Novement Games ("we" or "our") highly values the privacy rights of users ("user" or "you"). This Privacy Policy ("this Policy") describes how we collect, store, use, and manage information, including personal information, through any Novement Games games (including games developed by Novement Games, collectively referred to as "Services"). Please note that the scope of this Policy is limited to the information collected or received by Novement Games through your use of the Services. Novement Games shall not be liable for the actions of third parties, the content of their sites, the use of information you provide to them, or any products or services they may offer.
By using the Services, you agree to this Policy and the manner in which your data, including your personal information, is processed in accordance with this Policy. If you do not agree to these terms, please do not use this service.
In accordance with applicable law, children under the age of 13 (or other ages required by local law) are not permitted to access this service. If you are 13 years old but are considered a minor in certain jurisdictions (for example, under the age of 18 in some jurisdictions), you must have your parents or legal guardians read this Privacy Policy with you, and you declare that you have obtained their permission to create your account.
If you are the parent or legal guardian of a minor in your country/region, please read this Privacy Policy before allowing your child to create an account or use the service. You agree to be bound by this Privacy Policy and to be responsible for your child's activities while using the service. You agree to monitor your child's use of the service and ensure that they only access content suitable for their age.
I. What Information Do We Collect?
When you use this service, we automatically collect certain information. More information on the categories and sources of information is provided below. In this Policy, "information" means any information related to an identified or identifiable individual.
For example:
Registration information: Such as your nickname, email address, password, phone number, and information we import from your connected social media accounts (WeChat, Facebook, QQ, VKontakte, Twitter, Google Play, Game Center, or LINE) to set up your profile, including the name in your social media profile, your user ID, and profile picture. In some regions, you may also be asked to provide your date of birth (stored only on the device) to verify your age and manage the game management system.
Identifiers and device information: Such as your device type, operating system type, browser type, device ID, Internet Protocol (IP) address, and other software, including type, version, language, settings, and configuration.
Usage data: Such as the website that brought you to our site, when you use the service and for how long, which pages and content you visit, and which features you use on the service.
Geolocation data: With your consent, the service can access the precise geolocation data on your mobile device to provide functionality and deliver content based on your current location.
Customer support: If you contact us directly, we may receive additional information about you. For example, when you contact us for support, we may receive your name, email address, phone number, the content of the message you send us, and any other information you choose to provide.
We may use SDKs and other similar technologies to collect the above information. For more information on the list of SDKs we use, please refer to the section below on "How We Share Your Information".
To comply with relevant laws, regulations, and policies such as the "Notice on Preventing Minors from Becoming Addicted to Online Games" and the "Notice on Further Strengthening the Management to Effectively Prevent Minors from Becoming Addicted to Online Games," as well as the real-name system requirements of the relevant authorities, you are required to provide us with your name, phone number, and identification when registering an account or using Novement Games services. This type of information is considered sensitive information. Refusal to provide real-name authentication information may result in your inability to log in or restrictions during gameplay. To enhance minor protection measures, in certain cases, we may also require you to provide facial recognition information for real-person verification. Refusal to provide real-person authentication information may result in corresponding anti-addiction restrictions during gameplay.
In accordance with relevant laws, regulations, and national standards, we may legally collect and use your personal information without obtaining your consent under the following circumstances:
- Related to national security and defense security;
- Related to public safety, public health, and significant public interests;
- Related to criminal investigation, prosecution, trial, and execution of judgments;
- Necessary to protect the significant legitimate rights and interests of you or other individuals, but it is difficult to obtain your consent;
- Information that you have publicly disclosed to the general public;
- Personal information collected from legally disclosed information, such as legitimate news reports, government information disclosure, and other channels;
- Related to our fulfillment of obligations stipulated by laws and regulations;
- Other circumstances stipulated by laws and regulations.
- Necessary to maintain the safe and stable operation of the products or services provided, such as discovering and dealing with faults in products or services.
