Combat of Hero Privacy Policy
Last Updated: [Aug 17, 2020]

Welcome to Combat of Hero (the “Game”). The Game is provided, operated and controlled by Bytedance Pte. Ltd, whose registered address is at 8 Marina View Level 43 Asia Square Tower 1 Singapore 018960 (“Ohayoo”, “we” or“us”).

You are reading the Privacy Policy, which explains how we collect, use and disclose your personal data when you download the Game from Apple App Store or Google Play, access the Game, and the rights you may have under applicable privacy laws. If you do not agree with this policy, you should not play the Game.

If you have any questions about how we use your personal data, please contact [combatofhero@ohayoogames.com].

Below is a summary of key points in our Privacy Policy.

This privacy policy consists of a main body and a jurisdiction-specific section. The jurisdiction-specific section might include additional information required under local data protection laws and/or render certain aspects of the body policy to be inapplicable or amend them accordingly due to local data protection laws.

SUMMARY

1. What data do we collect about you?
We collect and process your data when you create an account and play the Game, including your contact details and other data you provide when you register for an account or play the Game. We also collect data you share with us from third parties (such as Facebook, etc.) if you choose to log in to the Game via your account with such third party networks, and technical and behavioral data about your use of the Game. We may also collect data about you automatically through your use of the Game.
2. How and for what purpose will we use the data about you?
We use your data to provide the Game to you and to improve, develop and administer it. We may also use your data to, among other things, ensure your safety. We may also use your personal data to serve you targeted advertising and promote the Game and other products and services (in each case, if required under applicable law, where we have your consent).
3. Who else will access and collect your personal data and who do we share your data with?
The third party developer of the Game will have access to your data. Your data may also be collected by/shared with other companies in the same group as the Ohayoo, payment providers, and advertising service providers. Where required or permitted by law, we will share your data with law enforcement agencies or regulators and with third parties pursuant to a legally binding court order.
4. Your rights
In certain circumstances, you have rights in relation to your data such as the right to access and the right to correction. Depending on your jurisdiction, you may have additional rights - please see the jurisdiction-specific section at the end of this Privacy Policy.
5. How long do we keep hold of your data?
We retain your data for as long as it is necessary to provide you with the Game service so that we can fulfill our contractual obligations and rights in relation to the data involved. Where we do not need your data in order to provide the Game to you, we retain it only as long as we have a legitimate business purpose in keeping such data or where we are subject to a legal obligation to retain the data. We will also retain your data if necessary for the establishment, exercise or defense of legal claims.
6. How will we notify you of any changes to this Privacy Policy?
We will generally notify all users of any material changes to this policy through a notice within the Game when you log in. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. By accessing the Game, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it.

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1. The types of personal data we use
Unless otherwise stated in this policy, the personal data we collect from you or about you is required so that we can perform our contract with you to provide the Game to you as detailed in our Terms of Service. The provision of certain data is mandatory for the purposes of your access to the Game, and if you do not provide certain types of data, we may not be able to grant you access to the Game, provide certain aspects of the Game or certain functionalities may be lost. However, you have control over certain kinds of personal data that you can choose to share or to withhold from us, and still be able to access the Game, as detailed in this policy.

We collect and use the following data about you:

Data You Provide to Us, Including Your Profile Data. You give us data when you register an account to play the Game via the application directly or if you choose to register using your social network account details (e.g. Facebook, etc.),including your name, username, password, age, language, email address, country, data you disclose in your user profile, character name or nickname, and data you voluntarily elect to provide in order to customize game play, such as gender. We link your data with your activity on our Game across all your devices, using your email or other log-in or device data.

We also collect data in correspondence you send to us.

Behavioral and Use Data.

Gameplay
We process data regarding your use of the Game including login history, purchase history, how you engage with the Game, the preferences you set, the amount of time spent in the Game, your gameplay and activity, your Game progress, and other pieces of data in connection with your various activities within or through the Game or otherwise that are sent by your device or computer system when you access the Game, which are automatically tracked and recorded by our servers. We also link your subscriber data with your activity on our Game across all your devices using your email address or similar data that you have provided.

Feedback
We also collect data and content of messages you provide to us through your feedback such as product reviews you write, or questions and data you provide for customer support. In this case, we may collect and store your contact data that you give them (i.e. your name and email address), your social network or service user ID number. When you contact us, such as for customer support, phone conversations or chat sessions with our representatives may be monitored and recorded.

Data from Third Parties. You may choose to share certain data with us from third parties or through your use of the Game. We have set out further details on the data we receive from third parties below:

Social Networks
If you choose to register to use the Game using your social network account details (e.g. Facebook, etc.), you will provide us or allow your social network to provide us with your username and public profile (including your name, profile picture, gender, networks, user IDs, list of friends, followers and accounts you follow, date of birth, email address, and any other data you have set to public on your account).

