KOF: Legend

PRIVACY POLICY

(Effective Date: 1st July, 2026)

JOYMAKER GAMES PTE. LTD. (“Company,” “we”, “us” or “our”) maintains these Privacy Policy (“Privacy Policy”) that summarizes our policies and processes on how we collect, use, disclose, transfer, and store your personal information.

The Privacy Policy applies only to the collection, use and storage of personal information that you (“users”) may decide to provide to us in your use of: (1) our website(s) (our “Sites”), (2) our application titled KOF: Legend is a mobile Game which can be played by y End Users on mobile devices, including smartphones and tablets supporting Android and iOS operating systems (collectively, the “Application”) and (3) chat rooms, blogs, web forums, messaging boards, or other public forums in Application and our Sites (collectively, our “Forums”). The Application, Sites, and Forums are referred to herein collectively, as the “Services”.

By accessing, registering with or using our Services, you agree to the Privacy Policies. If you do not agree with anything described in the Privacy Policies, please do NOT use our Services. We may amend this Privacy Policy from time to time. (see Section Changes to Our Privacy Policies.), so please check the Policies periodically for updates. Any such amendments will be automatically effective 10 calendar days after they are initially posted or displayed. You will be deemed to have accepted such amendments by continuing to use the Services.

We may translate this Privacy Policy into other languages. If there is any difference between the English version and other language versions, then the English version, subject to applicable laws and regulations, shall prevail.

What Information We Collect.

Personal information may be collected from you during your use of the Service, including, during (a) the registration process, (b) promotional campaigns, (c) customer support and technical service requests, and/or (d) ordering and use of products and other services, or from and through third-party service providers and partners.

A. Information Collected Directly From You

Registration Information. When you communicate directly with us, either through an Application, at our Site, or a Forum, you are authorizing us to collect, store, and use/share information collected from you in accordance with this Privacy Policy. Such information is limited to: (i) UID, valid e-mail address, and mobile phone number provided for registration verification purposes; and (ii) billing information collected solely for in-game top-up records.

From time to time, we may expand or change the information requested upon registration or log-in, so this may not be a complete list. We ask that you provide only your personal information, not that of anyone else.

Usage Information. We collect details of your use of our Services and the resources that you access. Such usage information includes how and when you access or use our Services (such as Games accessed, game scores, pages visited, purchases, and use of Virtual Money and/or Virtual Goods, the details of your purchases, and your gameplay).

Interaction and Communications among Users. We collect information about (i) your interaction with other users (for example, invite, gift, sharing of your rank or level, screen-shots, etc.) and (ii) your communication and interaction with your contacts through social media channels (including, social network services, messengers, and any other services which has social features like invite friends and sharing information with friends).

Information through Mobile Devices. When you use an Application or Third Party Mobile Application on your mobile telephone or other mobile devices (“Mobile Device”), in addition to such information described above, you are authorizing us to collect, store and use/share the following information (as applicable): (a) Mobile Device type; (b) mobile carrier; (c) Internet Protocol address; (d) geographic location/country; (e) platform version; (f) navigation, interaction and engagement information regarding our users (g) MAC address, International Mobile Equipment Identity (IMEI), display resolution, time and date on screen of Mobile Devices (h) O.S. information, (i) Installed application list, process information, and crash logs; (j) Device sensor data (accelerometer, gyroscope); (k) Network quality data, user operation/behavior data, and game screen data, and (l) such other information you choose to provide to us. In addition, we receive and store information you provide when you sign up to have Short Message Service (“SMS”) notifications set directly to your Mobile Device.

Payment and Billing Information. If you purchase any in-Service items, our third party partners will collect the payment and billing information necessary to complete the transaction. Such information may include: (i) your first and last name; (ii) your valid e-mail address; (iii) credit card, PayPal and other third party payment processor information; (iv) billing address; and (v) such other information you choose to provide. Our third-party partner may also receive the foregoing information that you provide when you purchase the Application and the Third Party Mobile Application through your Mobile Device.

Customer Service and Support. When you send an email or other communications to us in connection with customer service and support, we will collect and store your contact information, information about your use of the Service, your user ID, and such other information you provide to us in order to process your inquiries, respond to your requests, and improve our Service. We will also store the correspondence and any information contained therein.

