PRIVACY POLICY Last updated: March 10,
2023. Effective March 10, 2023.
1. Introduction
Shizhan (collectively, “Shizhan”, “us”, “our” or “we”) develops and publish games for mobile devices. This Privacy Policy
(this “Policy”) describes
the ways we collect, store, use, and disclose the information, including
personal information, and data that our users (“users” or “you”)
provide and any Shizhan game provided on a
mobile platform (each a “Service,” collectively, the “Services”).
Additionally, this Policy describes your rights and choices
concerning your information.
Please note that the scope of this
Policy is limited to information and data collected or received by Shizhan through your use of the Services. Shizhan
is not responsible for the actions of individuals
with no relationship to Shizhan or third-party
companies, the content of their sites, the use of information or data you
provide to them, or any products or services they may offer. Any link to those
sites does not constitute our sponsorship of, or affiliation with, those
individuals or companies.
If you do not want Shizhan to collect, store,
use, or share your information
in the ways described in this Policy, you should not use our Services.
2. Information and Data We Collect
from You and How We Collect It
When you use our Services, you may
give us your contact information directly on our website, generally your name
and email address.
Registration Information: We may also
offer you the option to complete a user profile that is visible to other Shizhan users (“Account”). If
you create an Account, you may provide us you name, a username, e-mail address,
a password and other information that helps us confirm that it is you accessing
your Account. We may do this through in-game dialog boxes, which you may choose
to skip. If you sign into the Services with Facebook Connect we
will collect information that is visible via your Facebook account such as: (1)
your first and last name, (2) Facebook ID, (3) Profile Picture/URL, and (4)
list of Facebook friends. Your Account may be used to publicly identify you as
part of social features of the Services, which may include user-to-user
interaction, chat or messaging functionality, public leaderboards, head-to-head
competition, and other similar features. The Shizhan
username will be public and will be shown to other users, but will only permit
access to information that is considered public or that you have designated as
public in your user profile settings.
We may also offer you the ability to
import your contacts or manually enter e-mail addresses so that you can locate
your contacts on Shizhan and invite your
contacts to join you in the Services. We will store those contacts for purposes
of helping you and your contacts make connections through our Services.
Payment Information: When you order
any good or service through the Services, including any virtual currency or
virtual good, our payment processing service provider will collect your name,
phone number, e-mail address, mailing address, billing address, and complete
credit card information that enables them to receive your payment. Our payment
processing service provider may also retain this information to enable you to
purchase additional items through our Services without having to re-enter it
each time. Please note that purchases from third parties may also be subject to
additional policies
InformationCollected by Customer Support: When you
ask for assistance from our Customer Support team, we will collect and store
the contact information you provide (generally your name and e-mail address),
information about your gameplay or activity on the Services, and your user-name
or ID number. We will also store the correspondence and any information
contained within.
Technical and Usage Information: When
you access our Services, we may collect (i) certain
technical information about your mobile device or computer system, including IP
Address, mobile device ID (IDFA, Google Advertising ID or other identifiers),
and the version of your operating system; and (ii) usage statistics about your
interactions with the Services. In certain Services we will create and assign
to your device an identifier that is similar to an account number. We may
collect the name you have associated with your device, device type, telephone number,
country, and any other information you choose to provide, such as username,
character name, or e-mail address. We may also access your contacts to enable
you to invite friends to join you in the Services. This information is
typically collected through the use of third-party mobile device software
development kits. We may occasionally send you push notifications through our
Services to send you game updates, high scores and other service-related
notifications that may be of importance to you. You may at any time opt-out
from receiving these types of communications by turning them off at the device
level through your settings.
3. How We Use Your Information
Shizhan's primary goals in using your
information are to create your account, provide Services to you, troubleshoot,
improve and optimize our Services, contact you, conduct research and create
reports for internal use. We use information collected through our Service for
purposes described in this Policy or disclosed to you in connection with our Service.
For example, we may use your information to:
- Create accounts and allow users to
use our Services;
- Identify and suggest connections
with other Shizhan users;
- Operate and improve our Services;
- Understand you and your preferences
to enhance your experience and enjoyment using our Services;
- Respond to your comments and
questions and provide customer service;
- Provide and deliver products and
services you request;
- Deliver advertising and marketing
and promotional information to you;
- Send you related information,
including confirmations, invoices, technical notices, updates, security alerts,
and support and administrative messages;
- Communicate with you about
promotions, contests, rewards, upcoming events, and other news about products
and services offered by Shizhan and our selected
partners;
- Conduct and administer contests
promoted by Shizhan;
- Enable you to communicate with
other users; and
- Link or combine it with other
information we get from third parties, to help understand your preferences and
provide you with better services.
Use of Your Information by Others:
Third Party Services. We may provide
your information to third party companies to perform certain services,
including but not limited to hosting services, payment processing, analytics,
customer service and to assist us in our marketing efforts. Where we share your
information with third-party service providers and business partners, we ensure
that we have appropriate agreements in place to protect your information as
required by applicable data protection laws.
