30 June 2016
Article 1 (Introduction)
1.1 We use commercially reasonable efforts to protect and handle your information properly by complying with this Policy and any separate terms or rules we may establish in connection with the Services, as well as all applicable laws and regulations.
1.2 This Policy is not applicable to any external services (“External Services”) provided by third-party service providers. For information regarding the handling of User Information in connection with External Services, please refer to the privacy policies or terms separately prescribed by the respective External Service providers.
Article 2 (Information We Collect)
We collect the following information, which include your personal information, when you register to use the Services or during your use of the Services. Personal information refers to information that can identify you as a particular individual whether directly or indirectly:
(1) Information provided by you:
(a) Month of birth;
(b) E-mail Address;
(d) Use of Social Networking Service; and
(e) User name.
(2) Other information collected automatically:
(a) UUID issued by us;
(b) Device information: Model, country code, language setting, time-zone, and other device-specific IDs provided by advertising agencies;
(c) In-game information: Region in which the Services are used and the division you belonged in when you last logged on;
(d) Publisher information;
(e) App version information;
(f) Data version information;
(g) Advertising IDs provided by iOS or Android;
(h) Log files and access history: IP address, date of request and other information relating to your activities within the Services; and
(i) Cookies and anonymous IDs.
Article 3 (How We Collect Information)
3.1 We collect your information in an appropriate manner and only to the extent necessary for us to provide you with the Services.
3.2 Other than the information you provide us directly, we collect your information through Cookies and similar automated technologies in connection with the Services. Cookies are small files applied to your device that allow web servers to recognize your browser information and track movements within the Services, although they do not collect personal information about you. You may choose to disable cookies by changing your device preferences. However, some of the Services may not function properly if the ability to accept cookies is disabled.
3.3 We use the following information gathering modules to analyze your information in connection with the Services. Accordingly, we may provide User Information to the following module service providers. The information analyzed using these modules will be managed by the respective module providers in accordance with their privacy policies and other terms and conditions:
(a) Facebook SDK by Facebook, Inc.
(b) Google Analytics by Google, Inc.
(c) Flurry SDK by Yahoo! Inc.
(d) Zendesk SDK by Zendesk
(e) KONNECT SDK by Mobilus Corporation
(f) adjust SDK by adjust Inc
(g) Other SDKs intended for advertising and analysis purposes provided by cloud service providers.
Article 4 (Targeted Advertising)
4.1 We may provide your information to third-party advertising providers (“Advertising Providers”) for the purpose of providing advertisements tailored to your interests and preferences (“Targeted Advertising”).
4.2 The information we provide to Advertising Providers will not contain any information that is personally identifiable, and any non-personal information provided to Advertising Providers will be handled by them in accordance with the privacy policies and terms established by the respective Advertising Providers.
Article 5 (How We Use Your Information)
5.1 We will use your information generally to provide you with the Services, to better enhance your user experience, to improve our products and services, to understand the preferences of our customers, to generate statistical data regarding the Services, to troubleshoot technical problems, for authentication, communication and notification purposes, to ensure proper functioning of the Services as well as to help improve them. Specifically, we use the following information for the following purposes:
(a) UUID, model information, country code, language, time zone, region, division, publisher, app version, data version, month of birth, E-mail address, location, Use of Social Networking Service and IP address: To provide you with the Services and respond to your inquiries; and
(b) Advertising IDs provided by iOS and Android, and device-specific IDs provided by advertising agencies: To conduct advertising and marketing activities in connection with the Services.
5.2 We may amend the above purposes of use at any time, and will notify you of any material changes by posting on our website or through other means as determined by us. Such changes are effective when they are posted on this page.
Article 6 (How We Share Your Information)
6.1 We may share your information with third parties in the following circumstances:
(a) If your consent is obtained;
(b) If required by laws or regulations, or by government agencies, local public bodies or agents for purposes of national or public security, law enforcement or for other issues of public interest;
(d) If such provision is necessary to protect the life, body or property of an individual, and the situation renders it difficult to obtain your consent;
(e) If such provision is necessary for improving public health or promoting the sound growth of children, and the situation renders it difficult to obtain your consent; or
(f) In the event of a merger, acquisition, company split, transfer of business or any other business succession involving transfer of user data containing personal information.
