PRIVACY POLICY

Last updated on 11.10, 2021

This privacy policy (this "Privacy Policy") explains how HIGGS TECHNOLOGY CO.,LIMITED and our Affiliates ( "we", "our" or "us") collect, use and disclose your information. This Privacy Policy applies to information we collect when you use our games (including but not limited to PC games, web games, HTML5 games, mobile games, television/tablet games and any other form of games) (each a "Game"), and other related online products and services (collectively, our "Services").

 

HIGGS TECHNOLOGY CO.,LIMITED is the "data controller" for the purposes of applicable data protection laws. Our contact information is as follows:

 

Email: tongits-bd@higgsgamestudio.com

 

By downloading, accessing, using and/or interacting with our Services, you agree and expressly consent to our collection, use and disclosure of the information that you provide as described in this Privacy Policy. This Privacy Policy is incorporated by reference into the end user license agreement available at https://i.tongitsstar.com/eula.html (the "EULA") and is subject to the provisions of the EULA. Capitalized terms used but not defined in this Privacy Policy shall have the meaning ascribed to such terms in our EULA. If you do not accept the terms of this Privacy Policy, please refrain from using our Services.

This Privacy Policy was written in English. To the extent any translated version conflicts with the English version, the English version controls.

 

 

How we collect and use information

 

This section describes the different types of personal information we collect and how we collect it. All your data is protected by the account authorization. Therefore, you must keep your password safe and do not disclose it to anyone else in any way.

Depending on the purpose for which the data is used, the legal basis for the processing of your data can be:

 

1. Your consent;

2. Our legitimate interest, which can be:

a. Improvement of our products and services: more specifically, our business interests to help us better understand your needs and expectations and therefore improve our services and products for our consumers' benefit;

b. Fraud prevention: to ensure payment is complete and free from fraud and misappropriation;

c. Securing our facilities: to keep our facilities used to provide services safe and secure and to ensure they are working properly and are continually improving.

3. The performance of a contract: more specifically to perform the services you request from us; and

4. Legal grounds where a processing is required by law.

 

We will collect and use your information for the following purposes:

1. To help you complete your registration, you need to provide basic registration information:your nominated nickname,telephone number, email address and password. To clarify, you have the choice to not provide us with your telephone number or email address, you can still register and play normally. Your telephone number and email address will be required only when you try to set up your password protection;

1. If you refuse to provide such data, you may not be able to use our services, and information we import from your connected social media account (e.g. Facebook, Twitter, Apple or Google sign-in account) in order to set up your profile, including your name as it appears on your social media profile and your profile picture, real name, gender, date of birth ;

1. including your IP address, physical location and device information (such as device ID and similar unique identifiers, device type, operating system, CPU, RAM, IP address, MAC/IMFI address, IDFA, network data, operating system and its version, hardware and software versions, ISP and browser type, processing capabilities, manufacturer and model, language and other regional settings, screen resolution, other device attributes or similar settings) and information regarding your use of the Game and/or the Services, such as date and time stamps of actions. We also collect and store your data each time you interact with us.To provide you with continuous and stable services, we automatically collect certain data from you when you use the Game and/or the Services:

2. You may also provide or generate information including operation record, game information, payment information, communication information, preference choice information, and other related information when you communicate with other users in the Game (e.g., level, characters, score, chat log, chat content, virtual items).

3. In some service items, in order to facilitate the delivery of goods or services to you, we will process your basic information :including role name and game server, the payment information including order detail information, recharge amount and payment mode you provide to us to facilitate the payment.

4. To provide you with customer service,we will collect your basic information:including the game you play, role name and game zone, contact information, the detail of your request and communication record, and the purchase history record for retrieving password in order to respond to your inquiry or support request;

 

 

Third party services

 

Our services may be linked to social media or other services (including websites or other forms of services) provided by third parties, including:

 

(1) You can use the "share" button to share some content with our services, or you can use a third-party service to log in to our services. These functions may collect your information (including your log information) and may install Cookies on your terminal device, so as to operate the above functions normally;

(2) Other access to third-party services.

We share your Security-related information including User account information (Account ID, Character ID, Nickname, Server, Channel), Dump information when a game crash occurs, Basic hardware information, OS version, Memory data in the current process, disk drive model, firmware revision, serial number, The memory data in the current process with our SDK partner , such as Google, for security purposes, including to game anti-tamper, for purposes of solving Game crash and improving our services.

 

The chart below details other types of third-party SDKs related to our services and illustrates what information they collect and the purposes for which they collect them.

