Privacy Policy

Last Updated: October 15, 2024

Dopuz Games (hereinafter referred to as "we") fully respects the privacy of our users (hereinafter referred to as "you") and is committed to protecting your privacy. This privacy policy aims to help you understand how we collect, use, store, and protect your information and how you can control this information. Please be reminded that your act of clicking to agree with this privacy policy indicates your acceptance to our rules and policies concerning your personal data and your approval to grant us the right to collect, process, use, and store your personal data. As stated in this privacy policy, you are not to use our service if you do not agree with this privacy policy.

For the purpose of complying with relevant laws and regulations on data protection, the data controller of your personal information related to game services is Dopuz Games. You can contact our data protection officer to request the deletion of your data through the contact information provided by us. We will contact you within 15 business days.

This privacy policy will help you understand the following content:

1. How Do We Collect and Use Your Personal Information?

2. How Do We Share, Disclose or Transfer Your Personal Information?

3. How Do We Store Your Personal Information?

4. How Do We Protect Your Personal Information?

5. How Do We Manage Your Personal Information?

6. How Do We Process Personal Information Of Minors?

7. How Do We Use Cookies and Similar Technologies?

8. Updates and Notifications of Privacy Policy

9. Contact and Complaints

10. Supplementary Appendix - Special Jurisdictions

 

1. How Do We Collect and Use Your Personal Information?

1.1 The information you proactively provide

1.1.1 When using our product and/or services, you can choose to register an account to log in or enter without an account. When you register an account, you can use an account from a third party, such as Facebook, Google and Line, to log in to our product. In doing so, you are required to provide us with your third party account's avatar, username, account ID, and other information. You can also choose to directly enter our product as a guest.

1.1.2 The information you proactively send to us includes personal information, which includes and is not limited to your account, E-mail address, phone number, device ID, system language, APP version, which you may be required to send to us in situations where you desire to provide us with feedback concerning various problems, such as account management and payment in the course of using our products and/or services. Your act of providing us with such information indicates your consent to our collecting, using, managing, and storing your information in accordance with this privacy policy.

Please be reminded that all information we collect will be anonymized and de-identified.

1.2 The information we collect and use and permissions we request for

1.2.1 To ensure that you can normally use our products and services while realizing the analysis and statistics of product data and enhancing your device account's security, we or the third parties we cooperate with will collect your device ID, device name, device type, and version, system version, IP address, application ID, Google Advertising ID（GAID/AAID） or other identifiers, user behaviours, application interactions, network connection status, network access method and type after your consent is obtained. Refusing to grant permissions to us or the third parties we cooperate with to acquire the above said information might affect your normal usage of our App or bring corresponding restrictions while you are using our App. Please be reminded that we might collect your [IMEI, IMSI, MAC address] if the system version of your android device is below 6.0. Therefore, we strongly advise you to update it to 6.0 or a higher version.

1.2.2 In order to save players' game data, images, and other information required for using our feedback feature, we might request permission for external device storage (access application and write to APP external storage space). But we will ask for your separate consent when exercising this permission.

1.2.3 When you are using our services, we need to check your network connection status to send alerts to you on data usage for the purpose of saving your data.

1.2.4 In order to provide you with a more diverse experience, we sincerely request your permission for our application to access the following permissions, so we can obtain your Google Advertising ID for ad attribution and analysis:

l Allow the application to access Advertising ID

l Allow the application to receive advertising attribution information

l Allow the application to access advertising topic information

l Allow the application to access Google Play services ads.

1.2.5 Request permission for the application to use Google Play Billing Service, which is used for purchasing in-app items or subscription services.

1.2.6 Request permission for the application to create foreground services, in order to provide services to user programs.

1.2.7 Request permission for the application to publish notifications, used for alerting or informing the user.

1.2.8 Request permission for the application to receive messages from Google Cloud Messaging services, used to receive real-time messages and notifications.

1.2.9 Request permission for the application to control phone vibration, used to provide haptic feedback or alert the user.

1.2.10 Request permission for the application to keep the device awake, preventing the device from entering sleep mode.

1.2.11 Request permission for the application to bind to the Google Play store’s install referrer service, used to understand the channels through which users download and install applications.

