Privacy Notice

Last updated: December 7, 2023

Hi, Players! Thank you for getting WARTUNE (the “Game”) from your application stores, or our official websites, or other permitted resources. We have prepared this Privacy Notice to explain what personal data we collect from you when you download, install, open and play this Game, ways we might use or share it, as well as your data protection rights.

The data controller is 7road International HK Limited (the “Company” or “we”, “us” and “our”) under the EU GDPR and other applicable data protection laws. Additionally, we are the “business” for the purpose of CCPA compliance. The company is the Game’s operator who determines the purposes and means of your personal data processing in this Game. If you have any questions, comments, or concerns about the data processing activities in this Game, or you would like to exercise your rights under applicable data protection laws, please contact us by using the contact details provided at the bottom of this Privacy Notice.

1.What Personal data will be collected in this Game and why?

The personal data we collect from you may include followings:

(1) The personal data you provide to us in connection with this Game.

Your basic Personal data: such as your phone number, your mobile number, and your email address.

Network identification information: such as your account ID, username, nickname, game ID, character image, game friend list.

Transaction related information: such as transaction order records, transaction and consumption records (including recharge), completed payment verification information, virtual currency, virtual transactions, game redemption codes, game coins, game props, and game equipment.

Personal data related to the game and the Internet: such as communication records between customer service and players, player/user/visitor’s complaint content, game login/item log, game match information, game friend information, player game progress, game crash records, and Personal data obtained by Cookie, SDK or similar technologies, and information obtained by the microphone; and

Other information: such as game research results information and game membership information.

The reasons why we need your personal data include:

Ensuring the normal operation of the game, such as creating an account for you; support you on your needs in the Game e.g. transaction/order needs; verifying you are the correct player, providing necessary game functions or features for you;

Protecting your account, and conducting product risk control, including Anti-Fraud and Anti-Money Laundering.

Enable customer service to solve your problems, handling complaints from users, or communicating with you.

Optimising the player experience.

Phone/email marketing.

Developing and improving our products.

Testing for the stability of our products.

Internal analysis and reporting.

We may also use your personal data for other purposes that are not incompatible with the purposes we have disclosed to you (such as archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes) if and where this is permitted by applicable data protection laws, or we may get your additional consent for those purposes at that time

(2) The personal data we collect automatically

The personal data we collect automatically may include: your game devices information such as your device ID/name/model, MAC address, device platform, manufacturer brand of device, unique device identification code (such as IME/Android ID/IDFA/OPENUDID/GUID), random storage memory and external storage permissions, system type/version, language settings, resolution, mobile network status/WIFI status/WLAN hotspot information.

We use this information for our internal analytics purposes and to improve the quality and relevance of our App to the players like you.

Some of this information may be collected using Cookies and/or similar tracking technology, as explained further under the heading “4. Cookies and/or similar tracking technology”.

(3) The personal data we receive from third parties.

The personal data that we receive from third parties may include transaction and consumption records (including recharge), consumer service question or request. We only get that information in legal ways.

We collect and use your Personal data because we need to operate, provide, develop, and improve our products for our customers. In general, we will use the personal data collected from you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your Personal data.

2.Whom do we share your Personal data with?

We may share your Personal data with the following categories of recipients:

to our group company and our affiliates in the worldwide. Due to our Game has a web version which is operated by another affiliate within our group, thus you can choose to either login the web version or this App version, for this purpose, we will share your personal data with that affiliate. In addition, we may also need to share your data with our group company and other affiliates due to the purpose we have disclosed to you in this Notice (such as to support the delivery of our services in the Game or to provide functionality on, or help to enhance the security of our Game) if and where this is permitted by applicable data protection laws.

to our vendors/processors or third parties for certain purposes. We may engage some vendors/processors or third parties to support us on some affairs, such as for marketing purposes, or for risk control/security purposes. We will sign contracts with them to protect your personal data in accordance with applicable laws.

to the Game SDK providers. We will share your personal data with SDK third parties for different purposes as followings:

No SDK Providers Purposes
1 Google Login
2 Facebook Login
3 Login

Please note, this list may be changed due to the development of this Game, we will update the list if there is any new SDK third party involved to process your data.

to any competent law enforcement body, regulatory, government agency, court or another third party, only for the reasons of (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person, if such disclosure is necessary;

to an actual or potential buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice; and

to any other person with your consent.

3.Legal basis for processing your personal data

Our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it.

However, we will normally collect personal information from you only 1) where we need the personal data to perform a contract, terms and conditions with you; 2) we have your consent to do so; 3) where the processing is in our legitimate interests and not overridden by your rights, or 4) where in some cases, we may also have a legal obligation to collect Personal data from you or 5) we may otherwise need the personal data to protect your vital interests or those of another person.

If you have questions about or need further information concerning the legal basis, please contact us using the contact details provided under the “How to contact us” heading below.

4.Cookies and similar tracking technologies

We may use cookies and similar tracking technologies to manage our Game and make them can recognize your mobile device or provide and improve our products. You may click here to review more information about cookies and similar tracking technologies and how we use them.

5.How do we keep your personal data secure?

Pertaining to your use of our products, we have endeavoured to take reasonable and appropriate organizational and technical measures to prevent unauthorized access to or improper use of your Personal data, such as access control or encryptions.

