3. How We Use Your Information
We use your personal information, both individually and combined together, in the following ways.
A. To operate our business and to enhance and personalize your game experience, including to:
· Operate, analyze, improve, and develop our games and Services;
· Undertake research and analysis to develop and demonstrate our technology, and to better understand our players;
· Measure the health of our Services;
· Set up and maintain accounts for which you register;
· Identify, fix, and troubleshoot bugs or functionality errors;
· Adhere to your preferences and to deliver content;
· Help keep our Services safe and fair, resolve disputes, investigate and help curb fraud and illegal behavior, comply with the law, and to enforce our agreements and policies; and
· Other purposes you consent to, are notified of, or are otherwise disclosed to you when you provide personal information.
B. To provide you support, including to:
· Help identify and troubleshoot problems with your account or Services;
· Questionnaires;
· Communicate with you and respond to your specific requests or questions; and
· Manage and send you confirmations and important information about your account, Services, subscriptions, and warranties.
C. To personalize our communications with you, including to:
· Provide you with relevant content, recommendations or information; and
· Provide you with Service updates.
D. Retention
We retain the information we collect for as long as necessary to provide our Services, and we may retain that information beyond that period if necessary for legal, operational, or other legitimate reasons.
Where possible, we may also de-identify, anonymize, or aggregate the information we collect, or collect it in a way that does not directly identify you. We may use and share such de-identified information as necessary for our business purposes and as permitted by applicable law.
4. How We Share Your Information
A. Entrust
Some specific modules or functions in this business function are provided by external vendors. We will sign strict confidentiality agreements with companies, organizations, and individuals with whom we entrust personal information to handle it, requiring them to process personal information under our requirements, this policy, and any other relevant confidentiality and security measures.
B. Share
We take the protection of your personal information very seriously and we do not share your personal information with companies, organizations, and individuals other than our game providers, except in the following cases:
· Share with explicit consent: We will share your personal information with other parties with your express consent;
· Sharing in statutory circumstances: We may share your personal information under the provisions of laws and regulations, the resolution of litigation disputes, or as required by administrative and judicial authorities under the law; and
· Necessary sharing with affiliates: Your personal information may be shared between us and our affiliates as necessary to facilitate our consistent services based on a unified account system for you to manage, personalize recommendations, secure systems, and account security. We will only share the necessary personal information and will seek your authorization again if we share your sensitive personal information or if an affiliate changes the purpose for which personal information is used and processed.
C. Share with third-party partners
For external processing purposes, we may share your personal information with third-party partners (third-party service providers, contractors, agents, advertising partners, app developers, etc., for example, communications service providers who send an email or push notifications on our behalf) to enable them to process such information for us under our instructions, this policy, and other relevant confidentiality and security measures, and for the following purposes:
· to provide you with our services;
· to achieve the purposes set out in the section “How We Collect Your Information” and “How We Use Your information”; and
· to fulfill our obligations under the User Agreement or this policy and to exercise our rights.
If we share your information with third-party partners, we will use encryption, anonymization, etc. to keep your information safe.
D. Disclosure in the event of merger, sale, or other asset transfer
In the event of a reorganization, divestiture, merger, sale, or bankruptcy, we may transfer all information we collect to the relevant third party and will obtain your consent to do so if required by law or contract.
E. Public disclosure
We will only disclose your personal information if:
· Disclose the information you specify with your consent; and
· We may disclose your information under the type of information requested and the way it is disclosed, as required by law, regulation, mandatory administrative enforcement, or judicial requirements. Subject to laws and regulations, when we receive a request for such disclosure, we require the recipient to produce legal documents, such as a subpoena or investigation letter. We strongly believe that the information requested from us should be as transparent as possible to the extent permitted by law. All requests are carefully reviewed to ensure that they are legally based and limited to data that law enforcement has a legitimate right to obtain for specific investigative purposes.
F. Exceptions where prior authorization is required to share, transfer or disclose information
We collect, use, share, transfer, and disclose your information without prior authorization in the following circumstances:
· Directly related to national security and national defense security;
· Directly related to public safety, public health, major public interests;
· Directly related to judicial or administrative enforcement of criminal investigations, prosecutions, trials, and enforcement of sentences;
· To safeguard the life, property, and other important legitimate rights and interests of you or other individuals which it is difficult to obtain your consent;
· Information that you disclose to the public on your own;
· Collecting information from legitimate publicly disclosed information, such as legitimate news reports, government information disclosure, etc.; and
· Related to our compliance with our obligations under laws and regulations.
According to the law, the sharing, transfer, disclosure of personal information processed by de-identification, and to ensure that the data recipient cannot recover and re-identify the subject of the information, is not the external sharing, transfer and public disclosure of personal information, the preservation and processing of such data will not require your notice and your consent.
5. How We Protect Your Information
A. Personal information store
Unless the law specifies a different retention period, we will only keep your Data for the time strictly necessary. 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 relevant laws and regulations to notify you in advance, and delete or anonymize your personal information after terminating the service or operation, unless otherwise provided by laws, regulations or regulatory authorities.
The personal information you provide will be processed within the PRC, unless: i. The law has specific rules; ii. You authorize us clearly; iii. You request to obtain overseas services and other personal initiatives.