1.3 The information third parties we cooperate with collect and use and permissions they request for

1.3.1 You can acquire virtual products (used for below-said products only) related to our products and related services, including game items, and in-game Remove Ads service via purchasing. The above said payment service is provided by Google. We will only receive result verification information confirming that you have completed the payment process from the Google payment service provider, then provide corresponding products and services to you. If you wish to learn the specific rules as to how Google service provider collects personal information, please read Google's privacy policy.

1.3.2 Products not integrated with third-party services: For these products, we do not incorporate third-party services; thus, no third party will collect your personal information during your use of these products.

1.3.3 Products integrated with third-party services: In order to provide you with better products or services, we have incorporated third-party services within our products (including but not limited to data analysis, third-party payments, advertising, etc.). Please be assured that we do not share your personal information with these third parties. These third parties act as independent data controllers, deciding on their own how to collect, use, and process your personal information. We will make reasonable efforts within the scope of this policy to monitor the actions of third parties, for example by stipulating data processing legality and individual processing responsibilities when signing agreements with them. Below are links to the privacy policies of third-party platforms we work with; please read the list carefully, and we encourage you to look at their privacy policies to learn more about their data handling practices.
The following includes SDKs and related information integrated within our products on the Google Play market, please review them. 

【Legal Basis for Collecting and Using Information】

To provide our services, we collect and process your personal information for one or more purposes as detailed in the first part of this policy. These purposes have a lawful basis. Through this policy, you can understand the legal grounds under which we collect and use your personal information in various situations.

l Data Processing for Contractual Performance
When we are about to enter into or have already established a contractual relationship with you, we process your personal data as necessary to provide the services you have requested. Additionally, we might process your data to quickly respond to your inquiries related to the services.

l Data Processing to Uphold Legitimate Interests
We may collect your information when necessary to maintain our legitimate interests or those of a third party. For example, to ensure the services we provide are safe and stable and comply with our terms and policies, we must collect such information to protect our legitimate rights.

l Compliance with Legal and Regulatory Obligations
To comply with legal or regulatory requirements, we may need to provide your personal information to government agencies or regulatory bodies. This is to satisfy the statutory queries or reporting requirements of government or regulatory authorities.

l Consent Under Legal Requirements
In jurisdictions where applicable laws and regulations require user consent, we will use your personal information based on your explicit consent following legal requirements. This primarily applies to countries/regions where laws require user consent for using their personal information. For all data processing activities reliant on user consent, you can contact us at any time via email to withdraw your consent.

If you have any questions or suggestions regarding the above content, you can write an email clearly expressing your concerns. Our data protection officer can be contacted at DopuzGames-Team@hotmail.com.

2. How Do We Share, Disclose or Transfer Your Personal Information?

You have the right to know if your personal information is shared or “sold” third parties. We solemnly declare we do not sell your personal information in any way.

When sharing, transferring, and revealing your personal information, we stick to three principles, minimum, necessary, and legal. Under no normal circumstances will we share, transfer, sell or reveal your personal information to outsiders. But, within the confines of applicable laws and regulations, we might share, transfer and reveal your personal information under the following circumstances:

2.1 We are under a legal obligation or this is a mandatory requirement from relevant departments.

2.2 We will reveal it to consultants, law enforcement agencies, and judicial and regulatory authorities to protect the legal rights and interests of you or other users or other individuals' lives, property, and other legal rights within the confines of laws and regulations.

2.3 When structural changes, including M&A and reorganization, take place, we may need to transfer your personal information to the third parties who acquire or inherit part or all our assets or stocks. If the changed entity needs to change the purpose of using your personal information, we will require it to solicit your explicit consent first.

You have the right to object to our sharing, transferring, and disclosing of your personal information. You can exercise your right by contacting us via email at DopuzGames-Team@hotmail.com. We will respond to your request upon verifying your identity.

3. How Do We Store Your Personal Information?

3.1 In order to protect your personal information, the information that we collect will be stored according to relevant privacy laws and regulations in related countries. We will also store collected personal information inside or outside of the country or region where we operate within the permitted confines of local laws and regulations.

