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PRIVACY POLICY

NETDRAGON WEBSOFT (HONG KONG) LIMITED, (herein "we" or "us", “ours”), including its subsidiaries and affiliates, understands the importance of protecting your personal information (the "Personal Information"). We have adopted this privacy policy (the "Policy") to explain how we collect, use, process, store and share the Personal Information that provide to us or we collect when you use our websites, software applications, games or any other products and services provided by us (the " Products and Services").

We collect, use, process, store and transfer your Personal Information in accordance with applicable data protection legislation, including but not limited to the (EU) General Data Protection Regulation ("GDPR") and applicable national data protection legislation ( together with GDPR, "Applicable Laws"). Wherever we talk about Personal Information below, we mean any information that can either by itself identify you as an individual or that can be connected to you indirectly by linking it to your Personal Information. We also collect, use, process, store and transfer anonymised data, whether aggregated or not, to analyse and generate reports related to usage patterns, spending habits, demographics of users, etc. As an individual is not or no longer identifiable from such anonymous data, the use of such data will not be governed by this Policy.

You agree that we will engage other third parties and may transfer your Personal Information to such third parties in order to fulfil our purposes and obligations as set out in this Policy. You acknowledge that some of these third parties may be located outside the country of your residence where there may not have as strict privacy legislation as yours. We will only transfer your Personal Information to such countries if we are allowed to do so, please see section D for more information.

By downloading, registering, accessing and/or using our Products and Services, you consent to our collection and use of your Personal Information in accordance with this Policy. IF YOU DO NOT AGREE TO THE POLICY, PLEASE DO NOT PROVIDE YOUR INFORMATION WHEN REQUESTED AND SHOULD REFRAIN FROM USING OUR PRODUCTS AND SERVICES.

A.COLLECTION OF YOUR PERSONAL INFORMATION
We collect Personal Information about you to provide you with our Products and Services.
Depending on the type of Products and Services you are using, we may collect the following types of information from you:
(i)Personal Information
· Identification information, including but not limited to your surname and first name, date of birth, nominated nickname, identification we import from your linked social media accounts, gender, age, country of residence, user ID and profile picture.
· Contact information, including but not limited to your email address and mobile phone number

(ii)Data that may be collected automatically concerning how you use our Products and Services
· Data about your connection and device, including but not limited to your open ID, IP address, mobile device identifier, advertising ID, MAC address, IMEI device name, operating system, browser type, hardware information and language.
· Data about your use of our website, including but not limited to browsing time, click-activity, referring website, date/time stamp for your visit and/or data we collect with cookies and similar technologies (Please see Section B for further information).
· Data about your location, including general and precise geo-location data such as GPS location.
· Data about your use of the Products and Services, including but not limited to account history, usage/session time, preferences, audio or video recordings, gameplay data, game progress, crashes or bugs data, social media sharing and interactions, purchase history and billing history.
· Data required to be collected for detection, investigation and prevention of fraud, cheating, misuse of our Products and Services or other violations to our End User Agreement or Applicable Laws.

(iii)Data that you may provide to us
· Data about processing payments, including bank card information such as name, issuer, card number, billing address, expiration date, security code, e-wallet account number, name or ID or other anti-fraud verification code.
· Data about your use of our Products and Services, including but not limited to messages, posts, comments, conversations transmitted or submitted through the Products and Services (such as chat logs and player support tickets).
· Data you choose to provide to us to request information or support from us or to purchase Products and Services or to participate in competitions or tournaments or respond to our questionnaires or surveys, including but not limited to personal data to identify a lost account, account number, email address, photographs, security questions and answers you created, contact information.
· Any other data that you provided to us as part of the Products and Services, or that we collected with your consent to provide you with the Products and Services or for specific purposes made known to you at the time of collection.

(iv)Data that may be provided to us by third parties
· Data about you from other third-parties who have obtained your consent or otherwise are permitted by Applicable Laws to share such data with us, including but not limited to your account information registered under other third-party applications (if you have linked such applications to our Products and Services or accessed such applications by using our social media features) and may include profile picture, email address, user name, gender, language, country, users ID and profile pictures of your followers, friends or contacts. The types of information we receive will depend on your settings with such third-party applications.
· Data which include attributes about you and your interests as further detailed in section B.