Advertising Service Providers
We use the data collected from you and your interaction with the Game to infer your likely interests to provide you with more relevant advertising. We will obtain your consent to do this where required by applicable law. This data tells us about purchases you have made so that we can predict what else might interest you in the future and assess how effective the advertising on our Game is. We collect this data by the use of Cookies and similar technologies in our Game and from similar data received from third parties who advertise through our Game and whose sites you visit.

Technical Data we collect about you. We automatically collect certain data from you when you use the Game. Such data includes your IP address, time zone settings, language, data regarding the device or hardware you are using to access the Game such as the model of your device, mobile device’s unique identifier (UDID) or serial number, cellular information, WiFi network, identifier for vendor (IDFV), source of user (where you use your account on a third party platform to log in), IMEI number, device screen resolution, mobile carrier, network type, device ID, operating system, Android ID, Google Advertising ID, MAC address and connection, as well as other types of data sent by your device when you access the Game. Where you log-in from multiple devices, we will be able to use your profile data to identify your activity across devices.

Buy virtual items. If you buy virtual items and advantages via in-app purchases, your purchase will be made via your Apple iTunes or Google Play account. When you play the Game or access any of our other services on connected third-party applications or platforms (like Apple, Google, etc.), any purchases you make will be processed by that third-party application and subject to that third-party application’s terms of service and privacy policy. We do not collect any financial or billing data from you in relation to such a transaction but may receive non-financial data related to your purchase,like your name and approximate physical location, and the items purchased. Please review the relevant app store's terms and notices in respect of the handling of such data. So that we can credit your account with the correct value in virtual items, we keep a record of the virtual assets/items you own, purchases you make, the time at which you make those purchases and the amount spent.

Other. Ohayoo may also receive either non-personal or public data from third parties in connection with market and demographic studies and/or data that Ohayoo may use to supplement personal data provided directly by you. Ohayoo may ask some third-party service providers to supplement the personal data that you provide to Ohayoo for its own marketing and demographic studies, so that Ohayoo can consistently improve its services and related advertising to better meet its visitors' needs and preferences. To enrich its understanding of individual customers, Ohayoo may tie this data to the data you provide to it.

2. Cookies

We, our vendors and service providers use cookies and other similar technologies (e.g. pixels, web beacons etc.) (collectively, “Cookies”) to enhance your experience using the Game. We will obtain your consent to the use of Cookies where required under applicable law.

(a) What is a Cookie?
Cookies are used to collect data, including personal data, from you. Cookies are small files which, when placed on your device, enable the Game to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar data from your computer or device.

Cookies are stored on your browser by website or apps that you visit. When you return to that website or app (or visit websites or apps that use the same cookies) these platforms recognize the Cookies and your browsing device.

b) Categories of Cookies
Cookies do many different jobs,like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. Cookies can tell us, for example, whether you have visited the Game before or whether you are a new player. They can also help to ensure that adverts you see online are more relevant to you and your interests.

There are different categories of Cookies, including:
· First-party Cookies: First-party Cookies are small amounts of text which are served by us directly to your device.
· Third-party Cookies: Third-party Cookies, which are served by a third party on our behalf. We use third party Cookies for essential, functionality,analytic and performance, targeting or advertising and social media purposes.

Cookies can remain on your computer or mobile device for different periods of time. Some Cookies are 'session cookies', meaning that they exist only while your browser is open and are deleted automatically once you close your browser. Other Cookies are 'permanent cookies', meaning that they survive after your browser is closed. They can be used by the platform to recognize your computer when you open your browser and browse the Internet again.

c) What types of Cookies do we use and how do we use them?
The types of Cookies and similar technologies used by us and our partners in connection with the Game can be classified into one of five categories, namely 'essential Game Cookies', 'functionality Cookies', 'analytics and performance Cookies', 'targeting and advertising Cookies', and 'social media Cookies'. Cookies do a lot of different tasks to ensure you enjoy your use of the Game, for example, they are used to remember your preferences on sites you visit, to help you navigate between pages more efficiently and to make sure the adverts you see on our Game are relevant to you and your interests. We have set out some further information about each category, and the purposes of the Cookies we and third parties set in the following table.

Cookies that are necessary for essential purposes
These Cookies are essential to provide you with the Game and to use some of its features, such as to enable you to log in. Without these Cookies, we would not be able to provide you with a secure log in account. We use Cookies to uniquely identify you. Each time you log in to the Game, a Cookie containing a unique identifier that is tied to your account is placed on your browser. These Cookies allow us to uniquely identify you when you are logged into the Game and to process your online transactions and requests.