Profile Information. We provide areas on our Service where you can post information about yourself and others and communicate with others or upload content such as photographs. Such postings are governed by the applicable Terms of Service. In addition, such postings may appear on other websites or services, or when searches are executed on the subject of your posting. Also, whenever you voluntarily disclose personal information in publicly viewable areas, that information will be publicly available and may be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control anyone who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information.

Distribution of Promotional Merchandise. We may collect your precise location for the purpose of delivering gifts in promotional activities such as sweepstakes. Such sensitive information will be deleted upon completion of the delivery service.

B. Information Received from third parties

Because the Application is accessible through third-party platforms, you authorize us to access certain information from your profile through their Application Programming Interface (“API”). The information we receive varies by the Application and by the privacy settings of the third-party platforms, and may include any or all of the following information, as allowed by you, the third-party platforms, and your privacy preferences: (i) your first and last name; (ii) your profile picture or its URL; (iii) your user ID number, which is linked to publicly available information such as name and profile photo; (iv) the user ID numbers of your friends who are also connected to our Application(s); (v) the login email you provided to the third-party platform when you registered; (vi) your physical location and that of your access device(s); and (vii) your gender. The third-party platforms through which such information is collected may include social media platforms or software service providers (e.g., Facebook, LINE, Instagram, YouTube, Discord, Google, etc.).

How We Collect Personal Information

As described below, when you access our Services, we collect certain technical information and may associate such information with your user or account ID number for our internal use.

Cookies. A cookie is a small text file stored on your device when you visit a website. We use cookies to collect general, non-personal information (e.g. user name, pages viewed, time spent on our Site(s), and referring/exit pages) for statistical and market research purposes, to improve our Services, and to better understand user behavior.

We may also use flash cookies to prevent fraud, remember your in-game settings, and track your progress on certain tasks.

You have choices regarding cookies. By adjusting your browser settings, you can reject or limit certain cookies. Flash cookies are not managed through your browser; you can manage them at www.adobe.com. Please note that limiting cookies may, in some cases, affect your ability to access certain features of our Services.

Log Files. Like most online services, we use server-side log files. These logs may collect your IP address, device type, operating system version, language settings, device identifiers, session timestamps, and in-game activity data. We use this data to analyze trends, administer our Services, and improve our products and marketing efforts.

Our software also generates log and temporary files stored on our servers, which may contain your account information, preferences, system notifications, and other data necessary for you to use our Services. Your information may also be included in routine server backups.

Tracking Technologies. We may use tracking technologies such as web beacons (also known as pixel tags or clear GIFs). These are small data elements embedded in images to analyze traffic patterns, such as how often users visit certain areas of our Services. Pixel tags may also help us deliver more efficient advertising by excluding current users from certain promotions or identifying new installations. These technologies may transmit information to us or to authorized third parties on our behalf. We also use them in HTML emails to determine if they have been opened or if links have been clicked. The information collected through web beacons is anonymous and does not include your name, address, phone number, or email address.

Third-Party Advertisers. Some advertisements on our Services are managed by third parties. These advertisers may use cookies, web beacons, or similar technologies on your device to deliver targeted ads and measure their effectiveness by collecting non-personal information when you interact with their ads. We may share certain non-personal information with advertisers to help them deliver more relevant ads. In some cases, we may receive information from these third-party technologies that allows us to identify other sites or services you have visited that are associated with the advertiser.

The use of cookies, web beacons, or similar automated information collection technologies by third party advertisers is subject to their own privacy policies. Finally, once you have clicked on an advertisement and have left the Service, our Privacy Policy no longer applies and you must read the privacy policy of the applicable third party advertiser to see how your personal information will be collected, stored and used as part of their service.

Monitoring/Public Information. You may also choose to disclose personal information in our Forums. Personal information you disclose in such Forums is public information, and there is no expectation of privacy or confidentiality. Please refer to the Terms of Service for additional information relating to the disclosure of personal information in such Forums.

Other Sources. We may collect or receive information from other sources including other users of the Service and third party information providers and partners. For example, we receive and store the information you provide when you enter any promotion, sweepstakes or loyalty program. Such information may be used to supplement your account information and/or profile and may be combined with other information we collect from you.

