Last Updated: [ 02 ] 2023
Welcome
to Lohas Games!
Scope of this Policy
This Privacy Policy
(this “Policy”) describes how we
collect your personal data (“Data”)
when you use Lohas games and its related apps / websites / services
(collectively, the “Service”), and
also explains how we use, store and share the Data we collect from you, and
your rights in relation to that Data.
In this Policy, “you” or “your” refers to the authorised user of our Service.
Your access and use of
the Service is subject to the Terms
of Service. This Policy is an integral part of and incorporated
by reference into the Terms
of Service, and all other terms not defined in this
Policy will have the meanings set forth in the Terms of Service.
By using the Service, you are deemed to
accept all the provisions of this Policy, and to expressly acknowledge and,
where required, consent to us processing the information that you provide to us
(including your Data) for the purposes outlined in, and otherwise in accordance
with, this Policy. If you do not agree with the provisions of this Policy, we
may not be able to make available to you the Service.
If
you reside or use our Service in the country or region specifically mentioned
under COUNTRY / REGION SPECIFIC TERMS
below, these terms and conditions shall specifically apply to you.
For
the purpose of data protection laws, the data controller of your Data in
relation to the Service is Lohas games Pte. Ltd, whose registered address is 1
Raffles Place #36-01 One Raffles Place Singapore 048616 (“we”, “us”, “our”). We own
and operate the Service.
Our data protection officer can be
contacted at gameprivacy@lohasgames.com. For a list
of our local data protection representatives in different jurisdictions, please
refer to the section “Local
Representatives”.
Summary
Here is a summary to help you understand
the Policy quickly. However, it should not be treated as a substitute for
reading everything.
|
|
In order to set up an account for you, we
will need to collect some information from you. In order to enable or
participate in certain features of the Service, you can provide certain other
information. If you need to contact our customer support team, then we will
also retain some information so that we can get back in touch with you and
address any concerns. |
|
How is my Data used? |
We use the information to provide you with
the Service and to support and improve the Service. |
|
Is my Data shared with third parties? |
We use some third-party partners to help us
deliver the Service (e.g., payment processors to facilitate any payments you
may make when using the Service). When we share information with a third-party
partner, this is only done so in accordance with the purposes described in
this Policy. We also share information with our affiliates around the world
who help us deliver the Service. We may also be required under law or by a
law enforcement agency to disclose certain information in some circumstances.
|
|
Where is my Data stored? |
Our servers are located in Singapore. Our
support, engineering and other teams are located in our offices around the
world, including in the People’s Republic of China (for the purpose of this
Policy, it excludes Hong Kong SAR, Macau SAR and Taiwan) (“PRC”) and Singapore. |
|
How long is my Data retained for? |
We generally retain your Data for as long as
you have an account for the Service, after which your information is deleted,
unless otherwise required by applicable laws. |
|
What rights do I have over my Data? |
Depending on where you are located, you may
have certain data subject rights with respect to your Data, such as rights of
access, correction, deletion or objection to the processing of your Data. |
|
How to get in touch with us? |
If you have any questions about this Policy
or want to exercise any rights you may have, please contact us at gameprivacy@lohasgames.com. |
|
How will we notify you of changes? |
Changes to this Policy will be posted here.
Please check this page frequently to see if there are any updates or changes
to this Policy. |
This
section describes the different types of Data we collect from or about you and
your devices, how we use your Data and for how long we store your Data for.
We
collect Data about you from a variety of sources, including:
If
you are located in the United Kingdom, the European Economic Area, Switzerland,
Turkey, Brazil or Thailand (each a “Specified Jurisdiction”), it
also identifies the legal basis under which we process your Data.
