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Flow Entertainment Privacy Policy
Welcome to games provided by Flow Entertainment.
Your information security is very important to us. Flow Entertainment commits itself to provide a safe game environment for every user. This policy is part of the Terms of Service , which also means that users who visit this site are also subject to these Terms of Service (including but not limited to the limitations of liability, dispute resolution, and applicable law provisions). Please review and understand all applicable rules and only use Flow Entertainment Products and Services (as defined below) if you agree.
The purpose of the Privacy Policy is to provide our users with a clear idea of how we collect, use, share, transmit, and protect their information. In short, we will only process the user’s personal information according to their consent and/or other legal bases on which its personal information is processed.
Introduction
The Privacy Policy applies to products and/or services offered by Flow Entertainment . Please carefully read and fully understand the Policy before using (including but not limited to, installation, access, registration, or otherwise) the Products and Services provided by us. Once you use or continue to use our Products and Services, it means that you are well-informed and voluntarily and explicitly agree that we process your relevant information in accordance with the Privacy Policy.
How Do We Collect and Use Your Personal Information
2.1 Providing you with Products and Services
2.1.1 Security assurance. We will use part of your frequently used equipment personal information for authentication, security protection, fraud monitoring, archiving and backup, and other purposes. For example, the unique equipment code is used for security protection and user identification and the personal Internet surfing record is used for security protection and fraud monitoring.
2.1.2 Product development and service optimization. To fix game faults, improve functions, manage advertisements, and enhance the experience, information collected by us includes device information such as device model, operating system version, and unique device identification code, software information such as IP address and software version number, and service log information such as game fault information.
We have listed the information we collect in the Personal Information Collection List here.
2.2 Sensitive personal information and special categories of information
Sensitive personal information refers to personal information that may endanger personal and property security and easily result in damage to personal reputation and physical and mental health or discriminatory treatment once it is disclosed, illegally provided or abused. Special categories of information refer to the information specified in Article 9 of the General Data Protection Regulation ("GDPR"), such as information on health, race, religion, political opinion or philosophical belief, and sexual preference or sexual orientation. Flow Entertainment does not require users to provide such information and reminds users that they should be careful when sharing their or others' such information in the service.
2.3 Exceptions to obtaining authorization and consent
In accordance with relevant laws and regulations, we may process some necessary personal information without your authorization and consent under the following conditions:
a. if it is directly related to national security and national defense security;
b. if it is directly related to public security, public health and major public interests;
c. if it is directly related to the criminal investigation, prosecution, trial, and execution of judgment;
d. if this information aims to safeguard your or others' personal life, property, and other important legitimate rights and interests, but it is very difficult to obtain your consent;
e. if the personal information involved is open to the public on your own;
f. if this information is necessary to sign and fulfil a contract according to your requirements;
g. if your personal information is collected from lawfully and publicly disclosed information such as legal news reports, government information disclosure, and other channels.
h. if this information is necessary to maintain the safe and stable operation of Products and Services of Flow Entertainment such as detecting and handling product or service faults.
i. other conditions prescribed by laws and regulations.
2.4 Scope of application of the Policy
The Policy applies to all our Products and Services except certain specific Products and Services. Specific privacy policies apply to these specific Products and Services. Specific privacy policies for certain specific Products and Services describe more concretely how we collect and use your information in such Products and Services. If there is any inconsistency between privacy policies for relevant specific Products and Services and the Policy, privacy policies for these specific Products and Services prevail.
2.5 Applicable exceptions of the Policy
Our services may include or be linked to social media or other services (including websites) provided by third parties. For example:
You share our Products and Services, or you access our Products and Services using a third-party online service. These functions may collect your relevant information (including your log information) and install cookies on your computer to run the above-mentioned functions properly.
We provide you with links by advertisements or other means of our service so that you can access third-party services or websites. Such third-party social media or other services may be operated by third parties. Your use of such third parties' social media services or other services (including any personal information you provide to such third parties) is subject to the third parties' terms of service and privacy policy (rather than the Policy). You need to read their terms carefully. The Policy applies only to the information we collect. It does not apply to any services provided by third parties or the rules governing the use of information provided by third parties. We are not responsible for any third party's use of the information provided by you.
