Overview

Hello! Welcome to the Privacy Policy of Shanghai Shengbing Technology Co., Ltd. (hereinafter referred to as "Shanghai Shengbing"，"we","our"). This policy outlines how Shanghai Shengbing collects, uses, processes, and shares your information.

This Privacy Policy applies to your download, access, and use of Shanghai Shengbing games (hereinafter referred to as "Games"), whether on your computer, mobile device, our website (hereinafter referred to as the "Website"), or any other website, device, or platform. It also covers our marketing and advertising campaigns on all platforms, as well as other services we provide to you, including activities with public figures. Additionally, this Privacy Policy extends to any other services we may offer related to our games or websites, such as customer support, social media and community channels, and other websites we may operate from time to time. In this Privacy Policy, we collectively refer to all our games and other services as our "Services."

By downloading, visiting, and/or playing our games, or interacting with our websites or other services, you consent to our collection and use of your information in accordance with this Privacy Policy. This includes consent for Shanghai Shengbing and our advertising partners to use your data for targeted advertising, as detailed in the Marketing and Advertising section of this Privacy Policy. These sections also explain how you can opt out of using your personal information for targeted advertising purposes. If you have any concerns about providing information to us or using that information in accordance with this Privacy Policy, you should not use our games or other services.

Sources of Information We Collect

The way we collect information depends on how you use our services. For example, we:

· Collect information you provide directly to us, such as when you create an account, sign up for marketing, or contact us.

· Automatically collect information related to the games you play.

· Collect information from third-party platforms, such as when you use a third-party account to play our games or access our services.

· Automatically collect information, including through cookies and similar tracking technologies.

· Collect information from third parties, such as ad networks, business partners, third-party information providers, and other players.

1.Information You Provide

You provide us with information when you use our services, such as when you:

· Create an account or use the services.

· Subscribe to marketing and communications.

· Post comments on our message boards, forums, chat rooms, feeds, websites, or other services.

· Purchase or redeem one of our products or services (including physical items, virtual items, virtual currency, or add-ons).

· Download, install, or access demo games, programs, or other software.

· Contact us for support or other purposes.

· Use our email or sharing features.

· Participate in events, contests, promotions, surveys, or game testing.

· Engage in activities where you provide your information.

We may collect your name, email address, phone number, photo, mailing address/zip code, payment or purchase information, age, gender, password, platform ID, software products played, survey data, geographic location, and the gaming systems or platforms you use, depending on the service or your activities. We combine this information across the devices you use.

2.Game Information

When you use the services, we automatically receive information related to your games. Game information includes your platform ID or game service ID, game achievements, game scores and performance, IP address, MAC address or other device ID, other platform/device information, and other information and statistics related to your use of the services. We collect game information even if you do not register for the services. We may combine game information with other information we have about you. We may also use internal and third-party anti-cheat technology to detect and prevent cheating in our services.

3.Platform, Game, and Social Network Information

When you access our services using a third-party platform account (such as a gaming platform account, game network service account, or social network service account), we collect information. If you access our services in this way, the third-party platform will provide us with information about you. For example, depending on your use of the third-party platform or activities on such platforms, we may receive your username, friend list, or account information necessary to provide services or purchase in-game items. Third-party platforms may allow you to control the information provided to us. We are not responsible for the terms, policies, disclosures, or actions of any third-party platform.

4.Cookies and Similar Technologies

We may use cookies, web beacons, pixel tags, Flash cookies, internet log files, software development kits, and similar tracking technologies to improve and maintain the functionality of our services; enhance security and fraud prevention; and provide you with targeted advertising. Our systems may not respond to “Do Not Track” requests or headers from some or all browsers. More information about our use of cookies and similar technologies, as well as options for managing cookies, can be found in the section Managing Your Account, Communications, and Data. You can also use cookie preference tools (if available) or visit our Cookie Policy posted within the services to learn more.

5.Information Received from Third Parties

We receive information from third parties to update the information we collect about you. We may receive information from public databases, platform manufacturers, analytics providers, game developers, and other business partners, as well as from other Take-Two companies involved in providing you with services. This includes demographic information and information related to your interests. We may collect publicly available information (including from social media) to protect our users, employees, facilities, and services, and to assist in investigations. We also receive information from other individuals using our services. This may include information about you if you are mentioned in comments on the services or if individuals send us direct messages.