B.Use of Data
We may use your Personal Information for the following purposes:
· to provide you with and maintain our Products and Services, including but not limited to our games, websites and mobile applications;
· to evaluate, customise and improve the Products and Services and the user experience;
· to handle, process and execute any transactions related to the Products and Services;
· to provide you with our customer and/or technical support;
· to analyse the use and trends of the Products and Services;
· to seek your opinion about our Products and Services and conducting surveys on the Products and Services;
· to send or disseminate confirmation notices, updates, and security alerts;
· to manage any abusive, unlawful or dishonest uses of Products and Services or violation to our End User Agreement, such as managing player bans;
· to prepare and offer push ads, newsletters, promotions, rewards, and other types of content or features that match with your interests;
· to customise the Products and Services, in particular by providing features or ads which correspond to your interests and/or your preferences;
· to improve the safety and reliability of our Products and Services;
· to research and develop other services; or
any other purposes described in the Policy or for specific purposes made known to you at the time of collection.

Legal Basis
Under Applicable Laws, our use of your Personal Information must be justified under one of a number of legal bases. Our principal legal basis that justifies our use of your Personal Information are:
· Contract Performance: where it is necessary for us to perform our contract with you in providing you with our Products and Services;
· Legitimate Interests: where we collect and use your Personal Information for legitimate interests, such as for the purposes of our compliance with Applicable Laws, to ensure information security, to prevent fraud, etc. When we rely on a legitimate interest, we shall ensure that our interests do not override your interests or fundamental rights and freedoms.
· Your Consent: where you have consented to our collection and use of your Personal Information, for example, by agreeing to this Policy. You may withdraw your consent at any time;
· Legal Requirement: where it is necessary for us to defend, prosecute or make a claim against you, us or a third party.

Analytics and optimisation
(i)Cookies
Cookies, or similar technologies such as cookies, web beacons, web server logs, scripts, eTags or other similar technologies (“Cookies”), are small computer files stored on your hard drive. Various types of Cookies may be used to enable us to provide certain features and functionalities and they are placed on our websites either by us or by other third parties permitted by us. The information collected by Cookies enables us to monitor site traffics and users’ interactions with other services. We may also use certain cookies that can only collect generic information in relation to browser configurations and personalize the appearance of our websites. We also use anti-cheat technologies that also use Cookies as described below.
You have the option to permit installation of such Cookies or subsequently disable them. You may accept or decline or instruct to be notified of the storage of Cookies by changing the configurations of your web browser (in the case of websites) or the device (with respect to games or applications). However, if you decline to install Cookies, the Products and Services and/or certain features may not work properly as intended. For more information on cookies, please refer to the following website: http://www.allaboutcookies.org.

(ii)Third-party analytics tools

Marketing and Advertising
If you choose to receive our marketing materials, newsletters and news releases, the Personal Information you have provided us with will allow us to send you messages regarding new features, updates, contests and events concerning our Products and Services or to show you promotions, services or products that might be of interest to you in connection with the Products and Services. You may opt-out of this service at any time.
You acknowledge and agree that if you opt-out of receiving interest-based or targeted advertising, you may still see advertising which may or may not be related to our Products and Services, but the relevant advertising will not be targeted using your Personal Information.
We also use information about you to improve user experience and to ensure that you only see marketing materials that might be of interest to you. Our marketing partners use ads serving technologies for this purpose.

Ads Serving Technologies
Ads serving technologies, including interest-based ads, from our suppliers, involve the use of pixels and/or other similar technologies to collect data in order to determine what kinds of advertising you would prefer to see.
Data collected by these third parties may include, without limitation, (i) your age and/or sex, (ii) your IP address and/or country, (iii) the advertisements placed and their location in the Products and Services, (iv) the duration of visibility of an advertisement as well as the number of views, (v) the identifiers and settings of your device, (vi) your use of the Products and Services and/or other websites (including third party websites) you have viewed (as well as the date and the time of such viewing), and/or (vii) your responses to the advertisements, if any, to allow our suppliers to calculate the number of views of the advertisements or to present ads in a format that best suits your device. Advertisements may be tailored to your interests, for example, you could view an offer for a game or product that might interest you.
Third-party advertising service providers may associate Personal Information with data that they have collected independently from other services in accordance with their own privacy policies. We do not collect or access data that may be independently collected by these third parties. To learn more about some of these ad network practices, you can visit www.networkadvertising.org, www.aboutads.info/choices, or www.youronlinechoices.com.

The technologies deployed by us as described above are fundamental to our Products and Services. If you do not consent to the use of the abovementioned technologies, you should stop using or accessing our Products and Services.

