Privacy Policy

Effective Date: Friday, Sep 9, 2022

Latest Update: Friday, Sep 9, 2022

 

Introduction

This privacy policy informs you of your choices and our practices regarding the processing of your personal information in connection with the Service. Your use of the product(s), service(s) and related websites (“Service”) is distributed by WOOBEST INTERACTIVE (HONG KONG) COMPANY LIMITED (“WOOBEST”, “Woobest”, “we” or “us”) or their derivatives.

Affiliate in this Privacy Policy shall mean an entity that directly or indirectly controls, is controlled by or is under common control with WOOBEST INTERACTIVE (HONG KONG) COMPANY LIMITED hereto.

When you contract to use the Service, you accept our rules and policies regarding your personal information, and you expressly consent to us collecting, processing, using and storing your personal information, as described in this policy.

It is important for you to understand how this happens and how you may control it. By accessing our APP, websites or otherwise, and clicking the “Agree” button on the pop-up window, you acknowledge that you have read, understood, and accepted the following terms. In the case you do not agree to any of the terms, you should immediately stop using our services.

Part of our Services are not designed for Minor, and since a “Minor” is usually considered to be under the age of 16GDPR/14KOREA and other countries or regions /13 (CCPA, JAPAN and other countries or regions, subject to the laws of your country under applicable laws of most regions, we do not directly provide Services to Minor under the age of [16/14/13]. If you are under the age of [16/14/13], you shall ask for the consent of your parent or legal guardian before using our Services. We also do not knowingly collect Data from Minor through the Service. If you are the parent or guardian of a Minor and you believe that we have inadvertently received your kid’s information, please contact us . We will delete the Data from our records as soon as possible after verifying your identity. If you are not a parent or legal guardian but believe that we might possess any Data from or about a Minor under the age of [16/14/13], you are also encouraged to contact us as well. We encourage parents to instruct their Minor to never give out personal data when online.

In the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, we will make an announcement in advance, disclose the details of the event and information about the successor, and with the express consent of you or your guardian in advance again, your personal data may be transferred to the successor of Woobest.

If you have any comments, questions or complaints regarding the processing of your personal information, you can contact us at dyqlb.kefu@gmail.com.

 

1. The Scope of this Privacy Policy

WOOBEST publishes and operates games both on webpages and mobile devices. WOOBEST, including its affiliates, subsidiaries or other entities that control, are controlled by or are under common control with WOOBEST will be referred to as "WOOBEST", "we", "our" or "us" in this Privacy Policy.

This Privacy Policy shall apply when you access and use our Services and Websites, including any websites, games, applications, domains owned or controlled by WOOBEST.

 

2. What Data We Collect and Process

This section describes the different types of personal information we collect and how we collect it. Personal information means data that may be used to identify an individual, such as email address, contact address, postal code, position data, title, occupation, personal interests, and other data that you choose to submit. As we change our offerings and features from time to time, the information we need may vary depending on the services you are using. You are fully aware that you are not compelled to provide the information we need, and if you refuse to provide, you might not to be able to access or enjoy certain Woobest’s Services, offering or features. In general, we may need your agreement.

2.1. Information you provide us.

2.1.1 When you register for the Game (including your nominated nickname, or custom accounts and information we collect from your connected social media account (Apple, Facebook, Google) in order to set up your profile, including your name as it appears on your social media profile and your profile picture);

2.1.2 When you log in as a ‘guest’ in order to use the Game (your nickname);

2.1.3 You may also choose to provide us with your mobile phone number or email address to set up a Game account and create a password by yourself. These will be linked to your account (once verified by way of a verification code we will send to you) for the purposes of enabling login by email or mobile phone number. If you choose to link your phone number or email address with your account, you will have the option to log in via your mobile phone number or email address, and we will access your phone number or email address to verify you as a user without you having to enter a validation code or password every time you log in. 

