Privacy Policy
1. Who We Are and How to Contact Us
For purposes of applicable data protection laws, we are the controller of personal data that we determine how and why to process.
Data Controller: Hong Kong National Interactive Technology Co., Ltd. (HK ATP INTERACTION TECHNOLOGY LIMITED)
Address: Rm 20, Unit B3, 07/F, Tuen Mun Industrial Centre, 2 San Ping Circuit, Tuen Mun, Hong Kong
Email: [email protected]
You may contact us at the email address above for privacy questions, requests to access or delete your data, or other privacy-related concerns.
2. Personal Data We Collect
Depending on the Service, platform, features you use, your device settings, and your privacy choices, we may collect the following categories of data.
2.1 Account and game data
- A game-specific or player-specific identifier, including an identifier created for guest users.
- Nickname or profile information that you choose to provide.
- Game progress, level, inventory, virtual currency balances, achievements, settings, in-game actions, event participation, and other gameplay records.
- If sign-in with Apple, Google, Facebook/Meta, or another login provider is enabled and you choose to use it, identifiers and basic profile information made available by that provider in accordance with your settings and permissions.
2.2 Device, technical, and network data
- Device model, manufacturer, operating system and version, language, time zone, app version, and similar technical information.
- Internet Protocol (IP) address and approximate location derived from IP address, such as country or region.
- Advertising identifiers, such as Apple's Identifier for Advertisers (IDFA) or Google Advertising ID (GAID), where available and permitted.
- Other app or device identifiers that may be generated or accessed by our software or service providers, such as Android ID, Identifier for Vendors (IDFV), Firebase Installation ID, push notification tokens, or similar identifiers, depending on platform and configuration.
- Diagnostic information such as crash reports, error logs, performance data, network status, and technical events.
Our games do not require precise GPS location unless a specific Service expressly requests it and obtains any permission required by applicable law and the device platform.
2.3 Purchase and transaction data
If you make an in-app purchase, we may receive transaction information from Apple App Store, Google Play, or another authorized platform, such as product identifier, purchase or transaction identifier, price, currency, purchase time, payment status, refund status, and information needed to verify and fulfill the purchase. We do not receive your full payment card number from Apple or Google for standard in-app purchases.
2.4 Analytics, attribution, and marketing data
We may collect app installation data, sessions, events, campaign and referral information, advertising identifiers where permitted, and related device or technical data to understand how our Services are used, measure marketing campaigns, prevent advertising fraud, and improve our games.
2.5 Customer support and communications
If you contact customer support, we may collect your email address, player identifier, messages, attachments you choose to provide, support ticket history, relevant account or transaction information, and technical or gameplay information reasonably necessary to investigate and resolve your request. Our Services may use our own customer-support software development kit (SDK) to support these functions.
2.6 Website data
If you visit our websites, we may collect IP address, browser and device information, pages visited, timestamps, and cookie or similar technology data. Where required by law, non-essential cookies or similar technologies will be used only after the required consent.
3. How We Use Personal Data and Our Legal Bases
We use personal data for the purposes below. For users in the European Economic Area (EEA), the United Kingdom, and other jurisdictions that require a legal basis, the corresponding legal bases may include performance of a contract, our legitimate interests, compliance with legal obligations, and consent.
| Purpose | Typical legal basis where required |
|---|---|
| Provide the game, create and maintain player records, save progress, deliver virtual items, and provide requested features. | Performance of a contract / steps requested by you. |
| Process and verify in-app purchases, refunds, and related transaction issues. | Performance of a contract; legal obligations; legitimate interests in preventing fraud and maintaining accurate transaction records. |
| Provide customer support and investigate player requests. | Performance of a contract; legitimate interests in operating and supporting the Services. |
| Maintain security, prevent cheating, fraud, abuse, unauthorized access, and protect our Services and users. | Legitimate interests; legal obligations where applicable. |
| Measure performance, analyze gameplay, fix bugs, balance features, and improve the Services. | Legitimate interests or consent, depending on the technology and applicable law. |
| Measure advertising campaigns, attribution, audience performance, and marketing effectiveness. | Consent where required; otherwise legitimate interests where permitted by law. |
| Comply with law, respond to lawful requests, establish or defend legal claims, and enforce our rights. | Legal obligations; legitimate interests. |
Where applicable law requires consent for analytics, advertising identifiers, tracking, cookies, or similar technologies, we will seek that consent before using those technologies for the relevant purpose. You may withdraw consent through available privacy or device settings, or by contacting us. Withdrawal does not affect processing that was lawful before withdrawal.
4. Third-Party Services and SDKs
We use service providers to operate, analyze, secure, support, and market our Services. Not every provider or feature is enabled in every game. Depending on the Service, providers may include:
- ThinkingData / ThinkingEngine — gameplay and product analytics, including player identifiers, game events, game economy data, and technical information configured by us.
- Google Firebase — services that may include Analytics, Crashlytics, Cloud Messaging (FCM), Remote Config, and Authentication, depending on the Service. These services may process app usage, installation identifiers, crash or diagnostic data, notification tokens, and authentication data.
- Adjust — mobile attribution, campaign measurement, fraud prevention, and analytics. Adjust may process advertising identifiers where available, IP address, device/app information, install data, and in-app event data configured by us.
- Meta / Facebook — services that may include Meta App Events for advertising measurement and attribution, and Facebook Login where enabled. Depending on configuration and your choices, Meta may receive app events, advertising identifiers where permitted, technical data, and login/profile information if you use Facebook Login.