II. How Do We Use Your Information?
Within a reasonable and necessary scope, we use your information to perform our contract with you, based on your consent or legal requirements, and for our legitimate business objectives, including:
Business operations: To provide you with our products and services, and to maintain, optimize, and improve our products, services, operations, and service security, including performing operational tasks such as billing, accounting, communication, and fulfilling transactions for products and services.
Product and service delivery: To tailor content and experiences based on your preferences and interests;
Marketing: To provide and personalize your notifications, communications, press releases, advertisements, event notifications, and activities for Novement Games and our third-party partners' products and services;
Product improvement, development, and research: To understand you through your activities on our services, responses to surveys, or activities on third-party websites and applications, including troubleshooting and improving our services; conducting market research and performing statistical, demographic, and marketing analyses of our service users and their purchasing patterns;
Service security: To detect, investigate, and prevent unauthorized activities, activities that may violate our terms and policies, or potentially illegal activities, such as fraud or security breaches;
Customer support: To answer questions you submit to us.
III. Cookies and Similar Technologies
To measure the effectiveness of our services, we may use cookies, which are small text files used to add functionality or track site usage. We may use cookies and/or authorize third-party tracking utilities from time to time to (a) record your IP address to determine the navigation path of users on our website and identify repeat users, (b) collect websites or sources that link or refer you to our services, and/or (c) collect technical data about the devices and software you use to access our services, your device's operating system, and other similar technical data. If you do not wish to accept cookies or would like to be notified when they are placed, you may do so in your browser settings (if allowed by your browser).
We use cookies, web beacons, and similar technologies to personalize your experience, as well as for various other purposes, including;
Remembering you: Cookies, web beacons, and similar technologies help us recognize you as a registered user and retain preferences or data you have previously provided;
Analyzing how you use our services: Cookies, web beacons, and similar technologies help us understand the activities of visitors (including users) on our services, or which pages or sections are the most popular;
Delivering advertisements: Cookies, web beacons, and similar technologies help us provide you with advertisements that we believe are relevant or of interest to you based on the data you provide;
Other relevant functions or purposes mentioned in Section II of this article.
We or our authorized contractors may use cookies and similar technologies to provide and personalize services, prevent fraud, and meet the above other purposes. Please note that you can disable cookies in your browser settings, but if you do so, some of our service functions may not work properly.
IV. How Do We Share Your Information?
In addition to Novement Games, other parties may also access your personal data under the following circumstances. You acknowledge that by providing personal data, you have anticipated such disclosure.
Business partners. We share information with third-party partners and service providers, including payment processors and gateway companies, platform services, game developers, game publishers, game console providers, customer support services, cloud storage and hosting providers, social media companies (who may collect information when you use the service or connect the service to your social media account), and analytics and advertising companies, to help us provide and improve our services and operate our business. For more information on these business partners, please contact us.
Other users. Your profile information, including your username and pictures that you may provide, as well as information about your activities on the service, may be visible to other service users or third-party websites and services. For example, your game results, scores, and profile information may be seen by other users of the service, and if you choose to link to social media sites like Facebook, users of those sites may also see it.
Legal purposes. When we believe it is necessary to do so, we may provide your information to third parties to comply with the law or cooperate with regulatory or law enforcement agencies. If we believe there is an emergency that poses a threat to your health or safety, or that of others or the public, we may disclose your information to protect the rights or property of Novement Games, including enforcing our Terms of Service and End User License Agreement, as well as the rights of others.
Corporate transactions. If Novement Games participates in a corporate transaction, such as a merger or acquisition by another company, we may transfer your information to the successor organization in that transaction in accordance with applicable law.
With your consent. For any other purposes disclosed to you at the time of information collection or with your consent, we may share information.
If you access our services through a third-party device or platform, these third parties may be able to collect and process information about you, including information about your activities on the service, and they may notify your contacts on the third-party service in accordance with their own privacy policies.
The following is a list of third-party user information sharing for Novement Games:
Unity 3D
Third-party company name: Unity Technologies (Shanghai) Co., Ltd.