|
Use |
Legal Basis (only applicable
if you are located in a Specified Jurisdiction) |
|
|
Account registration information: your email
address, username, user ID and password. |
We use this
information to create your account for the Service in accordance with your
request. |
Necessary for
performance of contract to provide you with the Service. |
|
Social media account data: if you choose to link your social media account (Facebook, Google,
Apple, YouTube, Instagram, Twitter) with the Service, your social media
account ID, access token, referring URL, username, profile picture and
gender. |
We use this
information to: · allow
you to login to the Service using your social media account (if applicable);
and · link
your social media account to the Service so that you may share your in-game
updates / progress on the social media platform. |
Necessary for
performance of contract to provide you with the Service. |
|
[Date of
Birth (not stored)] |
We use your
date of birth to verify your age if you are a user in certain regions. This
is processed device-side only and is not transferred to us. |
N/A |
|
[Email address (for
verification of parental or guardian consent)] |
If you are located in certain regions, we may ask you to provide an
email address for the purpose of verifying parental or guardian consent to
use the Service if you are under the relevant minimum age. |
Necessary for performance
of contract to provide you with the Service. |
|
Location data: general
location data that you select (country/region) and IP address |
[We use this
Data to connect you to our server and to deliver the appropriate version of
the Service to you.] |
Necessary for
performance of contract to provide you with the Service. |
|
Gameplay data: game data and gameplay statistics (level, score/s and their date and
timestamps), log in data (e.g. log in date and time) and in-game consumption
records (if any). |
[We use this Data to provide you
with the Service and to improve your experience of the Service, such as by: · providing
you feedback about your gameplay; · providing
interactive or personalized elements in the Service; · simplifying
the operations process when you launch a certain function; and · enabling
you to find other friends and social contacts.] |
Necessary for
performance of contract to provide you with the Service. |
|
[Payment
transaction data: your
payment transactions records (Open ID, cost, product purchased, IP address,
device details and, if it is a web-based transaction, your email address) if
you conduct any payment transactions within the Service.] [We do not collect your
payment details, such as credit card details, as this is collected by the
third-party payment processor.] |
[We use this
Data to facilitate your payment (which is done via third-party payment
processors) made within the Service.] |
Necessary for
performance of contract to provide you with the Service. |
|
Mobile device identifiers: device ID, advertising ID and MAC address. |
[We use this Data for advertising purposes,
for example in order to: · display
advertising which would be of interest to you; and · measure
the effectiveness of our advertising.] |
[It is in our legitimate
interests to monitor the success of our advertising and marketing programs.] |
|
[Analytics data: data collected from our third-party partners [(Facebook, Google) via a
third-party SDK (Appsflyer)]: · which
users click/view ad campaigns; ·
device information
(IDFA, advertising ID); ·
user engagement
data (purchase behaviour, in-app behaviour); ·
Facebook campaign
ID (where data is collected from Facebook); and · user
search terms and Google Adwords campaign information and identifiers (where
data is collected from Google).] |
We use this information: · for
analytics, profiling and audience measurement; · to
improve our advertising, marketing and promotional activities; · to
develop and display personalised advertising (if applicable) tailored to your
interests on our Service where we think this may be of interest to you; and · to
perform research and analysis about your use of, or interest in, content via
the Service. |
[It is in our legitimate
interests to monitor the success of our advertising and marketing programs.] |
|
[Technical information: your device model,
operating system settings, network type, device ID, and screen resolution.] |
[We use this information: · to improve
our services, including the functionality of the
Service; · for
security, anti-fraud and verification purposes; and · to
identify and address
bugs.] |
It is in our legitimate
interest to ensure the security of our Service, manage registrations and
improve our Service. |
|
[Customer Support Data: username, email address (if you
choose to disclose your email), photo (if you choose to upload one to
illustrate the error), and details of ticket and error.] |
We use this Data to provide customer support services. |
Necessary for
performance of contract to provide you with the Service. |
We have no access to the Data collected
by third parties except to the extent you connect with that third-party service
as part of the Service, and in any event only to the extent provided in this
Policy.
Pursuant to our contract
with you to provide you with the Service, we may process and transfer your Data to countries /
regions that do not provide the same level of data protection. Applicable legal
and regulatory requirements are taken into consideration before any cross-border
transfer of your Data. We apply our global data standards and policies wherever
your Data is stored.
Our
servers for the Service are located in Singapore. We may share your Data with
our affiliates and support, engineering, content moderation, and other
functional teams located in other jurisdictions, including in the PRC and
Singapore, who may have limited access to your Data, for internal, business and
operational purposes and to provide you with the Service. We have
rigorous internal control measures in place to strictly limit data access to
designated personnel only.
By accepting this Policy and
using the Service, you expressly acknowledge and consent to the transfer of
your Data to our affiliates, support teams and/or third parties located outside
of your jurisdiction, including the PRC and Singapore, and acknowledge that
such jurisdictions may not provide the same level of data protection.
We will not share or
transfer any of your Data to any third parties except as explicitly provided
in this Policy and only where necessary. We will only share your Data with
third parties in the following circumstances:
|
Third Parties |
Purpose |
|
Our
corporate affiliates |
To facilitate the provision of the Service to you, we
may share your Data with our affiliates and members of our corporate group.
All affiliates and related group companies may only use your Data in
accordance with this Policy. |
|
In the
context of a transaction, including mergers, acquisitions or asset sales |
We may transfer your Data to another legal entity for
the purpose of a collaboration, joint venture, corporate reorganization,
change of legal form or other similar event. In order to develop our
business, we may engage in transactions such as mergers, acquisitions, sales
and asset transfers. In these circumstances, we will inform you of the
related circumstances, and will continue to protect or require the successor
to protect your Data in accordance with applicable laws and regulations and
this Policy. |
|
Third
parties in support of the Service |
We may engage third parties, such as professional
advisors, auditors, lawyers and accountants, to perform functions on our
behalf or to provide services to us. We share your Data with these service
providers and also third parties for purposes such as hosting or operating
our Service, sending e-mail communications, rewards vouchers, marketing and
data analysis, transaction processing and market research. We may share your
Data with third parties in order for them to provide content or otherwise
perform services on our behalf, and we will require such parties to maintain
appropriate security to protect such Data from unauthorized access or
processing. |
|
Legal,
regulatory, law enforcement, government and tax agencies |
In circumstances where we are legally required to
disclose information about you to authorities, such as to comply with a legal
obligation or processes, we may transfer your Data to local or overseas
bodies or authorities such as legal, regulatory, law enforcement, government
and tax authorities, all in accordance with applicable laws and regulations.