Name

Information collected

Purpose of Use

AF-Android-SDK

Click log, game event log

For marketing advertising

firebase-messaging

Push

Push game activities and functional content

 

 

Cookies

 

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) ("Cookies") to enhance your experience using the Services. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities. We use cookies and similar technologies for purposes such as:

 To authenticate your identity (to identify the sites and services that are accessible to you);

 For security purposes and to maintain the integrity of our websites and products (to protect the security of your account data and prevent possible data threats);

 For advertising, making recommendations, performing effectiveness analyses and measurement purposes;

 To provide the features and services of our websites; and

 To enhance performance.

 

You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies, or instruct the device or web browser (as applicable) to provide notice at the time of installation of cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event that you refuse to install cookies, the Game may be unable to operate as designed.

 

 

Children

 

You hereby represent that you are an "adult" (as defined in the applicable in your jurisdiction) and have the requisite power and authority to access and/or use our Services. If you are not an adult, you must obtain the consent of your parent or legal guardian to use the Services. Our Services are not intended for children under the age of 16 and we do not knowingly collect any personal information from such children. Children under the age of 16 should not use or attempt to use our Services, and if you are under 16, please do not attempt to use our Services.

 

In the event that we learn that we have inadvertently gathered personal information from a child under the age of 16, we will take reasonable measures to delete such information from our records. Parents who believe that we might have gathered any information from or about a child under the age of 13 may submit a request to the email address set forth in the section "Contact & Complaints" below.

 

 

How We Store and Share Your Personal Information

 

In order to perform our contract with you, your personal information will be accessible from and will be processed on our servers (depending upon your location and the game server you select). Our servers are located in:

1. Your country;

2. The United States which is our Our main IDC;

 

You are CLEARLY aware of the above-mentioned cross-border transfer of personal data, understand the risks that may exist, and FULLY AGREE that we may transfer and store your personal data according to the Privacy Policy.

 

In case you want to withdraw your consent and stop us from transferring your personal data out of the EEA, you can refer to our email submit a request.

 

We may share your personal data with the following categories of third parties who may be located outside of your country:

 SDK partner: we share your Security-related information including User account information (Account ID, Character ID, Nickname, Server, Channel), Dump information when a game crash occurs, Basic hardware information, OS version, Memory data in the current process, HASH of disk drive model, firmware revision, serial number, The hash of the memory data in the current process with our SDK partner , such as Google, for security purposes, including to game anti-tamper, for purposes of solving Game crash and improving our services.

 

 Payment partners: we share your IP address, information about in-game purchases requested by you, and other information you provide to us for the purpose of fulfilling your purchase and withdrawal requests with our payment partners. To clarify, our payment partners offer the payment interface, and we will not have access to your payment information such as your bank account;

 

 Advertising and advertising measurement partners: we share your email, nickname, IP address and other information you provide to us with our advertising and advertising measurement partners, in order to facilitate targeting, delivery, and measurement of online advertising on third-party services, facilitate transmittal of information that may be useful, relevant, or of interest to you, e.g.. allowing you to get rewards for viewing in-Game advertisements;

 

 Data storage partners: we store some of your information using third-party data storage services, such as Google Cloud;

 

 Software providers: proper Services rendering requires us to use third party software solutions;

 

 Research partners: we may provide access to some of your data, such as your Game statistics, to provide marketing-related and other research;

 

 Player support partners: for some territories and products we engage third parties to provide you with appropriate player support services. Such companies may get access to your personal data, including but not limited to personal data that you may provide in your player support requests.

 

 Information available to other players: making your nickname and game statistics available to other players through our Services is an important part of making players' experience more enjoyable. Please note that members of your clan have access to a bigger amount of your game statistics than others;

 

 Publicly available information: our website for the Game may also have message boards, forums and/or chat areas, where users can exchange ideas and communicate with each other. When posting a message to a board, forum or chat area, please be aware that the information is being made publicly available on-line; therefore, you are doing so at your own risk. Your nickname and game statistics may also become available within Game replays and other videos, which we or other players may generate and put online. Please do not include into your nickname any data that can identify you personally.