How We Use Your Information

1. Purpose of Use

We use information we collect about you, including your personal information, to operate our business, improve our Services, and personalize your experience. We may also use the information for such other purposes as allowed by law. For example, we (or a third party on our behalf and under our instructions) may collect, process and use your information for such purposes including the following:

(a) to allow you to register for and use our Services, and personalize your service experience;

(b) to audit and analyze data to improve and ensure the continued smooth operation of our Service;

(c) for market research purposes, including, without limitation, to analyze user characteristics and usage patterns in order to understand better how our Services are used and market them more effectively;

(d) to communicate with you concerning your account, purchases, subscriptions or services, and to send you announcements, newsletters, promotional materials, offers, and other information about our Services or offerings of our business partners, and to offer you opportunities to participate in surveys, contests and sweepstakes;

(e) to prevent or investigate actual or suspected fraud, hacking, infringement, cheating, malicious or illegal activity, or other misconduct involving our Service;

(f) to respond to inquiries, troubleshoot problems, investigate incidents, and handle complaints;

(g) provide, maintain, protect and improve our Services, including keeping you posted on our latest Service announcements, software updates and upcoming events, and develop new services;

(h) protect our rights or property or that of our users;

(i) to satisfy any applicable law, regulation, legal process or enforceable government request;

(j) to send notices, such as communications about your purchases and changes to our Terms of Service, this Privacy Policy and other Service-specific policies, and to enforce applicable terms and conditions set forth in such policies;

(k) to enable user-to-user communications; and

(l) protect against harm to the rights, property or safety of the Company, its users or the public as required or permitted by law;

The Company processes personal information on our databases, equipment and servers (owned by the Company and/or third parties in Hong Kong and in other countries). In some cases, we may process personal information outside of your country.

If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications or contact us as specified in section How to Contact Us.

1. Data retention

In general, we retain your personal information for as long as necessary to fulfill the purposes for which it was obtained and to provide our Services. We may retain your personal information even after you have closed your account with us or we have ceased providing services to you, if retention of your information is reasonably necessary for our legal or legitimate business reasons, such as to comply with our legal obligations, resolve disputes, prevent fraud or abuse, or enforce the Privacy Policies or our agreements.

Where required by applicable laws and regulations, we will retain your information for the statutory retention period; upon the expiry of such period, your personal information shall be deleted or anonymized in line with applicable laws and regulations.

C. Automated Decision-Making

To optimize our services, enhance security, and provide personalized experiences, we may use automated systems to process your personal information and make decisions in certain aspects of our services (hereinafter referred to as “Automated Decision-Making”).

We use automated decision-making for the following purposes: (a) fraud detection and prevention; (b) content moderation and enforcement of our Terms of Service; (c) personalization of in-game content and recommendations; and (d) optimization of server performance and matchmaking. We do not use automated decision-making for profiling that produces legal or similarly significant effects on you, such as decisions affecting your creditworthiness, employment, or access to essential services.

If any automated decision-making has a significant legal or similar effect on your rights or obligations, you have the right to object to such a decision, request human intervention, and request review of the decision. You may exercise this right by contacting us as specified in Section How to Contact Us.

With Whom We May Share Your Information

We generally do not disclose or transfer personally identifiable information to third parties. However, we may share aggregated or anonymized data that does not identify you with our business partners, analytics providers, ad networks, and advertisers (“Partners”). Some Partners may also act as service providers and, in that capacity, may access your personal information solely to perform services on our behalf, and they are contractually prohibited from using it for any other purpose. Partners may also obtain publicly available information from your profile or other public sources.

We may engage in co-marketing activities with complementary solution providers, but we will only send communications on their behalf and will not share your personal information with them. In certain business partnerships, if you sign up for partner services or respond to an offer, we may share your name and contact information as necessary for the partner to provide services or contact you.

We may also disclose your personal information to service providers, vendors, or other third parties that help us deliver our Services (e.g., payment processing, data analysis, email delivery, hosting, customer support, and promotions). These third-party service providers are authorized to access your personal information only to perform tasks on our behalf and are obligated not to disclose or use it for other purposes.

