ZPLAY PRIVACY POLICY

Updated: April, 26, 2021

Effective Date: May 29, 2018

Published: May 29, 2018

This Privacy Policy (the “Policy”) describes how ZPLAY (Beijing) Information Technologies Co., ltd. (also referred to as “ZPLAY,” “Company,” “we,” “us,” or “our”), collects, stores, uses and protects your information when you use our website at https://www.zplay.com and http://games.zplay.com (the “Site”), any mobile applications that hyperlink to this Policy and are available for download in the Google Play Store, Apple App Store or any other third party app store, or are pre-installed on third party devices (the “Apps”), or any other websites, pages, features, or content owned or operated by zplay (collectively, including the Site and Apps, the “Services”).

This Privacy Policy is part of, and is governed by, the terms and conditions set forth in our Terms of Service located at https://www.zplay.com/terms-of-service/.Please read the Terms of Service carefully before you use our Services.

Acceptance of this Policy

By accessing, visiting or using our Services, you warrant and represent that you have read, understood and agreed to this Policy and our Terms of Service. If you disagree with anything in this Policy, you must not use or access the Services.

I. How your personal information is collected and used?

Personal information refers to all kinds of information recorded electronically or otherwise that can identify a specific natural person or reflect the activities of a specific natural person, either alone or in combination with other information.

1.1. Information you provide on your own initiative

When you use our App service, you can choose to register an account and login or directly enter the App. when you register an account, you can create an App account through Apple, Facebook, Google and other third-party platform accounts and login to our App, then you will provide us with your third-party platform account avatar, nickname and other information; when you directly enter the App, it is a quick access to the App as a visitor.

1.2. Information collected and used and the permissions obtainedby us or the third-party platform that we work with

In order to provide you with better products or services, we have accessed third-party services (including but not limited to data analysis, third-party payment, advertising, etc.) within the App. When you use our products or services, in order to ensure that you can use the App normally and optimize user experience, we and the third-party platforms that we cooperate with may collect some device-related information and personal information (including: device information, read and write external memory, location information) by calling device permissions during the installation and use of the App.

1） Device information

In order to protect your normal use of our products or services, to achieve statistics and analysis of App data and to enhance the security of your device account, we or our partner third-party platforms will collect your device ID, device name, device type and version, system version, IP address, MAC address, application ID, network connection status, mode and type of access to the network and other information with your consent . Refusal to authorize us or the third-party platforms that we cooperate with to obtain your above information may result in your inability to use our App normally or the corresponding restrictions in the process of using our App.

2） Storage permission

In order to ensure that you can fully use the functions of the App and save the player App data, we and the third-party platforms that we cooperate with will obtain the storage permission of your mobile device with your consent. Refusal to authorize us or the third-party platforms that we cooperate with to obtain the storage permission of your mobile device may result in you not being able to use our App normally or being restricted in the process of using our App.

3） Geographic location information

In order to enrich the App experience and achieve content diversity, the third-party platforms that we cooperate with will collect your geographic location information with your consent. Refusal to provide geographic location information will only prevent you from using the functions related to location information, but will not affect your normal use of other functions of our App. You can also cancel your authorization to obtain your geographic location information from the third-party platform we cooperate with at any time.

4） Real name identity information

In order to comply with relevant laws and regulations and the requirements of relevant authorities, users of our App may need to undergo real-name authentication in order to continue to use our App, and the third-party platform that we cooperate with will ask you to fill in your real-name identity information with your consent, which is sensitive information, and refusal to provide real-name identity information may result in your inability to log into our App or the corresponding restrictions in using our App. Refusal to provide your real name identification information may result in you being unable to access our App or being restricted in your use of our App. If you want to know the specific rules of third party service providers to collect personal information, please refer to the privacy policy of the third party payment service provider you choose.

5) Payment Information

You may obtain virtual products related to our App, including game coins, game props, game equipment, etc., by means of payment. The above payment service is provided by a third party, which may collect your transaction information such as top-up records and consumption records. We will not obtain the payment account number, password and other information related to your payment. After you have made a successful payment, we will only obtain information about your completed payment from the third party payment service provider to provide you with the corresponding virtual products. If you would like to know the specific rules for collecting personal information from third-party service providers, please refer to the privacy policy of the third-party payment provider you have selected.

The third-party platforms that we work with and their privacy policies are linked below. If you would like to learn more about how the third-party platforms we work with collect, use, and protect your personal information, you can review them by yourself.