2.1.4 When you participate in a survey in the Game (in which case we will process the information you provide to us as part of the survey, including country, age, gender, profession and email address)

2.1.5 When you participate in one of our sweepstake events, which may be conducted in-Game, on our Website or otherwise, you provide us with information including email address, Open ID, phone number, mailing address and country; 

2.1.6 If you participate in one of our game-based events, to send you digital prize(s) once you win such prize(s), we will process your email address and telephone number; to deliver physical prize(s) once you win such prize(s), we will process your name (as shown on your passport), email address, telephone number, mailing address and postal code.

2.1.7 When you transact through our Services (if applicable) or with our third-party payment service providers authorized by uswe will process your registration information related to payments and other personal information related to payments.

2.1.8 When you link your Account with Your Social Media Accounts (Facebook, Google, etc.) or other external accounts or use other social media functions in accordance with the Provider's policies.

2.2. Information we may collect about you.

We automatically collect certain data from you when you use the Game Services, namely your open ID, IP address, device information (such as application version, network type, OS version, platform, carrier, Android ID, IDFV, time zone settings), registration time, login time, battle performance information, and other information regarding your use of the Game Services, such as date and time stamps of actions. We also collect and store your data:

2.2.1 each time you interact with us. For example, when you use in-app or in-Game support to communicate with uswe may collect your question and feedback about our game, or your chatting records with us.

2.2.2 if you choose to log in using a social media service, we collect the social media user ID and name of the friends (and in the case of Facebook, their Facebook nickname and profile picture) from your social media profile so that you can connect with your friends and share game activities with your friends;

2.2.3 Information we need you to provide or information you provide to us voluntarily

i. Contact Information (such as email address or telephone number, if necessary)

ii. Account Information (such as Nick name, profile photo, User ID etc.

iii. Customer Support Information, such as the purchases and purchase records, including purchase time, product, currency, cost; the screenshot photo (if you choose to upload the photo to illustrate the questions); verification information (such as User ID, Nickname, Server ID, Device ID, etc.)

iv. Other Information You Provide (such as information contained in your posts, comments when using certain functions in our Services; information you send when communicating with other users; information you provide to us when participating in competitions, contests, tournaments and online surveys).

v. IDFA (for IOS) (In order to better provide you with personalized service)

 

2.2.4 Information we collect automatically

We may also collect Information automatically through technologies such as log files, web beacons from you when you are using our Services. We use these Data for purposes such as assigning servers based on IP address of the users, maintaining the purchase history, modifying or improving features of our Services, managing advertising, addressing technical issues and improving the security of the game, preventing fraud, and conducting data analytics. The type of Data that we automatically collect may vary, but generally includes:

i. Game Data: Gameplay data (such as game setting, level, heroes, scores), Ad clicks, In-game interactions (such as friends list and chat logs), Referral/exit pages, Click records (such as battle records, mall records, activity records, social category), Player behavior data (such as user’s online time), data related to the stability of the game software (such as Flash back, crash data);

ii. Device Information: Internet Protocol (“IP”) address, device ID, device name, device type, operating system version, advertising ID, MAC, IMEI, inventory of installed apps, Hardware Information (e.g. storage, CPU, device type, operating system, language).

iii. Transaction Records: Transaction information from payment platform, such as Google Play or iOS App Store (purchase time, order number, in-game product purchased, cost, email address (if the payment platform provide for us), Purchase history in-game Amount, (e.g. virtual item, payment channel, order number, exclude actual finance information). But for security reasons and to better protect your privacy, we do not directly collect or store your payment information like valid credit card number, expiration date etc.     

 

Certain game features of our different Services may require access to your Camera, Microphone, device location and other sensitive device or usage data. We will use a runtime permissions request whenever available prior to accessing data gated by Android or IOS permissions. For example, we will request you to grant us the Camera Permission before scanning QR code, to grant the Microphone Permission before functioning the in-game voice chatting feature, to grant the read-external-storage permission (or other permissions similar with different name in the operating system) to read game data and screenshots of the game, etc.