Currently, the name of Third Party Partner, services performed by it on our behalf, service territory of it, and period of retention and use by it of Personal Information are as follows:

In the event Company combines with another company in the future through a corporate merger, sale, acquisition, liquidation, or other similar process, your personally identifiable information may be transferred with the business or a part of it, or may be sold as an asset of the business, to the successor organization in such transaction. If material changes to the Company’s privacy practices will occur as a result of such transaction, we will notify you and other users in the manner described in this Privacy Policy.

Your personally identifiable information, and communications you make within the Service, may be accessed and disclosed if we believe that our Service is being used in the commission of a crime, when we believe in good faith that there is an emergency that poses a threat to the safety of you or another person and when necessary either to protect our rights or property including to enforce our Terms of Service, or for us to render the service you have requested.

We may also disclose personally identifiable information when required by law, regulation, court order, or in response to a subpoena or litigation discovery request, or in the good faith belief that such action is necessary in order to conform to the edicts of the law or comply with a legal process served on us. In addition, we will make any legally required disclosures to government authorities and provide notice to you of any breach of security, confidentiality, or unauthorized release of personal or private data in accordance with applicable laws, rules, and regulations.

Cookie Declaration

Cookies are small text files installed on your electronic devices when you visit our Services. We use cookies and similar technologies (including web beacons, pixel tags, and flash cookies) to collect information for various purposes, such as ensuring proper functionality, monitoring performance, analyzing user behavior, and displaying advertisements.

Cookies are files installed on users' electronic devices to collect information about the site for various purposes, such as ensuring the proper functionality of the site, monitoring performance, or displaying advertisements.

The Services of Company use non-essential cookies with non-essential functionalities, so they may be disabled by the user without prejudice to the operation of the site.

Cookies retain user data for the periods mentioned above, and may be transferred other country.

Cookies are small text files installed on your electronic devices when you visit our Services. We use cookies and similar technologies (including web beacons, pixel tags, and flash cookies) to collect information for various purposes, such as ensuring proper functionality, monitoring performance, analyzing user behavior, and displaying advertisements.

The user has the option and may change permissions, block or refuse cookies at any time using the tools provided by the browser, however, it is possible that the usability of the site may be impaired. For more information, please refer to the links below:

• Internet Explorer: https://windows.microsoft.com/de-de/internet-explorer/delete-manage-cookies
• Firefox: https://support.mozilla.org/en-US/kb/introducing-total-cookie-protection-standard-mode?utm_source=www.firefox.com&utm_medium=referral
• Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471%5Breference:2%5D
• Chrome: chrome://settings/cookies?search=cookie
• Microsoft Edge: https://support.microsoft.com/zh-cn/edge/manage-cookies-in-microsoft-edge-view-allow-block-delete-and-use
• Opera: https://help.opera.com/en/faq/

How We Keep Your Information Secure

The security of your personal information is important to us. We maintain appropriate technical and physical safeguards to protect your personal information against unauthorized access, loss and misuse. We take commercially reasonable security measures to protect your personal information, including encryption of sensitive information, firewalls and IDS (intrusion detection system).If you have any concerns or complaints regarding our processing of your personal information, please contact us via email at [email protected].

Although we take appropriate measures to safeguard against unauthorized disclosure or access of your information, no security measure is perfect. Thus, we cannot guarantee the security of your information. You hereby agree to use our Services at your own risk. We do not assume any responsibility for the unauthorized use or access of your information beyond our reasonable control.

Protection of Children's Privacy

By children, we mean users under the age of 18 years old; or in the case of a region where the minimum age for processing personal information differs, such different age. We will confirm your age by implementing appropriate age verification measures, in order to comply with applicable legal requirements. You should refer to the laws in your jurisdiction to ensure you are above the relevant legal minimum age.

We do not knowingly collect personal information from children under these ages for any purpose. If you become aware that your child has provided us with personal information at our Service, we invite you to notify us so that we may delete the information from our records and discontinue any related features or services. We also urge parents to instruct their children never to give out their real names, addresses or phone numbers without parental permission when using the Internet. We appreciate your cooperation in assisting us to provide a safe and enjoyable online experience for your children.