Such disclosures may be made with or without your consent, in compliance with
applicable laws. We may also have to transfer your Data to third parties when
they receive a request by an authority empowered by law to do so, pursuant to
applicable laws and regulations. |
|
Advertisers
and third party measurement companies |
Where advertising services are available to users, we
share aggregate information which no longer contains personal data with
advertisers and third-party measurement companies to show how many and which
users of our platforms have viewed or clicked on an advertisement. We never
share Data about you with advertisers without your consent. |
|
Social Media
Platforms |
We also share certain information about you with your
selected social network account to ensure authorized use and access to your
social media account. |
|
Promotions |
If you choose to register for a promotion, such as a
competition, sweepstake, lucky draw, contest or user incentive program, your
Data may be disclosed to third parties for the purpose of administration of
such promotion. |
|
Other Business Partners |
Where shopping features are available, our business
partners may offer goods or services to you through the Service. When you
interact with or order such goods and/or services, we will share your Data
such as your user ID and username with such business partners to facilitate
your transactions and to show you the status of orders made through the
Service. |
If you submit certain information on the
Service, any such information that is meant to be shown to the public on Kwai
will be disclosed publicly. This Policy does not apply to third-party uses of
any such information after it is uploaded and displayed on the Service.
We may share your anonymized
data with other parties not listed above. If we do this you won’t be
identifiable from this data, i.e. it no longer contains personal data.
Except as otherwise provided
in this Policy, we will not disclose any of the Data collected from your use of
the Service to the public. If public disclosure is required by applicable laws
and regulations, we will inform you of the purpose of the disclosure and the
type of disclosed information.
We do not keep your Data for
longer than is necessary unless we are required to do so under applicable laws.
See below for the durations for which we retain your Data:
|
Data |
Retention Period |
|
Account
registration information [Social
media account data] [Email
address (for parental / guardian consent verification)] Location
data Gameplay
data [Payment
transaction data] Geolocation
data Mobile
device identifiers Analytics
data [Technical
information] Customer
support data |
Stored
for as long as you maintain an account and use the Service. If you
request for account deletion, your Data will be deleted within [30] days of
your request. |
|
[Date of
birth] |
We do
not store this. |
If we are required to retain your information
beyond the retention periods set out above, for example to comply with
applicable laws, we will store it separately from other types of Data.
We will take appropriate
technical and organizational measures to help protect and secure your Data. We
will protect your Data against unauthorized or unlawful processing, accidental
loss, destruction or damage through these measures,
including:
·
using encryption techniques;
·
establishing specialized systems
and procedures, such as strictly limiting the scope of personnel with access to
your Data, and requiring those who have such access to comply with related
confidential obligations; and
·
establishing a specialized
department in charge of information safety. In case of events such as
information leakage or data or security breach, we will take timely measures to
deal with such events, and we will notify you promptly in an appropriate
manner, including through messages or announcements.
While we are committed to protecting
your Data, no electronic data transmission or storage of information can be
completely secure. Therefore, although we take appropriate technical and organizational steps to
secure your Data, we do not guarantee, and you should not
expect, that your Data will always remain secure. If you do not agree to these
risks and conditions, you must discontinue your use of the Service.
Depending on where you are located, you
may have certain legal rights to your Data (which may include access,
correction, deletion or other rights). This section entitled “Your Rights” applies to users
that are located in the Specified Jurisdictions. If you are not located in these jurisdictions, please refer to the COUNTRY / REGION SPECIFIC TERMS for an overview of your rights
and how they can be exercised.
We must respond to a request by you to exercise those rights
without undue delay and at least within one month (though this may be extended
by a further two months in certain circumstances). To exercise any of your
rights, please contact us at gameprivacy@lohasgames.com.
