Privacy Policy
Last Updated: September 5, 2022
B.I.G TECHNOLOGY CO., LIMITED (""we", "us", "our") fully respects and is committed to protecting the right to privacy of our users ("users", "user", "you") who visit our websites, access or use our games whether played on mobile devices, personal computers, our websites or any other applicable platforms and/or devices ("our Games"), and access or use any services offered by us, including but not limited to technology services, customer support, competitive gaming activities, marketing and advertising (collectively, "our Services").
This Privacy Policy ("Policy") is provided to help you understand our practices related to the collection, use, storage, and disclosure of information we collect from or about you when you interact with us, your rights regarding the information provided to us, and how we transfer and secure such information.
Please make sure to read this Policy carefully to understand our practices regarding your Personal Data (as defined below) and access it frequently to understand the updates to this Policy. 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 Terms of Service available at https://www.tongitsstar.com/eula.html(our "Terms of Service") and is subject to the provisions of the Terms of Service. If you have any concerns about providing information to us or the use of that information as described in this Policy you should not use our Services.
If we update this Policy, we will notify you by announcements in our Games to let you know about the changes we made and obtain your consent again. By accessing or using our Services after we have placed such a notice, you are deemed to have accepted the updated Policy. You can see when this policy was last updated by checking the "last updated" date displayed at the top of this policy. If we are required by applicable data protection laws to give you enhanced notice or seek your consent for any such changes, we will do so. Any revised Policy will supersede all previous privacy policies.
This Privacy Policy will help you understand the following contents:
XIV. Extra Help
·"Personal Data" means any information that relates to a living individual directly or indirectly and can be used to identify a living individual, in particular by reference to an identifier, location, or factors specific to the physical, physiological, genetic, economic, cultural or social identity.
·"Usage Data" means data collected automatically either generated by the use of the Service or from the Service infrastructure itself.
·"Cookies" are small data files stored on your hard drive or in device memory that helps us to improve our Services and your experience and see which areas and features of our Services are popular and count visits.
·"Data Controller" means a natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Data is, or will be, processed. For the purpose of this Policy, we are a Data Controller of your data.
·"Data Subject" is any living individual who is the subject of Personal Data.
For your better experience in our Services, we may require you to provide us with certain Personal Data while using our Services.
We may collect your Personal Data in the following ways: 1) information you directly provide to us (such as your nickname, profile picture and phone number you provide to us when you register or login to your account); 2) information we obtain automatically during your use of our Services (such as Device Information and Usage Data); or 3) information we obtain from other sources.
We will collect and use your Personal Data only for the purposes described in this Policy. The following describes your Personal Data that we collect and how we use it.
We may collect some or all of the following information about you when you use our Services for legitimate interests.
(1)Login Information
If you sign up with your e-mail/mobile phone number when you create an account in our Games, you consent to provide some of your Personal Data, such as e-mail address, verification code by email or SMS, and password.
If you register via social network accounts, such as Apple ID, Facebook or Google Play ("Social Networks"), we may collect information you authorized the Social Networks to share with us to sign up for our Services. Exactly what information we receive from the Social Networks may vary due to your privacy settings on such Social Network, but it would typically include your basic public profile information such as your nickname, username and profile picture. If you refuse to provide information of your Social Networks accounts, you may not have the option to register and log in by your Social Networks accounts.
For certain regions, you may be asked to provide us with your date of birth to verify that you are eligible to access or use our Services.
(2)Account Information
When you use our Services, you have choices about the information you provide on your Account, such as your profile picture, nickname, gender, date of birth and location. You don’t have to provide additional information on your profile; however, profile information helps you to get more from our Services, including making others to better know you. Please do not post or add additional information to your profile that you would not want to be publicly available.
