Privacy Policy
EFUN COMPANY LIMITED (hereinafter referred to as "we") respect and protect your personal privacy. To provide you with more accurate and personalized services, we will use and disclose your personal information according to this privacy policy. However, we will treat this information with caution. Unless otherwise specified in this privacy policy, we will not disclose such information to any third party without your prior consent. We will continue to update this privacy policy. If you use our services, please confirm that you have read and understood this privacy policy. If you do not agree with this privacy policy, please do not use our services.
This privacy policy mainly includes:
1. What information we will collect from you;
2. How we will use your information;
3. Sharing your information;
4. Storage of your personal information;
5. Withdrawal of consent and deletion of information;
6. Accessing and correcting personal information;
7. Information about children;
8. International transfers;
9. Other;
10. Supplementary provisions (specific jurisdictions).
1. What Information We Collect from You
1. Information you provide to us:
1) Information you provide when registering on the platform, including the information you fill in (such as nickname, avatar, etc.) and/or information imported from your associated social media accounts (such as avatar, nickname, etc.);
2) Information you fill out when participating in our surveys, promotions, activities, etc.;
3) Information you provide when using payment services;
4) Information you provide while using our services.
2. Information we obtain from you:
1) Identity information: name, gender, date of birth, age, email address, phone number, address, occupation, etc.;
2) Log information, including: login logs, item logs, operation information, game match information, friend information, interaction records, login accounts, game IDs, IP addresses, network environment, language used, etc.;
3) Device or software information, including: device ID, device name, device type, hardware serial number, device MAC address, device sensor information, package name, application ID, network type, network port information, application version, application settings, system clipboard, Wi-Fi status/parameters, Wi-Fi access name (SSID), router MAC address (BSSID), IP address, and mobile device system version and identification code;
4) Chat information: including text, images, voice, video, etc. that you chat with others in the game;
5) Transaction information: including bank/debit/credit card number, card expiration date, order content, etc.;
6) Game information: including login status, match information/status, achievement information, game progress, game identification information, game event information (including errors, crashes, restarts, upgrades), etc.;
7) Application information: including device identifier information, hardware and operating system information, etc.;
8) Other information: we may collect other information based on specific services or features on the platform. In such cases, we will provide a separate privacy statement detailing the collection and use of such information.
3. Information we obtain from other third parties:
We may receive personal data about you from third parties and other publicly available sources.
4. Cookies:
1) We may use cookies to collect your data, which can help you revisit the site. A cookie is a small piece of data sent by a web server and stored in a web browser, allowing the data to be read from the browser at a later time. Currently, the data collected from cookies is used to improve service functionality. The data we provide is analyzed and organized based on your accumulated usage of the service. Cookies can help make the login process faster and smoother and can store data between calls.
2) You can disable cookies in your browser without affecting your experience on our website, but cookies do make our services more convenient. Disabling cookies may complicate your use of our services and involve more input processes. You should also be aware that if you disable cookies, certain features of our services may be affected.
2. How We Use Your Information
We fully respect and protect all personal information you submit and generate while using our services. Unless otherwise specified in this privacy policy, we will not disclose your privacy information to any third party without your prior consent. Unless permitted by you, third parties or companies providing separate or collective services will be denied access to your information, including all previously accessible information upon termination of services.
1) Verify your identity and help you complete registration and login. This is to provide you with stable services and ensure the security of your service usage;
2) Assist you in placing orders, making payments, recharging, and delivering goods/services to you, ensuring account and property safety. This is used to provide you with in-game recharge and transaction services, show you and facilitate your management of services and/or orders, while maximizing the protection of your virtual items, and for verification and inquiry of transaction behaviors by relevant administrative departments and judicial authorities;
3) Maintain the normal operation of game functions. This is to provide you with basic game functions and maintain their normal operation;
4) Create a fair, healthy, and safe gaming environment. This is used to combat actions that disrupt the fairness of the game or interfere with or destroy normal game services (including detection of piracy, scanning for cheats, preventing cheating, and preventing malware such as viruses and trojans), ensuring the safety of your gaming account;
5) Provide interactive and publishing services, information push, and conduct product/service marketing. To timely provide you with updates about products and services, we will use your personal information to push hot content, activity notifications, and progress;
6) Game operation statistical analysis, conduct service satisfaction surveys, improve services. To provide you with better and higher quality services, we will use your data for research, analysis, and service improvement. Additionally, we will use the information obtained from the surveys you fill out to enhance and optimize our services;
7) Contact you when necessary. In situations where you participate in our activities, consult us, or lodge customer service complaints, we need to use your information to contact you;
8) Help you view your history. We need to store, host, and back up your personal data so that when you request to view your game history, we can provide feedback on your game history;
9) Fulfill legal obligations. This is used to respond to legal processes, comply with or act according to the applicable laws, government, or regulatory requirements in any relevant jurisdiction, including but not limited to the disclosure requirements imposed by any laws binding on us, related companies, or affiliates;
10) Other purposes permitted by applicable laws, and we have notified you when obtaining your consent.