When our products or services stop operating, we will make announcements and notices in accordance with relevant laws and regulations to protect your legitimate rights and interests.
B. Personal information security
i. Technical measurements.
Zhonglian takes a range of appropriate security measures (include establishing reasonable rules & standards and applying security technology) designed to to help protect your information from unauthorized access, use, modification, destruction, loss, or disclosure both during transmission and in storage.
We also take encryption techniques to ensure that the personal information collected is protected. For example, we use SSL to encrypt and store your personal information.
During processing personal information, we takes multiple data masking technology to enhance the data security.
Furthermore, we use computer systems with multi-factor authentication and limited access in controlled facilities to protect personal information.
ii. Other security measurements
· We establish management system controlling. The minimum amount of your information will be accessed to the authorized staff. We will also apply strict limitation on the scope of people authorized to access the information. Meantime, we strictly require them to perform their confidentiality and security duties, if they fail, we will pursue their legal obligations or end the cooperative relationship with them. We control the data security by confidentiality agreement, monitor and audit mechanism. We also hold training program on security and privacy protection for our staff;
· To protect information security, If you think the personal information we hold about you is incorrect, the product will access, modify or delete the relevant information according to your request (unless it is necessary to retain these personal information for legal purposes;
· We will take reasonable measures to try to avoid collecting irrelevant personal information. We will only store your information for a necessary period for achieving the purpose of providing our services or as required by laws and regulations;
· However, the Internet by its nature is not a secure environment and the nature of security risks is constantly evolving, as are the technical and organizational industry standards relating to management of those risks. Please pay attention to protect your information security. Choosing a complex password you don’t use on any other system is important;
· We strive to protect information security. We shall remain liable if there is any damage to your legitimate rights caused by the damage of our physical, technical or administrative protect facilities;
· The computer system and the communication network or the devices when you using the game services are beyond our control, please you understand and pay attention to protect your personal information;
· Please note that the information you share voluntarily may be involved in your or others’ personal information, even or sensitive information. For example, the pictures you upload when you post your comments. Please consider more carefully whether to share the relevant information when using our services; and
· Please choosing a complex keyword to help us to ensure your account in safe security. We will endeavor to ensure the security of any information you send us. We shall remain liable if there is any damage to your legitimate rights caused by the damage of our physical, technical or administrative protect facilities.
C. Dealing with Security Incident
We have formulated multiple systems to deal with the potential risks (such as disclosure, damage, loss etc.). The systems develop the standard of classification and gradation of security incidents and design the processing flow. We have also set up the emergency team for security incidents. In addition, we occasionally organize internal training and emergency drill to ensure our staff handle the procedures of emergency response.
If any security incident occurs, we will initiate the emergency plan to prevent it from expanding. Upon the occurrence of such incident, we will inform you the basic situation of the security incident, the treatment measures and remedies we will take or have taken as well as our advices for you, via announcements, push notifications or emails, etc. If it is difficult to inform every user, we will issue the warning through public announcements. Meantime, we will also actively report the proceeding of the security incident in accordance with laws and rules.
Please understand the Internet by its nature is not a secure environment and the nature of security risks is constantly evolving, as are the technical and organizational industry standards relating to management of those risks. The complete security of any personal information cannot therefore be guaranteed, even if we have tried to strengthen security measures. Please note that there may be problems with the computer system and the communication network when you using the game services, because of the situation beyond our control.
Please keep properly your account, keyword and other identify elements. When you using the game service, we will verify your identify by your account, keyword and other identify elements. Once you leak the above information, you may suffer loss. If you think your account, keyword and / or other identify elements may be or have been leaked, please contact us immediately so that we could take measures in time to avoid or reduce losses.
6. Your Choices and Controls
We seek to provide you with meaningful choices about the personal information we collect. The specific choices available to you often vary depending on the exact nature of our relationship with you, such as our Services you use. Common examples include:
· You can request that we provide access to, or that we correct or delete, personal information we’ve collected from you. Please submit requests to access, update, or delete personal information associated with your account by reaching out to us as described in “Contact Us” below. Note that we may ask you for additional information to help us verify who you are before completing your request.
· You can change your email marketing preferences at any time, such as by using the opt-out mechanism provided in our marketing emails or contacting us with your request (see “Contact Us” below).
· You can change your browser or mobile device settings to block, manage, delete, or limit tracking technologies like cookies. In some cases, blocking or disabling cookies may cause our Services not to work as intended and some features may not be available.
· If you’re under the age of 18 and have a Zhonglian account, you can ask that we remove or anonymize certain content you’ve provided on our Services. Please direct requests to help delete or edit content on our Services to Zhonglian as described in “Contact Us” below.
Some parts of the world provide individuals with specific choices related to their personal information by right under local law.
7. Children’s Privacy
Minors are not allowed to create their own account without the parent’s or guardian’s consent. If you are a minor, it is recommended that you ask your parents or guardians to read this privacy policy carefully. You can only use our services or provide us with information with the consent of your parents or guardians.
In the case of we collecting minors’ personal information when their using our product or services under parent’s or guardian’s consent, we only use, share, transfer or disclosure this information when permitted by laws and regulations, the parent’s or guardian's explicit consent, or the protection of minors is necessary.
The personal information protection policy for minors under 14 years old is followed by the "Children's Personal Information Protection Policy". |
