Privacy Notice of Sunborn Game

Privacy Notice of Sunborn Game

Effective Date: 2024/05

Darkwinter Software Limited (registered address: Building 10, No. 860, RM602, 6/F, GOLDEN GATE COMMERCIAL BLDG, 136-138 AUSTIN ROAD, TSIMSHATSUI, HONG KONG, hereinafter referred to as “we”, “us” or “Sunborn Game”) is well aware of the importance of privacy and committed to respecting and protecting your privacy. This Privacy Notice describes how we collect, use, disclose, transfer, store and otherwise process your personal data when you are using our US website, game apps or services (hereinafter collectively referred to as "Services"). Please read the Privacy Notice carefully and familiarize yourself with our privacy practices before using our Services or providing your personal data.

For information about our information practices regarding children, please see Section “VIII. How We Process Children's Personal Data” below.

To print this Privacy Notice, please click here.

This Privacy Notice will help you understand the following:

A. General Provisions

I. How We Collect and Use of Your Personal Data

II. How We Use Cookies and Similar Technologies

III. How We Disclose Your Personal Data

IV. How Your Personal Data Is Transferred Globally

V. How Long We Keep Your Personal Data

VI. How We Protect Your Personal Data

VII. Your Rights Regarding Your Personal Data

VIII. How We Process Children's Personal Data

IX. Third-Party Websites

X. How This Privacy Notice Is Updated

XI. Third-Party SDK List

B. United States Specific Provisions

I. Additional Information on What and How Your Personal Data Is Processed

II. Additional Information on Your Rights Regarding Your Personal Data

III. Additional information for the “consumers” in California

IV. Further Information for United States Users

C. Contact Us

In addition to this Privacy Notice, specific privacy notices might apply depending on the Services used. We will, in each case, provide you with the applicable privacy notice.

The general provisions of Section A shall apply to you, regardless of your location (excluding the mainland of China). If you are a user in the mainland of China, please refer to the China-specific privacy policy of Sunborn Game.

A. General Provisions

I. How We Collect and Use Your Personal Data

Personal data refers to any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. The personal data we collect about you depends on the environment in which you interact with us and the choices you make, including your privacy settings and the features and Services you use.

You may provide personal data to us directly, in which case you are generally free to choose which personal data you want to provide to us. However, if some personal data is required for the performance of our Services and you choose not to provide that personal data, we may not be able to provide you with the Services you requested.

We will collect and process your personal data according to the following methods and purposes, so as to provide you with, improve our Services and protect your account security.

1. Registration and login services. To assist you in registering and logging in our Services, you are required to provide us with your email address. If you choose not to provide such information, you may not be able to use our Services. You can also choose to use your third-party social accounts (e.g., Facebook, Google, Apple ID, Game Center) to login our Services.

2. Maintenance of basic functions and account security. In order to provide you with the basic function of our Services, to ensure the security of your game account and create a fair, healthy and safe game environment, we need to obtain your permission to read/write the external storage of your devices (for example, if you use Android devices, which include reading permission to external storage, reading/writing permission to SD card content, and modifying/deleting permission to SD card content), and collect device and software information such as your user ID, device ID, device name, device type, device model and version, system version, IP address, device unique identifier (IMEI and Android ID for Android devices, IDFA for iOS devices), network type, and MAC address, etc.

3. Logs and application information of game. When you play our online games, we will also collect your game log information such as login log, item log, game match information, friends record, game identification information, hardware and operating system information, application list, progress and game crash record, etc. If you refuse to provide the aforesaid information, you may not be able to use the basic functions and services of our related products.

4. Transaction information. In order to provide you with transaction services, we will collect recharge records, consumption records, payment records (including Google payment and iOS payment records) and other necessary information related to transactions so that you can check your transaction records and protect the security of your virtual property to the greatest extent possible. Your consumption records, payment records and other necessary information related to transactions may be sensitive personal data. The collection of the above information is necessary to realize the consumption function of our Services, otherwise the transaction cannot be completed, but it does not affect your normal use of our Services with basic functions.

