PRIVACY POLICY

 

Effective Date:    , 2025

 

1. Introduction

 

1.1 This PRIVACY POLICY create a legal agreement between you ("you" or "your") and Guangzhou Lulin Technology Co., Ltd. ("us”, “we" or "our"). We respect the privacy of everyone who uses our games, website(s) and all related services which we may provide to you from time to time ("Services").

 

1.2 This document, the "Privacy Policy", explains how we collect, process and store any personal data belonging to you, meaning information about you which is personally identifiable such as your name, address, telephone number or email address. Such information is referred to throughout this policy as "Personal Information" or "data".

 

1.3 By accessing and/or using our Services you consent to us collecting, processing, storing and sharing your Personal Information in the ways set out in this Privacy Policy. If you have any concerns about providing data to us or having it used in any manner permitted in this Privacy Policy, you should not use our Services.

 

1.4 As set out in the terms and conditions relating to our Services, you should faithfully register your age. We hope that you are at least 18 years old and that if you are between 13 years and 18 years old, (i)your legal guardian must have reviewed and agrees this Privacy Policy and is happy for you to access and use our Services, in addition to satisfying the condition of (i), (ii)You will also be subject to some of our limitations in the game, including but not limited to online time, recharge, etc. If you are under 13 years old, although we will not collect any privacy information from you, but you should also promise you will not provide us with your personal privacy information in any ways. The minimum age for you to use our Service without supervision according to the applicable laws and regulations of the relevant region.

 

The Privacy Policy will help you to understand the following:

How we collect your Personal Information

How we use your Personal Information

How we share, transfer, and publicly disclose your Personal Information

How we store, transmit, and protect your Personal Information

Your rights as data subject

Update of the Policy

Contact information

 

2. How we collect your Personal Information

 

2.1 To use the Services, you may directly provide certain personally identifiable information to us, such as:

2.1.1. Contact information (e.g. your name, personal identification number, postal or e-mail address, telephone numbers)

2.1.2. Registered username and password

2.1.3. Character Information (e.g. Account ID, character name, profile picture. Please be reminded that such information may be disclosed to other users in connection with the use of the Services and may also be made available to your connections or the public on third party services)

2.1.4. Profile information (e.g. profile photo)

2.1.5. Messages to the Services (e.g. chat logs)

2.1.6. Billing and financial information (Please be reminded that the use of any merchant service provider and/or third-party platforms for the payment of the Admission Fee is subject to the privacy policy of the relevant merchant service providers and/or third-party platforms)

2.1.7. Other data that you voluntarily provide (e.g. data to identify a lost account) 

 

2.2. Cookies

2.2.1 We use cookies and other similar technologies. Cookies are small files which store some information on your computer or mobile device.

2.2.2 We use cookies and similar technologies:

(1) to allow us to recognize you and your device, for example by identifying your IP address.

(2) to allow our Services to interact with a third-party social network or platform (where you have chosen to allow such interaction).

(3) to allow our payment processors to process your payment instructions.

(4) to provide you with more customized Services, for example to provide our Services in the correct language.

(5) to obtain data which will allow us to understand how people are using our Services so that we can improve them.

2.2.3 By accessing our website(s) or using our Services you consent to our use of cookies in accordance with this Privacy Policy. You can disable cookies through your web or phone browser settings, but you may find you are not able to enjoy all the features of our Services if you do so.

 

 

3. How we use your Personal Information

 

You agree that we (or a supplier or group company acting on our behalf and only under our instructions) may use your Personal Information for the purposes of:

3.1. contacting you, for example as part of customer service or to send you updates about our Services.

3.2. managing your account and relationship with us and improving your experience when you use our Services.

3.3. research, surveying, and engaging with you, for example by sending you communications (including by email) for these purposes.

3.4. marketing and promotion of our Services or related products, for example sending you communications (including by email) for these purposes on our, or a third party's behalf. For example, we might send you information about merchandise relating to our Services If you do not want us to use your data in this way, please let us know by contacting us.

3.5. to create reports, analysis or similar services for use by us for the purposes of research or business intelligence, for example to track potential problems or trends with our Services.

3.6. preventing cheating, crime or fraud. We may also need to pass your information to fraud prevention agencies and other organizations involved in crime and fraud prevention.

3.7. as otherwise expressly set out in this Privacy Policy or as required by law.

 

 

4. How we share, transfer, and publicly disclose your Personal Information

 

4.1 We will only share your data with third parties (for example, our group companies or suppliers):

4.1.1. with your consent (including as set out in this Privacy Policy).

4.1.2. as reasonably necessary to provide the Services to you (for example, by providing your Personal Information to suppliers we may use to fulfill the Services or to communicate with you).

4.1.3. where it is necessary to carry out your instructions (for example, to process a payment instruction we must provide your Personal Information to our payment processors).

4.1.4. where your data is on an anonymous and aggregated basis, meaning you could not be personally identified from it.

4.1.5. when you submit information as part of a competition or otherwise interact with our social media channels (for example, by providing a testimonial about one of our Services) we may publish the information you submitted, alongside your name and home country on our website and social media channels.

4.1.6. as we reasonably believe is permitted by law or regulation.

4.1.7. to comply with any legal obligation, or to enforce or apply our terms and conditions and/or any other agreement with you; or to protect the rights, property, or safety of us, our users, or others.

4.1.8. if there is a sale of the assets of us or corporate restructuring, or because of a change of control of us or one of its group companies, or in preparation of any of these events. Any third party to which we transfer or sell our assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in this Privacy Policy.

 

4.2 Interaction with third party social networks or platforms:

4.2.1 You may allow our Services to interact with a third-party social network or platform, which will provide data about you to us. These applications or websites are created and maintained by a third party which is not a part of or controlled by us. You should ensure that you read their terms of service and privacy policies to understand how they treat your data and what data they might share with us.