6.2 We may share your information with CYBIRD Co., Ltd. (“CYBIRD”) which we outsource the operation of Services to the extent necessary for allowing them to provide you with affiliated services in connection with the Services. If and when we share your information with our partners other than CYBIRD, we will notify you by posting on our website or through other means as determined by us.
6.3 You will be notified before your personal information is collected by any third party that is not our agent/service provider, so you can make an informed choice as to whether or not to share your information with that party.
6.4 When we provide your information to our partners or third party service providers, we require that they use data consistently with this Policy and conduct necessary and appropriate supervision over such partners and third parties to ensure proper and safe management of your information.
Article 7 (How We Protect Your Information)
7.1 We understand the importance of keeping your information safe and secure, and will make commercially reasonable efforts to protect your personal information from any loss, theft, misuse, unauthorized access, disclosure, alteration or destruction.
7.2 We take necessary and appropriate measures to securely manage your information by allowing only minimal and limited access to files containing your information. In addition, we ensure the security of our systems through the use of SSL (Secure Sockets Layer) and other equivalent encryption technologies whenever we transmit sensitive information collected from you.
7.3 Although we take reasonable precautions, we cannot guarantee that your information will never be accessed, disclosed, altered or destroyed by breach of any of our safeguards on our Services, databases, equipment or servers. Accordingly, we cannot assume responsibility or liability for unauthorized access to our servers and systems beyond our control and thus, strongly urge you to take reasonable measures at all times to protect your own personal information.
Article 8 (Requests for Review, Correction and Deletion)
8.1 If you wish to review, correct or delete the information you have previously provided us, you may submit a request by contacting us using the inquiry form on our website or app or by email.
8.2 Upon receipt of your request and verification of your identity, we will take appropriate steps to respond to your request to the extent we deem reasonable. However, we may not always be able to accommodate your request if we are not required to do so under applicable laws or regulations, if the same request is repeatedly submitted without justifiable grounds, or if your request requires excessively technical work.
Article 9 (Special Note about Children)
9.1 We may allow persons under the age of 18 to register to use the Services and collect personally identifiable information from such users, if the express consent of their parent or guardian is obtained.
9.2 When we confirm that a user under the age of 18 has registered to use the Services or has submitted any personally identifiable information to us, we will, in accordance with applicable laws or regulations or at our discretion, request a parent or guardian's e-mail address to notify them of the activity of the user. We take appropriate steps to ensure that parental/guardian consent is obtained for our collection, use and sharing of children's personal information.
9.3 If we learn that we have collected personal information from a child under the age of 18 without verification of parental/guardian consent, we will delete that information as quickly as possible.
9.4 Please contact us using our inquiry form on our website or app or by email if you believe that we might have obtained any information from or about a child under the age of 18 without parental/guardian consent, or if you wish to review, correct or delete your child’s information previously provided to us with your consent.
9.5 If we change this privacy statement in a way that expands the collection, use or disclosure of children's personal information to which their parents or guardians have previously consented, we will notify them to obtain additional consent.
Article10 (Changes to This Policy)
10.1 We use commercially reasonable efforts to continuously review and improve our handling of your information, and may update this Policy from time to time as necessary.
10.2 We will notify you of any material revisions to this Policy by posting on our website or through other conspicuous means of notification. Changes to this Policy are effective when they are posted on this page. However, if we are required by applicable laws or regulations to obtain your consent before we make certain revisions, then we will take appropriate steps to comply with such laws or regulations accordingly.
For any inquiries regarding this Policy or our handling of your information, including any suggestions, questions, complaints or comments, please contact us at:
nxTomo Games Limited
Inquiry Form: https://nxtomo.zendesk.com/hc/zh-tw/categories/200032795-BFB
Article 12 (Jurisdiction)
Any disputes arising out of or in connection with this Policy shall be subject to the exclusive jurisdiction of the Hong Kong Court as the court of first instance.
The original language of this Policy is English and any translation will serve only as a guide to interpretation.
Effective 21 Jun 2016
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