Privacy Policy

What Data We Collect and Process

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

• Account Registration Information: When you create an account, we may collect your username, email address, mobile phone number, password, verification code, and Open ID, to help you create and manage the account, to provide game login services, and for other purposes set forth in Section 2 of this Privacy Policy.
• Birthday: Where applicable, you may need to provide us your birthday when you apply for birthday gifts or other benefits available in our Services. You may choose to provide us your birthday in your user profile.
• Connected Social Media Account Information (Third Party): If you choose to log in to our Services via your social media account(s), we may receive your social media account information from third-party social media providers. Such information will be added to your account information.
• Personal Profile Information: You can create your personal profile (where available) by setting a nickname, creating a personal signature, uploading an avatar, and providing other information depending on the setup of our Services.
• Game Data: We process information about your gameplay status, progress, and usage statistics to provide you with feedback and improve your experience.
• Chat Data: If you use the chat function in our Services (e.g., in-game chat), we may process the communication record and apply appropriate encryption to protect your data.
• Malicious Content Information: Nickname, signature, and chat data (solely in the form of text) — in order to ensure a healthy online environment in the game, we collect this information to filter content that may offend or distress others.
• User Service Information: When you seek our technical and/or customer service support, we may collect the information that you provide in communications with our support team.
• Survey Information: We will collect your survey responses if you participate in our surveys.
• Activity Participation Information: If you agree to participate in any activities organized by us (such as sweepstakes), we may collect your participation information including your name, UID, email address, mobile phone number, nickname, and country/region. Where you win any prizes, you may also need to provide us your mailing address.
• Internet Protocol (IP) Address and other device information.
• Advertising Information: Advertising ID and select device information. We store the Advertising ID for that advertisement and the other device information with your profile to track the success of our advertising and marketing programs. We may also use your de-identified email address (with appropriate hashing/encryption) to track marketing effectiveness.
• Payment Data: If you choose to make a purchase, we may need to collect your payment data in order to process your purchase, which may include your name, billing address (country, city, postal code, address). Note: full credit card numbers and CVV are processed directly by our third-party payment providers and are not stored by us.
• Other Information Subject to Specific Notice: For some Services, we may collect additional information beyond the above. We will develop individual privacy notices to inform you how we process your personal data when you use the specific Services.

(2) Data We Automatically Collect

To ensure security and stable operation, provide a fair gaming environment, prevent cheating, and improve the functionality and quality of our Services, we may automatically collect data using mechanisms like cookies, browser web storage, and application data caches. Categories include:

• Device-related data: device ID, device name, device type/model, MAC address, IMEI data, CPU data, graphics card model, OS version and language, time zone, screen DPI, device resolution, memory data.
• Diagnostic data: registration/login time, game version, UID, stack trace, crash reports, abnormal process data.
• Security-related data: installed APK names, startup time, request and referral URLs, system activity details, game-related plug-in and runtime data.
• Interaction data: the pages and other content you view, any content you post, and the dates and times of your visits.

Why We Collect and Process Your Personal Data

In order to provide our Services to you, we collect and process your personal data for one or multiple purposes including to:

• allow you to access or restrict your access to our Services;
• provide you the Services required by you and perform our contractual obligations towards you;
• analyze and manage our Services for system administration, user service, security, fraud-detection, checking the authenticity of an account owner, archival and/or backup purposes;
• correct bugs or errors, improve our Services, and respond to customer preferences (including language and location customization, personalized support and instructions);
• develop new services or products and improve the user experience;
• verify and confirm payment;
• deliver advertising that may be relevant to your interests and track the success of our advertising and marketing programs;
• communicate with users (including by sending text messages and/or push notifications) and take action against violations;
• personalize your experience;
• keep you up to date with the latest product announcements and provide other information pertaining to our Services;
• provide software verification, upgrades and administration, and notify of special events;
• offer to participate in our surveys or activities;
• fulfill our obligations under applicable laws and regulations, and respond to requests of government authorities;
• establish, exercise, or defend legal claims;
• analyze, profile, segment, merge, and/or update all collected data (regardless of an aggregated or individualized manner) for the purposes of improving service quality;
• protect the integrity, information safety, and financial security of our Services or users, comply with legal obligations, and enforce compliance with the Terms of Service;
• verify that you are not a bot and optimize our Services;
• any other purposes for which we provide specific notice at the time the information is collected.