 

 External moderators and testers: some limited data about you (such as your nickname, content of player support ticket) may become available to third party volunteering moderators and testers who contribute to providing you with better Services, e.g. to quickly respond to your questions about the Game;

 

 Anti-cheat and anti-fraud companies: we may share the information required for our detection, investigation and prevention of cheating in the Game and EULA violations only for the purposes of detection, investigation and prevention of cheating in the Game;

 

 Game developers and change of publisher: The Game developers can process certain data required for the Game's and other Services' further improvement. If we transfer the right to publish the Game and other related Services to a third party, the new publisher will have the right to continue using your data in the manner substantially the same as set out in this Privacy Policy unless you are specifically informed otherwise;

 

 Public authorities and auditors: some personal data shall be disclosed to public authorities, e.g., tax and customs authorities, auditors, and other competent parties in accordance with the applicable laws;

 

 Our subsidiaries and Affiliates;

 

 Change of control: a third party that acquires all or substantially all of us or our business. We will disclose information to a third party in the event that we sell or buy any business or undergo a merger, in which case we will disclose your data to the prospective buyer of such business. We will also disclose information to a third party if we sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, personal information may be among the transferred assets. You will be notified via email and/or notice on our website of any change in ownership or users of your personal information.

 

 

The Security of Your Personal Information

 

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. Our group companies have information security and access policies that limit access to our systems and technology. We also protect data through the use of technological protection measures such as encryption. Your personal information will remain subject to our technical and organizational controls and our policies and procedures (including but not limited to this Privacy Policy).

 

Unfortunately, the transmission of information via the internet is not completely secure. Although we will use commercially reasonable efforts to protect your personal information, we cannot guarantee the security of the information transmitted to our services; any transmission of your information is at your own risk.

 

 

Data Retention

 

We will retain most of your personal information as long as needed to provide services or products to you, or as required or permitted by applicable laws.

 

When destroying personal information, measures will be taken to make the personal information irrecoverable or irreproducible, and electronic files which contain personal information will be deleted permanently using a technical method which makes the files irreproducible.

 

In the event that the processing and retention period have terminated, but personal information is required to be retained continuously for other reasons including but not limited to for the purposes as prescribed under applicable laws, the relevant personal information will be stored and maintained separately from other types of personal information. If you require us to destroy your personal information before the end of its life cycle (as set out in the retention policy above), we will destroy your personal information in accordance with local laws.

 

 

Request for Accession and Deletion

 

You have the right to access personal information we hold about you, how we use it, and who we share it with.

Also,you can delete your account, or remove certain personal information. If there is any other personal information you believe we process that you would like us to erase, please contact us. You may request that we erase the personal information we hold about you in the following circumstances:

 

 you believe that it is no longer necessary for us to hold such personal information; or

 you believe the personal information we hold about you is being unlawfully processed by us.

 

You can also exercise your right to restrict our processing of your personal information (as described below) whilst we consider your request.

 

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (e.g., for the defense of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Services and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.

 

If you have any of the above requirements,please contact us and submit a request to the email address set forth in the section "Contact & Complaints" below.We will verify your user information and assist in managing or deleting your personal privacy within 10 working days of your application.

 

 

Portability

 

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent (e.g., gender information) or pursuant to our contract with you (e.g., game play statistics), as described in the section "How We Use Your Personal Information" above. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party. 

 

If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another's rights (e.g., where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

 

 

Restriction of Processing to Storage Only

 

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (e.g., for the defense of legal claims or for another's protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

You may request we stop processing and just store the personal information we hold about you where:

 you believe the personal information is not accurate for the period it takes for us to verify whether it is accurate;

 you wish to erase the personal information as the processing we are doing is unlawful but you want us to retain the personal information but just store it instead; or

 you wish to erase the personal information as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defense of legal claims.

 

 

Advertisements/Announcements

 

By providing your email address or telephone number to us, you expressly consent to receive emails or texts from us. We may use email or SMS to communicate with you, to send information that you have requested or to send information about other products or services developed or provided by us; however, we will not give your email address or telephone number to another party to promote their products or services directly to you without your consent. If you prefer not to receive marketing emails from us, please follow the "unsubscribe" information included in any marketing email from the Service or send a request to the email address set forth in the section "Contact & Complaints" below. You may also opt-out of receiving SMS notifications from us, either via SMS or by emailing us.

 

We may from time to time send you announcements when we consider it necessary to do so (such as when we temporarily suspend Game access 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.

 

Contact &Complaints

 

In the event that you wish to make a complaint about how we process your personal information, please contact us immediately, and we will respond to you within 3 working days.

 

Email: tongits-bd@higgsgamestudio.com

 

Changes

 

If we make any material changes to this policy, we will post the updated policy here and notify our users. Please check this page frequently to see any updates or changes to this policy.