2. How to use cookies or similar technologies？

2.1. Cookies or similar technologies are technologies commonly used in the Internet. When you experience, log in to, or use our Services, we or the third party platforms that we work with may use the relevant technology to send one or more cookies or anonymous identifiers to your device to collect and store information about your access to, and use of, the Services for the purpose of analyzing your preferences in using our Services and optimizing your experience. We promise that we will not use cookies for any purpose other than those described in this Privacy Policy.

2.2. We will use cookies or similar technologies in strict compliance with relevant laws and regulations and provide effective security measures to protect your personal information. If you would like to learn more about how the third party platforms that we work with use cookies or similar technologies, you can review the privacy policies of the third party platforms.

3. How to share, disclose or transfer your personal information？

We will not share your personal information with third parties without your consent. The exceptions are the following.

3.1. we may share your personal information as required or permitted by law to comply with a subpoena or similar legal process or governmental request.

3.2. Disclosure to consultants, law enforcement agencies, judicial and regulatory authorities to protect the rights, property and safety of us or others.

3.3. When we are involved in a merger, acquisition, reorganization or other change, we may transfer your personal information to a third party that acquires or succeeds to all or part of our assets or shares. If the changed entity needs to change the purpose for which the personal information is used, we will require it to obtain your prior express consent.

4. How your personal information is stored？

4.1. We will only store your personal information for as long as necessary for the purposes described in this Privacy Policy and for the shortest period of time required by law and regulation. If we terminate our services or operations, we and the third-party platforms that we cooperate with will promptly stop the activities of continuing to collect your personal information, and will comply with the requirements of relevant laws and regulations to notify you in advance and delete or anonymize your personal information after the termination of services or operations, unless otherwise provided by laws, regulations or regulatory authorities.

4.2. The personal information we collect and generate is stored in the territory of the People’s Republic of China.

5. How to protect your personal information？

5.1. We will use strict security systems and industry-common security technologies and procedures to ensure that your personal information is not lost, leaked, destroyed or misused.

5.2. Our service adopts the same industry-required level of encryption technology, anonymization processing and other reasonable means to encrypt and store your personal information, and isolate it through isolation technology. We also use strict data access rights control and multiple identity authentication technology to protect personal information from unauthorized use of data.

5.3. We strengthen the security awareness of our employees and the importance of protecting information by establishing data security management practices and adopting strict data access rights control.

5.4. We allow access to personal information data only to those persons who have a need to know such information, and have set up strict access control and monitoring mechanisms for this purpose. We also require all persons who may have access to your personal information to comply with the corresponding confidentiality obligations. Failure to comply with these obligations may result in legal liability or suspension of the relationship with us.

5.5. We will take all reasonably practicable steps to ensure that no personal information is collected that is not relevant to our services.

5.6. The Internet environment is not 100% secure and we will do our best to protect the security of your personal information. When your personal information is leaked, destroyed or lost or other security incidents, we will, in accordance with the requirements of laws and regulations, promptly inform you of: the basic situation and possible impact of the security incident, the measures we have taken or will take to deal with it, the suggestions you can independently prevent and reduce the risk, and the remedial measures for you. We will also promptly inform you of the event-related situation by email, letter, telephone, push notification, etc. When it is difficult to inform the information subjects one by one, we will take reasonable and effective ways to issue announcements. At the same time, we will also take the initiative to report the disposal of information security incidents in accordance with the requirements of the regulatory authorities.

5.7. When you acquire the virtual products related to our App by way of payment, you will transact through a third party payment service provider. At that time, you will inevitably disclose your information, such as contact information, bank account or email address, to the counterparty or potential counterparty. Please protect your information and provide it to others only when necessary.

5.8. If we become aware that you are using our App and Services and related information for fraudulent or illegal purposes, we will take appropriate action, including but not limited to suspending or terminating your use of our App or Services.

6. How to manage your personal information？

6.1. Accessing, updating and deleting personal information

We take your right to manage your personal information very seriously. You can access, update and delete your personal information within the App or in the third party services accessed in the App in accordance with the guidelines within our App. When accessing, updating and deleting the aforementioned information, we may require you to authenticate your identity in order to safeguard the security of your information.

6.2. Cancellation of Account

If you want to cancel your App account, you can follow the guidelines in our App to submit an account cancellation request, or contact us through the contact information we set out in Article 11 of this Privacy Policy [legal@zplay.com], and we will tell you in detail how to cancel your App account.

6.3. Unless otherwise required by law or regulation, when you update or delete your personal information or apply for account cancellation, we may not update or delete the corresponding information from the backup system immediately, but will update or delete such information when the backup is updated.