5. Interactive game information. In order to purify the game environment and maintain a healthy online environment, we will collect the text, picture, voice and video information you send in the game to filter inappropriate content such as pornography, violence, politically incorrect content, abuse and malicious advertisements, etc. If you wish to interact with other players through pictures, voice or video (if applicable to game functions), after obtaining your authorization and consent, we will obtain the permission of photos or files storage, microphone or camera to provide you with the functions such as screenshot saving, picture uploading and voice chatting. If you refuse to provide the aforementioned permission, you may not be able to use such functions, but your normal use of the basic functions will not be affected. You can also disable the preceding permissions in privacy settings at any time. Unless you voluntarily upload pictures, recordings and other information, we will not collect such information from your device.

6. Customer service information. In response to your request for customer service, we will collect data generated during your request for customer support.

7. Additional service. To provide you with additional functions/services besides other basic services and functions, including gifts, prizes, birthday wishes, questionnaire survey, etc., subject to your consent, we may collect your personal data, including such as date of birth, address, email, nickname and profile image. If you disagree to provide the above information, the additional functions will not be realized or the results we expect will not be achieved, but your normal use of basic functions will not be affected.

You understand and agree that the functions and services we provide to you are constantly updated and developed, if a new function or service is not mentioned in the foregoing statement but processes your personal data, we will inform you of the updated content of data processing activity, and we may also use your personal data for other purposes not incompatible with the disclosed purposes (such as archiving in the public interest, scientific or historical research, or statistical purposes) if permitted by applicable data protection laws, or we may get your additional consent for those purposes at that time.

You understand and agree that some of our Services may require you to enable specific permission on your device for the collection and use of your personal data. While the fact that we obtain a specific permission does not necessarily mean that we will collect your relevant personal data. Even if we have obtained such permission, we will only collect your personal data when necessary and in accordance with the Privacy Notice. You can disable any permissions at any time on the device. Please however note that once you close any permission, it means you have cancelled your authorization and we will no longer collect and use relevant data based on the corresponding permission, nor will we be able to provide you with the corresponding services. However, your decision to close your permission does not affect the collection and use of your personal data previously obtained under your authorization.

II. How We Use Cookies and Similar Technologies

1. Cookies are small text files stored on browsers, computers or mobile devices by websites you visit. They allow websites to recognize your device. The content of cookies can only be retrieved or read by the server that created the cookies. Each cookie is unique to your browser or mobile application. Cookies usually contain identifiers, common information and other details.

2. Cookies and similar technologies are usually used for remembering your identity, analyzing your use of services, advertising optimization and other commercial, market analysis or academic purposes. These cookies and similar technologies may collect non-personally identifiable information related to you, which may be used to analyze how you use these services, send you advertisements that may be of interest to you, or evaluate the effectiveness of advertising services.

3. We do not use cookies on our US website and other Services, but we use third-party analytics tools on our Services and the third-party analytics tools may use cookies to collect, store and track relevant data of users at certain time. See below details about the analytics tools we use on our Services. The collection and use of such data by third-party cookies and similar technologies is not bound by this Privacy Notice, but by its own personal data protection statement, and we will not take any responsibility for the third-party cookies and similar technologies or the third-party collection or use of any of your information.

4. Cookies are not the only way to recognize or track visitors or a game player. We may use other similar technologies from time to time, like SDKs, we may use SDKs to recognize you when you log in our Game or for advertising statistics, or risk control purposes. For more detail, please see XI. Third-Party SDK List.

5. We use local storage technologies, including SharedPreferences (for Android device) and NSUserDefault (for iOS device), on our US website to store user information and user login token.

6. We also use analytics tools on our game apps include the following:

• AppsFlyer Analytics: We use AppsFlyer’s attribution and marketing analytics services that enable us to measure and analyze the effectiveness of our marketing campaigns and certain events and actions within our game apps and to detect and prevent fraudulent activities. Please note AppsFlyer Analytics can access to end users’ information including but not limited to device information (e.g., bundle ID, advertising identifier), network information (e.g., IP address, time zone, network connection type) and payment information (e.g., payment item ID, payment item name, amount, payment currency, order number). For more information about AppsFlyer Analytics and how it collects and processes information, and how to opt out of AppsFlyer Analytics, please visit: https://www.appsflyer.com/legal/services-privacy-policy/.