 

2.2.5 if you choose to participate in our Beta test, the following information will be used to verify your eligibility: your login credentials, Open ID, account type, Game level, frequency of use of Game, whether your Game account is linked to a Beta test account, and whether you have cheated in the Game;

2.2.6 We may offer publicly accessible Services, such as pages, blogs, private messages, or community forums. You should be aware that, when you disclose information about yourself in our Services, the Services will collect the information you provide in such disclosure, including any Personal Information. If you choose to submit content to any public area of the Services, such content will be considered "public" and will not be subject to the privacy protections set forth herein.;

2.2.7 If you add event schedule information to your system calendar, this will be provided on the device-side only;

2.2.8 If you contact our support team, we may collect information including name (optional), Open ID, device ID, application version, network type, OS version, platform, carrier, details of ticket, email address (optional if in-app/in-Game support) and any information that you provide in your communications. You also have the option of providing a photo to illustrate any errors;

2.2.9 When you are using the Game Services, our security and anti-cheating security features will

i. monitor users to identify and observe cheating behavior;

ii. collect (in addition to the categories of data listed above) user’s in-Game instructions to generate an in-Game behavior video clip of suspected cheating behavior for our review;

iii. identify abuse, harassment, the sale of plug-ins or other conduct in violation of our Terms of Service and restrict your use of the chat functions where you have engaged in any of the foregoing if this is the case;

iv. detect if your signature, nickname, profile photo or chat history contains malicious information and changing it to its default setting and prompting you to change it subsequently if this is the case and

v. detect if you are using tools to cheat, take screenshots where there is suspected cheating behavior for our review and restrict your use of the Game if this is the case.

2.2.10 Processing of Unique Identification Information

i. Unique Identification Information refers to a resident registration number, passport number, driver's license number, and foreign registration number in the Personal Information Protection Act and Enforcement Decree

ii. Woobest collects and processes Unique Identification Information for the following purposes, and it will be collected upon separate consent from you.

a. Tax or utility charges are imposed on prize winners in kind

b. When required by applicable laws

iii. The collected unique identification information is not used or provided for purposes other than those specified in paragraph 2, unless otherwise stipulated by law, and it will be encrypted and safely managed when stored.

 

2.3.Data we obtain from third- parties

We also may receive Personal Information from or through certain third-party service providers (such as Social Media Platforms, third-party payment platforms, Advertising Partners, Fraud-Detection Service Provider, Customer Support Partner, Anti-Crack and Anti-Cheat Service Provider, Social sharing Tools Provider, etc.) which help us provide the Services and/or facilitate your access to the Services:

i. Data we receive from Social Media Platforms to or through which you link, connect or log in to Woobest Services (e.g. Tap.io) as explicitly allowed by you (such as (a) your nick name in Tap.io; (b) your profile photo used in Tap.io; (c) your Tap.io user ID number; (d) contact list in Tap.io; € your physical location/region and (f) your gender). Please bear in mind that the Third Party controls your Data and you may vary your authorization and revoke consent through privacy setting on the Third Party’s platform.

ii. Data to fight cheating and fraud.

iii. Data from third-party payment platforms that help Woobest Services run on (such as to verify and confirm payment, record purchase history and/or protect our legitimate interest when resolving subsequent payment disputes and inquiries).

iv. Data to measure the effectiveness of advertising.

v. Crash and Errors data.   

 

We collect the above information for the purposes of updating your profile, performing market analysis, and/or otherwise improving the Woobest Services. We abide by this Privacy Policy when we use Personal Information provided to us by third -parties.

 

3. How And For What Purpose Do We Use Your Personal Information?

3.1 We will only collect your personal information for the provision of our service and to improve our service quality for better user experience. For example, we may use your phone/mobile phone number in promoting activities (to send push notifications, to send gifts, etc.). In most cases, we will not share your personal information we collected from you. Your prior approval will be obtained if we need to share your personal information with other third parties beyond the scope that you have consented to.

