Privacy Policy

Last updated: April 21, 2022

Welcome to the game application operated by FingerFun (HK) Limited ("Game App”)!

FingerFun (HK) Limited and its affiliated companies operating globally (hereinafter referred to as “we” or “us”) respect your right to privacy and value the protection of your Personal Data. This FingerFun Privacy Policy (hereinafter referred to as “Privacy Policy”) explains how we collect, use and protect your Personal Data when you use our Game App and other associated functions and how you can exercise your data subject rights.

This Privacy Policy applies to your use of our Game Apps .

“Personal Data” under this Privacy Policy refers to all kinds of information, recorded electronically or otherwise, that is related to an identified or identifiable natural person, including but not limited to the natural person’s name, identity number, address, account information, property, location, etc. “Personal Data” under this Privacy Policy does not include information that has been anonymized.

If you have any questions about this Privacy Policy, please contact us using the contact details provided in “How to contact us” of this Privacy Policy.

This Privacy Policy informs you of the following information:

1.1 How do we collect and use your Personal Data

1.2 How do we use cookies and similar technologies

1.3 How do we process children’s Personal Data

1.4 How do we share your Personal Data and entrust the processing of your Personal Data

1.5 How do we protect your Personal Data

1.6 How do we store your Personal Data

1.7 Lawful basis for processing Personal Data (applicable to players located in the EU/EEA)

1.8 Your data subject rights

1.9 How do we update this Privacy Policy

1.10 How to contact us

1. How do we collect and use your Personal Data

The Personal Data we collect depends on how you use our Game App and what services you use. The details of our collection of your Personal Data for different purposes are summarized in the below.

Registration and login. When you register with our Game App and log in through a third party platform (e.g., Facebook, Google, Twitter, VK, Apple, GameCenter), we will collect your player ID, OpenID, username, profile photo and other data from the third party platform through its Application Program Interface (API). Alternatively, if you choose to register with our Game App via your personal email or mobile phone number, we will collect this data to help you complete your registration and login to the game.

Top-up and payment. We will collect your top-up amount, payment time, payment method and order number through the APIs provided by the relevant third parties (e.g., Google Play Store and Apple App Store) to help you complete the top-up process for your player ID.

Maintaining game operation and account security. In order to maintain the normal game operation and account security and to check your game equipment and gaming records in your account, we will collect your operation data related to the game playing, including your login status, game battle status, achievement data, game character data, device data (including MAC/IMEI/Android ID/IDFA/IP address), etc. In addition, to provide you with a better gaming experience, we will also collect game-related data generated during your play of our games, including data about the players' virtual property such as virtual currency, virtual transactions, redemption codes, as well as your voice data when you send voice messages through our Game App.

Customer services. We provide customer service to you based on the support of third-party built-in service systems such as AIHELP and we may collect your player ID, character data, and other information necessary to provide customer service.

Customer survey. To know your opinions about Game App and to improve our products and services, we will use third-party built-in questionnaire systems such as SurveyMonkey to collect your player ID and responses to our survey questions.

Personalized services and marketing. We may recommend personalized game services and gift package through notifications on your mobile device based on your player level, preference, personal behaviors and other characteristics. You can opt-out the notifications through the setting function on your device. We may also send messages related to our services and marketing communications to your email address, mobile phone number, or via third party accounts. Where required by the applicable laws and regulations, we will obtain your consent before sending marketing communications to you. If you have any questions about our marketing communications, you can contact us using the contact details provided in "How to contact us" of this Privacy Policy.

If you provide us with the Personal Data of any data subjects other than yourself, please disclose this Privacy Policy to such data subjects. You hereby acknowledge that you have obtained their consent or completed other formalities as required by other lawful basis for the Personal Data processing in lieu of consent before providing such Personal Data to us. By providing such Personal Data to us, you represent to us that you are entitled to provide and we are entitled to process such Personal Data for the purposes as stated in the Privacy Policy.

In general, we will process your Personal Data only for the purposes stated in this Privacy Policy or for the purposes that we explain to you at the time when we collect the relevant Personal Data from you. However, we may also process your Personal Data for other purposes that are not incompatible with the purposes we have disclosed to you if and where permitted by the applicable laws and regulations.