(3)Payment Information
When you purchase virtual currency or virtual items in our Services, we may collect and process your purchase and transaction record in the Services, including device information (including Open ID, Internet Protocol (IP) address, OS version, type of device, internet connection), transaction details (time and date, cost, product purchased, currency, order ID) and transaction records (including player ID, time of transaction, country, email, phone number, purchase history and payment card details), to perform our contract with you to facilitate your payment and provide you with details of your transactions.
All purchases and withdrawals are processed by payment processing companies. We do not process the payments for any payment nor do we have any access to your credit card information or billing information.
(4)Any Information You Submit to Our Support Team
If you encounter any problems while using our Services, you may contact us and seek assistance through our technical and/or customer service. In case of receiving your request for support, we may collect the content of your enquiry, your device information, contact details or other contact information you leave with us in order to contact you or help you resolve the problem, or to record the problem and its solution. If you choose not to provide such information, we may not be able to provide you with this service, but your use of other features of our Services will not be affected.
(5)Advertising Information
We may store the ad identification number for the advertisement, such as Android ADID and Apple IDFA information and device information with your profile to track the success of our advertising if you click on advertisements in our Services.
In order to provide you with personalized advertisements, promotional activities and marketing communications, subject to your election and consent, we may collect and process the following information, such as age, gender, e-mail address, geographical location, device type, in-game information (such as your habits and preferences in our Games) and other information you choose to provide to us in any surveys or inquiries.
We may also use the information you provide to send you deliver advertisements, market surveys or research by email. If you don’t want to receive such messages from us, you may opt-out of receiving such messages (see "Promotional Communications" below).
Please note that when you opt out of receiving interest-based or targeted advertising, you will still see advertisements from us or on our online services, but that advertising will not be targeted using your Personal Data.
If we know that you are a registered user under the legal age of majority in accordance with the applicable laws of some jurisdictions from which you access or use our Services, we will not target you with advertising or send you such messages.
(6)Data We Automatically Collect
During your use of our services, in order to improve our services and ensure the security of our services, we will automatically collect information about your devices or your usage of our Services, including:
·Internet Protocol (IP) address. We collect and process this information to allow you to access or restrict your access to our Services.
·Device information. When you start using our Services, based on your specific actions in our Services and the specific permissions you have granted to us during the installation and use of our Services, we will collect information about the mobile device you are using to ensure service security, manage registrations and improve our Services, such as UUID, IMEI, MAC address, IDFA, your device model, operating system and version, APK name, App version, device display resolution, device setting, CPU information, storage information, battery usage status, time zone settings and device location information (Internet Protocol (IP) address, GPS location and WLAN connection, Bluetooth and cell site information that provides location information).
·Usage Data. For the purposes of performing our Terms of Service, we will collect details of your use of our services and keep them as Usage Data when you use our services, including your login account, IP address, provider information, internet connection environment, WIFI status information, and other Usage Data generated when you use our Services.
Please note that some of the above-mentioned information alone cannot be used to identify a specific natural person, thus cannot be considered as Personal Data. Only when such non-Personal Data is used in combination with other information to identify a specific natural person, or when it is used in combination with Personal Data, will this information be regarded as Personal Data during such combination. In this case, we will anonymize and de-identify this type of information, unless with your consent or otherwise according to laws and regulations. The above-mentioned information is essential as to the provision of the Service. If you choose not to provide them, we may not be able to provide you with our Services.
(7)Survey Information
We may also collect other information about you that we reasonably need to improve our products or services, including any feedback you provide when you contact customer service and any questionnaire you send back to us when you participate in a survey. We may combine information from one service with information from others in order to provide you with better service.
(8)Other Situations in Which Your Information May Be Collected
To the extent permitted by law, we may obtain your Personal Data from other individuals, business entities, public sources or other third parties acting at your direction, our partners who work with us to provide our products and services and assist us in information security and fraud prevention, and from other lawful sources. We will explain it to you at the time of such collection and obtain your consent.
We may also use other methods to collect other information about you, your device or your use of services, which will be explained to you at the time of collection prior to obtaining your consent.
