PRIVACY POLICY
Updated: 27 February 2024
Scope of this Privacy Policy
Please read this Privacy Policy carefully to understand
our policies and practices regarding your Information (as defined below) and
how we will treat it.
This Privacy Policy explains how your Information is
collected, used, and disclosed by MOBEE, Ltd. entities as listed in the
controllers & contact section ("we" or "us"). It also
tells you how you can access and update your Information and make certain
choices about how your Information is used.
This Privacy Policy covers both our online and offline
data collection activities, including information that we collect through our
various channels such as websites, apps, console games, third party social
networks, customer care centres, studios,
attractions/exhibitions, points of sales and events. Please note that we can
combine information that we collect via one method (e.g. a MOBEE, Ltd. website)
with information that we collect via another method (e.g. a MOBEE, Ltd. video
game). As part of this, we can combine information that was originally
collected by different MOBEE, Ltd. entities.
TABLE OF CONTENTS
_ THE INFORMATION WE COLLECT
_ HOW WE USE THE INFORMATION
_ INFORMATION SHARING AND DISCLOSURE
_ YOUR CHOICES
_ COOKIES AND OTHER TECHNICAL INFORMATION
_ DATA RETENTION
_ HOW YOU CAN ACCESS OR CORRECT INFORMATION
_ MANAGING YOUR INFORMATION
_ INTERNATIONAL TRANSFER
_ NOTIFICATION REGARDING UPDATES
_ JOINT CONTROLLERS & HOW TO CONTACT US
INFORMATION WE COLLECT
We collect and combine different types of information
together, and collectively refer to all of this information in this Privacy
Policy as ¡°Information¡±. Such Information includes:
Registration, account, and sign-up information. We collect
Information in the course of your use of, or registration with, us. For
example, when you create an account, register for, or download an application,
or sign-up for a product or service, you provide us with certain personal
information. This type of personal information can include: name, postal address,
telephone number or email address. We can also receive Information about your
interest in and use of various products, programs, services, and content
available.
Product/service purchase. Where you
make a purchase on one of our sites, we will also collect certain payment
information (e.g. credit/debit card, billing information and delivery address).
Information about others/inviting friends. In certain
situations, we collect Information you submit about other people. For example,
you can submit Information to invite a friend to participate in an offering,
make recommendations, share content, or you have multiple players sharing the
same video game session. By processing these requests, we can receive the other
person¡¯s Information, including details such as his/her name, postal address,
email address, telephone number, or information about the recipient¡¯s interest
in and use of various products, programs, services, and content. In certain
situations, we also allow you to invite your friends to participate in
activities by providing their contact details or importing contacts from your
address book or from Social Media Sites (as defined below).
Information from other sources. We, on
occasion, combine Information we receive online with other information,
including usage information from our other sites and our online advertising and
media. We also supplement or combine Information with information from a
variety of other sources or outside records, such as demographic, transaction
history, or personal information, and we use that combined information in
accordance with this Privacy Policy.
Social media. You can
engage with some of our content and offerings, such as videos, games,
applications, and other offerings on or through third party communities, forums,
and social media sites, services, plug-ins, and applications (¡°Social Media
Sites¡±). When you link to or interact with us or content through Social Media
Sites, you allow us to receive certain Information from your social media
account (e.g., name, user ID, email address, profile photo, photos and videos,
gender, birthday, your list of friends and their contact details, people you
follow and/or who follow you, the posts or the 'likes' you make). We also
receive Information from your interaction with our content (e.g., content
viewed, game performance, high scores, and information about advertisements you
have been shown or have clicked on). Where permitted by law, by providing this
Information or otherwise interacting with our Sites through Social Media Sites,
you consent to our use of Information from the Social Media Site in accordance
with this Privacy Policy.
Public forums. If you post
or share Information or content, such as photos, letters, videos, or comments,
while participating in online forums we operate, or when you interact with us
through Social Media Sites, depending on your privacy settings this Information
and your username can become public on the Internet or within a community of
users. We cannot prevent further use of this Information once it is made
public. For information about how you can customise
your privacy settings on Social Media Sites, and how those Social Media Sites
handle your personal information and content, please refer to their privacy
help guides, privacy policies, and terms of use.
Location information. We have
access to certain Information about your location, such as your country or
address, when you provide it or via device information (such as an IP address).