Functionality Cookies
Functionality Cookies record information you have entered or choices you have made. These Cookies also enable you to optimize your use of the Game after logging in so that we can personalize our content for you, greet you by name and remember your preference. These Cookies can also be used to remember settings you have applied. These Cookies mean that when you continue to use or come back to the Game, we can enable you to start the Game from where you left off.

Analytics and Performance Cookies
We use analytics/performance Cookies to analyze how you use the Game, including your level in the Game, measure any errors that occur and test different design ideas. The information is used to report and evaluate your activities and patterns as a user of the Game to provide services in accordance with these activities. These Cookies do not collect information that individually identifies you and all information these Cookies collect is aggregated and anonymous. We also use third-party analytics tools to help us measure traffic and usage trends for the Game (with your consent if required under applicable law).

Targeting or Advertising Cookies
Analytics: As you use the Game,you will notice that it features advertising. We allow third party companies, including advertising companies, to place Cookies in the Game to track the performance of our advertisements (with your consent if required under applicable law). As an example, these Cookies remember which users have used the Game. The information provided to third parties does not include personal information but it may be associated with personal information after they receive it.

Marketing: We may also (with your consent, where required under applicable law) contract with third-party advertising networks that collect IP addresses and other information from the Game, from third party websites and apps. Ad networks follow your online activities and collect information through automated means (such as through the use of Cookies, again, with your consent, if required under applicable law). Ad networks use this information, mainly to serve adverts about products and services that are likely to interest you. We may also partner with third parties to provide certain features in the Game or display advertising based on your web browsing activity. We may also use information from one device to help personalize your experience on another device. For advertising purposes, we may collect your Google Ad ID, Android Ad ID or (where applicable) your IDFA (IDFA stake the place of Cookies in mobile advertising delivered to iOS devices).

Social Media Cookies
Third parties whose applications are connected to the Game by you will set their own Cookies in order to customize their applications for you. Because of how Cookies work, we cannot access these Cookies, nor can the third parties access the data in Cookies used by us. If you are logged in to your account with the third party, the third party will be able to link information about you with your actions via Cookies.

3. How and for what purpose we use your personal data

We may use the data we collect about you in the following ways:
• In accordance with, and to perform our contract with you, we may use your data to:
￮ allow you to play the Game;
￮ notify you about changes to the Game and send Game-related communications to you;
￮ provide you with user support;
￮ enforce and notify you of changes to our terms of service, conditions and policies;
￮ administer the Game including troubleshooting;
￮ enable you to participate in the virtual items program; and
￮ communicate relevant information (such as updates and security alerts) and provide support to you.
• In order to comply with our legal obligations, we may use your data to help us detect abuse, fraud and illegal activity in the Game;
• In accordance with our legitimate interests to provide an enjoyable and safe Game experience, we may use your data to:
￮ ensure your safety and security;
￮ ensure the Game is presented in the most effective manner for you and your device;
￮ improve, promote, update and develop the Game and your experience, and protect the Game from any cyber-attacks;
￮ better understand customer behavior and improve our products and services through analytics;
￮ carry out data analysis and test the Game to ensure its stability and security and data about installed packages and running apps or processes in order to ensure the security of the Game network and prevent the spread of viruses and malware; and
￮ provide you with personalized advertising and promotional emails (with your consent, if this is required by law), namely by sending messages regarding new products, features, enhancements, special offers, upgrade opportunities, contests and events of interest.
• We may also take measures to ensure that you are old enough to play the Game, as required by law.

4. Who else will access your personal data and how we share your data

Third Party Game Developer
We work with third party game developers, and the third party developer of the Game will have access to your technical data and other data.

Social Networks
If you choose to register to use the Game using your social network account details (e.g. Facebook, etc.), you will provide us or allow your social network to provide us with your user name and public profile (including your name, profile picture, gender, networks, user IDs, list of friends, date of birth, email address, and any other data you have set to public on your account).

If you access third-party services, such as Facebook, to log in to the Game, these third-party services may be able to collect data about you,including data about your activity on the Game, and they may notify your connections on the third-party services about your use of the Game, in accordance with their privacy policies. Facebook's privacy policy may be found at: Facebook Privacy Policy.

To manage the data Ohayoo receives about you from a third-party application, such as Facebook, you will need to follow the instructions for the third-party application for updating your data and changing your privacy settings. You can also manage some aspects of data collection and use by visiting the “settings” page of your mobile device and reviewing the permissions of each application or “app.” Once Ohayoo receives your data from a third-party application or your mobile device, that data is stored and used by Ohayoo in accordance with this Privacy Policy. You may access and update that data as described herein.