2. How do we use cookies and similar technologies

When you use our Game App, we may use cookies to automatically collect certain technical information from your device. Such information allows us to better understand the players of our Game App, such as where you come from and what functions of our Game App attract you. We use this information for internal analysis and troubleshooting, and to improve the player’s experience. We also need to keep appropriate logs to record the status of our Game App in order to comply with the applicable laws and regulations.

Certain technical modules of the functions of Game App and the safe and stable operation of Game App are supported by third-party Software Development Kits (SDKs). The processing of your Personal Data by these SDK providers will be governed by the privacy policies of the relevant SDK providers.

3. How do we process children’s Personal Data

Please note that we may collect and process Personal Data of children under the age of 13. Children can play our games with parental or guardian consent. We also give parents or guardians controls and choices over the processing of their children’s information in Game App where we think necessary.

For the Personal Data of children we collect upon the consent of parents or guardians, we will only use or disclose such data to the extent where permitted by laws, explicitly authorized by parents or guardians, or necessary for the protection of children.

If you are the parent or guardian of a child under the age of 13 and have questions on how we process children’s Personal Data, please contact us using the contact details provided in “How to contact us” of this Privacy Policy. We also encourage you to talk with your children about communicating with strangers and the risks of disclosing Personal Data online. You and your children may need to review together the privacy settings applicable to their use of our Game App.

4. How do we share your Personal Data and entrust the processing of your Personal Data

In order to provide gaming services, we may engage third parties (such as those who support the functions of online payment, login by third-party accounts, customer service and survey, personalized ads, cloud service, etc.) to process your Personal Data. We will enter into confidentiality terms with such third parties and require them to adopt sufficient security measures as required by the applicable laws and regulations when processing your Personal Data. We do not sell your personal data and only share non-personally identifiable, aggregated, and public data with third parties.

We may share your Personal Data with third parties in the following circumstances:

In the event of any change, financing, merger, acquisition, reorganization, or liquidation involving the transfer of Personal Data, we will ask the new company or organization holding your Personal Data to continue to process your Personal Data in accordance with this Privacy Policy. If the new company or organization holding your Personal Data needs to use your Personal Data for purposes not stated in this Privacy Policy, the new company or organization will obtain your consent, unless otherwise provided by the applicable laws and regulations.

• To the relevant competent law enforcement body, regulatory, government agency, court or other third party where we believe that such disclosure is to (i) comply with an applicable law or regulation; (ii) exercise, establish or defend our legal rights, or (iii) protect your vital interests or those of any other person.

Please be aware that we cannot control the activities of such third parties, and we cannot guarantee that they adhere to the same privacy policy as we do. We encourage you to check their privacy policies on their official websites and learn more about their data processing practices.

5. How do we protect your Personal Data

We use appropriate technical and organizational measures to protect your Personal Data that we collect and process. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Data. Please be aware and understand that we cannot ensure an absolutely secure network. If you find that your Personal Data are breached, please contact us immediately using the contact details provided in “How to contact us” of this Privacy Policy so that we can take the corresponding measures.

In the event of any accident, force majeure event or other circumstances leading to the breach of your Personal Data, we will make every effort to control the situation and promptly inform you of the cause, the security measures we have taken and you can take, and other relevant information when required by the applicable laws and regulations. In the event of a security incident related to your Personal Data, we will report such incident to the competent authorities in accordance with the requirements of the applicable laws and regulations, promptly investigate the problem, and take the corresponding remedial measures.

6. How do we store your Personal Data

Storage location:

We may store the Personal Data that we collect from you within the jurisdiction where you locate in accordance with the applicable laws and regulations.

However, for the need of our global operation, your Personal Data may be transferred to, and stored at, a jurisdiction different from the one where you locate. Such jurisdiction may not provide the same level of data protection as your jurisdiction. Under such circumstances, we will take necessary and appropriate safeguards to ensure the security of your Personal Data concerned and require the recipient of your Personal Data to offer an adequate level of protection and security in accordance with this Privacy Policy and the applicable laws and regulations, for instance by entering into the appropriate data processing agreements and, if necessary, cross-border data transfer agreement (with or without prescribed template) with the recipient or adopting an alternative mechanism for the transfer of your Personal Data as approved by the applicable regulators.