• Facebook: We also use Facebook to optimize the advertisement delivery, track device behavior and enable login functionality. Please note Facebook can access to your device information, in-game data such as device identifier (e.g., IDFA), device attributes (e.g., device model), network information and connection (e.g., time zone, IP address), payment information (e.g., payment item ID, payment item name, amount, payment currency, order number) and device operations, in accordance with Facebook’s data policy which can be found at https://www.facebook.com/privacy/policy/.

• Google Firebase: We also use Google Firebase to optimize the advertisement delivery, track device behavior and detect and prevent fraudulent activities. Please note Google Firebase can access to end users’ information including but not limited to device information (e.g., bundle ID, advertising identifier), network information (e.g., IP address, time zone, network connection type) and payment information (e.g., payment item ID, payment item name, amount, payment currency, order number), in accordance with Google Firebase’s privacy policy which can be found at https://firebase.google.com/support/privacy.

• MTP: We also use MTP to detect and prevent fraudulent activities such as cheating, hacking and cracking. Please note MTP for such purposes will collect end users’ information including but not limited to Android device application installation list, internet access, current network environment, WIFI environment, device information (e.g., device model), and read/write storage. For more information on how MTP collects and processes information, please refer to: https://privacy.qq.com/policy/tencent-privacypolicy.

• Tencent Bugly: We also use Tencent Bugly’s services to discover and solve App crashing problems in time and improve App stability. Please note Tencent Bugly for such purposes will collect end users’ information including but not limited to internet access, current network environment, WIFI environment, device information (e.g., device model), and read/write storage. For more information on how Tencent Bugly collects and processes information, please refer to: https://privacy.qq.com/document/preview/fc748b3d96224fdb825ea79e132c1a56.

III. How We Disclose Your Personal Data

At times Sunborn Game may make certain personal data available to other companies that are wholly or jointly controlled by us (hereinafter as "Affiliates") and other third parties that work with Sunborn Game in order to provide Services to you. Your personal data will not be shared with third parties for their own independent marketing purposes.

• Affiliates: Your personal data may be shared with Sunborn Game's Affiliates for the purpose of rendering our Services to you. If Affiliates wish to process your personal data for a different purpose, they must first seek your consent, unless another lawful basis exists.

• Service Providers and Partners: Some of our Services will be provided with the assistance of third parties. We sometimes use third parties to control the collection of your personal data. We may also share some personal data with our partners in particular so as to deliver you a better service and improve your user experience. For example, we may share your user ID with the social media platforms and other parties we partner with (e.g., Apple) when you choose to use social accounts to log into the Services or use Apple Pay on the Services.

• Purchasers and third parties in connection with a business transaction: Where a merger, acquisition, bankruptcy liquidation or similar action takes place, we may transfer or disclose your personal data following completion of such transaction and/or during the assessment process pending transfer. If transferred in such a case, your information would remain subject to this Privacy Notice or a privacy policy that, at a minimum, protects your privacy to an equal degree as this Privacy Notice.

• Law enforcement, regulators and other parties for legal reasons: We may disclose your personal data to third parties as required by law, or if we reasonably believe that such action is necessary (a) to comply with a subpoena or other legal proceedings, legal actions or government agency requests; (b) when we believe in good faith that a disclosure is necessary to comply with the law and the reasonable requests of law enforcement; (c) to protect and exercise our legal claims, rights and property; (d) to protect your rights, property or personal safety or that of others; (e) to investigate fraud and (f) to protect the security or integrity of our Services.

• The public, when posted in certain public spaces: Some of our Services allow you to connect and interact with others. Your profile information or information that you post in a public space, including personal data, will be accessible to other users or the general public by default when you create it. Such content will be accessible by the general public or the members of the Services depending on the Services used.

Without your consent, we will not disclose your personal data to other third parties other than the above mentioned.

IV. How Your Personal Data Is Transferred Globally

Sunborn Game is a global business and our Services are spread around the world. As a result, we collect and transfer personal data on a global basis. That means that we may transfer your personal data to locations outside of your country. For more information, please contact us using the details set out in “Contact Us” section.

