II. What Data We Collect and Process
III. How does XD Use Your Personal Information?
IV. Who May Access Your Personal Information?
V. Data Storage, Cross-Board Transfer, Security and Retention
VI. What Rights do You Have to Your Personal Information?
LAST UPDATED: September 15, 2022
1.Disclosed the new Third-Party Service Providers and its Main third-party services embedded in our Services which may collect your Personal Information.
2. Added new terms for CCPA.
3. Modified our Contact details.
IT IS IMPORTANT FOR YOU TO UNDERSTAND HOW THIS HAPPENS AND HOW YOU MAY CONTROL IT. AND BY ACCESSING OUR WEBSITES OR OTHERWISE, USING OUR SERVICES AND CLICKING “AGREE” BUTTON ON THE POP-UP WINDOW, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND ACCEPTED THE FOLLOWING TERMS. IN THE CASE YOU DO NOT AGREE TO ANY OF THE TERMS, YOU MAY IMMEDIATELY STOP USING OUR SERVICES.
Our Services are not designed for Minor, and since a “Minor” is usually considered to be under the age of [16（GDPR）/14（KOREA and other countries or regions ）/13(CCPA,JAPAN and other countries or regions/12 (Brazil and other countries or regions）Subject to the laws of your country] under applicable law of most regions, we do not directly provide Services to Minor under the age of [16/14/13/12] If you are under the [16/14/13/12] you shall ask for the consents of your parent or legal guardian before using our Services. We also do not knowingly collect Data from Minor through the Service. If you are the parent or guardian of a Minor and you believe that we have inadvertently received your child’s information, please contact us through the methods listed in Section IX. We will delete the Data from our records as soon as possible after verifying your identity. If you are not a parent or legal guardian but believe that we might possess any Data from or about a Minor under the age of [16/14/13/12], you are also encouraged to contact us as well. We encourage parents to instruct their Children to never give out personal data when online.
IN THE EVENT OF A MERGER, ACQUISITION, REORGANIZATION, BANKRUPTCYBANKRUPTCY, 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 OR YOUR GUARDIAN IN ADVANCE AGAIN, YOUR PERSONAL DATA MAY TRANSFER TO THE SUCCESSOR OF XD.
II. What Data We Collect and Process
Personal information may be collected from you during your use of the Service, including, during (a) the registration process, (b) promotional activities, (c) customer support and technical service requests, and/or (d) ordering and use of products and other services, or from and through third-party service providers and partners.
We may also collect information that does not generally identify you but may become associated with your account. We reserve the right to use information that does not generally identify you in connection with any lawful purpose.
1.Information We Need You to Provide or Information You Provide to Us Voluntarily
For using XD’s Services, we may ask you to provide necessary information or you may provide information to us voluntarily. In general, we will collect the following information that you may provide to us :
- Information You give us when register for the Game and set up your profile for the Game: your nominated nickname, and information we import from your connected social media account in order to set up your profile, including your nickname as it appears on your social media profile, your profile picture, etc. For certain regions, you may also be asked to provide us with your date of birth (stored device-side only) to verify your age and for administration of the gameplay management system. You also provide us with additional information when you set up your profile for the Game (including region location and information you voluntarily elect to provide, such as gender) or your nickname when you log-in as a ‘guest’ in order to use the Game.
- Information you provide when you contact our support team or DPO team: Information that you provide in your communications; Specifically, For requests relevant to data or privacy subject, we may collect information to verify your identity, your rights and to process the requests, including country/region, alias, user email address, screenshot of Game avatar, account ID, account registration date, account balance, request details, and if applicable, name of requestor, email address of requestor, requestor’s relationship with user, proof of requestor’s identity, proof of user’s identity and requestor’s authority.
- Information you provide when participating in-game surveys, sweepstakes events, game-based event, etc.: When you participate in a survey we will process the information you provide to us as part of the survey, such as country, age, gender, profession and email address; When you participate in one of our sweepstakes events, you may provide us with information such as email address, Open ID, phone number, mailing address and country; If you participate in our game-based events, to send you digital prize(s) if you win such prize(s), we may collect and process your email address and telephone number; to deliver physical prize(s) if you win such prize(s), we may collect and process your name (as shown on your passport), email address, telephone number, mailing address and postal code.
2.Information We Collect Automatically
We automatically collect certain data from you when you use the Services, namely:
- IP address, we collect IP address to allow you to connect to the Game server; and suggest your country/region when you seek to change your location setting.