Payment Provider
If you choose to buy virtual items, we will share data with the relevant payment provider to facilitate this transaction. We share a transaction ID to enable us to identify you and credit your account with the correct value in virtual items once you have made the payment.

Advertising Service Providers
We may share and/or advertisers and third party measurement companies may collect some of your personal data, for example to show how many and which users of the Game have viewed or clicked on an advertisement. We may also share and/or they may collect non-personal and personal data e.g. IDFA, IP address, time zone settings, browser type, language, operating system, network connection type and speed, and data regarding the device or hardware you are using to access the Game such as the model and make of your device. You may refer to the advertisers' privacy policies for more information:
• Adcolony
• -https://www.adcolony.com/privacy-policy/
• Applovin
• -https://www.applovin.com/privacy/
• Criteo
• -https://www.criteo.com/privacy/
• Facebook
• -https://www.facebook.com/about/privacy
• Fyber
• -https://www.fyber.com/privacy-policy/
• Google
• -https://policies.google.com/privacy
• Inmobi
• -https://www.inmobi.com/privacy-policy/
• Ironsource
• -https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
• Mintegral
• -https://www.mintegral.com/en/privacy/
• Mopub
• -https://www.mopub.com/legal/privacy/
• Oath
• -https://policies.oath.com/in/en/oath/privacy/
• Ogury
• -https://ogury.com/privacy-policy/
• Tapjoy
• -https://www.tapjoy.com/legal/tapjoy-users/#privacy-policy
• Vungle
• -https://vungle.com/privacy/

Please note, after clicking on a third party advertisement, you may no longer be on a site hosted by Ohayoo or the social network through which you are playing the Game. If you no longer want to receive tailored in-Game advertisements from third parties, you may adjust your privacy settings.

Our third-party analytics providers use this data to help us serve targeted adverts which may be of interest to you (if you have chosen to receive personalized advertising from us and/or our partners). For more data about how our analytics providers collect data from the Game, please see the above section on Cookies.

Our Corporate Group
We may also share and/or other members, subsidiaries, or affiliates of our corporate group may collect, your data to provide the Game including improving and optimizing the Game, preventing illegal use, and supporting users.

Law Enforcement
We may share your data with law enforcement agencies, public authorities or other organizations if legally required or permitted to do so,or based on our legitimate business interests if such use is reasonably necessary to:
• comply with a legal obligation, process or request Ohayoo is not required to question or contest the validity of any legal process, search warrant, subpoena or other similar governmental request that it may receive);
• enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;
• detect, prevent or otherwise address security, fraud or technical issues; or
• protect and defend the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging data with other companies and organizations for the purposes of fraud protection and credit risk reduction).

Sale or Merger
We will also disclose your data to third parties:
• in the event that we sell or buy any business or assets (whether a result of liquidation, bankruptcy or otherwise), in which case we will disclose your data to the prospective seller or buyer of such business or assets; or
• if we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user data may be among the transferred assets.

5. International data transfers
For the purpose of performance of our contract with you, the personal data that we collect from you may be transferred to, and stored at, or otherwise accessed from or processed in a destination outside of your jurisdiction of residence (including Singapore and the United States of America) that has laws and regulations that may not guarantee the same level of security and protection of personal data as your jurisdiction. However, we will take reasonable and necessary steps to ensure that we handle personal data in accordance with this Privacy Policy and provide a standard of protection that it is comparable with the protection under the laws of your jurisdiction,regardless of where your personal data is transferred to or accessed from.

We will separately obtain your consent for international data transfer if this is required under applicable law.

6. Your rights
You may have the following rights under applicable laws:
• The right to request free of charge (i) confirmation of whether we process your personal data and (ii) access to a copy of the personal data retained;
• The right to request proper rectification or removal of your personal data or restriction of the processing of your personal data; and
• The right to object to processing your personal data for the purposes of sending you promotional messages.

Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.
Depending on your jurisdiction, you may have additional rights. Please see the jurisdiction-specific section at the end of this Privacy Policy.

Please send an e-mail to [combatofhero@ohayoogames.com] if you would like to exercise any of your rights. We will respond to your request consistent with applicable law and subject to proper verification.

In addition:
• You can change your preferences by using the toggle features in the Game's cookie settings or by adjusting your browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. For example, due to differences in how browsers and mobile apps function, you may need to take different steps to opt out of Cookies used for targeted advertising in a browser and to opt out of targeted advertising for a mobile application, which you may control through your device settings or mobile app permissions. In addition, your opt-out selection is specific to the particular browser or device that you are using when you opt out, so you may need to opt-out separately for each browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Game may no longer be available to you.
• You may opt out of receiving advertising and/or marketing communications by following the instructions in such communications or by using options provided in the game settings.
• Your mobile device may include a feature that allows you to opt out of some types of targeted advertising (“Limit Ad Tracking” on iOS and “Opt out of Interest-Based Ads” on Android).
• Some browsers transmit “do-not-track" signals to websites. Because of differences in how browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.
• If you have registered for an account, you may access, review, and update certain personal data that you have provided to us by logging into your account and using available features and functionalities.
• If you want to remove your contacts stored by us, follow the instructions provided in the game to request that we remove them from our systems. If you need to enter a password to allow us to access your address book, we will not store that password.