11) Legal basis for processing. If you are a resident of the EU, we will process your information based on a range of legal bases. For example, we will process your information when we have obtained your consent, we have legitimate interests in doing so, it is necessary for the performance of a contract with you, and we have legal obligations to process your information. For example, we rely on our legitimate interests to provide targeted marketing services and on contractual necessity to process the information you provide when creating an account. To learn more about the legal bases we rely on for processing your information for any specific purpose, please contact us using the contact information provided in this privacy policy.
3. Sharing Your Information
1) Sharing. We value the protection of your personal information and will only provide your personal information to third parties for legitimate, proper, necessary, specific, and explicit purposes, and will maintain strict confidentiality. We will require our partners to handle your personal information in accordance with our requirements, this privacy policy, and any other relevant confidentiality and security measures. In general, we will not share your personal information with any company, organization, or individual, except in the following cases:
A. With your prior consent;
B. Sharing your personal information as required by applicable laws, regulations, legal processes, government mandates, or judicial decisions;
C. When necessary to protect us, you, or the public from threats to their interests, property, or safety, information may be provided to third parties;
D. Your personal information may be shared among our affiliated companies. We will only share necessary personal information, and such sharing must comply with the purposes described in this privacy policy;
E. To provide you with better and higher quality products and services, we will share some of your personal information with our partners for advertising-related services, message push functions, payment-related services, third-party authorized services, support product feature modules, etc. If you refuse to let our partners collect the necessary personal information for providing services, you may be unable to use that third-party service on our platform;
F. To comply with the law, protect the legitimate rights and interests of us and our affiliates or partners, you, or others, or to prevent fraudulent activities and reduce credit risks.
Our partners' collection and processing of information are governed by their respective privacy policies or relevant statements, which do not apply to this privacy policy. Therefore, we recommend that you review the privacy policy of any third-party service before use. To protect your legal rights, if you find potential risks associated with the relevant third-party service, we recommend terminating the operation immediately and contacting us promptly.
2) Transfer.
A. With your prior consent, we will transfer your personal information to other parties;
B. As our business continues to develop, we may engage in mergers, acquisitions, asset transfers, or similar transactions, or for other reasons need to transfer personal information, and your personal information may be transferred as part of such transactions. At that time, we will inform you of the name or contact information of the receiving party and require the new company or organization holding your personal information to continue to protect your personal information according to legal regulations and no less than the requirements of this privacy policy;
C. Necessary disclosures as required by applicable laws, regulations, legal processes, and mandatory administrative or judicial requirements.
3. Disclosure
We will only publicly disclose your personal information in the following situations:
1) With your prior consent or at your request;
2) According to applicable laws, regulations, legal processes, and mandatory administrative or judicial requirements, we may publicly disclose your personal information.
4. Exceptions to prior authorization for sharing, transferring, or disclosing personal information:
In the following situations, sharing, transferring, or disclosing your personal information does not require prior authorization:
1) Information you publicly disclose;
2) Related to national security or defense;
3) Related directly to criminal investigations, prosecutions, trials, and judgments, and executions;
4) Related directly to public safety, public health, or significant public interests;
5) Necessary to protect the life, health, and property safety of natural persons in emergency situations, but difficult to obtain your consent;
6) Other information that has already been legally disclosed, such as legal news reports, government information disclosures, etc.;
7) Other situations provided for by laws and regulations.
According to legal provisions, sharing, transferring, or disclosing de-identified personal information that cannot be restored or re-identified does not constitute sharing, transferring, or disclosing personal information. The storage and processing of such data do not require notification or consent from you.