We may use your Personal Data to send you updates about our Services, including exclusive offers, promotions, or new services. We have a legitimate interest in processing your Personal Data for promotional purposes. This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly. We will always treat your Personal Data with the utmost respect and never sell it to other organizations for marketing purposes.
You have the right to opt-out of receiving promotional communications at any time by:
· Contacting us (see "How to Contact Us" below); or
· Using the "unsubscribe" link in emails or "STOP" number in texts.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in the law, applicable regulations, or structure of our business.
Under data protection law, we can only use your Personal Data if we have a proper reason for doing so, e.g.:
·To comply with our legal and regulatory obligations;
·For the performance of our contract with you or to take steps at your request before entering into a contract;
·For our legitimate interests or those of a third party; or
·Where you have given consent.
A legitimate interest is when we have a business or commercial reason to use your Personal Data, so long as this is not overridden by your own rights and interests.
We may use your Personal Data for:
·Providing Services to you for the performance of our contract with you or to take steps at your request before entering into a contract;
·Preventing and detecting fraud against you for our legitimate interests or those of a third party, i.e. to minimize fraud that could be damaging for us and for you;
·Conducting checks to identify our customers and verify their indent to comply with our legal and regulatory obligations;
·Ensuring the confidentiality of commercially sensitive information for our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information, and to comply with our legal and regulatory obligations;
·Statistical analysis to help us manage our business, e.g. in relation to our financial performance, customer base, product range or other efficiency measures, for our legitimate interests or those of a third party, i.e. to be as efficient as we can so we can deliver the best service for you;
·Preventing unauthorized access and modifications to systems for our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could be damaging for us and for you, and to comply with our legal and regulatory obligations;
·Updating and enhancing customer records for the performance of our contract with you or to take steps at your request before entering into a contract, to comply with our legal and regulatory obligations and for our legitimate interests or those of a third party, e.g. making sure that we can keep in touch with our customers about existing orders and new products; and
·Marketing our Services and those of selected third parties to (i) existing and former customers; (ii) third parties who have previously expressed an interest in our Services; and third-parties with whom we have had no previous dealings for our legitimate interests or those of a third party, i.e. to promote our business to existing and former customers.
We do not use your Personal Data for any automated decision making purposes.
Personal Data may be held at our offices and those of our third-party service providers or representatives and agents (see "How We Share, Transfer, and Disclose Your Data" below). Your data collected by us will be stored in accordance with the laws and regulations on the personal privacy data protection of the countries concerned. You acknowledge and agree that, to the extent not prohibited by local laws and regulations, your data will be processed on our servers which may not be located in your country of residence and can be accessed by our support, engineering and/or our affiliates around the world. Your information we collect may be stored and processed for the purposes set out in this Privacy Policy in Hong Kong, Singapore or any other country in which the Company, its subsidiaries, or third party agents operate. No matter where our servers are located, we will make great efforts to take the appropriate safeguards to guarantee your rights in conformity with this Policy and any applicable laws.
We will keep your Personal Data while you have an account with us or while we are providing you services. Thereafter, we will keep your Personal Data for so long as is necessary to:
·Respond to any questions, complaints or claims made by you or on your behalf;
·Show that we treated you fairly; or
·To keep records required by law.
·We will not retain your Personal Data for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of Personal Data:
-Login information - Stored for so long as needed to provide our Services or we are required by law.
-Account information – Stored for so long as needed to provide our Services or we are required by law.
-Payment information – Stored for so long as needed to provide our Services or we are required by law.
-Information submitted to our support team – Stored for so long as needed to provide our Services or we are required by law.
-Advertising information – Stored for so long as needed to provide our Services or we are required by law.
-Automatically collected information – Stored for so long as needed to provide our Services or we are required by law.
-Survey information – Stored for so long as needed to provide our Services or we are required by law.
-Other information – Stored for so long as needed to provide our Services or we are required by law.