How Long Do We Store Your Personal Information
3.1 Data we collect will be retained only for so long as reasonably necessary for the purposes set out above, unless applicable law requires otherwise. If the purpose of collecting information is achieved, for example, when the user's account is terminated or when the user withdraws consent to the use of personal information, Flow Entertainment will immediately destroy the collected personal information. Personal information in printed form will be shredded and incinerated, and electronic files will be destroyed in an irretrievable manner.
How Do We Use Cookies and Similar Technologies
4.1 Cookie
Cookies typically contain identifiers, site names, and some numbers and characters. We will store small data files called cookie on your computer or mobile device to ensure the normal operation of the website and help us identify you as our registered user. We will not use cookies for any purpose other than those stated in the Policy. You can set managing or deleting cookies based on your preference through a browser or otherwise.
4.2 Do Not Track
Many web browsers provide the Do Not Track function that can make a Do Not Track request to websites. If the Do Not Track function is enabled in your browser, all our sites will respect your choice. However, note that this may affect your experience in using the Products and Services provided by Flow Entertainment.
How Do We Share and Transfer Your Personal Information
5.1 Sharing
You understand and agree that we will provide personal information to third parties by means of sharing and transfer under the condition of ensuring that the data receiver cannot re-identify the personal information subject (de-identification).
We may share your personal information with any company, organization, or individual other than Flow Entertainment under the following conditions:
a. Sharing with express consent: We will share your personal information with other parties with your express consent.
b. We may externally share your personal information in accordance with laws and regulations or any mandatory requirements of the competent administrative department.
c. Sharing with our affiliates: Your personal information may be shared with affiliates of Flow Entertainment. We will only share necessary personal information and be bound by the purposes stated in the Policy. If affiliates want to change the processing purpose of personal information, we will ask for your authorization and consent again.
d. Sharing with authorized partners: Some of our services will be provided by authorized partners for only the purposes stated in the Policy. We may share some of your personal information with our partners to provide better customer service and user experience. We will share your personal information for only legitimate, rightful, necessary, specific, and specific purposes and only share personal information required to provide services. Our partners have no right to use shared personal information for any other purpose. Currently, our authorized partners include the following two types:
a) Authorized partners of advertising and analysis service type. Unless we get your permission, we will not share your personal identity information (information that is enough to identify you, such as a name or email address, through which we can contact you or identify you) with partners who provide advertising and analysis services.
b) Suppliers, service providers and other partners. We will send information to suppliers, service providers and other partners who support our business, such as communication service providers who push notifications on our behalf. These supports include the provision of technical infrastructure services, the analysis of the use method of our services, the measurement of the effectiveness of advertisements and services, the provision of customer services and payment convenience, and other supports for Products and Services of Flow Entertainment.
5.2 Transfer
We will not transfer users' personal information to any unrelated company, organization or person except as required by laws and regulations of the People's Republic of China and relevant jurisdictions. We will continue to protect users' personal information in accordance with standards required by laws and regulations or require new administrators to continue to do so in accordance with the Policy.
We have listed out details on how we share and transfer your personal information in the Personal Information Sharing List here.
Your Rights
In accordance with relevant laws, regulations, and practices in relevant countries and regions, we guarantee that you can exercise the following rights on your personal information:
6.1 Access your personal information
You have the right to access your personal information except for exceptions prescribed by laws and regulations.
6.3 Delete or correct your personal information
We will collect and use your information only to achieve the functions of our products or services, as stated in the Private Policy. If you find that we collect and use your personal information in violation of laws, administrative regulations, or agreements between the parties, you may ask us to delete it. If you find that your personal information that we collect and store is incorrect, you can also ask us to correct it. Please contact us through the contact details stated in the Private Policy.
6.5 Respond to your above-mentioned request
To ensure security, you may need to provide a written request or otherwise prove your identity. We may ask you to verify your identity and then process your request. We will reply within a reasonable time limit. If you are not satisfied, you can contact the Flow Entertainment in-game customer service or . We do not charge any fee in principle for your reasonable request, but we will charge a certain cost for repeated requests that exceed a reasonable limit. We may refuse requests that are repeated for no reason, need excessive technical means (for example, needing to develop new systems or fundamentally changing the existing practices), pose a risk to others’ legitimate rights and interests, or are highly impractical (for example, involving information that is stored on backup tapes).
