OUTFIT7 CHINA PRIVACY POLICY FOR GAMES

(Last update August 27, 2024)

ABOUT US AND THIS PRIVACY POLICY

Your privacy is very important to us, and we will only use your personal information for the purposes as described in this Privacy Policy for Games (“Privacy Policy”). As used in this Privacy Policy, "Outfit7", "we", "us" or "our", "ours" refers to Outfit7 Limited, registered at 1st Floor Sackville House, 143-149 Fenchurch Street, London EC3M 6BN, United Kingdom, with business address at Christaki Kranou 20, 2nd Floor, 4041 Limassol, Cyprus, and all of its subsidiaries.

This Privacy Policy forms a part of and is incorporated by reference into the End User License Agreement (the "EULA") governing the use of all Outfit7 software applications (the "Game/s"), which may operate on any type of computing device (including without limitation, a mobile device), and applies to your use of the Game. If you are under the age of 14, you are also subject to our Children's Privacy Policy.

It is important that you read and understand this Privacy Policy carefully and in its entirety before using our Games, particularly the terms and conditions highlighted in bold. You should not play our Games until you have confirmed that you fully understand and agree to this Privacy Policy. Once you start playing our Games, you will be deemed to have fully understood and agreed to this Privacy Policy.

This Privacy Policy is intended to help you learn more about how we collect, use, share, protect, transfer and store personal information, and how you can access, copy, delete, correct and withdraw authorised personal information. You understand that the cross-border transfers of data under this Privacy Policy are necessary to enter into and perform a contract to which you are a party. We have bolded important content regarding your personal information rights, so please pay particular attention to them.

HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION

HOW WE MAY SHARE YOUR PERSONAL INFORMATION

THIRD PARTY TERMS AND CONDITIONS

MINORS PROTECTION

YOUR RIGHTS

PROTECTION OF YOUR INFORMATION

PERSONAL INTERNATIONAL TRANSFER

STORING AND DELETION OF YOUR PERSONAL INFORMATION

CHANGES TO OUR PRIVACY POLICY

CONTACT US

HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION

Please note that you can play our games without registering an account. When you play our Games, we do not ask for your full name, address, email or phone number for account registration. We will only collect the necessary information from you or your device directly in the following circumstances:

you play our Games, or;
you interact with our service providers in our Games, or;
you interact with our advertisements in other publisher’s applications.

Once we have obtained your consent, we may collect and use your personal information for the following purposes:

Help you to enter the Games

According to the applicable laws, regulations and requirements of national authorities, you are required to complete the real-name verification before you start playing our Games. We are required to integrate a state-designated real name verification system in our Games, so that the real name verification institution can verify your true identity. The personal information you need to provide includes the full name and ID number, which is sensitive personal information. Please note that we will not read or store this sensitive personal information from you and the aforementioned personal information will be collected and verified directly by the verification institution through its Application Programming Interface (API), and we will only receive the results of such verification. Based on the result of such verification, we are able to comply with the anti-addiction system requirements of the national authorities. If you refuse to provide such true identity information or provide false information, you will not be able to pass real name authentication and we will not be able to provide you with our Games.

Provide you with the game functions

To provide you with a good gaming experience, we will provide you with a unique, randomly generated user ID ("UID"). This UID is for internal use only and is non-identifying personal information that cannot be used to personally identify you.
To provide you with the game functionality and to improve the adaptability of the game, we collect your UID, game progress, in-game virtual currency, in-game purchase, network status, IP address, language, locale, browser plug-in types and versions, user agent string (UA), store platform, SDK version, timestamp, technical device information (device model and name, operating system name and version, CPU information, storage size, screen size, firmware, software, mobile phone carrier, Internet service provider, API key identifier for application, dark mode, volume, font size and power mode. Please note that IP addresses and advertising identifiers are typical personal information, but we do not use and cannot use IP address to accurately identify your location (only country or city); other technical information above is non-identifying personal information that cannot be used to personally identify you.
To monitor and repair any application crashes and bugs and to make sure the Game functions without interruptions, we collect your UID and IP address. To prevent malicious programs and maintain normal operation, we may collect overall Game operation progress, usage frequency, crashes and bugs, UID, IP address, installation situation and performance data when you play our Game. Please note with the exception of IP address, the above information is gaming usage information and is non-identifiable personal information.
If you choose to login and use our partners’ game center, we will collect your player identifier string. If you are connected to such gaming network account, you may participate in leaderboards, restore your game progress, use your network account to log in on multiple devices and to synchronize progress across those devices. If you participate in game related activities, such as in leaderboards, you will also share your personal information (scores, rankings and achievements) with other players and gaming networks. Please note that use of gaming networks is operated by our partners and governed by their own privacy policies, terms and end user agreements. We are not responsible for, and have no control over, the sharing practices or policies of such networks that operate those sites.
To provide you with the game reminders, we may use your device’s notification function to send you relevant reminders. If you prefer not to receive such reminders, you can turn them off in your device settings.

