UNIT5 Privacy Policy

UNIT5 PRIVACY POLICY

Welcome to choose the game provided by UNIT5 Inc. (hereinafter referred to as “we” or “UNIT5”). Through the UNIT5 PRIVACY POLICY, we will explain to you how we collect, use, store and share personal information when you use our game, as well as the rights you enjoy. This privacy policy is an integral part of the UNIT5 SERVICE AGREEMENGT. The main points are as follows:

in order to provide you with game entertainment and related services such as player interaction and consumption, we need to collect your game history, device information, login log and other information.

address book, exact geographic location, camera, microphone, album permissions are not enabled by default, and will only be used for specific functions or services after your express authorization. You can also revoke authorization. In particular, it is important to note that, even if you authorize us to obtain these sensitive rights, we will not collect your information when the relevant functions or services are not required.

you may manage your personal information and related authorization as described in this privacy policy.

we adopt multi-directional security measures to ensure the protection of your personal information at a reasonable level of security.

You can read the full version of “UNIT5 PRIVACY POLICY” to understand the corresponding relationship between the type of personal information and the purpose of more detailed personal information processing rules.

The following will help you understand in detail how we collect, use, store, transmit, share and protect personal information from the following aspects: Help you understand how to query, access, delete, correct, and revoke authorized personal information.

1. How do we collect and use personal information

2. How do we use cookies or similar technologies

3. How can we share, transfer and publicly disclose personal information

4. How do we store personal information

5. How can we protect personal information

6. How do we manage your personal information

7. Terms of use for minors

8. Amendment and notification of privacy policy

9. How to contact us

1. How do we collect and use personal information

In the course of your use of our game services, our game will collect the information that you provide voluntarily or as a result of your use of the services in the following ways to provide you, optimize our services and protect the security of your account:

1.1 When you register or use our game service, you can create an account through your mobile phone number, and you can improve the relevant network identity information (avatar, nickname, password), which is collected to help you complete the registration. You can also fill in gender, date of birth, region and personal introduction according to your own needs to improve your information. You may also use a third-party account to log in and use it. You will authorize us to obtain your public information (avatar, nickname and other information authorized by you) registered on the third-party platform for binding with our game account so that you can directly log in and use the product and related services.

We will collect your network identity information and personal frequently used device information to mark you as a user of our game.

1.2 In order to meet the requirements of relevant laws, regulations, policies and relevant competent authorities, our game users shall conduct real-name authentication to continue to use and enjoy our game. We will collect your real-name identity information with your consent or upon your initiative. This information is sensitive information. Refusing to provide real-name identity information may cause you to be unable to log in our game or be subject to corresponding restrictions in the process of using our game.

1.3 To protect your normal use our service, maintain the normal operation of the game basis function, optimize the game product performance, improve your game experience and ensure the security of your account, we will collect your device ID, name of equipment, equipment type and version, system version, IP address, MAC address, the application ID information, network type, etc.

1.4 When you use our game service, we will collect your game log information, such as a login journal and articles, games, game information, friendships, etc, so that you can view your game on the client history, at the same time for game operation statistics and analysis, customer complaint handling and other games security analysis, and to enhance your gaming experience, we can put the information synchronization to subsequent version of the game or you are using other products we offer.

1.5 If you use Xiaomi, Meizu, Huawei and other brand mobile phone, our game access the handset vendors Push SDK need to collect phone unique identification information (such as IMEI), and could collect your phone models, system type, system version, equipment parameters, such as screen size are used to implement our game products and activities, such as information Push, details please refer to the SDK operator’s privacy policy or the relevant statement.

1.6 When you use the consumption function of our game products, we will collect your recharge record, consumption record and other information, so that you can query your transaction record, and protect the security of your virtual goods to the greatest extent. Recharge records, consumption records belong to sensitive information, the collection of the above information for the realization of our game product consumption function is necessary, otherwise will not be able to complete the transaction.

1.7 In order to ensure the security of your game accounts, build a fair , health and safety game environment, we will collect your game identification information, hardware and operating system information, processes, and game crash logs, to combat the acts that destroy the fair game environment or the interference and destruction of normal game service (e.g., used to detect pirated, scan plugin, prevent cheating, etc.).

1.8 When you interact with other players in the game through text, pictures, voice, video and other ways, we may collect and save the above information you send to filter pornography, violence, politics, abuse, malicious advertising and other inappropriate content, in order to purify the game environment, maintain a healthy online environment.

1.9 We have enabled the reminder function of moderate games. If you use the wearable device, we will collect your information after obtaining your consent, so as to issue a system reminder when you play excessively.