|
Data
Subject Right |
Description |
|
Access and
information |
You have the right to access Data we hold about you,
how we use it, and who we share it with. You have the right to be informed in
a concise, transparent, intelligible and easily accessible form of the way in
which your Data is processed. You also have the right to obtain confirmation
as to whether or not Data concerning you is being processed, and, where that
is the case, to access such Data and obtain a copy thereof. You can access
the Data you have made available as part of your account by emailing us at gameprivacy@lohasgames.com. |
|
Restrict
processing to storage only |
You have a right to require us to stop processing the
Data we hold about you other than for storage purposes in certain
circumstances. Please note, however, that if we stop processing the Data, we
may use it again if there are valid grounds under data protection laws for us
to do so (for example, for the defence of legal claims or for another’s
protection). As above, where we agree to stop processing the Data, we will
try to tell any third party to whom we have disclosed the relevant Data so
that they can stop processing it too. |
|
Objection |
You have the right to object to our processing of your
Data. To the extent provided by applicable laws and
regulations, you may withdraw any consent you previously provided to us for
certain processing activities. Where consent is required to process your
Data, if you do not consent to the processing or if you withdraw your consent
we may not be able to deliver the expected service. |
|
Portability |
You may receive a copy of certain Data we process about
you, including any Data we process on the basis of your consent or pursuant to
our contract with you, as described above in the section “Data We Collect and How We Use Your Data”. This Data should be provided in a structured,
commonly-used and machine-readable format. You also have the right to request
that we transfer that Data to another party, with certain exceptions. If you
wish for us to transfer such Data to a third party, please ensure you detail
that party in your request and we will do so where it is technically
feasible. For example, in the event that providing that Data about you would
interfere with another’s rights, we may not be able to provide you with such
Data. We will provide further information to you about this if you make such
a request. |
|
Rectification |
You have the right to request us to rectify the Data we
hold about you in the event that it is inaccurate. You also have the right to
have incomplete Data completed. You can access the Data we hold about you by
emailing us at gameprivacy@lohasgames.com. |
|
Deletion |
In certain circumstances, you have the right to delete
the Data we hold about you. You can delete your account, or remove certain
Data, by emailing us at gameprivacy@lohasgames.com. However,
there may be instances where we need to retain Data if there are valid
grounds under data protection laws for us to do so and we will notify you in
such an event. Following your request to delete publicly-available Data, we
will try to take reasonable steps to inform others displaying the Data to
delete it too. |
Once you have completed your account
registration and have in place reasonable and necessary authentication measures, you
can review, modify, and delete the Data you submit to us. In general, you can
browse, modify, and delete your own information at any time, but you may not be
able to modify certain initial registration information and verification
information provided at the time of registration for security and
identification purposes.
We may from time to time send you announcements when we consider it
necessary to do so (for example, when we temporarily suspend access to the
Service for maintenance, or security, privacy or
administrative-related communications). You may not opt out of these
service-related announcements, which are not promotional in nature.
If our Service or operations terminate, we will
notify you at least 30 days in advance and delete or anonymize your Data after
the termination.
Cookies are pieces of information
that any website or app may transfer to your browser that are then stored in
your computer or mobile system. For example, the deposit of cookies enhances
your online experience by allowing us to save your preferences.
You can contact us at any time via
in-app access for feedback or complaints or through the details below. We will
verify your identity before we disclose or make any changes to your Data.
Lohas games Pte. Ltd
·
Address: 1 Raffles Place #36-01 One Raffles Place Singapore 048616
·
Email: gameprivacy@lohasgames.com
We will use our best efforts to respond
to your request as soon as possible and this is without prejudice to any right
you may have under data protection laws to launch a claim with a data
protection authority in your country / region if you think we have breached
data protection laws.
We may revise the terms herein at any time, and such revisions shall
constitute a part of this Policy. We will inform you by means such as prompting
on a prominent location of the home page or sending a notification to you when
you log in or app updates of the changes to the Policy.
Any revisions will become effective on the next day after notification
and will apply to all your Data.
Minors must not use the Service, except where valid parental / legal
guardian consent has been provided.
By minors, we mean users who are under the age of 16 or the relevant
legal minimum age of majority in your country / region, as defined under
applicable laws (“Minimum Age”).
If you are a minor in your country or region, your use of the Service
may be subject to age restrictions imposed by third-party vendors. You may be
unable to use third-party vendor services without the assistance of your parent
or legal guardian. For users located in certain countries we have listed the
relevant Minimum Age below.
If you are under the Minimum Age, you undertake that you have obtained
your parent or legal guardian’s consent to register an account on and use the
Service.
|
Country / region in which the user is located |
Minimum age |
|
Algeria |
19 |
|
Argentina |
13 |
|
Australia |
18 |
|
Bangladesh |
18 |
|
Brazil |
18 |
|
Colombia |
18 |
|
Cambodia |
18 |
|
Canada |
13 |
|
Egypt |
18 |
|
European Economic Area |
16 |
|
Hong Kong |
18 |
|
Indonesia |
21 |
|
Japan |
18 |
|
Kuwait |
21 |
|
Macau |
18 |
|
Malaysia |
18 |
|
Mexico |
18 |
|
Morocco |
18 |
|
Myanmar |
18 |
|
New Zealand |
16 |
|
Nigeria |
13 |
|
Philippines |
18 |
|
Qatar |
18 |
|
Russia |
14 |
|
Saudi Arabia |
18 |
|
Serbia |
15 |
|
Singapore |
13 |
|
South
Africa |
18 |
|
South Korea |
18 |
|
Sri
Lanka |
18 |
|
Switzerland |
16 |
|
Taiwan |
20 |
|
Thailand |
20 |
|
Tunisia |
18 |
|
Turkey |
18 |
|
United Arab Emirates |
21 |
|
United Kingdom |
13 |
|
United States |
13 |
|
Vietnam |
16 |
We do not knowingly collect Data from minors. If you learn that a minor
has registered for an account or is using the Service without having first
obtained their parent or legal guardian’s written consent, please alert us at gameprivacy@lohasgames.com. We will promptly verify, take
steps to remove such minor’s Account information from the Service and terminate
the minor’s account.