We will not be able to respond to your request under the following conditions, as required by laws and regulations:
a. if it is directly related to national security and national defense security;
b. if it is directly related to public security, public health and major public interests;
c. if it is directly related to criminal investigation, prosecution, trial, and execution of judgment;
d. if there is sufficient evidence to show that you have subjective malicious intent or abuse rights;
e. if responding to your request will result in serious damage to the legitimate rights and interests of you or any other person or organization;
f. if business secrets are involved;
g. other cases where we have reasonable grounds to refuse.
How Do We Handle Minors' Personal Information
In cases where minors' personal information is collected with the consent of their parents or guardians, we will use or publicly disclose this information only with the permission of the law, the express consent of their parents or guardians or the protection on minors.
How Do We Protect Your Personal Information
8.1 We take reasonable and feasible measures to protect your personal information
Our legal team is also responsible for handling matters relating to data protection. We have also set up specific processes and security procedures for specific user data collection and processing to ensure that data storage and usage can meet our expectations and legal and regulatory requirements. In addition, we regularly conduct risk assessments of security strategies and data protection measures to ensure that our products are not threatened by risks such as data breaches or privacy violations. But please note that information collected by third parties may not have the same security protections as information users submit to us, and we are not responsible for protecting the security of such information.
8.2 Other security measures that we take to protect
a. We manage and standardize the storage and use of information by establishing a data classification and grading system, a data security management standard, and a data security development standard.
b. We perform comprehensive security control over data through an information contact confidentiality agreement and a monitoring and auditing mechanism.
c. We only allow the information to be accessed by Flow Entertainment employees who need to know about this information and require that all those who may have access to your information should fulfil the corresponding confidentiality obligations. Failure to fulfil these obligations may lead to legal liability or suspension of the employment or cooperative relationship with Flow Entertainment.
d. We will take all reasonable and feasible measures to ensure that no unrelated personal information is collected. We will retain your personal information only for a reasonable period unless it is necessary to extend the retention period or unless otherwise permitted by law.
e. The Internet environment is not 100% secure and we will do our best to ensure or guarantee the security of any information that you send to us. While we take reasonable precautions against possible loss, misuse, or unauthorized access, no storage system or transmission of data over the Internet can be guaranteed to be secure. If our physical, technical, or administrative safeguards are damaged, resulting in unauthorized access to, publicly disclosure, tampering, or destruction of information and thus damage to your legitimate rights and interests, we will be held legally accountable accordingly.
f. Following the unfortunate incident of personal information security, we will take the necessary measures to stop the security incident from escalating and inform you in the form of push notifications, announcements, etc.
Special Sections for Specific Jurisdictions
9.1 EU. If you are located in the EU, the General Data Protection Regulation (EU regulation No. (EU) 2016/679) applies to the collection and use of your data by Flow Entertainment.
Flow Entertainment is a multinational group incorporated outside the EU. Your information can be accessed from China, where our main place of business locates. Using our service and providing information to us means that you confirm and understand that your information will be transmitted, stored, and processed on a computer located in China in the manner described in the Policy. Do not use this service if you object to the transmission or use of personal information in the manner described in the Policy.
9.2 Japan. If you are located in Japan, the Personal Information Protection Act of Japan applies to the collection and use of your data by Flow Entertainment.
Flow Entertainment is a multinational group incorporated outside Japan. Your information can be accessed from China, where our main place of business locates. Using our service and providing information to us means that you confirm and understand that your information will be transmitted, stored, and processed on a computer located in China in the manner described in the Policy. Do not use this service if you object to the transmission or use of personal information in the manner described in the Policy.
9.3 South Korea. We will remove as soon as possible any information that is no longer needed under the purposes stated in the Policy and retain your data in the games in accordance with the retention period requirements specified in the relevant Korean laws.
a.The Policy specifies that our Products and Services are only applicable to users aged over 14 and that children under the age of 14 shall not use our services.
b.To help prevent fraudulent users from using the services and to comply with applicable laws, Flow Entertainment may retain the information collected for the following periods:
a) Records on the conclusion of the contract and the exercise of the right of withdrawal: 5 years.
b) Records on payment and provision of goods/services: 5 years.
c) Records on customer complaints or dispute resolution: 3 years.
d) Proof of all transactions stipulated by the Tax Law based on the Framework Law on National Taxation: 5 years.
e) Information related to withholding tax under the Income Tax Act: 5 years.
f) Request form, consent form and related documents of the user or the legal representative of the minor (only if the consent form is provided offline): 3 years.
g) Duplicate subscription confirmation information of fraudulent users:5 years from the date of with drawal of membership.
