Privacy Policy
Last Updated: [ ˜ ]
2024
Thank you for using our products and services! We respect your
concerns about privacy and appreciate your trust and confidence in us.
Please note that this privacy policy (“Privacy Policy”)
only applies to the Closed
Beta Test (“CBT”) of Mahjong Wish (“Service”). If you use any other
products or services, please refer to the
privacy policy for that particular product or service.
If you have any questions about
anything in this Privacy Policy, or want to exercise any rights you may have,
our contact information can be found here.
For the purpose of data protection laws,
the data controller of your personal information in relation to the Service is Proxima
Beta Pte. Limited.
SUMMARY
Here is a summary of the
information contained in this Privacy Policy. You can find more detail by
clicking ‘More Information’.
|
What information do we need to be able to provide
the Service? |
· If you register an account
to use the Service, then we will need some information from you to set this
up. We will generate an Open ID, which is an internal ID for your account.
Depending on your use of the Service and the jurisdiction where you are based,
you may also need to provide some additional information to help us set up
your account. ·
If
you choose to set up your profile using Steam, we collect information provided
by Steam to automatically generate your profile, including your open ID and
user ID. |
|
|
How will we use your information? |
· We use your information to set
up your account, enable you to use the Service, localise the Service
experience, save your progress, ensure the safe and secure operation of the
Service, address bugs, optimise and improve the Service, protect users, and
to comply with our legal obligations and enforce our legal rights. |
|
|
Who do we share your information with? |
·
We
use third parties and work with our affiliates to help us deliver the best
possible experience (such as needed to back up your progress). · All third
party service providers providing services for us are prohibited from
retaining, using, or disclosing your personal information for any purpose
except where strictly necessary for the Service (i.e., to fulfil the
purpose(s) described above). · In some cases
we may be required by a court or be under a legal obligation (such as a valid
search warrant or subpoena) to disclose certain information. |
|
|
Where
do we process your information? |
· Pursuant to our contract
with you, we may transfer data outside of the location in which you are based
for the purposes described in this Privacy Policy. · We have servers for the
Service in Singapore. The servers applicable to
your use of the Service will depend upon your location. We also have support,
engineering and other teams who may support the Service, including from Singapore
and the People’s Republic of China. |
|
|
How long do we keep your information? |
·
Unless
otherwise required or permissible by applicable laws, we retain your
information for the period during which you maintain an account for the
Service, or for so long as the information is needed to fulfil the purpose
for which it was collected (as further described in this Privacy Policy). We
then delete or anonymise such data, in accordance with applicable laws. |
|
|
How can I exercise my rights over my information? |
·
Certain
jurisdictions offer users specific rights with respect to their information, so
you may have a right to access or receive a copy of your data, or to delete
your data or restrict or object to our processing of your data. |
|
|
How will we notify you of changes? |
· Changes to this Privacy
Policy will be posted here. We will also notify you of changes in accordance
with relevant legal requirements. |
This
Privacy Policy explains the when, how and why when it comes
to the processing of your personal
information in connection with the Closed Beta Test
(“CBT”) of Mahjong Wish (the “Service”), and sets out your choices and rights in relation to that
information. Please read it carefully – it will allow you to understand how we
collect and use your information, and how you can control it.
Please note that this Privacy
Policy only applies to the Service. If you use any other products or services please refer to the privacy policy for that
particular product or service.
If you do not agree to
the processing of your personal information in the way this Privacy
Policy describes, please do not provide your information
when requested and stop using the Service. By using the Service, you are acknowledging
how we process your personal information as described in this Privacy Policy.
For the purpose of
data protection laws, the data controller of your personal information in
relation to the Service is Proxima Beta Pte. Limited
(“we”, “us”, “our”).
If you have any questions about
anything in this Privacy Policy, or want to exercise any rights you may have,
our contact information can be found here. You can also reach out to our
data protection officer at dpo@levelinfinite.com.
Children must not use the Service
for any purpose, except where their parent or guardian has provided lawful consent
(to the extent this option is available in your jurisdiction).
By children, we mean users under the age of 18 years old; or
in the case of a region where the minimum age for processing personal
information differs, such different age. We have listed the relevant minimum
age as of the date of this policy in the table below. You should in any case
refer to the laws in your jurisdiction to ensure you are above the relevant
legal minimum age.