Collect feedback about the Games

To improve and enhance our Games, we may conduct in-game questionnaires or surveys from time to time. You are free to choose whether or not to participate, and we will only collect personal information that you voluntarily provide. Please note that such personal information will be anonymized and aggregated.

Conduct our marketing campaigns

To attribute the performance of our marketing campaigns, assess and measure their success, optimize our campaigns, prevent any fraud, we and our third-party services providers will collect your device data and information, such as ads impressions, clicks, installs or other marketing campaign indicators when you interact with our Games advertisement in other publishers’ application.
To present you with our other Games and not to show you ads for those of our Games which you’ve already installed, we will collect a list of Outfit7 apps installed on your device. Please note that we will not collect a list of third-party apps installed on your device.

Help you with in-app purchase and refund

You may obtain virtual products (for example, game coins, character costumes) and subscriptions in our Games by playing the Game or by making a purchase. Please note that while we offer the in-game purchases, we do not directly provide the payment service. Your payment will be made directly to the app store. They may collect your name, bank card type, card number, expiry date and mobile phone number, etc. Please note that the personal information above is mostly sensitive personal information, but it’s necessary information for the payment function; refusal to provide such information will result in inability to use the payment function. We do not receive any sensitive details about your payment. Once you have completed your payment, the app store will only inform us when the payment was successful so that we can provide you with the virtual product you requested. For more details, please refer to the privacy policy of the app store.
To assist you with the required refund, the app store may ask you to provide necessary personal information, such as your ID number, bank account and commitment letter to verify your identity and provide you with the relevant refund. Please note that ID number and bank account information are sensitive personal information, but they will only be used for refund purposes. They will be processed and stored by our third-party service provider within the territory of China. Our service provider will only share with us some necessary non-identifiable personal information for our internal analysis, such as the Game you play, your UID, recharge time, recharge amount and refund amount.

Provide you with customer service

When you request our support through the in-game support function, our customer service will automatically receive your UID as fundamental information. Customer service will use this information in order to process your request and provide you with appropriate support. If our customer service needs more information from you, they will obtain your separate confirmation and use it only within the scope authorized by you.

Provide you with advertising

In our Games we may show you advertising and in order to do so, we may integrate third party’s Software Development Kits (“SDKs”) in our Games to ensure appropriate advertisement is presented to you, to calculate the number of ads shown to you and how you interact with them. There are two types of ads in our games – ads that may be relevant to the content you are currently on (“contextual advertisement”) and ads that are based on your preferences and online habits (“personalized advertisements”). In order for third parties to show you personalized advertisements they may track you across websites and apps to analyse your preferences, habits and approximate location in order to provide you with more relevant advertising. The personal information they may collect for the purpose of personalized advertisements includes but is not limited to your technical device information (device model/device name/OS name/version/device settings/device serial number, etc.), device identifier (IDFA/IDFV), application installation list, MAC address, Wi-Fi information (SSID/BSSID/signal strength/connection status), sensor information (gyroscope/acceleration sensor/gravity sensor), IP address (country/city), advertisement data (advertisement interaction/impression/click/conversion data), network information (WiFi status/telecom operator/network type/network connection status/network environment), software information (software version number/software signature/package name/software source), and storage permission, etc.

Your device identifiers will never be collected for the purposes of contextual advertisements.