4. Storage of Your Personal Information
1) Unless otherwise provided by laws, regulations, or regulatory authorities, we will only store your personal information for the duration necessary for the purposes stated in this privacy policy and within the time limits required by laws and regulations. After the expiration of the aforementioned period, if you do not contact us to delete your personal information, we will take all reasonable and necessary measures to continue to ensure the security of your personal information. In deciding the retention period for personal data, we will consider the quantity, nature, and sensitivity of the information, risks that unauthorized use or disclosure may pose, the purposes for processing this information, applicable legal provisions, and our regular business operations.
2) When we no longer need the data for our business or legitimate purposes, we will take appropriate measures to destroy or permanently anonymize the personal data.
3) We will store your personal information securely, including taking technical and organizational measures to protect your information from unauthorized access and illegal processing, accidental loss, damage, and destruction. However, neither data transmission over the internet nor electronic or physical storage methods can guarantee absolute security. Therefore, we cannot guarantee the safety of your personal information. You bear the risk of any such data transmission.
4) If you have a password to access any of our products, you are responsible for keeping that password confidential. Do not share your password with anyone. We are not responsible for any unauthorized transactions made using your personal data (including but not limited to your account and/or password). If you suspect unauthorized access, you should immediately change your password to a strong one.
5.Withdrawal of Consent and Deletion of Information
1) Withdrawal of Consent: Unless you submit a written request to withdraw your consent, your consent to the collection, use, and disclosure of your personal information will remain valid. If you need to withdraw your consent, you can contact us via email, online customer service, etc., and submit your request. You can withdraw your consent and ask us to stop collecting, using, and/or disclosing your personal information for any (or all) of the aforementioned purposes.
2) Deletion of Information: You have the right to request the deletion of your personal data. If you need to request the deletion of your personal data, you can contact us via email, online customer service, etc., and submit your request. Please note that once your personal information is deleted, it cannot be recovered.
3) Processing Time: After receiving your request to withdraw consent or delete personal data, we may need a reasonable amount of time to process your request, generally requiring 15 calendar days. If special circumstances require a longer processing time or other additional procedures and rules, we will provide you with further explanations.
4) Processing Impact: Please note that depending on the nature and scope of your request, we may not be able to continue providing our services. In such cases, we will notify you before completing the processing of your request. Please decide whether to make a request after understanding the potential impacts and your needs.
5) Revocation of Application: If you decide to cancel your withdrawal of consent or deletion request, please contact us via email, online customer service, etc.
6) Exceptions: Please note that if applicable law permits or requires the collection, use, and disclosure of your personal information without your consent, the withdrawal of consent or deletion request will not affect our rights to continue collecting, using, and disclosing personal data.
6. Accessing and Correcting Personal Information
1) Viewing Information: You can view your account basic information, including account, account ID, device, and device login information, as well as other personal information you choose to fill in, through the ��Account�� module in our game products, subject to specific game settings.
2) Copying, Correcting, and Supplementing Information: Some information can be directly copied, corrected, or supplemented using our game products through the ��Account�� module. If the information you need to copy, correct, or supplement cannot be operated through the ��Account�� module, you can contact us via email, online customer service, etc., and submit your request.
3) Processing Time: We may need a reasonable amount of time to process your request, generally requiring 15 calendar days. If special circumstances require a longer processing time or other additional procedures and rules, we will provide you with further explanations. If we are unable to process your personal data as you requested, we will inform you of the reasons we cannot do so.
4) Fee Charges: Please note that some requests may incur reasonable fees. If this is the case, we will inform you of the fees before processing your request.
7. Information about Children
1) We place a high priority on protecting the privacy of children and adolescents. Therefore, we generally do not collect or retain personal data or non-personal identification information from children under 13 years old. If you believe we have inadvertently collected personal data or non-personal identification information from children under 13, please contact us using the contact methods provided in this privacy policy. We will delete the relevant data after verification.
2) If you are a child or adolescent under 13 years old, please do not use our services. Children and adolescents under 13 are not allowed to create any accounts using our services.
3) If you are 13 years old or older, but are considered a minor in your country or region, please inform your guardian to read this privacy policy. You need to seek your guardian's consent and guidance before using our game services.
4) If you are the guardian of a child or adolescent who is 13 years old or older but still a minor, please read this privacy policy carefully. If you agree to this privacy policy, please take responsibility for your child's activities while using our services and supervise their activities. If you do not agree with the privacy policy, please do not allow your child to use our services.