7. The security of your personal data
We take steps to ensure that your data is treated securely and in accordance with this policy. We understand the importance of keeping your personal data safe and private, and we are committed to protecting your personal data from being lost, stolen or misused.

You are also responsible for keeping your personal data safe. Also, you are responsible for keeping your account details (if any) confidential.

We will, from time to time, include links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Because Ohayoo cannot control the activities of third parties, it cannot accept responsibility for any use of your personal data by such third parties, and it cannot guarantee that they will adhere to the same privacy and security practices as Ohayoo. Please check these policies before you submit any data to these websites.

8. How long do we keep your personal data
We retain your data for as long as it is necessary to provide you with the service so that we can fulfill our contractual obligations and rights in relation to the data involved. However, there are occasions where we are likely to keep this data for longer in accordance with our legal obligations or where it is necessary for the establishment, exercise or defense of legal claims.

9. Data relating to children
The Game is not directed at children under the age of 13 and we do not knowingly collect or solicit personal data from children under 13. If you believe that we have personal data about or collected from a child under the relevant age, please contact us at [combatofhero@ohayoogames.com] and we will ensure that it is deleted.

10. Complaints
In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at [combatofhero@ohayoogames.com] and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to lodge a claim with the relevant data protection authority.

11. Changes
We will generally notify all users of any material changes to this policy, through a notice provided via the Game and providing any other notice required by applicable law. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. By accessing the Game, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it. If you do not agree to the updated policy, you must stop accessing or using the Game.

12. Contact
Questions, comments and requests regarding this policy should be addressed to [combatofhero@ohayoogames.com].


Supplemental Terms – Jurisdiction-Specific

In the event of a conflict between the provisions of the Supplemental Terms –Jurisdiction-Specific that are relevant to your jurisdiction from which you access or use the Services, and the rest of policy, the relevant jurisdictions’ Supplemental Terms – Jurisdiction-Specific will supersede and control.

EUROPEAN JURISDICTIONS

Germany

In the Summary, under How will we notify you of any changes to this Privacy Policy?, the following sentence shall be deleted:

By accessing the Game, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it.

Section 11 (Changes) is modified to delete the sentence:
Your continued access to or use of the Game after the date of the updated policy constitutes your acceptance of the updated policy.

EEA, UK and Switzerland

In Section 2 (Cookies), the following shall be added:

We will only make use of Cookies to obtain and share your data if you provide your express consent. You may withdraw your consent at any time and such withdrawal shall not affect the lawfulness of the processing based on consent before its withdrawal.

In Section 3 (How we use your data), the following shall be added:

• With your consent, we will use your data (including ad identifiers, age, region, gender, language, data related to your use of the Game and interactions with others, messages including content of the message and data about when the message has been sent, received and/or read, as well as the participants of the communication, username and public profile) to:
￮ collect and process, which includes scanning and analyzing, data you provide in the context of composing, sending, or receiving messages through the Game messaging functionality. That data includes the content of the message and data about when the message has been sent, received and/or read, as well as the participants of the communication;
￮ monitor and record customer support communication, phone conversations or chat sessions with our representatives;
￮ access posts to your social media walls, posts in your news feed and access your social network data at any time, including any of your favorite websites, friend data or fan pages and any other data included in your application, social network or online profile, even if you are not using the social network or you chose not to make that data public;
￮ provide you with personalized advertising. Please see the section entitled “Advertising Service Providers" for more information. You can manage ‘Personalized Ads’ via your Game settings;
￮ collect and process certain technical data, namely list of installed packages and running apps or processes and third-party apps you have on your device;
￮ collect data about your location. In certain jurisdictions, with your permission, we will collect Global Positioning System (GPS) data and mobile device location data based on your SIM card;
￮ find other users and invite your friends in your preferred social networks as outlined in the body section of this privacy policy and to show descriptions of your game activity and game profile to other players on the social network,regardless of whether they are your social network friends or not;
￮ supplement personal data provided directly by you with either non-personal or public data from third parties in connection with market and demographic studies and/or data that Ohayoo may use, or to ask third-party service providers to supplement the personal data that you provide to Ohayoo for its own marketing and demographic studies, and to tie individual customer data to data you provide to Ohayoo.
￮ to send you direct marketing via email or SMS; and
￮ use cookies as outlined under section 2.