If your account is canceled or terminated pursuant to the Terms of Service, we will delete or anonymize your Personal Data.
The security of your Personal Data is important to us and we implement security safeguards designed to protect your Personal Data and regularly monitor our systems for possible vulnerabilities and attack. We are constantly working to improve on these safeguards to keep your Personal Data secure.
However, we need to remind you that that no method of transmission over the internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
When sharing, transferring, and disclosing your Personal Data, we uphold the principles and requirements of minimization, necessity, and legality. Except as described below, we do not share, transfer or disclose your Personal Data externally:
WE DO NOT SELL ANY PERSONAL DATA TO THIRD PARTIES. We will share your Personal Data with only where necessary. Situations where this occurs are:
·Third parties that provide services in support of the Services, including providers of cloud and network services that process or back up information identified in this Policy on their servers for the purpose of providing the Services, for the purpose of user authentication, for the purpose of processing customer support and support communication, for the purpose of analysing crashes and improving service performance, for the purpose of providing marketing and advertisements and monitoring the success of our marketing and advertising programs, for the purpose of providing you with updates and information regarding the Services, for the purpose of providing translations, for the purpose of detecting whether user-generated content violates applicable laws, our terms or community rules, for the purpose of payment processing services (including security and fraud detection) and for the purpose of informing and improving the refund process if you request a refund. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services in support of the Services.
·Companies within our corporate group who process your personal information in order to operate the Services. All related group companies may only use your personal information in accordance with this Policy.
We only allow our service providers to handle your Personal Data if we are satisfied they take appropriate measures to protect your Personal Data. We also impose contractual obligations on service providers to ensure they can only use your Personal Data to provide services to us and you. Your Personal Data received by these third party service providers may be subject to their respective privacy policies or notices, and this Policy does not apply to any products, services, websites or content that are offered by third parties. We are not responsible for the third-party service provider’s collection, use and/or processing of your Personal Data.
We will not transfer your data to any other parties, except in the following circumstances:
·Where we have obtained your explicit consent.
·If we are involved in a merger, acquisition or sale of all or part of our assets, which may affect your Personal Data, we will issue a prominent notice via email and/or on our website or other appropriate methods to inform you of any changes in the ownership and your rights of your Personal Data, and any choices you may have about your Personal Data.
·Where we have explained we will transfer Personal Data to third parties in this Policy or have notified you by other means.
We may need to disclose data about you when required by law, subpoena, or other legal process or if we have a good faith belief that the disclosure is reasonably necessary to (1) investigate, prevent or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you; (3) investigate and defend ourselves against any third-party claims or allegations; (4) protect the security or integrity of our Services; or (5) exercise or protect the rights and safety of our Services, our users, personnel or others. We attempt to notify users about legal demands for their Personal Data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
Additionally, we may share your data with:
·Our attorneys, lawyers, accountants, auditors, or similar consultants when we request them to provide professional advice.
·Investors and other relevant third parties, if actual or potential sales or other company transactions occur and are related to entities within our group.
·Other third parties, for example, the disclosure of specific information with your authorization.
For the purposes described in this Policy, and to the extent permitted by applicable local laws and regulations and with your authorized consent, we may transfer your Personal Data to our servers stipulated in Section V (How We Store and Protect Your Personal Date) of this Policy for storage or processing, we may also transfer your Personal Data to third-party service providers and business partners and your data may therefore also be transmitted to other countries or regions.
In the circumstance that we transfer Personal Data outside of your jurisdiction, whether it is transferred to our affiliates or third-party service providers, we will comply with relevant applicable laws. We will take appropriate security measures and safeguards to make sure that all such transfers meet the requirements of applicable local data protection laws.
Our Services are not intended for children under the age of thirteen (13) or the minimum age in the relevant territory if that age is older than thirteen (13) (the "Child" or "Children"), and we do not knowingly collect any personal information from such Children. Children should not use or attempt to use our Services, and if you are a Child, please do not attempt to use our Services or send any information about yourself to the Company.
