Privacy Policy

Valid from the 2st of February 2021

General provisions

We are HALOMOBI PTE. LTD. (“Halomobi Games, LTD”, “Hiliang Games”, “Company”, “We”), established and acting under the laws of the PRC.

We are grateful to you for playing our games!

We respect Users of our applications, services, and visitors to our website. The privacy and security of our Users are of paramount importance to us, and we comply with provisions of applicable privacy and data protection laws, including the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and the Federal Law of the PRC "On Personal Data."

The present Privacy Policy ("Policy") applies to our games, websites, and related services ("Services"). The Policy is complemented and should be considered in conjunction with the License Agreement.

For the purposes of the present Policy, we define the term the "User" ("You") as a natural person with whom we have established relations and who has accepted our License Agreement.

The policy determines how and what data about you we collect and process when you use our Services, how such information is protected, and what rights you have regarding this information.

In accordance with the General Data Protection Regulation (GDPR) and other data protection laws in the member states of the European Union, HALOMOBI PTE. LTD. is the Data Controller in regards to our Services.

We classify as "Data about you" (personal data, information about the User) any data that can identify you personally or are indirectly related to you and by which you can be identified.

By "Processing" information, we mean any action (operation) or a set of actions (operations) carried out with personal data using automation tools or without using such tools, including collection, recording, structuring, sorting, accumulation, storage, adaptation, or modification, downloading, viewing, analyzing, disclosing by transmission, distributing or otherwise providing access, matching or combining, reducing, deleting or destroying.

Anonymous or anonymized information that we cannot associate with your person is not classified by us as personal data.

In providing the Services, we, acting reasonably and in good faith, believe that you:

· have all the necessary rights to use the Services;

· provide valid data about yourself to the extent necessary to use the Services;

· you understand that by publishing your data if such a technical capability is available in the Services, and where it is available to other Users of the Services, you have expressly made this data commonly available, and the data may become available to other Users, copied and distributed by them;

· understand that some kinds of information about the User transmitted by you to other Users of the Service cannot be deleted by you or us;

· are aware of the present Policy, have understood and accept the present Policy.

We do not verify the information received from you about the Users unless such verification is necessary to implement our obligations.

1. Data we collect and process

The company collects and processes only those personal data that are necessary to implement obligations under the License Agreement concluded with you and in order to ameliorate the quality of our Services.

To use our Services, there's no need to provide us with information about your name and surname, residency or place of stay, telephone number, or e-mail address. We do not request or process your financial information and information about bank accounts, bank cards, and their holders.

The information necessary to make purchases in our Services is provided by you to the payment service provider using secure protocols in accordance with its established procedure. If you pay in a mobile application, then this information is collected and stored by the platform you use (for example, Apple Store or Google Play) or the platform's payment service provider.

Under no circumstances we collect and process a special category of personal data revealing racial or ethnic origin, political views, religious or philosophical beliefs, membership in any public organizations, genetic and biometric data, data on health conditions, criminal records and offenses, and other intimate information about a natural person.

We will process your personal data on the basis of your consent and provide you with all the information necessary to make a voluntary decision to grant or refuse consent.

1.1. Data received during registration

When registering, you automatically provide us with identificators of service providers: Google Play, App Store, and other platforms on which our Services are hosted. This information is used by the Company to identify the User, provide him/her with support, services, mailing, marketing campaigns, and can be transferred to our partners.

You can use our Services without an authorized Google Play and App Store account only in a restricted mode since we will not be able to synchronize data between your different devices and will not create a save file. In this case, your profile and saved data will be associated with your device ID.

1.2. Communication data

When you contact us or report problems using our Services, issue any content, or provide any other information, we may process all of that information. This information may include:

· contact information that you can provide through our support channels;

· data sent through the internal chat of the Services, including voice chat;

· data about our Services that you post, comment on, or like on any of the open and public resources;

· information about purchases on our Services, which includes only the amount of the transaction, but does not include financial information or bank card information of the cardholder;

· information that you can provide by partaking in our promotions, contests, surveys, and other events;

· information about your profiles on social media websites to integrate with such services.

