INTRODUCTION

We recognize that people who access and/or use (“you” or “Users”) the website https://store.igg.com/ (the “IGG Store”, the “Site” or the “Website”) and other related services (“Services”) value their privacy.

This Privacy Policy provides important information regarding:

i) the data collected from you and the ways we collect your data,

ii) the reasons why we collect your data,

iii) to whom we disclose your data, and

iv) the options you have about your personal data.

Unless stated otherwise, this Privacy Policy applies to our use and disclosure of Users information that we collect on or otherwise through IGG Store or during your access and use of the Services from you and your Account. We therefore provide this Privacy Policy to help you make an informed choice about whether to use or continue using our Services. We may periodically update this Privacy Policy by posting a new version on our website. Your continued use of the Services after the effective date will be subject to the new version of Privacy Policy. IF YOU DO NOT AGREE TO THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS SET OUT HEREIN, PLEASE DO NOT USE IGG STORE.

This Privacy Policy is incorporated into, forms part of and is subject to the Terms of Service. Your use of the Services and any personal information you provide on the Site is subject to the terms of this Privacy Policy and the Terms of Service.

Any terms not defined herein but defined in the Terms of Service shall have the meaning ascribed thereto in the Terms of Service.

Please note: any graphics, designs, images, data, communications, and other content other than personal information and unable to identify any personal information will not be regarded as information that is subject to this Privacy Policy.

I. THE DATA COLLECTED FROM YOU AND THE WAYS WE COLLECT YOUR DATA

1. Data provided by you

To use the Services, you may directly provide certain personally identifiable information to us, such as:

·       Registration information: including personally identifiable information, contact information (e.g. your name, personal identification number, postal or e-mail address, telephone numbers) and registered user name and password

·       Personal content preferences

·       Your information about social media accounts (such as Facebook, Twitter, WeChat, etc.) : if you register an Account using your social media accounts, the following information may be collected: (1) your friends lists, and (2) the email address associated with your Account,

·    Your information on your use of IGG Store: if you submit information to IGG Store, the following information may be collected as well: (1) the purchase of goods or services from IGG Store, (2) product or account registration, (3) message boards or forums, (4) warranty registrations, (5) consumer complaints, (6) surveys, (7) customer service or technical support info. We do not require that you provide us with this information to gain access to our websites; however, you will not be able to utilize certain products, services, or features that require registration or receive materials unless such information is provided.

·       Profile information (e.g. profile photo)

·       Messages to the Services (e.g. chat logs, your support tickets)

·       Billing and financial information : you may also disclose billing and financial information to us, the relevant merchant service provider and/or third-party platform when you purchase the Products using any payment instruments and channels. Use of any merchant service provider and/or third-party platform is subject to the privacy policy of the relevant merchant service provider and third-party platform.

·    Other data that you voluntarily provide (e.g. data to identify a lost account)：we may require access to other additional information from time to time and shall seek your specific permission at such times

2. Data collected automatically

When you access our Website or use the Services, we may use cookies and/or other similar technologies. Cookies are small text files stored by browser(s) on your desktop computer or mobile device. We use these cookies to help learn more about your preferences and therefore make the most of your experience on our services by providing personalized content and information the next time you visit. We may also use cookies for various purposes, including our shopping cart, to remember users’ settings (e.g. language preference), and for authentication. Some web browsers automatically accept cookies, but you can usually modify browser setting to decline cookies. If you choose to decline cookies, you may not be able to access certain Services and may experience technical problems receiving current information from the cookie-disabled services. The use of cookies and/or other similar technologies is to identify your browsers and to collect data from your device such as:

·       Data about your Account

·       Internet Protocol (IP) address, web request, domain name, URLs, referring/exit pages, platform type and mobile device identifiers (e.g. your device ID, advertising ID, MAC address, IMEI)

·       Data about your device (e.g. device name, operating system, browser type and language)

·       Data we collect with cookies and similar technologies

·       Monitoring of aggregate metrics (e.g. total number of visitors, pages viewed, usage of the Services)

·       General location data

·       Precise geo-location data (i.e. GPS)

·       Data about your use of the Services and visits of the Website: we may use software tools such as JavaScript to measure and collect number of clicks, landing pages, page response times, pages viewed and order of those pages, the amount of time spent on particular pages, download errors, page interaction information (such as scrolling, clicks, and mouse-overs), and ways in which users exit the page, the date and time of your request.