In addition, if your information is collected for a specific purpose (e.g., promotion or surveys), that information will be destroyed as soon as Flow Entertainment achieves the purpose for which it was collected.
9.4 United States.
a. Minimum age: The minimum age of users is 13 years old in the United States. Therefore, unless otherwise permitted by law, we do not intend to collect any personal information of children under the age of 13 in the United States without parental consent. If we know that children under the age of 13 provide us with personal information, we will delete them in accordance with applicable laws.
b. Do Not Track: Some web browsers can send "Do Not Track" signals to websites and other online services that communicate with the browsers, as described in the above-mentioned section "3. How do we use cookies and similar technologies". Currently, no standard specifies how to respond when websites and online services receive these signals. Currently, we do not take any action to respond to these signals. If response standards are established, we may review the Policy to respond to these signals.
c. User privacy rights in the state of California (hereinafter referred to as "California"):
If you are located in California, Flow Entertainment will not share your personal information with third parties for the purpose of direct marketing of third parties pursuant to the Shine the Light Law of California.
In addition to describing our common practices on data processing as completely as possible above, we supplement other practices on information collection and sharing under this item pursuant to the California Consumer Privacy Act (hereinafter referred to as "CCPA") to comply with the CCPA's requirements for information disclosure to California residents:
a) In the past 12 months, Flow Entertainment collected, used, and shared personal information of the types described in the section "How do we collect and use your personal information" of the Policy. For example, such information may include your identifier such as IP address and mobile device identifier, depending on services you use.
b) We do not share information by selling personal information pursuant to the state laws.
c) Pursuant to the California laws, we give you the rights stated in Item 6 above, i.e. rights to access, control, correct, and delete personal information. Please send your request to our in-game customer services or to our email at . Upon receipt of your request, we may require you to provide sufficient information to confirm your identity and thus verify the request, including requesting you to verify information about your use of services.
9.5 Brazilian
a. The Brazilian General Data Protection Act provides you the right to:
a) Confirm Flow Entertainment’s processing of your data;
b) Access your data;
c) Correct your incomplete, inaccurate, or outdated data;
d) Request anonymization, blocking or elimination of unnecessary or excessive data or of data processed in noncompliance with the Brazilian General Data Protection Act;
e) Port your data to other service providers or suppliers of products;
f) Delete your personal data when processed with your consent;
g) Obtain information on the public and private entities with whom Flow Entertainment shared your data;
h) Obtain information on the possibility of not providing consent and on the consequences of the denial;
i) Revoke your consent to the processing of your data when we seek your consent;
j) Lodge complaints before data protection authorities.
b. Whenever we use your personal information based on your consent, you may revoke the consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account via our in-game customer service.
c. If you are under the age of 18, you should not use our service for any purpose without first obtaining parental/guardian agreement to this privacy policy (both for themselves and on your behalf). We do not knowingly collect personal information from any children under the age of 18 without such consent. Please contact us if you believe we have any personal information from any children under the age of 18 without such parental/guardian consent – we will promptly investigate (and remove) such personal information.
BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORIZE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES AND TRANSFERRING TO COUNTRIES OTHER THAN BRAZIL, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.
Possible Changes to The Policy
We may revise this Policy from time to time if it deems necessary or appropriate, such as technology enhancements, legal compliance, or changes in our business operations. We will not diminish your rights under this privacy policy without your express consent. We will publish any changes to the Policy on this page.
For major changes, we will also provide more obvious notices. We will notify you before such changes take effect by posting the updated policy or otherwise in accordance with applicable law. If you do not agree to the changed content, you may choose to stop using our services. If you continue to use our services, it means that you agree to be bound by the amended Policy. We encourage you to periodically check this Policy to review any changes made since your last visit. This will help us better understand your relationship with us, including how we process your information.
Contact Us
With respect to your personal data, if you have any questions, comments, or suggestions on the Policy, contact our customer service.
Additionally, if your inquiry has not been satisfactorily addressed, please feel free to email our Data Compliance Protection Department at .