Anti-cheating services
We may use anti-cheating tools ("Anti-Cheating Tools") that are provided or operated by third parties in form of software (the "Software") that has been integrated into our Products and Services, in particular, in our games.
When you start a new game session, the Software may automatically load and install its latest version on your device. When using the game, the Anti-Cheating Tools may scan the game's binary files and the device's memory to detect and prevent cheating in the game (the "Objective"). By installing or accessing any of our games, you agree that the Anti-Cheat Products and Services may collect, store and disclose to us Personal Information for the sole purpose of fulfilling the Objective and also to identify players who cheat in games and prohibit them from doing so. This Objective is necessary to pursue our legitimate interests and to ensure the safety of you and other users of our Products and Services.
The collection of data by such Anti-Cheat Service providers will be governed by their privacy policies. If you think that your access to our Products and Services has been blocked by mistake by the Anti-Cheating Tools, please contact us at co@netdragon.com.

Social Media Features
You may be able to use our social media features for logging into our Products and Services, find out if your friends play our games, and invite them to join you in these games. If you choose to use social media features in some of our Products and Services or to create an account with us using your account with a certain social media platform, the social media platform will provide us with some of your Personal Information, such as your social media platform user ID, your profile picture (to create your avatar in certain games) and the user IDs and profile pictures of your followers, friends or contacts on such social media platform. You may determine the scope and extent of Personal Information that will be provided to us by modifying your sharing settings.

Public data, including user-generated content, online forums, blogs, chat and profiles
You may communicate Personal Information when you provide or otherwise create content by using or accessing our Products and Services, whether as part of games, online forums, blogs, discussion platforms, public user profiles or other similar forums available as part of our Products and Services (collectively, the "Forums"). Any Personal Information you disclose in the Forums would become public data and may be read or used by other users without your consent. If you decide to disclose Personal Information on the Forums, you will do so at your own risk and we shall not be responsible for held liable for any unauthorised use of such Personal Information by any third parties.
You may choose not to provide certain Personal Information. However, you may not be able to use certain or all features of our Products and Services.

C.Personal Data Shared with Third Parties
We may, from time to time, engage independent subcontractors to provide us with certain services, such as sending e-mails, processing payments, hosting data, and providing customer support. We take reasonable contractual measures to ensure that these third parties adequately protect Personal Information.
We do not share Personal Information with other third-parties, except as necessary for providing the Products and Services, for our legitimate business needs, for carrying out your requests, and/or as may be required or permitted by Applicable Laws.
In particular, we engage third parties to collect and process your Personal Information on our behalf and for our benefits in order to provide the Products and Services, including but not limited to:
· Our holding companies, subsidiaries or affiliated companies in and/or outside of Hong Kong in order to operate the Products and Services globally
· Independent contractors and/or service providers for them to provide their services to us information technology system providers, customer relationship providers, marketing research and profiling services providers, advertising partners, payment processing services providers
· Providers of cloud and network services that process or back up information identified in this Policy on their servers for the purposes of providing our Products and Services and other associated services
· Potential investors, valuers or such professionals in connection with any potential merger, acquisition, sale, assignment, financing or transfer of our business
· Insurance companies
· Regulators and law enforcement bodies for legal compliance purposes
We may share Personal Information that does not identify you directly, which is anonymized and/or aggregated, with third parties, for example, to analyze trends in the use of the Products and Services. In addition, we do not control the data sent by your web browser to third parties who receive this information in your normal course of activity on the Internet.

D.Location and Transfer of Your Personal Information
The Personal Information may be hosted and processed, for the purposes of the Policy, on servers operated by trusted partners that may or may not be located where you live. Our support, developers and other team members are located in different parts of the world and they may have access to your Personal Information from outside of where you live in order to provide timely support to constantly maintain our Products and Services. The servers of our games are located in [Hong Kong], or otherwise specified ]. These locations are either a jurisdiction with an adequate level of protection recognized by the European Commission or such transfers subject to appropriate safeguards as required by the Applicable Laws.
Some of our subcontractors described in Section C may be located in other countries, including outside the European Economic Area. By using the Products and Services and the games, you agree that your Personal Information may be processed by such subcontractors in countries that may not offer the same degree of data protection as your country. We will, however, only transfer the Personal Data in compliance with Applicable Laws.
We have taken reasonable contractual measures to ensure that our subcontractors would process your Personal Information in accordance with our directions and for our purposes as set forth in this Policy. Our subcontractors are prohibited from using your Personal Information for any other purposes without your consent.