Advertising providers may collect your personal information to display advertisements to you, and these actions are governed by the respective privacy policies of aforementioned providers. We will use commercially reasonable efforts to require advertising providers to comply with applicable laws and regulations when processing your personal information and to require them to take appropriate confidentiality and security measures, but we cannot guarantee that they will comply with our requirements. Please refer to the Third Party Information Sharing List to check their privacy practices and other details.

You can opt-out of personalized advertising at any time by using the following methods:

You can find the "Personalized recommendations/tracking/intelligent advertising" option in your device’s settings and choose to turn on or off personalized advertising; or
You can turn on or off personalized advertising in some of our Games. You can do this by checking ''Information Screen'', ''Settings'' and ticking the ''Disable Interest-Based Ads''; or
You may opt-out of personalized advertising from a specific provider by contacting this provider we work with. The specific opt-out can be processed by contacting them via our Third Party Information Sharing List.

If you choose to opt out of personalized advertising we will stop showing you personalized advertising, but this will not affect your experience of using other features in the Game. Opting out of personalized advertising will not decrease the number of ads you see, but the ads will be less relevant to your preferences.

Request access to system features on a device when necessary

Some of our Games have a feature in which the virtual character repeats back what you say. We will always ask you in advance for your permission to access the microphone on your device. If you choose to give the permission, the virtual character will be able to repeat what you say to it. Please note that our Games will not record the audio, what you say to the virtual character is not stored on our servers, it is only used by the Game to repeat back to you in real time. If you refuse to give us the permission to access the microphone on your device, the virtual character will not be able to repeat after you, but you will still be able to play the Game and use other features.

Exceptions

In accordance with applicable laws and regulations, your authorised consent is not required for the processing of your personal information in the following circumstances:

when the processing is necessary for the conclusion, performance or execution of a contract requested by you;
where processing is necessary to comply with a statutory duty or legal obligation;
where processing is necessary to respond to a public health emergency or in an emergency to protect the life, health and property of you or others;
to conduct news reporting, opinion polling and other actions in the implementation of the public interest within reasonable limits;
to process, the personal information that you voluntarily disclose or that is been lawfully disclosed, within reasonable limits;
in other circumstances required by laws and regulations.

We cannot provide all services necessary for the successful operation of the Games by ourselves. We have therefore partnered with other companies to help us provide certain services. Please note that we will obtain your consent before sharing your personal information with other companies.

We take the privacy and protection of your personal information very seriously. We will only share your personal information to third parties for lawful, justifiable, necessary, specific and explicit purposes. We sign strict cooperation agreements with companies that receive personal information from us, requiring them to handle the information in accordance with our requirements and any other relevant confidentiality and security measures.

To achieve the purposes stated in this Privacy Policy, we may integrate SDKs or other similar technologies provided by third party service providers in order to provide you with our Games. The circumstances in which your personal information may be processed or shared on behalf of us to fulfill our services are as follows:

to our cloud service providers: we store and transfer personal information we collect from you on servers provided by our third party cloud service provider and proxy server provider;
to our crash reporting provider: we send bugs and crash information so that we may fix them and the Game can function;
built-in customer support tool: we offer an in-app customer support tool, which allows users to contact us within the Games
to our advertising providers: we share information so that advertising providers may offer advertising including personalized advertising in our Games;
to our analytics providers: we analyse impressions, downloads, and traffic sources using third party technology to see how many times our apps have been viewed or downloaded from an app store;
to our attribution and fraud prevention providers: we share information for the purposes of measuring performance and optimizing our advertising campaigns and for fraud prevention (eg. so that the clicks are attributed to actual users and not to bots, malicious scripts and other technologies);

Please note that the third-party SDKs or similar technologies may collect your personal information directly. If you use such third-party services in connection with our Games, you agree that your information will be collected and processed directly by the SDKs or similar technologies such providers may use. We will assess the legality, propriety and necessity of the collection of personal information by such third-party services and require such third parties to take measures to protect your personal information and to strictly comply with relevant laws, regulations and regulatory requirements. You can find out more details about the third parties’ SDKs that we may use in our Games by clicking on the Third Party Information Sharing List.