Information that Users can share using the chat function or forums may contain personal data.

We do not encourage or ask Users to share such information, but we cannot prevent it. The user who has shared his/her data via chat or forum is fully responsible for such actions.

In all cases, you can always contact us and request to delete your data from any Services controlled by us.

1.3. Data we collect automatically

The browser or the Client part of our Services may collect and transmit certain information about Users, including:

· IP address, traffic information, and actions in the Services;

· GameCenter ID if you are using iOS;

· Google Play ID if you are using Android;

· identifiсators in social media and online services, such as Facebook, YouTube, and others;

· identifiсators, settings, and characteristics of devices and operating systems used to interact with the Services;

· preferred communication language;

· general information about your location, which does not include exact location information.

1.4. Cookies and similar technologies

For our Services to function properly, we or our partners may use cookies. Cookies are small pieces of textual information stored in memory, which is generated automatically and stored on your device to associate and identify User activity. Cookies do not contain personal information.

Cookies or similar technologies stored on your device through which you use our Services carry out the following functions:

· Authentication. Cookies help us demonstrate you the correct information and personalize your experience;

· Preferences and settings. Cookies or similar technologies may indicate which language you prefer and/or what your communication preferences are;

· Performance, analytics, and research. Cookies or similar technologies help us to obtain information about the versions of the Services, how well they work, to update and improve them.

· Safety. With the help of cookies, we can monitor means of achieving security and counter-fraud when using the Services.

· Marketing. We or our partners may use cookies or similar technologies to carry out marketing campaigns, track their effectiveness, determine the effectiveness of advertisements, and provide more effective targeted advertising.

In order to refuse to transmit any information using cookies or other tracking technologies, you can actively manage the settings of your browser or mobile device. Please see the technical information of your browser or mobile device to get instructions on how to remove and disable cookies and other similar tools.

1.5. Information we receive from third parties

We may collect information from third parties for our legitimate purposes in addition to the information provided by you and collected by us automatically. For example:

· we receive information from third-party platforms (such as the Apple Store or Google Play) when you download our Services to your mobile device;

· when linking your Facebook or VKontakte account to our Services using the “Add to Friends” function or similar ones. Please make sure that you are satisfied with the amount of information provided to third-party services by acknowledging the published rules, and, if necessary, make changes to your privacy settings directly on the third-party service;

· we may collect advertising and analytical information from third parties to implement our marketing initiatives, improve the Services, and better manage our advertising campaigns.

1.6. Anonymous or impersonal information

We also process information that does not directly or indirectly link to a specific natural person and cannot be used to identify him/her.

Such information may include a summary or generalized information about the actions and achievements in the Services, visiting hours of the Services, the duration of their use, and other similar information.

We may use a third-party analytics provider to help us collect and manage this data. We use this information to provide the Services and improve them.

By using our Services, you consent to the collection and processing of anonymous or impersonal information.

2. Use of information

2.1. Legal grounds, purposes of collecting and processing information

We collect and process your information to deliver services per the License Agreement, with your consent, in the legitimate interests of our company, as well as for other legitimate reasons.

The main purpose of collecting and processing information about you is to ensure that our Services are delivered and the quality is improved.

We collect and process your data and impersonal data to:

· create accounts, save user preferences, and enable you to use our Services;

· to ensure compliance with the terms of service following the License Agreement and this Policy;

· to manage, monitor, test, improve and optimize our Services, means of how Users interact with the Services, conduct analysis, and research for specified purposes;

· to update and improve our Services, provide technical support to Users, fixing defects and errors;

· to provide Users with the ability to communicate with each other and share our Services;

· to prevent cases of fraud or other illegal activity that can cause damage to us, you, or other persons;

· to notify Users about various events on the Services, updates, new products, content, or promotions;

· to manage contextual and customized advertising, to send certain offers on the Services that, in our opinion, will be most useful to you;

· to reward, сonduct surveys, prize draws, competitions, or other promotional events organized by us or our partners;

· to ensure security and fairness when using our Services, prevent violations, сounter fraud, and deception;

· to comply with our obligations under the legislation, to resolve any disputes that may arise between us and you or other Users, and to ensure compliance with treaty obligations with third parties.