With your consent (where required by law), we can also collect Information
about your device¡¯s precise location (e.g. geolocation via mobile devices).
Technical and usage information. We also
collect certain technical and usage information such as the type of device,
browser, and operating system you are using, your Internet service provider or
mobile carrier, unique device identifier, IDFA or IDFV, MAC address, IP
address, device and browser settings, the webpages and apps you use,
advertisements you see and interact with, and certain site usage information.
See our Cookies and Other Technical Information section for more information on
how we may use these technologies to collect this Information.
Customer enquiries. Where you
contact us through one of our customer helpdesks or customer call centres, we can have access to the application, or
product/service that you have purchased, your purchase history, your previous
correspondence with us or your contact details. Calls to customer call centres may be recorded.
HOW WE USE THE INFORMATION
We use Information for the purposes described in this
Privacy Policy or disclosed at the time of collection.
Providing and marketing products and services. We use
the Information we collect about you, to fulfill your purchase, or to fulfill
your requests for, and otherwise provide or analyse
your use of our products, application, services, video games and content, to
facilitate sharing and other interactions with Social Media Sites, and to
provide, develop, maintain, personalise, protect, and
improve your experience and our offerings. For example, we use Information
collected on our sites to enable you to do things like (i)
watch trailers and video clips, (ii) get entertainment news and updates, (iii)
get information about our products, services, and content, (iv) locate and
access personalised information, ads or functionality
based on your interests and location (e.g., find stores, theaters, or show
times), (v) buy digital content, products/services or movie tickets, (vi) play
games, (vii) engage with interactive features, activities, and Social Media
Sites, (viii) read and post comments, content, and reviews, or (ix) enter
promotions, contests, and sweepstakes. We also use Information for your payment
of any products/services you purchase, to prevent fraud or to offer, market,
and advertise products, programs, and services from us and our affiliates,
trusted partners, and select third parties that we believe can be of interest
to you.
Our reasons
_ Fulfilling contractual obligations
_ Legal obligations
_ With your consent (where required)
_ Our legitimate interests:
o Improving and developing new products and services
o Being more efficient
o Fighting fraud
o Retaining your shopping history and use details of the
products you have previously purchased to make suggestions to you for other
products which we believe you will also be interested in
Communicating with you and others. We use
Information about you to communicate with you, such as (i)
to notify you when you win one of our contests or sweepstakes, or when we make
changes to our policies or user agreements, (ii) to respond to your inquiries,
(iii) to communicate with you about your purchases or transactions, (iv) to
contact you about your account, or (v) to send you information about
promotions, offerings, and our features. You can also choose to receive push
notifications from us on your mobile device. If you choose to submit content
for publication online or in other forums, we can publish your screen name and
other Information you have provided to us, the Internet, or elsewhere. If you
choose to contact one of our call centres we can
record such calls. We use Information that you provide about others to enable
us to send them invitations, promotions, or other content on your behalf or
through our sites. From time to time, where permitted by law, we also use this
Information to offer, market, or advertise products, programs, or services to
them from us and our affiliates, business partners, and select third parties.
Our reasons
_ Fulfilling contractual obligations
_ Legal obligations
_ With your consent (where required)
_ Our legitimate interests
o Communicating important information
o Improving and developing new products and services
o Being more efficient
o Compiling statistics
Third party social networks. We use
your Information when you interact with third party social networking features
to serve you with advertisements and engage with you on third party social
networks. You can learn more about how these features work, the profile data
that we obtain about you, and find out how to opt out by reviewing the privacy
notices of the relevant third party social networks.
Our reasons
_ With your consent (where required)
_ Our legitimate interests:
o Retaining and evaluating information on your recent
visits to our mobile apps, and video games, and how you move around for
analytics purposes in order to understand how people use our mobile apps, and
video games so that we can make them more intuitive
o Defining types of customers for new products or
services
o Developing a profile of you and your interactions with
us so that we can provide tailored offers, opportunities and services that may
be of interest to you
Use of technical and usage information. We use
technical and usage information to improve our design, functionality and
content and to enable us to personalise your
experience with our content and offerings. We use this Information (i) to provide, develop, maintain, personalise,
protect, and improve our products, applications, services and video games, and
to operate our business, (ii) to perform analytics, including to analyse and report on usage and performance, (iii) to
protect against, identify, and prevent fraud and other unlawful activity, (iv)
to create aggregate data about groups or categories of our users, and (iv) for
us and our affiliates, business partners, and select third parties to target,
offer, market, or advertise products, programs, or services.