Transfer

In the event of a merger, acquisition, transfer of assets, separation, dissolution, declaration of bankruptcy or similar situation, we will inform you of the situation, provide you with the name and contact information of the recipient, and will require the new recipient to continue to protect your personal information in accordance with the laws, regulations and requirements no less stringent than this policy.

Public Disclosure

We will only disclose your personal information publicly when:

we have obtained your express consent;
required to do so by laws or regulations.

Exception

Please note that there are certain circumstances in which we may share, transfer or publicly disclose your personal information without your consent, in accordance with applicable laws and regulations. Please refer to the "Exceptions" section of "HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION" for more details.

THIRD PARTY TERMS AND CONDITIONS

Our Games may contain links to third party websites, products, or services. Please note that while using such third-party websites, products, or services, you are using sites, products, and services developed and administered by people or companies not affiliated with or controlled by us. We cannot control the actions of those people or companies, the content of their sites, products or services, the use of personal information you provide to them, or any products or services they may offer. Our link to such third parties does not constitute our sponsorship of, or affiliation with, those people or companies. Nor is such linking an endorsement of such third party's privacy or information security policies or practices or their compliance with laws. Personal information collected by third parties, which may include such things as location information or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of third parties with which you interact.

MINORS PROTECTION

Our Games are a source of entertainment for players of all ages and we work hard to provide a safe gaming environment in which every player can enjoy at all times. The protection of the minors’ privacy is of the utmost importance to us, and we will actively comply with the requirements of the anti-addiction policy and protect the legitimate rights and interests of minors by implementing the anti-addiction system. We will receive information from the anti-addiction system whether you are a minor and take the necessary measures required by laws and regulations.

We will protect the personal information of minors in accordance with relevant laws and regulations. If we discover that personal information about minors has been collected without the prior, verifiable consent of a parent or other guardian, we will delete that information as soon as possible.

If you are a minor under the age of 18, you should read and agree to this Privacy Policy under the supervision and guidance of your parents or other guardians before playing our Games;
If you are the guardian of a minor, please check whether the minor in your custody is playing our Games or providing personal information after obtaining your authorized consent. Please contact us promptly if you have any questions about the personal information provided by the minor in your custody;
In particular, if you are a minor under the age of 14, you are subject to both this Privacy Policy and the Children's Privacy Policy. You may not use our Game services unless you have obtained your parent’s or guardian's consent to the Children's Privacy Policy.

As a guardian of minors, you should guide minors to use the internet in a safe and reasonable manner, pay attention to the situation of minors' access to the internet, as well as their physiological and psychological conditions and behavioral habits, prevent minors from being exposed to information on the internet that is harmful to, or is likely to affect, their physical and mental health, and reasonably organize minors' use of the internet and prevent and intervene in minors' indulgence to the internet.

YOUR RIGHTS

You have certain rights in relation to the management of your personal information and how we handle it. Please note that some of these rights may be subject to some exceptions or limitations, and we reserve the right to ask for reasonable evidence to verify your identity before assisting you in exercising such rights. You may exercise these rights at any time by contacting us with your requests regarding your personal information.

You have the right to change your consent to the processing of your personal information that is processed on the basis of your consent and as described in this Privacy Policy. You can always withdraw your consent and opt-out from the collection of your personal information by us and other companies we work with by uninstalling the Games from each of your computing devices.

Access, Copy, Correction, Supplement, Transfer and Deletion of Your Personal Information

Right of access and copy. You have a right to know what information we hold about you, and in some cases, to have that information communicated to you. If you wish to exercise this right, please contact us and let us know that you wish to exercise your right of access and what personal information in particular you would like to receive. Please note that we may not be able to provide all of the information you request, for example, if the information includes personal information about another person. Where we are not able to provide you with information that you have asked for, we will explain to you why.
Right of correction and supplement. We try to keep the information that we hold about you accurate and up to date. Should you realize that any of the information that we hold about you is incorrect, please contact us promptly and we will correct it as soon as we can.
Right of Transfer. In some circumstances, you have the right to request that we provide you with the personal information which you have provided to us, so you can transfer this information to another party. Should you wish to do that, please contact us with the required information and recipient.
Right of deletion. You have the right to request the deletion of any personal information we hold about you. If you wish to do this, please contact us. Once we have verified the information necessary to identify you (eg. your UID), we will delete the personal information you have requested us to delete as soon as possible. Please note that, we may still retain some or all of this information in an anonymized form according to the laws and regulations. In addition, you are always free to stop the further processing and collecting of your personal information by uninstalling all the Games from each of your devices.