Our Servers automatically track and record certain information in connection with your various activities within or through our Services or otherwise that are sent by your browser, device, or computer system when you access our Services. These server logs may include but are not limited to information such as your network requests, Internet Protocol ("IP") address, MAC addresses, browser type, browser language, referring URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages and the date and time of your request, your gameplay and activity on services provided, and technical information about your device or computer.

Electronic images may be contained within our Services known as web beacons – also referred to as single-pixel gifs – that permit us to count Users who have visited those pages and for other related statistics, e.g. to record the popularity of certain content and to verify system and server integrity. Web beacons are not used to access your personal information through our Services; they are solely used to compile aggregate statistics concerning the use of our Services. Web beacons collect only a limited set of information including a cookie number, the time and date of a page view, and a description of the page on which the web beacon resides.

 

3. Data collected from our partners

When you access the Services through any third party services such as social networking sites (e.g. Facebook, WeChat, Google) or from any mobile devices, you allow us access to certain information stored on these third party services or mobile devices such as:

·       Demographic data (e.g. determination of your IP address)

·       Data to fight against fraud (e.g. refund abuse in games or click fraud in advertising)

·       Data from platforms that the games run on (e.g. verification of  payment)

·       Data associated with your device (e.g. device type, technological information, telephone number, country, contacts)

·       Data to do advertising, marketing and analysis

 

II. THE REASON WHY WE COLLECT YOUR DATA

1. To provide the Services and fulfill your product or service order

To provide the Services and fulfill your product or service order, we process data necessary to

·       Create Accounts

·       Allow you to use the Services and fulfill your product or service order

·       Operate the Services

·       Verify and confirm payments

·       Provide and deliver products and Services that you request

·       Send service-related communications to you

·       Update your contact information

2. To improve and optimize the Services

To better understand and serve you and to adapt our products and Services to better suit your needs, we have a legitimate interest to collect and process necessary data to

·       Update and develop the quality, use and design of our Services

·       Manage and update your Account

·       Develop and improve your experience

·       Manage the relationship with you

·       Provide social features to you

·       Customize your service experience

·       Respond to your comments and questions and provide support to you

·       Provide offers in the Services as well as in other websites and services

·       Send related information (e.g. updates, security alerts, support messages) to you

·       Enable you to communicate with other users

3. To carry out activities related to advertisements and marketing

To send you personalized advertising and marketing materials, we may use the information collected from you such as ad identifiers, age, country, region, gender, language, games played by you, information related to the interaction of you with the Services and with other users, and so forth.

We may also use various third party advertising and marketing partners to assist us on our behalf and may share information collected from you with such third parties for this purpose.

Hence, we have a legitimate interest to process necessary data to

·       Track the content you access in connection with the Services and your online behavior

·       Deliver, target and improve our advertising and marketing materials

·       Pass the information collected from you to third party advertising and marketing partners

By accepting this Privacy Policy and downloading or continuing to use the Services, you consent to us and our advertising and marketing partners collecting and using information about you to personalize advertising and marketing materials and to improve your experience unless you opt out of receiving this service.

We encourage you to review the privacy policies of our third party advertising and marketing partners so that you can understand how these third parties collect, use and share your information. We are not responsible for the privacy policies of any third party whether accessed through the Services or otherwise.  

For information on how to opt-out from receiving personalized advertising and marketing materials, see section 'The options you have about your personal data” below.

4. To secure the Services

Ensuring the security in the course of performing the Services is a top priority for us. We take appropriate security and technical measures to protect your information from unauthorized access, loss and misuse. To achieve this purpose, we also request our suppliers who process personal information on our behalf to take appropriate security measures.

In order to keep the Service and its social features safe and fair, to fight fraud and to ensure acceptable use otherwise, we have a legitimate interest to process necessary data to

·       Analyze and monitor use of the Services and its social features

·       Moderate and monitor chats

·       Prevent cheating, crime or fraud

·       Take action against fraudulent or misbehaving users 

·       Pass your information to agencies or organizations in charge of crime and fraud prevention and repression

Despite our efforts, we cannot guarantee the absolute security of your personal data, nor can we ensure the security of any of the communication facilities provided by us. We recommend that you exercise caution when disclosing any information through the Services. In particular, please note that any personally identifiable information or personally sensitive data that you communicate or disclose to any user in connection with the Services may be collected and used by others. As such, you should take care of the information shared online. Please also be reminded that any questions answers, comments, submissions that you post in the forum will be publicly available.