Please note that different countries or regions offer different levels of data protection. This means that your personal data could be stored in a country that offers a level of protection that may, in certain instances, be less protective of your personal data than the country or region in which you are located. However, in such cases, we will take measures to ensure that the personal data we collect is processed in accordance with this Privacy Notice and applicable laws, and that your personal data is adequately protected. For example, we might ask your permission to transfer your personal data across borders, and we will implement adequate security measures and sign the necessary data transmission/sharing agreements with the recipients of your personal data prior to the transfer taking place. We will also specifically ensure that we comply with laws that require us to store data locally within a specific country or region. Specifically, this Game’s servers are located in the US, and our group locations and third-party service providers and partners operate around the world. This means that when we collect your Personal data, we may process it in any of these countries. In this case, we will take appropriate organizational and technical measures to ensure that your personal data is properly protected.

V. How Long We Keep Your Personal Data

We will only store your personal data for as long as necessary to achieve the collection purposes set out in this Privacy Notice, unless we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested, to perform a contract with you or to comply with applicable legal, tax or accounting requirements.

After the expiry of the retention periods, we will delete or anonymize your personal data, if this is technically not possible (for example, because your personal data has been stored in backup archives), then we will securely store your Personal data and isolate it from any further processing until deletion is possible.

VI. How We Protect Your Personal Data

We will adopt safety protection measures in line with industry standards, including establishing reasonable system standards and security technologies to prevent your personal data from being accessed, used or modified without authorization, and to avoid data leakage or loss.

The Internet is not an absolutely safe environment. We recommend that you use complex passwords and pay attention to protecting your information security. Please take good care of your account number, password and other identity elements. When you use our Services, we will identify you by your account number, password and other identity elements. Once you disclose the above information, you may suffer losses that may be detrimental to you. If you find that your account number, password and/or other identity information may or have been leaked, please contact us immediately so that we can take corresponding measures in time to avoid or reduce related losses.

When communicating with a third party or purchasing goods and services through our Service, you will inevitably disclose your own information, such as contact information or email address, to the counterparty or potential counterparty. Please protect your information properly and provide it to others only when necessary.

The Internet environment is not one hundred percent secure, and we will try our best to protect the security of any information you send to us. Please understand that due to technical limitations and risk prevention limitations, even though we have tried our best to strengthen security measures, we can't always guarantee one hundred percent information security. You need to know that the system and communication network you use to access our Service may have problems due to circumstances beyond our control. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk. If we learn of a security system breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using the services or providing personal data to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the services. We may post a notice via our Service if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

VII. Your Rights Regarding Your Personal Data

Data protection laws may give you a number of legal rights in relation to the personal data that we hold about you. Not all data protection laws are the same so not all of these rights apply in all places. Also, some of these rights are subject to qualifications and limitations and exercising these rights may impact on the Services that we can provide to you. However, we will take appropriate technical measures to enable you to control how we use your personal data where we can do that.

Subject to the data protection laws in your country, your rights may include:

1. The right to be informed: Sunborn Game provides this Privacy Notice to keep you informed about how your personal data is handled, the purposes for processing it, the categories of personal data collected, the recipients of this data, and the duration for which the data will be stored.

2. The right to access: If you wish to access your personal data, some of our Services provide an interface through which you may directly search for or access certain personal data. You may also request access to the personal data we hold about you by contacting us using the "Contact Us" section.

3. The right to rectification: If you find that the personal data we process about you is inaccurate or incomplete, you are entitled to ask us to make rectifications without undue delay and request the completion of your personal data where appropriate.

4. The right to erase (Right to Be Forgotten): You have the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data, but we are legally entitled to retain it

5. The right of portability: In some circumstances, you have the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit this information to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;

6. The right to withdraw your consent: You have the right to withdraw your consent to our processing of your personal data. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so. For example, we may need to retain your personal data to comply with a legal obligation;

7. The right to object to or restrict processing: You have the right to object to, and the right to request that we restrict, our processing of your personal data in certain circumstances. Please note that there may be circumstances where, even if you object to or request restriction of our processing, we are legally entitled to continue processing your personal data.

