GameLoop Privacy Policy

Last Updated: ˜ ] 13 February 2020

Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Here is a summary of the information contained in this privacy policy. This summary is to help you navigate the privacy policy and it is not a substitute for reading everything! You can use the hyperlinks below to jump directly to particular sections.

What information do we need to provide the App?

If you use the App then we will process some information (e.g., to set up your account and to facilitate your use of the App). If you need to get in touch with us then we will also retain some information so that we can get back in touch with you and address any concerns. More Information.

How will we use your information?

We use your information to provide you with the many features that comprise the App. We do not share your information with any third parties, except where we need to in order to provide the service (e.g., using our affiliates around the world to help us to deliver the App) or we are instructed to by a court, authority or compelled by law. More Information.

Who do we share your information with?

We may share your information with our affiliates around the world who help us deliver the App and we may be required by a court or legal obligation to disclose certain information in some circumstances. More Information.

Where do we process your information?

Our servers are located in the People’s Republic of China (for the purpose of this privacy policy, this term excludes Taiwan and Macau), Hong Kong Special Administrative Region (Hong Kong), Singapore, the United States and Germany. Our support, engineering and other teams are located in our offices around the world. More Information.

How long do we keep hold of your information?

We retain your information in accordance with the periods specified in our data retention policy as further described in this privacy policy, unless otherwise required by applicable laws. More Information.

How can I exercise my rights over my information?

Depending on where you live, you may have certain rights with respect to your information, such as rights of access, to receive a copy of your data, or to delete your data or restrict or object to our processing of your data. More Information.

How to get in touch with us

If you have any questions about anything in this policy, or want to exercise any rights you may have, please contact us here.

How will we notify you of changes?

If there are any significant changes to this privacy policy, we will update the policy here. More Information. 

Contact Information

Data Controller: Oriental Power Holdings Limited

Email: You can contact the data controller at privacy@gameloop.com

EU Representative: Tencent International Service Europe B.V. Email: eudataprotection@tencent.com yes

 

 

 

 

 

 

 

 

 

 

 

 

 

 


Welcome to GameLoop!

This privacy policy explains the when, how and why when it comes to processing of your personal information in connection with the GameLoop App (the “App”), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

If you do not agree to the processing of your personal information in the way this privacy policy describes, please do not provide your information when requested and stop using the App. By using the App you are accepting our rules regarding your personal information as described in this privacy policy.

 

This App has been developed by Oriental Power Holdings Limited (“we”, “us”, “our”), who is the data controller. Our representative in the EU for the purpose of EU data protection laws is Tencent International Service Europe B.V., a company registered in the Netherlands. Their registered address is 26.04 on the 26th floor of Amstelplein 54, 1096 BC Amsterdam, the Netherlands and can be contacted at eudataprotection@tencent.com.

Please reach out to us if you have any questions or concerns regarding the processing of your personal information: you can contact us anytime at privacy@gameloop.com. 

The Types of Personal Information We Use

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled “How we use your personal information below.

The following is a high level summary of the types of personal information we use:

1. Information you provide to us (either directly or through a third party). 

 

You give us information about you, such as your Open ID, nickname, profile picture, IP address, and language settings, when you create an account and log-into the App. We use this information as well as your nationality and chat content to facilitate your communication with your friends, if you choose to use the App’s private and/or group chat functionality. We also receive certain information including your Open ID, IP address, error log and your email address when you use the App’s support and feedback features.

 

2. Information about you generated as part of the App (and its in-App services)

 

We automatically collect certain data from you so that we can provide you with the many functions and services that comprise the App. This includes your IP address and your language settings. This App also incorporates a security feature to help us maintain a fair playing experience and to detect cheating behaviour. This security feature collects information about the device, network and system on which you are using this App.

Cookies

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the App. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.

You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies, or instruct the device to provide notice at the time of installation of cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event of your refusal to install cookies, the App (or part of the App) may be unable to operate as designed.