Compliance. We use
Information we collect to detect, investigate, and prevent activities that
violate our terms of use, could be fraudulent, violate copyright, or other
rules or that can be otherwise illegal, to comply with legal requirements, and
to protect our rights and the rights and safety of our users and others.
Our reasons
_ Legal obligations
_ Our legitimate interests:
o Protecting our business interests and rights, privacy,
safety and property, or that of the public
o Sharing your Information with third parties in order to
permit us to pursue available remedies or limit damage that we may sustain
Note: We have carried out balancing tests for all the
data processing we carry out on the basis of our legitimate interests, which we
have described above. You can obtain information on any of our balancing tests
by contacting us using the details set out later in this Privacy Policy.
INFORMATION SHARING AND DISCLOSURE
We share and disclose Information in the following ways
or for any other purpose disclosed at the time of collection:
Law enforcement bodies and courts. We
disclose Information in response to legal process, for example in response to a
court order or a subpoena, or in response to a law enforcement body's request.
We also disclose such Information to third parties: (i)
in connection with fraud prevention activities, (ii) where we believe it is
necessary to investigate, prevent, or take action regarding illegal activities,
(iii) in situations that can involve violations of our terms of use or other
rules, (iv) to protect our rights and the rights and safety of others, and (v)
as otherwise required by law.
Change of control. We
transfer Information in the event of a business transaction, such as if we or
one of our business units or our relevant assets are acquired by, sold to, or
merged with another company or as part of a bankruptcy proceeding or a business
reorganisation.
Service providers. Our
agents and contractors have access to Information to help carry out the
services they are performing for us, such as, but not limited to, fulfilment,
creation, maintenance, hosting, and delivery of products and services, conduct
marketing, handle payments, email and order fulfillment, administer contests,
conduct research and analytics, or customer service.
Linked sites. Some of
our sites contain links to other sites, including Social Media Sites, whose
information practices can be different from ours. You should consult the other
sites' privacy disclosures and terms before submitting any Information, as we
have no control over Information that is submitted to, or collected by, these
third parties.
Sponsors and co-promotions. We sometimes
offer content or programs (e.g., contests, sweepstakes, promotions, games,
applications or Social Media Site integrations) that are sponsored by or
co-branded with identified third parties. By virtue of these relationships, the
third parties collect or obtain Information from you when participating in the
activity. We have no control over these third parties' use of this Information.
We encourage you to look at the privacy disclosure of any such third party to learn
about their data practices.
Advertising networks. We share
certain Information with third parties to provide advertising to you based on
your interests. For more information, please see our (i)
Cookies and Other Technical Information and (ii) Ad Choices sections below.
YOUR CHOICES
Marketing communications and sharing with third parties. We
provide you with an opportunity to express your preferences with respect to
receiving certain marketing communications from us, and our sharing of
Information with trusted partners for their direct marketing purposes. If you
ever decide in the future that you would like to update these preferences, you
can send us an email at support@mobeegaming.com. If you previously chose
to receive push notifications on your mobile device from us, but no longer wish
to receive them, you can manage your preferences through your device or app
settings, depending on the type of device.
Ad Choices. We work with reputable third
parties to present advertisements, and engage in data collection, reporting, ad
delivery and response measurement, and site analytics on our sites and on third
party websites across the Internet and applications over time. These third
parties use cookies, web beacons, pixels, or similar technologies to perform
this activity. They also obtain information about applications you use,
websites you visit, and other information from across your devices and browsers
in order to help serve advertising that will be more relevant to your interests
on and off our sites and across your devices and browsers. This type of
advertising is known as interest-based advertising. They also use this
information to associate various browsers and devices together for the purpose
of interest-based advertising and other purposes like analytics.