8. The Right to Avoid Automated Decision-Making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except under certain circumstances (such as when you have given explicit consent or when necessary for the performance of a contract).

9. The Right to Non-Discrimination: Under CCPA, Sunborn Game will not discriminate against you for exercising any of your privacy rights. This means we will not deny you goods or services, charge you different prices, or provide a different level or quality of services unless such differences are reasonably related to the value of your personal data.

10. The right to lodge a complaint: You have the right to lodge a complaint with the supervisory authority if you think that any of your rights have been infringed by us.

11. The right to opt-out of targeted advertising: If you wish to not to receive targeted ads, you have the right to opt-out of targeted advertising at any time. You can also contact us by using the "Contact Us" section.

In addition to exercising your rights through user account as otherwise state above, you can exercise your rights by contacting us using the details set out in the “Contac Us” section.

You may have some additional data protection rights according to applicable data protection laws in different countries or regions, if you wish to make such a request of data protection rights, please contact us by using the contact details provided under the “Contact us” heading below. However, please note, for data security purposes, before responding to your request, we may ask you to verify your identity and provide further details about your request to ensure that you are the right person to access such data or request to have other data rights.

We respond to all requests we receive from individuals wishing to exercise their personal data protection rights in accordance with applicable data protection laws.

In principle, we do not charge a fee for responding to your reasonable request. However, for multiple and repetitive requests that exceed a reasonable limit, we may charge a reasonable fee to cover some of our costs, depending on the nature of the request. We are entitled to refuse requests in whole or in part, and we may refuse requests that are manifestly unfounded, unreasonably repetitive or that require disproportionate technical effort (for instance, requests that require the development of new systems). In addition, we may not respond to requests that directly concern significant issues of public interest or may cause serious damage to the legitimate rights and interests of you or other individuals or entities.

VIII. How We Process Children's Personal Data

1. Personal data we collect from children.

This Privacy Notice also applies to children’s personal data we collect from our Services, and for the purposes of this Privacy Notice, we consider a “child” to be any user who is of the age 16 or younger. We require parent or guardian consent for children’s use of our Services, as required by applicable law. We do not require children to disclose more information than is reasonably necessary to participate in our Services.

The following personal data is collected from children when they use our Services. We do not allow children to make their personal data publicly available. However, children are free to enter any information in their personal signature bar within the game app. We have taken reasonable measures to remind children not to enter any personal data in the personal signature bar but it cannot be excluded that children may still enter their personal data in the personal signature bar within the game app.

· Identifiers, which may include registration and login services, name, address, online identifier or username, Internet Protocol address, persistent identifiers, email address, telephone number, or account name. These are sourced directly or indirectly (e.g., from observing the child’s actions on the Services). They are used to fulfill or meet the reason the child provided the information, to contact the child in relation to our Services, to respond to an inquiry, for product and service improvement, or to process an order. We disclose this information for business purposes to Affiliates and service providers.

· Characteristics of protected classifications, such as gender, age, or nationality. We source this information directly from the child. We use this information to fulfill or meet the reason the child provided the information, or to provide relevant Services. We disclose this information for business purposes to Affiliates and service providers.

· Picture, voice, and video information. We source this information directly from the child. We use this information to personalize the Services content, or to provide relevant Services. We disclose this information for business purposes to Affiliates and service providers.

· Commercial information, which may include records of Services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. We source this information directly from the child. We use this information to fulfill or meet the reason the child provided the information, to contact the child in relation to our Services, and to respond to an inquiry or process an order. We disclose this information for business purposes to Affiliates and service providers.

· Internet or other similar network or device activity, which may include persistent identifiers, external storage of your devices, device ID, user ID, device type, device model and version, system version, network type, MAC address, usage and browsing history, including information such as persistent identifiers, IP address, cookie data, a processor or device serial number, or a unique device identifier that can be used to recognize a user over time and across different websites or online Services, error logs, error codes, and error descriptions, and other information provided relating to faults or defect experienced with use of our Services. We source this information directly or indirectly (e.g., from observing actions on our Services). We use this information to fulfill or meet the reason the child provided the information, or to improve our Services. We disclose this information for business purposes to Affiliates and service providers. Please also see the “II. How We Use Cookies and Similar Technologies” section.

