Privacy Policy

Welcome to the game developed and operated by us . This Privacy Policy aims to clarify how we collect, use, store, share, and protect the personal information you provide or generate during your use of the game, while also explaining your rights regarding your personal information to ensure your privacy is fully protected.

This Privacy Policy strictly adheres to the App Store Review Guidelines, Apple's Privacy Policy, and relevant laws and regulations. It also complies with all user privacy protection provisions of iOS (iOS 14.5 and above), including but not limited to the App Tracking Transparency (ATT) framework requirements. Please carefully read and fully understand all the contents of this agreement before using this game. If you do not agree to any terms of this agreement, please do not download, install, or use this game. Once you download, install, or use this game, it signifies that you have fully understood and agreed to all the terms of this agreement.

I. Definitions and Explanations

1.1 Personal Information

Personal information refers to information relating to an identified or identifiable individual, including but not limited to your name, contact information, device information, and usage data. This information is considered personal information regardless of where you reside. Aggregated data not associated with any individual is not considered personal information.

1.2 Data Collection

This refers to the act of allowing us and/or our third-party partners access to data during the transmission of data from your device, and the access time exceeding the time necessary to provide real-time service for the transmitted request.

1.3 Tracking

This refers to the act of linking user or device data collected from this game with user or device data collected from other companies' apps, websites, or offline files in order to target advertising, measure advertising effectiveness, or share data with data agents.

1.4 Third-party partners

This refers to analytics tools, advertising networks, third-party SDKs, or other external vendors that have added their code to the game, including but not limited to payment processing service providers, data analytics service providers, cloud service providers, etc.

II. Information We Collected and the Methods of Collection

We collect your personal information following the principle of "minimum necessity," collecting only information necessary to achieve the core functions of this game and enhance the gaming experience, and not collecting information unrelated to the functions of this game. All information collection will be subject to your explicit consent in advance (unless otherwise stipulated by laws and regulations). Specific information collected is as follows:

2.2.1 Equipment - related information

To ensure the game runs smoothly, optimize game performance, and prevent cheating, we will automatically collect information related to your device, including but not limited to:

• Basic device information: device model, operating system version (iOS version), device identifier (IDFV, used only to analyze the usage of apps under the same developer, not to track you), device name, screen resolution, and battery status.
• Device operation information: game operation log, crash log, lag record, network connection status (Wi-Fi/mobile network), IP address (only used to locate your general area to provide suitable game services, not to collect precise location).

We will not obtain your device's Advertising Identifier (IDFA) in any way unless you explicitly consent to us tracking you through the AppTrackingTransparency framework; if you do not consent, the IDFA will be all zeros, and we will not use it for any tracking activities. Furthermore, we will not use fingerprint features or signals emitted by the device to uniquely identify it.

2.3 Game-related information

To optimize game content and improve user experience, we will collect usage data generated during your use of this game, including but not limited to:

• Game behavior data: game login time, online time, game level progress, in-game operation records, item purchase and usage records, social interaction records (such as friend additions, chat content, chat content is only used for instant messaging and not for other purposes).
• Preference settings: Your in-game language settings, graphics settings, sound effects settings, etc., are used to provide you with a personalized gaming experience.

2.4 Selective Disclosure of Information

If you voluntarily submit optional feedback forms, customer service requests, etc. within the game, the information contained therein (such as your feedback content and contact information) may be disclosed by us as it is unrelated to the main functions of the game, you have full choice, and you are fully aware of the content to be collected and confirm the submission.

2.5 Information Not Collected

We will not collect your health and fitness information, financial information (unless you make in-game purchases, in which case the relevant payment information is processed by a third-party payment service provider, and we will not obtain any payment card number, bank account information, etc.), precise location information (unless you explicitly authorize it and the game function requires it), or any personal information unrelated to this game.

III. Purpose of Information Use

All information we collect will be used solely for the following purposes, and in accordance with Apple's privacy policy and applicable laws and regulations, and will not be used for any other purpose unrelated to this game:

1. Ensure normal game operation: This includes game installation, login verification, account security maintenance, prevention of account theft, and prevention of cheating, ensuring that you can use all the core functions of this game normally.
2. Optimize your gaming experience: Based on your device information and usage habits, we optimize game performance (such as adapting to different device models and resolving lag issues) and adjust game content (such as pushing game events that may interest you) to provide you with a personalized gaming experience.
3. Customer Service Support: When you contact our customer service for assistance, we will use the contact information and game-related information you provide to quickly respond to your questions and resolve your requests (such as account recovery and item anomaly handling).
4. Compliance and Security: To comply with the App Store Review Guidelines and related laws and regulations, respond to regulatory inspections, prevent cybersecurity risks and fraudulent activities, and protect your and our legitimate rights and interests.
5. Data Analysis and Improvement: Collected non-personal information is aggregated and anonymized to analyze game operation and user behavior trends, thereby improving game functions, developing new game content, and enhancing the overall game quality.

If we need to use the information for purposes other than those stipulated in this agreement, we will obtain your explicit consent in advance, and this will not violate Apple's relevant privacy policies and legal requirements.

IV. Information Sharing and Disclosure

We strictly protect your personal information and will not share, sell, rent, or transfer it indiscriminately. We will only disclose or share your information with third parties in the following circumstances, and all of these circumstances comply with Apple's Privacy Policy:

4.1 Shared by third-party partners

We will only share your information with third-party partners who are necessary to implement the functions of this game, and we will strictly screen third-party partners, requiring them to comply with this agreement and related privacy regulations, and to take sufficient security measures.