1.10 In accordance with relevant laws, regulations and national standards, we may collect and use your relevant personal information without your authorization in the following situations:

1) directly related to national security, national defense security and other national interests; Directly related to major public interests such as public safety, public health and public knowledge;

2) directly related to criminal investigation, prosecution, trial and execution of judgment;

3) for the purpose of safeguarding your or other personal life, property, reputation and other major legal rights and interests, but it is difficult to get the consent of the person;

4) the personal information collected is disclosed to the public by yourself;

5) collecting personal information from legally disclosed information, such as legal news reports, government information disclosure and other channels;

6) it is necessary to sign and perform the contract according to your requirements;

7) necessary for maintaining the safe and stable operation of the products or services provided, such as discovering and disposing of faults of the products or services;

8) necessary for carrying out legitimate news reports;

9) it is necessary to carry out statistics or academic research out of the public interest, and when the results of academic research or description are provided to the public, the personal information contained in the results is de-identified;

10) other circumstances stipulated by laws and regulations.

1.11 Please understand, we provide you with the functions and services are constantly updated and development of the, if a certain function or service is not in the foregoing statement and collected your information, we will have a page hint, interactive process, website announcement to explain to you the content of the information collection, the scope and purpose, with the consent of you.

At present, we will not take the initiative to obtain your personal information from any third party other than us, except to collect game research information from third-party research organizations to help us improve our game products and provide personalized services. As for business development in the future from a third party outside of our indirect access to your personal information, we will clearly show you the source, type and scope of your personal information before we obtain it. For example, the personal information processing activities required for our game business are beyond the scope of your original consent to provide personal information to third parties other than us, we will obtain your explicit consent before processing your personal information. In addition, we will strictly comply with relevant laws and regulations and require the third party to ensure the legality of the information provided.

2. How do we use cookies or similar technologies

2.1 Cookie or similar technologies are commonly used on the Internet. When you experience, log in and use our game, we may use relevant technologies to send one or more cookies or anonymous identifiers to your device to collect and store information when you access and use the game. We undertake not to use cookies for any purpose other than that described in this privacy policy. We use cookies or similar technologies mainly for the following functions or services:

1) remember who you are. For example, cookies or similar technologies can help us identify you as a registered user or save information about your preferences or other information provided to us by you.

2) analyze your use of our game. We can use cookies or similar technologies to find out what activities you use our games for, or which games are the most popular;

3) advertising optimization. Cookies or similar technologies help us provide you with ads that are relevant to you based on your information, rather than making general advertising.

2.2 When we use cookies or similar technologies for the above purposes, we may aggregate non-personally identifiable information collected through cookies or similar technologies and provide it to advertisers and other partners for the purpose of analyzing how you and other users use our game and use it for advertising services.

3. How do we share, transfer and publicly disclose personal information

3.1 The Shared

3.1.1 Sharing Principle

1) Principle of authorization and consent: sharing your personal information with our affiliates and third parties requires your authorization and consent, unless the shared personal information is de-identified and processed, and the shared third party cannot re-identify the natural person subject of such information. If our affiliates or the third parties use the information for purposes beyond the scope of the original authorized consent, they need to obtain your consent again.

2) The principle of legality and minimum necessity: the data shared with affiliates and third parties must have legitimate and proper purposes, and the shared data is limited to the extent necessary to achieve the purpose.

3) Principle of security prudence: we will prudently evaluate the purpose of using the shared information for the data of affiliates and third parties, comprehensively evaluate the security capability of these partners, and ask them to comply with the cooperation legal agreement. We will strictly monitor the security of the software tool development kit (SDK) and application program interface (API) that the partner obtains information, so as to protect the data security.

3.1.2 Realize Shared Information of Functions or Services

1) When you use our games with functions provided by our affiliates, third parties, or when software service providers, smart device providers, system service providers and us jointly provide services to you, we will share the de-identified personal information with these affiliates and third parties, make comprehensive statistics and analyze the characteristics and preferences of the algorithm to form the indirect crowd portrait to recommend, display or push information that may be of interest to you, or push specific features, services or commercials ads that are more suitable for you.

2) location service: when you use location-related services, we will share the GPS information with the location service provider so that the location results can be returned to you. GPS information is sensitive personal information, refused to provide, will only affect the geographical location service function, but does not affect the normal use of other functions.

3) Payment function: the payment function is provided to you by the third-party payment institution cooperating with us. The third-party payment agencies may need to collect your name, bank card type and card number, expiry date and mobile phone number. Bank card number, expiry date and mobile phone number are personal sensitive information, which is necessary for payment function. Refusal to provide this information will cause you to be unable to use this function, but will not affect the normal use of other functions.

3.1.3 Realize Ad-related Sharing Information

1) Advertising push: we may share information with partners who have commissioned us for promotion and advertising, but we will not share information (name, ID number) that used to identify you personally, we will only provide these partners with no personal identification of you Identity indirect portrait tags and de-identified or anonymized information to help them improve the effective reach of ads without identifying you personally.