7. Terms of Use for Minors

7.1. According to the relevant national laws and regulations, if you are a minor, you should read and agree to this privacy policy together under the supervision and guidance of your parents or other guardians before using our App and related services.

7.2. We protect the personal information of minors in accordance with the relevant national laws and regulations and will only collect, use, store, share, transfer or disclose the personal information of minors as permitted by law, with the express consent of their parents or other guardians or as necessary to protect them; if we discover that we have collected personal information of minors without prior verifiable parental consent then we will seek to delete the relevant information as soon as possible.

7.3. If you are the guardian of a minor, please contact us at the contact information listed in this Privacy Policy if you have questions about the personal information of a minor in your care.

8.Amendments and Notices to the Privacy Policy

8.1. In order to provide you with better services, our App and related services will be updated and changed from time to time, and we will revise this Privacy Policy from time to time, and these revisions will form part of this Privacy Policy and have the same effect as this Privacy Policy, and we will not reduce your rights under this Privacy Policy currently in effect or obtain your unauthorized access without your express consent.

8.2. After the privacy policy is updated, if the version of our App is updated and the privacy policy is updated, we will remind you of the updated content in an appropriate way before the updated terms take effect, so that you can keep abreast of the latest version of the Privacy Policy. If you continue to use our services, you agree to accept and be bound by this Privacy Policy as amended.

9.Special Notice to Residents of the State of California, USA

9.1 California law allows users of the Services who are California residents to request and receive once a year, free of charge, a notice from us describing what categories of personal information (if any) we shared with third parties, including our corporate affiliates, for their direct marketing purposes during the preceding calendar year. If you are a California resident and would like to request a copy of this notice, please contact contacting us as provided in the Article 11 “How to Contact Us” section. In your request, please specify that you want a “California Privacy Rights Notice.” Please allow at least thirty (30) days for a response.

9.2 In addition, if you are a California resident under the age of 18 and are a registered user of the Services, you may request that we remove content or information that you posted on Services or stored on our servers by: submitting a request as provided in the Article 11 “How to Contact Us” section and (ii) clearly identifying the content or information you wish to have removed and providing sufficient information to allow us to locate the content or information to be removed.

However, please note that we are not required to erase or otherwise eliminate content or information if:

1) other state or federal laws require us or a third party to maintain the content or information;

2) the content or information was posed, stored, or republished by another user;

3) the content or information is anonymized so that the minor cannot be individually identified;

4) the minor does not follow the instructions posted in this Privacy Policy on how to request removal of such content or information;

5) the minor has received compensation or other consideration for providing the content.

9.3 Further, nothing in this provision shall be construed to limit the authority of a law enforcement agency to obtain such content or information.

10. Special Notice to EU Residents

10.1. We may store or process your personal information outside of the country in which we collect it or the country in which you reside. Our principal place of business is in China. You should understand that we may transfer some or all of your personal information to China to carry out certain operational and processing needs as described in this Policy.

10.2. When transferring personal information outside the EU, we will use technical and physical safeguards to protect your personal information and strictly comply with the requirements of relevant EU laws and regulations. If you have questions about the mechanism for transferring your personal information in relation to your personal information, please contact us.

10.3. We will only collect, use or store your personal information in the following circumstances：

1) Information that you voluntarily provide to us on your own initiative.

2) In order to provide you with the services you have requested.

3) To protect the vital interests of you or others.

10.4. We will comply with your request in accordance with applicable law and subject to legal requirements when you exercise your rights as set out below. Please contact us as set forth in theArticle 11 “How to Contact Us” section. In your request, please indicate that you require a “Notice of EU Privacy Rights”. Please allow at least thirty (30) days for us to respond.

1) To request that we assist you in contacting third party platforms to correct, update, or delete content or information that you have posted on the Services or stored on our servers.

2) Restrict us from certain processing of your personal information or object to certain types of processing of your personal information;

3) Withdraw your license at any time, including objection to the use of your personal Information for marketing or advertising purposes.

10.5. We are not required to delete your personal information if we have a legitimate reason to retain it, for example, to prevent fraud. Please note that there are certain circumstances where we are prohibited by law from performing the action you have requested, including

1) When we are unable to confirm your identity;

2) When the request is deemed excessive;

3) When doing so would adversely affect the rights or freedoms of other individuals.

11. How to contact us?

11.1. In the process of using our App, if you have any doubts or suggestions about this privacy policy, or you think your personal information is not protected by this privacy policy, you can contact us through the following ways, we will give feedback promptly after verifying and validating your user identity.