Death Coming Privacy Policy
SUMMARY
What information do we collect about you?
We collect information when you play the Game. If you play the Game, we collect your unique vendor identifier, player name, device information and game data, such as your game scores. [More Information]
How will we use the information about you?
We use your information to provide the Game to you. We use your information to identify you, keep track of your progress in the Game and to support and improve the Game. [More Information]
Who do we share your information with?
In certain situations, we may share your information as required by law.] [More Information]
Where do we process your information?
Our servers are located in the People’s Republic of China. Our support, engineering and other teams are located in our offices in the People’s Republic of China (including Hong Kong). [More Information]
How long do we keep hold of your information?
We general store your data for the period during which you have an account, with some exceptions. [More Information]
How can I exercise my rights over my information?
You may have rights to access, receive copy of, or delete, your data or restrict or object to our processing of, your data. [More Information]
Dispute Resolution
If you have any concerns or complaints, please contact us [here].
How will we notify you of changes?
If there are any significant changes to this privacy policy we will include a prominent notice on the Game. [More Information]
Contact Information
Data Controller: Sixjoy Hong Kong Limited Email: deathcoming@thenextstudio.net
EU Representative: Tencent International Service Europe B.V. Email: eudataprotection@tencent.com
Data Protection Officer: dpo@thenextstudio.net
INTRODUCTION
This privacy policy informs you of your choices and our practices regarding any personal information you provide to us. Your use of the mobile, PC and web game Death Coming (“Game”) 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.
When you contract to use the Game (the “Game Services”), you accept our rules and policies regarding your personal information and you expressly consent to us collecting, processing, using and storing your personal information, as described in this policy.
You acknowledge that you have read and understood this privacy policy. If you do not agree with this privacy policy, you must not use the Game Services. If you change your mind in the future, you may withdraw your consent to use of your personal information in accordance with this policy.
Sixjoy Hong Kong Limited (“we” or “us”) is a company registered in Hong Kong with its office located at Room 907, Wing Tuck Commercial Centre, 177-183 Wing Lok Street, Hong Kong. Our representative in the EU for the purpose of EU data protection laws is Tencent International Service Europe B.V., a company registered in the Netherlands. Their registered address is Strawinskylaan 3127, 8th floor, 1077 ZX Amsterdam, the Netherlands and can be contacted at eudataprotection@tencent.com. Our data protection officer can be contacted at dpo@thenextstudio.net. The data controller for the purpose of EU data protection laws is Sixjoy Hong Kong Limited.
If you have any comments, questions or complaints regarding the processing of your personal information, you can contact us at dpo@thenextstudio.net. .
SECTION 1: WHERE WE ARE A DATA CONTROLLER
The Types of Personal Information We Use
This section describes the different 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:
o when you download the Game, including your unique vendor identifier such as your Apple ID, Steam ID or Google Play ID, depending on which platform you use to download the Game.
o when you edit your player name in the Game (which is randomly generated when you first use the Game); and
o when you access the Game, including your IP address, your device version and identification number.
· Information we collect about you. We automatically collect certain data from you when you use the Game, including your IP address and device information (such as application version, network type, OS version, display card and CPU, memory storage) and information regarding your use of the Game, such as date and time stamps of actions. We also collect and store your data each time you interact with us, for example, when you communicate with us by email or through the community forum for the Game on Steam.
· Information you generate and display in the course of using the Game Services. You may provide or generate additional information when you play the Game, such as your game scores, number of times you have played a certain level, and duration spent playing certain levels.
Cookies
Cookies are small files which, when placed on your device, enable us to provide certain features and functionality (“Cookies”).
You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event of your refusal to install cookies, the Game may be unable to operate as designed.
For more information about our Cookies policy, click [here]
Children
Our Service is not intended for persons under the age of 16. Persons under the age of 16 must not use the Service for any purpose.
How We Use Your Personal Information
We will use the information in the following ways and in accordance with the following legal bases:
|
Personal Information |
Use |
Legal Basis for Processing (EU) |
|
Nickname |
We use this information to keep track of your progress in the Game. Your nickname will be randomly generated when you first use the Game, and you can change it at any time. |
Necessary to perform our contract with you to provide the Game. |
|
Unique Vendor Identifier, such as Apple ID, Steam ID or GooglePlay ID |
We use this information to identify you and to keep track of your progress and rank in the Game. We also use your unique vendor identifier to track how frequently you use the Game. We use your Steam ID to log bugs and crash history to improve the Game Services. |
Necessary to perform our contract with you to provide the Game. |
|
Game Play Statistics (Rank, Score/s) |
We use this information to provide you with feedback and information about your gameplay and progress. |
Necessary to perform our contract with you to provide the Game. |
|
Game Play Statistics (Rank, Score/s) |
We use this information to provide you with feedback and information about your gameplay and progress. |
Necessary to perform our contract with you to provide the Game. |
|
IP Address |
We use this information to improve our services, including the functionality of the Game and to log bugs and crash history. |
Necessary to perform our contract with you to provide the Game. |
|
Device Information (Device ID, application version, battery level, WiFi strength, available space, network type, OS version, platform) |
We use this information: · to improve our services, including the functionality of the Game; and · identify and address bugs and assess game function for optimisation. |
It is in our legitimate interest to improve our services. |
|
User Communications with Support (Name, email address, QQ number). You also have the option of providing a photo to illustrate any errors. |
We use this information to: · improve our services; · provide troubleshooting, such as addressing and remediating technical issues and bugs. |
Necessary to perform our contract with you to provide and support the Game. |
How We Store and Share Your Personal Information
In order to perform our contract with you, your personal information will be accessible from and will be processed on our servers. Our servers are located in the People’s Republic of China (excluding Hong Kong, Taiwan and Macau) (“PRC”).