Other than as provided above, we do
not knowingly collect personal information from children under these ages for
any purpose. If you believe that we have personal information of a child under
these ages without lawful consent, or if you are the parent or guardian of the
user and wish to withdraw consent, please contact us.
|
Region in
which the user is located |
Minimum age
of the user |
|
Hong
Kong |
18 |
|
Japan |
18 |
|
Macau |
18 |
|
Taiwan |
20 |
This
section provides more detail on the types of personal information we collect
from you, and why.
|
Personal
Information |
Use |
|
Information you provide
to us (either directly or through a third party) |
|
|
Steam
login information: Open
ID, user ID from Steam |
We use this information to allow you to register
and create your account for the Service in accordance with your request, log
in to the Service and participate in game activities and receive
notifications of the Service. |
|
Nickname |
We use this information to create your account
for the Service in accordance with your request. |
|
Information
generated as part of the Service |
|
|
Identity / account information: Open ID, user ID, login channel ID |
We use this information to: ·
allow you to use the Service smoothly and to use
all features of the Service; and ·
allow for game configuration. |
|
Compliance information: nickname, gameplay information |
We use this information to identify abuse,
harassment and other inappropriate behaviours in violation of our End User
License Agreement, and to improve the tools we use to identify such
violations. |
|
Survey information: content you choose to provide as part of a
survey response. |
We use this information to better understand our
users and to improve the Service. |
We
have servers for the Service in Singapore. The servers applicable to your use of the Service will depend upon
your location. We
also have support, engineering and other teams who may support the Service,
including from Singapore and the People’s Republic of China.
Only where necessary
will we share your personal information with third parties. Situations where
this occur are:
·
Third parties that provide services in support of the Service, including
providers of services that process information identified in
this policy for the purpose of providing the Service, for the purpose of processing gameplay and
game rendering data to provide game analytics to improve gameplay.
All
third party service providers providing services for us are prohibited from
retaining, using, or disclosing your personal information for any purpose
except where strictly necessary for the Service (i.e., for the purpose(s)
described above).
· Companies
within our corporate group who
process your personal information solely for the purpose of providing the
Service to you. All such group companies may only use your personal information
in accordance with this Privacy Policy.
We have information security and access policies that limit access to
our systems and technology, and we protect data through the
use of technological protection measures such as encryption.
Unfortunately, the
transmission of information via the internet is not completely secure. Although
we will implement and maintain reasonable measures to protect your personal information,
we cannot guarantee the security of the information transmitted through the
Service or otherwise via the Internet; any transmission is at your own risk.
We do not keep your data for longer than is
necessary to fulfil the relevant purpose described above unless we are required or permitted to do so under
law. If we retain
your information beyond the retention periods set out below, for example to
comply with applicable laws, we will store it separately from other types of
personal information.
|
Personal Information |
Retention Policy |
|
Steam
login information Nickname Identity
/ account information Compliance
information Survey
information |
Stored for
30 days after the end of the CBT of the Service, unless you request for
deletion, in which case it will be deleted within 7-14 days of your request
(whichever is earlier). |
Some
jurisdictions’ laws grant specific rights to users of the Service. Please refer
to the Supplemental Jurisdiction-Specific Terms, or the applicable laws in your
jurisdiction, for an overview of specific rights that apply to persons subject
to data protection laws in the listed jurisdictions and how these can be
exercised.
You may 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). You can
exercise some of these rights directly by accessing and updating the
information in your account. If you believe we hold any other personal
information about you, please contact us.
Access
You may have the right to access
personal information we hold about you, how we use it, and who we share it
with.
Portability
You may have the right to receive a copy of certain personal
information we process about you. For example, in certain jurisdictions this
can comprise personal information we process on the basis of your consent
(e.g., survey information) or pursuant to our contract with you (e.g., account
name), as described above in the section “How We Use Your Personal Information”. We will provide further
information to you about transferring this data if you make such a request.
Correction
You may have the right to correct personal information we hold
that is inaccurate.