Before
your child can use the Service, you will need to provide your consent to
approve your child’s account set-up and the processing of their personal
information.
|
FAQ |
|
|
What Data does Lohas games process? |
Lohas games is a platform consisting of a number of different
individual games. If your child successfully signs up to Lohas games, this
will result in the collection and sharing of certain personal information:
For more details on what personal information we
collect and how we use and process the information, please review our Privacy Policy . |
|
Is Lohas games different depending on whether a
user is a child or an adult? |
[Yes. In some jurisdictions, children will not be
able to access certain features] [No. Lohas games is the same whether the
user is a child or an adult.] |
|
What is the reason for my consent? |
Certain jurisdictions require or recommend the consent
of a parent or legal guardian before their child can sign up to a game such
as Lohas games, where personal information will be processed. If you do not
consent, or withdraw your consent, we will immediately delete any personal
information collected up to that point. |
|
How do I verify my child’s
account? |
We will not allow a child to
sign-up without first obtaining verifiable consent from that child’s parent
or legal guardian. As part of this, we need to verify that you are an adult
capable of providing such consent. We do not process your credit card
information – only the third party payment processor collects credit card
information. The credit card information is not retained for any reason,
including future purchases or connected to in-app payment functions (if any)
in the game. |
|
What if there are changes to Lohas games in the future? |
If we make any changes to the way their personal information is
processed, we will notify you of those changes. You must consent to those
changes before your child’s personal information will be processed for that
new purpose. |
|
Will you retain my Data? |
We will keep a record of your email address so that we can notify you
of any changes to the processing of your child’s personal information, and so
that we know you are a parent or legal guardian of a player when you contact
us. Your credit card information is not processed by us, but instead only
processed by a third party payment processor. We do not have access to your
credit card information. |
|
What if I do not consent? |
If you do not consent
(including by providing your credit card details for verification)
then your contact information will be deleted. |
|
How do I
withdraw my consent or delete my child’s account? |
You can withdraw your consent or delete your
child’s account by emailing us at gameprivacy@lohasgames.com. You can also request a copy of your child’s
personal information at any time. |
This Policy is drafted in the English language. If
this Policy is translated into any language other than English, the English
version shall prevail to the extent of any inconsistency, unless otherwise
required under applicable laws and
regulations and as set out in the COUNTRY / REGION SPECIFIC TERMS.
The contact details of our local data protection
representatives in certain jurisdictions are set out below.
|
Jurisdiction |
Representative
|
Address |
Contact
details |
|
/ |
/ |
/ |
/ |
These Country / Region Specific Terms are incorporated by
reference and form part of the Policy. This section sets out additional terms
under certain countries / regions for users of the Service. If you are a user
located in one of the countries / regions below, the terms set out below under
the name of your country / region apply to you in addition to the terms set out
in our Policy above.
Argentina
If you are dissatisfied with how we dealt with your
request to exercise your data subject rights (access to, correction or erasure
of your Data) or you wish to make a privacy complaint in respect of your Data,
you may contact the Agency for Access to Public Information at: Av. Pte. Gral.
Julio A. Roca 710, Piso 2°, Ciudad de Buenos Aires (Telephone: +5411 3988-3968
or email: datospersonales@aaip.gob.ar).
Australia
Where practicable,
we will give you the option of not identifying yourself or using a pseudonym
when registering an account on or using the Service.
If you are dissatisfied with how we dealt with your
request to exercise your data subject rights (access to or correction of your
Data) or you wish to make a privacy complaint in respect of your Data, you may
contact the Office of the Australian Information Commissioner (Telephone: +61
1300 363 992 or email: enquiries@oaic.gov.au).
California
This section
applies to California residents covered by the California Consumer Privacy Act
of 2018 (“CCPA”).
Collection
and Disclosure of Personal Information
Over the past 12 months, we have collected and
disclosed the following categories of personal information from or about you or
your device:
We collect your personal
information for the following purposes:
For additional information about what each type of personal information
is used for, see the main portion of the Policy.
We disclose personal information
to the following types of entities:
In the past 12 months, we have not sold Personal
Information of California residents within the meaning of “sold” in the CCPA.