3.2 Our objective in storing and collecting your information is to provide players with a better gaming experience by allowing us:

3.2.1 To operate, improve and optimize our Services, Websites and our players’ experiences;

3.2.2 To create your game accounts and allow you to play our games;

3.2.3 To identify and suggest connections with other players and personalize our Services to you;

3.2.4 To enable players to communicate with each other;

3.2.5 To provide technical support and respond to player inquiries;

3.2.6 To help prevent fraud or potentially illegal activities, and enforcing our Terms of Services;

3.2.7 To manage and deliver contextual and behavioral advertising;

3.2.8 To notify players of in-game updates, new products or promotional offers;

3.2.9 To administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners;

3.2.10 To comply with our legal obligations, resolve any disputes we may have with you or other players, and to enforce our agreements with third parties; and

3.2.11 To improve our service.

3.3 We may send you promotional information to the email address you provided us. If you have left your mobile numbers or identifiers of your communication device, we may send some promotional information to the mobile phone or the communication device. IF YOU DO NOT WISH TO RECEIVE SUCH INFORMATION, YOU CAN CANCEL THE PUSH THROUGH [UNSUBSCRIBE] IN THE EMAIL OR TEXT MESSAGE.

 

4. Cookies or Similar Technologies

4.1 In order to measure the effectiveness of our services, we may use cookies, which are small text files for added functionality or for tracking site usage. We may use cookies and/or authorize a third-party’s tracking-utility, from time to time, (a) to log your IP address in determining the path that users take on our sites and identifying repeated users of our sites, (b) to collect the websites or sources that linked or referred you to our services, and/or (c) to collect technical data about the devices and software you use to access our services, the operating system of your devices, and other similar technical data. Notwithstanding the foregoing, we do not link your IP address to your personal data. If you do not wish to accept cookies or want to be notified of when they are placed, you may set your web browser to do so, if your browser permits.

4.2 We use the cookies, web beacons and similar technologies to personalize your experiences on our services and for various other purposes, including:

4.2.1 Remembering you: cookies, web beacons and similar technologies help us identify you as a registered user and keep the preferences or data that you have previously provided;

4.2.2 Analyzing how you use our services: cookies, web beacons and similar technologies help us understand what visitors (including users) are doing on our services, or what pages or sections are most popular;

4.2.3 Deliver advertising: cookies, web beacons and similar technologies help us provide you with advertising that we believe is relevant to you or of interest to you, on the basis of the data you provide; and/or

4.2.4 Other related functions or purposes mentioned in Article 2 herein.

4.3 We or our authorized contractors may use cookies and similar technologies to provide and personalize services, prevent fraud and fulfil other purposes mentioned above. Please note you can disable cookies in your browser settings, while some parts of our services may then not function properly.

 

5. Who May Access Your Personal Data

In addition to WOOBEST and/or its affiliates, other parties may also access your personal data in the following situations. You acknowledge that you have foreseen and agreed to the occurrence of such disclosure when you provide your personal data.

5.1 Other In-Game Users of Our Services

Other users may, for example, in a group challenge, access your in-game activities in the process of such group challenge. Other users may also see your displayed data and read the messages you have posted on or through our services. You acknowledge and agree that our services may also include message boards, communities, forums, and/or other chat areas, where users may exchange ideas or communicate with other users, and that any data you post to any communication area is publicly viewable. We strongly recommend that all users avoid posting personal or sensitive data at any time on or through our services.

5.2 Competent Authorities

5.2.1 We may provide a certain portion of your personal data to judicial or administrative authorities as so requested. Besides, we may disclose certain portion of your personal data to a strictly limited scope of recipients when we reasonably think it is necessary to protect us, our users or a portion of the public.

5.2.2 In addition to being required by applicable laws, we reserve the right to disclose your personal data in the cases if we, in our good faith, believe that disclosing such data is necessary to identify, contact, or bring legal action against you, if (a) you are violating any other agreement(s) between you and us, such as the Terms of Service, this Privacy Policy or otherwise damage us; (b) you are infringing third-parties’ rights and interests (including but not limited to intellectual property rights); and/or (c) we believe that it is necessary to prevent fraud or other illegal activities.

