LUXSOFT Privacy Protection Guidelines

Summary

Thank you for your choice of Luxsoft game provided by LUXSOFT CO., LTD (hereafter referred to as “we” or “us”; in the Guidelines, “LUXSOFT” refers to LUXSOFT Game and its service provider – [LUXSOFT CO., LTD]; the contact information regarding personal data protection is: [Name: LUXSOFT; Email: [email protected]]). In addition to “LUXSOFT CO., LTD Privacy Policy” and “LUXSOFT Game License and Service Agreement”, through the LUXSOFT Game Privacy Protection Guidelines (“Guidelines”), we will further elaborate on how we collect, use, store and share your personal information when you are playing LUXSOFT Game, as well as the relevant rights you are entitled to. The Guidelines are part of the “LUXSOFT Game License and Service Agreement”. The highlights are as follows:

In order to provide you with game entertainment and to support the related player interaction, consumption and other services, we need to collect information such as your game history, device information, login data and others. You hereby consent to provide the following specific information for the purpose:

• your age or birthday;
• your first and last names;
• your e-mail address;
• a password;
• game username(s);
• details about the games you play;
• approximate location information;
• your game history;
• your device’s operating system and version;
• your mobile device’s identifiers, like your MAC Address, Identifier for Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI);
• your login data;
• other information that helps us make sure it’s you accessing your account, information necessary for us to provide the support you request, or information you provide to help us improve our Service (such as answers to an online surveyor a feedback form).

In order to better protect both the physical and the mental health of minors and facilitate a healthy access to the internet by minors, we may implement more stringent anti-addiction measures in addition to the relevant regulations on anti-addiction policies of online games. At the same time, we have been constantly developing and testing various new technologies to better protect the minors.

You can manage your personal information and the relevant authorizations according to the provisions of the Guidelines.

We adopt a wide range of security measures to ensure that your personal information is protected under a reasonably safe manner.

By reading the full version of “LUXSOFT Privacy Protection Guidelines Studio Game Privacy Protection Guidelines”, you may learn more about the processing rules of personal information such as the correspondence between the types and the uses of personal information.

1. Information We Collect

While you are using LUXSOFT Game Service, LUXSOFT Game will collect through the following ways the information that you voluntarily provide when using the service or the information generated by your use of the service, in order provide and optimize our services to you and to ensure your account in safe security:

1.1 When you register or use LUXSOFT Game Service, we will collect the information of your network identity and the personal device that you frequently use, in order to mark you as our users. If you use a Facebook and (or) other account recognized by us (hereafter referred to as “Third-Party Account”) as the game account to login to LUXSOFT Game, we will collect your unique ID, avatar and user name of Facebook and Third-Party Account to store your login information so that you can login on different devices.

If you use a Facebook and (or) Third-Party Account as the game account to login to LUXSOFT Games, in order to provide you with better services and improve your game experiences, we will collect and you hereby consent to provide the following information for the purpose:

• your first and last name;
• your profile picture or its URL;
• your user ID number (like your Facebook ID number), which may be linked to other information like your name and profile photo, and your friends’ identifiers;
• the user ID number and other information of your friends, like their names and profile photos;
• the login e-mail you provided to the third-party account;
• nicknames;
• your log-in status, battle information/status, achievement information related in LUXSOFT Privacy Protection Guidelines Studio Game;
• your physical location and that of the devices you use to access our Service;
• your gender;
• your birthday and/or age range;
• information about your activities on or through the third-party account;
• other information you have shared on the third-party account;
• If you access our Service from a third-party account or connect our Service to a third-party account, you should also read that third-party account’s Terms of Service and Privacy Notice. If you are unclear about what information a third-party application is sharing with us, please go to the third-party application to find out more about their privacy practices.

and Luxsoft may present it to you or other users or your friends. Depending on the specific situations of a game product, we may provide you with the relevant permissions enabling you to adjust the settings as to whether or not to display Such Information.

1.2 In order to comply with the relevant laws, regulations and policies and the requirements of competent authorities, LUXSOFT Game users may need to complete the real-name verification before using and enjoying LUXSOFT Game. For the purpose, you hereby consent that we may collect your real-name ID and other information, including:

• your first and last names;
• your age or birthday;
• ID number;
• photos.

Your refusal to provide your real-name ID information may result in a failure to log into LUXSOFT Privacy Protection Guidelines Studio Game or the corresponding restrictions to your use of LUXSOFT Privacy Protection Guidelines Studio Game.