For the purposes set forth above, our affiliates may be commissioned to process your information, provided that such affiliates comply with the terms in this Privacy Policy. "Affiliates" means an entity that directly or indirectly controls, is controlled by, or is under common control with OXALUS PTE. LTD.

Advertisements and Your Choices

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

• deliver, target, and improve our advertising; and/or
• improve advertising and other marketing and promotional activities.

We work with industry-standard advertising partners and ad networks (which may include but are not limited to Google AdMob, Meta Audience Network, Unity Ads, AppLovin MAX, Pangle, and Mintegral) to deliver advertisements within the Services. These partners may use device identifiers and other information to serve personalized ads.

You may opt out of personalized advertising at any time:

• On Android: Settings → Google → Ads → "Delete advertising ID" or "Opt out of Ads Personalization".
• On iOS: Settings → Privacy & Security → Tracking → disable "Allow Apps to Request to Track".

If you do not wish to receive marketing communications from us, you may opt out by following the unsubscribe instructions in the communication, or by contacting us via the details in Section 10.

Cookies and Similar Technologies

In order to measure the effectiveness of our Services, we may use cookies, which are small text files for added functionality or for tracking site usage. We may use cookies and/or authorize third-party tracking utilities to (a) log your IP address in determining the path that users take on our sites and identifying repeated users, (b) collect the websites or sources that linked or referred you to our Services, and/or (c) collect technical data about the devices and software you use.

We use cookies, web beacons, and similar technologies to:

• Remember you: identify you as a registered user and keep the preferences or data you have previously provided.
• Analyze how you use our Services: understand what visitors do on our Services, or what pages or sections are most popular.
• Deliver advertising: provide you with advertising that we believe is relevant to you.
• Other related functions or purposes mentioned in Section 2 herein.

You may disable cookies in your browser settings, but if you do so, some parts of our Services may not function properly.

Who May Access Your Personal Data

In addition to Xanlabs and/or its affiliates, other parties may also access your personal data in the following situations.

(1) Other In-Game Users of Our Services

Other users may, for example in a group challenge, access your in-game activities. Other users may also see your displayed data and read the messages you have posted on or through our Services. Any data you post to any communication area is publicly viewable. We strongly recommend that all users avoid posting personal or sensitive data on or through our Services.

(2) Competent Authorities

We may provide a certain portion of your personal data to governmental authorities as requested according to applicable laws and regulations. We may also disclose certain portions of your personal data within a strictly limited scope of recipients when we reasonably think it is necessary to protect us, our users, or a portion of the public.

(3) Third-Party Vendors

We may work with the following types of third parties on or through our Services:

• Social networking portals that provide login and/or content-sharing services;
• Logistics service providers that provide shipping services (such as delivering physical prizes);
• Information communication service providers that provide SMS-messaging services;
• Payment service providers that facilitate payment processing and maintain transaction records;
• Advertising service contractors that provide marketing and advertising activities (including Google AdMob, AppLovin MAX, Pangle, Mintegral, and similar ad networks/mediation platforms);
• Analytics providers (such as Google Analytics, Firebase Analytics);
• Cloud service providers for hosting and storage;
• Other contractors for the purpose of providing our Services to you.

Such contractors may use cookies, web beacons, and/or other tracking technologies to collect or receive data about you. For specific third parties, please refer directly to their privacy policies on their official websites.

We may also disclose your information with your permission.

