OUTFIT7 CHINA PRIVACY POLICY FOR GAMES

(Last update July 6, 2023)

ABOUT US AND THIS PRIVACY POLICY

Your privacy is very important to us, and we will always use your personal information only 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 Network Technology Co., Ltd, Shaoxing Outfit7 Network Technology Co., Ltd, and/or Shanghai Lizhi Network Technology Co., Ltd, and all of their affiliates.

This Privacy Policy is part of and 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 14 years old, you will also be subject to the Children's Privacy Policy.

It is essential for you to read and understand this Privacy Policy carefully and completely before using our Games, particularly the terms and conditions highlighted in bold, and only play our Games after you have confirmed that you have fully understood and agreed with them. Once you start playing our Games, you are deemed to have fully understood and agreed to this Privacy Policy.

This Privacy Policy will 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. We have bolded important content regarding your personal information rights, please pay extra attention to it.

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

When you play our Games, we do not collect your personal information, such as your full name, address, email or phone number. Please note that you can play our games without registering an account. Most of the personal information we collect about you comes directly from you or your device when:

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.

After we receive your consent, we may collect and use your personal information for the following purposes:

1. Help you to enter the Games

According to the applicable laws and requirements of national authorities, we require you to provide your true identity information, including your name and ID number , to the relevant real name verification institution before you start playing our Games. Please note that we will not collect or store this sensitive personal information from you and the aforementioned personal information will be provided directly to verification institutions. If you refuse to provide such true identity information or provide false information, we shall not be able to provide you with our Games.

2. Provide you with the game functions

To provide you with gaming experience, we will provide you with a unique user ID ("UID") generated randomly. This UID will only be used internally and 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, power mode, volume), and sensor information (gyroscope, acceleration sensor, gravity sensor), IMSI. Please note that IP addresses are typical personal information, whereas the technical information can not 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 IP address. To prevent malicious programs and maintain normal operation, we may collect Game overall operation process, usage frequency, crashes and bugs, IP address , installation situation and performance data when you play our Game.
If you are able to login and use gaming networks, 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 leader boards, 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 governed by their own privacy policies, terms and end user agreements and 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 the notification function of your device to send you relevant reminders. If you prefer not to receive such reminders, you can turn them off in your device settings.

3. Collect feedback about the Games

To improve and enhance our Games, we may issue in-game questionnaires or surveys from time to time. You are free to decide 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.

4. Conduct our marketing campaigns

To measure the performance of marketing campaigns, optimizing our campaigns, conduct analysis to improve our services and for fraud prevention, we or our third party services providers will collect your device related data and information, such as impressions, clicks, installs or other marketing campaign indicators when you interact with our Games advertisement in other publisher's applications.
To present you with our other Games, 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.

5. Help you with in-app purchase and refund

You can obtain virtual products (for example, game coins, character costumes) in our Games by playing the Game or by making a purchase. Please note that the purchase is not entirely facilitated by us and your payment is made directly to an application store or to a third party payment providers. They may collect your name, bank card type and card number, expiry date and mobile phone number, etc. Please note that such personal information is mostly sensitive personal information but necessary information for the payment function; refusal to provide such information will result in inability to use the payment function. We will not obtain any payment information related to your payment. After you have made a successful payment, we will only receive confirmation of your completed payment from our partner in order to provide you with the appropriate virtual product. If you want to know more details, please refer to the privacy policy of the app store or the third party payment provider you have chosen.
To help you with the required refund, our third party services provider 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 requested refund. Please note ID number and bank account information are sensitive personal information, but they will only be processed and stored by our third party services provider within the territory of China. We will only receive general information such as the Game you play, your UID, recharge time, recharge amount and refund amount from our provider.

6. Provide you with customer service

When you ask for 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 to provide you with the corresponding 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.

7. Provide you with personalized advertising

In our Games we may show you advertising that is based on your preferences and online habits ("personalized advertising"). To show you personalized advertising, we may integrate third party SDKs into our Games. Such third parties may track you across websites and apps to analyse your preferences, habits and approximate location in order to provide you with more suitable advertising. The information they collect for this purpose includes your technical device information (device model and name, operating system name and version), advertising identifiers (IDFA, OAID) and IP address (country and city).

Such third party advertising providers may collect your personal information necessary to provide you with personalized advertising in accordance with their own privacy policies. We will use commercially reasonable efforts to require third party advertising providers to comply with applicable laws and regulations when processing your personal information and to require them to take relevant confidentiality and security measures, but we cannot guarantee that they will comply with our requirements. Please check the Third Party Information Sharing List for more details (https://talkingtomandfriends.com/o7-networktech-thirdpartysdk/zh-simp).

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

You can find the "Personalized recommendations/tracking/intelligent advertising" option in the settings of your device and choose to turn on or off personalized advertising;
You can turn on or off personalized advertising in some of our Games. You may do so by visiting ''Information Screen'', ''Settings'' and ticking the ''Disable Interest-Based Ads'';
You can opt-out of a specific provider's personalized advertising by contacting such specific third party advertising providers we work with. The specific opt-out can be processed by contacting them via our Third Party Information Sharing List, accessible at https://talkingtomandfriends.com/o7-networktech-thirdpartysdk/zh-simp.