3.2 If we cease to provide services or operate, we and the third parties we cooperate with will stop collecting your personal information in time and shall abide by relevant laws and regulations to inform you in advance and delete or anonymize your personal data after we cease to operate or provide services unless there are laws, regulations or regulatory authority that demand otherwise.

4. How Do We Protect Your Personal Information?

4.1 Data Protection Capability

4.1.1 We will apply every measure reasonably possible to ensure that we do not collect personal information unrelated to our services.

4.1.2 We apply encryption technologies normally required in the industry, anonymization, and other reasonable measures to encrypt and store your personal information and segment it. We will also use strict data access permission control to protect your personal data from unauthorized usage.

4.1.3 We are enhancing our employees' security consciousness and recognition of the importance of protecting information by establishing data security management practices and applying strict data access controls.

4.1.4 We will only allow necessary personnel to access personal information and have set strict access control and monitoring mechanisms. We also require all personnel that might access your personal information to respect corresponding obligations to be discrete, failing of which might cause legal responsibilities or terminate his/her relation with us.

4.1.5 We will use strict security systems and standard security technologies and programs in the industry to ensure that your personal data will not be lost, leaked, damaged, or abused.

4.1.6 The internet environment is not 100% safe. We will try our best to protect your personal information. When your personal information is leaked, damaged, lost, or involved in other security events, we will, in accordance with laws and regulations, inform you in time of the basic situation of the security event and its possible repercussions, the measures we have taken or will take, advice for you to independently prevent and decrease risks, and remediation measures suitable for you. We will also inform you of information related to this event via notifications. When it is difficult to inform all involved users, we shall choose a reasonable and effective way to make an announcement.

4.2 Personal Data Protection Advice

4.2.1 When you obtain virtual products related to our products via purchasing, the transaction will take place via a third party payment service provider. You will then inevitably disclose to this provider or a potential transaction provider your information, including contact information, bank account, or email address. Please protect your information by providing it to others only when it is necessary.

4.2.2 If we discover that you are utilizing our applications, services, and their related information for fraud or illegal activities, we will take suitable measures which include but are not limited to suspending or terminating your access to our application or services.

5. How Do We Manage Your Personal Information?

Under applicable laws and regulations, as a user of our services, you may have the following data protection rights and the right to withdraw your consent.

 

If you wish to exercise any of the following rights, or other statutory data subject rights granted to you by relevant laws and regulations, please contact us via the email address provided in the “Contact and Complaints” section: DopuzGames-Team@hotmail.com to make your request.

To ensure the security of your personal data, we may require you to provide additional verification information before processing your request. Please note that in certain statutory circumstances, we may refuse to comply with your request in accordance with relevant laws and regulations. Furthermore, if your request is deemed manifestly unfounded or excessive, we may charge a reasonable fee for processing your request according to applicable laws.

5.1 Right to access and be informed about personal information
You have the right to access the personal data we hold about you and are entitled to obtain a copy of the personal data currently being processed. However, you must submit a verifiable request using the contact information provided in the “Contact and Complaints” section below.

5.2 Right to correct personal information
While processing your personal data, we implement appropriate measures to ensure the accuracy and up-to-dateness of this data to fulfill the purposes for which it was collected. If you discover any inaccuracies or incompleteness in your personal data, you are fully entitled under relevant laws and regulations to request us to correct this inaccurate information.

5.3 Right to delete personal information
Pursuant to relevant laws and regulations, when there is a lawful basis for deleting personal data, you have the right to request the deletion of your personal data. You must submit a verifiable request using the contact information under “Contact and Complaints”, namely DopuzGames-Team@hotmail.com.

Please note that if you decide to delete this data which is essential for our services, its removal could affect your use of our services.

5.4 Right to restrict processing of personal information
In certain specific situations, you have the right to request that we suspend processing your personal information, unless it is necessary to retain the data. For this, you need to submit a verifiable request to the contact details listed under “Contact and Complaints”.

However, if data protection law provides us with a lawful basis to continue processing information, such as responding to legal disputes or protecting the rights of others, we may continue or restart processing your information. Once we suspend processing your information at your request, we will take reasonable steps to inform all known third parties who have access to your personal information to ensure they also follow the suspension directive.