Data Retention

Your Rights and Choices

(1) Right to Know about Personal Data Collected or Disclosed

You have the right to access your personal data that we hold about you, including information about whether your personal data is collected or disclosed, the categories of personal data collected, the sources, and the business or commercial purposes. You may also request a copy of your personal data undergoing processing.

(2) Right to Rectify

If your personal data is inaccurate or incomplete, you have the right to request rectification of your inaccurate personal data and may modify the information in the privacy settings of the Services (if available).

(3) Right to Request Deletion of Personal Data

You have the right to request the deletion of your personal data if the reason as stated in Section 2 of this Privacy Policy no longer exists, or if there is another legal ground for its deletion. You may submit an account deletion request via email to [email protected] or via the in-game settings (if available).

You acknowledge that as a result of deleting your account, you will lose access to game-related services, account information, subscriptions, and game-related information linked to such account.

(4) Right to Opt-out of Marketing Communications

You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing messages we send you.

(5) Right to Complain

You may have the right to complain to a data protection authority about our collection and use of your personal information. Please contact your local data protection authority where applicable.

(6) Right to Withdraw Your Consent

If we have collected and processed your personal data with your consent, you can withdraw your consent in accordance with applicable laws. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal. If you withdraw consent, it may not be possible for us to continue to provide you with the Services you require.

Securing Your Data

Age Limits and Children Protection

Contact and Complaint

If you have any requests, concerns, or questions about us, this Privacy Policy, or how we process your personal data, or you want to make any complaint or exercise your data subject rights, please contact us at:

Supplemental Terms — Jurisdiction-Specific

(1) Additional Information for California Residents

• Lawfully made available from government records;
• Deidentified or aggregated;
• Otherwise excluded from the scope of the CCPA.

We collect and disclose for a business purpose the following categories of personal information:

• Contact Information and Identifiers: name, alias, online identifiers, IP address, email address, or other similar identifiers.
• Customer Records: name, telephone number, and financial information (such as payment information processed via third-party providers).
• Commercial Information: products or services purchased or obtained.
• Internet or Other Electronic Network Activity Information: browsing history, search history, and information regarding interaction with our Services.
• Inferences: consumer preferences drawn from the above.

• The right to request a copy of the personal information we have collected about you in the prior 12 months;
• The right to request details about the categories of personal information we collect, the sources, the business or commercial purposes, and the categories of third parties with which we share information;
• The right to request deletion of personal information we have collected about you, subject to certain exemptions.

You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights. An authorized agent may submit an access or deletion request on your behalf by sending a written authorization signed by you using the contact information in Section 10.

(2) Additional Information for EEA and UK Residents

• ask us to restrict the processing of your personal data;
• data portability;
• object to the processing of personal data.

Legal basis for processing your personal data. Our legal basis for collecting and using the information described in Section 1 for the purposes in Section 2 is:

• Our or our partners' legitimate interests, where those interests are not overridden by your data protection interests or fundamental rights (e.g., to protect our legal rights, to pursue or defend legal claims, to improve our Services);
• Consent, where obtained separately;
• Compliance with our legal obligations under applicable laws;
• To protect our or your vital interests or those of another person (e.g., against fraud and violations of our terms);
• While we typically do not collect sensitive or special category personal information, where we do this, it will be on the grounds of consent or other applicable lawful basis.

(3) Additional Information for Vietnam Residents

If you are located in Vietnam, the processing of your personal data is also governed by the Personal Data Protection Decree (Decree 13/2023/ND-CP). In addition to the rights set out in Section 7, you have the right to: (i) be informed of the processing of your personal data; (ii) consent or refuse to consent; (iii) access, correct, or delete your personal data; (iv) restrict the processing of your personal data; (v) request the provision of your personal data; (vi) object to processing; (vii) lodge a complaint, denounce, or initiate a lawsuit; (viii) claim damages; and (ix) self-protect.