4.2.2 You understand that where you allow our Services to interact with any third-party social network or platform, we may share data about you with your contacts (and vice versa) in order that you may enjoy playing socially (the “Social Data”). This Social Data includes your name, your social media profile picture and your scores and/or progress in our games.

4.2.3 You can make changes to what data a third-party social network or platform shares with us or stop our Services interacting with that social network or platform by adjusting your settings with that third party provider, however you may find you are not able to enjoy all the same features of our Services.

4.2.4 Users of our Services may be automatically assigned a profile which is visible to other users of our Services. Your profile may include the Social Data described above; game achievements or other game play information and details of which other account holders have viewed your profile.

4.2.5 Your profile will be visible to other users of our services. If you choose to view another individual’s profile, that individual and other users of our Services will know that you have visited them because some of your Social Data and a link to your profile will be displayed on that individual’s profile. They will also be able to visit your profile.

 

4.3   We may provide links to third party websites from our Services. You understand that when you click on these links any data which you provide thereafter is subject to such third party's privacy policy and not to ours. Although we will endeavor only to link to reputable websites, we take no responsibility for the content, safety or security of any third-party website.

 

4.4 We will not sell or rent your information to any third party outside of these circumstances.

 

 

5. How we store, transmit, and protect your Personal Information

 

5.1 We will retain your Personal Information for as long as is necessary to fulfill the purposes for which it was collected or as needed to provide you with Services. We may retain your Personal Information after you have closed any account you have with us or after we have ceased providing Services to you if retention of your Personal Information is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes between members, prevent fraud, cheating or abuse, or enforce this Privacy Policy or any other agreement we may have with a user.

 

5.2 The Personal Information collected by us is stored and encrypted on our servers in Singapore. You understand and agree that your personal information can be transmitted to a destination other than Singapore and stored in that destination. It may also be processed by staff operating outside the Singapore who work for us or for one of our suppliers. We will take all steps reasonably necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy.

 

5.3 The security of your Personal Information is important to us. We maintain appropriate technical and physical safeguards to protect your Personal Information against accidental or unlawful destruction or loss, alteration, unauthorized disclosure or access, use and all other unlawful forms of processing of the data in our possession. We use the same level of skill in protecting your Personal Information as other similar games developers. However, since the internet is not a completely secure environment, we cannot guarantee that information you transmit via our Games will not be accessed, disclosed, altered or destroyed by breach of any of our safeguards.

 

 

6. Your rights as data subject

 

6.1 Right of Access: 

In principle, you can access the following information

6.1.1. Account information: You can log in to your personal account at any time, access or edit personal information in your account, change your password, add security information, carry out account association or identity authentication, etc.

6.1.2. Use information: You can consult or clear your playback record, search record, upload content, order information and so on in your website, client and other services.

6.1.3. Other information: If you encounter operational problems during this visit or need access to other previously unknown personal information content, you can contact us provided at the end of this User Privacy Protection Statement. We will provide it after verifying your identity, unless otherwise stipulated by laws and regulations.

 

6.2 Right of Correction

After verifying your identity and correcting without affecting the objectivity and accuracy of the information, you have the right to correct or update the errors or incomplete information. You can correct the errors or incomplete information on your own website or client or submit your application for correction through feedback and error reporting published by us under specific circumstances, especially in the case of data errors. We require us to correct or update your data, except as otherwise stipulated by laws and regulations. However, for security and identity reasons, you may not be able to modify some of the initial registration information submitted at the time of registration.

 

6.3 Right of Delete

You can request us to delete your personal information, for example, you no longer need us to continue to provide services for you, except for data anonymity processing or other provisions of laws and regulations.

 

6.4 Right of Demand

If you need a copy of your personal data, you can contact us provided at the end of this Privacy Policy. After verifying your identity, we will provide you with a copy of your personal information in our services (such as basic information, identity information), except as otherwise provided by laws and regulations.

 

6.5 Right to Withdraw Consent

If you want to change the authorization scope of related functions (such as location, address book, camera), you can modify personal settings through your hardware device or operate on the related function settings interface in our products or services. If you encounter operational problems in this process, you can contact us provided at the end of this Privacy Policy.

When you cancel the authorization of personal information collection, we will no longer collect this information and can no longer provide you with the corresponding services mentioned above; but you know and agree that unless you exercise the aforementioned "Right of Delete", your actions will not affect the processing and storage of personal information based on your previous authorization.

 

6.6 Knowing in advance the right to stop operation of products and services

We are willing to accompany you all the time. If some or all our products and services are forced to stop operation due to special reasons, we will notify you 90 days in advance by mail or email or other suitable ways to reach you on the main page of the products or services and will stop collecting your personal information. At the same time, we will stop collecting your personal information according to the law. Personal information is deleted or anonymously processed, except as otherwise provided by laws and regulations.

 

 

7. Update of the Policy

 

7.1 To ensure that you will have better services and to adapt to the platform business adjustment and future development, this Policy will be updated with the times. However, when updating, we shall obtain your authorization in a separate and obvious way, otherwise we shall maintain the rights granted to you by this Policy.

 

7.2 For material changes, we shall notify you in more significant ways (including but not limited to emails, text messages, announcements, special reminders on homepages or on the browsing page) of the changes to this Privacy Policy, especially those changes such as relating to your rights, the way we collect, process, and transmit information. We shall obtain your authorization and consent again in the form of a pop-up window when you use the services again.

 

 

8. Contact information

 

8.1 We hope that you won't have any complaints about us or our Services. If you are unhappy with our use of your Personal Information, or you have any questions regarding this Privacy Policy, you may contact us using the information below:

gm1000years@gmail.com