2) Advertising statistics: we may share analytical de-identified statistics with service providers, suppliers and other partners of the business, which are difficult to correlate with your identity information, and which will help us analyze and measure the effectiveness of advertising and related services.

3) You may refuse us to push programmed advertisements to you without affecting your use of other functions or services of our game.

3.1.4 Realize Shared Information of Security and Analysis Statistics

1) Ensure the security of use: we attach great importance to the security of accounts and services. In order to ensure the security of your and other users’ accounts and property and protect you and our legitimate rights and interests from illegal infringement, we may share necessary equipment, accounts and log information with our affiliates or service providers.

2) Analysis of product usage: in order to analyze the usage of our game and improve the user experience, we may share the statistical data of the game usage (crash, flashback) with affiliates or third parties, which is difficult to identify your personal identity in combination with other information.

3.1.5 Help You to Participate in Marketing Activities

When you choose to participate in relevant marketing activities organized by us and our affiliates or third parties, you may be required to provide your name, mailing address, contact information and bank account information. This information is sensitive personal information, refusal to provide may affect your participation in relevant activities, but will not affect other functions. Only with your consent will we share this information with affiliates or third parties to ensure that you can experience consistent services in joint activities or entrust third parties to cash rewards to you in a timely manner.

3.2 The Transfer

1) We will not transfer your personal information to any other third party without your express consent.

2) With the continuous development of our business, it is possible for us to conduct merger, acquisition and asset transfer, and your personal information may be transferred accordingly. In the event of any of the foregoing changes, we will require the transferee to protect your personal information in accordance with laws and regulations and security standards not less than those set forth in this privacy policy. Otherwise, we will require the transferee to obtain your authorization consent again.

3.3 Disclosure

1) We will not publicly disclose your information unless we comply with national laws and regulations or obtain your consent. We publicly disclose your personal information using security measures that meet industry standards.

2) We will disclose the information of relevant accounts when we announce the punishment of illegal accounts and fraudulent behaviors.

3) After you authorize the game or small program, you and your friends’ avatars and nicknames will be displayed in the ranking and related functions.

3.4 Personal Information Exempt from Obtaining Consent to Share, Transfer, and Public Disclosure

Please understand that under the following circumstances, in accordance with laws, regulations and national standards, we do not need your authorization to share, transfer or publicly disclose your personal information:

1) directly related to national security and national defense security;

2) those directly related to public safety, public health or major public interests;

3) directly related to criminal investigation, prosecution, trial and execution of judgment;

4) for the purpose of safeguarding your or other personal life, property and other major legal rights and interests, but it is difficult to get the consent of the person;

5) personal information that you disclose to the public by yourself;

6) collecting personal information from legally disclosed information, such as legal news reports, government information disclosure and other channels.

4. How do we store personal information

4.1 we will store your personal information only for the period necessary for the purposes stated in this privacy policy and for the shortest period required by laws and regulations. If we terminate the service or operation, we will promptly stop the activities of continuing to collect your personal information, at the same time, we will comply with the relevant laws and regulations to inform you in advance, and after the termination of the service or operation, your personal information will be deleted or anonymized, except as otherwise stipulated by laws and regulations or regulatory authorities.

Personal information collected and generated in our operations in the People’s Republic of China is stored in the People’s Republic of China, except:

1) laws and regulations have clear provisions;

2) obtain your authorization agreement;

3) you use our game to cross the border, we need to provide your personal information to the overseas.

4) for the above situations, we will ensure that your personal information is adequately protected in accordance with this privacy policy and national laws and regulations.

5. How do we protect our personal information

We take your information security very seriously. We have set up a special security team and take all reasonable and feasible measures to protect your personal information:

5.1 technical measures for data security

1) We will adopt security measures in line with industry standards, including establishing reasonable regulations and security technologies to prevent unauthorized access, use and modification of your personal information, and avoid data damage or loss.

2) Our service adopts a variety of encryption technology, which encrypts and saves your personal information and isolates it through the isolation technology.

3) In the use of personal information, such as information display and information association calculation, we will adopt a variety of data desensitization technologies to enhance the security of information in use.

4) We will also adopt strict data access control and multiple authentication technologies to protect personal information and prevent data from being used illegally.

5.2 Other Security Measures We Take to Protect Personal Information

1) We manage and regulate the storage and use of personal information by establishing a data classification and grading system, data security management specifications, and data security development specifications.

2) We fully control the security of data through the confidentiality agreement, monitoring and audit mechanism of information contacts. We will also conduct security and privacy protection training courses to enhance staff’s awareness of security and the importance of protecting information.

5.3 We only allow employees and partners who need to know the information to access your personal information, and we set strict access control and monitoring mechanism for this purpose. We also require all persons who may have access to your personal information to comply with the corresponding confidentiality obligations. Failure to meet these obligations may result in legal action or suspension of cooperation with us.