Retention Period:

We will store your Personal Data to the extent as necessary to the proper business needs of our company (e.g., for the purposes of providing gaming services to you or complying with the requirements of laws, tax and finance), except as provided otherwise by the applicable laws or regulations. When there is no such business need to use your Personal Data or the time limit for the retention expires according to the applicable laws or regulations, we will delete or anonymize your Personal Data, or if this is not possible (for example, because your Personal Data has been stored in backup archives), then we will securely store your Personal Data and isolate it from any further processing until deletion or anonymization is possible.

7. Lawful basis for processing Personal Data (applicable to players located in the EU/EEA)

Our lawful basis for collecting and using the Personal Data provided in this Privacy Policy will depend on the Personal Data concerned and the specific context in which we collect it. The specific lawful basis on which we rely for each of the purposes which we process your Personal Data for is summarized in the below:

Purposes

Lawful basis (as applicable)

Collect your Personal Data to complete the registration and login process.

Collect your Personal Data to maintain the normal operation of Game App and account security.

Collect your Personal Data to provide customer service and survey and to answer your inquiries.

Collect your Personal Data to provide personalized services and marketing communications.

“The necessity of entering into and/or performing a contract” or “the legitimate interests” to provide the products and/or services as the lawful basis for processing Personal Data.

Collect your Personal Data to complete top-up and payment process.

“Performing a contract” as the lawful basis for processing Personal Data.

Collect Personal Data of children to provide access to the use of Game App.

“Parental or guardian consent” as the lawful basis for processing Personal Data of children.

Collect your Personal Data to comply with regulatory, compliance, or legal obligations and/or requirements, or to assist law enforcement and government authorities as permitted or required by applicable laws and regulations.

“The necessity for the performance of legal obligations” as the lawful basis for processing Personal Data.

8. Your data subject rights

If you want to access, correct, update and delete your Personal Data, and exercise other data subject rights provided by the applicable laws and regulations (e.g., to withdraw the consent we obtained from you to collect and process your Personal Data, or to request us to transfer your Personal Data to a designated third party, to restrict our processing of your Personal Data, to object to any processing of your Personal Data carried out on the basis of legitimate interests, etc.), you may use the functions (if applicable) on the player's personal page and the “Setting” page on Game App. You may also contact us using the contact details provided in “How to contact us” of this Privacy Policy. In order to help you exercise your rights, we may need to verify your identity based the Personal Data you have already provided to us before responding to your rights request.

We will respond to your requests of exercising your data subject rights in accordance with the requirements of the applicable laws and regulations within the required time limit. To the extent as permitted by the applicable laws and regulations, we may not respond to your requests of exercising your data subject rights under certain circumstances. For instance, if your request is contrary to our performance of legal obligations under the applicable laws and regulations, or may infringe our trade secrets, we may refuse to respond to your request. Besides, if we have sufficient evidence of your subjective malice or abuse of your data subject rights, or response to your request would infringe other individuals' significant legitimate rights and interests, we may also decline your request. Under such circumstances, we will simultaneously provide you with our reason of refusal in the response.

If we terminate our services or operations, we will notify you at least thirty (30) days in advance and will delete or anonymize your Personal Data after termination of services or operations.

9. How do we update this Privacy Policy

We may update this Privacy Policy from time to time in response to the changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, depending on the significance of the changes we make. We will obtain your consent to any material changes to Privacy Policy if and where required by the applicable laws and regulations.

You can see when this Privacy Policy was last updated by checking the "last updated" date displayed at the top of this Privacy Policy. If you continue to use our Game App or contact us through the contact details shown on our Game App, you are deemed to have accepted the updated version of our Privacy Policy.

10. How to contact us

If you have any questions or concerns about this Privacy Policy or our processing of your Personal Data, especially if you consider that our processing of your Personal Data impairs your legitimate interests, please contact us via the information below. We will review your inquiries without delay and make timely reply according to the applicable laws and regulations.

Company:

FingerFun (HK) Limited

Email:

fingerfun.gm@gmail.com

Online Customer Service:

fingerfun.gm@gmail.com

Contact Address:

Suite 603, 6/F, Laws Commercial Plaza, 788 Cheung Sha Wan Road, Kowloon, Hong Kong