Rights
under the CCPA
If you are a
California resident, you have the right to:
We aim to fulfil
all verified requests within 45 days pursuant to the CCPA. If necessary,
extensions for an additional 45 days will be accompanied by an explanation for
the delay.
How
to Exercise Your Rights
First, you may
wish to log into your account and manage your data from there. If
you are a California resident to whom the CCPA applies, you may exercise your
rights, if any, regarding other data by contacting us at gameprivacy@lohasgames.com.
Canada
If you wish to understand more about
our policies and practices with respect to our service providers located
outside Canada, you may email us at gameprivacy@lohasgames.com. Where we use
service providers who might have access to your Data, we require them to have
privacy and security standards that are comparable to ours.
We use contracts and other measures
with our service providers to protect your Data and to ensure it is only used
for purposes as provided in this Policy.
Colombia
Your
consent for us to process your Data for the Service may be (i) in writing; (ii)
expressed orally; or (iii) through unequivocal conduct that allows us to
reasonably conclude that your authorization has been granted, such as the act
of accepting the Policy. We may keep a record of your consents as evidence,
while respecting the principles of confidentiality and privacy of information.
You
have the right (i) to request access to, update and rectify your Data; (ii) to
request a copy of the consent you have given us; (iii) to be informed about how
we have processed your Data; (iv) to file claims before your country’s data
protection authority; (v) to revoke the consent you have given us to process
your Data, unless the processing is based on compelling legitimate grounds or
is needed for legal reasons; (vi) to ask for the suppression of your Data
(right to erasure); and (vii) to freely access your information.
Egypt
You acknowledge your consent to
receiving marketing messages from us (e.g. through emails, pop-up
notifications).
If you are a new user, you have a
right to inform us of any objection to this Policy within seven days.
As an Egyptian data subject, you have certain rights
under the Egyptian Personal Data Protection Law.
France
You may provide us with general or specific instructions
for the retention, deletion, and communication of your Data after your death. Such instructions are only
valid for such processing activities, are subject to your specific consent and
you may amend or revoke your instructions at any time.
You
may appoint a person responsible for carrying out your instructions. This
person will be informed of your instructions and may request us to implement
your instructions in the event of your death. In the event of the death of the
appointed person, their heirs will have the right to be informed of your
instructions and to request their implementation from us.
Hong Kong
You
have the right to request a copy of the data we process about you, request we
correct your Data and to object to the use of your Data for direct marketing
purposes. A small fee may be chargeable by
us for complying with a data access request.
Indonesia
Where the confidentiality
of your Data has been compromised, we will notify you through the contact
information provided by you or via the Service, to the extent required by local
laws and regulations.
You are
responsible for making sure that any Data which you provide to us are accurate
and current. To confirm the information’s accuracy, we may also verify the
information provided to us, at any time. You represent that you have secured
all necessary consent(s) before providing us with any other person’s Data, in which
case we will always assume that you have already obtained prior consent, and as
such, you will be responsible for any claims whatsoever from any party arising
as a result of the absence of such consent(s).
Japan
By
clicking “accept”, you consent to the transfer of your Data to third parties
(if any), which may include the cross-border transfer of your information to
any country where we have databases or affiliates and, in particular, to the jurisdictions specified in the
section “Data
Storage and International Data Transfers”.
The
categories of Data collected may include "special care-required personal
information" (i.e., sensitive information as detailed under the Act on the
Protection of Personal Information of Japan), and you consent to the collection
of such information.
You may request us to
notify you about the purposes or use of, to disclose, to make any correction
to, to discontinue the use or provision of, and/or to delete any and all of
your personal information which is stored by us, to the extent provided by the
Act on the Protection of Personal Information of Japan.
Kingdom of Saudi Arabia
By accepting this Policy,
you consent to the collection, use, disclosure, export and storage of your Data
as described in this Policy including, but not limited to, for the purposes of
displaying personalised advertising when you use the services.
Macau
SAR
You have the right to
request access to and receive a copy of your Data, correct your Data and to
object to the use of your Data for marketing or any other form of commercial
prospecting, or on any grounds of personal nature. A fee may be chargeable by
us for complying with a data access request.
Malaysia
You have the right to request access to and obtain a copy of your
Data, correction of your Data and limit the processing of your Data. We reserve the right to impose a fee for providing access
to your Data in the amounts as permitted under law and to request for certain
information to verify the identity of the requester to ensure that he/she is
the person legally entitled to make the data access request.
We have appointed the
following department responsible for managing and protecting your Data and to
handle any complaints you may make in respect of your Data.
Mexico
Some of the purposes of processing specified in
the section “Data We Collect and How We Use Your Data” are optional, which may include to
show you personalised advertising.
[You can register with
the Public Registry to Avoid Advertising (‘REPEP’) (REPEP (profeco.gob.mx)) to
refuse to receive advertising to your phone number.]