· Inferences drawn from other personal data, which may include your game log information, item log, game match information, friends record, game identification information, application list, progress and game crash record, a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. We source this information indirectly (e.g., from observing actions on our Services). We use this information to fulfill or meet the reason the child provided the information. We disclose this information for business purposes to Affiliates and service providers.

2. Parent and guardian consent.

Consistent with the requirements of the U.S. Children’s Online Privacy Protection Act (“COPPA”) and to ensure that we act in accordance with other applicable laws, on any child-targeted site or application, or in any instance where we ask for age and determine the user is age 16 or under, we may ask for a parent or guardian email address before we collect any personal data from the child. If you believe your child is participating in an activity that collects personal data and you or another parent/guardian have NOT received an email providing notice or seeking your consent, please contact us through the contact methods provided in “Contact Us” section. We will not use parent emails provided for parental consent purposes to market to the parent, unless the parent has opted in or has separately participated in an activity that allows for such email contact.

In the event we discover we have collected information from a child in a manner inconsistent with COPPA’s requirements, we will either delete the information or immediately seek the parent’s consent for that collection.

3. Parent and guardian rights.

Parents or guardians are entitled to exercise any rights that their child may have in relation to their personal data. For example, at any time, parents or guardians may review their child’s personal data, direct us to delete their child’s personal data, and may refuse to allow any further collection or use of the child’s personal data (in all cases subject to the requirements and restrictions set out in applicable law). Please keep in mind that a request to delete records may lead to a termination of Services. Parents and guardians may also agree to the collection and use of their child’s personal data, but still not allow disclosure to third parties unless it’s part of the requested service. To exercise these rights, Parents/Guardians can contact us through the contact methods provided in “Contact Us” section to exercise their rights. All valid requests will be accommodated within a reasonable time. To protect children’s privacy and security, we will take reasonable steps to help verify a parent’s identity before granting access to any personal data.

4. Disclosure of children’s personal data.

We may share or disclose personal data collected from children only in a limited number of instances. We will not disclose the personal data collected from children to third parties unless one of the following applies:

· We may share personal data with our service providers if necessary for them to perform a business, professional, administrative, or technology support function for us.

· We may provide the personal data in case of sale of our business or assets or merger with another company, and we may disclose personal data to the prospective buyer for due diligence purposes and on completion of the assignment, sale, or merger. If transferred in such a case, the purchaser will abide by the terms and conditions of this Privacy Notice.

We may disclose personal data if permitted or required by law, for example, in response to a court order or a subpoena. To the extent permitted by applicable law, we also may disclose personal data collected from children (i) in response to a law enforcement or public agency’s (including children services) request; (ii) if we believe disclosure may prevent the instigation of a crime, facilitate an investigation related to public safety or protect the safety of a child using our Services; (iii) to protect the security or integrity of our Services and other technology, as well as the technology of our service providers; or (iv) enable us to take precautions against liability.

IX. Third-Party Websites

1. Sunborn Game Services may contain links to third-party websites, products and services. You can choose whether to access websites or accept products and services provided by third parties or not.

2. We do not control third-party privacy and data protection policies and do not accept any responsibility or liability for such policies. At the same time, such third parties are not bound by this Privacy Notice. Therefore, before submitting personal data to third parties, we strongly recommend that you refer to the privacy protection practices of such third parties.

X. How This Privacy Notice Is Updated

We reserve the right to update or modify this Privacy Notice from time to time. We will, as appropriate, send you notifications of material updates to this Privacy Notice in a form we deem appropriate and we will update the "last updated" date at the start of this Privacy Notice.