- Device information: such as application version, battery level, WiFi strength, available space, network type, OS version, platform, carrier, country code, series ID, Android ID, IDFV, WiFi SSID (stored device-side only) and time zone settings, registration time, login time.
- Battle Performance Information: such as opening time, hero, player/team UID, scores/badges earned, damage amount, current round rank, etc.
- Game play statistics (e.g. level, scores, game settings);
- Transaction Records (in-app): cost, product purchased, IP address, details of transactions linked to player ID, and device details including OS version, phone model, device root status, etc. For security reasons and to better protect your privacy, we do not directly collect or store your payment information like valid credit card number, expiration date, etc.
- Malicious content information: signatures, nicknames, profile photos and chat histories which is suspicious of containing malicious content such as the sale of plug-ins or pornographic or any other malicious contents as stipulated in the END USER LICENSE ARGEEMENT (we will detect if your signature, nickname, profile photo or chat history contains malicious information and changing it to its default setting and prompting you to change it subsequently if this is the case).
Please note that if certain features on the Services are provided by third parties, those third parties may also use automated means of data collection and may record information about your use of the Services over time. These features are subject to those third parties’ privacy notices and policies.
3.Data We obtain From Third- Parties
We also may receive Personal Information from or through certain third-party service providers (such as Social Media Platforms, third-party payment platforms, Advertising Partners, Fraud-Detection Service Provider, Customer Support Partner, Anti-Crack and Anti-Cheat Service Provider, etc.) which provide us services in support of the operation of XD Services:
- Data we imported from the Social Media (Sign-in with TapTap, Sign-in with Apple, etc.) via which you choose to log in XD Services (for TapTap, we will import nickname in the profile, profile photo, etc.).
- Malicious content/behavior information related to cheat and fraud and any other prohibited behaviors as stipulated in END USER LICENSE ARGEEMENT, such as video clips of suspected cheating behavior generated from user’s in-Game instructions detected by our third-party anti-cheating service provider.
- Data from third-party payment platforms when you conduct any transaction within the Game to facilitate your transaction and to maintain transaction records.
- Data to measure the effectiveness of our advertising campaign from our advertisement service provider.
- Safety observation and security related information: such as game crashes and errors data.
Certain game features or third-party services embedded in our Services may require for the access to your Camera, Microphone, and other sensitive device or usage data, we will use a runtime permissions request whenever available, prior to accessing data gated by Android or IOS permissions. For example, if you want to use the Scan QR code feature, you will be required to grant the Camera Permission; if you want to function the in-game voice-chatting feature, you will be required to grant the Microphone Permission; if you want to store/read game data, or want to store/read/post/share photos or screenshots, you will be required to grant the Write/Read-External-Storage permission (or other similar permission with different name in the operating system), etc.
III. How does XD Use Your Personal Information?
1.We only collect, use, store, and process your Data based on:
- The principle of lawfulness, fairness and transparency;
- Your consent that we may obtain from you time to time;
- Specified, explicit and legitimate purposes;
- The extent that is adequate, relevant and limited to what is necessary in relation to the purposes, such as to perform the obligations under EULA and to provide our Services;
- Your or our other legitimate interests;
- Necessity for protecting the vital interests of you;
- Other legal bases including if required under any law or required by governmental and regulatory bodies.
2.We need collect and use certain Personal Information to operate our business and to enhance and personalize your Service experience, such as:
- Software: For example, identify, fix, and troubleshoot bugs and service errors; provide software updates;
- In-game Communications: For example, enable you to communicate, share your gaming experiences, or express your feelings with other users;
- Account: Set up and maintain your accounts; activate or authenticate your games and save game progress and status; recover your account, locate your account when you receive rewards;
- Gaming Functions: For example, facilitate your gameplay on multiple devices; enable online matchmaking; enable purchasing related functions; monitor, analyze, test, improve, and develop our Service, etc.;
- Marketing/Advertising(optional): For example, serve and measure the effectiveness of advertising; adhere to your preferences and to deliver dynamic and personalized content;
- Solve In-game disputes: Keep our Services safe and fair, investigate and resolve disputes between you and other users as well as XD;
- Compliance and security: help identify fraud and illegal behaviors, comply with the law or to enforce our agreements and policies, ensure the security of our services, to maintain a fair gaming environment in the Game and to prevent the sale of plug-ins or the availability of pornographic content on the services.
