This Privacy Policy explains what personal data YOUZU GROUP (also "we", "us" or "our") will collect from a GTarcade user (hereinafter referred to as "you") and how we store, transfer, use and protect such personal data. We will also inform herein you of your rights in respect to your personal data. This Privacy Policy shall apply to the GTarcade platform content, games, applications, activities, purchases and other services provided by us (hereinafter collectively referred to as the "services").

This Privacy Policy was last modified on September 09, 2019.

YOUZU GROUP, including but not limited to YOUZU GAMES HONGKONG LIMITED, YOUZU (SINGAPORE) PTE LTD and their affiliates, is responsible for the personal data that you share with us. YOUZU GROUP is the “data controller” for the purposes of applicable data protection laws. Our contact information is as follows:

Email:

Website:

DPO’s Email:


<h3> 1. What Data We Collect </h3>
1.1 Data you provide to us

1.1.1 Data you provide when sign up

To sign up for a GTarcade account, you are required to provide us with account information and contact information, as follows:

Account information, including your account name and account password (which will be encrypted); and
Contact information, namely your email address, which will be used to reset the password.
The above data you provided is necessary and essential to provide you with the requested services, and if you refuse to provide such data, you will not be able to use our services.


In addition, you may edit your profile as needed, including head portrait, name, gender, date of birth, living location, national code and extra contact information. Such profile will ensure you a better experience of our services and if you choose to edit such profile, you shall be deemed as giving your consent for us to process such profile accordingly.
All your data is protected by GTarcade account authorization. Therefore, you must keep your password safe and do not disclose it to anyone else in any way.


1.1.2 Data you provide during using services


During using our services, you may be required to provide certain personal data as needed. To be specific, the scenarios include:



Mobile number: In order to secure your account, such as password reset, account recovery and account security verification, we will collect your mobile number. If you have agreed and confirmed to receive push notifications, we may occasionally send you text messages about our promotions, sales or any other information you may be interested in. Please contact us at should you have any questions or would like to decline receiving push notifications.

Order processing: In order to process orders that you make on GTarcade platform, we will collect your basic information (including role name and game zone), payment information (including the owner, card number, CVC, postal code and validity period of the bankcard) and order detail information (including recharge amount and payment mode);
Customer service: In order to respond to your inquiry or support request, we will collect your basic information (including the game you play, role name and game zone), contact information, the detail of your request and communication record, and the purchase history record (for retrieving password);
Survey: In order to conduct surveys for multiple purposes, we may ask for your basic information (including age, role name and game zone) and your preference information (such as your preferences, interests, hobbies, your favorite games, and general demographic information or other related information); and
For the supplementary account information and information we collect during survey or promotion, since they are not essential or mandatory, it’s your right to refuse to provide such information. Please note that if you choose not to provide us with such information, we may not always be able to provide you with the service which may be based on such information.



1.2 Data we automatically collect

1.2.1 Data about your devices

When you use the services, we may automatically collect some device-related information accordingly, to be specific:


Device data, including the operating system and its version, hardware and software versions, ISP and browser type, processing capabilities, manufacturer and model, language and other regional settings, unique device IDs and similar unique identifiers, screen resolution, other device attributes or similar settings; and

Data collected by your device, including geographic location, network environment information, device preference settings, APP version number, IP address and other data you allow us to collect by enabling permissions in your device's setting. 




1.2.2 Data about your behavior

When you use the services, we may automatically collect some information about your behavior, to be specific:

Operation record, namely the record of your use of the services, including timestamps, clicks, scrolling, browsing times, searches, closing pages, the games you play, in-game activity and interactions, the links you accessed on
Game information, including game name, zone name, server name, role name, role level, virtual currency and other items in the game, friend list, group list;
Payment information, including order number and purchased product, purchase history, amount, currency, payment status, delivery information;
Communication information, including your comments in the game, your current status, the content you post on the forum and other your communications and interactions with others;
Preference choice information, namely your preference settings, including preferred language, font, color, the game you play, the browsed advertisement; and
Other related information, including the monitoring data of availability and quality of the services, loading errors and bugs. We also collect data by cookies and   similar technologies, the detailed information please refer to our 



1.3 Data from third parties


We only collect limited data from third parties when you use the services through their products or platforms. Such third parties include but are not limited to Apple, Facebook, Google, Twitter, Yahoo and Windows. To be specific:

Third parties account information: we may collect third parties account open-id and authentication status when you login via third parties account or download our products on your device from third-party platforms; and

Payment information: we may collect order number and purchased product, your purchase history, amount, currency, payment status, delivery information when you purchase products or make payments via third-party platforms.