For more information about interest-based advertising on
your desktop or mobile browser, and your ability to opt out of this type of
advertising by third parties that participate in self-regulatory programs,
please visit Your Online
Choice and/or the EDAA Self-Regulatory Initiative for Online
Behavioral Advertising. Please note that any opt-out
choice you exercise through these programs will apply to interest-based
advertising by the third parties you select, but will still allow the
collection of data for other purposes, including research, analytics, and
internal operations. You can continue to receive advertising, but that advertising
will be less relevant to your interests.
You can have more options depending on your mobile device
and operating system. For example, most device operating systems (e.g., iOS for
Apple phones, Android for Android devices, and Windows for Microsoft devices)
provide their own instructions on how to limit or prevent the delivery of
tailored in-application advertisements. You can review the support materials
and/or the privacy settings for the respective operating systems to learn more
about these features and how they apply to tailored in-app advertisements.
Precise location information. To
disable the collection of precise location information from your mobile device
through our mobile apps, you can access your mobile device settings and choose
to limit that collection.
See also Cookies and Other Technical Information for more
choices about managing other technical and usage information.
COOKIES AND OTHER TECHNICAL
INFORMATION
Cookies and other technologies. We,
and our affiliates, third party service providers, and trusted partners send
"cookies" to your device or use similar technologies to understand
and enhance your online experience with us and through our advertising and
media across the Internet including Social Media Sites, mobile apps, and video
games.
Cookies are small text files placed in your browser. We
also use pixels or "web beacons" that monitor your use of our sites.
Web beacons are small strings of code that provide a method for delivering a
graphic image on a webpage for the purpose of transferring data, such as the IP
address of the device that downloaded the page on which the web beacon appears,
the URL of the page on which the web beacon appears, the time the page
containing the web beacon was viewed, the type of browser that fetched the web
beacon, and the identification number of any cookie on the device previously
placed by that server. We also integrate ¡°Software Development Kits¡± (¡°SDKs¡±), javascripts or portions of code into our applications/video
games to perform similar functions as cookies and web beacons. For example,
SDKs collect technical and usage information such as mobile device identifiers
and your interactions with our app. Some of our sites use locally stored
objects (¡°LSOs¡±) to provide certain content, such as video on demand, video
clips, or animation, and a better user experience.
We can use cookies and other technologies to help recognise your browser or device, maintain your
preferences, provide certain features, and collect Information about your
online interactions with us, our content, and our communications. For example,
when corresponding with you via HTML capable email, web beacons and other
technologies let us know about your activity, including whether you received
and opened our email, clicked through a link, or otherwise interacted with our
content, and this information can be associated with Information previously
collected.
We also use cookies and other technologies (i) to provide, develop, maintain, personalise,
protect, and improve our sites, products, apps, services and video games, and
to operate our business, (ii) to perform analytics, including to analyse and report on usage and performance of our content
and marketing materials, (iii) to protect against, identify, and prevent fraud
and other unlawful activity, (iv) to create aggregate data about groups or
categories of our users, (v) to synchronise users
across devices, affiliates, and trusted partners, and (vi) for us and our
affiliates, and trusted partners to target, offer, market, or advertise
products, apps, services or video games. Cookies and other technologies also
facilitate, manage, and measure the performance of advertisements displayed on
or delivered by or through us.
Managing cookies and other
technologies.
Websites and mobile applications
Details
Strictly necessary cookies or similar technologies: They
are essential in order to enable you to move around our sites or apps and use
its features, such as accessing secure areas. Without them, services like
enabling appropriate content based on your type of device cannot be provided.
Performance cookies or similar technologies: They collect
information about how you use our sites or apps, so that we can analyse traffic and understand users' interactions. We may
use third party service providers such as Google Analytics for this purpose who
may use their own cookies or similar technologies. The information is used to
improve our site or app.
Functionality cookies or similar technologies: They
allow our sites or apps to remember choices you make (such as your user name,
or the region you are in) and provide enhanced, more personal features. They
can also be used to remember changes you have made to text size, fonts and
other parts of web pages that you can customise. They
may also be used to provide services you have asked for such as watching a
video or commenting on a blog.
Social media cookies or similar technologies: They
are used when you share information using a social media sharing button or
¡°like¡± button on our sites or apps, or when you link your account or engage
with our content on or through a social media site such as Facebook, Twitter or
Google+. The social network will record that you have done this. This
information may be linked to targeting/advertising activities.