5.5 Right to portability of personal information
Upon your request, we will provide a copy of the personal data you provided to us. When conditions allow, we will transfer data to a third party in any feasible manner upon your request, unless legally restricted or not permitted due to the protection of other individuals’ rights and freedoms. If you wish to exercise your right to data portability, you must submit a verifiable request to the contact details listed under “Contact and Complaints”.

5.6 Right to object to processing of personal information
You have the right to object to the processing of your personal data and should submit a verifiable request to the contact details provided in “Contact and Complaints”.

5.7 Right to withdraw consent
If we have collected and processed your personal information with your consent, you can withdraw your consent according to applicable laws. However, please note that withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal nor does it hinder further processing of your personal data based on legal grounds other than consent. You should submit a verifiable request to the contact details listed under “Contact and Complaints”. Withdrawing your consent may affect the functionality dependent on explicit consent.

5.8 Account cancellation
If you wish to cancel your product account (if applicable), you must submit a verifiable request to the contact listed under “Contact and Complaints”. Please note that once an account is canceled, it cannot be restored; please proceed with caution.

Once your account cancellation request has been processed and you decide to cancel the account, we will cease providing all related services and manage your personal information appropriately (e.g., deletion or anonymization) according to your instructions and applicable laws, unless otherwise stipulated by laws and regulations.

5.9 Right to lodge a complaint
You have the right to complain to a data protection authority about our collection and use of your personal data. However, we suggest contacting our data protection officer at DopuzGames-Team@hotmail.com first, as this may help us resolve your complaint more quickly. For more information, please contact your local data protection authority (if applicable).

6. How Do We Process Personal Information Of Minors?

6.1 According to relevant laws and regulations, minors under the age of 16 should read this privacy policy in the company of parents or legal guardians. Under no circumstances are minors allowed to use our services without parents' or legal guardians' consent to this privacy policy. Please contact us if you have questions.

6.2  Please be reminded that we will not intentionally collect or solicit personal data about minors under the age of 16, or direct them to interest-based advertisements, or intentionally allow such people to use our services. If you are a minor under the age of 16, please do not send us any personal data about you, including your name, address, phone number, or email address. Minors under the age of 16 cannot provide any personal data. If we learn that we have collected any personal data about minors under the age of 16, we will apply every reasonable method to delete that data. Please contact us if you believe that we might have data from or related to minors under the age of 16.

6.3 Please be reminded that the definition of a minor varies in different nations. In order to make sure that minors' information is properly and safely protected, we have set the age limit at 16 according to laws and regulations in relevant nations. Please contact us at DopuzGames-Team@hotmail.com if you have questions.

7. How Do We Use Cookies and Similar Technologies?

We use Cookie and similar technologies for the purpose of providing you with better products and/or services. With the help of these advanced technologies, we are able to track your game progress and learn about your game info so as to provide you with a smooth and high-quality user experience. We shall not apply the above-said technology for any other purpose that is not listed in this policy. Please understand that certain services can only be achieved with these above-said technologies. If your device or related program permits, you can turn off or delete the above-said technologies by changing settings or visiting those technology providers' websites. But this might affect your experience with our products/services.

8. Updates and Notifications of Privacy Policy

8.1 In order to provide you with better service, our products, and their related services will update and iterate from time to time. We will also update this privacy policy without depriving you of any rights you have in this current effective privacy policy. We will not make unauthorized access without your explicit consent.

8.2 We reserve the right to change this Privacy Policy at any time. We will notify users on this page and possibly in this application or by any available means where technically and legally feasible. It is strongly recommended that you check this page frequently and refer to the last updated date listed in this privacy policy.

9. Contact and Complaints

DoPuz Games is your data controler. You can contact it at DopuzGames-Team@hotmail.com.
Please contact our data protection officer if you have any questions or suggestions for this privacy policy in the course of using our products and/or services. We will contact you within 15 business days once your user identity is verified. 

Data Protection Officer (DPO) : DoPuz Games;

Contact Information: DopuzGames-Team@hotmail.com

10. Supplementary Appendix - Special Jurisdictions

10.1 Additional Information for California Residents
If you are located in California, in addition to the privacy policy mentioned above, the following additional information also applies to you.