- Apple and Google — app distribution, in-app purchases, platform authentication where enabled, and related platform services.
- Our customer-support systems — our own systems and software used to receive support requests, investigate issues, and respond to players.
These providers process data under their own terms and privacy documentation, and some may act as our processors while others may act as independent or joint controllers for certain processing activities. We encourage you to review the privacy information provided by the relevant platform or provider.
5. How We Share Personal Data
We may disclose personal data only as reasonably necessary for the purposes described in this Privacy Policy, including to:
- cloud hosting, analytics, attribution, customer support, security, fraud prevention, and other service providers;
- Apple, Google, Meta, and other platform or technology providers used by a particular Service;
- professional advisers such as legal, accounting, audit, and insurance providers where necessary;
- law enforcement, regulators, courts, or other authorities where required or permitted by law;
- a successor or prospective successor in connection with a merger, acquisition, financing, reorganization, or sale of all or part of our business, subject to appropriate safeguards.
We do not sell personal data for money. However, some privacy laws may define certain disclosures of identifiers or app activity to advertising or measurement partners as "sharing," "targeted advertising," or similar activity. Where such laws apply, we provide the rights and choices required by law.
6. Advertising, Attribution, and Tracking Choices
We may use Adjust, Meta, Google, or similar services to measure how users discover and engage with our games and to evaluate or optimize our advertising campaigns. This may occur even where a particular game does not display third-party advertisements inside the game.
On Apple devices, access to the IDFA and certain forms of tracking are subject to Apple's App Tracking Transparency (ATT) framework. On Android and other platforms, you may be able to reset, delete, or limit use of advertising identifiers through your device settings. Where applicable law requires additional consent or opt-out rights, we will honor those requirements.
7. International Data Transfers and Storage
Our Services are offered internationally. Our primary game account, save-data, analytics, and customer-support infrastructure is generally hosted in Singapore, while our service providers may process data in Singapore, the United States, the EEA, or other countries and regions where they operate.
Accordingly, your personal data may be processed outside the country or region where you live. Where applicable law requires safeguards for international transfers, we use or rely on appropriate legal mechanisms available for the relevant transfer, which may include adequacy decisions, approved standard contractual clauses, contractual and technical safeguards, or other lawful transfer mechanisms.
8. Data Retention
We retain personal data only for as long as reasonably necessary for the purposes described in this Privacy Policy.
- Gameplay, analytics, diagnostic, and customer-support records are generally retained for up to 12 months, unless a longer or shorter period is reasonably necessary for the relevant purpose.
- Account identifiers and game progress may be retained while an account or persistent player profile remains active, and for a limited period afterward to support recovery, security, dispute handling, or deletion processing.
- Transaction, refund, anti-fraud, tax, accounting, and legal records may be retained longer where required by law or reasonably necessary to establish, exercise, or defend legal claims.
When data is no longer needed, we delete it, anonymize it, or otherwise remove it from active use in accordance with our retention processes.
9. Your Privacy Rights and Choices
Depending on where you live, you may have rights regarding your personal data. These may include the right to request access, correction, deletion, restriction, portability, or objection to certain processing, and the right to withdraw consent where processing is based on consent.
Residents of the EEA or United Kingdom may also have the right to lodge a complaint with their local data protection supervisory authority. We do not make decisions that produce legal or similarly significant effects about you solely through automated processing.
Residents of certain U.S. states may have rights to know or access personal information, request deletion or correction, obtain a portable copy, and opt out of certain sale, sharing, targeted advertising, or profiling activities, subject to applicable law. We will not discriminate against you for exercising a privacy right.
To exercise a privacy right, contact [email protected]. We may need to verify your identity and may request information reasonably necessary to locate your account or records. We will respond within the timeframe required by applicable law.
10. Account and Data Deletion
You may request deletion of your game account or associated personal data by emailing [email protected]. Please include the game name, your player identifier if available, and enough information for us to identify the relevant account or data.
After we verify the request where reasonably necessary, we will delete or anonymize personal data associated with the account, except information that we must or are permitted to retain for legal, accounting, fraud prevention, security, dispute resolution, or other legitimate purposes.
If a Service offers an in-app account deletion feature, you may also use that feature. Deleting your game account does not automatically delete an Apple, Google, Facebook/Meta, or other third-party account that you use to sign in.
11. Children's Privacy
Unless a specific Service expressly states otherwise, our Services are not directed to children under 16, and we do not knowingly collect personal data from children under 16. If you are under 16, please do not use the Services or provide personal data to us.
If we learn that we have collected personal data from a child under 16 in circumstances where such processing is not permitted, we will take reasonable steps to delete the data. A parent or guardian who believes that a child has provided personal data to us may contact [email protected].
12. Security
We use reasonable technical and organizational measures designed to protect personal data against unauthorized access, loss, misuse, alteration, or disclosure. These measures may include access controls, encryption in transit, restricted administrative access, logging, and other safeguards appropriate to the nature of the data and the Services. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.
13. Changes to This Privacy Policy
We may update this Privacy Policy from time to time to reflect changes to our Services, technology, legal requirements, or business practices. When we make changes, we will update the "Last updated" date above. Where required by law, we will provide additional notice or request consent before material changes take effect.
14. Contact Us
For privacy questions, requests, or complaints, contact:
Hong Kong National Interactive Technology Co., Ltd. (HK ATP INTERACTION TECHNOLOGY LIMITED)
Rm 20, Unit B3, 07/F, Tuen Mun Industrial Centre
2 San Ping Circuit, Tuen Mun, Hong Kong
Email: [email protected]