You can optimize or disable notifications about various events and advertisements in the settings of our Services.

The legal ground to process data (for Users from the European Union).

Our legal ground for processing your data will depend on the purpose for which We use your data. In general, We will rely on the following legal bases to process your data:

· to complement treaty obligations with you;

· based on our legitimate interests;

· to comply with our responsibilities under the requirements of the law;

· in some cases based on your consent.

2.2. Data transfer and sharing

To achieve the purposes prescribed by the present Policy and the License Agreement, We сan share your data with third parties. These may include the following categories of beneficiaries:

· companies that provide services to us and process data on our behalf when providing these services to you (for example, hosting services providers, payment services, services that add functionality to the Services, or other services that help us when analyzing, developing, and operating of our Services);

· companies we work with when providing the Services (which may process your data independently of us), including advertising partners;

· competent courts or other public bodies, if disclosure of the information is necessary for accordance with applicable legislation;

· natural persons or legal entities, if, in our view, the disclosure of the information is necessary to exercise or protect our legal rights or to protect your legitimate interests or the legitimate interests of others;

· any other natural or legal person, on your behalf or with your consent.

Also, We may disclose the information collected and processed in the event of a reorganization, merger, sale, the formation of a joint venture, disposal, transfer, or another disposal, in whole or in part, of HALOMOBI PTE. LTD. and/or our assets.

2.3. Transboundary data transfer

To deliver the services of our Services and following the License Agreement, the above data may be processed and stored wherever we or our partners carry out their activities, including outside the European Union and the European Economic Area.

To store and process your data, We currently use the services of our partners Selectel and DigitalOcean.

By using our Services, you authorize the transfer of personal data in the quantities indicated above outside of your country of residence and acknowledge that your data may be transferred to other countries, each of which may have privacy rules that differ from those applicable in your country of residence.

Regardless of where exactly your data is processed, the Company uses the same security measures described in the present Policy, inter alia, by including special conditions in contracts with our partners.

2.4. List of third-party services and partners

To meet the objectives described in the present Policy and License Agreement, we are currently working with the companies listed below. Also, when using our Services, Users can click on links to other sites and/or software applications that are beyond our control.

HALOMOBI PTE. LTD. only works with competent and reliable partners, but we cannot be responsible for the content or privacy policies of our partners.

For information on how third parties may use your information, please see their privacy policies.

Apple (https://www.apple.com/legal/privacy/en-ww/)

Google (https://policies.google.com/privacy)

Facebook (https://www.facebook.com/about/privacy/)

AppsFlyer (https://www.appsflyer.com/legal/privacy-policy/)

Unity (https://unity3d.com/legal/privacy-policy)

3. Data storage

HALOMOBI PTE. LTD. will not maintain data more than needed to achieve the purposes for which it was collected or as required by applicable legislation or regulation.

We may periodically identify unused accounts, and we regularly check and delete unused and unnecessary data.

To the specified data, we refer to the User's data that is not used for 1 (one) year since the last use of the Service.

Please note that if you ask us to delete your data following the procedure described in the “Your rights” section, we may retain it as necessary to protect our legitimate business interests, for example, to comply with our obligations, settle disputes, and enforce compliance with our agreements.

4. Security

To provide security when using our Services, we use and implement organizational, administrative, legal, technical, and physical measures to protect your data from unauthorized access, fraudulent use, distribution, and other threats to information security.

For example, to store information, We use computer systems with limited access in controlled areas. We also use encoding and encryption technologies to protect some of the information we collect.

Currently, you can download our games on Google Play and App Store, and valid links can be found on our website.

