity.
5. Your rights to manage your personal information
We understand your concerns about personal information and strive to ensure your rights to access, correct, delete, and withdraw authorization for your personal information, empowering you to fully protect your privacy and security. Your rights include:
5.1 You have the right to access your personal information
You can review the relevant personal information you have provided to us according to the relevant instructions (or settings) of our provided products and services. This includes: avatar, nickname, player number, alliance basic information, personal signature, leaderboards, etc. (if any). If you encounter issues during access and need to obtain other personal information content not available through the aforementioned means, you can contact us using the methods provided in this Privacy Policy.
5.2 You have the right to correct/modify your personal information
When you discover that the personal information you provided to us contains registration errors, is incomplete, or needs updating, you can correct/modify your personal information within our products and/or services.
- For some of your personal information, we provide operational settings on the relevant function pages of our products, allowing you to make corrections/modifications directly. For example, the path to correct/modify "avatar/nickname" in the game client is: Click avatar -> Click edit button/corresponding area of the content to be modified.
- For difficulties you encounter in exercising the above rights, or for other information for which online self-correction/modification services are currently unavailable, subject to verification of your identity and provided the correction/modification does not affect the objectivity and accuracy of the information, you have the right to correct or modify erroneous or incomplete information. In specific circumstances, especially in case of data errors, you can submit a request through our published feedback, error reporting, or customer service contact methods, requiring us to correct or modify your data, unless otherwise stipulated by laws and regulations. For security and identification reasons, you may not be able to modify certain initial registration information submitted during registration.
5.3 You have the right to delete your personal information
When the following situations occur, you can directly request us to delete your personal information, unless it has been anonymized or otherwise stipulated by laws and regulations:
- When our processing of personal information violates laws and regulations;
- When we collect or use your personal information without obtaining your consent;
- When our processing of personal information violates our agreement with you;
- When you delete your game account;
- When we terminate service and operations.
If we decide to comply with your deletion request, we will also simultaneously notify entities that have obtained your personal information from us, requiring them to delete it promptly, unless otherwise stipulated by laws and regulations or these entities have obtained your independent authorization. When information is deleted from our services, we may not immediately delete the corresponding information in backup systems, but will delete such information when backups are updated.
5.4 You have the right to withdraw all or part of your authorization for personal information
As mentioned earlier, some functions of our provided products and services require obtaining relevant permissions on your device (including: camera, microphone, etc., specific details subject to Article 1 of this Privacy Policy). You can withdraw (or stop) the continued authorization for these permissions at any time after granting them. When you update the App version, we will not change the permission status you previously set without your explicit consent. You can also permanently withdraw our continued authorization to collect all your personal information by deleting your account. You need to understand that after you withdraw authorization, we will be unable to continue providing you with the specific functions and/or services corresponding to the withdrawn authorization, but this decision will not affect previous personal information processing conducted based on your authorization.
5.5 You have the right to delete your account
You can apply to delete your account through customer service or other methods we announce. After account deletion, you will no longer be able to log in and use our products and services with that account; all rights and interests generated but not exhausted during the use of all products and services with that account, as well as all future lapsed interests, will be cleared; content, information, data, records, etc., under that account will be deleted or anonymized (unless otherwise required by laws and regulations or regulatory authorities, e.g., according to the "Cybersecurity Law of the People's Republic of China", network operation logs must be retained for at least six months). Game account deletion cannot be reversed once completed. For more details on the process and conditions for account deletion, please contact customer service.
6. Contact Information
Questions, comments, and requests regarding this policy are welcomed. Please contact us via email: Contact@kithmatt.com.