Advertising. To the extent we display
advertising in our Services, we may allow advertising networks of our
affiliates and partner networks to collect information about your mobile device
to enable them to serve targeted ads to you. Such mobile device data includes
the following:
- Device make, model and operating
system;
- Device properties related to screen
size & orientation, audio volume and battery;
- Carrier;
- Operating system;
- Name and properties of mobile
application through which a consumer interacts with the Services;
- Country, time zone and locale
settings (country and preferred language);
- Network connection type and speed;
- IP Address;
- Internet browser user-agent used to
access the Services; and
- Advertising ID (IDFA on iOS devices
and GAID on Android devices).
You may visit
www.aboutads.info/choices or www.youronlinechoices.eu (for individuals in the
EU) to learn more about interest-based advertising and how to opt-out of this
form of advertising on your web browser by companies participating in the
Digital Advertising Alliance (“DAA”) self-regulatory program.
If you wish to opt-out of interest based advertising in mobile apps on your
device by companies that participate in the DAA’s AppChoices app, you may
download that app onto your device and exercise your choice. AppChoices is available at the links below:
DAA AppChoices iOS
DAA AppChoices Android
DAA AppChoices Amazon
You may also limit data collection by
third parties by using your mobile device settings. Please note that electing
to opt-out will not stop advertising from appearing in your browser or
applications. It may make the ads you see less relevant to your interests.
Additionally, please not that if you use a different browser or erase cookies
from your browser, or use a different mobile device, you may need to
renew your opt-out choices.
4. How We May Disclose Your
Information to Third Parties
Shizhan does not share your personal
information except as approved by you or as described in this Policy.
We may share information we collect
or derive with third parties for the following purposes:
- With service providers that perform
services on our behalf, including the ones referenced above under “Third Party
Services”;
- With our affiliates;
- For analytics and research
purposes;
- When we have a good faith belief
that we have to disclose the information in response to lawful requests by
public authorities, including law enforcement or legal process purposes;
- To satisfy any applicable laws or
regulations;
- When we believe in our sole
discretion that our Services are being used in committing a crime, including to
report such criminal activity or to share information with other companies and
organizations for the purposes of fraud protection, credit risk reduction, and
other security precautions;
- To protect our or a third party’s legal rights, investigate fraud, or
to defend against a legal claim;
- As part of a business transfer such
as a merger, acquisition, or at bankruptcy;
- We may share aggregate or anonymous
information about you with advertisers, publishers, business partners,
sponsors, and other third parties; and
- We may use analytics services
provided by third parties, including Google Analytics. These service providers
may use cookies to collect information about your online activities across this
and other sites over time for non-advertising purposes. To learn more about how
Google analytics collects and processes data and the choices Google may offer to
control these activities, you may visit
http://www.google.com/intl/en/policies/privacy/partners/.
5. Specific Provisions for EU
Individuals
This section only applies to
individuals located in the European Economic Area, United Kingdom, or
Switzerland (collectively, the “Designated Countries”) at the time of data
collection.
We may ask you to identify which
country you are in when you use or access some of the Services, or we may rely
on your IP address to identify which country you are located in. When we rely
on your IP address, we cannot apply the terms of this section to any individual
that masks or otherwise hides their location information from us so as not to
appear located in the Designated Countries. If any terms in this section
conflict with other terms contained in this Policy, the terms in this section
shall apply to individuals in the Designated Countries.
Accessing and Correcting Your
Personal Information. At any time, you may contact Shizhan
at the address provided in the “Contact Shizhan” section herein and request to access the personal data
that Shizhan holds about you. Shizhan
may need to ask you to provide certain information
to make sure you are who you claim to be. If you find the information on your
account is not accurate, complete or updated, then please provide Shizhan with the necessary information to correct it.
Withdrawing Your Consent. Contact us
if you would like to withdraw your consent to the processing of your personal
data. Exercising this right will not affect the lawfulness of processing based
on consent before withdrawal.
Erasing or Restricting Access to Your
Information. You may request to delete or restrict access to your personal
data. We may postpone or deny your request if your personal data is in current
use for providing Services or for other legitimate purposes, in which case we
will let you know if we are unable to do so and why.
Transferring your Personal Data
(Otherwise known as Your Right to Data Portability). You have the right to
receive your personal data that you have provided us in a structured, commonly
used and machine-readable format and the right to transmit that data to another
party of your choice, where technically feasible. However, this right shall not
apply where it would adversely affect the rights and freedoms of others.
Right to Make Complaint: if you
consider that our processing of your personal data infringes data protection
laws, you have a legal right to lodge a complaint with a supervisory authority
responsible for data protection. You may do so in the EU member state of your
habitual residence, your place of work or the place of the alleged
infringement.
If you have any concerns about the
way we process your personal data, you are welcome to contact our data
protection officer at [email protected] or write to us at the
address set forth in the “Contact Shizhan” section. We will
look into your request and make good faith
efforts to resolve any concern you may have.