You may withdraw your consent at any time and such withdrawal shall not affect the lawfulness of the processing based on consent before its withdrawal.

The following shall be added to section 5 - International data transfers:

The personal data that we collect from you will be transferred to, and stored at, a destination outside of the European Economic Area (“EEA”).

Where we transfer your personal data to countries outside the EEA, we do so under the Commission’s model contracts for the transfer of personal data to third countries
(i.e. standard contractual clauses) pursuant to 2004/915/EC or 2010/87/EU (as appropriate). For a copy of these Standard Contractual Clauses, please contact us at [combatofhero@ohayoogames.com].

The following shall amend section 6 - Your Rights:

• Right to request access to your personal data: You have the right to obtain from us confirmation as to whether or not personal data concerning you is processed, and, where that is the case, to request access to the personal data. The access information includes - inter alia - the purposes of the processing, the categories of personal data concerned, and the recipients or categories of recipient to whom the personal data have been or will be disclosed. However, this is not an absolute right and the interests of other individuals may restrict your right of access.

You have the right to obtain a copy of the personal data undergoing processing free of charge. For further copies requested by you, we may charge a reasonable fee based on administrative costs.

• Right to request rectification: You have the right to obtain from us the rectification of inaccurate personal data concerning you. Depending on the purposes of the processing, you may have the right to have incomplete personal data completed,including by means of providing a supplementary statement.

• Right to request erasure (right to be forgotten): You have the right to obtain from us the erasure of personal data concerning you and we may be obliged to erase such personal data.

• Right to request restriction of processing: You have the right to obtain from us that we restrict the processing of your personal data. In this case, the respective data will be marked and may only be processed by us for certain purposes.

• Right to data portability: Where processing of your personal data is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, you have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format or to have your personal data transmitted directly to another company, where technically feasible;

• Right to withdraw consent: Where the processing of your personal data is based on your consent,you have the right to withdraw your consent at any time without impact to data processing activities that have taken place before such withdrawal;

• Automatic decision making: You have the right not to be subject to any automatic individual decisions, including profiling, which produces legal effects on you or similarly significantly affects you unless we have your consent, this is authorized by EU or EU Member State law or this is necessary for the performance of a contract;

• Right to Object: You have the right to object to processing if we are processing your personal data on the basis of our legitimate interest unless we can demonstrate compelling legitimate grounds which may override your right. If you object to such processing, we ask you to state the grounds of your objection in order for us to examine the processing of your personal data and to balance our legitimate interest in processing and your objection to this processing; and

• Right to complaint: You have the right to lodge complaints before the competent data protection authority.

These rights might be limited under applicable national data protection law.
Please send an e-mail to [combatofhero@ohayoogames.com] if you would like to exercise any of your rights. We will respond to your request consistent with applicable law and subject to proper verification.

Section 8 (How long we keep your personal data) is modified to add:

Where we do not need your data in order to provide the service to you,we retain it only for so long as we have a legitimate business purpose or other valid legal basis for keeping such data.

Section 9 (Information relating to children) shall be replaced with the following:

The Game is not directed at children under the age of 16 and we do not knowingly collect or solicit personal data from children under 16. If you believe that we have personal data about or collected from a child under the relevant age, please contact us at [combatofhero@ohayoogames.com] and we will ensure that it is deleted.


ASIA-PACIFIC JURISDICTIONS

Japan

The following shall be added to Section 5 - International data transfers:

The personal data that we collect from you will be transferred to, and stored at, a destination outside of Japan, in particular in Singapore and the United States of America.

Hong Kong

Section 3 (How we use your personal data) is modified to add:

We intend to use your personal data (name and email address) for promotional marketing purposes, namely to send you messages concerning new products, features, enhancements, special offers, upgrade opportunities,contests and events of interest in relation to the Game. We require your express consent (for use) and written consent (for transfer) before we do so.

We will not transfer your personal data to other parties for gain.

Macau

In Section 1 (The types of personal data we use), the first sentence of the second paragraph is modified to read: "You expressly consent that we will collect and use the following data about you:".

In Section 3 (How and for what purpose we use your personal data), the first sentence is modified to read: "You expressly consent that we may use the data we collect about you in the following ways:"

In Section 4 (How we share your personal data), the first sentence is modified to read: "You expressly consent that we will share your data with the following selected third parties:"

Section 5 (International data transfers) shall be modified as follows:

You expressly consent that the personal data that we collect from you may be transferred to, and stored at, or otherwise processed in a destination outside of your jurisdiction of residence. These jurisdictions include Singapore and the United States of America. The list of jurisdictions may be supplemented from time to time in accordance with Section 11 of this Policy.