5.3 Third-Party Contractors

WOOBEST works with a number of (if any) third parties on or through our services to help us provide services and functionalities to you. We do not sell your personal data and only share data that is non-personally identifiable on its own, aggregated, or public with third parties under the following necessary circumstances, and such third-parties thereof are prevented from processing (including but not limited to accessing, storing, using, or disclosing) your personal data except for achieving the purpose of their cooperation with us:

5.3.1. Social networking portals who provide login and/or content-sharing service to and in our services;

5.3.2 Logistics service providers who provide shipping services such as delivering physical prizes to users;

5.3.3. Information communication service providers who provide SMS-messaging services;

5.3.4 Payment service providers who provide payment services, such as assisting our services to run on, facilitating users’ payment, and maintaining a record of the users’ transaction history;

5.3.5 Advertising service contractors who provide marketing and advertising activities, including conducting the programs, tracking the success, and analyzing the effect thereof; and

5.3.6. Other contractors, if any, for the purpose of providing our services to you.

5.3.7 Besides, such contractors may use cookies, web beacons, and/or other tracking technologies to collect or receive data about you and might claim the data controller rights over your personal data. For example, users purchasing and/or subscribing products or services will be required to provide additional data to third-party payment contractors, such as a valid credit card number and expiration date. Such third-party payment contractors may collect, process and retain your data to process payments and resolve subsequent payment disputes and inquiries. We may also receive, process and store the provided information from you and/or such third-party payment contractors to confirm payment, record purchase history and/or protect our legitimate interest when resolving subsequent payment disputes and inquiries.

5.3.8 Notwithstanding the foregoing, if you make any payments in using our services, any of your payment details are fully handled by the relevant payment service provider. We do not, however, receive and/or process any of your actual payment details such as card number or security code. We only keep the data concerning transaction date, currency, cost, and product(s) purchased.

5.3.9 Each third-party has its own privacy policy and security measures for processing data and information, so when specific third parties are involved in collecting data and information, please review their privacy policies. Since those contractors may access, collect, or process your data as the data controller and operate under their own privacy policies, please refer directly to their privacy policies on their official websites and learn more about their data processing practices. YOU MAY CLICK HERE TO KNOW THE DETAILS OF THE DATA DISCLOSURE.

 

6. How We Share and Disclose Your Personal Data

6.1 In addition to WOOBEST and/or its affiliates, other parties may also access your personal data in the following situations. You acknowledge that you have foreseen and agreed to the occurrence of such disclosure when you provide your personal data.

6.2 We will NOT share or disclose your personal data with any other commercial entity, organization or individuals, except for the following situations:

6.2.1 With your consent. We may disclose sharing or disclose your personal data when you provide us with your consent to do so;

6.2.2 Law enforcement bodies and courts. We disclose information in response to legal process, for example, in response to a court order or a subpoena, or in response to a law enforcement body's request. We also disclose such information to third parties:

i. in connection with fraud prevention activities;

ii. where we believe it is necessary to investigate, prevent, or take action regarding illegal activities;

iii. in situations that can involve violations of our terms of use or other rules;

iv. to protect our rights and the rights and safety of others; and

v. as otherwise required by law.

6.2.3 Service providers. In order to support the purpose listed in this Privacy Policy, our agents or contractors (either data controller or data processor) may need access to information to carry out services, including but not limited to, logistic, payment, SMS, email, anti-fraud, risk management, advertisement attribution, etc.

Information shared with such service providers will follow the principle of legal, proper, essential, and with clearly defined purpose. We also sign NDA and DPA with each service provider to make sure they will follow our requirements, including the requirements mentioned in this Privacy Policy, to deal with the shared information and subject to confidentiality obligations;

6.2.4 Linked sites. Some of our sites contain links to other sites, including Social Media Sites, whose information practices can be different from ours. You should consult the corresponding sites' privacy disclosures and terms before submitting any information, as we have no control over information that is submitted to, or collected by these third parties; and

6.2.5 Other third parties. Where permitted by law, we may also share information with authorized third parties for the following purpose in case of essentials: protect crucial public interest, statistics analysis, science or history research.

 

7. Data Retention

7.1 In order to perform our contract with you, your personal information will be accessible from and will be processed on our servers. Our servers are hosted on cloud servers such as Amazon Web Services. Your information may be transferred to and processed in countries outside the country you are located. We will take steps necessary to comply with applicable legal requirements, such as using European Commission approved Standard Contractual Clauses to protect your information. In particular, your information will be transferred to and processed in Hong Kong where our central database is based.