8. International Transfers
We may transfer your information across borders to affiliated entities or other third parties. We may also transfer your information from your country or jurisdiction to other countries or jurisdictions around the world. Please note that these countries and jurisdictions may not have data protection laws identical to those in your jurisdiction, but we will take measures to ensure that adequate safeguards are in place to protect your information.
9. Other
1) Updates to the Privacy Policy: We reserve the right to modify the terms of the privacy policy at any time. When modifying terms, we may publish the revised content on the relevant webpage. If you do not agree with the modified content, you may stop using all services we provide. If you continue to use any services we provide, it will be deemed that you have accepted the revised content we provide.
2) Contact and Complaints: If you have any questions, comments, or suggestions regarding this privacy policy, or need to report complaints or violations related to the security of your personal information, you can contact us via our official email: customer_service@efunsea.com. Additionally, our contact address is Unit F, 12/F, Kaiser Estate, No. 41, Man Yue Street, Kowloon,Hong Kong.
3) Applicable Law and Jurisdiction: This privacy policy and any related actions are governed by the laws of the People's Republic of China, without regard to its conflict of laws principles. Any disputes arising from or related to this privacy policy shall be submitted to the Guangzhou Arbitration Commission for arbitration, which will be conducted in accordance with the arbitration rules in effect at the time of the arbitration application. The arbitration location shall be Guangzhou, Guangdong Province, People's Republic of China. The language used in the arbitration process shall be Simplified Chinese. The arbitration award shall be final and binding on both parties.
10. Supplementary Provisions (Specific Jurisdictions)
Additional Information for Residents of the European Economic Area (EEA) and the United Kingdom (UK). If you are in the EEA or the UK, the following additional information applies to you and supplements the above privacy policy.
1) Rights of Data Subjects. In addition to the information listed in the "Your Rights and Choices" section of the above privacy policy, you also have the right to:
A. Request that we restrict the processing of your personal data;
B. Exercise the right to data portability;
C. Object to the processing of personal data.
2) Legal Basis for Processing Your Personal Data. The legal basis for our collection and use of the information described in Section 2 of the above privacy policy is:
A. To establish and fulfill our contract with you (i.e., our terms of service) and to provide our services;
B. For the legitimate interests of us or our partners, provided that these interests are not overridden by your data protection interests and fundamental rights and freedoms, such as protecting our legal rights, pursuing or defending legal claims, and improving our services;
C. Based on consent when obtained separately;
D. To comply with our legal obligations under applicable laws and regulations;
E. To protect the vital interests of us or others (e.g., other players), such as preventing fraud and violations of our terms;
F. Although we do not generally collect sensitive or special categories of personal information, if we do so, it will be based on consent or other applicable legal grounds.
3) If you have any questions or need further information about the legal basis for processing your personal information or wish to withdraw your consent, please refer to the relevant sections of the above privacy policy.
4) Cross-Border Data Transfers.
A. As a global company, we may transfer your personal data to our affiliates, third-party service providers, and partners operating globally, which may be located outside your country (e.g., Singapore). The data protection laws of these countries may differ from those of your country.
B. When we transfer your personal information to countries outside the EEA and the UK, we rely on relevant "adequacy decisions" from the European Commission if those countries are formally recognized as providing an adequate level of personal information protection.
C. If the transfer is not subject to an adequacy decision, we have implemented appropriate safeguards to ensure that your personal information remains protected in accordance with this privacy policy. The safeguards we use include standard contractual clauses published by the European Commission on June 4, 2021, including the UK annex, and/or agreements permitted under Article 46 of the UK GDPR for international data transfers. These are the protective measures we take for the transfer of personal information between us and other companies. All companies must protect the personal information they process from Europe in accordance with EU data protection laws. Transferred personal information includes basic information such as your name or contact details, such as your email address.
5) Children's Notice. Our services are not directed towards or suitable for children. For the purposes of our services, a child is defined as (a) under 13 years of age, or if older (b) between 13 and 18 years old but not reaching the age at which valid consent under applicable data privacy laws is required for processing their personal information. We strive to adhere to various regional legal minimum age guidelines to determine the age at which children can access certain features of our services.
6) Data Protection Supervisory Authority. If you wish to lodge a complaint with the data protection supervisory authority in your country or region, please contact the relevant authority.