5. To analyze, research and test

In all of the above cases and purposes, we may use analytic tools, which may include third party’s analytic tools, to carry out research, surveys and analysis, to create reports for use, to track potential problems of the Services or to test out features and content.

6. To obtain your consent

With your consent, we may process personal data for additional purposes.

 

III. TO WHOM WE DISCLOSE YOUR DATA

1. Our personnel, related or affiliated companies

We may provide your personally identifiable information and non-personally-identifiable information to our personnel, our related or affiliated companies for our legitimate business purposes. We may also provide your personally identifiable information and non-personally-identifiable information to other businesses or persons for the purpose of processing such information or otherwise assist us in performing any services on our behalf including in any advertising and marketing activities. We require that these parties agree to process such information in compliance with our Privacy Policy contained herein, and we will use reasonable efforts to limit their use of such information and to use other appropriate confidentiality and security measures.

2. Other users

We may also have message boards, forums, and/or chat areas, where users can exchange ideas and communicate with one another. When posting to a message board, forum, or chat area, please be aware that the information is being made publicly available on-line and the user does so at his or her own risk. For certain forums, anyone posting or replying to a post may be doing so using their Real ID -- that is, their full first and last name -- with the option to also display the name of their primary in-game character (see discussion regarding Real ID below). If your personal information is posted on one of our community forums, you may contact us to request removal. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Any user who receives any information including personally identifiable information, from another user shall not disclose or use such information, save where expressly permitted by that user or save where such information has ceased to be of a confidential nature. You must not collect or harvest any of this information, nor use the communication facilities or any part of our Services for any commercial solicitation purposes. In any event, we shall not be liable for any unauthorized disclosure or use by another user or other person of any content.

3. Partners working for us

We have partners (including but not limited to advertising, marketing and social media partners) to perform services for us. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices.

4. Other companies and public authorities

We may release personally identifiable information and/or non-personally-identifiable information to, exchange such information with companies and organizations or provide such information to public authorities if required to do so by law, or in the good faith belief that such action is necessary to comply with all and any applicable laws, or where it is pursuant to we are required to respond to a governmental, regulatory, administrative or court order or directive, a subpoena or a search warrant, or to combat fraud and illegal activity.

We also reserve the right to disclose personally identifiable information and/or non-personally-identifiable information that we believe, in good faith, is appropriate or necessary to enforce the Privacy Policy, take precautions against liability, to investigate and defend against any third-party claims or allegations, to assist government authorities and enforcement agencies, to protect the security or integrity of the Services, and to protect the rights, property, or personal safety of ourselves, our users or others.

 

IV. THE OPTIONS YOU HAVE ABOUT YOUR PERSONAL DATA

1. Opt out of advertising and/or marketing materials

You may opt out of receiving advertising and/or marketing communications by following the instructions in such communications or by using options provided in the  settings.

2. Access and correct the personal data we hold about you

In order to ensure that you get better Services, we hope you can provide us with the right personal information. You are entitled to check whether or not we hold data about you and to have access to that data, and to request for a copy of such data. If any part of the data is incorrect or inaccurate, you have the right to request for corrections. And you also have the right to refrain from providing any information to us. You understand that this may, however, have an impact on your use of the Services and on the ease of User interactions (such as engaging in trades with other Users)

3. Other rights

You also have the right to have your personal data deleted, object how we use or share your personal data, and restrict how we use or share your personal data. You can always withdraw your consent.

If you have questions about data protection, or any requests for resolving issues with your personal data, we encourage you to primarily contact us so we can reply to you more quickly. We will respond to all requests within a reasonable time frame.

4. Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://policies.igg.com/view/?id=124.

V. INTERNATIONAL DATA TRANSFERS

By accepting this Privacy Policy, Users understand and agree that your data may be collected, stored, used in any country and/or transferred to any country in the world. Because different countries may have different data protection laws than Users’ own country, we will try to ensure that adequate safeguards are in place to protect Users’ data.