How We Use Your Personal Information

We use your information for the following purposes:

Providing You with Games: We use your information to fulfill our contractual obligations, enabling you to create an account, play games (including as a guest), track your progress, and play with friends, including communicating via in-game chat, audio, or video calls (if applicable). Additionally, we use your information to facilitate purchases through Google Play, the iOS App Store, or Xsolla, Inc., and to maintain records of such transactions. The information we process includes your registration details, identifiers, in-game activity, and related game usage data.

Improving and Monitoring Game Usage: It is in our legitimate interest to enhance our games for our customers. To achieve this, we may automatically collect or generate information about your gameplay and device, such as battery status, Wi-Fi strength, device manufacturer, model, operating system, and available storage.

Providing Support and Responding to Requests or Complaints: If you seek support from us, we use your information to create a support account, respond to and resolve your queries and complaints, and facilitate support (e.g., retrieving forgotten passwords). By doing so, we fulfill our contractual obligations to you. The information we process includes your registration details, identifiers, device information (e.g., Wi-Fi strength and available storage), and any other information collected through our customer support channels.

Conducting Analytics: It is in our legitimate interest to analyze the usage of our games, newsletters, and advertising campaigns, as well as any other interactions or interests. We process information that is automatically collected or generated during gameplay or interaction with our newsletters and ad campaigns to (a) create anonymous and aggregated data, (b) segment users by specific characteristics or interests, and (c) conduct predictive analysis on your interests.

Sending Updates About In-Game Offers: Based on your gameplay, geographical location, device data, and in-game interactions, we tailor promotional offers and information about purchasable virtual items in the game. This is based on our legitimate interests.

Providing You with Advertising: We deliver advertisements and suggestions to you within our games and elsewhere. These may relate to our own games or other services you might be interested in. These advertisements and suggestions can be tailored specifically to you. Where required, we will do this only with your consent. In cases where consent is not needed or where we provide contextual advertising, we do so based on our legitimate interests. If you no longer wish to receive targeted ads, you can withdraw your consent in the game settings to opt out and adjust your browser and device settings. To customize ads and allow our advertising partners to do the same, we process information that is automatically collected or generated during gameplay and information received from third parties.

Conducting Surveys: We may periodically invite you to participate in surveys, which align with our legitimate interests as they help us understand our user base and improve our games. If you choose to participate, we will process your registration information and any other information collected through survey questions.

Information Sharing

We respect and protect your personal information. In certain circumstances, to provide better services and comply with legal requirements, we may share your personal information as follows:

· Sharing with Third Parties: We may share your personal information with authenticated partners or service providers to support our game services and technical support. These partners and service providers may process your information on our behalf but only to fulfill specific tasks necessary for our services.

· Legal Requirements or Protecting Our Rights: We may share your information as required by applicable laws or to protect our legitimate interests (such as safety, property, or other rights). This may include cooperation with law enforcement agencies or other third parties to comply with legal and regulatory obligations.

· Sharing with Your Consent: We may share your information after obtaining your explicit consent.

We are committed to taking reasonable measures to protect the security of your personal information and only share it when necessary. We will never sell or rent your personal information to third parties.

Disclosure of Your Information

We do not sell or market your personal information. However, in the course of providing our services, we may disclose aggregated information about users for the following purposes:

1.To Contractors, Service Providers, and Third Parties: We share information with contractors, service providers, and other third parties that support our business. These entities are contractually obligated to keep personal information confidential and to use it only for the purposes we disclose to them.

2.In Business Transfers: If Shanghai Shengbing undergoes a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of its assets, personal information held by the company about our users may be among the assets transferred. This could occur whether as part of a going concern or as part of bankruptcy, liquidation, or similar proceedings.

3.To Fulfill the Purpose of Your Information Submission: For example, if you provide us with your social media account information to use our services' social sharing features, we will transmit the content of that request to the intended recipient.

4.For Any Other Purpose Disclosed at the Time of Information Provision: We will disclose your information for any other purpose that we disclose to you when you provide the information.

5.With Your Consent: We may disclose your information with your consent.

6.To Comply with Legal Obligations: This includes complying with any court order, law, or legal process, including responding to any government or regulatory request.

7.To Protect Rights and Safety: If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Shanghai Shengbing, our customers, or others, we may disclose your information. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

By adhering to these guidelines, we ensure that your personal information is handled responsibly and with respect for your privacy.