Your Privacy Rights

Consumer privacy laws may provide their residents with additional rights regarding their personal information. You may have the following rights depending on where you live.

The right to access your personal information. Upon receipt of your access request, we will allow you to review the personal information that we collected about you, including the categories of information and sources from which we collected it, the business purpose of using or sharing your information, and with whom we may share it.

The right to delete certain personal information. You may request that we delete your personal information, subject to certain exceptions under the applicable laws. For example, we may deny your deletion request if retaining the information is necessary for us or our service providers to provide Services that you requested, protect against fraudulent or illegal activities, comply with a legal obligation or make other internal and lawful uses permitted under the law. We will delete personal information not subject to one of such exceptions from our records and will direct our service providers to take similar action.

The right to correct inaccuracies. You may request to correct any inaccurate or incomplete information that we have about you.

The right to object. You may have the right to object to our processing of your personal data for direct marketing purposes or research or statistical purposes, or processing based on certain legal grounds such as processing necessary for our or a third party’s legitimate interest or performing a task in the public interest.

The right to opt-out of automated individual decision-making, including profiling. Certain state residents have the right to opt-out of automated decision-making or profiling in furtherance of decision that produce legal or similarly significant effects. We currently do NOT engage in “profiling” with such purpose or effect.

The right to opt-out of targeted advertising. You may have the right to opt out of personal data processing for targeted advertising and sales under the laws of some states. As explained in the Privacy Policies, certain information about you may be collected by or shared with our advertising partners for the purposes of delivering advertisements that may be more relevant or interest to you. You may opt out of such sharing and disable targeted advertising at any time by contacting us as specified in section How to Contact Us.

The right to nondiscrimination. We will not discriminate against you for exercising any of your privacy rights. Unless permitted by the law, we will not deny, or provide a different level or quality of goods or services for choosing to exercise such rights; however, provided that we may select the most suitable users to participate in a specific event, contest or activity based on your information.

The right to withdraw consent. To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent, we may not be able to deliver the expected service. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.

The right to suspend processing of personal data. You may request that we suspend the processing of your personal data. Upon receiving your request, we will temporarily halt certain or all processing activities related to your personal data, except in cases where processing is required by law, necessary to protect the rights of others, or necessary to fulfill contractual obligations when you have not clearly requested contract termination.

The right to Complain. You may have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority where applicable.

Announcements. We may, from time to time, send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to Our Services for maintenance, security, privacy or administrative-related communications). There are essential system and service-related announcements and you may not opt out of these notifications, which are not promotional in nature.

How to exercise your rights. You may also contact us with your personal information inquiries or for assistance in modifying or updating your personal information and exercising your rights. Our contact details are provided in the Section How to Contact Us.

Your request to access or delete your personal information must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information. You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to personal information associated with that specific account. For non-accountholders, we may verify by asking and confirming unique details we have about you or your device.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Authorized Agents. Only you, or someone legally authorized to act on your behalf, may exercise your rights. If your agent submits a request to know or a request to delete, we may ask you to confirm directly with us your identity and your designated agent’s authority to submit the request for you, unless you have provided your agent with a valid power of attorney duly executed under the law of your residence.

Privacy Notice for California Residents

The Privacy Notice for California Residents supplements the information contained in our Privacy Policies and applies solely to all visitors and users who reside in the State of California.

A. Notice at Collection.

We collect your personal information and sensitive personal information to support our business operations, including the business purposes described in Section How We Use Your Information.
Depending on how consumers use our Services, we may collect the following categories of personal information from consumers in California.

Identifiers, such as email address, IP address, social media account or channel ID, store account number or username, Game ID, and device identifier.

Customer records, such as name, addresses, customer’s correspondences with us.

Account details, including JoyMaker account information with password and other login details.

Commercial information, including Games and products purchased, acquired or considered and other order, payment and transaction records.

Internet or network activities, such as details of a user’s access and use of our Services, including, Games accessed, Game progress and scores, pages visited and a user’s interaction with online content.

Geolocation data, such as approximate location derived from IP address or country code.

Technical data about a user‘s mobile device, software, and system, including: device identifiers (such as IDFV and IDFA), IP address, device type, device model, device brand and manufacturer, operating system version, system language and regional settings, screen size and resolution, network type and status, network operator information, SIM card carrier information, device configuration and environment information, as well as app-related information (including app name and version).