Welcome to games provided by Flow Entertainment.
Your information security is very important to us. Flow Entertainment commits itself to provide a safe game environment for every user. This policy is part of the Terms of Service , which also means that users who visit this site are also subject to these Terms of Service (including but not limited to the limitations of liability, dispute resolution, and applicable law provisions). Please review and understand all applicable rules and only use Flow Entertainment Products and Services (as defined below) if you agree.
The purpose of the Privacy Policy is to provide our users with a clear idea of how we collect, use, share, transmit, and protect their information. In short, we will only process the user’s personal information according to their consent and/or other legal bases on which its personal information is processed.
Introduction
The Privacy Policy applies to products and/or services offered by Flow Entertainment . Please carefully read and fully understand the Policy before using (including but not limited to, installation, access, registration, or otherwise) the Products and Services provided by us. Once you use or continue to use our Products and Services, it means that you are well-informed and voluntarily and explicitly agree that we process your relevant information in accordance with the Privacy Policy.
How Do We Collect and Use Your Personal Information
2.1 Providing you with Products and Services
2.1.1 Security assurance. We will use part of your frequently used equipment personal information for authentication, security protection, fraud monitoring, archiving and backup, and other purposes. For example, the unique equipment code is used for security protection and user identification and the personal Internet surfing record is used for security protection and fraud monitoring.
2.1.2 Product development and service optimization. To fix game faults, improve functions, manage advertisements, and enhance the experience, information collected by us includes device information such as device model, operating system version, and unique device identification code, software information such as IP address and software version number, and service log information such as game fault information.
We have listed the information we collect in the Personal Information Collection List here.
2.2 Sensitive personal information and special categories of information
Sensitive personal information refers to personal information that may endanger personal and property security and easily result in damage to personal reputation and physical and mental health or discriminatory treatment once it is disclosed, illegally provided or abused. Special categories of information refer to the information specified in Article 9 of the General Data Protection Regulation ("GDPR"), such as information on health, race, religion, political opinion or philosophical belief, and sexual preference or sexual orientation. Flow Entertainment does not require users to provide such information and reminds users that they should be careful when sharing their or others' such information in the service.
2.3 Exceptions to obtaining authorization and consent
In accordance with relevant laws and regulations, we may process some necessary personal information without your authorization and consent under the following conditions:
a. if it is directly related to national security and national defense security;
b. if it is directly related to public security, public health and major public interests;
c. if it is directly related to the criminal investigation, prosecution, trial, and execution of judgment;
d. if this information aims to safeguard your or others' personal life, property, and other important legitimate rights and interests, but it is very difficult to obtain your consent;
e. if the personal information involved is open to the public on your own;
f. if this information is necessary to sign and fulfil a contract according to your requirements;
g. if your personal information is collected from lawfully and publicly disclosed information such as legal news reports, government information disclosure, and other channels.
h. if this information is necessary to maintain the safe and stable operation of Products and Services of Flow Entertainment such as detecting and handling product or service faults.
i. other conditions prescribed by laws and regulations.
2.4 Scope of application of the Policy
The Policy applies to all our Products and Services except certain specific Products and Services. Specific privacy policies apply to these specific Products and Services. Specific privacy policies for certain specific Products and Services describe more concretely how we collect and use your information in such Products and Services. If there is any inconsistency between privacy policies for relevant specific Products and Services and the Policy, privacy policies for these specific Products and Services prevail.
2.5 Applicable exceptions of the Policy
Our services may include or be linked to social media or other services (including websites) provided by third parties. For example:
You share our Products and Services, or you access our Products and Services using a third-party online service. These functions may collect your relevant information (including your log information) and install cookies on your computer to run the above-mentioned functions properly.
We provide you with links by advertisements or other means of our service so that you can access third-party services or websites. Such third-party social media or other services may be operated by third parties. Your use of such third parties' social media services or other services (including any personal information you provide to such third parties) is subject to the third parties' terms of service and privacy policy (rather than the Policy). You need to read their terms carefully. The Policy applies only to the information we collect. It does not apply to any services provided by third parties or the rules governing the use of information provided by third parties. We are not responsible for any third party's use of the information provided by you.