6. Security Safeguards.
Shizhan takes reasonable measures to protect
your information from unauthorized access or against loss, misuse or alteration
by third parties. Although we make good faith efforts to store the information
collected on the Services in a secure operating environment that is not
available to the public, we cannot guarantee the absolute security of that
information during its transmission or its storage on our systems. Further,
while we attempt to ensure the integrity and security of our network and
systems, we cannot guarantee that our security measures will prevent
third-party “hackers” from illegally obtaining
access to this information. We do not warrant or represent that your
information will be protected against, loss, misuse, or alteration by third
parties. No method of transmission over the Internet, or method of electronic
storage, is 100% secure, however. Therefore, we cannot guarantee its absolute
security.
7. Data Retention.
Shizhan retains your personal data for as
long as needed to provide you Services, unless we are required by law to delete
or if Shizhan accepts your request to delete the
information. We will also retain and use your personal data as necessary to
comply with our legal obligations, resolve disputes, and enforce our
agreements.
8. Our Policy Regarding Children.
We do not knowingly collect or
solicit personal data from anyone under the age of 16 or knowingly allow such
persons to use our Services. If you are under 16, please do not send any
information about yourself to us, including your name, address, telephone
number, or email address. No one under the age of 16 may provide any personal
data. In the event that we learn that we have collected personal data from a child
under age 16, we will delete that information as quickly as possible. If you
believe that we might have any information from or about a child under the age
of 16, please contact us.
9. Transfer of Personal Data Outside
Your Country.
We may transfer information that we
collect about you to affiliated entities, or to other third parties across
borders and from your country or jurisdiction to other countries or
jurisdictions around the world. Please note that these countries and
jurisdictions may not have the same data protection laws as your own
jurisdiction, and we take steps to ensure adequate safeguards are in place to
enable transfer of information to the U.S. and the use and disclosure of
information about you, including personal data, as described in this Policy.
10. Lawful Basis for Processing.
On certain occasions, we process your
personal data when it is necessary for the performance of a contract to which
you are a party, such as to provide the Services to you. We may also process
your personal data to respond to your inquiries concerning our products and
services.
On other occasions, we process your
personal data where required by law. We may also process your personal data if
necessary to protect your interests or the interests of a third party.
Additionally, we process your
personal data when necessary to do so for fraud prevention, improving our
network and services, and marketing our services to advertisers and publishers;
where these interests are not overridden by your data protection rights.
If the processing of personal data is
necessary and there is no other lawful basis for such processing, we will
generally ensure that consent has been obtained from you. You have the right to
withdraw your consent to processing of personal data at any time.
For questions about data processing,
please contact our Data Protection Officer. Visit the “Contact Shizhan” section below for
contact information.
11. Specific Provisions for
California Consumers
These additional provisions for
California consumers apply only to individuals who reside in California. The
California Consumer Privacy Act of 2018 (“CCPA”) provides
additional rights to know, delete and opt out, and requires “businesses” collecting or disclosing
personal information to provide notice and a means to exercise those rights.
- Categories of personal information
collected in the preceding 12 months
- Business purpose for collection
- Third parties with whom we may
share your information
Right to Know and Right to Delete For
any of the personal information described above, you can request to know what
personal information we collected, disclosed, used and sold, and request that
we delete your personal information at any time.
To exercise your right to know and
right to deletion, please submit a request by: Emailing [email protected] with
the subject line “California Rights
Request.” 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. In
certain circumstances, we may decline a request to exercise the right to know
and right to deletion, particularly where we are unable to verify your
identity.
Upon verification of your request, we
will delete (and direct our service providers to delete) your personal
information from our records, unless retaining the information is necessary for
us or our service providers to complete the transaction with you, detect security
incidents or fraud, fixing errors, exercise free speech or another right
provided by law, comply with legal obligations, or other internal and lawful
uses.
Right to Opt Out
of Sale CCPA gives you a right to direct a business that sells your personal information
to stop selling your personal information and to refrain from doing so in the
future. We do not sell any of your personal information and will require our
service providers not to sell your personal information.
You also have the right not to be
discriminated against for exercising any of the rights listed above.
If you are a California resident
seeking to exercise your rights under the CCPA or have any questions or
concerns, please email us at [email protected]. In certain circumstances,
you are permitted to use an authorized agent to submit requests on your behalf
where (i) you provide sufficient evidence to show
that the requestor is an authorized agent with written permission to act on
your behalf and (ii) you successfully verify your own identity with us.
We aim to respond to a consumer
request for access or deletion within 45 days of receiving that request. If we
require more time, we will inform you of the reason and extension period in
writing.
12. Changes to This Policy.
We may update this Policy to reflect
changes to our data and information privacy practices. If we make any
material changes we will notify you by means
of a notice on the Services prior to the change becoming effective. We
encourage you to periodically review this Policy for the latest information on
our privacy practices. Please note that if Shizhan
needs to adapt the policy to legal requirements, the new policy will become
effective immediately or as required
13. Contact Us
You may contact Shizhan’s Data Protection Officer at [email protected]