7.2 Our Service is global by nature and your Personal Information can therefore be transferred to third parties or service providers or business partners located within or outside your jurisdiction. We will ensure: 1) We will anonymize or de-tag your personal information; 2) We will give you a special reminder and obtain your consent again.

7.3 We will keep your personal information for as long as your account is active or that information is necessary for us to provide you with the Woobest Services unless we receive your request to deleteAnd we will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or where a longer storage and retention period is required to comply with any statutory, regulatory, or legal obligations. After that, your personal information will be deleted, blocked or anonymized, as provided by applicable laws.

7.4 In the event that the processing and retention period have terminated, but personal information is required to be retained continuously for other reasons including 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, we will destroy your personal information in accordance with local laws.

7.5 INTERNATIONAL DATA TRANSFERSAs different countries may have different Data Protection and Privacy lawspolicies, and other regulations, you are fully aware that applicable laws in some country may not offer you privacy protection which is in the same level as such offered in the country where you live or work. In such cases, we will take steps to ensure adequate safeguards are in place to protect your data. For example, we will contractually oblige the receiving parties to ensure that the same level of data protection is accorded to your information that is adhered to by us under applicable laws. Further, we contractually ensure that such information is not disclosed, published, or transferred further.

8. Your Rights

If you request in writing, we will provide you a copy of your personal data in an electronic format after passing our verification process. You also have the right to correct or modify your data, have your data deleted, object how we use or share your data, restrict how we use or share your data, and make any other request as provided herein or regulated by the applicable regulations from authorities (including but not limited to the GDPR and the CCPA) through sending an email to us. Upon receiving your request via email, we will promptly conduct a verification process including but not limited to instructing you to provide information to confirm that you are the user from whom we have collected information, subject to the specific instructions of us. 8.1 Right to know about personal information collected, disclosed, or sold

You have the right to access your personal data that we hold about you, i.e. the right to require free of charge, (i) information whether your personal data is collected, used, or disclosed , (ii) categories of your personal data which has been collected, (iii) categories of sources from which your personal data is collected, (iv) business or commercial purpose for collecting your personal data (if any): i.e. the categories of your personal data which has been disclosed to third parties, the categories of third parties to whom your personal data was disclosed; and you have the right to require us to provide a duplicate of your personal data undergoing processing, subject to submitting a verifiable request in the form of email to us as agreed in Article 14. According to our reasonable and unilateral judgement, if your verifiable request affects or will affect the rights or freedom of other users or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs arising therefrom) or refuse to act on the request.

8.2 Right to rectify

If we process your personal data, we shall endeavor to ensure by implementing suitable measures that your personal data is accurate and up to date for the purposes for which it was collected. If your personal data is inaccurate or incomplete, you have the right to obtain rectification of your inaccurate personal data without undue delay according to Article 16 of the GDPR and you can modify the information you provided via the privacy dashboard.

8.3 Right to request deletion of personal information

You have the right to obtain deletion of your personal data, if the reason as stated in Article 3 of this Privacy Policy does not exist anymore, or if there is another legal ground for its deletion, subject to submitting a verifiable request in the form of sending an email to us as agreed in Article 14.

You have the right to request deletion of your account and related Personal Information. If you choose to have your Personal Information removed from our active databases, we will carry out your request within 15 days after we verify your identity unless otherwise required by applicable laws and regulations. After deletion, we will only retain necessary information to document your request and the actions we took to carry out your request. And you are fully aware that once your personal information is deleted, we will not be able to provide you with corresponding services or recover the information with today’s technology.

You acknowledge and agree that as a result of deleting your Game Account, you will lose access to game related services, including the account information, subscriptions and game-related information linked to such Game Account and lose the possibility to access other services through the Game Account.

