Privacy Policy

INTRODUCTION

This privacy policy informs you of your choices and our practices regarding any personal information you provide to us. Your use of a mobile game (“Game”) distributed by Happy Elements S.à r.l (“Happy Elements”, “we” or “us”) involves the collection and use of your personal information. It is important for you to understand how this happens and how you may control it.

In order to use a Game (the “Game Services” or “Services”), you must accept our rules and policies regarding your personal information and consent to us collecting, processing, using and storing your personal information, as described in this policy. If you change your mind in the future, you may withdraw your consent to use of your personal information in accordance with this policy.

If you have any comments, questions or complaints regarding the processing of your personal information, you can contact us at Privacy@happyelements.com.

 

The Types of Personal Information We Collect and How We Collect It

We will collect and use the following information about you:

•       Information you give us. You give us information about you when you:

o   register for a Game, including your nominated nickname and selected avatar; information we import from your connected social media account (Facebook) in order to set up your profile, including your name on your social media profile and profile picture; and ID on social media accounts (“Social ID”) ( collectively “Registration Information”); and

o   set up or change your profile for a Game, including information you voluntarily provide in order to customize gameplay, such as other nickname or Open ID ( collectively “User Profile”).

•       Information we collect about you. We automatically collect certain data from you when you use the Game and Game Services, including:

o   device information, including device ID, device type, operating system, CPU, RAM, IP address and MAC address ( collectively, “Device Information”);

o   information about your use of the Game, such as dates/times of actions and physical location;

o   your communications with other users in the Game, such as in-game messages; and

o   your interactions with us, for example when you use in-app support.

 

Cookies

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Services. Cookies are small files which, when placed on your device, enable us to identify you (e.g. by device information, IP address or nickname) in order to provide certain features and functionality.

You have the option to permit installation of such Cookies or disable them. You may configure the cookie settings of your device to accept all cookies, to provide notice at the time of installation of cookies (with option to accept or reject them), or to refuse to accept all cookies. However, if you refuse to install cookies, the Game may be unable to operate as designed.

 

Children

If you are located in the European Economic Area and under the age of 16, you may not use the Service without parental consent (which your parents must provide as part of the Service registration process).

 

How We Use Your Personal Information, and Legal Basis for Use

We will use your personal information in the following ways:

•       Registration Information: We use Registration Information to set-up user accounts, allow users to log-in to the Game and provide Services to users.

•       Device Information: We use this information to provide and improve the Game Services, including to allow users to download and install the Game on their devices; to record and keep track of requests from users of the Game; to detect the user network and device status when the user is playing the Game; and to correct bugs or errors that occur when the user is playing the Game.

•       Physical Location: We use this information to provide some location-based services such as forming a team with people nearby.

•       Social ID: We use this information to share certain content on social media.

•       User Profile: We use this information to provide customized services to users such as a personal information page.

•       Game Data (e.g. Level, Score, in-game messages, etc.): We use this information to provide Services as part of the Game.

We use Registration Information, Physical Location, Social ID and User Profile based upon your consent to this Privacy Policy. You have your right to withdraw your consent at any time by cancelling your account and/or exercising the rights set out under “Your Rights” below. Our use of Device Information, Game Data and Payment Information is necessary to perform our contract with you to provide the Game and Game Services.

 

How We Store and Share Your Personal Information

In order to provide the Game and Game Services to you, it is necessary for us to share your personal information (on a confidential basis) with certain third parties outside your home country. Your personal information will be accessible from and processed on our servers, which are located in Canada, the People’s Republic of China (“PRC”) and Taiwan. The location(s) of the servers used to provide the Game and Game Services to you depend upon your location.

We share your personal information with group companies of Happy Elements, as well as certain third parties inside and outside your country, including:

•       third parties that provide services in support of the Game, including:

o   Chunghwa Telecom (located in Taiwan) and Tencent Cloud (located in Canada), which process download and installation information, account set-up and log-in information, user log information, purchase information, notification push information, social sharing information, for the purpose of hosting the Game;

o   Apple and (located in the United States), Google (located in the United States) and Fortumo (located in Estonia), which process information for in-app purchases;

•       law enforcement agencies, public authorities, judicial bodies and certain private-sector organizations, if we are legally required to do so, or if we believe that such sharing is reasonably necessary to:

o   comply with a legal obligation, process or request;

o   enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof;

o   detect, prevent or otherwise address security, fraud or technical issues; or

o   protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection); and

•       any third party that acquires all or substantially all of us or our business, provided that ongoing use of your personal information by such a third party will remain subject to this privacy policy.

 

Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. Our group companies have information security and access policies that limit access to our systems and technology. We also protect data through the use of technological protection measures such as encryption. Your personal information will remain subject to our technical and organisational controls and our policies and procedures (including this Privacy Policy).

Unfortunately, the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the information transmitted to our services; any such transmission of your information is at your own risk. We rely on you to select secure passwords, to protect those passwords, and to use appropriate security software on you devices.

 

Retention of Your Personal Information

We will retain your personal information for the lifetime of your use of the Services (i.e. until account deletion in accordance with your request). In-game messages are stored for up to 15 days (unless deleted earlier by the user).

In certain cases, personal information may be required to be retained for longer periods under applicable laws. If you request us to erase your personal information (see “Your Rights” below), we will do so in accordance with local laws.

When erasing personal information, technical measures will be taken to make the personal information irrecoverable.

 

Your Rights

You have the following rights in relation to the personal information we hold about you:

•       Access: You have the right to access personal information we hold about you, how we use it, and who we share it with.

•       Correction: You have the right to correct any inaccurate personal information that we hold about you.

•       Erasure: You can request deletion of your account, or removal of certain personal information. Your right to erasure may be limited where we have another legal basis to retain the information, or where the information has been made public.

•       Portability: You have the right to receive a copy of certain personal information we process about you in machine-readable format, including to transfer such information to a third party (please identify any such third party in your request). Portability requests are subject to technical feasibility.

•       Restriction of Processing: You may request that we stop processing your personal information (a) while we verify whether your personal information is accurate or (b) in certain circumstances where you wish us to stop processing and retain information rather than deleting it.

•       Objection: You may object to processing of your personal information for marketing purposes, and if you do so we will stop any marketing to you. This right does not apply to service-related announcements, such as notices of temporary suspension of Game access for maintenance, or security, privacy or administrative communications.

To exercise any of these rights, please contact us at Privacy@happyelements.com. We will respond to such requests without undue delay and generally within one month (this may be extended by two further months in certain circumstances). We may ask that you provide further information or complete a form in connection with a request. We will work with third parties to which we have transferred your personal information as appropriate to fulfill your request. We may not be able to fulfill requests that would interfere with rights of others (e.g., where providing personal information would reveal information about another person) or our rights (e.g. where we have an independent basis for processing, or the information includes our trade secrets or intellectual property).

 

Contact and Complaints

Happy Elements S.A R.L is the data controller under this Privacy Policy, and its address is 39, Avenue John F. Kennedy, L-1855 Luxembourg. If you have questions or wish to make a complaint about how we process your personal information, please contact us at Privacy@happyelements.com and we will endeavor to deal with your request as soon as possible. You may also have the right to complain to data protection authorities in the country in which you live or work.

 

Changes

If we make any material changes to this policy, we will post the updated policy here and notify our users.

 

Effective Date:2018.5.25