Function type: Game development framework
Types of personal information involved: Reading device information (device model, system name, system version, MAC address, unique device identifier), network status information, reading stored data, obtaining Android ID, device sensor information
Third-party link: https://unity.cn/legal/china-privacy-policy
V. What Rights Do You Have Over the Processing of Your Information?
As a user of our service, you may have the following data protection rights and the right to withdraw your consent, in accordance with applicable laws and regulations. You also have the right to lodge a complaint with local authorities.
To exercise any of the applicable rights below or any other statutory data subject rights you may have under applicable laws and regulations, you may contact us using the contact information provided in Section VIII below.
To protect the security of your account and personal data, we may ask you to provide certain additional information before responding to your request. In some cases, where permitted by applicable laws and regulations, we may refuse to comply with your request. We may also charge a reasonable fee to meet your request in accordance with applicable law, for example, if your request is clearly repetitive or excessive.
Right to be informed about collected or disclosed personal data
You may have the right to access the personal data we hold about you, namely (i) whether your personal data has been collected or disclosed, (ii) the categories of personal data that have been collected or disclosed, (iii) the sources of the categories of personal data collected about you, (iv) the business or commercial purposes for collecting or disclosing your personal data (if any); you have the right to request a copy of the personal data we are processing about you, but you must submit a verifiable request to us using the contact information provided in Section VIII below. If applicable, you may also exercise the right to access some of your personal data through the privacy settings provided in the service (for example, the profile page or privacy dashboard).
Right to rectification
If we process your personal data, we will endeavor to take appropriate measures to ensure that your personal data is accurate and up-to-date for the purposes of collection. If your personal data is inaccurate or incomplete, you have the right to request rectification of your inaccurate personal data in accordance with applicable laws and regulations, and you may modify information in the privacy settings of the service (if available).
Right to erasure of personal data
You acknowledge and agree that upon deletion of your account, you will no longer be able to access game-related services, including account information, subscriptions, and game-related information associated with that account, and you will not be able to access other services through that account.
Right to opt out of marketing communications: You may exercise this right by clicking on the "unsubscribe" or "opt-out" links in the marketing messages we send to you.
Right to lodge a complaint: You may have the right to lodge a complaint with a data protection authority regarding our collection and use of your personal information. For more information, please contact your local data protection authority (if applicable).
Right to withdraw consent: If we collect and process your personal data with your consent, you may withdraw your consent in accordance with applicable law. Withdrawing your consent will not affect the legality of any processing we have carried out before your withdrawal, nor will it affect the processing of your personal data based on lawful processing grounds other than consent. In many cases, we need to use your personal data to provide you with the services you require. If you do not provide us with the required personal data, or if you withdraw your consent for us to use and/or disclose your personal data for these purposes, we may not be able to continue providing you with services or providing you with the services you need.
VI. How Do We Store and Transmit Your Information?
We guarantee that personal information collected and generated within the People's Republic of China will be stored within the People's Republic of China. Without your explicit authorization, explicit provisions of laws and regulations, and/or requirements of relevant authorities, we will not transfer your personal information out of the country. We will store your information securely, including local storage (using APPs for data caching), databases, and server logs. If cross-border transmission is required, we will conduct a security assessment in accordance with legal requirements. If data needs to be transferred out of the country, we will inform you of the purpose, scope, content, recipient, and the country or region where the recipient is located, and we will obtain your consent.
VII. How Long Will We Retain Your Information?
We guarantee that we will only store your personal information for as long as necessary to achieve the purposes of the service or under the conditions and time limits stipulated by laws and regulations. After the above storage period has expired, we will delete or anonymize your personal information. However, this does not apply if you exercise your right to deletion, cancel your account, or if there are other provisions under laws and regulations (for example, the E-Commerce Law stipulates that information on goods and services, and transaction information must be kept for no less than three years from the date of transaction completion).
VIII. How to Contact Us
If you have any requests, concerns, or questions about us, this Privacy Policy, or how we handle your personal data, or if you wish to lodge a complaint or exercise your data subject rights, please contact us as soon as possible by email: Siglota@Novement-Games.com.
When we update this policy, we will notify you. We recommend that you regularly review this policy to understand our privacy practices.