Wish Interactive Technology Ltd. (“Wish Interactive”, “we” or “us”) see it as our responsibility to set examples and help establish the standards for privacy on the Internet.
·The ways we collect personal data about you and why we do so
·How we use, share and protect your personal data, and
·The choices you have about your personal data.
Wish Interactive intends through the use of such information in good faith to deliver better services to our online users (“users” or “user”). It is important for you to understand how this happens and how you may control it.
THE INFORMATION WE COLLECT AND HOW WE COLLECT IT
In providing our services, we collect, store and use the following Information relating to you:
·Information you give us. You give us information about:
1.when you register for the Game (including your nominated nickname, and information we import from your connected social media account (Facebook, Google, Twitter and WeChat) in order to set up your profile, including your name as it appears on your social media profile and your profile picture);
2.when you set up your profile for the Game (including information you voluntarily elect to provide in order to customize gameplay, such as gender);
3.when you submit your contact details to us (including your name, email address and physical address) as part of promotional activities for the Game; and
4.when you make purchases in the Game (in which case we will process the information you provide to us to facilitate the payment).
Information we automatically collect about you when you use the Game and/or the Community Website.
1.Data about your account and game progress;
2.Your IP address and mobile device identifiers (such as your device ID, advertising ID, MAC address, IMEI);
3.Data about your device, such as device name and operating system, browser type and language;
4.Data we collect with cookies and similar technologies (see more below);
5.Physical location data;
6.Precise geo-location data (GPS, with your consent);
7.Data about your use of the Service, such as gameplay data, your interactions with other players inside the Service, date and time stamps of actions;
8.We also collect and store your data each time you interact with us, for example, when you use in-app support to communicate with us.
In most cases, we also create a Wish Interactive-specific ID for you when you use the Service.
Data we collect from our partners.
1.Data we receive if you link a third party tool with the Service (such as Facebook, WeChat, Google or Twitter)
2.Demographic data (such as to determine the coarse location of your IP address)
3.Data to fight fraud (such as refund abuse in games or click fraud in advertising)
4.Data from platforms that the games run on (such as to verify payment)
5.Data for advertising and analytics purposes, so we can provide you a better Service
COOKIES AND SIMILAR TECHNOLOGIES
You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies, or instruct the device (in the case of the Game) or web browser (in the case of the Community Website) to provide notice at the time of installation of cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event of your refusal to install cookies, some parts of the Service may then not function properly.
WHY AND HOW WE USE YOUR INFORMATION
We will use the information in the following ways and in accordance with the following legal bases:
We may use your Information for any of the following purposes:
1.to provide our services to you;
2.for customer service, security, fraud-detection, archival and backup purposes in connection with the provision of our services;
3.to provide you with advertising (as discussed in more detail under the “Advertising” section below);
4.to better understand how you access and use our services, for the purposes of trying to improve our services and to respond to customer desires and preferences, including language and location customisation, personalised help and instructions, or other responses to your and other customers’ usage of our services;
5.to help us develop our new services and improve our existing services;
6.to assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with our services;
7.for the purposes of software verification or administering software upgrades; and
8.to allow you to participate in surveys and other activities about our products and services.
Please note that for the purposes of seeking to provide our users with a better experience, to improve our services or otherwise where you have consented, Personal Information collected through one of our services may, subject to user privacy controls (where available), be used by our other services (including in an aggregated or individualised manner).
For example, Personal Information collected during your use of one of our services may be used to suggest particular content that can be made available to you on another service or be used to try to present more relevant advertising to you in another service. You may also from time to time ask us to migrate or export your Personal Information contained in one of our services to another of our services, where such migration option is available.
·Our service-specific privacy guidance may more particularly describe how we use Personal Information within the relevant services.
2.Device Information (Device ID, Device Type, Operating System, CPU, RAM, IP address, MAC address): We use this information to provide and improve the Game Services such as: to allow users to download and install the Game on their devices; to record and keep track of requests from users of the Game; to detect the user network and device status when the user is playing the Game; and to correct bugs or errors that occur when the user is playing the Game. Use of Device Information is necessary to perform our contract with you to provide the Game.
7.Game Data (Level, Heroes, Score, chat log and etc): We use this information to provide Services to users as it is the basis of our Game. Use of Game Data is necessary to perform our contract with you to provide the Game.
How We Store and Share Your Personal Information
In order to perform our contract with you, your personal information will be accessible from and will be processed on our servers (depending upon your location and the game server you select). Our servers are located in:
·the United States; and
·Hong Kong, China
Apart from Wish Interactive, your data can be accessed by selected third parties in and outside your country, in the following situations:
Other players and users.
Social features are a core component of our games. Other players and users may, for example, see your profile data, in-game activities and read the messages you have posted.
Partners working with Wish Interactive.
Wish Interactive has partners to perform services for us. These partners process your data only at and according to our instructions to provide the Service, such as hosting, player support, advertising, analytics and fraud prevention.
1.Other companies and public authorities.
In order to combat fraud and illegal activity, we may exchange data with other companies and organizations and provide it to public authorities in response to lawful requests.
We may also disclose your data based on your consent, to comply with the law or to protect the rights, property or safety of us, our players or others.
2.Advertising and Social Media partners.
The Service includes features from our partners, such as social media interaction tools and in-game advertising. A list of these partners is available at supercell.com/en/partner-opt-out. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.
International data transfers
Our Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy. Adequate safeguards that our partners may use include standard contractual clauses approved by EU Commission and the Privacy Shield certification in case of transfers to the USA.
HOW DO WE PROTECT YOUR DATA
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the information transmitted to our services; any transmission of your information is at your own risk.
In order to help ensure a secure and safe player experience, we are continuously developing and implementing administrative, technical and physical security measures to protect your data from unauthorized access or against loss, misuse or alteration.
We retain your data for as long as your account is active or as needed to provide you the Service. We will for example periodically de-identify unused game accounts and we regularly review and de-identify unnecessary data.
Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
YOUR RIGHTS AND OPTIONS
You have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at firstname.lastname@example.org.
Opt-out of marketing emails and other direct marketing.
You may opt-out of receiving promotional communications, such as marketing emails from us by following the instructions in such communications.
Opt-out of targeted advertising.
You can opt-out of interest-based advertising on mobile applications by checking the privacy settings of your Android or iOS device and selecting "limit ad tracking" (Apple iOS) or "opt-out of interest based ads" (Android).
For personalized in-game offers opt-out, you can use the options provided in the game settings.
·Access the personal data we hold about you.
If you request, we will provide you a copy of your personal data in an electronic format.
Your other rights.
You also have the right to correct your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. You can always withdraw your consent, for example by turning off GPS location sharing in your mobile device settings.
We will respond to all requests within a reasonable timeframe. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us via e-mail at email@example.com.
We do not knowingly collect or solicit personal data about or direct or target interest based advertising to anyone under the age of 13 or knowingly allow such persons to use our Services. If you are under 13, please do not send any data about yourself to us, including your name, address, telephone number, or email address. No one under the age of 13 may provide any personal data. If we learn that we have collected personal data about a child under age 13, we will delete that data as quickly as possible. If you believe that we might have any data from or about a child under the age of 13, please contact us.
Last Updated June 25th, 2018