Any other download sources are invalid, and we cannot guarantee your safety when you receive services from other sources.

5. Age restrictions

Since our Services are intended for capable Users (as understood by applicable legislation), we do not purposefully collect or use "Personal information" (as defined in the Children's Online Privacy Protection Act (COPPA)) obtained from anyone under the age of 13.

If you are under 13 (or under 16, depending on the country you are in), please do not use our services or ask your parents (or their authorized representatives) to consent to your use of our services.

We respect the privacy rights of parents and children, and we are committed to complying with the provisions of COPPA. If you are a parent (a person exercising parental authority) and you believe that we have collected your child's data in violation of the law, please let us know in any way convenient for you following the "Appeals" section of the Policy. We will delete this data per applicable law.

6. Your rights

You have certain rights regarding your personal data. There is a brief overview of these rights below, their use, and probable restrictions.

You can send us a request to provide information about your personal data that we process, under section "Appeals". Carrying out of your requests may be limited in some cases, for example, when your request concerns the disclosure of information about another person, or if you ask to delete information that we are entitled to process in accordance with the provisions of the law, regardless of your consent.

You have the right to access your personal data, object to our use of your information (including for marketing purposes), request the deletion or restriction of your information, or request your data in a structured format.

Right to delete data. You have the right to entrust us to completely or partially delete your personal data. In addition, in some of our Services, you can independently use the "Reset Account" function, and thus delete your personal data. If you delete your account, you will permanently lose progress, experience, upgrades, and all digital content on the Services.

Right to object to data processing. You can exercise your right to object to the processing of your data. If you refuse to process your data, we will no longer process your personal data unless there are strong and prevailing legal grounds for processing and if the data is not used to protect our legitimate rights and interests.

You can withhold your consent to the processing of data by contacting us by the section "Appeals". If you revoke your consent, this will not affect the legality of the processing based on your consent before its withdrawal.

Refusal to direct marketing. You can turn off push notifications in our Services by visiting the appropriate section of the settings. To reject receiving interest-based advertising on mobile applications, please check the privacy settings of your Android or iOS device and select "Restrict ad tracking" (Apple iOS) or "Restrict interest-based advertising" (Android).

You can also refuse to receive our information for marketing purposes by contacting us following the "Contact" section.

You have the right to make a complaint with a supervisory body.

6.1. For European Union Users Only:

Right to data migration. You have the right and the opportunity to get some of your personal data in a format that you can relocate from one service provider to another, from our Services to other software products. Depending on the context, this applies to some, but not all of your data.

6.2. Only for Users - residents of California, USA.

The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to obtain information, delete data, and refuse to proceed data and requires companies to collect or disclose data to submit notifications and opportunities to exercise rights.

Over the past 12 months, we have collected data from the following categories mentioned in the CCPA:

· data categories we have collected about you;

· categories of sources from which data about you was obtained;

· the business or commercial purpose of collecting personal data on you;

· particular Data we have collected on you.

You also have the right to have your data deleted.

To exercise any of the mentioned rights, send a request by email: hailianggame@gmail.com. In the request, please indicate: the Service you use, your name or nickname, what right you want to exercise, and to what extent. Within 10 days, We confirm that your request is received. We may solicit specific information to help us verify your identity and process your request.

However, we inform you well in advance that in the above case you will have to tell us more information about you than we had before.

You can appoint an accredited representative to send inquiries on your behalf. However, for this, we need written confirmation of the representative's authority and immediate verification of your identity.

You have the right not to be discriminated against by us for the exercise of any of your rights.

Our Services' users who are California residents may request (i) a list of their data's categories that we disclosed to third parties during the preceding calendar year for marketing purposes; and (ii) a list of the categories of third parties to whom we have disclosed such data.

The request may be submitted to the following contacts (email or mailing address), indicating that it is being carried out in accordance with the California Shine the Light Act. Please note that we have an obligation to respond to such inquiries only once per calendar year.