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

8. Request access to system features on a device when necessary

Some of our Games offer a feature in which the virtual character repeats back what you said. We will always ask you in advance for your permission to access the microphone on your device. If you decide to give the permission, the virtual character will be able to repeat what you say to it. Please note that our Games do not have a function to record audio, so what you say to the virtual character is not stored on our servers, it is only used by the Game to repeat to you in real time. If you decide not 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 can continue playing the Game and use other features.

9. 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 processing is necessary for the signing, performance of a contract requested by you;
when processing is necessary for performing a statutory duty or legal obligation;
when processing is necessary to respond to a public health emergency or in an emergency to protect you or others' life, health and property;
to conduct news reporting, opinion monitoring and other actions in the implementation of the public interest within reasonable limits;
to process, the personal information that you disclose on your own or that has been lawfully disclosed, within reasonable limits;
ther circumstances as stipulated 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 that help us provide certain services. Please note that we will rely on your consent before sharing your personal information to other companies.

We take the protection of your personal information very seriously. We will only provide 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 analytics providers : we analyse impressions, downloads, and traffic sources to see how many times people viewed or downloaded our apps from an app store and may share such information with our service providers;
to our cloud service providers : we store personal information we collect from you on servers provided by our third party cloud service providers;
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;
to our advertising providers : we share information so that advertising providers may offer advertising including personalized advertising in our Games;
to our crash reporting provider : we send information in order for the Game to function without bugs and crashes;
built-in customer support tool : we offer an in-app customer support tool, which allows users to contact us within the Games

Some of the third party SDKs or similar technology that we integrate will collect your personal information, and if you use such third party services in connection with our Games, you agree that your information will be collected and processed directly by them. 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 (https://talkingtomandfriends.com/o7-networktech-thirdpartysdk/zh-simp).

2. 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, inform you the name and contact details of the recipient, and will require the new recipient to continue to protect your personal information in accordance with the law, regulations and requirements no less stringent than this policy.

3. Public Disclosure

We will only publicly disclose your personal information when:

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

4. Exception

Please note that there are certain circumstances in which we may share, transfer or publicly disclose your personal information without your authorised consent, in accordance with applicable laws and regulations. Please refer to the point "Exceptions" under the "HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION" section 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 environment in which everyone can enjoy. The protection of the privacy of minors is of utmost importance to us and we will actively follow 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 of minors has been collected without prior verifiable parental or other guardian consent, we will delete the relevant 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 only use our Game services if you have obtained your guardian's consent to the Children's Privacy Policy.

YOUR RIGHTS

You have certain rights in connection with 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 we assist you in exercising such rights. You can exercise these rights at any time by sending your requests regarding your personal information to us.

You have the right to change consent for the processing of your personal information that is processed on the grounds of consent. You are always free to withdraw consent and opt-out from the collection of your personal information by us and other companies we work with by uninstalling all the Games from each of your computing devices.

2. Access, Copy, Correction, Supplement, Transfer And Deletion 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 the information communicated to you. If you wish to exercise this right, please contact us by letting 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 the information you ask for, for instance 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 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.
Right of deletion. You have a right to request deletion of the personal information that we hold about you. If you wish to do that, please contact us. Once we receive all information we need in order to be able to identify you (eg. by checking your UID), we will delete your personal information you requested us to delete as soon as possible. Please note that, we may still retain some or all of that information in an anonymized form according to the laws and regulations. You are always free to stop the further processing and collecting of your personal information by uninstalling all the Games Apps from each of your devices.

PROTECTION OF YOUR INFORMATION

1. Security Protection Measures

To protect the security of your information, we have implemented a variety of physical, electronic and managerial security measures that meet industry standards and are practicable 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; 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, signing non-disclosure agreements, and monitoring their operations. Although we use commercially reasonable efforts to assure that your information remains secure when maintained by us, please be aware that no security measures are perfect or impenetrable.

2. Security Incident Treatment Measures

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

PERSONAL INTERNATIONAL TRANSFER

We 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 Game development, improvement of the Game performance and optimization of the overall user experience, transfer your information to our affiliated entities and/or to other third party service providers across border and from your country 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 information in accordance with the requirements of this Privacy Policy and applicable laws.

STORING AND DELETION OF YOUR PERSONAL INFORMATION

We will store your information in a secure manner. In general, we store your information for the minimum period necessary for the purposes described in this Privacy Policy. Beyond the minimum necessary period, we shall delete or anonymize your information using reasonable measures to protect the information from unauthorized access or use. We may only store your information for longer than the minimum period necessary when such a 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 information and will be available at https://talkingtomandfriends.com/o7-networktech-privacypolicy/zh-simp.

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 abreast of 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's 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 China office: Room 2130 KrSpace, Building 4, No.126 Yude Road, Xuhui District, Shanghai, China. Postcode: 200030

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, v. 1.2, July 6, 2023