For more information about our Cookies policy, click here.

Children

The App is not intended for children. Children must not use the App for any purpose. By children, we mean users under the age of 16 years old; or in the case of users located in in the countries specified below, the specified age.

 

If you are over the age of 16 years old but under the age stipulated below, you need the consent of your parent or guardian before using the App.

 

Country/region

Minimum age

Brazil

18

European Economic Area

(all EU countries, Iceland, Liechtenstein and Norway)

16

Malaysia

18

Switzerland

16

Turkey

18

Thailand

20

Russia

14

Indonesia

21

 

We do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under this age, please contact us at privacy@gameloop.com  and we will delete such information.

How We Use Your Personal Information 

This section provides more detail on the types of personal information we collect from you, and why. For users who live in the European Economic Area (“EEA”), it also identifies the legal basis under which we process your data.

Personal Information

Use

Legal Basis (only relevant if you are located in the EEA)

App

Information you provide to us (either directly or through a third party)

Account creation and log-in:

If you use Facebook or Google to log-in: Open ID, nickname, profile picture, IP address and your language settings.

We use this information to set up your account and facilitate your log-in in accordance with your instructions.

Necessary to perform our contract with you to provide this App.

Information generated as part of the App (and its in-App services)

IP Address and your language settings

We use this information to determine your region to allow you to connect to the server, to facilitate your use of the App and to improve our servers and services to you.

Necessary to perform our contract with you to provide this App.

Chat data: If you choose to use the App’s private and/or group chat functionality to communicate with your friends, then we will collect the content of your communication, your Open ID, nickname, profile pictures and nationality.

We use this information to facilitate your communication with your friends.

Necessary to perform our contract with you to provide the App’s chat functionality.

Support and troubleshooting: When you report an error, we collect your Open ID, IP address, email address and the error log

We use this information to provide troubleshooting, such as addressing and remediating technical issues and bugs.

Necessary to perform our contract with you to provide and support the App.

Feedback: If you decide to use our feedback system, we collect your Open ID, email address and the content of your feedback

We collect this information to improve our services to you.

Necessary to perform our contract with you to provide this App.

Security-related information: basic hardware information, operating system information, machine codes for security authentication, user account information, network information, information of files, processes, modules, memory and driver which is related to the game running, user behaviour and status that may be related to plug-in use, image files, memory image and shellcode which is related to the game running, system API calls, method calls, system procedures and related data of active windows, information on in-game modules, game screenshots, external programs attempting to access private data which belongs to process of game application.

We use this information:

·  for security purposes, including to detect cheating behaviours;

·  to provide a fair game environment for users of the App; and

·  to solve App crashes and to improve our services.

It is in our legitimate interests to use this information for security purposes.

We may collect other personal information from you from time to time for specific reasons (such as a promotion in your jurisdiction). When this happens, we will provide more information on any specific changes to the way we process that personal information that might differ to this privacy policy prior to collecting or processing any additional information. In some cases, that information may be shared with us with your consent – and if that is the case, we will provide you with further information on how we process that information and your rights.

How We Store and Share Your Personal Information

The Tencent group operates around the world. Pursuant to our contract with you to provide you with this App, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this privacy policy. Our servers for this App are located in the People’s Republic of China (for the purpose of this privacy policy, this term excludes Taiwan, and Macau), Hong Kong Special Administrative Region (Hong Kong), Singapore, the United States and Germany.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

·  Companies within the Tencent corporate group who process your personal information in order to operate this App. All related group companies may only use your personal information in accordance with this privacy policy.

·  Regulatory and judicial authorities and law enforcement agencies. There are circumstances in which we are legally required to disclose information, including to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users.

·  A third party that acquires all or substantially all of us or our business. If we sell or buy any business, undergo a merger, enter into a partnership, or sell some or all of our assets we may disclose your information to the prospective buyer of such business. Under these circumstances, we will always require the prospective buyer to comply with this privacy policy.

Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted to our services; therefore we do not assume any responsibility for any transmission of your information which you do at your own risk.

Data Retention

Personal Information

Retention Policy

Chat data*

Private chat: We store this data for 7 days from the date of collection before its automatic deletion.

Group chat: We store the last 200 messages within a group at any point in time and messages over this limit are deleted automatically.

Security-related information*

We generally retain this data for no longer than 90 days with the exceptions listed below. Upon a deletion request, we will delete the data within 30 days except where they relate to confirmed malicious activities.

·  File sample collection and memory sample collection related to confirmed malicious activities: up to 10 years 

·  In-game process information and system information: up to 10 years.

Security authentication: up to 5 years.

All other data*

3 weeks from the date of upload or collection (as applicable).

*Full description of data is set out in the section “How We Use Your Personal Information” above.

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.

Your Rights

Some jurisdictions’ laws grant specific rights to users of this App, which are set out in this section.

This section entitled “Your Rights” applies to users that are located in the European Economic Area and Switzerland.

The sub-sections entitled “Access”, “Correction”, and “Erasure” also apply to users that are located in Brazil, Canada, Indonesia and Russia. The sub-section “Objections” also applies to users that are located in Russia.

You have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at privacy@gameloop.com.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. If you believe we hold any other personal information about you, please contact us at privacy@gameloop.com. 

Portability

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent or pursuant to our contract with you, as described above in the section “How We Use Your Personal Information”. You have the right to receive this personal information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer it to another party, with certain exceptions. We will provide further information to you about this if you make such a request.  

Correction

You have the right to correct any of your personal information we hold that is inaccurate. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at privacy@gameloop.com.  

Erasure

If there is any personal information you believe we process that you would like us to erase, please contact us at privacy@gameloop.com.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on this App and there are grounds for erasure, we will use reasonable steps to try to tell others who are displaying the personal information or providing links to the personal information to erase it too.   

Restriction of Processing to Storage Only

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below by contacting us at privacy@gameloop.com.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at privacy@gameloop.com. 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.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend App access for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these App-related announcements, which are not promotional in nature.  

Contact & Complaints 

We welcome questions, comments and requests regarding this privacy policy. Please address them to privacy@gameloop.com. 

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at privacy@gameloop.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the jurisdiction in which you live or work where you consider we have infringed data protection laws.

Changes

If we make any material changes to this privacy policy we will post the updated privacy policy here. Please check this page frequently to see any updates or changes to this privacy policy.

 


SUPPLEMENTAL TERMS FOR USERS IN CERTAIN JURISDICTIONS

Some jurisdictions’ laws contain additional terms for users of this App, which are set out in this section.

If you are a user located in a jurisdiction listed below, then the terms set out below under the name of your jurisdiction apply to you.

Brazil

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORIZE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL DATA, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

California

This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).

 

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:

·  Identifiers, such as your our name as it appears on your social media profile, open ID / user ID, IP address, device ID, device token, phone number, mailing address, email address, and nickname. This information is collected directly from you and your device and from social media platforms if you choose to sign up using a social media account.

·  Internet or other electronic network activity information, such as your information regarding your use of the App services, including level, score, date and time stamps of actions, log-in and clickstream data and other Device Information as described in the main policy. This information is collected directly from you and your device.

·  Audio and visual information such as your social media profile picture, photos shared in the App, and audio messages. This information is collected directly from you and from social media platforms if you choose to sign up using a social media account.

·  Professional or employment-related information such as your profession if you choose to provide it in a survey. This information is collected directly from you.

·  Other information described in subdivision (e) of Section 1798.80, including information about your gender, nationality, or age. This information is collected directly from you in the context of being our consumer.

 

We collect your personal information for the following purposes:

·  To provide you the App services, including offering the App, maintaining your account, providing customer service, processing payments, and delivering audio and text messages;

·  To improve our services, including the functionality of the App;

·  For security and verification purposes, including to prevent and detect fraudulent activity;

·  To address and remediate technical issues and bugs.

