Welcome to 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 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, our contact information can be found here. You can also reach out to our data protection officer at dpo_guandan@proximabeta.com.

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.

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.

2. How We Process Your Personal Information

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

Personal Information	Use
Information you provide to us (either directly or through a third party)
Login data: If you choose to login with QQ: User ID, device operating system information, SSID/BSSID, device model information (e.g. iPhone 15), QQ number, profile picture, nickname and whether QQ is installed on your device’s operating system If you choose to 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)	We use this information to: create your account for the Service; and enable you to login either using your QQ or WeChat login.
Sharing data: If you choose to share via QQ: Clipboard information (i.e. what is copied/pasted on the device), photos you choose to share and memory card permissions 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 the social media platform you logged in with.
Information generated or processed by us as part of the Service
Customer support data: Identity information: User ID 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 Open 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.
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.
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	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.
Game data: Identity information: User ID Device information: CPU usage rate, WiFi SSID, CPU model, GPU information, device system version, WIFI address, UUID (Android phones) >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, dating information, etc)	We use this information to enable you to use the Service, and to ensure the smooth running of 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 detect and combat fraud or suspicious transactions on the 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 the Peope’s Republic of China (“PRC”). We also have support, engineering and other teams who may support the Service, including in the PRC.

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 (QQ and WeChat) if you choose to login to the Service via such platforms and third parties that are responsible for crash reporting. 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 Sharing data Bug reporting data Performance and analytics data Game data Transaction data	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

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.

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

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.