5.4 We will take all reasonably practicable steps to ensure that irrelevant personal information is not collected.

5.5 The Internet is not an absolutely secure environment, and the way of communication with other users such as email, instant messaging, social software or other service software cannot be determined whether it is fully encrypted. We recommend that you use complex passwords when using such tools, and pay attention to protect your information security.

5.6 The Internet environment is not 100% secure. We will do our best to ensure or guarantee the security of your personal information sent to us. If our physical, technical, or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of personal information, resulting in damage to your legitimate rights and interests, we will assume the corresponding legal responsibility.

5.7 Handling of Security Incidents

1) when communicating with third parties or purchasing goods and services through our game, you will inevitably disclose your information, such as contact information, bank account or email address, to the counterparty or potential counterparty. Please protect your information and provide it to others only if necessary.

2) in order to deal with the possible risks of personal information disclosure, damage and loss, we have developed a number of systems to clarify the classification and grading standards of security incidents and security vulnerabilities and the corresponding processing procedures. We also set up a special emergency response team for security incidents. According to the requirements of the safety incident handling standards, we started the safety plan for different security incidents, carried out stop-loss, analysis, positioning, formulation of remedial measures, and cooperated with relevant departments to trace and strike.

3) after the unfortunate information security incident, we will timely inform you of the basic information and possible impact of the security incident, the measures we have taken or will take to deal with it, the suggestions that you can independently prevent and reduce the risk, the remedial measures for you, etc., in accordance with the requirements of laws and regulations. At the same time, we will timely inform you of the relevant information of the event by email, letter, phone, push notification, etc. If it is difficult to inform the information subject one by one, we will take a reasonable and effective way to issue the announcement. At the same time, we will also according to the requirements of the regulatory authorities, take the initiative to report the handling of information security incidents.

4) please understand that, due to the limitations of technology and risk prevention, even though we have tried our best to strengthen the security measures, we cannot always guarantee the security of the information. You need to understand that your use of our game may cause problems outside of our control.

5) please take good care of your account number, password and other identity elements. When you use our game, we will identify you by your account number, password and other identity factors. Once you leak the foregoing information, you may suffer losses and may work against you. If you find that your account, password and/or other identity elements may or have been leaked, please contact us immediately so that we can take timely measures to avoid or reduce the loss.

6. How do we manage your personal information

6.1 Access, Update, and Delete

1) We encourage you to update and modify your personal information to make it more accurate and effective. You can access your personal information through our game, and according to the management of the corresponding information to complete or ask us to modify, supplement and delete. We will take appropriate technical measures or provide contact channels for submitting applications to ensure that you can access, update and correct your personal information as much as possible.

2) When accessing, updating, correcting, and deleting the foregoing information, we may require you to authenticate to ensure the security of the information. We also explain the selection mechanism provided to you in section 2 “how we use cookies or similar technologies” of this privacy policy for your information collected through cookies or similar technologies. If you want to query, modify or delete some of your information, please follow the specific instructions in our game.

3) Except as otherwise provided by laws and regulations, when you correct or delete your personal information or apply for account cancellation, we may not immediately correct or delete the corresponding information from the backup system, but will correct or delete such information when the backup updates.

7. Terms of Use For Minors

7.1 If you are a minor under the age of 18, you should read and agree to this privacy policy under the supervision and guidance of your parents or other guardians before using our games and related services.

7.2 We protect the personal information of minors in accordance with relevant national laws and regulations. We will only collect, use, store, share, transfer or disclose the personal information of minors when the law permits, parents or other guardians expressly agree or it is necessary to protect the minors. If we find that personal information about minors has been collected without prior and verifiable parental consent, we will seek to remove the information as soon as possible.

7.3 If you are the guardian of a minor, if you have any questions about the personal information of the minor under your supervision, please contact us through the contact information published in this privacy policy.

8. Amendment and notification of privacy policy

8.1 In order to provide better service to you, our game and related services will be updated and changed from time to time, we will timely to revise this privacy policy, the revision of this part of the privacy policy and is equal to the effectiveness of this privacy policy, without the clear permission of you, we will not reduce your rights under this privacy policy that is currently in effect.

8.2 After this privacy policy is updated, if our game version is updated and the privacy policy is updated, we will remind you of the updated content in an appropriate way before the updated terms take effect, so that you can timely understand the latest version of this privacy policy. If you continue to use our services, you agree to accept and be bound by this revised privacy policy.

9. How to Contact Us

9.1 If you have any doubts or suggestions about this privacy policy or you think your personal information is not protected by this privacy policy during the use of our game, you can contact us through the following ways. We will give you feedback after checking and verifying your user identity.

Email address:

UNIT5 Inc.

20-AUG-20