XI. Third-Party SDK List

Third-Party SDK’s Name	Functions	Possible Permissions/Information Obtained	Privacy Policy
AppsFlyer Analytics	to measure and analyze the effectiveness of our marketing campaigns and certain events and actions within our game apps and to detect and prevent fraudulent activities	device information (e.g., bundle ID, advertising identifier), network information (e.g., IP address, time zone, network connection type) and payment information (e.g., payment item ID, payment item name, amount, payment currency, order number)	https://www.appsflyer.com/legal/services-privacy-policy/
Facebook	to optimize the advertisement delivery, track device behavior and enable login functionality	device identifier (e.g., IDFA), device attributes (e.g., device model), network information and connection (e.g., time zone, IP address), payment information (e.g., payment item ID, payment item name, amount, payment currency, order number) and device operations	https://www.facebook.com/privacy/policy/
Google Firebase	to optimize the advertisement delivery, track device behavior and detect and prevent fraudulent activities	device information (e.g., bundle ID, advertising identifier), network information (e.g., IP address, time zone, network connection type) and payment information (e.g., payment item ID, payment item name, amount, payment currency, order number)	https://firebase.google.com/support/privacy
MTP	to detect and prevent fraudulent activities such as cheating, hacking and cracking	Android device application installation list, internet access, current network environment, WIFI environment, device information (e.g., device model), and read/write storage	https://www.tencentcloud.com/document/product/1018/36786
Tencent Bugly	to discover and solve App crashing problems in time and improve App stability	internet access, current network environment, WIFI environment, device information (e.g., device model), and read/write storage	https://privacy.qq.com/document/preview/fc748b3d96224fdb825ea79e132c1a56

B．United States Specific Provisions

Notice at Collection. We may collect or process various categories of personal data. The section directly below titled “Additional Information on What and How Your Personal Data Is Processed” contains information on the categories of personal data collected and/or whether we sell or share the personal data. The section titled “Third Party Collection” contains information about third parties that control the collection of personal data on our behalf.

If you have a request regarding your information and would like to exercise your rights under applicable law, please contact us through the methods provided in the “Contact Us” section below. To exercise your right to ask that we do not sell, share, or use your personal data for targeted advertising or to limit the use of your sensitive personal data, please click the “Your Privacy Choices” link here. We also recognize the Global Privacy Control opt-out preference signal in a frictionless manner. The Global Privacy Control is available here. The Global Privacy Control applies to devices, so additional devices may need to have the Global Privacy Control activated.

I. Additional Information on What and How Your Personal Data Is Processed

Please note that except that (i) we use analytics tools as described in Section II of Part A (General Provisions); and (ii) your user ID number may be disclosed to social account platforms if you use your social account to login our game app, we will not share your personal data to any third parties.

Category of personal data	Source(s)	Purpose	Disclosure to third parties	Retention Period
Identifiers, such as phone number, email address	Directly from users	For registration and login of accounts	None	We retain this information for as long as needed to fulfill the purposes for which it was collected, including described in this Privacy Notice or as required by law.
Identifiers, such as real name, ID number	Directly from users	For real-name authentication	None
Identifiers, device identifiers, and network activity information, such as user ID, device ID, device name, device type, device model and version, system version, IP address, device unique identifier (IMEI and Android ID for Android devices, IDFA for iOS devices), network type, and MAC address, etc.	Directly from users	For providing basic functions of the game, safeguarding the account security, and creating a safe game environment	None
Identifiers, device identifiers, and network activity information, such as game log information including ConLog, item log, game match information and friends record, game application information including game identification information, hardware and operating system information, application list, progress and game crash record, etc.	Directly from users	For providing basic functions of the game	None
Commercial and payment information, such as recharge records, consumption records, payment records and other necessary information related to transactions	Directly from users	For realizing the consumption function of the product	None
Text, picture, voice and video information users send in the game	Directly from users	For filtering inappropriate content such as pornography, violence, politically incorrect content, abuse and malicious advertisements, etc., and maintaining a healthy network environment	None
Identifiers, such as data generated during user’s request for customer support	Directly from users	For responding to requests made by users	None
Identifiers, such as date of birth, address, email, nickname, image, etc.	Directly from users	For providing users with gifts, prizes, birthday wishes, questionnaire survey, etc.	None

II. Additional Information on Your Rights Regarding Your Personal Data

For residents of California, United States only, California Civil Code Section 1798.83 permits users who are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please contact us using the details in the “Contact Us” section below.

