Privacy Policy

Last Updated:     Apr 1, 2023

 

Thank you for using our game （“GAME”）and services.

Here is a summary of the information contained in this privacy policy (“Privacy Policy”).

 

What information do we need to provide the GAME and services?

When you register an account to use the GAME then we will need some information from you. If you choose to set up your profile using a social media account, we collect information, including user ID and name from the social media account. We may collect information for analytics purposes, to send you push notifications, and to ensure the security of the GAME. If you need to get in touch with us, we will retain some information so that we can get back in touch with you and answer your concerns. We may collect information for analytics purposes, to send you push notifications and to ensure the security of the GAME. 

 

How we use your information?

If you participate in the GAME, we will use your information to provide the many functions that comprise the GAME. We also use your information for account verification, security purposes and to support and improve the GAME. We do not share your information with any third parties, except where we need to in order to provide the GAME (e.g., use local cloud providers or to back up your data; use our affiliates around the world to help us to deliver the GAME) or monitor the success of our marketing and advertising programs, or where we are instructed to by a court, authority or compelled by law. .

 

How long do we keep hold of your information?

We generally retain your information for the period during which you maintain an account for the GAME, after which time your data is deleted (as further described in this Privacy Policy), unless otherwise required by applicable laws. 

 

Who do we share your information with?

We use some third parties to help us deliver the best possible experience (e.g., cloud services to back up your data and support services). When we use a third party, we only do this to process or store your information for the purposes described in this Privacy Policy. We also have affiliates around the world who help us deliver the GAME and we may be required by a court or legal obligation to disclose certain information in some circumstances. .

Where do we process your information?

Our servers are located in your country. Your information can be accessed from outside of where you live by our support, engineering, and other teams. .

.

How can you exercise your rights over your information?

Depending on where you are, you may have certain rights with respect to your information, such as rights of access, to receive a copy of your data, or to delete your data or restrict or object to our processing of your data. .

How to get in touch with us

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, please contact us.

How will we notify you of changes?

Changes to this Privacy Policy will be posted here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy. .

Contact Information

Data Controller Representative: Pandora. Email:  Project-Pandora@topjoy.com. 

 

 

This Privacy Policy explains when, how and why it comes to the processing of your personal information in connection with the Game and its website (the “GAME”), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

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 GAME. By using the GAME, you are acknowledging our rules regarding your personal information as described in this Privacy Policy.

 

Our data protection officer can be contacted at Project-Pandora@topjoy.com.

 

Please reach out to us if you have any questions or concerns regarding the processing of your personal information. You can contact us anytime at Project-Pandora@topjoy.com.

 

1.                 The Types of Personal Information We Use

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section “How We Use Your Personal Information” below.

The following is a high-level summary of the types of personal information we use:

Information you provide to us (either directly or through a third party) 

• Account registration information: You give us information about you when you set up an account to register for the GAME. If you create and log in via your social media account, your social media profile picture will be set as your GAME profile picture by default. You can elect to change your default profile picture to other options in the GAME.
• Compliance information: To verify your edibility to participate in the GAME.
• Customer support and feedback information: Relevant information that you provide to us when you communicate with our customer service, when you give us reviews or feedback or otherwise provide information to us through the GAME.
• Survey information: If you choose to participate in a survey about the GAME, you may be asked to provide certain personal information, such as your age, gender, email, address, geographic (country) location, device information (phone model and configuration preference), game information (game habits and preferences) and any other content you choose to provide as part of the survey response.

 

We automatically collect certain data from you when you use the GAME:

 

• your IP address, Open ID and device information, including device ID, platform and Advertising ID) and information regarding your use of the GAME, such as play statistics (e.g. level, scores, and geographic ranking based on your selected region location);

• each time you interact with us, for example, if you contact our support team;
• when you communicate with other users in the GAME (e.g., voice and text chat content and log data);
• if you click on a link that advertises the GAME, we store the advertising ID for that advertisement and analytics data (e.g., device data, engagement data and search terms) with your profile;
• Data for advertising and analytics purposes;
• if you conduct any transactions within the GAME, we collect information to facilitate your transaction and to maintain transaction records (Open ID, cost, product purchased, IP address, device details);
• when you are using the GAME, our security feature collects (in addition to the categories of data listed above) device information including a list of installed hack software, equipment brand and model, available space on the device, and information about your internet connection including the type; and
• for bug fixing and analysis purposes.