How Long Do We Store Your Personal Information
3.1 Data we collect will be retained only for so long as reasonably necessary for the purposes set out above, unless applicable law requires otherwise. If the purpose of collecting information is achieved, for example, when the user's account is terminated or when the user withdraws consent to the use of personal information, Flow Entertainment will immediately destroy the collected personal information. Personal information in printed form will be shredded and incinerated, and electronic files will be destroyed in an irretrievable manner.
How Do We Use Cookies and Similar Technologies
4.1 Cookie
Cookies typically contain identifiers, site names, and some numbers and characters. We will store small data files called cookie on your computer or mobile device to ensure the normal operation of the website and help us identify you as our registered user. We will not use cookies for any purpose other than those stated in the Policy. You can set managing or deleting cookies based on your preference through a browser or otherwise.
4.2 Do Not Track
Many web browsers provide the Do Not Track function that can make a Do Not Track request to websites. If the Do Not Track function is enabled in your browser, all our sites will respect your choice. However, note that this may affect your experience in using the Products and Services provided by Flow Entertainment.
How Do We Share and Transfer Your Personal Information
5.1 Sharing
You understand and agree that we will provide personal information to third parties by means of sharing and transfer under the condition of ensuring that the data receiver cannot re-identify the personal information subject (de-identification).
We may share your personal information with any company, organization, or individual other than Flow Entertainment under the following conditions:
a. Sharing with express consent: We will share your personal information with other parties with your express consent.
b. We may externally share your personal information in accordance with laws and regulations or any mandatory requirements of the competent administrative department.
c. Sharing with our affiliates: Your personal information may be shared with affiliates of Flow Entertainment. We will only share necessary personal information and be bound by the purposes stated in the Policy. If affiliates want to change the processing purpose of personal information, we will ask for your authorization and consent again.
d. Sharing with authorized partners: Some of our services will be provided by authorized partners for only the purposes stated in the Policy. We may share some of your personal information with our partners to provide better customer service and user experience. We will share your personal information for only legitimate, rightful, necessary, specific, and specific purposes and only share personal information required to provide services. Our partners have no right to use shared personal information for any other purpose. Currently, our authorized partners include the following two types:
a) Authorized partners of advertising and analysis service type. Unless we get your permission, we will not share your personal identity information (information that is enough to identify you, such as a name or email address, through which we can contact you or identify you) with partners who provide advertising and analysis services.
b) Suppliers, service providers and other partners. We will send information to suppliers, service providers and other partners who support our business, such as communication service providers who push notifications on our behalf. These supports include the provision of technical infrastructure services, the analysis of the use method of our services, the measurement of the effectiveness of advertisements and services, the provision of customer services and payment convenience, and other supports for Products and Services of Flow Entertainment.
5.2 Transfer
We will not transfer users' personal information to any unrelated company, organization or person except as required by laws and regulations of the People's Republic of China and relevant jurisdictions. We will continue to protect users' personal information in accordance with standards required by laws and regulations or require new administrators to continue to do so in accordance with the Policy.
We have listed out details on how we share and transfer your personal information in the Personal Information Sharing List here.
Your Rights
In accordance with relevant laws, regulations, and practices in relevant countries and regions, we guarantee that you can exercise the following rights on your personal information:
6.1 Access your personal information
You have the right to access your personal information except for exceptions prescribed by laws and regulations.
6.3 Delete or correct your personal information
We will collect and use your information only to achieve the functions of our products or services, as stated in the Private Policy. If you find that we collect and use your personal information in violation of laws, administrative regulations, or agreements between the parties, you may ask us to delete it. If you find that your personal information that we collect and store is incorrect, you can also ask us to correct it. Please contact us through the contact details stated in the Private Policy.
6.5 Respond to your above-mentioned request
To ensure security, you may need to provide a written request or otherwise prove your identity. We may ask you to verify your identity and then process your request. We will reply within a reasonable time limit. If you are not satisfied, you can contact the Flow Entertainment in-game customer service or . We do not charge any fee in principle for your reasonable request, but we will charge a certain cost for repeated requests that exceed a reasonable limit. We may refuse requests that are repeated for no reason, need excessive technical means (for example, needing to develop new systems or fundamentally changing the existing practices), pose a risk to others’ legitimate rights and interests, or are highly impractical (for example, involving information that is stored on backup tapes).