In the event that we learn that we have inadvertently gathered personal information from a Child, 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 may submit a request to delete such information to our email address listed in Section XIII (How to Contact Us) below.
You have specific rights regarding your personal information, which are described in this Section. You or an authorized agent acting on your behalf may exercise your personal information rights by submitting a verifiable request or through our platform (see "How To Exercise Your Rights" below). If an authorized agent submits a request to know or delete your personal information, we require you to:
·Provide your authorized agent with signed permission to exercise your rights and choices;
·Verify your identity directly with us; and
·Directly confirm with us your authorized agent has permission to submit the request.
You have the following data protection rights:
·The right to access or delete the data we have on you. You have the right to access your Personal Data that we hold about you. If you request a copy of your Personal Data, we will provide you a copy in an electronic format after passing our verification process. Subject to certain exceptions permitted by applicable law, on receipt of a verifiable request we will delete your Personal Data from our records and direct our service providers, contractors or other third party affiliates to delete your Personal Data from their records unless they have obtained your separate consent for processing. However, if you choose to delete any of your Personal Data, some features that require such data may no longer be available, and you acknowledge and agree that we may retain your Personal Data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
·The right to rectify. If you consider that Personal Data we hold about you is inaccurate or incomplete, you have the right to obtain rectification of your Personal Data without undue delay.
·The right to object and restrict. You have the right to object to our processing of your Personal Data (e.g., at any time to your Personal Data being processed for direct marketing) or request that we restrict the processing of your Personal Data. You can ask us to stop using all or some of your Personal Data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your Personal Data is inaccurate or unlawfully held).
·The right to data portability. You have the right to be provided with a copy of the data we have on you in a structured, machine-readable and commonly used format.
·The right to withdraw consent. You also have the right to withdraw your consent at any time where we relied on your consent to process your Personal Data. You can withdraw your consent previously granted to us for a specific purpose by deleting data, turning off device features, and requesting to withdraw consent by contacting us (see "How to Contact Us" below), including the collection, use and/or disclosure of your Personal Data that we manage or control. If you withdraw your consent, you may not be able to continue receiving the part and/or full benefit of our Services. The withdrawal of your consent or authorization will not affect the validity of our previous processing activities based on your consent.
·Right to control your privacy settings. You have the right to control your privacy settings and restrict our collection, use, disclosure, or processing of your Personal Data via such privacy settings. For example, you can choose to turn on or turn off the permissions of "Location Access" or "Storage"; you can obtain detailed data regarding the device security status or change such status in "Privacy Settings" on your device.
·Right to close your account. You can close your account via instructions in our Services or contact us for help. Please understand that for security reasons, your account cannot be closed unless you follow our instructions. We hereby kindly remind you that, if you wish to close your account, such closure may prevent you from using our Services, and such closure is irreversible. Once you close your account, we will delete or de-identification your relevant data. If you sign into the accounts through a third-party account (e.g., via Apple ID, Facebook, Google ID), you need to apply for account closure from such third party.
According to the applicable laws of some jurisdictions, you may have other data subject’s rights. Please refer to Jurisdiction Specific Supplemental Terms at the end of this Policy.
To easily access, view, update, correct, delete or port your Personal Data, or to update your subscription preferences, please sign into your account and visit "Account Settings" or contact our customer service. Where we rely on consent to collect and use information about you, you can withdraw your consent at any time. If you make a request to delete your Personal Data and that data is necessary for the Services you have purchased, the request will be honored only to the extent it is no longer necessary for any Services purchased or required for our legitimate business purposes or legal or contractual record keeping requirements.
To exercise the access, data portability, correction, and deletion rights described above please submit a verifiable request to us by emailing us at tongits-bd@higgsgamestudio.com.
Only you, or a person authorized by law to act on your behalf, may make a verifiable request related to your Personal Data. You may also make a verifiable request on behalf of your minor child.