<h3> 2. How We Use Your Personal Data </h3>


Depending on the purpose for which the data is used, the legal basis for the processing of your data can be:


1)      Your consent;

2)      Our legitimate interest, which can be:

Improvement of our products and services: more specifically, our business interests to help us better understand your needs and expectations and therefore improve our services and products for our consumers’ benefit;
Fraud prevention: to ensure payment is complete and free from fraud and misappropriation; and

Securing our facilities: to keep our facilities used to provide services safe and secure and to ensure they are working properly and are continually improving.


3)      The performance of a contract: more specifically to perform the services you request from us; and

4)      Legal grounds where a processing is required by law.


2.1 To provide products and services and complete daily operation

Our following data processing is necessary to provide our products and services, and if you refuse us to conduct such processing, you may be unable to use our services or certain functions:

In the signing up procedure, we may process your account information and contact information to create your personal account;
We may process your device data, data collected by your device, preference settings information to adapt our services to your device;
To complete daily operation of the services, we may process your device data, account information, operation record, network environment information, the data related to customer service and payment information;
To provide customer service, respond to inquiries, requests, problems, and support transaction process, we may process your account information, the data related to customer service, communication information and data collected by your device.
To provide and deliver the products and services you order, we may process your name, address, email address and other necessary data;
To verify whether you are qualified for contests or promotion activities, we may process your user name, role name, game zone and contact information; and

We may process your account information, contact information and the data related to customer services to send you policy announcement, security alerts and other necessary notifications.




2.2 To optimize our products and user experience

Our following data processing aims to optimize our products and user experience. If you refuse us to conduct such processing, you may not be able to use better products and services:

To improve the services and your experience, we may process your operation record, device data, preference information collected from survey, communication information, payment information and monitoring data of availability and quality of the services; and
To provide social features and improve your game experience, we may process your preference information collected from survey, game information, preference choice information and data from third party.
Upon your confirmation, you will be able to obtain better experience through our data processing as follows:

To send you the information in which you may be interested, including activity notification and promotional information, we may process your account information, personal basic data and data related to customer service;
To conduct surveys, contests, promotions and similar offerings, we may process your account information, data related to customer service and your preference information collected from survey; and

To evaluate the effectiveness of survey, promotion and campaign activities, we may process your account information, operation record and payment information.




2.3 To ensure the security of personal data and the services

We may use the information which we collect to verify your account and activities, suppress against harmful activities, detect and prevent junk information and other malicious actions, and strengthen the security of your personal data within and outside GTarcade products. To fulfil our legal obligations in the applicable laws, we may process necessary information for the following purposes:

To monitor and protect services against fraud behavior, such as robot access, illegal add-ons, we may process your account information, device data, network environment information, operation record and game information;
To keep heathy social environment, and limit communication against illegal topics and content, we may adopt automatic technologies and process your account information and communication information to detect, filter and block forbidden content in black list; and
To protect your account from unauthorized access and protect your transaction from fraud, we may process your account information, personal basic data, payment information, device data, network environment information and the data related to customer service.


<h3> 3. Cookies </h3>
A cookie is a small piece of information stored as a text file on your web browser. We use cookies and similar technologies for purposes such as:

To authenticate your identity (to identify the sites and services that are accessible to you);
For security purposes and to maintain the integrity of our websites and products (to protect the security of your account data and prevent possible data threats);
For advertising, making recommendations, performing effectiveness analyses and measurement purposes;
To provide the features and services of our websites; and
To enhance performance.
In certain circumstances, third parties may use cookies for our products in order to provide you with services which are associated with our services.

Please see our   for more information regarding the use of cookies and other technologies described in this section, including regarding your choices relating to such technologies. If you disable our cookies, some of the services we provide to you will be unavailable or affected.