8.4 Right to object

When our processing of your personal data is based on legitimate interests according to Article 6(1)(f) of the GDPR and/or Article 3 of this Privacy Policy or any other applicable laws in your country of residence, you have the right to object to our processing. If you object, we will no longer process your personal data unless there are compelling and prevailing legitimate grounds of processing as described in Article 21 of the GDPR or any other applicable laws in your country of residence; in particular, if the data is necessary for the establishment, exercise or defense of legal claims. You also have the right to lodge a complaint at a supervisory authority.

8.5 Right to restrict processing

You have the right to restrict the processing of your personal data under the conditions set out in Article 18 of the GDPR or any other applicable laws in your country of residence.

8.6 Right to personal data portability

You have the right to receive your personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller under the conditions set out in Article 20 of the GDPR or any other applicable laws in your country of residence.

8.7 Right to opt-out of the sale of personal information (if any)

You have the right to opt-out of the sale of your personal data (if any) and require us to make a statement regarding whether or not we sell your personal data and provide an opt-out mechanism or link to it except as otherwise stipulated in the CCPA.

8.8 Right to non-discrimination for the exercise of a consumer’s privacy rights

You have the right not to receive discriminatory treatment by us for the privacy rights conferred by the CCPA, namely that we shall not offer a financial incentive or a price or service difference due to your exercise of any of your rights under the CCPA unless such difference is reasonably related to the value of your personal data. Notwithstanding the foregoing, we have the right to deny your request to know, request to delete, or request to opt-out for reasons permitted by the CCPA or those regulations thereof, and such denial shall not be considered discriminatory.

8.9 Right to authorize an agent to make a request on your behalf

You have the right to authorize an agent on your behalf to make a request to know, delete, or opt-out under the CCPA. When you use an authorized agent to submit any request provided above, we may require you to provide signed permission to authorize your agent to do so for the purpose of verifying your identity, and the official permission by your agent to submit this request. In the case of failure to provide any of the requested materials, to protect the user’s information and data security, we are entitled to denying such request.

8.10 Notwithstanding the foregoing, if the applicable laws in your country of residence provide otherwise, the corresponding laws shall govern.

8.11 Right to lodge a complaint

You have the right to lodge a complaint regarding our collection, processing, or storage of your Personal Information with a data protection supervisory authority in the country where you live or work.

 

9. Age Limits and Children Protection

9.1 You represent that you are an adult or older in your country of residence (or at other age in your jurisdiction where you are classified as a majority) when using our services. If you are a minor or under the legal age of majority ("Minor" or "Child"), please do not send any personal data about yourself to us, including your name, address, telephone number, or email address.

9.2 Notwithstanding the foregoing, we recognize that we have a special obligation to protect children in regard to the collection and processing of personal data, and we do not and will not knowingly collect personal data from children without consent from their parents or guardians. We strongly urge parents and guardians to instruct their children never to disclose or give out their personal data when using our services without the prior permission of their parent/guardian. If we learn that we have collected personal data about a child, we will delete that data as quickly as possible. Also, if you believe that we might have any data from or about a child, please contact us at our email.

 

10. Links to Sites and Service Operated by Others

WOOBEST Service may contain links to other sites, applications, and services. Because WOOBEST does not operate those other sites, applications, and services, we cannot take responsibility for the privacy practices of the entities that operate them. We recommend that you consistently check privacy policies to understand an operator’s practices. As a reminder, this policy describes only WOOBEST’s practices.

 

11. MERGER, ACQUISITION, SALE OR INSOLVENCY

11.1 In the event that we are acquired by or merged with another entity, we reserve the right, in any of these circumstances, to transfer the information or assign our rights to the information that we have collected from our Users as part of such merger, acquisition, sale, or other change of control.

11.2 In the event of our insolvency, reorganization, receivership, winding-up or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your personal information is treated, transferred, or used.

 

12. The Security of Your Personal Information

12.1 Pertaining to your use of our services, we have endeavored to take reasonable measures to prevent unauthorized access to or improper use of your personal data, such as organizational controls, technical protection, and other protection measures.

12.2 Unfortunately, the transmission of information via the internet is not completely secure. While we strive to protect your personal data, we also remind you to be aware of hacking, cyber-attacks, and other risks on the internet.