1.3 In order to ensure your use of our service under normal conditions, to maintain the normal operation of basic functions of the game, to optimize the performance of the game product, to improve your gaming experience and protect the security of your game account, we will collect the information including:

• your device ID as well as the name;
• type and version of your device;
• the version of the system;
• IP address;
• MAC address;
• application ID;
• network type.

1.4 When you use LUXSOFT Game Service, we will collect your game log information, including:

• log-in data;
• item logs;
• game battle information;
• friends relation records.

so that you can view the records of your game history on your terminal and we can use the above information for analyzing game operation statistics, handling customer service complaints and other game security analyses. Also, to improve the game experience for you, we may synchronize the afore-mentioned information with the later versions of the game or with other products you are using that are provided by us.

1.5 When you use the consumption function of LUXSOFT Game products, we will collect your recharge history, purchase records and other information, so that you can check your transaction records, and at the same time to protect your virtual items to the greatest extent possible. Recharge history and purchase records are sensitive information. It is necessary to collect the above information in order to enable the consumption function of LUXSOFT Game product s, otherwise the transaction could not be completed.

1.6 To protect the security of your game account and to create a fair, healthy and safe gaming environment, we will collect information such as your game identity information, hardware and operating system information, processes and breakdown records and other information, for the purposes of fighting against the behaviors that destroy the fair gaming environment or that interfere and disrupt normal game services (such as detecting counterfeits, scanning plug-ins, preventing cheating, etc.).

1.7 According to reports and targeting of keywords involving pornography, violence, political and abusive content, terrorism, malicious advertising, and other legally prohibited content, we may store temporarily and filter the information when you interact with other players through text, images, voice, video and other means in the game, for the purpose of purifying the game environment and maintain a healthy Internet environment.

1.8 If you wish to interact with other game players through voice and video, and to participate in live broadcasting, upon your authorization, LUXSOFT Game will access your microphone and camera to accommodate you with voice chatting, interaction during live broadcasting and other functions. But we will never violate the privacy of your voice and video. You can also revoke the authorization of the microphone and camera at any time.

1.9 If you wish to interact with nearby game players, upon your authorization we will collect the information of your geographic location to search for nearby game players, so that you can match with them or team up with them, etc. Geographic location information is a type of sensitive information. Your refusal to provide this information will only result in your incapability to interact with nearby game players, and will not affect your normal use of other functions provided by LUXSOFT Privacy Protection GuidelinesStudio Games. You can also withdraw your authorization for the geographic location information at any time.

1.10 We have enabled a reminder function for moderate time length of playing games. If you use a wearable device, we will, with your consent, collect information such as your heartbeat when you are playing the game, so as to issue a system reminder when you have spent excessive time on the game.

1.11 We may analyze your game data to understand your preference, and we may share your such preference and relevant necessary information to other products and services within the LUXSOFT Group, in order to better show you what you may be of interest within LUXSOFT Games and other products and services within LUXSOFT Group.

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

（1）where it is directly related to national interests such as national security and national defense security; and directly related to major public interests such as public security, public health, and public knowledge;

（2）where it is directly related to criminal investigations, prosecutions, trials and enforcement of judgments, etc.;

（3）where it is for protecting the fundamental legal rights of you or other individuals, such as life, property and reputation, but it is also difficult to obtain consent from you or the related individual;

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

（5）where the personal information is collected through legitimate and public channels, such as legitimate news reports, government information disclosure, etc.;

（6）where it is necessary to sign and perform the contract according to your requests;

（7）where it is necessary to maintain a safe and stable operation of the products or services provided by us, such as the discovering and treating of the malfunctions of such product or service. But we will continue to protect the security of your personal information and ensure that it will not be used for other purposes;

（8）where it is necessary to conduct statistical or academic research for public interests; and when externally providing the results of academic research or description, applying de-identification method to the personal information contained in the results. In addition, it will not be used for any other purposes and activities; or

（9）other circumstances as stipulated by the laws and regulations.

1.13 Please understand that the functions and services we provide to you are constantly updated and developed. If a certain function or service is not included in the above descriptions herein but your information is collected there, we will separately explain to you the content, scope and purpose of such collection through prompts, interaction process, website announcement and other ways in order to obtain your consent.