Additional Information for California Residents.California Consumer Privacy Act (CCPA). Under the CCPA, we need to provide the following additional notice to residents of California. According to this notice, personal information refers to information that can identify, relate to, describe, or is reasonably capable of being associated, or could be reasonably linked (directly or indirectly) to a specific consumer or household, or as defined by the California Consumer Privacy Act of 2018 (California Civil Code ��� 1798.100 to 1798.199) and its implementing regulations.
1) Personal Information Exclusions:
A. Information obtained from government records legally.
B. De-identified or aggregated information.
C. Other information excluded from the scope of the CCPA.
2) Categories of Personal Information Collected for Business Purposes:
A. Contact information and identifiers, including names, aliases, online identifiers, IP addresses, email addresses, or other similar identifiers.
B. Customer records, including names, phone numbers, and financial information (such as payment information and bank account numbers).
C. Commercial information, including products or services purchased or obtained.
D. Internet or other electronic network activity information, including browsing history, search history, and interactions with internet websites or applications.
E. Inferred information, such as consumer preferences derived from the above information.
3) As mentioned, to provide our services to you, we collect and process your personal data for one or more purposes, including:
A. Allowing you to access or limit your access to our services;
B. Providing you with the services you need and fulfilling our contractual obligations to you;
C. Analyzing and managing our services for system management, service security, fraud detection, verifying account ownership, archiving, and/or backup purposes;
D. Fixing errors or defects, improving our services, and responding to customer wishes and preferences, including language and location customization, personalized support and guidance, and other responses;
E. Developing new services or products and improving your experience;
F. Verifying and confirming payments;
G. Providing advertisements that may be relevant to your interests (you can enable or disable this feature in device settings as described below);
H. Communicating with you (including sending SMS and/or push notifications) and taking action against violations;
I. Personalizing your experience;
J. Keeping you informed about the latest product announcements and providing other information related to our services;
K. Providing software verification, upgrades, and management, and notifying you of special events;
L. Offering opportunities to participate in our surveys or activities;
M. Fulfilling our obligations under applicable laws and regulations, responding to government requests;
N. Establishing, exercising, or defending legal claims;
O. Analyzing, configuring, segmenting, merging, and/or updating all collected data (whether aggregated or personalized) to improve service quality and provide a better experience;
P. Protecting the integrity, information security, and financial security of our services, complying with legal obligations, and enforcing compliance with the terms or other restrictions on your use of our services;
Q. Tracking your processes on our website and applications to verify you are not a robot and to optimize our services;
R. And/or for any other purposes specifically notified to you when collecting information.
4) Collection of Personal Information. In the twelve months prior to the last update of this notice, we collected personal information from the following categories of sources:
A. You/your device: Information directly provided by you or your device.
B. Affiliates.
C. Advertising networks.
D. Analytics providers.
E. Operating system/platform providers: Operating systems and platforms.
F. Social networks.
G. Partners: Business partners.
H. Public information: Publicly accessible sources.
5) If you are a California resident, you may exercise the following rights:
A. Request a copy of the personal information we collected about you in the past 12 months.
B. Request details about the categories of personal information we collected, the categories of sources for that information, the business or commercial purposes for collecting that information, and the categories of third parties with whom we share that information.
C. Request the deletion of personal information we collected about you, subject to certain exceptions.
Additional Information for Residents of Turkey . If you are in Turkey, the following additional information applies to you and supplements the above privacy policy.
1) Data Collection and Processing. Your personal data will only be processed in accordance with data protection laws, particularly the Turkish Personal Data Protection Law (Law No. 6698, "DPL").
2) Categories of Personal Data Collected and Their Sources are described in the "Data We Collect" section of the global privacy policy.
· Article 5, Paragraph 2 (f)
· Article 5, Paragraph 2 (c)
· Article 5, Paragraph 1
3) Your Rights. Under Article 11 of the DPL, you have the following legal rights regarding your personal information data held by us. As a data subject receiving services from the Republic of Turkey, you may apply to the data controller (and within the limits allowed by applicable laws and regulations):
A. To learn whether your personal data has been processed;
B. To request information about whether your personal data has been processed;
C. To understand the purpose of processing your personal data and whether it is being used for that purpose;
D. To know the third parties to whom your personal data has been transferred domestically or abroad;
E. To request correction of incomplete or inaccurate data (if any);
F. To request deletion or destruction of your personal data in accordance with Article 7 of the DPL;
G. To object to results generated about you through automated systems only;
H. To claim compensation for damages arising from the unlawful processing of your personal data.