Erasure
You may be
able to delete your account, or remove certain personal information, by logging
into your Service
account. We may need to
retain personal information if there are valid grounds under data protection
laws for us to do so (for example, for the defence of legal claims or freedom
of expression) but we will let you know if that is the case. Where you have
requested that we erase personal information that has been made available
publicly on the Service and there are grounds for erasure, we will use
reasonable steps to try to tell others that are displaying the personal
information or providing links to the personal information to erase it too.
Objection
You may have
the right to object to our processing of your personal information. If you wish
to do so, please contact us at dpo@levelinfinite.com or using the contact
details set out below, and we will consider your
request.
Consent Withdrawal
To the extent provided by applicable laws and regulations,
you may withdraw consent you previously provided to us for certain processing
activities by contacting us at
dpo@levelinfinite.com. Where consent is
required to process your personal information, if you do not consent to the
processing or if you withdraw your consent we may not
be able to deliver the expected service. Please
note that the right to withdraw consent is only available if the legal basis
for processing information is consent.
Announcements
We may from time to time send you
announcements when we consider it necessary to do so (for example, when we
temporarily suspend access to the Service for maintenance, or security, privacy
or administrative-related communications). These are essential system and
service-related announcements and you are not able to
opt-out of these notifications, which are not promotional in nature.
Please get in touch with us
if you have any questions. You can reach
us in the first instance at:
Email: dpo@levelinfinite.com
Mailing Address:
Tencent International Privacy & Data Protection
Centre
79 Robinson Rd #07-01
Singapore 068897
We
will endeavour to deal with your request as soon as possible. This is without
prejudice to any right you may have to launch a claim with a data protection
authority in the region in which you live or work where you think we have
infringed data protection laws.
If we make any changes to
this Privacy Policy we will post the updated Privacy
Policy here and notify you in accordance with relevant legal requirements.
Except as otherwise
prescribed by law, in the event of any discrepancy or inconsistency between the
English version and local language version of this Privacy Policy, the English
version shall prevail.
SUPPLEMENTAL TERMS –
JURISDICTION-SPECIFIC
Some jurisdictions’ laws contain additional terms for users of the
Service, which are set out in this section. If you are a user located in one of
the jurisdictions below, the terms set out below under the name of your
jurisdiction apply to you in addition to the terms set out in our Privacy
Policy above.
Hong Kong
As a Hong Kong data subject
you have legal rights in relation to the personal information we hold about you
(to the extent permitted under applicable laws and regulations). You are
entitled to make a subject access request to receive a copy of the data we
process about you, a data correction request as well as a right to reject to
the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a
data access request.
If you are under the age of 18, you must obtain your
parent’s or legal guardian’s consent to register an account on and use the
Service.
By clicking “confirm” or “accept”, you
consent to the transfer of your personal information to third parties (if any),
which may include the cross-border transfer of your information to any country
where we have databases or affiliates and, in particular, to the
jurisdictions specified in Section
4 (How We Store and Share Your Personal Information).
The categories of personal information
specified in to the jurisdictions specified in Section 4 (How We Store and
Share Your Personal Information) may
include "special care-required personal information" (i.e., sensitive
information as detailed under applicable law), and you consent to the collection
of such information.
You may
request us to notify you about the purposes of use of, to disclose, to make any
correction to, to discontinue the use or provision of, and/or to delete any and
all of your personal information which is stored by
us, to the extent provided by the Act on the Protection of Personal Information
of Japan. When you wish to make such requests, please contact us as
set out in Section
8 (Contact).
You have
the right not to provide your personal information. However, as a result, we
may not be able to provide the Service to you. As a Macau data subject you have legal rights in relation to your personal
information (to the extent permitted under applicable laws and regulations).
You are entitled to make a subject access request to request a copy of the data
we process about you, to make a data correction request, and have the right to
oppose the use of your personal information for marketing or any other form of
commercial prospecting, or on any grounds of personal nature. A fee may be
chargeable by us for complying with a data access request.
Taiwan
We do not knowingly collect or solicit
personal information from
anyone under the age of 7 or knowingly allow such persons to register on the Service platform. If you are under 7 years of age, please do not attempt to use or
register for our Service or send any personal information about yourself to us.
No one under the age of 7 may provide any personal information to us while using the Service. In
the case of users located in Taiwan, persons under the age of 20 are required
to obtain parental/guardian consent prior to using the Service.