If you are a user of our Services, and you are a California resident under the age of 18, you can ask us to remove any content or information that you post on our Services. Please submit a request specifying the information you want to remove to our email address: lianghaigame@gmail.com with the subject line "California Under 18 Content Removal Request". We will make all reasonable attempts to remove posted information from the relevant public domain. However, we cannot ensure the content to be completely removed, and it may retain the content necessary to comply with our legal obligations, resolve disputes, and for the enforcement of our agreements.

You may have other rights under the laws of your country of residence or where you are a resident.

7. Acceptance of terms and conditions and introduction of amendments

We assume that our Services' Users have carefully read this document and agree with its content. If you disagree with the present Policy, please refrain from using our Services.

We will make the needed improvements and additions to our Privacy Policy in case of changes in legislation and as necessary.

Changes to the Policy will be posted on this page and, if the changes are essential, we will give you notice using our existing communication means in our Services.

We will keep previous versions of the present Privacy Policy in our documentation archive.

If you continue to use the Services after you have been informed of any such changes, it constitutes acceptance of the present Policy.

8. Appeals

HALOMOBI PTE. LTD. is the data controller and is responsible for privacy and personal data protection issues.

When addressing us on a matter that concerns the exercise of your rights, per the rules of the existing legislation, we may require additional information for fulfilling a request or implement an instruction. In most cases, we will fulfill your request or mandate within one calendar month, if all the required information is available on your part.

By the existing legislation, users from the PRC are provided with information about the processed personal data on the grounds of a written request (request) sent to the postal address indicated below. In the appeal, it is necessary to indicate the number of the basic identity document of the subject of personal data or his representative, information about the date of issue of the specified document and the issuing authority, the name or nickname of the User, the signature of the subject of personal data or his representative, and other information necessary for identification. The appeal can be sent in the form of an electronic document and signed with an electronic signature following the legislation of the PRC.

If we are not able to fully satisfy your request or fulfill the mandate within a calendar month (due to the complexity or the number of requests), we can extend this period for another two calendar months, if this is not at variance with the existing legislation. If an extension is necessary, we will explain the reasons for the delay. If you make your request electronically, we will provide you with the information electronically, unless you request otherwise.

If you have any questions regarding the present Policy, mandates on how to process your data, or requests to resolve problems related to personal data, please contact us in a convenient way for you:

Data Controller - HALOMOBI PTE. LTD.

Email address: hailianggame@gmail.com

Postal address: 9 RAFFLES PLACE #06-00 REPUBLIC PLAZA SINGAPORE (048619)

9. Information Collection and Use

9.1. Types of Information Collected

When you use the game, we may collect the following types of information:

a) Personal Information: such as your name, email address, and contact information.

b) Device Information: such as your mobile device's unique identifier, operating system version, network type, and mobile device information.

c) Game Data: such as your in-game progress, achievements, and gameplay statistics.

9.2. Use of Collected Information

We may use the collected information for the following purposes:

a) To provide and improve our services, including gameplay features, updates, and customer support.

b) To personalize your gaming experience and offer tailored content, promotions, and recommendations.

c) To communicate with you regarding game-related announcements, updates, and promotional offers.

d) To analyze and monitor game performance, usage patterns, and trends for research and development purposes..

10. Information Sharing and Disclosure

We may share your information with third parties in the following circumstances:

a) With your consent: We may share your information with third parties if you provide your explicit consent.

b) Service Providers: We may engage trusted third-party service providers to assist us in delivering and improving our services, subject to confidentiality obligations.

c) Legal Requirements: We may disclose your information if required to do so by law or in response to valid legal requests, such as court orders or government regulations.

11. Data storage

We implement industry-standard security measures to protect the confidentiality and integrity of your information. However, please note that no method of transmission over the internet or electronic storage is completely secure.

12. Your Rights and Choices

You have the right to access, correct, or delete your personal information. You may also opt-out of certain data collection and processing by adjusting your device settings or contacting us directly.