At present, aside from collecting game research information from third-party research organizations to help us upgrade our game products and provide personalized services, and aside from your use of Third-Party Account to login in LUXSOFT Games prescribed in Section 1.1 herein, we do not take the initiative to obtain your personal information from any third party outside of LUXSOFT Group. In the future, if LUXSOFT Privacy Protection Guidelines Studio needs to obtain your personal information indirectly from a third party outside of LUXSOFT Privacy Protection GuidelinesStudio Group and process such personal information, we will strictly comply with the relevant laws and regulations, and we will require the said third party to obtain your consent and to guarantee the legality of the information it provides.

2. Storage of Information

2.1 Manner and Term of Storing Information

We will store your information in a secure manner, including storing it locally (such as data caching via APP), using database and server logs.

In general, 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.

2.2 Territory of Storing Information

Personal information collected would be stored within [Amazon servers located in Singapore] pursuant to the laws and regulations.

2.3 Termination Notice of the Product or Service

In the event the operation of a product or service is terminated, we will make an announcement in accordance with the relevant laws and regulations, and will protect your legitimate rights and interests.

3. Information Security

3.1 Security Measurements

We strive to protect information security of the users to avoid any information leakage, loss, improper usage, unauthorized access and disclosure, etc. We employ multiple security measures, including technical protection solutions, management system controlling, security system guarantee and others to make sure the user’s personal information is protected in a reasonably secured manner.

We adopt leading technical protection measures in the industry. The measures we take include but not limited to firewall, encryption (such as SSL), de-identification or anonymization, access controlling, etc. Further, we will constantly strengthen the security capacity of the software installed in your devices. For example, we will implement part of the encryption work in your devices locally to consolidate a secured transmission; we will collect the information of the applications installed in your devices and its processing information during operation to avoid malicious programs such as virus and Trojan.

We have established special management regulations, procedures and organizations to safeguard the security of the personal information we collected. For example, we will apply strict limitation on the scope of people authorized to access the information, requiring them to obey confidential obligations and conducting audits. Those who violates such obligations will be punished in accordance with the regulations. We will also review the management regulations, procedures and organizations to prevent unauthorized access, use or disclosure of the users’ information by those people that are without authorization.

We suggest you give full attention to the protection of personal information when using the products and services, and we will also provide multiple security methods to assist you to protect the security of your personal information.

3.2 Dealing with Security Incident

If any security incident such as the leak of personal information occurs, we will initiate the emergency plan to prevent it from expanding, and ensure to inform your of what we know within 72 hours upon knowledge, or when there is reasonable belief, that a personal data breach has occurred. 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 or other reasonable means.

4. How We Use the Information

We will strictly obey the laws, regulations and the agreement with our users, and we will make use of the collected information in accordance with the Guidelines, “LUXSOFT Game License and Service Agreement” and “LUXSOFT Privacy Policy” so as to provide you with better service.

4.1 Rules for Using Information

We will use the collected information in accordance with the following rules:

（1）based on the information we collected, we will provide you with multiple functions and services, including the general gaming functions, interactive functions between players, live broadcasting functions as well as consumption functions;

（2）we will analyze the operation of our products based on the frequency and situations of your use o LUXSOFT Game, malfunction information and performance information, etc., so as to ensure a safe provision of our services, and to optimize our products and improve the quality of our services. We will not combine your personal information with the information we stored in the analysis software.

4.2 The Way to Seek Consent after Informing the Purpose of Changing

We will use the collected information within the scope included in the Guidelines. If we use your personal information beyond the scope and a direct or reasonably relevant scope, of purpose we claimed when collecting the information we will again inform you and seek your express consent before using your personal information.

5. Provide to Other Entities

Currently, except for the conditions provided in the Guidelines and “LUXSOFT Game License and Service Agreement”, we will not actively share, provide or transfer your personal information to any other third party outside of LUXSOFT Group. In the event we share, provide or transfer your personal information or you need us to share, provide or transfer your personal information to a third party outside of LUXSOFT Group, we will directly ask for your prior express approval or confirm that the third party has obtained your express approval.

Notwithstanding the above paragraph, we might provide your log-in information and relevant information (such as log-in data, item logs, etc.) generated in the game to the overseas developer entities or relevant third parties for the purpose of conducting security analysis, and helping to improve game services and further optimize users’ experience in game. In addition, we will try to contact the parent or legal guardian after a person that is suspected to be a minor has made consumption, and inform the parent or legal guardian of the consumption records and other information to remind the parent or legal guardian to confirm and handle this issue.