The definitions of “personal information” and “sensitive personal information” in this additional section are implemented in accordance with the provisions of the “California Consumer Privacy Act of 2018” (as amended by the “California Privacy Rights Act of 2020”, hereinafter referred to as “CCPA”). Any information not included within the scope of CCPA is not covered here.

In the past 12 months, we have collected and used your personal information within the scope described in Part One, “How Do We Collect and Use Your Personal Information”, of this policy. During this period, we did not share, sell, or disclose your personal information to any third party without authorization.

In the past 12 months, we have not sold or shared the personal information of California residents as defined under “sale” and “sharing” in the CCPA, and we have not sold or shared the personal information of users under the age of 16. We safeguard your right to be informed, and you have the right to know whether your personal information has been sold or shared. You have the right to refuse the sale or sharing of your personal information, and you can email us at DopuzGames-Team@hotmail.com clearly indicating your refusal to sell or share your personal information.

In the past 12 months, we have not collected any of your sensitive personal information. Unless necessary to fulfill reasonable expectations of an ordinary consumer and provide essential services, we will not use sensitive personal information for any other purpose.

We retain your personal information only for as long as necessary to achieve the collection purposes, unless a longer retention period is required by relevant laws and regulations. These purposes include, but are not limited to, those described in the first part of this policy, compliance with legal obligations, maintaining internal records, fulfilling contractual terms, and resolving any disputes that may arise.

Data Subject Rights:

· Request that we disclose free of charge the copies of your personal information pertaining to the 12 months prior to your request;

· The right to request information about the categories of personal information we collect, the categories of sources from which the personal information is collected, the purposes for collecting your personal information, the categories of third parties to whom your personal information is disclosed, the categories of personal information disclosed (if applicable), and the purposes for disclosing your personal information, as well as the specific personal information we have about you;

· Request that we delete personal information collected from you, unless an exception recognized by the CCPA applies;

· Request that we correct inaccurate personal information we hold about you;

· Be free from unlawful discrimination for exercising your CCPA rights, including receiving different levels or quality of goods or services, or being denied goods or services, although certain limitations apply;

In certain circumstances, you have the right to restrict using any category of sensitive personal information. As noted, we do not collect or attempt to obtain sensitive categories of personal information;

In certain situations, you have the right to opt-out of automated decision-making related to your personal information.

Under the provisions of the CCPA, we commit to processing all relevant requests within 45 days after receipt and verification; however, if for special reasons an extension of time is needed, we may extend it by an additional 45 days and notify you promptly of the specific reason for the delay.

Under the CCPA, you may exercise these rights yourself or designate an authorized agent to act on your behalf. Authorized agents can submit access or deletion requests on your behalf by sending a written authorization signed personally by you, using the contact information provided in the “Contact and Complaints” section. We may still require you to verify your identity directly and confirm that you have granted authorization to the agent to submit the requests.

If you have any questions about this section or want to learn more, please feel free to contact our data protection officer and clearly state your inquiry. We are more than willing to assist you, discuss your concerns, and ensure that you have a comprehensive and accurate understanding of our privacy policy and data handling practices.

 

10.2 Additional Information for Residents of the European Economic Area (EEA) and United Kingdom

If you are located in the European Economic Area (EEA) or the United Kingdom (UK), in addition to the privacy policy mentioned above, the following additional information also applies to you.

The definitions of “personal information” and “sensitive personal information” in this additional section are implemented according to the provisions of the General Data Protection Regulation (GDPR). Any information not within the scope of the GDPR is not covered here.

Data Subject Rights:

l Right to access: According to regulations, you have the right to request that we provide you with information about whether we hold any of your personal information.

l Right to rectification: You have the right to request that we correct any inaccurate data about you.

l Right to erasure: In accordance with relevant laws and regulations, when there is a lawful basis for deletion of personal data, you have the right to request the deletion of your personal data.

l Right to restrict processing: Request that we restrict the processing of your personal data.

l Right to data portability: Upon your request, we will provide a copy of the personal data you have provided to us, and under permissible conditions, we will transfer this data to a third party in any feasible manner, unless legally restricted or disallowed due to considerations to protect other individuals’ rights and freedoms.

l Right to object: In certain cases, you have the right to object to the processing of your personal data.

l Right to withdraw consent: If we have collected and processed your personal information with your consent, you can withdraw your consent according to applicable law.