13. Children's Privacy

GAME is not intended for children under the age of 13. We do not knowingly collect personal information from children. If we become aware that a child under 13 has provided us with personal information, we will take steps to delete it.

14. Updates to this Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the updated policy on our website or through other communication channels.

15. List of third-party services and partners

To meet the objectives described in the present Policy and License Agreement, we are currently working with the companies listed below. Also, when using our Services, Users can click on links to other sites and/or software applications that are beyond our control.

HALOMOBI PTE. LTD.only works with competent and reliable partners, but we cannot be responsible for the content or privacy policies of our partners.

For information on how third parties may use your information, please see their privacy policies.

Apple (https://www.apple.com/legal/privacy/en-ww)

Google (https://policies.google.com/privacy)

Facebook (https://www.facebook.com/about/privacy)

AppsFlyer (https://www.appsflyer.com/legal/privacy-policy)

Unity (https://unity3d.com/legal/privacy-policy)

Singular（Privacy Policy - Singular）

Liftoff(https://www.liftoff.io)

Applovin: (https://dash.applovin.com)

Mintegral: https://www.mintegral.com/

16.  DATA SECURITY

We have put in place appropriate security measures to prevent your information from being accidentally  lost,  used  or  accessed  in  an  unauthorised  way,  altered  or  disclosed.  In addition, we limit access to your information to those employees, agents, contractors and other  third  parties  who  have  a  business  need-to-know.  They  will  only  process  your information on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

17. DATA RETENTION

HOW LONG WILL YOU USE MY INFORMATION FOR?

We will only retain your information for as long as necessary to fulfil the purposes we collected it for (e.g. such as providing you access to our Services), including for the purpose of satisfying any legal, accounting, or reporting requirements.

Where  it  is  no  longer  necessary  to  process  your  Personal  Data,  we  will  delete  it  or anonymise it by removing all details that identify you in accordance with Data Protection Laws. For example, if you withdraw your consent to process your Personal Data, we will delete your Personal Data unless this is required to be retained to enable us to comply with

Data Protection Laws.

The length of time for which we retain your Personal Data will depend on what we are using it for as set out in this privacy notice. For example, whilst you are using our products and services, we may need to use it to answer your queries about our products and services. We will also keep your email address whilst you have subscribed to receiving marketing

communications but, even when you unsubscribe, we are required to continue to retain to ensure that we do not send you any marketing communications in future.

If you want to know how long we retain information collected via the use of cookies, read

our cookie policy

Please note, however, that we may be subject to legal and regulatory requirements to keep Personal  Data  for  a  longer  period,  in  particular  pursuant  to  any  applicable  statutory

limitation period.

18. YOUR RIGHTS

Under certain circumstances, you have rights under Data Protection Laws in relation to

your Personal Data, including the right to:

. request access to your Personal Data;

. request correction of your Personal Data;

. request erasure of your Personal Data;

. object to processing of your Personal Data;

. request restriction of processing your Personal Data;

. request transfer of your Personal Data;

. withdraw consent;

. object (where our lawful basis for processing your Personal Data is based on our Legitimate Interests); and

. complain to the regulator (if you are unhappy with our response to your query) by visiting www.halomobi.com

. Our Ad Partners do collect and use the usage data described in Section 7 above. If you wish to exercise any of the rights set out above in respect of such data, please contact the Ad Partners using the details in their privacy notice.

19. QUESTIONS

If you have any questions about this privacy notice or wish to otherwise exercise your rights (such as to withdraw your consent from receiving marketing communications), please

contact us： hailianggame@gmail.com

20. CHANGES TO THIS PRIVACY NOTICE

We may, from time to time, change or update this privacy notice. All changes to this privacy notice will be published on this page of our App. Each change will become effective upon publication. We recommend that you revisit and read this privacy notice regularly to ensure

that you are up-to-date with the current terms.

21. GLOSSARY

Term                                                                       What this means

We committed to protecting your personal information and privacy.

If you have questions or comments regarding how our app protects your information or this Privacy Policy, please contact us at: hailianggame@gmail.com