 

2.                 Cookies

We use cookies and other similar technologies (e.g., web beacons, log files, scripts and ETags) (“Cookies”) to enhance your experience using the Game website. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities.

 

3.                 Children

Children must not use the GAME for any purpose, except where their parent or guardian has provided consent (to the extent this option is available in your jurisdiction).

By children, we mean users under the age of 13 years old; or in the case of a region where the minimum age for processing personal information differs, such different age.
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 parental/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at Project-Pandora@topjoy.com. and we will delete such information.

 

4.            GDPR

Under the GDPR and the related regulations, you can delete your account, or remove certain personal information, by contacting us at Project-Pandora@topjoy.com.

 

5.                 How We Use Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why.

 

Personal Information	Using	Legal Basis (only relevant if you are in a Relevant Jurisdiction)
Account Creation (if you choose to log in via your social media account): Facebook: Name, Facebook ID, profile picture, user token, OpenID Google Play: User ID, nicknames, profile picture, user token, OpenID Twitter: User ID, nickname, profile picture, user token, OpenID If you create and log in via your social media account, your social media profile picture will be set as your GAME profile picture by default. You can elect to change your default profile picture to other options in the GAME.	We use this information to create your account for the GAME in accordance with your request. We will use your social media account profile picture as your default profile picture in the GAME.	Necessary to perform our contract with you to provide the GAME.
Compliance Data: OpenID, token, region, user name	We use this information to verify your eligibility to participate in the GAME.	Legitimate interest to ensure compliance with applicable age-gating rules.
Account Creation (guest log-in): nickname, guest ID	We use this information to create your account for the GAME in accordance with your request.	Necessary to perform our contract with you to provide the GAME.
Customer Support: name, OpenID, device ID, email address (if contacted via email), details of ticket, complaint and handling, content of correspondence, game data and details of gameplay under review, IP address	We use this information to improve our services and provide troubleshooting, such as addressing and remediating technical issues and bugs.	Necessary to perform our contract with you to provide and support the GAME.
Survey Information: User and contact information (age, gender, email, address, mobile number, select geographic location (country)), device information (phone model, device configuration preference), game information (game habits and preferences (including recently played games, game duration and favorite game categories and experience, language preference), and other content of survey responses user may choose to provide If you choose to participate in an in-game survey via IMUR, we will only receive an aggregated report of the above data  If you choose to participate in a survey via a channel other than IMUR, we will retain your survey response for 30 days  Email address	We use the survey information to allow you to participate in surveys about the GAME to improve the GAME. We may use your email address to invite you to participate in surveys after the GAME send you marketing information after the GAME, if we have obtained your consent to do so.	Consent.
Account Creation & Authentication: IP address, OpenID, system time	We use this information to create your account for the GAME in accordance with your request, and authenticate your log in.	Necessary to perform our contract with you to provide you with customized gender-specific GAME features.
Game Data: OpenID, IP address (only kept in aggregated format for server improvement), device model, game play statistics (e.g., level, scores)	We use this information to allow you to play the GAME.	Necessary to perform our contract with you to provide the GAME.
Geographic Matchmaking (optional): GPS information (approximate distance, but no exact location shown)	If you choose to use this feature, we use this information to allow you to connect with users nearby your location. Your and users’ exact location GPS information is not shared with other users.	Necessary to perform our contract with you to allow you to connect with users nearby.
Analytics, Crash Reporting & Performance:  User Region: country, province, city, carrier id, region, IP address Device Information: application version, application ID, battery information, WiFi strength, available space, network type, OS version, OS name, carrier, country code, device language, device resolution, brand, manufacturer, device model, RAM, ROM and CPU information, GPU information, Google advertising ID, Game Frame information, mobile signal strength, network round trip time, network bytes received/sent, login/pay step event information, XWID	We use this information to perform general and game data analytics, including for the purposes of track which advertisements have been successful for future campaigns and for payment to advertising partners (such analytics also includes reviewing game performance and payments) and for the purposes of error-fixing, troubleshooting, and debugging.	It is in our legitimate interest to carry out data analytics to track which advertisements have been successful for future campaigns and for payment to advertising partners, and for the purposes of solving game crashes.
