Privacy Policy
Effective Date: 2024/11
Sunborn and its affiliates are well aware of the importance of privacy and committed to respecting and protecting your privacy. This Privacy Policy describes how we collect, use, disclose, transfer, store and otherwise process your personal data when you are using our US website, game apps or services (hereinafter collectively referred to as "Services"). Please read the Privacy Policy carefully and familiarize yourself with our privacy practices before using our Services or providing your personal data.
Data Controller: Hecate Network Technology Co., Ltd. (hereinafter referred to as “we”, “us” or “Sunborn Game”) is the controller of your information processed in connection with this Privacy Policy.
This Privacy Policy will help you understand the following:
A. General Provisions
I. How We Collect and Use of Your Personal Data
II. How We Use Cookies and Similar Technologies
III. How We Disclose Your Personal Data
IV. How Your Personal Data Is Transferred Globally
V. How Long We Keep Your Personal Data
VI. How We Protect Your Personal Data
VII. Your Rights Regarding Your Personal Data
VIII. How We Process Children's Personal Data
IX. Third-Party Websites
X. How This Privacy Policy is Updated
XI. Third-Party SDK List
B. Specific Provisions
I. ADDITIONAL PROVISIONS FOR USERS FROM PHILIPPINE ONLY.
II. ADDITIONAL PROVISIONS FOR USERS FROM THILAND ONLY.
C. Contact Us
In addition to this Privacy Policy, specific Privacy Policies might apply depending on the Services used. We will, in each case, provide you with the applicable Privacy Policy.
A. General Provisions
I. How We Collect and Use Your Personal Data
Personal data refers to any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. The personal data we collect about you depends on the environment in which you interact with us and the choices you make, including your privacy settings and the features and Services you use.
You may provide personal data to us directly, in which case you are generally free to choose which personal data you want to provide to us. However, if some personal data is required for the performance of our Services and you choose not to provide that personal data, we may not be able to provide you with the Services you requested.
We will collect and process your personal data according to the following methods and purposes, so as to provide you with, improve our Services and protect your account security.
1. Registration and login services. To assist you in registering and logging in our Services, you are required to provide us with your email address. If you choose not to provide such information, you may not be able to use our Services. You can also choose to use your third-party social accounts (e.g., Facebook, Google, Apple ID, Game Center) to login our Services.
2. Maintenance of basic functions and account security. In order to provide you with the basic function of our Services, to ensure the security of your game account and create a fair, healthy and safe game environment, we need to obtain your permission to read/write the external storage of your devices (for example, if you use Android devices, which include reading permission to external storage, reading/writing permission to SD card content, and modifying/deleting permission to SD card content), and collect device and software information such as your user ID, device ID, device name, device type, device model and version, system version, IP address, device unique identifier (IMEI and Android ID for Android devices, IDFA for iOS devices), network type, and MAC address, etc.
3. Logs and application information of game. When you play our online games, we will also collect your game log information such as login log, item log, game match information, friends record, game identification information, hardware and operating system information, application list, progress and game crash record, etc. If you refuse to provide the aforesaid information, you may not be able to use the basic functions and services of our related products.
4. Transaction information. In order to provide you with transaction services, we will collect recharge records, consumption records, payment records (including Google payment and iOS payment records) and other necessary information related to transactions so that you can check your transaction records and protect the security of your virtual property to the greatest extent possible. Your consumption records, payment records and other necessary information related to transactions may be sensitive personal data. The collection of the above information is necessary to realize the consumption function of our Services, otherwise the transaction cannot be completed, but it does not affect your normal use of our Services with basic functions.
5. Interactive game information. In order to purify the game environment and maintain a healthy online environment, we will collect the text, picture, voice and video information you send in the game to filter inappropriate content such as pornography, violence, politically incorrect content, abuse and malicious advertisements, etc. If you wish to interact with other players through pictures, voice or video (if applicable to game functions), after obtaining your authorization and consent, we will obtain the permission of photos or files storage, microphone or camera to provide you with the functions such as screenshot saving, picture uploading and voice chatting. If you refuse to provide the aforementioned permission, you may not be able to use such functions, but your normal use of the basic functions will not be affected. You can also disable the preceding permissions in privacy settings at any time. Unless you voluntarily upload pictures, recordings and other information, we will not collect such information from your device.
6. Customer service information. In response to your request for customer service, we will collect data generated during your request for customer support.