3.We need collect and use certain Personal Information to provide you with customer support, including:
- Help identify and troubleshoot problems with your account or Services;
- Collect your opinions through surveys or questionnaires;
- Communicate with you and respond to your specific requests or questions;
- Help you find your friends or share your related gaming experience;
- Manage and send you confirmations and important information about your account, purchases, subscriptions, and warranties.
IV. Who May Access Your Personal Information?
In addition to XD 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.
Social features are a core component of our games and Services, other players and users may, for example, see your profile data, in-game activities and read the messages you have posted depending on the setting adopted by you. We strongly recommend that all users avoid posting personal or sensitive information at any time, do not use your real name when selecting a username or post your real name in public-facing areas of the Services, such as forums, chat rooms, or message boards, and do not share anything private about yourself on such public platforms, including your phone number or address. Use sernames/nicknames instead of real names at all times.
We may provide certain portion of your Personal Information to judicial or administrative authorities when we are required to do so by law, legal process, or a reasonable request from law enforcement authorities or other government officials. Besides, we may disclose certain portion of your Personal Information 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.
We ensure that, even in this case, we will not provide your Personal Information to third parties.
3.Third-Party Service Providers
XD works with some (if any) third-party service providers and business partners to support the operation and provision of our Services. For example, we may share certain limited information, such as device identifiers, with marketing partners for purposes of executing and optimizing campaigns, and gauging the effectiveness of advertising and other marketing strategies solely on XD’s behalf. Other common examples include partners that assist with cloud storage, payment processing, customer supporting ticketing, and monitoring and securing the XD Services. These service providers are not authorized by us to use or disclose personal information except as necessary to perform services on our behalf or comply with legal requirements and we do not share Personal Information with third parties for their direct marketing purposes.
- For the purpose of providing payment processing services (including security and fraud detection): Google;
- For the purpose of providing services of login: TapSDK, Share SDK, Line, Twitter, FaceBook, Mob;
- For the purpose of providing services of social features such as game community forum, content sharing and posting, in-game friends system: TapSDK;
- For the purpose of executing and optimizing campaigns, and gauging the effectiveness of advertising and other marketing strategies solely on XD’s behalf: Adjust, CrashSight,Firebase, Facebook, Mob SDK, Google, Tap SDK, Taobao, Unity3d, TradPlus SDK, HUAWEI Ads SDK, Amazon Vungle SDK, Aurora SDK,etc.;
- For the purpose of providing performance and stability monitoring service to solve crashes and optimize compatibility, to identify and address bugs and assess service function for optimization and to improve our services: Tencent WeTest, Sentry,etc.;
- For the purpose of providing anti-cheating and security reinforcement service: ACE, AppsFlyer,Shumei SDK, etc.;
- For the purpose of providing in-game voice communication services: Tencent GME, WWise;
- For the purpose of providing image processing and QR Code scanning services: Google, QR Code/Barcode Scanner and Generator--Cross Platform(Pro), etc.;
- For the purpose of third-party social platform sharing service: Share SDK, Line, Twitter,FaceBook, mob, Google.
Tencent WeTest: https://www.wetest.net/introduction/agreement/tabprivacy
Share SDK: https://www.mob.com/wiki/detailed?wiki=heguizhinan&id=undefined
Mob SDK: https://www.mob.com/about/policy?fileGuid=5xkGMn99P9c5lP3X
TradPlus SDK: https://docs.tradplusad.com/privacy-policy
HUAWEI Ads SDK: https://developer.huawei.com/consumer/en/doc/development/HMSCore-Guides/publisher-service-personal-data-0000001050066921
Amazon Vungle SDK: https://support.vungle.com/hc/zh-cn/articles/360002922871
QR Code/Barcode Scanner andGenerator--Cross Platform(Pro): https://assetstore.unity.com/packages/tools/integration/qr-code-barcode-scanner-and-generator-cross-platform-pro-56083#publisher
Tencent GME: https://cloud.tencent.com/document/product/301/11470
V. Data Storage, Cross-Board Transfer, Security and Retention
1.Storage and Cross-Board Transfer
Security of our users’ Personal Information is a priority at us, and we are continuously implementing and updating administrative, technical, and physical security measures such as access control, compressed encryption to help protect your data against unauthorized access, loss, destruction, or alteration. As part of our privacy compliance processes we review these security procedures on an ongoing basis to consider new technology and methods as necessary. Due to the continuous updating of technology, we will try our best to continuously improve our information protection measures. If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. If there is a security breach, we may also post a notice on our Website or by other effective means to notify you for you to take steps to protect the safety of your information as well as your property. We will send an emergency report to authorities in case that the security breach is serious and assist authorities as well to take steps to prevent further harm.