User profile information (if any) that a user may provide.

Content and information that users post, publish or display on our Websites or Applications.

Content of users’ text messages and chats with others through our Services.

Inferences drawn from other personal information.

If you are California resident, we do not sell your personal information or share it with third parties for purpose of targeted advertising.

In general, we retain your personal information for as long as necessary to fulfill the purposes for which it was obtained and to provide our Services. We may retain your personal information even after you have closed your account with us or we have ceased providing Services to you, if retention of your information is reasonably necessary for our legal or legitimate business reasons.

B. Additional Information for California Residents.

Personal Information Categories. In the preceding 12 months, we have collected the same categories of personal information as described in the preceding Sectio10 A from California consumers when they used our Services (as defined in the Privacy Policies).
We obtained the categories of personal information listed above from the sources listed in Section What Information We Collect.
We may use or disclose the personal information we collect for one or more of the business purposes described in Section How We Use Your Information.
Sharing of Personal Information. In the preceding 12 months, we have disclosed the following categories of personal information to the third party categories indicated in the chart below for one of the business purposes listed in Section How We Use Your Information. except for targeted advertising.

See the preceding Section With Whom We May Share Your Information for full description of corresponding information categories.

We have not sold or shared the personal information of California consumers for the purpose of targeted advertising in the preceding 12 months, and we do not have actual knowledge of any sale of personal information of California consumers under 16 years of age.

Sensitive Personal Information. Sensitive personal information is a subtype of personal information consisting of specific information categories. While we collect certain information that falls within the information categories, we use it only for the limited purposes that do not require us to offer you the option to limit our use of such information.
Your rights and choices. The California Consumer Privacy Act (“CCPA”) provides California residents with specific rights regarding their personal information. Such rights include among others (1) the right to access your personal information, (2) the right to delete certain personal information, (3) the right to correct inaccurate personal information, and (4) the right not to receive discriminatory treatment for exercising your privacy rights conferred by the CCPA. Please see Section Your Privacy Rights. to understand how to exercise the above rights.

C. Privacy Rights for California Minors.

California residents under the age of 18 have the right to request removal of any content or information that he or she posted anywhere within our Services, such as public forum or message boards. You can make the request by contacting our customer services. Please be aware that the removal of your information or content may not be complete or comprehensive, and residual copies of such removed information or content may remain on our servers. In addition, we are not obligated to remove any posted content or information that has been copied or reposted by a third party, that has been rendered anonymous, or that we are required to keep by law.

D. Other California Rights. California’s ‘Shine the Light’ law (Civil Code §1798.83) permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us via email at [email protected].
If you have any questions about the notice, please contact us by contacting our customer services or contact information provided in Section How to Contact Us.

Where We Hold Your Information

A.Data Storage

We will keep your data only for as long as your account is active or only for as needed to provide you with Our Services unless deleted in accordance with your request or where we are required to do so under applicable law.

The locations of servers for Our Services include one or a combination of the following locations:

• Singapore

You acknowledge and agree that your data will be collected and processed on our servers which may not be located in your country/region of residence and can be accessed by our support, engineering and/or our Affiliates around the world. No matter where our servers are located, we will make great efforts to take the appropriate safeguards to guarantee your rights in conformity with this Privacy Policy and any applicable laws and regulations.

Where required by law, we will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or where the applicable laws and regulations provide for longer storage and retention period. Upon the expiration of such period, your personal information will be deleted, or anonymized, in accordance with applicable laws and regulations.

From time to time, we may update the Privacy Policies to clarify our practices or to reflect new or different privacy practices, such as when we add new features. We reserve the right to modify and/or make changes to the Privacy Policies at any time.