If you wish to exercise the above rights, please contact our data protection officer using the contact details provided in the “Contact and Complaints” section.

When we transfer your personal information outside of the EEA and UK to countries or regions, which have been formally recognized as providing an adequate level of protection for personal information, we rely on the European Commission’s adequacy decisions (where applicable). If the transfer is not governed by adequacy decisions, we have put appropriate safeguards in place to ensure your personal information is protected according to this privacy policy.

 

10.3 Additional Information for Virginia Residents

If you are located in Virginia, in addition to the privacy policy mentioned above, the following additional information also applies to you.

The definitions of “personal information” and “sensitive personal information” in this section are implemented according to the provisions of the “Virginia Consumer Data Protection Act” (VCDPA). Any information not within the scope of the VCDPA is not covered here.

Currently, we are not collecting your sensitive personal information. We commit to obtaining your explicit consent before collecting any sensitive data from you.

Data Subject Rights:

l Right to access: You have the right to access your personal data, understand the purposes for data collection, the categories of data, the parties with whom the data is shared or sold, and information about our data practices.

l Right to delete: You have the right to request the deletion of your personal data, except where otherwise provided by law or regulation.

l Right to correct: You have the right to request that we correct any inaccurate personal data concerning you.

l Right to non-discrimination: When you exercise your rights under the law, you are entitled to protection from unlawful discrimination, including the denial of goods or services or the provision of goods or services at a different level or quality.

If you wish to exercise the above rights, please contact our data protection officer using the contact details provided in the “Contact and Complaints” section.

If you wish to review or challenge any decision made regarding your request for exercising rights under the VCDPA, you are welcome to contact the data protection officer at any time.

 

10.4 Additional Information for Residents of Brazil

If you are located in Brazil, in addition to the aforementioned privacy policy, the following additional information also applies to you.

The definitions of “personal information” and “sensitive personal information” in this section are implemented according to the provisions of the Brazilian General Data Protection Law (Lei Geral de Proteção de Dados Pessoais, abbreviated as “LGPD”). Any information not within the scope of LGPD is not covered here.

By accepting this policy (including the content of this additional information section), you agree that we may collect, use, store, transmit, and process your personal information according to the terms described in our privacy policy. This authorization also covers the disclosure of your personal information to third parties and the transfer of your personal information outside of Brazil.

Data Subject Rights:

l Right to be informed and access: You have the right to access your personal data and understand the purposes of data collection, categories of data, entities with whom the data is shared or sold, and information about our data practices.

l Right to correct: You have the right to correct any inaccurate personal information we hold about you.

l Right to restrict processing: For data that you believe is unnecessary or excessively processed, you can request that we anonymize, restrict access, or delete such data. Additionally, if you find our data processing activities do not comply with LGPD, you are entitled to request us to take appropriate corrective actions.

l Right to data portability: You have the right, subject to business and industrial secrecy and further specifications by ANPD, to request the transfer of your data to another service or product provider according to your instructions.

l Right to deletion: You have the right to request the deletion of personal data processed with your consent, but exercising this right is subject to limitations under LGPD. Contact our data protection officer for more information on this.

l Right to refuse processing: In specific situations, you have the right to refuse certain types of personal information processing activities, require us to stop processing your personal data, and understand the consequences of refusing processing.

l Right to withdraw consent: You have the right at any time to withdraw the consent previously given to us for processing your data. Upon withdrawal of consent, we will not continue to use your data in any way unless there is another legal basis for processing.

If you wish to exercise the above rights, please contact our data protection officer using the contact details provided in the “Contact and Complaints” section.

Minors (under 18 years) are not to use this service without explicit consent from parents/guardians. We do not intentionally collect any personal information from minors. If you believe that we might hold personal information of a minor under 18 without consent of a parent/guardian, please contact our data protection officer immediately. Upon verification, we will take necessary steps swiftly to ensure that the relevant data is deleted.