7. Additional service. To provide you with additional functions/services besides other basic services and functions, including gifts, prizes, birthday wishes, questionnaire survey, etc., subject to your consent, we may collect your personal data, including such as date of birth, address, email, nickname and profile image. If you disagree to provide the above information, the additional functions will not be realized or the results we expect will not be achieved, but your normal use of basic functions will not be affected.
You understand and agree that the functions and services we provide to you are constantly updated and developed, if a new function or service is not mentioned in the foregoing statement but processes your personal data, we will inform you of the updated content of data processing activity, and we may also use your personal data for other purposes not incompatible with the disclosed purposes (such as archiving in the public interest, scientific or historical research, or statistical purposes) if permitted by applicable data protection laws, or we may get your additional consent for those purposes at that time.
You understand and agree that some of our Services may require you to enable specific permission on your device for the collection and use of your personal data. While the fact that we obtain a specific permission does not necessarily mean that we will collect your relevant personal data. Even if we have obtained such permission, we will only collect your personal data when necessary and in accordance with the Privacy Policy. You can disable any permissions at any time on the device. Please however note that once you close any permission, it means you have cancelled your authorization and we will no longer collect and use relevant data based on the corresponding permission, nor will we be able to provide you with the corresponding services. However, your decision to close your permission does not affect the collection and use of your personal data previously obtained under your authorization.
II. How We Use Cookies and Similar Technologies
1. Cookies are small text files stored on browsers, computers or mobile devices by websites you visit. They allow websites to recognize your device. The content of cookies can only be retrieved or read by the server that created the cookies. Each cookie is unique to your browser or mobile application. Cookies usually contain identifiers, common information and other details.
2. Cookies and similar technologies are usually used for remembering your identity, analyzing your use of services, advertising optimization and other commercial, market analysis or academic purposes. These cookies and similar technologies may collect non-personally identifiable information related to you, which may be used to analyze how you use these services, send you advertisements that may be of interest to you, or evaluate the effectiveness of advertising services.
3. We use third-party analytics tools on our Services and the third-party analytics tools may use cookies to collect, store and track relevant data of users at certain time. See below details about the analytics tools we use on our Services. The collection and use of such data by third-party cookies and similar technologies is not bound by this Privacy Policy, but by its own personal data protection statement, and we will not take any responsibility for the third-party cookies and similar technologies or the third-party collection or use of any of your information.
4. Cookies are not the only way to recognize or track visitors or a game player. We may use other similar technologies from time to time, like SDKs, we may use SDKs to recognize you when you log in our Game or for advertising statistics, or risk control purposes. For more detail, please see XI. Third-Party SDK List.
5. We use local storage technologies, including Shared Preferences (for Android device) and NSUserDefault (for iOS device), on our US website to store user information and user login token.
6. We also use analytics tools on our game apps include the following:
• AppsFlyer Analytics: We use AppsFlyer’s attribution and marketing analytics services that enable us to measure and analyze the effectiveness of our marketing campaigns and certain events and actions within our game apps and to detect and prevent fraudulent activities. Please note AppsFlyer Analytics can access to end users’ information including but not limited to device information (e.g., bundle ID, advertising identifier), network information (e.g., IP address, time zone, network connection type) and payment information (e.g., payment item ID, payment item name, amount, payment currency, order number). For more information about AppsFlyer Analytics and how it collects and processes information, and how to opt out of AppsFlyer Analytics, please visit: https://www.appsflyer.com/legal/services-privacy-policy/.
• Google Firebase: We also use Google Firebase to optimize the advertisement delivery, track device behavior and detect and prevent fraudulent activities. Please note Google Firebase can access to end users’ information including but not limited to device information (e.g., bundle ID, advertising identifier), network information (e.g., IP address, time zone, network connection type) and payment information (e.g., payment item ID, payment item name, amount, payment currency, order number), in accordance with Google Firebase’s privacy policy which can be found at https://firebase.google.com/support/privacy.
• MTP: We also use MTP to detect and prevent fraudulent activities such as cheating, hacking and cracking. Please note MTP for such purposes will collect end users’ information including but not limited to Android device application installation list, internet access, current network environment, WIFI environment, device information (e.g., device model), and read/write storage. For more information on how MTP collects and processes information, please refer to: https://privacy.qq.com/policy/tencent-privacypolicy.
III. How We Disclose Your Personal Data
At times Sunborn Game may make certain personal data available to other companies that are wholly or jointly controlled by us (hereinafter as "Affiliates") and other third parties that work with Sunborn Game in order to provide Services to you.