B. International Data Transfers

The data protection laws and rules of such jurisdictions may differ from those of your country/region of residence. When we transfer your personal information to jurisdictions outside of your country/region of residence, we will implement appropriate safeguards as required by applicable law. The specific mechanisms we rely on include:

(a) For transfers to Singapore: We ensure that the recipient is bound by the Singapore Personal Data Protection Act 2012 (as amended) or comparable standards;

(b) For transfers to other jurisdictions: We enter into Standard Contractual Clauses ("SCCs") approved by the relevant data protection authority, or rely on Binding Corporate Rules ("BCRs") where applicable, or obtain your explicit consent where required by law;

(c) Third-party service providers: Prior to engaging any third-party service provider listed in Section With Whom We May Share Your Information, we conduct a data protection impact assessment to ensure that the recipient jurisdiction provides a standard of protection that is comparable to that under the PDPA of your jurisdiction. A summary of our transfer impact assessments is available upon request.

Where required by applicable law, we will obtain your explicit consent or authorization for such cross-border transfer before the transfer occurs. You may refuse to consent, but refusal may limit or prevent the use of certain Services.

We may also store your personal information in secure databases, equipment, and servers operated by us or our authorized third-party service providers in Hong Kong, South Korea, Singapore, or other jurisdictions, subject to the safeguards described above.

Where required by applicable law, we will obtain your explicit consent or authorization for such cross-border transfer. We may also store your personal information in secure databases, equipment, and servers operated by us or our authorized third-party service providers in Hong Kong, South Korea, Singapore, or other jurisdictions.

Changes to Our Privacy Policies

From time to time, we may update the Privacy Policies to clarify our practices or to reflect new or different privacy practices, such as when we add new features. We reserve the right to modify and/or make changes to the Privacy Policies at any time.

If we make any material changes, we will notify you by appropriate means ,such as pop-up windows, website announcements, or other methods required by applicable law.You will have 10 calendar days from the date of notification to review the updated Policies. If you do not raise any objections within this period, your continued access to or use of our Services will be deemed acceptance of the updated Privacy Policies.

How to Contact Us

If you have a question about the Privacy Policies or any of our privacy practices, you can contact us by one of the following methods.

Personal Information Protection Officer

Name：ZHAO GAO

E-mail:[email protected]

Telephone:+86 21 55698900

General Inquiries

E-mail:[email protected]

For Singapore users, this DPO is designated in compliance with the Singapore Personal Data Protection Act 2012 (as amended). You may contact our DPO for any data protection inquiries or complaints. We will respond to your inquiry within 30 days from the date of receipt.

Supplemental Terms-Jurisdiction-Specific

South Korea

If you are in South Korea, the following additional information applies to you in addition to the Privacy Policy set out above.

How we use your personal data. In addition to the main text of this policy, we intend to use your personal data (email address) to send you promotional messages concerning new products, features, enhancements, special offers, upgrade opportunities, contests and events of interest in relation to the Services. We require your express consent before we do so.

• Data retention. We destroy personal data whose purpose of collection as consented to by you have been achieved, or whose periods of and use to which you consented to or which were provided in this privacy policy have expired; provided, however, we will continue to store your personal data for the following statutorily-prescribed periods, where applicable including, but not limited to:

• Destruction of your personal information. If we determine that your personal information is no longer needed, we will destroy it under the supervision of our chief privacy officer and in accordance with applicable law and the Privacy Policy. Personal information in the form of electronic files will be securely deleted using technical methods to prevent recovery and reproduction, and printouts will be destroyed by shredding or incineration.
• Data security. We work hard to protect our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. To this end, we have in place technical, managerial and physical safeguards, including internal policy for data protection, limiting the access to personal data or a need-to-know basis and controlling access to the facilities where personal data is processed.
• Information relating to children. The Services are not directed at children under the age of 14 and we do not knowingly collect or solicit personal data from children under 14. If you believe that we have personal data about or collected from a child under the relevant age, please contact us and we will ensure that it is deleted. For children under the age of 14, their legal guardians have the right to exercise the rights of their children with respect to data protection.
• Cross-Border Transfer of Personal Information

With your explicit consent, we may transfer your personal information to overseas partners or service providers in order to provide relevant services. You may refuse to consent, but refusal may limit or prevent the use of certain services. Details of the transfer are as follows:

We ensure that the recipients will use and store your personal information in compliance with domestic and international regulations and will take all available physical and technical measures to protect your information.

To refuse the cross-border transfer of your personal information, please contact us using the information provided in Section How to Contact Us of this Privacy Policy.