Depending on your residence, the rights available to you may differ in some respects. We will respond to any rights request in accordance with legal regulations. If you, or an authorized agent acting on your behalf, wish to: (1) make a request related to any of the rights set forth below; (2) appeal a decision we made regarding a request; or (3) appeal our refusal to act within a reasonable time, please reach out to us using the contact information provided in the “Contact Us” section of this Privacy Notice. Information regarding the right to opt-out of sale, sharing, or targeted advertising and right to limit the use of sensitive personal data is also located in the above “Notice at Collection” section of this Privacy Notice.

We may need to verify your request before completing it. For example, we may ask you to confirm data points we already have about you. We will only use personal data provided in a request to verify the requestor’s identity or authority. Note that we may deny a request from an authorized agent that does not submit sufficient proof that they have been authorized to act on behalf of another individual.

(A) the right to know and access information about the categories and specific pieces of personal data we have collected about you, as well as the categories of sources from which such information is collected, the purpose for collecting such information, and the categories of third parties with whom we share the personal data we have collected;

(B) the right to request the information regarding our disclosure of personal data to third parties for business purposes.

(D) the right to opt out of the sale, sharing, and targeted advertising of your personal data to third parties. We do not sell personal data, including the personal data of minors under 16;

(E) the right to correct your personal data if it is inaccurate;

(F) the right to consent and/or limit the use and disclosure of your sensitive personal data;

(G) the right to opt-out of profiling; and

(H) the right to not be discriminated against for exercising any of the rights mentioned above.

(I) the right to deactivate your Sunborn Game account. You can deactivate your account via functions in “user center” with following the given instructions.

Whenever feasible for verification, we will match the identifying information provided by you to the personal data already maintained by us. If, however, we cannot verify your identity from the information already maintained by us, we may request additional information. You may designate an authorized agent to make a request on your behalf. Such authorized agent must be registered with the California Secretary of State. We may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf.

You can exercise your rights by contacting us using the details set out in the “Contact Us” section below and put “California Privacy Rights” in the subject line of your request and we will acknowledge receipt of your request within 10 business days of receiving it and provide information on how we will likely handle the request. We aim to respond to your request of data protection rights within 45 days. However, if your request is very complex for us to handle, we will inform you and extend this period, but the total period for handling such a request will be within 90 days.

III. Additional information for the “consumers” in California

If you are a California resident, you also have the right to request we disclose to you free of charge the following information covering the 12 months preceding your request:

（A） the categories of personal data about you that we collected;

（B） the categories of sources from which the personal data was collected;

（C） the purpose for collecting personal data about you;

（D） the categories of third parties to whom we disclosed personal data about you and the categories of personal data that were disclosed (if applicable), and the purpose for disclosing the personal data about you; and

（E） the specific pieces of personal data we collected about you.

IV. Further Information for United States Users

1. Deidentified Information. We maintain and use all deidentified information in deidentified form. We do not attempt to reidentify it except to ensure our deidentification processes are compliant with applicable data protection laws.

2. Website Interactions. We may use technology to monitor how you interact with our Services. This may include without limitation which links you click on, information that you type into our online forms, and about your device or browser. Further, we utilize session replay spyware to monitor and record mouse clicks and movements, keystrokes, and pages and content viewed by you. Please discontinue use of the Services if you do not consent to our collection of such information.

3. Do Not Track Signals. The “Do Not Track” (“DNT”) privacy preference is an option that may be made in some web browsers allowing you to opt-out of tracking by websites and online services. At this time, global standard DNT technology is not yet finalized and not all browsers support DNT. We do, however, recognize the Global Privacy Control.

4. Financial Incentives. We may offer various financial incentives from time to time. The terms of the financial incentive will be provided at the time you sign up for the financial incentive. You may withdraw from any of the financial incentives. In calculating these offers, we consider the expenses related to the offer and the value of your information.

C. Contact Us

If you have questions or concerns regarding our Privacy Notice or practices, please submit your request to Sunborn Game as specified below.

Email address: dpo@micateam.cn

Postal address: Rm1892B, Fortress Tower, 205 King's Road, North Point, HONG KONG