In Section 6 (Your rights), the following sentence: "The right to object to processing your personal data for the purposes of sending you promotional messages" shall be deleted and replaced with the following:

• "The right to object prior to and during our usage of your personal data for direct marketing purposes."

South Korea

Section 3 (How we use your personal data) is modified as follows:

We intend to use your personal data (name and email address) to send you promotional messages concerning new products, features, enhancements,special offers, upgrade opportunities, contests and events of interest in relation to the Game. We require your express consent before we do so.

Section 4 (How we share your personal data) shall be modified as follows:
We share your data with the following selected third parties:

Service Providers

We provide data and content to service providers who support our business, such as cloud service and data storage providers, and technical support providers who enhance game operations, improve the Game experience, conduct debugging, and provide general support services. Details of the service providers are as follows:


成都灵峰互娱科技有限公司 A.Information You Directly and Voluntarily Provide to Us. If you are a visitor to the Site, or a user of the App, we may collect information that you provide to us when you communicate with any of our departments such as customer service or technical services. If you sign up to receive access to some of our applications, you will be required to provide an email address as part of the registration process. If you use your Facebook Account or other third party social network accounts to register for the Service, we will collect your Facebook Account or other third party social network accounts information. B.Information Automatically Collected Through the Service. We automatically collect information about you when you use the Service. If you access the Service through a mobile device, we may be able to identify the general location of your mobile device. We will collect information including, but not limited to: your mobile device’s brand, model, operating system, resolution, screen size, system version, Bluetooth settings, internet connection, RAM, history, the apps you have installed, the apps you have running in the background, mobile device’s Android Advertising ID, along with your account activation time, content displayed to you and whether you clicked on it, advertisements displayed to you and whether you clicked on them, URLs you have visited, notifications that have appeared on your mobile device, your IP address, your mobile country code, and your identity. We will also request access to your photos, media and files, your device’s camera and microphone, your Wi-Fi connection information and your device ID and call information. C.The Service may include links to other websites and other content from third party businesses. We do not have access to or control over the technology that these third parties may use. We are not responsible for the privacy practices of these third parties or the content on any third party website. You are encouraged to review the privacy policies of the different websites you visit and of the advertisers whose ads you may choose to click while on our Service. D.Information Collected by Third Party Analytics Services. We may work with third party analytics services to help us understand how the Service is being used, such as tracking the frequency and duration of use of the Service. These services may collect information about the content you view, what websites you visit immediately prior to and after visiting the Service, and your system information and geographic information. The information generated about your use of the Service will be transmitted to and stored by the applicable analytics services. E.Information You Share on Third Party Websites or through Social Media Services. The Service may include links to third party websites and social media services where you will be able to post comments, stories, reviews or other information. Your use of these third party websites and social media services may result in the collection or sharing of information about you by these third party websites and social media services. We encourage you to review the privacy policies and settings on the third party websites and social media services with which you interact to make sure you understand the information that may be collected, used, and shared by those third party websites and social media services. We use the information we gather through the Service to help us better understand how the Service and our products and services are being used. By identifying patterns and trends in usage, we are able to better design the Service and our products and services to improve your experience. We may also use this information for commercial and marketing purposes, as described below.

Section 8 (How long we keep your personal data) shall be replaced with the following:

In principle, we will promptly destroy your personal data in our possession once we achieve the purpose of collection and use of your personal data.

Procedure and Method for Destruction of Personal Data

In principle, we will promptly destroy your personal data in our possession once we achieve the purpose of collection and use of your personal data.

Your personal data will be destroyed after storage for a certain period pursuant to our internal policy or applicable laws and regulations (please refer to the provisions on retention and use period). Personal data stored in electronic file format will be deleted by using technical means that will not allow data recovery.

Section 9 (Data relating to children) shall be replaced with the following:

The Game is not directed at children under the age of 14 and we do not knowingly collect or solicit personal data from children under 14. If you believe that we have personal data about or collected from a child under the relevant age, please contact us at [combatofhero@ohayoogames.com] and we will ensure that it is deleted.

For children under the age of 14, their legal guardians have the right to exercise the rights of their children with respect to data protection.

Taiwan

Section 5 (International data transfers) shall be modified as follows:

"The personal data that we collect from you may be transferred to, and stored at, or otherwise processed in destination outside of your jurisdiction of residence, including Singapore and the United States."

The following wording shall be added to Section 6 - Your rights:

• "The right to request the cessation of the collection, processing or use of your personal data."

"Questions,comments and requests regarding this policy should be addressed to [combatofhero@ohayoogames.com]."