• Right to request transmission of personal data to specified processors. Subject to the statutory conditions, you are entitled to request us to transmit your specific personal information in a structured, machine-readable format to the specialized personal information management agencies specified by law or other third parties complying with the security standards.

Singapore

By continuing, you consent to the cross-border transfer of your information to any country where we have databases or Affiliates and, in particular, the locations specified in Section Where We Hold Your Information.

You have the right to access your personal information, how we use it, and who we disclose it to. You have the right to correct any of your personal information that is inaccurate.

• Right to request transmission of personal data to specified processors. Subject to the statutory conditions, you are entitled to request us to transmit your specific personal information in a structured, machine-readable format to the specialized personal information management agencies specified by law or other third parties complying with the security standards.

Thailand

By clicking “accept”, you acknowledge that you have read, understood, and agree to the Privacy Policy. If you do not agree with the Privacy Policy, you must not use Our Services.

If you are under the age of 20, you undertake that you have obtained your parent or legal guardian’s consent to register an account on and use Our Services.We do not knowingly collect personal information from users under the age of 20 without such consent. If you believe that we have collected personal information from a user under 20 without parental consent, please contact us immediately and we will take steps to delete such information.

We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data. However, there are occasions where we are likely to keep this data for five (5) years (or longer if required) in accordance with our legal obligations or where it is necessary for the establishment, exercise, or defence of legal claims. After you have terminated your use of our Services and the five (5) year retention period has lapsed, we store your information in an aggregated and anonymized format. Non-personally identifiable information may be retained indefinitely for analytics.

• Right to request transmission of personal data to specified processors. Subject to the statutory conditions, you are entitled to request us to transmit your specific personal information in a structured, machine-readable format to the specialized personal information management agencies specified by law or other third parties complying with the security standards.

Indonesia

If you are using the Services in Indonesia, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall apply.

By accepting and consenting to this Privacy Policy, you agree that we may collect, use and share your personal information in accordance with this Privacy Policy, as revised from time to time. If you do not agree to this Privacy Policy, you must not access or use Our Services and we have the right to not provide you with access To Our Services.

• Age. If you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use Our Services.
• Notification. In the event we fail to maintain the confidentiality of your personal information in Our Services, we will notify you through the contact information provided by you or via our Services, to the extent required by local laws and regulations.
• Data Retention. We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information in order to provide the service to you. We retain it only for so long as we have a legitimate business purpose in keeping such data. However, there are occasions where we are likely to keep this data for five (5) years (or longer if required) in accordance with our legal obligations or where it is necessary for the establishment, exercise or defence of legal claims. After you have terminated your use of our Services and the five (5) years retention period has lapsed, we store your information in an aggregated and anonymised format. Non-personally identifiable information may be retained indefinitely for analytics.
• Your responsibility. You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time.

You hereby represent that you have secured all necessary consents before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consents.

Malaysia

• Right to request transmission of personal data to specified processors. Subject to the statutory conditions, you are entitled to request us to transmit your specific personal information in a structured, machine-readable format to the specialized personal information management agencies specified by law or other third parties complying with the security standards.
• Right to Claim Compensation. Subject to the statutory conditions, you are entitled to have the right to seek compensation for damages arising from unlawful processing of your personal data, and to lodge complaints with the relevant supervisory authority in accordance with applicable law.

To the fullest extent permitted by applicable law, Company shall not be liable for any incidental, indirect, special, or consequential damages or claims arising out of or in any way related to the use of Company’s products and services, including but not limited to damages resulting from personal injury, privacy breaches, failure to perform any duty (including duties of good faith and reasonable care), negligence, or any other pecuniary or other losses. Company’s aggregate liability for any claim shall not exceed the amount actually paid by the user for the services in respect of which the claim arises.

Vietnam

By clicking “accept”, you acknowledge that you have explicitly read, understood, and agree to the Privacy Policy. If you do not agree with the Privacy Policy, you must not use Our Services.

Right to Self-Protection. Subject to the statutory conditions, you are entitled to have the right to take any measures permitted by law to protect your personal data and privacy rights, including seeking assistance from competent authorities and bringing legal actions in accordance with applicable law.

We will respond to and process requests regarding restriction of processing, objection, access, and erasure within 72 hours.