Ensure Your Information Security

We have established security mechanisms within our services to protect your information.

All Shanghai Shengbing products feature robust security functionalities designed to continuously safeguard your information. Insights gained from maintaining our services help us detect and automatically thwart security threats. Should we identify risks that we believe you should be aware of, we will notify you and provide guidance on actions to better protect yourself.

We strive to protect you and Shanghai Shengbing from unauthorized access, alteration, disclosure, or destruction of the information we hold, including:

· We use encryption to protect the confidentiality of your data during transmission.

· We provide a range of security features such as secure browsing, security checks, and two-step verification to help safeguard your account.

· We review our information collection, storage, and processing practices, including physical security measures, to prevent unauthorized access to our systems.

· Access to personal information is restricted to Shanghai Shengbing employees, contractors, and agents who need this information to process it. Anyone with such access must adhere to strict confidentiality obligations under contract, and failure to meet these obligations may result in disciplinary action or termination.

Cross-border Data Transfer

We are dedicated to safeguarding your personal information and adhering to pertinent privacy laws and regulations. During the provision of our services to you, it may be necessary to store and process your personal information in countries outside of your own. Such transfers may occur for the following purposes:

· To deliver, maintain, and enhance our services;

· To fulfill contractual obligations with you;

· To comply with legal and regulatory mandates;

· To safeguard our legitimate rights and interests.

We take reasonable measures to ensure that all entities receiving this information maintain an equivalent level of privacy protection as mandated by our standards.

Children

Under our Terms of Use, you must meet a certain age requirement to play our games and use our Services. We do not knowingly collect or request personal information from residents under the age of 13, nor do we directly serve interest-based advertising to them or knowingly allow them to use our Games and Services.

Our games are designed for adults, and we do not knowingly collect, nor do we wish to collect, information about children. If you are under the appropriate age, please do not play our games or use our other services. If you believe that we may have information from or about a child under the age specified, please contact us immediately.

Your Rights

You have certain rights regarding your personal information and how we handle it. You can contact us at any time using the methods described in the Contact Us section below to exercise these rights. These rights include:

Right of Access: You have the right to know what personal information we hold about you and, in some cases, to request that we provide you with a copy of this information. If you wish to exercise this right, please contact us. Before providing any information, we reserve the right to request reasonable proof to verify your identity. Please note that we may not be able to provide all the information you request. For example, if the requested information includes personal information of other individuals, we cannot provide it. If we cannot provide the requested information, we will make reasonable efforts to explain why.

Right to Correct Personal Information: We strive to ensure that the information we hold about you is accurate and up-to-date. If you find any inaccuracies in the information we hold about you, please contact us here, and we will correct it as soon as possible.

Right to Deletion: You have the right to request the deletion of certain personal information we hold about you. If you wish to delete any information about you, please note that you must delete our games from your mobile device to process your request. If we delete your personal information, we may still retain some or all of it for other purposes (such as maintaining financial records, protecting or exercising legal rights, maintaining marketing opt-out lists, or technical reasons). Additionally, we will retain your information in an anonymous form. In some cases, personal information visible through the game (such as usernames, avatars, high scores, and chat messages) may be cached on other players' devices, and we cannot delete or update this information from those devices (for example, if the device is not connected to a Wi-Fi network).

Account Deactivation: If you have created an account with us, you can contact us using the information below to request that we deactivate your account. Before deactivating your account, we may ask you to provide additional information, which may include information about your mobile device. If you wish to deactivate your account completely, please note that all your progress in our games and any unused virtual items (such as gold bars or magic items) will be lost, and we will not be able to restore them.

Right to Restrict Processing: In certain circumstances, you have the right to request that we restrict the processing of your personal information, such as when you contest the accuracy of the data we hold about you.

Right to Object: You have the right to object to the processing of your personal information based on legitimate interests.

Updating Our Privacy Policy

We may periodically update our privacy policy. If we make significant changes to how we process users' personal information, we will post a new privacy policy on this page and notify you through email and within the application. These notifications will take effect immediately after your first use of the service following the changes.

The last revised date of the privacy policy will be indicated at the top of the page. It is your responsibility to ensure we have your current and valid email address and to regularly review this privacy policy for any updates.

Contact us

If you have any questions or concerns about anything in connection with this Privacy Policy, including the exercise of any of your rights, please contact us at [email protected] and we will get back to you as soon as possible.