Push Notifications (Firebase): Device information: Device model, device name, device manufacturer, running process information Other:  SDK version, application package name, application version, operator name, network type	We use this information to send you push notifications in the GAME.	Necessary to perform our contract with you to provide the GAME.
Payment Information (Midas in-app purchases - only via Google Play and App store): OpenID, product cost, product purchased, IP address, device information (OS version, phone model, device root status) and details of transactions linked to player ID	We use this information to process your payments in the GAME.	Necessary to perform our contract with you to process your payments in the GAME.
Service Information & Connection Management Data:  OpenID, device name, device model, login channel ID	We use this information to allow game servers to communicate.	Necessary to perform our contract with you to provide the GAME.
Game Update & SDK Data: OpenID, device information (device name and model, login channel ID)	We use this information to detect and download version updates and manage integrated SDKs.	Necessary to perform our contract with you to allow you to play the latest version of the GAME and use all functions of the GAME.
Text Data	We use this information to facilitate the posting of your communications with other users.	Necessary to perform our contract with you to facilitate the posting of your communications with other users.
Voice Chat Data (real-time voice): OpenID, device information (device name, device model, client exports IP, device brand, UUID, system time), SDK version IP address, network type, OpenID, model Please note voice chat contents data is only stored on your device, and is not processed by our servers	We use this information to facilitate the posting of your communications with other users.	Necessary to perform our contract with you to facilitate the posting of your communications with other users.
Voice Chat Data (non-real time voice messages): OpenID, device information (device name, device model, client exports IP, device brand, UUID, system time), SDK version IP address, network type, OpenID, model, voice file, report data	We use this information to facilitate the posting of your communications with other users.	Necessary to perform our contract with you to facilitate the posting of your communications with other users.
Anti-Cheat Data: Android: OS version, manufacturer, CPU, country code and language, root/simulator status, APK data, process data, SD card cache, APK name and version, start time, SD card target file, host file, screenshots of gameplay (if you are suspected of cheating behavior), sensor data, critical system library data, Open ID	We use this information to ensure the security of the GAME.	It is in our legitimate interest to ensure the security of the GAME.
Gift Data: IP address, device model platform data (including device ID, username, token, phone and email), game play statistics, task completion status, game account credits, user gift pack collection record, gift pack distribution status, activity points, identity information (Open ID, role ID), eligibility for gift package distribution, package contents	We use this information to facilitate gift delivery.	Necessary to perform our contract with you to facilitate the distribution of gifts.
Data analytics / profiling (Apps flyer): Technical information: browser, device, CPU, language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier Technical identifiers: IP address, user agent; Google Advertising ID, Open ID Engagement information: ad clicks/impressions, audiences, or segments to which an ad campaign is attributed, the type of ads and the webpage or application from which such ads were displayed, URL from the referring website, downloads and installations	We use this information for ad attribution purposes.	It is in our legitimate interest to carry out data analytics and profiling for ad attribution purposes to understand how our users interact with advertisements.
Data analytics / profiling (Firebase): device data (OS, model, app store, app version), event data (session duration, geography, open/launch/update, purchase, country, interests, language, new/established, ad clicks and impressions), analytics data (usage, clearance, crashes, removal, payment)	We use this information for user acquisition purposes and to monitor the effectiveness of our advertisements.	Legitimate interest to allow us to acquire users and to monitor the effectiveness of our advertisements.
Bug fixing and analysis: UUID and Android ID	We use this information to determine which devices commonly encounter bugs and crashes.	It is in our legitimate interest to monitor, analyze and fix bugs.
Data analytics (Facebook): Event Data: information shared by the user about people and the actions that they take on the relevant website, app or shop	We use this information for user acquisition purposes and to monitor the effectiveness of our advertisements. We also use the aggregated and anonymized data for analytics purposes.	It is in our legitimate interest for us to monitor the effectiveness of our campaigns.

 

6.                 How We Store and Share Your Personal Information

Our corporate operates around the world. Pursuant to our contract with you to provide you with the GAME, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this Privacy Policy.

In addition, your information can be accessed from outside of where you live by our support, engineering, and other teams around the world, including 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 GAME, including providers of cloud services that process information identified in this policy on their servers for the purpose of providing the GAME, analytics and ad attribution providers, and providers that carry out surveys. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.
• Companies within our corporate who process your personal information in order to operate the GAME. All related group companies may only use your personal information in accordance with this Privacy Policy.