Except as otherwise provided in the Guidelines, “LUXSOFT Game License and Service Agreement” and “LUXSOFT Privacy Policy”, we will not publicly disclose the information we collect. If a disclosure is necessary, we will inform you about the purpose of the disclosure, the type of the disclosed information and the sensitive information that may be involved, and we will also obtain your express approval.

As our business continuously develops, we are likely to conduct transactions such as mergers, acquisitions and asset transfers, etc. We will inform you of the information and continue or require the new controllers to continue to protect your personal information in accordance with the laws and regulations and the standards no lower than the requirements of the Guidelines.

In addition, in accordance with relevant laws, regulations and standards, we may share, transfer, or publicly disclose personal information without your prior authorization and approval in the following situations:

（1）where it is directly related to the national security and national defense security;

（2）where it is directly related to public security, public health or major public interests;

（3）where it is directly related to criminal investigation, prosecution, trial and enforcement of judgments;

（4）where it is for protecting the material legal rights and interests such as life, property and others of the personal information holder or other individuals but it is also difficult to obtain consent from the involved person;

（5）where the personal information holder publicly discloses personal information by himself/herself; or

（6）where the personal information is collected through legitimate and publicly channels, such as legitimate news reports, government information disclosure, etc.

6. Your Rights

During the time you use LUXSOFT Game Service, we may provide you with the corresponding operation settings based on the specific situation of the game products, so that you can search, delete, change or withdraw your relevant personal information. You can refer to the specific instructions of the corresponding game products to guide your operation. In addition, we have set up the channel to receive complaints and reports, and your opinion will be dealt with in a timely manner.

7. Amendments

We may amend the Guidelines as appropriate. When the provisions of the Guidelines have been amended, we will inform you of the amended Guidelines in a proper way at the time of version update. Please read the amended Guidelines or the content carefully. Your continuous use of LUXSOFT Game would be deemed as your approval for us to collect, deal with or use your personal information in accordance with the updated Guidelines.

8. Protection of Minors

We attach great importance to the protection of minors’ personal information, and we will keep exploring new ways to protect minors’ personal information.

We will protect the legitimate rights and interests of minors by initiating anti-addiction system in accordance with relevant regulations on online game anti-addiction policies. We will make a judgment on whether the real name information of an account belongs to a minor via the identification result of information such as real-name identity, based on which we decide whether the account shall be included in the anti-addiction system. In addition, we will collect information such as your login time, length of playing games, etc., and guide the minors to play games rationally through ways such as automatically intervening and limiting the game duration of the minors in our system, enabling the function of mandatorily exiting the game, etc. When the consumption is conducted by a person suspected to be a minor, we will then try to contact his or her parent or legal guardian for reminders, confirmations and deposition, so as to help the minors have a healthy access to the Internet.

At the same time, in order to better protect both the physical and mental health of minors and facilitate a healthy access to the Internet for them, we may employ stricter anti-addiction measures on the basis of relevant anti-addiction policies related to online games. Further, we will keep conducting researches and testing various technologies to protect the minors. For example, in order to further improve the accuracy of real-name verification on identities and to try best to prevent minors from impersonating the identity of others, we may enable face-recognition verifications in some games or for some users (subject to specific game strategies) under specific situations (for example, when you log into a game, or when you top up, purchase or make transactions during the game).

Besides, we may also collect your game behavior data generated during the game (for example, the data such as the click pressure and radius, the relative position of the click, the acceleration direction, and the direction of gravity formed when you operate the game on the terminal device, and the voice data generated when you interact with other players through online voice in the game) to preliminarily determine whether the user is a minor (regarding the voice data, the system will only randomly use some of your online voice to judge whether it is from a child or an adult). If the preliminary determination shows you are a minor, we may enable the face-recognition verification in accordance with the foregoing prescriptions.

If you are the parent or legal guardian of a minor, please pay attention to whether the minor uses LUXSOFT Game Service or provides his or her personal information after obtaining your authorization and approval. If you have questions about the personal information of the minor under your guardian, please contact us through the contact details provided in Section 9 herein.

9. Contact Us

When you have other complaints, suggestions, or questions regarding personal information of minors, please send your questions to [Name: LUXSOFT; Email: [email protected]].

We will review the relevant questions as soon as possible, and will respond within 15 days upon verifying your user identity.