Account Cancellation

Our games do not require account registration, but we still provide you with a similar function in some games in accordance with laws, regulations and some store requirements. You can click on the "Account Cancellation" button in the app’s settings and follow the instructions. Once you have clicked this button, your game progress, virtual products, etc. will be deleted. You can also contact us through the methods listed in the "Contact Us" section, and we will answer your questions as soon as possible. Once the information is deleted, it cannot be recovered, please operate with caution.

PROTECTION OF YOUR INFORMATION

Security Protection Measures

To protect the security of your information, we have implemented a variety of physical, electronic and managerial security measures that are consistent with industry standards and are reasonably designed to protect your information from disclosure, destruction or loss, including, but not limited to, TSL encryption when exchanging data between your mobile device and our Games; encryption technology to ensure data confidentiality; and trusted protection mechanisms to protect data from malicious attacks. We adopt strict management of employees who may have access to your information, including, but not limited to adopting different permission controls depending on their positions, requiring them to sign non-disclosure agreements, and monitoring their operations. Although we use commercially reasonable efforts to ensure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.

Security Incident Treatment Measures

If there is a security incident of personal information leakage, we will initiate the emergency plan to prevent the security incident from spreading. After the security incident occurs, we will inform you of the basic situation and the possible impact of the security incident, the disposal measures we have taken or will take to deal with it, the suggestions you can take independently to prevent and reduce the risk, and the remedial measures for you in accordance with the requirements of laws and regulations. We will keep you informed of the relevant situation by means of taking reasonable and effective steps to issue announcements. At the same time, we will also report our handling of personal information security incidents to the regulatory authorities in accordance with the applicable requirements.

PERSONAL INTERNATIONAL TRANSFER

We, and our Games, operate globally, and our Games are wholly or partially developed or provided by our overseas affiliated entities and/or other third-party service providers. We may, for the purposes of monitoring the actual performance of advertising, optimizing advertising and marketing campaigns, conducting analysis to improve performance and fraud prevention, transfer your information to our affiliated entities (for example, Outfit7 Limited) across borders and from your country to other countries or jurisdictions around the world; for the purpose of providing marketing and advertising performance monitoring and attribution services, and monitoring program crashes, our third party service providers may transfer your personal information across borders from China to other countries or jurisdictions around the world. Please note, that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, but wherever your information is transferred or stored by us, we will take reasonable measures and/or measures required by laws to safeguard the privacy of your personal information in accordance with the requirements of this Privacy Policy and applicable laws.

STORING AND DELETION OF YOUR PERSONAL INFORMATION

We will keep your information in a secure manner. In general, we will keep your information for the minimum period necessary for the purposes described in this Privacy Policy. After the minimum retention period, we will delete or anonymize your information using reasonable measures to protect the information from unauthorized access or use. We may retain your information for longer than the minimum period necessary only if such longer retention period is required or permitted by applicable laws and regulations or relevant regulatory authorities.

CHANGES TO OUR PRIVACY POLICY

We will occasionally update this Privacy Policy as necessary to protect our users, furnish current information, and respond to legal and technical changes. The most current version of the Privacy Policy will govern our use of your personal information and will be available at https://talkingtomandfriends.com/cn-privacypolicy/en.

After this Privacy Policy is updated, we will issue the updated version in the Games and notify you through pop-up prompts, so that you keep up with the latest version of this Privacy Policy. For previous versions of this Privacy Policy, please contact us with your requirement.

CONTACT US

If you have questions or concerns about Outfit7 China Privacy Policy for Games, please contact us through one of the following ways:

for privacy questions and exercising your rights via: [email protected];
for general information via: [email protected];
for reaching out to our office: Christaki Kranou 20, 2nd Floor, 4041 Limassol, Cyprus

We will review your questions as soon as possible and respond within 15 working days after verifying your identity.

OUTFIT7 China Privacy Policy for Games, August 27, 2024