THE AMERICAS

USA

Data relating to children
Section 9 (Data relating to children) is modified to add:

Ohayoo respects the privacy of parents and children, and is committed to complying with the Children’s Online Privacy Protection Act (“COPPA”). If a parent believes that his or her child under the age of 13 has submitted personal data to Ohayoo, he or she can contact us via email: [combatofhero@ohayoogames.com].

Supplemental California Disclosures

In this section, we disclose information about our data processing practices as required by the California Consumer Privacy Act of 2018 (“CCPA”). These disclosures are addressed only to residents of the State of California. These disclosures do not reflect our collection, use or disclosure of California residents’ personal information where an exception under the CCPA applies.

For the purpose of these supplemental disclosures, personal data as used in the Privacy Policy, shall have the same meaning as “personal information” under the CCPA.

A. Right to Know about Personal Information Collected, Disclosed or Sold

You have the right to request that we disclose what personal information we collect, use, disclose and sell about you specifically (“right to know”). To submit a request to exercise the right to know, please submit an email request to [combatofhero@ohayoogames.com] and include“California Request to Know" in the subject line. Please specify in your request the details you would like to know, including any specific pieces of personal information you would like to access.

We will ask that you provide certain information to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. We will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.

B. Our Personal Information Handling Practices over the Past 12 Months

We have set out below categories of personal information we have collected about California residents in the preceding 12 months. For each category of personal information we have collected, we have included the reference to the enumerated category or categories of personal information in California Civil Code § 1798.140(o)(1) that most closely describe such personal information.



Category of personal information Corresponding reference to category of personal information under CCPA definition of personal information (Cal. Civ. Code § 1798.140(o)(1))
Name (A) Name
Gender (B) Information that relates to a particular individual
User ID (A) Unique personal identifier
Age (B) Information that relates to a particular individual
Language (B) Information that relates to a particular individual
Email address (A) Email address
Telephone number (B) Telephone number
Information you disclose in your user profile, information you voluntarily elect to provide in order to customize gameplay, information you share on message boards and via in-game communications, and information on your social network account you choose to share with us (B) Information that relates to a particular individual
Profile photograph or video (H) Audio, visual, or similar information.
[Purchase history] (D) Commercial information]
Payment information (B) Credit card number, debit card number, or any other financial information
Login history and information about how you engage and interact with the Game and other players (F) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement
Preferences (K) Inferences reflecting the individual’s preferences and characteristics.
IP address (A) Internet protocol address
Location (G) Geolocation data
Information about your device, browser and network, including your mobile carrier, time zone settings, device model, network type, device ID, operating system, installed packages and running apps or processes, file names and types, Android ID, Google Advertising ID, and MAC address (F) Internet or other electronic network activity information
Feedback [and survey] responses (D) Commercial information, including histories and tendencies
We collect such information from you or your device. If you choose to provide us with information through your social network account, we also collect information about you from the provider of that social network. We may also collect information about your interests, preferences and characteristics from advertising networks and publicly available sources for the purposes of targeting advertising at you. We use your personal information for the purposes set forth in Section 3 of the Privacy Policy above.

In the past 12 months, we disclosed the above categories of personal information to our affiliated and unaffiliated service providers for the purposes listed in our Privacy Policy. If you direct us to share your personal information with other specified third parties, we may disclose information about you with these third parties for the purposes described in your directions. We may also disclose personal information to the recipients described in Section 4 of the Privacy Policy above.

We do not sell, and in the preceding 12 months did not sell, California residents’ personal information. We do not have actual knowledge that we sell the personal information of minors under 16 years of age.

C. Right to Request Deletion of Personal Information

You have a right to request the deletion of personal information that we collect or maintain about you. To submit a request to delete personal information, please submit an email request to [combatofhero@ohayoogames.com] and include “California Request to Delete” in the subject line. Please specify in your request the personal information about you that you would like to have deleted,which can be all of your personal information as required by the CCPA.

We will ask that you provide certain information to verify your identity.The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. Once confirmed, we will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.

D. Right to Non-Discrimination for the Exercise of CCPA Rights

You may not be discriminated against because you exercise any of your rights under the CCPA in violation of California Civil Code § 1798.125.

E. Right to Information about Direct Marketing Disclosures

Once a calendar year, you may be entitled to obtain information about personal information that we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information, as well as the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. To request a notice, please submit your request to [combatofhero@ohayoogames.com].

F. Authorized Agent

You can designate an authorized agent to make a request under the CCPA on your behalf if:

• The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and

• You sign a written declaration that you authorize the authorized agent to act on your behalf.

If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please have the authorized agent take the following steps in addition to the steps described in subsections A, C and D above; and

• Provide any information we request in our response to your email to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps, and we will respond to any request from such authorized agent in accordance with the CCPA.