3.Data Retention Policy
We will keep your personal information for as long as your account is active or that information is necessary for us to provide you with the XD Services unless we receive your request to delete. And we will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or where a longer storage and retention period is required to comply with any statutory, regulatory, or legal obligations. After that, your personal information will be deleted, blocked or anonymized, as provided by applicable law.
In the case you request to remove or delete your personal information, we will retain your personal information 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 us. Please note that the remove or deletion any of your personal information may result in the termination of some of our applicable services.
Information you have shared with others such as your chat logs with other users may continue to be retained for other users in the Services, even after your Account is cancelled. However, attribution of such information to you will be removed. Additionally, some copies of your information (e.g., log records) may remain in our database, but are disassociated from personal identifiers. Data protection and information security is important for us. While providing services to you and other users, we operate and maintain the Services or Game so as to protect Data and our systems from accidental or malicious loss and destruction. Therefore, as part of provision of Service and on account of overall safety of Data of all users, residual copies of your personal information may not be removed from our backup systems for a limited period of time.
VI. What Rights do You Have to Your Personal Information?
1.Right to Access/Data Portability, Correct, Delete or Withdraw consent, Restrict/Object Processing
Subject to any limitations under applicable law, you have the right to request access to your Personal Information and exercise a number of rights:
- You have the right to access, correct or update your Personal Information. In many cases, you can review or update the Personal Information in your account by accessing your account online or contacting us.
- You have the right to request deletion of your account and related Personal Information. If you choose to have your Personal Information removed from our active databases, subject to the terms and conditions as set forth in Section V, we will carry out your request within 30 days after we verify your identity unless otherwise required by applicable laws and regulations. After deletion, we will only retain necessary information to document your request and the actions we took to carry out your request. And you are fully aware that once your personal information is deleted, we will not be able to provide you with corresponding services or recover the information with today’s technology.
- Where you have provided your consent to our collecting and processing of your personal information, you can always withdraw your consent at any time for example by turning off GPS location sharing in your mobile device settings or contact us through the methods listed in Section IX. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Upon receiving your request to withdraw your consent we will stop the process and delete the corresponding information as well.
- You have the right to object to the usage of your Personal Information for marketing or advertising purposes.
You may exercise any of the rights described above by using any functionality available while using the Service and/or sending an email to the customer service email or DPO email as listed in Section IX and we will respond within 30 days or other shorter period (if any) as required by applicable laws or policies in the country where you live or work.To protect your privacy, we may need to take steps to verify your identity before fulfilling your request.
We will process such requests in accordance with applicable laws. Please note that we are legally prohibited from carrying out requested actions in some circumstances, including (i) when we are unable to confirm your identity; (ii) where the request is
considered excessive, and (iii) where doing so would adversely affect the rights or freedoms of other individuals.
2.Additional Notice for Users Whose Data is Subject to California Law
The personal information that XD collects, uses and/or discloses and has collected, used, and/or disclosed from users as set forth above in the twelve months prior to the effective date of this Policy, may include personal information as defined under the California Consumer Privacy Act (“CCPA”), depending on how you have accessed the Services and interacted with us.
For purposes of the CCPA, we do not “sell” personal information and in the past twelve months prior to the effective date of this Policy did not sell any personal information of our users, as defined under the CCPA. The California “Shine the Light” law also gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes.
In accordance with the CCPA or other applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of your personal information or ask us to send that information to another company; (iv) restrict our uses of your personal information, including the right to opt in or opt out of the sale of your personal information to third parties, depending on applicable law; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; and (vi)request erasure of personal information held about you by XD, subject to certain exceptions prescribed by law.
3.Right to Lodge a Complaint
You have the right to lodge a complaint regarding our collection, processing, or storage of your Personal Information with a data protection supervisory authority in the country where you live or work.
We use the cookies, web beacons and similar technologies to personalize your experiences on our services and for various other purposes, including:
- remembering you: cookies, web beacons and similar technologies can help us identify you as a registered user or keep the preferences or data that you have previously provided;
- serving 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 your provided data; and/or
- other related functions or purposes mentioned in Section II & III.
Name of the controller: XD Entertainment Pte. Ltd.
Address: 111 SOMERSET ROAD #05-11 111 SOMERSET SINGAPORE (238164)