• Affiliates: Your personal data may be shared with Sunborn Game's Affiliates for the purpose of rendering our Services to you. If Affiliates wish to process your personal data for a different purpose, they must first seek your consent, unless another lawful basis exists.
• Service Providers and Partners: Some of our Services will be provided with the assistance of third parties. We sometimes use third parties to control the collection of your personal data. For example, we may share your user ID with the social media platforms and other parties we partner with (e.g., Apple) when you choose to use social accounts to log into the Services or use Apple Pay on the Services. We may also share some personal data with our partners in particular so as to deliver you a better service and improve your user experience. For example, we may share your email address with advertising service providers who assist with marketing activities, such as displaying targeted ads, managing campaigns, tracking success, and analyzing performance to enhance your experience with relevant content.
• Purchasers and third parties in connection with a business transaction: Where a merger, acquisition, bankruptcy liquidation or similar action takes place, we may transfer or disclose your personal data following completion of such transaction and/or during the assessment process pending transfer. If transferred in such a case, your information would remain subject to this Privacy Policy or a privacy policy that, at a minimum, protects your privacy to an equal degree as this Privacy Policy.
• Law enforcement, regulators and other parties for legal reasons: We may disclose your personal data to third parties as required by law, or if we reasonably believe that such action is necessary (a) to comply with a subpoena or other legal proceedings, legal actions or government agency requests; (b) when we believe in good faith that a disclosure is necessary to comply with the law and the reasonable requests of law enforcement; (c) to protect and exercise our legal claims, rights and property; (d) to protect your rights, property or personal safety or that of others; (e) to investigate fraud and (f) to protect the security or integrity of our Services.
• The public, when posted in certain public spaces: Some of our Services allow you to connect and interact with others. Your profile information or information that you post in a public space, including personal data, will be accessible to other users or the general public by default when you create it. Such content will be accessible by the general public or the members of the Services depending on the Services used.
Without your consent, we will not disclose your personal data to other third parties other than the above mentioned.
IV. How Your Personal Data Is Transferred Globally
Sunborn Game is a global business and our Services are spread around the world. As a result, we collect and transfer personal data on a global basis. That means that we may transfer your personal data to locations outside of your country. For more information, please contact us using the details set out in “Contact Us” section.
Please note that different countries or regions offer different levels of data protection. This means that your personal data could be stored in a country that offers a level of protection that may, in certain instances, be less protective of your personal data than the country or region in which you are located. However, in such cases, we will take measures to ensure that the personal data we collect is processed in accordance with this Privacy Policy and applicable laws, and that your personal data is adequately protected. For example, we might ask your permission to transfer your personal data across borders, and we will implement adequate security measures and sign the necessary data transmission/sharing agreements with the recipients of your personal data prior to the transfer taking place. We will also specifically ensure that we comply with laws that require us to store data locally within a specific country or region. Specifically, this Game’s servers are located in the US, and our group locations and third-party service providers and partners operate around the world. This means that when we collect your Personal data, we may process it in any of these countries. In this case, we will take appropriate organizational and technical measures to ensure that your personal data is properly protected.
V. How Long We Keep Your Personal Data
We will only store your personal data for as long as necessary to achieve the collection purposes set out in this Privacy Policy, unless we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested, to perform a contract with you or to comply with applicable legal, tax or accounting requirements.
After the expiry of the retention periods, we will delete or anonymize your personal data, if this is technically not possible (for example, because your personal data has been stored in backup archives), then we will securely store your Personal data and isolate it from any further processing until deletion is possible.
VI. How We Protect Your Personal Data
We will adopt safety protection measures in line with industry standards, including establishing reasonable system standards and security technologies to prevent your personal data from being accessed, used or modified without authorization, and to avoid data leakage or loss.
The Internet is not an absolutely safe environment. We recommend that you use complex passwords and pay attention to protecting your information security. Please take good care of your account number, password and other identity elements. When you use our Services, we will identify you by your account number, password and other identity elements. Once you disclose the above information, you may suffer losses that may be detrimental to you. If you find that your account number, password and/or other identity information may or have been leaked, please contact us immediately so that we can take corresponding measures in time to avoid or reduce related losses.
When communicating with a third party or purchasing goods and services through our Service, you will inevitably disclose your own information, such as contact information or email address, to the counterparty or potential counterparty. Please protect your information properly and provide it to others only when necessary.