<h3> 4. How We Protect Your Personal data </h3>

4.1 Data security management system

We have implemented data security management system that meets industry-standard, including organizational processes and technical solutions, to protect your personal data against unauthorized access, modification, copy, or deletion. For example, our network communication is encrypted and protected by HTTPS protocol. We have set up firewalls, WAF (web application firewall) and anti-DDOS flow cleaning devices at network boundary to detect and defend against web attacks. We have encryption mechanism and strict access control to protect data in database. Besides, we have implemented collaborative security defense system at both network and terminal level to protect the information system and the computing environment. In addition to the technical solutions, we also implemented information security management system, which is based on ISO27001, to set up policy, process and procedures which regulate employees’ daily information processing activities, such as access, modify, editing, storage, share, transfer and deletion. This system ensures that only authorized personnel can access the protected data, and can be used only in the authorized way. And we also provide training and arrange awareness raising activities about data security and privacy protection, so as to enhance employees' awareness regarding the importance of personal data protection.


4.2 Data security capabilities

For the security of your personal data, we adopt leading security technologies and continuously update our data security capabilities. To be specific, our data security capabilities include but are not limited to application layer encryption, network layer encryption, database encryption, network access monitoring, database access monitoring, host behavior monitoring, terminal behavior monitoring and tracking, and other technologies.


4.3 Personal data protection suggestions

Even with our data security capabilities, the internet is still not an absolutely secure environment. We strongly recommend that you shall at least take the following steps to enhance the security of your account:

Avoiding sending personal data in an unencrypted way; and

Using complex passwords, which should include numbers, alphabet letters, special symbols, and avoid names, birthdays and similar information.




4.4 Response to data security incidents

We have implemented reasonable technical and organizational measures to safeguard your personal data. If unfortunately, any personal data breach or similar security incident happens, we will promptly take responses to control and mitigate the influence of the incident. According to mandatory requirements in applicable laws and regulations, we will timely inform you as needed and share with you the following information:

The nature and possible impact of the incident;
The name and contact details of the data protection officer or other contact point where more information can be obtained;
The measures taken or proposed to be taken by us to address the personal data breach, including, where appropriate, measures to mitigate its possible adverse effects;
The suggested actions you can take to eliminate or reduce risks; and
The remedial measures for you, where appropriate.
We will promptly inform you of the incident by mail, telephone, push notification, etc. When it is difficult to inform the affected data subjects one by one, we will take a reasonable and effective way to publish the announcement.

Besides, in the case of any security incident, we will actively and timely, where feasible, notify the incident to the competent supervisory authority according to requirements in applicable laws and regulations.


<h3> 5. How We Share and Disclose Your Personal Data </h3>
We will NOT share or disclose your personal data with any other commercial entity, organization or individuals, except for the following situations:

With your consent. We may disclose sharing or disclose your personal data when you provide us with your consent to do so;
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.


Service providers. In order to support the purpose listed in this Privacy Policy, our agents or contractors (either data controller or data processor) may need access to information to carry out services, including but not limit to, logistic, payment, sms, email, anti-fraud, risk management, advertisement attribution and etc. Information shared with such service providers will follow the principle of legal, proper, essential, and with clear defined purpose. We also sign NDA and DPA with each service provider to make sure they will follow our requirements, including the requirements mentioned in this Privacy Policy, to deal with the shared information and subject to confidentiality obligations; 

YOUZU GROUP Affiliates. GTarcade service is part of YOUZU GROUP. We may share information with our affiliates YOUZU GAMES HONGKONG LIMITED and YOUZU (SINGAPORE) PTE. LTD within the purpose and scope listed in this Privacy Policy; 

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 corresponding 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; and 

Other third parties. Where permitted by law, we may also share information with authorized third parties for the following purpose in case of essentials: protect crucial public interest, statistics analysis, science or history research. 
<h3> 6. Global Data Storage and International Transfer </h3>
Our services are provided globally. Our main IDC is located in California, USA, while our secondary IDC is located in Singapore. This means, your personal data as mentioned in section 1. What Data We Collect will be transferred to both IDC mentioned above. And also, your information will be processed and stored in both IDCs. We will not transfer your personal data out of the EEA until receipt of your explicit consent. In the meanwhile, we will implement all necessary and reasonable security measures before transferring data out of the EEA, and you can refer to section 4. How We Protect Your Personal data for details.

You are CLEARLY aware of the above-mentioned cross-border transfer of personal data, understand the risks that may exist, and FULLY AGREE that we may transfer and store your personal data according to the Privacy Policy.

In case you want to withdraw your consent and stop us from transferring your personal data out of the EEA, you can refer to section 7. How You Can Manage Your Personal data to submit a request.