We will not be able to respond to your request under the following conditions, as required by laws and regulations:
a. if it is directly related to national security and national defense security;
b. if it is directly related to public security, public health and major public interests;
c. if it is directly related to criminal investigation, prosecution, trial, and execution of judgment;
d. if there is sufficient evidence to show that you have subjective malicious intent or abuse rights;
e. if responding to your request will result in serious damage to the legitimate rights and interests of you or any other person or organization;
f. if business secrets are involved;
g. other cases where we have reasonable grounds to refuse.
How Do We Handle Minors' Personal Information
In cases where minors' personal information is collected with the consent of their parents or guardians, we will use or publicly disclose this information only with the permission of the law, the express consent of their parents or guardians or the protection on minors.
How Do We Protect Your Personal Information
8.1 We take reasonable and feasible measures to protect your personal information
Our legal team is also responsible for handling matters relating to data protection. We have also set up specific processes and security procedures for specific user data collection and processing to ensure that data storage and usage can meet our expectations and legal and regulatory requirements. In addition, we regularly conduct risk assessments of security strategies and data protection measures to ensure that our products are not threatened by risks such as data breaches or privacy violations. But please note that information collected by third parties may not have the same security protections as information users submit to us, and we are not responsible for protecting the security of such information.
8.2 Other security measures that we take to protect
a. We manage and standardize the storage and use of information by establishing a data classification and grading system, a data security management standard, and a data security development standard.
b. We perform comprehensive security control over data through an information contact confidentiality agreement and a monitoring and auditing mechanism.
c. We only allow the information to be accessed by Flow Entertainment employees who need to know about this information and require that all those who may have access to your information should fulfil the corresponding confidentiality obligations. Failure to fulfil these obligations may lead to legal liability or suspension of the employment or cooperative relationship with Flow Entertainment.
d. We will take all reasonable and feasible measures to ensure that no unrelated personal information is collected. We will retain your personal information only for a reasonable period unless it is necessary to extend the retention period or unless otherwise permitted by law.
e. The Internet environment is not 100% secure and we will do our best to ensure or guarantee the security of any information that you send to us. While we take reasonable precautions against possible loss, misuse, or unauthorized access, no storage system or transmission of data over the Internet can be guaranteed to be secure. If our physical, technical, or administrative safeguards are damaged, resulting in unauthorized access to, publicly disclosure, tampering, or destruction of information and thus damage to your legitimate rights and interests, we will be held legally accountable accordingly.
f. Following the unfortunate incident of personal information security, we will take the necessary measures to stop the security incident from escalating and inform you in the form of push notifications, announcements, etc.
Special Sections for Specific Jurisdictions
9.1 EU. If you are located in the EU, the General Data Protection Regulation (EU regulation No. (EU) 2016/679) applies to the collection and use of your data by Flow Entertainment.
Flow Entertainment is a multinational group incorporated outside the EU. Your information can be accessed from China, where our main place of business locates. Using our service and providing information to us means that you confirm and understand that your information will be transmitted, stored, and processed on a computer located in China in the manner described in the Policy. Do not use this service if you object to the transmission or use of personal information in the manner described in the Policy.
9.2 Japan. If you are located in Japan, the Personal Information Protection Act of Japan applies to the collection and use of your data by Flow Entertainment.
Flow Entertainment is a multinational group incorporated outside Japan. Your information can be accessed from China, where our main place of business locates. Using our service and providing information to us means that you confirm and understand that your information will be transmitted, stored, and processed on a computer located in China in the manner described in the Policy. Do not use this service if you object to the transmission or use of personal information in the manner described in the Policy.
9.3 South Korea. We will remove as soon as possible any information that is no longer needed under the purposes stated in the Policy and retain your data in the games in accordance with the retention period requirements specified in the relevant Korean laws.
a.The Policy specifies that our Products and Services are only applicable to users aged over 14 and that children under the age of 14 shall not use our services.
b.To help prevent fraudulent users from using the services and to comply with applicable laws, Flow Entertainment may retain the information collected for the following periods:
a) Records on the conclusion of the contract and the exercise of the right of withdrawal: 5 years.
b) Records on payment and provision of goods/services: 5 years.
c) Records on customer complaints or dispute resolution: 3 years.
d) Proof of all transactions stipulated by the Tax Law based on the Framework Law on National Taxation: 5 years.
e) Information related to withholding tax under the Income Tax Act: 5 years.
f) Request form, consent form and related documents of the user or the legal representative of the minor (only if the consent form is provided offline): 3 years.
g) Duplicate subscription confirmation information of fraudulent users:5 years from the date of with drawal of membership.