The Internet environment is not one hundred percent secure, and we will try our best to protect the security of any information you send to us. Please understand that due to technical limitations and risk prevention limitations, even though we have tried our best to strengthen security measures, we can't always guarantee one hundred percent information security. You need to know that the system and communication network you use to access our Service may have problems due to circumstances beyond our control. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you understand that any information that you transfer to us is done at your own risk. If we learn of a security system breach we may attempt to notify you electronically so that you can take appropriate protective steps. By using the services or providing personal data to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the services. We may post a Policy via our Service if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive Policy of a security breach in writing.
VII. Your Rights Regarding Your Personal Data
Data protection laws may give you a number of legal rights in relation to the personal data that we hold about you. Not all data protection laws are the same so not all of these rights apply in all places. Also, some of these rights are subject to qualifications and limitations and exercising these rights may impact on the Services that we can provide to you. However, we will take appropriate technical measures to enable you to control how we use your personal data where we can do that.
Subject to the data protection laws in your country, your rights may include:
1. The right to be informed: Sunborn Game provides this Privacy Policy to keep you informed about how your personal data is handled, the purposes for processing it, the categories of personal data collected, the recipients of this data, and the duration for which the data will be stored.
2. The right to access: If you wish to access your personal data, some of our Services provide an interface through which you may directly search for or access certain personal data. You may also request access to the personal data we hold about you by contacting us using the "Contact Us" section.
3. The right to rectification: If you find that the personal data we process about you is inaccurate or incomplete, you are entitled to ask us to make rectifications without undue delay and request the completion of your personal data where appropriate.
4. The right to erase (Right to Be Forgotten): You have the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data, but we are legally entitled to retain it
5. The right of portability: In some circumstances, you have the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit this information to a third party where this is technically feasible. Please note that this right only applies to personal data which you have provided to us;
6. The right to withdraw your consent: You have the right to withdraw your consent to our processing of your personal data. Please note, however, that we may still be entitled to process your personal data if we have another legitimate reason (other than consent) for doing so. For example, we may need to retain your personal data to comply with a legal obligation;
7. The right to object to or restrict processing: You have the right to object to, and the right to request that we restrict, our processing of your personal data in certain circumstances. Please note that there may be circumstances where, even if you object to or request restriction of our processing, we are legally entitled to continue processing your personal data.
8. The Right to Avoid Automated Decision-Making: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you, except under certain circumstances (such as when you have given explicit consent or when necessary for the performance of a contract).
9. The Right to Non-Discrimination: Under CCPA, Sunborn Game will not discriminate against you for exercising any of your privacy rights. This means we will not deny you goods or services, charge you different prices, or provide a different level or quality of services unless such differences are reasonably related to the value of your personal data.
10. The right to lodge a complaint: You have the right to lodge a complaint with the supervisory authority if you think that any of your rights have been infringed by us.
11. The right to opt-out of targeted advertising: If you wish to not to receive targeted ads, you have the right to opt-out of targeted advertising at any time. You can also contact us by using the "Contact Us" section.
In addition to exercising your rights through user account as otherwise state above, you can exercise your rights by contacting us using the details set out in the “Contac Us” section.
You may have some additional data protection rights according to applicable data protection laws in different countries or regions, if you wish to make such a request of data protection rights, please contact us by using the contact details provided under the “Contact us” heading below. However, please note, for data security purposes, before responding to your request, we may ask you to verify your identity and provide further details about your request to ensure that you are the right person to access such data or request to have other data rights.
We respond to all requests we receive from individuals wishing to exercise their personal data protection rights in accordance with applicable data protection laws.
In principle, we do not charge a fee for responding to your reasonable request. However, for multiple and repetitive requests that exceed a reasonable limit, we may charge a reasonable fee to cover some of our costs, depending on the nature of the request. We are entitled to refuse requests in whole or in part, and we may refuse requests that are manifestly unfounded, unreasonably repetitive or that require disproportionate technical effort (for instance, requests that require the development of new systems). In addition, we may not respond to requests that directly concern significant issues of public interest or may cause serious damage to the legitimate rights and interests of you or other individuals or entities.
VIII. How We Process Children's Personal Data
Please note, although the age of a child or minor may be different from different jurisdictions, if you are a child/minor in your jurisdiction, this Game is not for you. However, this Game does not knowingly collect personal data from a child or minor. If you are a child or minor, please do not attempt to use the products or send any personal data about yourself to us. If we learn that we have collected personal data from a child or a minor, we will delete that information as quickly as possible.
If you believe that a child in your jurisdiction may have provided us with their personal data; or if you are a parent, or legal guardian of a child, and you have any questions or concerns, please contact us using the contact details provided under the “Contact Us” heading below.
