Privacy Policy

Preface

1. How we collect and use your personal information
2. How we share, transfer, and publicly disclose your personal information
3. Your rights
4. Age restrictions
5. Possible changes to this Policy
6. How to contact us
7. List of third-party SDK partners

1. How We Collect and Use Your Personal Information

(1) To provide you with the products and services offered by Hong Kong Xuanhong Trading Co. Limited on its and/or its affiliated companies' game platforms

1. User Registration

    

   Information you provide to complete account creation, such as your mobile phone number, ID card number, and created username.
2. Collection of Operation Records and Necessary Device Information

    

   We may collect and use your operation records on Hong Kong Xuanhong Trading Co. Limited and some necessary device information (including Android ID, MEID, device serial number, network device hardware address (MAC), Open Anonymous Device Identifier (OAID) for mobile smart terminals, running processes, IMSI, and International Mobile Equipment Identity (IMEI)).

• IMEI, Android ID, MAC address, IMSI:
   
  a. Purpose of collection: To calculate and identify a single unique device and supplement the collection of device identifiers.
   
  b. Scope of collection: When you use the APP.
   
  c. Method of collection: Front-end SDK.
• Collection of installed APP list:
   
  a. Purpose of collection: To identify whether you have installed relevant payment applications and prompt you accordingly.
   
  b. Scope of collection: When you use the APP.
   
  c. Method of collection: Front-end SDK.
• Instructions for the use of BODY_SENSORS permission:
   
  a. Purpose of use: To collect the wearer’s heart rate per minute and feed back the user’s heart rate data in real time.
   
  b. Scope of use: Collection starts after you wear the device and successfully launch the APP.
   
  c. Method of use: Monitor heart rate through the wearable device while you operate and use the APP.

3. Payment and Settlement

    

   To facilitate your payment process, we will collect the installation list of your mobile phone to determine whether you have installed relevant payment software. In addition, to facilitate comprehensive judgment of your account and transaction risks, identity verification, and detection and prevention of security incidents when you pay for relevant orders, we may collect your personal virtual property information (limited to transaction records, virtual currency, virtual transactions, and virtual property information such as game redemption codes) during the transaction process.
4. Security Assurance

    

   We will use part of your frequently used personal device information for identity verification, security prevention, fraud detection, and archive backup. For example, unique device codes are used for security prevention and user identification; personal internet records are used for security prevention and fraud detection. When you use our customer service, we may save your communication/call records and content or the contact information you leave to contact you, help you solve problems, or record the solutions and results of relevant issues.
5. Product Development and Service Optimization

    

   For example, to fix system faults and optimize our services, we may need to record and analyze information generated when system faults occur.
6. Exceptions to Obtaining Authorization and Consent

    

   According to relevant laws and regulations, we do not need to obtain your authorization and consent to collect your information in the following circumstances:

    

   (1) Information related to national security and national defense security;

    

   (2) Information related to public security, public health, and major public interests;

    

   (3) Information related to criminal investigation, prosecution, trial, and execution of judgments;

    

   (4) Information necessary to protect the life, property, and other major legitimate rights and interests of the information subject or other individuals, but it is difficult to obtain your consent;

    

   (5) Information that you have publicly disclosed to the public on your own initiative;

    

   (6) Information collected from legally publicly disclosed information, such as legal news reports and government information disclosure channels;

    

   (7) Information necessary to sign a contract at your request;

    

   (8) Information necessary to maintain the safe and stable operation of the services of Guangzhou Juwan Culture Technology Co., Ltd., such as detecting and handling faults of Products or Services;

    

   (9) Information necessary for legal news reporting;

    

   (10) Information necessary for academic research institutions to conduct statistical or academic research for public interests, provided that when the results are provided to the public or described, the information contained in the results is de-identified;

    

   (11) Other circumstances stipulated by laws and regulations.
7. Authorization for Access Permissions

    

   You understand and agree that some individual services may require you to enable specific access permissions on your device (such as your location information, camera, photo album, microphone, address book, and/or calendar) to collect and use the information involved in these permissions. When you need to turn off this function, most mobile devices will support this requirement. For specific methods, please refer to or contact the service provider or manufacturer of your mobile device. Please note that enabling any permission means you authorize us to collect and use relevant information to provide you with corresponding services; once you turn off any permission, it means you revoke the authorization, and we will no longer continue to collect and use relevant information based on the corresponding permission, nor can we provide you with the services corresponding to this permission. However, your decision to turn off permissions will not affect the collection and use of information based on your previous authorization.
8. Reminder about Sensitive Personal Information

    

   Among the information you provide or we collect, some may be your sensitive personal information, such as bank account numbers, transaction and consumption records, virtual property information, system accounts, email addresses and their associated passwords, phone numbers, web browsing records, and location information. Please be cautious and pay attention to your sensitive personal information. You agree that we may process your sensitive personal information in accordance with the purposes and methods stated in this Policy.