Unfortunately, the transmission of information via the Internet is not completely secure. While we strive to protect your Personal data, we also remind you to be aware of the risks of hacking, cyberattacks, etc. on the Internet.

You agree to protect your personal data against unauthorized access to your password and to your computers, devices, and Apps by signing off your account when finished using a shared device.

6.Protection of minors’ information

Please note, although the age of a child or minor may be different from different jurisdictions, if you are a child/minor in your jurisdiction, this Game is not for you. However, this Game does not knowingly collect personal data from a child or minor. If you are a child or minor, please do not attempt to use the products or send any personal data about yourself to us. If we learn that we have collected personal data from a child or a minor, we will delete that information as quickly as possible.

If you believe that a child in your jurisdiction may have provided us with their personal data; or if you are a parent, or legal guardian of a child, and you have any questions or concerns, please contact us using the contact details provided under the “How to contact us” heading below.

7.International data transfers

Your Personal data may be transferred to, and processed in, countries other than the country in which you are a resident. These countries may have data protection laws that are different to the laws of the country you reside in (in some cases, may not be as protective).

Specifically, this Game’s servers are located in Sao Paulo, and our group locations and third-party service providers and partners operate around the world. This means that when we collect your Personal data, we may process it in any of these countries. In this case, we will take appropriate organizational and technical measures to ensure that your personal data is properly protected.

If we need to transfer personal data outside of EU/EEA, generally we will implement the EU Standard Contractual Clauses with supplementary measures to keep the data security.

8.Data retention

We retain the personal data for the shortest period necessary to achieve the purpose stated in this Notice. We may also retain your Personal data where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested, to perform a contract with you or to comply with applicable legal, tax or accounting requirements).

When we have no ongoing legitimate ground to process your Personal data, we will either delete or anonymize it or, if this is technically not possible (for example, because your personal data has been stored in backup archives), then we will securely store your Personal data and isolate it from any further processing until deletion is possible.

9.Your data protection rights

According to applicable data protection laws, you may have the following data protection rights:

If you wish to access, correct, update or request deletion of your Personal data, you can do so at any time by entering into Game, clicking on the “Support” and clicking on the “Data protection rights”. You can also contact us by using the contact details provided under the “How to contact us” heading below;

In addition, you can object to the processing of your Personal data, ask us to restrict the processing of your Personal data or request portability of your Personal data. Again, you can exercise these rights by contacting us using the contact details provided under the “How to contact us” heading below;

You have the right to opt out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. You can also contact us by using the contact details provided under the “How to contact us” heading below;

Similarly, if we have collected and processed your personal data with your consent, then you can withdraw your consent at any time unless otherwise provided by law. It is important to note that withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal; and

You have the right to complain to a data protection authority about our collection and use of your Personal data. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Economic Area, Switzerland are available here

You may have some additional data protection rights according to applicable data protection laws in different countries or regions, if you wish to make such a request of data protection rights, please contact us by using the contact details provided under the “How to contact us” heading below. However, please note, for data security purposes, before responding to your request, we may ask you to verify your identity and provide further details about your request to ensure that you are the right person to access such data or request to have other data rights.

We respond to all requests we receive from individuals wishing to exercise their personal data protection rights in accordance with applicable data protection laws, generally, for example, under the EU GDPR, we will respond your request of data protection rights within 1 month, however, If your request is very complex for us to handle, we will inform you firstly and extend this period, but the total period for handling such request will be within 2 months.

Additional information for the “consumers” in California

Under the CCPA and also CPRA, residents of California have certain rights regarding the personal data that businesses collect and process about them. This includes the rights to request access or deletion of your Personal data, as well as the right to direct a business to stop selling or sharing your Personal data.

We are required to detail the categories of Personal data that we collect and/or share for the purposes described in the section “What Personal data will be collected in this Game and why” of this Notice.

We collect and in the past 12 months have collected the following categories of Personal data for our business purposes:

Personal Identifiers.

Information collected by cookies and similar technologies

Internet or other electronic network activity information, including app log information, content you view or engage with, app information and device information.

Inferences drawn from any of the above categories of Personal data.

While we do not sell Personal data in exchange for any monetary consideration, we do share Personal data for other benefits as defined by Cal. Civ. Code 1798.140(ad)(2). We have shared in the preceding 12 months Personal data as necessary for specific “business purposes,” as defined by Cal. Civ. Code 1798.140(e). You have a right to direct Game not to sell or share your Personal data. We do not sell or share the personal data of consumers who are under 16 years of age.

If you would like to access, review, update, correct, delete any personal data we hold about you, or exercise any other privacy rights available to you, including the right to opt-out from selling or sharing your personal data, please contact us using the contact details provided under the “How to contact us” heading below.

We endeavor to respond to a Privacy Rights Request within the required timeframes. If we need more time, we will inform you of the reason and extension period in writing.

10.Updates to this Privacy Notice

We may update or amend this Privacy Policy at any time by direct electronic notification to you or by publishing the updated version on this page. All amended terms will automatically be effective for new users or new purchases immediately upon posting.

You can see when this Privacy Notice was last updated at the top of this Privacy Notice.

11.How to contact us

If you have any questions or concerns about our use of your Personal data, please contact us using the following details:

Email Address: [email protected]