IX. Third-Party Websites
1. Sunborn Game Services may contain links to third-party websites, products and services. You can choose whether to access websites or accept products and services provided by third parties or not.
2. We do not control third-party privacy and data protection policies and do not accept any responsibility or liability for such policies. At the same time, such third parties are not bound by this Privacy Policy. Therefore, before submitting personal data to third parties, we strongly recommend that you refer to the privacy protection practices of such third parties.
X. How This Privacy Policy Is Updated
We reserve the right to update or modify this Privacy Policy from time to time. We will, as appropriate, send you notifications of material updates to this Privacy Policy in a form we deem appropriate and we will update the "last updated" date at the start of this Privacy Policy.
XI. Third-Party SDK List
|
Third-Party SDK’s Name |
Functions |
Possible Permissions/Information Obtained |
Privacy Policy |
|
AppsFlyer Analytics |
to measure and analyze the effectiveness of our marketing campaigns and certain events and actions within our game apps and to detect and prevent fraudulent activities |
device information (e.g., bundle ID, advertising identifier), network information (e.g., IP address, time zone, network connection type) and payment information (e.g., payment item ID, payment item name, amount, payment currency, order number) |
|
|
Google Firebase |
to optimize the advertisement delivery, track device behavior and detect and prevent fraudulent activities |
device information (e.g., bundle ID, advertising identifier), network information (e.g., IP address, time zone, network connection type) and payment information (e.g., payment item ID, payment item name, amount, payment currency, order number) |
|
|
MTP |
to detect and prevent fraudulent activities such as cheating, hacking and cracking |
Android device application installation list, internet access, current network environment, WIFI environment, device information (e.g., device model), and read/write storage |
|
|
Tencent ACE |
to detect and prevent fraudulent activities such as cheating, hacking and cracking |
Android device application installation list, internet access, current network environment, WIFI environment, device information (e.g., device model), and read/write storage |
https://www.anticheatexpert.com/#/doc-center/8fc4c1195346a2c74e472881bca42c4010698921 |
|
Thinkdata |
to analyze game behavior |
Application processes，Retrieval of running processes, IP address, operating system and version, device ID, OAID, AAID, ODID, Android ID, device model, network status, network operator, program installation time, device RAM status, device storage status, system language, device frame rate |
https://docs.thinkingdata.io/ta-manual/v3.7/installation/installation_menu/privacy_cn.html |
|
|
account login |
Unique device identifiers (IDFA, IDFV, GAID, Android ID)，Firebase app-instance ID，IP address，Browser type and settings，Device type and settings，Operating system，Application version number |
https://policies.google.com/privacy#infocollect |
B．Specific Provisions
I. ADDITIONAL PROVISIONS FOR USERS FROM PHILIPPINE ONLY.
1. Right to be Informed: You have a right to be informed whether personal data pertaining to you shall be, are being, or have been processed, including the existence of automated decision- making and profiling. You shall be notified and furnished with information indicated hereunder before the entry of your personal data into our processing system, or at the next practical opportunity:
a. description of the personal data to be entered into the system;
b. purposes for which they are being or will be processed, including processing for direct marketing, profiling or historical, statistical or scientific purpose;
c. basis of processing, when processing is not based on your consent;
d. scope and method of the personal data processing;
e. the recipients or classes of recipients to whom the personal data are or may be disclosed;
f. methods utilized for automated access, if the same is allowed by you, and the
extent to which such access is authorized, including meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you;
g. the identity and contact details of the personal data controller or its representative;
h. the period for which the information will be stored; and
i. the existence of your rights as data subjects, including the right to access, correction, and object to the processing, as well as the right to lodge a complaint before the National Privacy Commission of the Philippines.
2. Right to Object: You shall have the right to object to the processing of your personal data, including processing for direct marketing, automated processing or profiling. You shall also be notified and given an opportunity to withhold consent to the processing in case of changes or any amendment to the information supplied or declared to the data subject in the preceding paragraph.
3. Right to Access: You have the right to reasonable access to, upon demand, the following:
a. Contents of your personal data that were processed;
b. Sources from which personal data were obtained;
c. Names and addresses of recipients of the personal data;
d. Manner by which such data were processed;
e. Reasons for the disclosure of the personal data to recipients, if any;
f. Information on automated processes where the data will, or is likely to, be made as the sole basis for any decision that significantly affects or will affect you;
g. Date when your personal data were last accessed and modified; and
h. The designation, name or identity, and address of the personal information controller.