 

For additional information about what each type of personal information is used for, see this chart in the main portion of the Privacy Policy.

 

We disclose personal information to the following types of entities:

·  Other companies within the Tencent corporate group who process your personal information in order to operate the App services

·  Other companies that provide services on our behalf who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing the services to us

·  Regulators and judicial authorities and law enforcement agencies

·  Entities that acquire all or substantially all of our business

 

In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” in the CCPA.

 

Rights under the CCPA

 

If you are a California resident, you have the right to:

·  Request we disclose to you free of charge the following information covering the 12 months preceding your request:

o  the categories of personal information about you that we collected;

o  the categories of sources from which the personal information was collected;

o  the purpose for collecting personal information about you;

o  the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and

o  the specific pieces of personal information we collected about you;

·  Request we delete personal information we collected from you, unless CCPA recognizes an exception; and

·  Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.   

 

We aim to fulfill all verified requests within 45 days pursuant to the CCPA.  If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

 

How to Exercise Your Rights

 

First, you may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may exercise your rights, if any, regarding other data by contacting us at eudataprotection@tencent.com.

 

India

 

SHARING OF YOUR PERSONAL INFORMATION

 

Where we permit any third parties to collect and use your Personal Information, we shall take reasonable measures to ensure that the third parties do not further disclose the Personal Information.

 

AGE RESTRICTIONS

 

Children under the age of 18 are not allowed to execute online contracts with us or sign up for our services. Parental consent is required for children under the age of 18 years to avail our services.

Indonesia

Consent

By accepting and consenting this privacy policy, you agree that we may collect, use and share your 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.

Accuracy of Information

You are responsible to make sure that any personal information 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 already secure all necessary consent before providing us with 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 claim whatsoever from any party as a result of absence of such consent.

Parental and Guardian Consent

If you are under the age of 21, you undertake that you have the consent of your parent or legal guardian to register an account on and use the App.

Data Subject Rights

You have the right to access, update, correct and request for erasure of personal information in our App from time to time in accordance with applicable data privacy laws and regulations in Indonesia.

Data Breach

In the event we fail to maintain the confidentiality of your personal information in the App, we will notify you through the contact information provided by you or via the App, to the extent required by local laws and regulations, at the latest 14 days since we acknowledge the breach of confidentiality..

 

Data Retention

 

Notwithstanding the provision on the erasure of personal information, to the extent required by local laws and regulations, we will retain your personal information, at the latest for 5 years.

 

Notification to Amendment of this Privacy Policy

 

In the event we amend this policy, we will provide a notification to you regarding the effective date of the changes at the latest 14 (fourteen) days prior the effective date, through (i) a notice to be posted on the landing page of our website, pop-up notification, or the splash screen of our mobile app or (ii) the contact information you provided to us. If you fail to explicitly express your objection to the amended policy within the above advance notification period, you will be considered as accepting the changes, therefore you will be considered to have agreed to the new policy.” However, you may stop using or accessing our App by unsubscribing at any time, if you cease to agree with the changed policy.

Japan

Your Rights (for Japan)

 

This section applies only to users that are located in Japan.

You may request us to notify purposes of use of, to disclose, to make any correction to, to discontinue the use or provision of, and/or to delete any and all of your personal information which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contact us at gameloopgameloop.com.  

Malaysia

Language of this Privacy Policy

In the event of any discrepancy or inconsistency between the English version and Malay version, the English version shall prevail.

Parental and Guardian Consent

If you are under the age of 18, please do not use the App.

In the event you are agreeing to this Privacy Policy in order for a minor to access and use the App, you hereby consent to the provision of personal information of the minor to be processed in accordance with this Privacy Policy and you personally accept and agree to be bound by the terms in this Privacy Policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor's compliance with this Privacy Policy.