• Regulators, judicial authorities and law enforcement agencies, and other third parties for safety, security, or compliance with the law. There are circumstances in which we are legally required to disclose information about you to authorities, such as to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant. We may also disclose your information to:
• enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
• detect, prevent, or otherwise address security, fraud or technical issues; or
• protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).
• A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organize any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

 

7.                 The Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data using 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 GAME or otherwise via the Internet; any transmission is at your own risk.

 

8.                 Data Retention

We do not keep your data for longer than is necessary unless we are required to do so under law.  We keep your data for as long as your account is active or as needed to provide you the Service. If we are required to retain your information beyond the necessary retention periods, for example to comply with applicable laws, we will store it separately from other types of personal information.

 

9.                 Your Rights

You have certain rights in relation to the personal information we hold about you, depending on where you are located. Some of these only apply in certain circumstances (as set out in more detail below). We will 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 Project-Pandora@topjoy.com.

 

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by contacting us at Project-Pandora@topjoy.com.

 

Portability

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process based on 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”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party, with certain exceptions. We will provide further information to you about this if you make such a request.

If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (for example, where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

 

Correction and Erasure

You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by contacting us at Project-Pandora@topjoy.com.

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 defense 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 GAME 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.

 

Restriction of Processing to Storage Only

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defense of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it.

 

Objection

You have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below by contacting us at 

 Project-Pandora@topjoy.com.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at Project-Pandora@topjoy.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.

 

Advertising

We will show you personalized advertisements in the Service as well as in other websites and services we have a legitimate interest to process necessary data to track the content you access in connection with the Service and your online behavior and deliver, target and improve our advertising and the Service. The Service includes features from our partners(e.g., MAX), such as social media interaction tools and in-game advertising. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies. You may opt-out of interest-based advertising on mobile applications by checking the privacy settings of your device and selecting "limit ad tracking" (iOS) or "opt-out of interest based ads" (Android). You may choose to stop receiving marketing messages/ advertising from us by using the unsubscribe option in the message or contact us at Project-Pandora@topjoy.com.

 

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 GAME for maintenance, or security, privacy, or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.

 

    
10. TERMS -SPECIFIC

 

Some jurisdictions’ laws contain additional terms for users of the GAME, 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.

 

Brazil

Whenever we use your personal information based on your consent, you may revoke the consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account or you can contact us as set out in this Privacy Policy. This may affect our provision of the GAME to you.

 

Egypt

By clicking “accept” or by proceeding with the sign-up process, you acknowledge that you have read, understood, and consented to this Privacy Policy. You are acknowledging your consent to the processing, storage, and cross-border transfer of your personal data. The cross-border transfer may be to any country in which we have databases or affiliates, to the jurisdictions specified in this Privacy Policy.

 

You also acknowledge your consent to receiving marketing messages from us, whether through e-mails or pop-ups or other such means.

 

If you are a new user, you have seven days to inform us of any objection you may have to this Privacy Policy.

 

As an Egyptian data subject, you have certain rights under the Egyptian Personal Data Protection Law.

 

Mexico

Some of the purposes of processing specified in Section of advertising are voluntary, which may include to show you personalized recommendations or advertising. We may also use your personal data for the voluntary purpose of sending information to your email or via SMS that we may consider relevant to you.

To understand more about and exercise your rights, as well as the applicable means, procedures and requirements to exercise any of your rights as specified in Section 9.

 

Turkey

You have legal rights, which are set forth in Article 11 of the DPL, in relation to the personal information data we hold about you. As a Turkish data subject, you may have the right to apply to the data controller and (to the extent permitted under applicable laws and regulations):

 

• demand compensation for the damages that you have suffered as a result of unlawful processing of your personal data.
• learn whether your personal data has been processed;
• object the occurrence of any consequence that is to your detriment by means of analysis of personal data solely through automated systems, and
• request information about processing if your personal data has been processed;
• learn the purpose of processing of your personal data and whether they have been used accordingly;
• know the third parties in the country or abroad to whom personal data has been transferred;
• request rectification in the event personal data is incomplete or inaccurate and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
• request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the DPL and to demand the operations in this regard be reported to third parties your personal data has been transferred to.

 

11.                 Contact & Complaints

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to Project-Pandora@topjoy.com.

If you wish to make a complaint about how we process your personal information, please contact us in the first instance at Project-Pandora@topjoy.com. and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the region in which you live or work where you think we have infringed data protection laws.

 

12.   Changes & Language

Please check this page frequently to see if there are any updates or changes to this Privacy.

 

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.