<h3> 7. How You Can Manage Your Personal data </h3>
We provide multiple channels to support your privilege to manage your personal data:

You are entitled to access and modify your account information by visiting My Account – Edit Profile;
Since the personal data we collect and store is necessary to deliver our services, we will not delete them except in the following circumstances that you can ask us to delete your account and personal data by visiting Support – Game Name – Submit A ticket. But please note, this may limit your access to GTarcade services:
a.     Where our processing of the personal data violates laws and regulations;

b.     Where we collect and use your personal data without your consent;

c.     Where our processing of personal data breaches the agreement with you;

d.     Where your account is terminated and personal data deletion request is submitted.

When you delete the information from our services, we may not immediately delete the corresponding information from the backup system, but will delete the information when the backup is updated;

We may sometimes be able to restrict the use of your data. This means that it can only be used for certain things, such as legal claims or to exercise legal rights. You can ask us to restrict the use of your personal data if:
a.     It is not accurate;

b.     It has been used unlawfully but you don’t want us to delete it;

c.     It is not relevant any more, but you want us to keep it for use in legal claims;

d.     You have already asked us to stop using your data but you are waiting for us to tell you if we are allowed to keep on using it.

If we do restrict your information in this way, we will not use or share it in other ways while it is restricted. If you want to ask us to restrict how we use your data you can send e-mail to ;

If you’re concerned with the way we process your personal data, or would like to submit a request regarding your personal data, such as asking for a portable and well formatted copy of your personal data, you can visit Support to submit your request, or find our contact information by visiting Contact Us, or send e-mail to ;
If you’re concerned with the cross-border data storage and transfer we described in section 6. Global Data Storage and International Transfer, and would like to submit a request to withdraw your consent, you can visit Support to submit your request, or find our contact information by visiting Contact Us, or send e-mail to ;
You shall have the right to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you, which is based on public interest, or our legitimate interest, including profiling based on those two legal grounds; and
You can object to an automated decision we have made, and ask that a person reviews it. If you want to know more about these rights, please contact us by sending e-mail to .
Other than the above, you can also:
a.     Make your choice regarding whether to connect your social media account with GTarcade account by visiting My Account - Connect Account;

b.     Make your choice regarding subscription services by visiting My Account - Subscription Services, including Account Services, Games, Player Benefits, Claim information;

c.     Manage the access authorization of our APP to your device by changing mobile device authorization settings; and

d.     Make your choice regarding cookie or other similar technologies by configure your browser settings.

To deal with your request, we may require proof of your identity. You can refer the complaint to the relevant regulatory authority in your jurisdiction. If you consult us, we will provide you with information on the applicable complaint route according to your actual situation.


<h3> 8. Children Personal data Protection </h3>
We will NOT knowingly collect or store personal data from children under 16. We can’t identify children users with the minimum information we collected, but we recognize a special need to protect the personal data of children.

We urge children’s legal guardian to instruct children not to give out their real names, addresses, or other personal data without legal guardian’s permission during online service. GTarcade also recommends that legal guardians familiarize themselves with parental controls available.

However, we may collect technical information required for delivering the service from all users. These information is protected with the information security system introduced in section 4. How We Protect Your Personal data. If legal guardian believe that we have unintentionally collected their children’s personal data or otherwise used their children’s personal data for unauthorized purpose, please reach out to us immediately and we will delete relevant data as soon as possible. Please see the section 10. Contact Us below for further details.


<h3> 9. Updates to This Privacy Policy </h3>
We may update our Privacy Policy from time to time to reflect changes in technology, law, our business operations, or any other reason we determine is necessary or appropriate. When we do make changes, we will update the “Last Modified” date at the top of the policy and post it to the GTarcade services. If we make material changes to the policy or the ways we process player information, we’ll provide you additional notice as well.

We encourage you to check back periodically to review this policy for any changes since your last visit. This will help ensure you better understand your relationship with GTarcade, including the ways we process your information.

We will give you prior notice of any modifications to this Privacy Policy to allow you to review the modified Privacy Policy before you choose to continue to use our products. If you do not consent to the modified Privacy Policy, you will be unable to continue to use our services.

Please click here to view the old version.


<h3> 10. Contact Us </h3>
For any inquiries or concerns of our services, you can visit to contact our customer support team, or send e-mail to , we will respond to you within 15 working days.

We have a privacy protection and management team to monitor and protect your personal data. If you have any questions or requests regarding the protection of personal data, please feel free to send email to: .