(1) Scope of Application of the Privacy Policy

(2) Exceptions to the Application of This Privacy Policy

1. You use the "Share" button to share certain content to our Services, or you use third-party connection services to log in to our Services. These functions may collect your relevant information (including your log information) and may store cookies on your mobile device or computer to ensure the normal operation of the above functions;
2. We provide you with links through advertisements or other methods of our Services to allow you to access third-party services or websites, and the third party collects and uses your information. Such third-party social media or other services may be operated by third parties. Your use of the third party’s social media services or other services (including any personal information you provide to the third party) shall be subject to the third party’s terms of service and privacy policy (not this Privacy Policy), and you need to read its terms carefully. This Privacy Policy only applies to the information we collect and does not apply to any services provided by third parties or the information use rules of third parties. We shall not be liable for any use of the information provided by you by any third party.

2. How We Share, Transfer, and Publicly Disclose Your Personal Information

(1) Sharing

1. To provide you with our Services. We may share your information with partners and other third parties to realize the functions of our Products and/or Services and enable you to use the services you need normally, such as payment institutions providing payment services, merchants settled on the Hong Kong Xuanhong Trading Co. Limited platform, partners providing data services (including online advertising monitoring, data statistics, and data analysis), third-party logistics companies, and other service providers;
2. Necessary sharing with affiliated parties. To facilitate us to provide you with consistent services based on a unified account system, facilitate your unified management, and ensure system and account security, your personal information may be shared between us and our affiliated parties as necessary;
3. To achieve the purposes stated in Section 1 "How We Collect and Use Your Personal Information" of this Policy;
4. To perform our obligations and exercise our rights under this Policy or other agreements reached with you;
5. To share with third-party partners who entrust us with promotion, for the purpose of allowing the entrusting party to understand the coverage and effectiveness of the promotion. For example, we may inform the entrusting party of how many people have viewed their promotional information or purchased the entrusting party’s products after viewing the information, or provide them with statistical information that cannot identify individuals to help them understand their audience or customers;
6. Within the scope permitted by laws and regulations, to comply with laws, protect the interests, property, or safety of us, our affiliated parties or partners, you, other users of Guangzhou Juwan Culture Technology Co., Ltd., or the public from damage. For example, to prevent fraudulent and illegal activities and reduce credit risks, we may exchange information with other companies and organizations. However, this does not include disclosing information for profit purposes, such as selling, renting, sharing, or otherwise disclosing information in violation of the commitments made in this Policy;
7. At your legal request or with your authorization and consent;
8. To provide your information at the legal request of your guardian;
9. To provide information in accordance with the provisions of the individual service agreement (including electronic agreements signed online and corresponding platform rules) signed with you or other legal documents;
10. To provide information based on academic research;
11. To provide information based on social public interests in line with laws and regulations.

(2) Transfer

1. As our business continues to develop, we may conduct mergers, acquisitions, asset transfers, or similar transactions, and your information may be transferred as part of such transactions. We will require the new company or organization that holds your personal information to continue to be bound by this Policy; otherwise, we will require the company or organization to obtain your re-authorization and consent.
2. With your explicit consent, we will transfer your personal information to other parties.

(3) Disclosure

1. Disclose the information you specify in the disclosure method you clearly agree to according to your needs;
2. In cases where laws, regulations require, or mandatory administrative law enforcement or judicial requirements require us to provide your information, we may disclose your information in accordance with the required type and method of information disclosure. Within the scope of compliance with laws and regulations, when we receive a request for such information disclosure, we will require the recipient to provide corresponding legal documents, such as a subpoena or investigation letter. We firmly believe that the information required of us should be as transparent as possible within the scope permitted by law. We carefully review all requests to ensure that they have a legal basis and are limited to the data that law enforcement agencies have the legal right to obtain for specific investigation purposes.

(4) Exceptions to Obtaining Prior Authorization and Consent for Sharing, Transfer, and Disclosure of Information

1. Information related to national security and national defense security;
2. Information related to public security, public health, and major public interests;
3. Information related to criminal investigation, prosecution, trial, judicial or administrative law enforcement, and execution of judgments;
4. Information necessary to protect the life, property, and other major legitimate rights and interests of you or other individuals, but it is difficult to obtain the individual’s consent;
5. Information that you have publicly disclosed to the public on your own initiative;
6. Information collected from legally publicly disclosed information, such as legal news reports and government information disclosure channels.

3. Your Rights

(1) Access to Your Personal Information

(2) Control of Your Personal Information

(3) Deletion of Your Personal Information

(4) Cancellation of Your Personal Account

(5) Response to Your Above Requests

1. Requests directly related to national security and national defense security;
2. Requests directly related to public security, public health, and major public interests;
3. Requests directly related to criminal investigation, prosecution, trial, and execution of judgments;
4. Requests for which there is sufficient evidence to show that you have subjective malice or abuse of rights;
5. Requests whose response will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;
6. Requests involving trade secrets;
7. Other requests for which we have reasonable grounds to refuse.

4. Age Restrictions

5. Possible Changes to This Policy

6. How to Contact Us

7. List of Third-Party SDK Partners