You may only make a verifiable request for access or data portability twice within a twelve (12) month period. The verifiable request must:
·Provide sufficient information (including your account name, passwords, email address and other information reasonable requested by the Company) that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized agent;
·Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you.
If your account is lost, you can verify through SMS, email or contact customer service to reset your password. However, in this process, you need to provide some Personal Data to verify your identity. When retrieving your password, we may need you to provide frequent login location, frequent login device, frequent listening content, registration time and city information.
Making a verifiable request does not require you to create an account with us. We will only use Personal Data provided in a verifiable request to verify the requestor’s identity or authority to make the request.
We endeavor to respond to any verifiable request within one (1) month of its receipt. If we require more time, we will inform you of the reason and extension period required in writing. We will send you confirmation of receipt of any verifiable request within ten
(10) business days of its receipt.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by the method you submitted your request.
If we cannot comply with a verifiable request, we will explain our reasons to you in writing, if applicable. For data portability requests, we will select a format to provide your Personal Data that is readily usable and should allow you to transmit the information from one entity to another without hindrance.
Typically, you will not have to pay a fee to access your Personal Data or to exercise any of your privacy rights. However, except in relation to consent withdrawal, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing the request. We may also refuse to comply with your request in such circumstances.
We may decline to comply with your request under the following circumstances, and in accordance with applicable laws and regulations:
·Where it is related to our obligations under law and/or regulation;
·Where it is related to national security and national defense security;
·Where it is related to public safety, public health and major public interests;
·Where it is related to criminal investigation, prosecution, and trial;
·Where there is sufficient evidence to show that you have subjective malice or abuse of rights;
·Where responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals and organizations;
·Where trade secrets are involved;
·Other conditions stipulated by laws and regulations.
Cookies are small text files to ensure that our software’s normal operation and your convenient access to it. Cookies usually contain identifiers, site names, and some numbers and characters. We may use Cookies and other similar technologies such as Pixel Tags and Web Beacons. We generally treat information collected by Cookies and similar technologies as non-Personal Data as they do not contain any of your personally identifiable information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered Personal Data by the laws of the countries concerned, we will also follow the laws of the countries concerned.
We and our partners may use cookies and similar technologies (e.g., pixels and ad tags) to collect data (e.g., device IDs) to recognize you and your device(s) on, off and across different services and devices where you have engaged with our Services. You can manage or delete Cookies according to your preferences.
Because consumers are often unaware that their do not track beacons are active, Do Not Track signals frequently do not reflect the actual preferences of our users. We do not respond to Do Not Track signals. In the meantime, you may opt out of certain types of tracking, including certain analytics and tailored advertising by changing your cookie settings.
You may receive links to third-party websites or content and services provided by third parties other than us during your use of our Services, and some third parties’ products or services can be accessed in the form of SDKs and others in order to provide you with some functions and features, such as to provide you with third party logins, notifications and user analysis (collectively, the "Third-Party Services").
You can choose whether to visit or accept such Third-Party Services at your sole discretion, and we encourage you to read and review the privacy statements of each Third-Party Service that you may choose to use.
For the purpose of establishing the Personal Data protection in a better and more efficient way, we, as the Data Controller, designate a Data Protection Officer (in short, "DPO") who is responsible for the oversight and implementation of the Personal Data protection strategy and ensures our processing of Personal Data is in compliance with necessary legal requirements stipulated in the applicable laws. If you have any comments, questions or concerns with respect to our Privacy Policy or Personal Data protection practices, please contact our DPO Rory at tongits-bd@higgsgamestudio.com (All requests must be labeled "Privacy Policy request" on the email subject line for us to better assist you).
We will review your privacy or Personal Data requests and respond to you as soon as possible after verifying your user identity. If your request itself involves any complicated or significant issue, we may ask you for more information.
If you would like this Policy in another format (for example: audio, large print, braille) please contact us (see "How to Contact Us" above).