New Zealand
Whilst
we take reasonable steps to ensure that third parties outside New Zealand
process your Data in such a way which is consistent with this Policy and with
New Zealand privacy laws, you acknowledge that we do not control, or accept
liability for, the acts and omissions of these third-party recipients.
You
have the right to request access to Data we hold about you, how we use it, and
who we share it with. You have the right to request the correction of your Data
if it is inaccurate.
If you are dissatisfied with how we
dealt with your request to exercise your data subject rights (access to or
correction of your Data) or you wish to make a
privacy complaint in respect of your Data, you may contact the Office of the
New Zealand Privacy Commissioner (www.privacy.org.nz).
Peru
You have the right to
request access to and receive a copy of your Data, correct your Data, delete or
suspend the processing of your Data, pursuant to Peru’s
Personal Data Protection Law. You may also exercise these rights through your
legal guardian or someone who has been authorised by you to exercise the right.
However, in this case, you must submit a power of attorney to us in accordance
with the Law.
You
can also withdraw your consent or demand a suspension of the Data processing at
any time.
If you are
dissatisfied with how we dealt with your request to exercise your data subject
rights
or you wish to make a privacy complaint in respect of your
Data, you may file a claim with the Peruvian National Authority of Personal
Data Protection.
Philippines
You
have the right to be informed, request access to and receive a copy of your
Data, correct your Data, suspend, withdraw or seek the blocking, removal or
deletion of your Data, and, in some circumstances, to object to the processing
of your Data (including for direct marketing, automated processing or profiling
purposes).
By
consenting to this Policy, you consent to the collection and processing of your
Data (as mentioned in the section “Data We Collect and How We Use Your Data”),
sharing of your Data with our affiliates and third parties outside of your
jurisdiction (as mentioned in the section “Third Parties Whom We May Disclose or Transfer your Data To”).
South Korea
Your Data is shared with the following third
parties:
|
Recipient
Name and Contact |
Data
Provided |
Use by
Recipient |
Retention
Period |
|
/ |
/ |
/ |
/ |
To provide the Service,
we delegate the processing of your personal information to the following
service providers:
|
Delegatee |
Delegated Services |
|
/ |
/ |
Transfer
of Data Overseas
We transfer Data to third parties overseas as follows:
|
Recipient |
Destination
Country |
Date and
Method of Transfer |
Types of
Data Transferred |
Use by
Recipients |
Retention
Period |
|
/ |
/ |
/ |
/ |
/ |
/ |
Data
Deletion
Data is
retained in accordance with the retention periods set out in the section “Data Retention”. Save for the Data set out below,
Data
will be destroyed in an irreversible way once the retention period is reached.
Data which is stored electronically will be deleted safely in an irreversible
way by using technical methods, and printed Data will be destroyed via
shredding or by incineration.
The Data detailed in section “Data Retention” are required to be retained
pursuant to the following laws:
|
Act on the Consumer Protection in Electronic Commerce, Etc. |
Article 6 of the Act on the Consumer Protection in Electronic Commerce |
In an electronic commerce or a mail-order sale: ·
Records
regarding labelling and advertising (6 months) ·
Records regarding
execution or withdrawal of a contract (5 years) ·
Records
regarding the payment of a price and the supply of goods and services (5
years) ·
Records
regarding customer services or dispute resolution (3 years) |
|
Protection of Communications Secrets Act |
Article 41 of the Decree of the Act, Article 15-2 of the Protection of
Communications Secrets Act |
·
Log
records, IP address (3 months) ·
The date
of telecommunications by users, the time that the telecommunications start
and end, the frequency of use (12 months) |
Data Subject Rights
Pursuant to applicable laws, such as the Personal Information
Protection Act (“PIPA”), you may request for access, correction, deletion or
suspension of processing of your Data. If you choose to exercise these rights
through your legal guardian or someone who has been authorized by you to
exercise the right, you must submit a power of attorney to us in accordance
with the Enforcement Regulations of the PIPA. You can also withdraw your
consent or demand a suspension of the Data processing at any time.
Additional Use and
Provision of Data
In accordance with the PIPA and in consideration of whether
disadvantages have been caused to data subjects and whether necessary measures
have been taken to secure such as encryption, we may use or provide Data for
purposes which are reasonably related to the initial purpose of the
collection. We will determine with due care whether to use or provide Data
in consideration of general circumstances including relevant laws and
regulations such as the PIPA, purpose of use or provision of Data, how Data
will be used or provided, items of Data to be used or provided, matters to
which data subjects provided consent or which were notified/disclosed to data
subjects, impact on data subjects upon the use or provision, and measures taken
to protect subject information. Specific considerations are as follows:
Domestic Privacy
Representative & Contact
Pursuant to the Article 32-5 of Network Act and Article
39-11 of the amended PIPA, our domestic privacy representative’s details are
set out in the section “Local Representatives”.