Advertising cookies or similar technologies: Some
of our sites or apps may use a third party advertising network, to deliver
targeted advertising. They may also have the capability to track your browsing
across sites, apps and Social Media Sites.
We do not currently take actions to respond to Do Not
Track signals because a uniform technological standard has not yet been
developed. We continue to review new technologies and may adopt a standard once
one is created.
See the Your Choices section to learn how to control data
collection for certain purposes.
DATA RETENTION
In broad terms, we will only retain your personal
information for as long as is necessary for the purposes described in this
Privacy Policy. This means that the retention periods will vary according to
the type of personal information and the reason that we have the personal
information in the first place. For example, some personal information related
to the provision of services to you or by you will be kept for a number of
years in order to comply with various finance and tax related legal
obligations. Other service related personal information may be kept for a
different period because it is in our legitimate interests to do so in order to
provide or receive appropriate follow up service.
We have a detailed internal retention policy that sets
out varying retention periods for different categories of personal information
depending on our legal obligations and whether there is a commercial need. After
a retention period has elapsed, the personal information is securely deleted.
HOW YOU CAN ACCESS OR CORRECT
INFORMATION
Under conditions, you have the right to ask us for a copy
of your Information, to correct it, erase it or restrict its processing, and to
obtain the Information you provide in a structured, machine readable format.
You also have the right to ask us to transfer some of this Information to other
organisations.
You have the right to object to the processing of
personal information on the basis of our legitimate interests. Where we have
asked for your consent to process Information, you have the right to withdraw
this consent at any time.
If you have unresolved concerns, you have the right to
complain to an EU data protection authority where you live, work or where you
believe a breach may have occurred.
We reserve the right not to allow access to your
Information or to limit your rights (e.g. if such disclosure is prohibited by
law or if the rights of another individual might be violated). In some
instances, this may mean that we are able to retain your Information even if
you withdraw your consent.
MANAGING YOUR INFORMATION
Subject to certain exemptions, you can manage information
we receive about you.
If you would like us to delete your information, you may
send an e-mail to support@mobeegaming.com and place ¡°Delete My Account¡± in
the subject line [or request to delete your information inside the app you are
using]. If youproceed with the deletion of your account, you will no longer have
access to the game account or services associated with your account. Other steps
you should take should you wish to delete your account include disassociating
your Facebook account from our mobile games, if applicable, and deleting the
game from your mobile device. Please note that if you ask us to delete your
account, all your progress in the game and any unused virtual items will be lost
and we may not be able to restore them in the future.Please note that your
information, for example records pertaining to payments or customer service
matters, may be retained for legal and accounting purposes. If you have sent or
posted content on the Service, we may not be able to delete it.
If you wish to review, change or correct the information we
have about you, you may send an e-mail to support@mobeegaming.com making this
request.
For all of the above requests, we will need to verify your
identity before processing your request. In order to verify your identity, we will
generally require the matching of sufficient information you provide us to the
information we maintain about you in our systems.
INTERNATIONAL TRANSFER
We operate internationally, and many of our systems are
currently based in the United States, this means Information we collect will be
processed by us in the U.S. where data protection and privacy regulations will
not offer the same level of protection as in other parts of the world, such as
the European Union.
When we transfer your Information to our United States
group members outside the European Economic Area (EEA), we make use of standard
contractual clauses which have been approved by the European Commission. We
also use these clauses when we transfer your Information to third parties
outside the EEA or we may adopt other means to ensure that adequate safeguards
are applied to your Information (e.g. Privacy Shield, BCR, etc).
You may obtain a copy of the documents we use to protect your Information when
it is transferred outside the EEA by contacting us via email at
support@mobeegaming.com.
NOTIFICATION REGARDING UPDATES
From time to time, we can update this Privacy Policy. We
will notify you about changes to this Privacy Policy by placing a notice on our
sites. We encourage you to periodically check back and review this policy so
that you always know our current privacy practices.
HOW TO CONTACT US
For any questions, comments or concerns about our Privacy
Policy or any other issue please contact MOBEE, Ltd. at: support@mobeegaming.com
or submit a ticket via the applicable support channel of the game. All notices
given by you or required from you under this Privacy Policy shall be in writing
and addressed to: MOBEE Ltd., Attn: Legal Department, A902, Chaowai
SOHO, Chaoyang District, Beijing, 100000, China.