12.3 Therefore, we strongly urge you to take every possible precaution to protect your personal data when using our services, including but not limited to changing your passwords from time to time, not reflecting your real name or other personal data in registration, using a combination of letters and numbers when creating passwords, using a secure browser and/or taking other possible security measures. Please note that for security reasons, we store passwords in encrypted form.

12.4 If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice on the Website if a security breach occurs.

12.5 Please be aware that advertisers or websites with links to and/or from our websites may collect personal data about you and this Privacy Policy does not apply to, and cannot control the activities of, those other advertisers or websites. We highly recommend that you read the privacy policy of such third-party websites which you may be directed to before providing any personal data.

 

13. Changes to This Privacy Policy

13.1 This Privacy Policy may change from time to time. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services after the updated Privacy Policy is posted on the Services. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Services.

13.2 Revision to the Privacy Policy. We may revise this Privacy Policy in our sole discretion, so please review it periodically. If you continue to use the Services made available to you after such changes have been made, you hereby provide your consent to the changes.

13.3 Posting of Revised Privacy Policy. If there are any material changes to this Privacy Policy, WOOBEST will notify you by email or as otherwise required by applicable laws. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.

13.4 New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, WOOBEST will endeavor to comply with the law or contract.

 

14. How to contact us

14.1 For any inquiries or concerns of our services, you can  send e-mail to dyqlb.kefu@gmail.com. We will respond to you within 15 business days.

14.2 We have a privacy protection and management team to monitor and protect your personal data. If you have any questions or requests regarding the protection of personal data, please feel free to send email to: dyqlb.kefu@gmail.com.

 

 

WOOBEST INTERACTIVE (HONG KONG) COMPANY LIMITED

 

 

Third Party SDK List

1Google SDK

SDK Objectives of UseLogin, Payment

Share Data Type (SDK Required User Info)

Access the web. Account information: Details about your google account.Unique identifiers, browser type and settings, device type and settings, operating system, mobile network information, and application version number.

Registration information related to payments: your name, bank card number, bank card validity period, billing address (country, city, postal code, address), CVV. other personal information related to payments.

Privacy Policy provided by SDKhttps://policies.google.com/privacy

 

2Apple SDK

SDK Objectives of UseLogin, Payment

Share Data Type (SDK Required User Info)

Access the web. Account information: Details about your Apple account.Unique identifiers, browser type and settings, device type and settings, operating system, mobile network information (including operator name and phone number), and application version number.

Registration information related to payments: your name, bank card number, bank card validity period, billing address (country, city, postal code, address), CVV. other personal information related to payments.

Privacy Policy provided by SDKhttps://www.apple.com.cn/legal/privacy/szh/

 

3Facebook SDK

SDK Objectives of UseLogin, Payment, Sharing

Share Data Type (SDK Required User Info)

Access the web. Account information: Details about your account.Unique identifiers, browser type and settings, device type and settings, operating system, mobile network information (including operator name and phone number), and application version number.

Registration information related to payments: your name, bank card number, bank card validity period, billing address (country, city, postal code, address), CVV. other personal information related to payments.

Name, Facebook ID, profile picture, your friends List( Facebook ),photo album (apply when relevant features are required)

Privacy Policy provided by SDKhttps://www.facebook.com/about/privacy/update

 

4AIHelp SDK

SDK Objectives of UseOnline customer service system, to answer the user questions

Share Data Type (SDK Required User Info)

Microphone, camera, photo album (apply when relevant features are required)

Access the network, get the current network environment, get the device mac address, get the device IMEI number

Area code, operator, network, device model, available storage space, total storage space, operating system version, application information, server ID

Privacy Policy provided by SDKhttps://aihelp.net/privacypolicy/

  

5Instagram SDK

SDK Objectives of UseSharing

Share Data Type (SDK Required User Info)

Access the web. Device properties: Information such as operating system, hardware and software versions, signal strength, available storage space, browser type, app and file names and types, and plug-ins.

User ID, nickname, profile image, your friends List( Instagram ), photo album (apply when relevant features are required)

Privacy Policy provided by SDKhttps://privacycenter.instagram.com/policy