To protect your Data and
handle complaints relating to your Data, we have appointed the following department responsible for
managing and protecting your Data:
Russia
The Service
is not targeted at Russian users or the Russian market and, in particular, is
not available in Russian. However, if you happen to be using the Service in
Russia, this section “Russia” applies to you.
By using
the Service you consent to:
We will
notify you of any material changes and may request you to acknowledge such
changes. Unless we require your acknowledgment, you shall be deemed to have
agreed to the changes if you continue using the Service after the notification.
Separate
Consent for Using Certain Data
To provide
the Service, we do not publicly disclose Data without your valid consent and in
compliance with the requirements of Article 10.1 of Russian Federal Law No.
152-FZ dated 27 July 2006 “On Personal Data” (as amended).
By using
the Service you also consent to the sharing of your Data with certain third
parties as outlined in the section “Third Parties Whom We May Disclose or
Transfer your Data To”.
It is up to
you to decide the terms of disclosure to the general public of your Data, by
choosing to use certain features of the Service and by choosing the appropriate
privacy settings in respect of your Data in the Service.
We process
your Data subject to the terms of this Policy and your chosen features and
settings.
This
consent is granted for as long as you use the Service. The consent may be
withdrawn by you (and you may set any restrictions on processing of your
relevant Data).
If you have
any questions, complaints, would like to exercise your Russian data subject
rights or would like to withdraw your consent, you may contact us at gameprivacy@lohasgames.com. Please include the word “Russia” in the
subject line of your email.
Serbia
For the purposes of complying with the Law on Personal
Data Protection, the identity and contact details of our local data protection
representative is set out in the section “Local Representatives”. Please include the word “Serbia” in the subject line
of your email.
Singapore
As a Singapore data
subject, you have the right to request access to or correct your Data and be
informed of how we use it and who we share it with.
Our designated data
protection officer for the purposes of compliance with the Personal Data
Protection Act 2012 can be contacted as gameprivacy@lohasgames.com.
South Africa
You have the right to lodge a complaint with the
Information Regulator (South Africa) by emailing it at inforeg@justice.gov.za. The Information Regulator
(South Africa)’s physical address is 33 Hoofd Street Forum III, 3rd Floor
Braampark, Braamfontein, Johannesburg, South Africa.
Taiwan
We do
not knowingly collect Data from persons under the age of 7 or knowingly allow
such persons to use the Service. If you are under 7 years of age, please do not
attempt to use or register for our Service or send any Data about yourself to us. No one under the age of 7 may
provide any Data to us while using the Service. If you are
located in Taiwan, persons under the age of 20 are required to obtain
parental/guardian consent prior to using the Service.
Thailand
To the extent provided for under the Thai
Personal Data Protection Act (PDPA), you have the right to:
· withdraw your consent to the processing of
your Data (only where the legal basis for our processing is consent); however,
where consent is required to process your Data, we may not be able to deliver
the Service without it;
· request access to, correct, cease any
automated processing or profiling (if applicable), discontinue, restrict the
use or provision of and/or delete your Data;
· request us to provide you or a third party
with your Data which is stored by us in a machine readable format; and/or
· lodge a complaint with a relevant authority.
Where you wish to make such requests, please
contact us at gameprivacy@lohasgames.com .
The contact details of our designated local
representative in Thailand for the purpose of compliance with the PDPA is as set out in the section “Local Representatives”. Please include
the word “Thailand” in the subject line of your email.
Turkey
Details of
our local representative in Turkey for the purpose of compliance with Turkish
Law on Personal Data Protection Law (“DPL”) and its
secondary regulations is set out in the section “Local Representatives”.
As a Turkish data subject, you have legal rights set forth in Article 11 of the DPL in relation
to the Data we hold about you. You have the right to:
In accordance with
Article 9 of the DPL, your Data may be transferred outside Turkey:
|
Overseas Recipient |
Location |
Use by Recipient |
Data provided |
|
/ |
/ |
/ |
/ |
United Arab Emirates
You consent
to the collection, use, disclosure, transfer, export (to the extent permitted
by applicable laws) and storage of your Data, as described in the Policy,
including, but not limited to, for the purposes of showing you personalised
advertising when you use the Service.
Where a
cyber-security incident constitutes a crime under UAE law (e.g. under the UAE
Cybercrime Law), we may report it to the relevant authorities for the purpose
of investigations. Please note that voluntary reporting of a cyber-security
incident can also be made to the UAE Computer Emergency Response Team (“CERT”). CERT is a security awareness
organisation that facilitates the logging of incidents and advises on known
cyber-security threats in the UAE.
Vietnam
You have the right
to request access to, correction of, and deletion of the Data we hold about
you. You also have the right to withdraw your consent to collect, store,
process, use and disclose your Data and to request us to stop providing your
Data to a third party.