E.Retention Period of Personal Information
We keep your Personal Information for a period not exceeding what is required for the purposes for which the Personal Information is collected and in accordance with Applicable Laws.
Your data will be kept in our active database:
· for the time as long as necessary to provide the Products and Services; or
· for the duration necessary to solve your technical problems or your request; or
· for the time needed to compile game statistics; and
· for 30 days for IP addresses and logs.
At the end of this period, your Personal Information will be deleted or anonymized by us, or archived in an intermediate database, if necessary, for legal, operational, or legitimate reasons, and for the legally prescribed period. The retention period may be changed upon your cancellation of or re-enrollment in the Products and Services, or in accordance with Applicable Laws.

F.Safeguards of your Personal Information
We take different measures to secure your Personal Information. We follow generally accepted rules in the video game industry, as well as Applicable Laws, to protect any loss, destruction, alteration, or unauthorized, unlawful or abusive use of Personal Information. We strive to use appropriate organizational and technical means to protect your Personal Information. For example, we will use encryption technologies (such as TLS, SSL), anonymization and other means to protect your personal information.
We have established a specialized management, process and organization system to ensure information security. For example, we strictly restrict the scope of personnel who can access information and require them to comply with their contractual confidentiality obligations and be subject to regular audits. In the event of a data breach or other security incident of Personal Information, we will activate an emergency response plan to prevent the expansion of such security incident and notify you in the form of push notifications, public announcements, etc.
However, you acknowledge that no security measures are 100% effective. To the extent permitted by Applicable Laws, we shall not be held liable for any direct or indirect loss, damages or costs sustained or incurred by you in the event of a data breach or if the Personal Information is subject to unauthorized use or access.
If you have any questions regarding the security of your Personal Information, please contact us by email at co@netdragon.com.

G.Your Rights and Choices on Your Personal Information
You enjoy the below rights with respect to your Personal Information that is in our possession or under our control under Applicable Laws.

The right to be informed
You have the right to be informed about the collection and use of your Personal Information by us. This Policy sets out the types of information we collect, the purposes for processing your Personal Information and the legal basis for doing so as well as the transfer, storage and handling by us of your Personal Information.
We strongly suggest you review this Policy carefully before using our Products and Services.

The right of access
You have the right access to Personal Information that is in our possession or under our control. The right of access also includes your right to know how we use your Personal Information in practice and who we share such information with.
For Products and Services for which you have created an account with us, you can access any of your Personal Information at any time by logging into the relevant Products and Services and adjusting your account settings.

The right of rectification
You have the right to rectify any of your Personal Information that is in our possession or under our control. Similar to the above, you may revise or supplement any of your Personal Information at any time by logging into the relevant Products and Services and adjusting your account settings.

The right to erasure and the right to restrict processing to storage
You have the right to request us to delete your account, to remove your Personal Information or to restrict the processing of your Personal Information where there are no compelling reasons for any continued processing. To do so, you may log in into the relevant Products and Services accounts or for any other information, you can contact us to request for erasure or restricted processing.
The right to erasure is however subject to our legitimate rights afforded under Applicable Laws to retain Personal Information for our legitimate purposes. An example is for enforcement of our legal rights.
If you require us to restrict the processing of your Personal Information other than for storage purposes, please note that we may use such Personal Information again if there are valid reasons under Applicable Laws for us to do so.

The right to data portability
You have the right to receive a copy of the Personal Information we process about you. You may also request us to transfer it to another party, except under certain exceptions.

The right to object
You have the right to object to our processing or use of your Personal Information at any time. In particular, you can object to our use of your Personal Information for direct marketing purposes.
If you wish to contact us regarding the processing of your Personal Information, or to have access to it in an electronic format, correct it, erase it, change how we process it (if applicable), or withdraw your consent (if applicable), or transfer them to another online provider (where technically possible), you may email us at co@netdragon.com. Please note that the withdrawal of your consent shall not affect the lawfulness of how we have used or processed your Personal Information before your withdrawal.
In the case of an email request, you agree to provide us with your contact information, the subject of the request and the Personal Information in question for our further action. We reserve the right to ask you for any information about you to confirm your identity.
Please note that if you choose to delete your Personal Information, you will no longer have access to the Products and Services associated with your internal and/or external identifier.
We reserve the right to reject deletion requests if there is a legal obligation on us to retain the Personal Information due to legal claims or as required by any Applicable Laws.
Your request will be processed within thirty (30) days of receipt, with the understanding that we reserve the right as permitted by Applicable Laws to extend this period to two months due to the complexity and number of requests.
You may also contact your local data protection authority for any questions relating to the collection and use of your Personal Information.