• Third-party payment service providers: If you make in-game purchases, we will share your order information (such as order number and payment amount) with third-party payment service providers (such as Apple Pay, WeChat Pay, and Alipay) to complete the payment process. Third-party payment service providers will not provide us with sensitive information such as your payment card number or bank account number.
• Data analytics service providers: We will share your device information and game usage data (which has been anonymized and cannot identify your personal identity) with data analytics service providers (such as Umeng and Firebase) to analyze game operation and optimize game experience. This data will not be used to track you or target ads.
• Cloud service provider: We will store your account information and game data on the servers of a third-party cloud service provider to ensure the secure storage and stable access of game data. The cloud service provider is only responsible for data storage and has no right to access, use or disclose your personal information.

If a third-party partner needs to use your personal information, we will require them to use it only to the extent necessary to achieve the functions of this game, and to obtain your explicit consent in advance (if required); if a third-party partner violates the relevant agreement, we will immediately terminate our cooperation with them and require them to bear the corresponding responsibilities.

4.2 Legally Required Disclosure

If required by laws and regulations, judicial authorities, or administrative agencies (such as court summons or administrative investigations), we may disclose your personal information in accordance with the law to comply with relevant legal provisions, safeguard the public interest, and protect the legitimate rights and interests of you or others.

4.3 Prohibit tracking and sharing

We will not associate your personal information with data from other companies' apps, websites, or offline files to track you, target advertising, or share it with data agents (unless required by selective disclosure or law). We will not track you or share your information for tracking purposes unless you consent to our tracking through the AppTrackingTransparency framework.

V. Information Storage and Security Protection

5.1 Information Storage

• Storage location: Your personal information will be stored on Apple-approved cloud servers or our compliant servers. The storage location complies with relevant laws and regulations and Apple's privacy policy requirements to ensure the security and compliance of data storage.
• Storage period: We will only store your personal information for the period necessary to achieve the purposes set forth in this Agreement; when the storage period expires, you cancel your account, or we no longer provide this game service, we will delete your personal information in accordance with the law, or anonymize it (the anonymized data can be used for data analysis and is no longer associated with personal identity).

5.2 Safety Protection Measures

We employ security measures that comply with Apple's privacy standards to fully protect your personal information and prevent its leakage, alteration, or loss.

• Technical protection: We employ HTTPS encryption, data anonymization, and access control to encrypt and store your personal information during transmission and storage, preventing it from being leaked or tampered with.
• Management and Protection: Establish a strict information security management system, clearly define information access permissions, allow only authorized personnel to access your personal information, and record and monitor access behavior; regularly conduct privacy protection training for employees to enhance their awareness of privacy protection.
• Emergency Response: We have established an information security emergency response mechanism. In the event of a security incident such as leakage, alteration, or loss of personal information, we will immediately activate the emergency response process, take remedial measures, and promptly inform you (if necessary) and report to the relevant regulatory authorities.

Please note that despite the security measures we have implemented, due to the limitations of internet technology, no data transmission and storage can be guaranteed to be 100% secure. You should safeguard your game account password, third-party login accounts, and other information to avoid information leakage due to your own improper operation.

VI. Your Rights

In accordance with Apple's privacy policy and relevant laws and regulations, you have the following rights regarding your personal information, and we will provide you with convenient ways to exercise these rights:

• Access rights: You have the right to access your personal information, including your account information, game usage records, etc., which can be viewed through "Settings - Personal Center - Privacy Management" in the game.
• Right to Correction: If you find any errors or incompleteness in your personal information, you have the right to request that we correct it. You can submit a correction request through customer service channels, and we will correct it promptly after verification.
• Right to delete: You have the right to request that we delete your personal information. You can submit a deletion request through "Settings - Personal Center - Cancel Account" in the game, or contact customer service to request deletion. After canceling your account, we will delete all your personal information (except for those that are required to be retained by laws and regulations).
• Right to withdraw consent: You have the right to withdraw your consent to the collection, use, and sharing of information. For example, you can turn off relevant permissions (such as notification permission) in iOS system "Settings - [Game Name] - Privacy". If you withdraw your consent, we will no longer collect or use the relevant information, but the information already collected will be processed in accordance with the law (it will not be deleted arbitrarily unless you request it).
• Right to complain: If you believe that our handling of your personal information violates this agreement or relevant laws and regulations, you have the right to complain to our customer service or report to the relevant regulatory authorities.

Upon receiving your application to exercise your rights, we will promptly verify and process it. Under normal circumstances, we will respond to you within 15 business days (this period may be extended in complex cases, but we will inform you in advance).

VII. Protection of Children's Privacy

This game is not intended for children under the age of 13. If we discover that we have unintentionally collected personal information from children under the age of 13, we will immediately cease collection, delete the relevant information in accordance with the law, and notify the child's guardian. If you are the guardian of a child and discover that your child has used this game and submitted personal information, please contact us promptly, and we will assist you in deleting the relevant information.

VIII. Updates and Notifications of the Privacy Policy

We will update this Privacy Policy from time to time in accordance with updates to Apple's Privacy Policy, changes in relevant laws and regulations, and adjustments to the game's features . The updated Privacy Policy will be displayed in a prominent location within the game (such as the login page and settings page), and may also be communicated to you via push notifications, email, and other means.

If you continue to use this game after the privacy agreement is updated, it will be deemed that you have fully understood and agreed to the updated agreement; if you do not agree to the updated agreement, please do not continue to use this game and you may apply to cancel your account.

IX. Contact Us

If you have any questions, comments, or suggestions regarding this Privacy Policy, or if you need to exercise your rights related to your personal information, please contact us by email at opris@tmdprosolutionssrl.com.