In addition, if your information is collected for a specific purpose (e.g., promotion or surveys), that information will be destroyed as soon as Flow Entertainment achieves the purpose for which it was collected.
9.4 United States.
a. Minimum age: The minimum age of users is 13 years old in the United States. Therefore, unless otherwise permitted by law, we do not intend to collect any personal information of children under the age of 13 in the United States without parental consent. If we know that children under the age of 13 provide us with personal information, we will delete them in accordance with applicable laws.
b. Do Not Track: Some web browsers can send "Do Not Track" signals to websites and other online services that communicate with the browsers, as described in the above-mentioned section "3. How do we use cookies and similar technologies". Currently, no standard specifies how to respond when websites and online services receive these signals. Currently, we do not take any action to respond to these signals. If response standards are established, we may review the Policy to respond to these signals.
c. User privacy rights in the state of California (hereinafter referred to as "California"):
If you are located in California, Flow Entertainment will not share your personal information with third parties for the purpose of direct marketing of third parties pursuant to the Shine the Light Law of California.
In addition to describing our common practices on data processing as completely as possible above, we supplement other practices on information collection and sharing under this item pursuant to the California Consumer Privacy Act (hereinafter referred to as "CCPA") to comply with the CCPA's requirements for information disclosure to California residents:
a) In the past 12 months, Flow Entertainment collected, used, and shared personal information of the types described in the section "How do we collect and use your personal information" of the Policy. For example, such information may include your identifier such as IP address and mobile device identifier, depending on services you use.
b) We do not share information by selling personal information pursuant to the state laws.
c) Pursuant to the California laws, we give you the rights stated in Item 6 above, i.e. rights to access, control, correct, and delete personal information. Please send your request to our in-game customer services or to our email at . Upon receipt of your request, we may require you to provide sufficient information to confirm your identity and thus verify the request, including requesting you to verify information about your use of services.
9.5 Brazilian
a. The Brazilian General Data Protection Act provides you the right to:
a) Confirm Flow Entertainment’s processing of your data;
b) Access your data;
c) Correct your incomplete, inaccurate, or outdated data;
d) Request anonymization, blocking or elimination of unnecessary or excessive data or of data processed in noncompliance with the Brazilian General Data Protection Act;
e) Port your data to other service providers or suppliers of products;
f) Delete your personal data when processed with your consent;
g) Obtain information on the public and private entities with whom Flow Entertainment shared your data;
h) Obtain information on the possibility of not providing consent and on the consequences of the denial;
i) Revoke your consent to the processing of your data when we seek your consent;
j) Lodge complaints before data protection authorities.
b. Whenever we use your personal information based on your consent, you may revoke the consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account via our in-game customer service.
c. If you are under the age of 18, you should not use our service for any purpose without first obtaining parental/guardian agreement to this privacy policy (both for themselves and on your behalf). We do not knowingly collect personal information from any children under the age of 18 without such consent. Please contact us if you believe we have any personal information from any children under the age of 18 without such parental/guardian consent – we will promptly investigate (and remove) such personal information.
BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORIZE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES AND TRANSFERRING TO COUNTRIES OTHER THAN BRAZIL, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.
Possible Changes to The Policy
We may revise this Policy from time to time if it deems necessary or appropriate, such as technology enhancements, legal compliance, or changes in our business operations. We will not diminish your rights under this privacy policy without your express consent. We will publish any changes to the Policy on this page.
For major changes, we will also provide more obvious notices. We will notify you before such changes take effect by posting the updated policy or otherwise in accordance with applicable law. If you do not agree to the changed content, you may choose to stop using our services. If you continue to use our services, it means that you agree to be bound by the amended Policy. We encourage you to periodically check this Policy to review any changes made since your last visit. This will help us better understand your relationship with us, including how we process your information.
Contact Us
With respect to your personal data, if you have any questions, comments, or suggestions on the Policy, contact our customer service.
Additionally, if your inquiry has not been satisfactorily addressed, please feel free to email our Data Compliance Protection Department at .