H.Children
Most of our Products and Services (including some of our games) are not directed to Children (“Controlled Products and Services”). WE DO NOT KNOWINGLY COLLECT, SOLICIT, MARKET TO OR REQUIRE THE PERSONAL INFORMATION BELONGING TO CHILDREN. IF YOU ARE BELOW THE MINIMUM APPLICABLE AGE IN YOUR COUNTRY, DO NOT SEND YOUR PERSONAL INFORMATION TO US AND DO NOT USE SUCH CONTROLLED SERVICES. If we obtain actual knowledge that we have collected data from Children, we will promptly delete it, unless we are legally obligated to retain such data.
For the purpose of this Section, by Children, we mean users under the age of 18 years old, or in the case of a country where the minimum age for processing Personal Information differs such different ages. The table below sets out the minimum relevant age specified in Applicable Laws:

Your Country Minimum relevant age
Brazil 18
China 14
Egypt 18
European Economic Area/Switzerland 16
India 18
Indonesia 21
Kingdom of Saudi Arabia 18
Malaysia 18
Russia 14
Singapore 18
Thailand 20
Turkey 18
United Arab Emirates 21
United Kingdom 13
United States 16

We require the parents’ and/or legal guardians’ personal information to create any user accounts for their Children to access our Controlled Products and Services. Such information may include full name and email address. We may also require the parent’s and/or legal guardian’s separate consent and acknowledgement to this Policy before allowing the creation of an account and/or access to our Controlled Products and Services.
Parents or legal guardians who are concerned about our use of data are welcome to contact us at co@netdragon.com.

I.Third party services
Our Products and Services may contain advertisements or links to third-party websites such as Twitter, Facebook and/or YouTube. The presence of these links on our Products and Services does not constitute an approval, authorization or affiliation with the websites in question. If you click on these links or use the services of a third party, you will leave our Products and Services and you must consult the privacy policy of the website in question before sharing your Personal Information.
Certain products and/or services are offered to you as part of our Products and Services in partnership with third parties and you may be required to provide Personal Information to them in order to register and access their products or services. The identity of these third parties will be indicated at the time of registration. If you choose to register, you will transmit your Personal Information to these third parties and their use of your Personal Information will be subject to their privacy policies.
We are not responsible for the use of your Personal Information by such third parties and we cannot guarantee that they have the same level of data protection policy as us.

K.Changes to the Policy
We reserve the right to change the Policy at any time. If we change the Policy, we will communicate the changes to you through the landing page or other similar page under the Products and Services, or any other appropriate means, for example, by email or with a pop-up notice in our games or on your account page, so that you will be fully informed of such changes. Any changes to the Policy will take effect thirty (30) days after such changes have been communicated to you. Your continued use of our Products and Services will be deemed as an acceptance of the changes to the Policy.

L.Severance
If any part or provision of this Policy is prohibited or deemed to be void or unenforceable, that part or provision shall be ineffective to the extent of such prohibition or unenforceability without invalidating the remaining provisions hereof.

M.Governing Law
This Policy shall be governed by, and construed in accordance with, the laws of Hong Kong Special Administrative Region (“Hong Kong”). Any dispute, controversy, difference or claim arising out of or relating to these Terms and Conditions, including the existence, validity, interpretation, performance, breach or termination thereof or any dispute regarding non-contractual obligations arising out of or relating to it shall be referred to and finally resolved by arbitration administered by the Hong Kong International Arbitration Centre (HKIAC) under the HKIAC Administered Arbitration Rules in force when the Notice of Arbitration is submitted. The seat of arbitration shall be Hong Kong. The number of arbitrators shall be one. The arbitration proceedings shall be conducted in English.

N.Communicate with Us
If you have any questions or concerns regarding this Policy, please contact us using information as follows:
Add: NetDragon Websoft, Inc.
21660 Copley Dr. Suite #180
Diamond Bar, CA 91765, USA
Tel: 1-909-612-1681 (10:00-18:00 PDT)
Email: co@netdragon.com.

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