Rights of Data Subjects

Right of access: You have the right to request access to and obtain a copy of information of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for access of your personal information in the amounts as permitted under law. 

When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

Right of correction: You may request for the correction of your personal information. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.

Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details provided above.  However this may affect our provision of the App to you.

Republic of Korea

How We Store and Share Your Personal Information

Delegation of Processing

For the performance of the services detailed in this privacy policy, we delegate the processing of your personal information to the following professional service providers:

Delegatee

Descriptions of Delegated Services

Shenzhen Tencent Computer Systems Company Limited

Internal data and infrastructure services.

Data Retention

Personal information, which has fulfilled the purpose for which it was collected or used, and has reached the period of time during which personal information was to be possessed, will be destroyed in an irreversible way. Personal information stored in electronic files will be deleted safely in an irreversible way by using technical methods, and printed information will be destroyed by shredding or incinerating such information.

Your Rights

 

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, etc. pursuant to applicable laws such as the Act on Promotion of Utilization of Information and Communications Network (the “Network Act”).

You may also exercise these rights through your legal guardian or someone who has been authorized by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Enforcement Regulations of the Network Act.

Upon your request, we will take necessary measures without delay in accordance with applicable laws such as the Network Act.

You can also withdraw you consent or demand a suspension of the personal information processing at any time.

Contact

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

·  Data Protection Officer, responsible for the management and safety of your personal information

·  +86 0755 8376 5566

·  privacy@gameloop.com 

Russia

If you are using this App in Russia, you consent (for the purposes of the Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (as amended) or any replacement regulations) to the processing in accordance with this privacy policy of your information. You also consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to the People’s Republic of China (for the purpose of this privacy policy, this term excludes Taiwan and Macau), Hong Kong Special Administrative Region (Hong Kong), Singapore, the United States and Germany. 

Thailand

By clicking “accept” below, you acknowledge that you have read, understood, and agree to this privacy policy. If you do not agree with this privacy policy, you must not use the App.

We will also give you notice by email of any changes to this privacy policy, and give you an opportunity to reject such changes, failing which the changes will become effective as stated in the notice.

Turkey

Our Data Controller Representative in Turkey for the purpose of compliance with Turkish Law on Personal Data Protection Law and its secondary regulations can be contacted at

privacy@gameloop.com.

You have legal rights in relation to the personal information data we hold about you. As a Turkish data subject, you may have right to (and to the extent permitted under applicable laws and regulations):

a) learn whether or not your personal data has been processed;

b) request information about processing if your personal data has been processed;

c) learn the purpose of processing of your personal data;

d) know the third parties in the country or abroad to whom personal data has been transferred;

e) request rectification in the event personal data is incomplete or inaccurate;

f) request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the Personal Data Protection Law (Turkey);

g) object to certain processing of data, and seek certain remedies in accordance with the Personal Data Protection Law (Turkey).

Users located in Turkey and under the age of 18 are required to obtain parental/guardian consent prior to using the App. Also above mentioned rights must be used by their parents/guardian on behalf of them.

Vietnam

By accepting this privacy policy, you expressly agree and authorize us to collect, use, store, and process your Personal Information, including, lawfully disclosing and transferring it to third parties, as described in this privacy policy.

 

We maintain international standards and security practices for data protection. When your Personal Information is transferred within or outside your jurisdiction of residence, it will be subject to the same or higher levels of security practices and data protection by the recipient entity as adhered to by us.    

 

Where we permit any third parties to collect and use your Personal Information, we shall take reasonable measures to ensure that the third parties do not further disclose the Personal Information.

 

Your Personal Information, if required to be disclosed to law enforcement agencies, public authorities or other judicial bodies and organisations, will be disclosed upon receipt of a written request from such organizations.

 

YOUR RIGHTS

 

You have the right to access, correct, and erase the Personal Information we hold about you. You also have the right to withdraw your earlier provided consent to collect, store, process, use and disclose your personal information and to request us to stop providing your Personal Information to a third party.