 

VI. SPECIAL NOTE TO INTERNATIONAL USERS

In the event of any dispute arising out of or in connection with this Privacy Policy, including any question regarding its existence, validity or termination, (a “Dispute”), we strongly encourage that a resolution first be sought through our Customer Support service.

You agree that in the event that a resolution is not obtained through our Customer Support service, such Dispute shall be referred by you and may be referred by us to and finally resolved by arbitration in Singapore in accordance with the Arbitration Rules of the Singapore International Arbitration Centre ("SIAC Rules") for the time being in force, which rules are deemed to be incorporated by reference in this clause. The Tribunal shall consist of three (3) arbitrators, with you appointing one (1) arbitrator and us appointing one (1) arbitrator and the third arbitrator to be selected by the two (2) arbitrators so appointed. The language of the arbitration shall be English.

Notwithstanding any of the foregoing, you agree that we are entitled to submit such Dispute for resolution through any other dispute resolution mechanism including the courts of any jurisdiction and we shall further be entitled to seek any injunctive or other equitable relief in the event of any breach or anticipatory breach by you, without any obligations of providing any bond or surety or proof of damages.

You irrevocably waive all rights to seek any injunctive or other equitable relief or to enjoin or restrain the operation or exploitation of the Services or any part thereof. You further irrevocably waive all rights to a class or representative action or as a named or unnamed member in a class, consolidated, representative or private attorney general action.

 

VII. OUR POLICIES CONCERNING CHILDREN

Accounts can only be registered by persons who are at least 18 years of age. Furthermore, IGG Store is not intended to be accessed by persons under 18 years of age. We do not intentionally collect any personally identifiable information from persons under 18 years of age. In the event that we learn that we have inadvertently gathered personally identifiable information from persons under 18 years of age, we will take commercially reasonable measures to ensure that such information is removed from our records. 

VIII. DATA SECURITY

We use commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your personal information. We cannot, however, ensure or warrant the security of any information you disclose on, through or within the Services and you do so entirely at your own risk. Please note that we cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. In particular, please note that any personally identifiable information or personally sensitive data that you communicate or disclose to any User in connection with our Services may be collected and used by others.

If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice on the Website if a security breach occurs.

We may record and store archives of any communications to monitor interactions between our Users and the use of our Services.

 

If you create an Account with the IGG Store, you will be required to select a password that can be changed at any time after you first log into the Account by using your current password. You are solely responsible for maintaining the confidentiality of your password and are fully responsible for all activities that occur under your Account and password or your account with any other third party service. Users agree to (i) notify us immediately if you are aware or reasonably suspect of any unauthorized use of your Account or password or of any unauthorized access of the Services through your Account, and (ii) ensure that you exit from your Account at the end of each session.

You should review the privacy policies of the communication facilities or other third-party services you choose to visit via hyper-links posted on or within the Services so that you can understand how these third parties collect, use and share your information. We are not responsible for the privacy policies of any third-party whether accessed through our Services or otherwise.

IX. MERGER, ACQUISITION, SALE OR INSOLVENCY

1. In the event that we are acquired by or merged with another entity, we reserve the right, in any of these circumstances, to transfer the information or assign our rights to the information that we have collected from our Users as part of such merger, acquisition, sale, or other change of control.

2. In the event of our insolvency, reorganization, receivership, winding-up or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control how your personal information is treated, transferred, or used.

 

X.  CHANGES AND UPDATES TO THIS PRIVACY POLICY

1. This Privacy Policy may be revised, amended or modified periodically. Please re-visit this page to stay in touch with any changes. Your access of the Services signifies your acceptance and agreement to this Privacy Policy (as may be amended or revised from time to time).

2. For questions about our privacy policy, please submit your questions via email to help.cn.store@igg.com. If you would like to change, modify or update your personal information which you have provided in relation to your Account which you registered with us or pursuant to your access of the Services through your account with any third party service, please submit the request via email to help.cn.store@igg.com.

 

XI. CONTACT US

If you have any questions or concerns about any of the matters in relation to this Privacy Policy, including to exercise any of your rights, then there are several ways of contacting us:

1. via email to help.cn.store@igg.com; or

2. to our European representative at igg@activemind.legal; or

3. to our Data Protection Officer at dpo@igg.com