4. Right to Erasure or Blocking: You shall have the right to suspend, withdraw or order the blocking, removal or destruction of your personal data from the personal information controller’s filing system. The personal information controller may notify third parties who have previously received such processed personal information. This right may be exercised upon discovery and substantial proof of any of the following:
a. The personal data is incomplete, outdated, false, or unlawfully obtained;
b. The personal data is being used for purpose not authorized by you;
c. The personal data is no longer necessary for the purposes for which they were collected;
d. You withdraw your consent or object to the processing, and there is no other legal ground or overriding legitimate interest for the processing;
e. The personal data concerns private information that is prejudicial to you, unless justified by freedom of speech, of expression, or of the press or otherwise authorized;
f. The processing is unlawful;
g. The personal information controller or personal information processor violated your rights.
5. Right to Damages: You have the right to lodge a complaint with the National Privacy Commission and, where appropriate, be indemnified for any damages sustained due to such inaccurate, incomplete, outdated, false, unlawfully obtained or unauthorized use of personal data, taking into account any violation of your rights and freedoms as data subject.
6. Right to Data Portability: Where personal data is processed by electronic means and in a structured and commonly used format, you shall have the right to obtain a copy of such data in an electronic or structured format that is commonly used and which allows for further use by you. The exercise of this right shall primarily take into account your right to have control over your personal data being processed based on consent or contract, for commercial purpose, or through automated means. The National Privacy Commission of the Philippines may specify the electronic format referred to above, as well as the technical standards, modalities, procedures and other rules for their transfer.
II ADDITIONAL PROVISIONS FOR USERS FROM THAILAND ONLY.
1. Data Protection Rights
Subject to the right indicated in VII. Your Rights Regarding Your Personal Data of this privacy policy, You have rights regarding your personal data in accordance with the Thai Personal Data Protection Act (PDPA). These rights are outlined below.
a. Right to Access
You have the right to access and request a copy of your personal data. You also have the right to request disclosure of the acquisition of your personal data obtained without your consent.
b. Right to Data Portability
In cases where we arrange your personal data in a structured, commonly used, and machine- readable format that can be transmitted via automated means, You have the right to transmit that data to another data controller using automated means. You also have the right to receive your personal data in such a format, except in situations where technological limitations prevent this.
c. Right to Objection
In circumstances where we are processing personal data that concerns you on the lawful basis of legitimate interest or for direct marketing purposes, You have the right to object to the processing of your personal data carried out by us or on our behalf.
d. Right to Restriction
You have the right to have our processing of your personal data restricted in the following circumstances:
ž When your request to correct your personal data is pending.
ž When your personal data should be deleted, but You have requested for restriction of processing instead.
ž When the periods of the processing have expired, but you have requested for restriction of processing instead due to legal reasons
ž During the verification process of your objection to the processing of personal data.
ž Right to Complaint
If you believe that we have not complied with the requirements of the PDPA as it applies to your personal data, and in addition to your rights set out above, you have a right to lodge a complaint with the Personal Data Protection Commission Office (PDPC) in Thailand.
2. Transfer of Personal Data outside Thailand
Your Personal Data may be transferred outside Thailand when it meets one of the following conditions, in accordance with the PDPA:
a. Your consent has been obtained, authorizing the transfer of your personal information to a destination country that have inadequate personal data protection standards.
b. The destination countries that receive your personal information have an adequate level data protection as prescribe by the PDPC.
c. The transfer is for compliance with Thai law.
d. The transfer is necessary to fulfill contractual obligations with you.
e. The transfer is necessary to carry out a contractual agreement between two entities for your benefit.
3. Collection of Personal Data from Minors in Thailand
The Services are not intended for minors under the age of 20 who residing in Thailand without the consent of a parent or legal guardian of such minor. We do not knowingly collect or maintain any personal data from anyone under the age of 20 residing in Thailand, nor is any part of our Site, Games or other Services directed to minors under the age of 20 living in Thailand. We will close any
Accounts used exclusively by such minors and will remove and/or delete any personal data we believe was submitted by any minor under the age of 20 residing in Thailand without the consent of a parent or legal guardian of such minor.
C. Contact Us
If you have questions or concerns regarding our Privacy Policy or practices, please submit your request to Sunborn Game as specified below.
Email address: dpo@micateam.com
Postal address: Rm1892B, Fortress Tower, 205 King's Road, North Point, HONG KONG