We share your personal information with selected third parties in and outside your country, including:
· law enforcement agencies, public authorities or other judicial bodies and organisations. We disclose information if we are legally required to do so, or if we have a good faith belief that such use 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 organisations for the purposes of fraud protection); and
a third party that acquires all or substantially all of us or our business. We will disclose information to a third party in the event that we sell or buy any business or undergo a merger, in which case we will disclose your data to the prospective buyer of such business. We will also disclose information to a third party if we sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.
The 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 transmission of information via 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 transmission of your information is at your own risk.
Data Retention
We will retain your personal information as described below (except if otherwise required to be retained by applicable law).
|
Personal Information |
Retention Policy |
|
Game |
|
|
Nickname
|
Stored for the lifetime of your use of the Game (i.e. until profile deletion in accordance with your request) and then deleted within 7 days of a request to delete your profile. |
|
Unique Vendor Identifier, such as Apple vender ID, Steam ID or GooglePlay ID |
Stored for the lifetime of your use of the Game (i.e. until profile deletion in accordance with your request) and then deleted within 7 days of a request to delete your profile. |
|
Game Play Statistics (Rank, Score/s) |
Game Play Statistics such as the date, time and duration is stored for 30 days from the date the relevant data is created. |
|
IP Address |
For mobile, this data is stored for six months from the date you first access the Game, and then deleted within 7 days of a request to delete your profile. For PC, this data is stored for the life of the Game, and then deleted within 7 days of a request to delete your profile. |
|
Device ID, Device Information |
For mobile, this data is stored for six months from the date you first access the Game, and then deleted within 7 days of a request to delete your profile. For PC, this data is stored for the life of the Game, and then deleted within 7 days of a request to delete your profile. |
|
Device ID, Device Information |
For mobile, this data is stored for six months from the date you first access the Game, and then deleted within 7 days of a request to delete your profile. For PC, this data is stored for the life of the Game, and then deleted within 7 days of a request to delete your profile. |
|
User Communications with Support |
Stored for the lifetime of the Game and deleted sooner if a user lawfully requests deletion. |
Personal Information is kept until the end of its life cycle (as set out in the retention policy above). When destroying personal information, measures will be taken to make the personal information irrecoverable or irreproducible, and electronic files which contain personal information will be deleted permanently using a technical method which makes the files irreproducible.
In the event that the processing and retention period have terminated, but personal information is required to be retained continuously for other reasons including for the purposes as prescribed under applicable laws, the relevant personal information will be stored and maintained separately from other types of personal information. If you require us to destroy your personal information before the end of its life cycle (as set out in the retention policy above), we will destroy your personal information in accordance with local laws).
This section (“Your Rights”) applies to users that are located in the European Economic Area only.
You have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please email us at dpo@thenextstudio.net.
Access
You have the right to access personal information we hold about you, how we use it, and who we share it with. To submit a request, please email us at dpo@thenextstudio.net.
Portability
You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent or pursuant to our contract with you (e.g., game play statistics), as described in the section “How We Use Your Personal Information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party. To submit a request, please email us at dpo@thenextstudio.net.
If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (e.g., where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).
Correction
You have the right to correct any personal information held about you that is inaccurate. If you believe we hold any other personal information about you and that information is inaccurate, please email us at dpo@thenextstudio.net.
Erasure
You can remove certain personal information by emailing us at dpo@thenextstudio.net. You may request that we erase the personal information we hold about you in the following circumstances:
· you believe that it is no longer necessary for us to hold such personal information; or
· you believe the personal information we hold about you is being unlawfully processed by us.
You can also exercise your right to restrict our processing of your personal information (as described below) whilst we consider your request.
We may need to retain personal information if there are valid grounds under data protection laws for us to do so (e.g., for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Game Services and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.
Restriction of Processing to Storage Only
You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (e.g., for the defence of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.
You may request we stop processing and just store the personal information we hold about you where:
· you believe the personal information is not accurate for the period it takes for us to verify whether it is accurate;
· you wish to erase the personal information as the processing we are doing is unlawful but you want us to retain the personal information but just store it instead; or
· you wish to erase the personal information as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims.
Objection
You have the right to object to our processing of personal information about you. We will consider your request in other circumstances as detailed below by emailing us at dpo@thenextstudio.net.
Announcements
We may from time to time send you announcements when we consider it necessary to do so (such as when we temporarily suspend Game access for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.
Contact & Complaints
Questions, comments and requests regarding this policy are welcomed and should be addressed todpo@thenextstudio.net .
In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at dpo@thenextstudio.net and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws.
Changes
If we make any material changes to this policy, we will post the updated policy here. Please check this page frequently to see any updates or changes to this policy.
Last Updated: 22 May 2018