PRIVACY POLICY

Updated Date:2024/06/12

INTRODUCTION

This privacy policy informs you of your choices and our practices regarding any personal information you provide to us. Your use of “QCPLAY Game Products” distributed by QC-GAME DIGITAL TECHNOLOGY (HONGKONG) CO., LIMITED or any of its subsidiaries and affiliates (collectively, “QCPLAY”, “we” or “us”) involves the collection and use of your personal information. It is important for you to understand how this happens and how you may control it.

THE MINIMUM AGE TO PLAY QCPLAY GAME PRODUCTS IS 18 (IN AUSTRALIA/CANADA) /16(EUROPEAN ECONOMIC AREA/SWITZERLAND), OR OTHERWISE SPECIFIED BY THE LAWS AND REGULATIONS OF YOUR COUNTRY OR REGION OF RESIDENCE. WE WILL NOT KNOWINGLY COLLECT PERSONAL DATA FROM CHILDREN UNDER THIS AGE. INSOFAR AS CERTAIN COUNTRIES APPLY A HIGHER AGE OF CONSENT FOR THE COLLECTION OF PERSONAL DATA, WE REQUIRE PARENTAL CONSENT BEFORE PERSONAL DATA ASSOCIATED WITH IT COLLECTED. WE ENCOURAGE PARENTS TO INSTRUCT THEIR CHILDREN TO NEVER GIVE OUT PERSONAL INFORMATION WHEN ONLINE.

In the event of a merger, acquisition, reorganization, bankruptcy or other similar event, we will make an announcement in advance, disclose the details of the event and information about the successor, and with the express consent of you or your guardian again. Your personal data may be trasferred to the successor of QCPLAY. We may periodically modify, adjust or revise the terms of this Privacy Policy. The updated terms will be announced to you , and we will obtain your consent again. You agree to check the new terms regularly. If major clause changes are involved, we will make an announcement in advance.

For your reference, the table of content of this privacy policy is listed below:

  1. WHAT DATA WE COLLECT AND PROCESS
  2. WHEN WE COLLECT AND PROCESS DATA
  3. WHY DO WE COLLECT YOUR PERSONAL DATA
  4. WHO MAY ACCESS YOUR PERSONAL DATA
  5. DATA RETENTION
  6. INTERNATIONAL DATA TRANSFERS
  7. SECURITY OF YOUR PERSONAL INFORMATION
  8. YOUR RIGHTS
  9. CHILD PRIVACY
  10. INTEREST-BASED ADVERTISING
  11. CONTACT AND COMPLAINTS
  12. CHANGES

1. WHAT DATA WE COLLECT AND PROCESS

"Personal Information" or "Personal Data" means information about your personal location and activities, such as information about your use of the Services, IP address or mobile device identifier, if directly associated with personally identifiable information that specifically identifies an individual (such as name, address, telephone number or other account number). If such information is associated with other personal information that identifies or identifies you, personal information also includes demographic information, such as date of birth, gender, geographic region, and preferences.

(1) Data You Provide

When you provide us with your personal information, we may collect it. You may provide us with information about you by filling in forms on our website or by corresponding with us by phone, email, or otherwise. This includes information you provide when you register to use our Services, subscribe to our newsletters, participate in discussion boards or other social media functions on our website, enter a competition, promotion, or survey, and when you report a problem with our Services. The information you provide may include your name, address, email address, phone number, username, password, and other information you choose to provide.

(2)Data Collected When You Use Our Services

When you access or use our services, we collect data from and about you and the device you use. This may include the following data:

(i) Data about game progressions and any use of QCPLAY Game Products

(ii) Internet Protocol (“IP”) address

(iii) Data about your device, such as your device ID, device name, device type, operating system, advertising ID, MAC address, CPU, language, network type, operator and the type of browser

(iv) General location data (manually selected by you)

(v) Transaction information: including top-up and consumption records and other transaction-related information, used to protect the safety of users' virtual goods and provide customer service staff with information to support the handling of disputes when they arise. However, we do not and cannot obtain sensitive transaction information such as payment passwords

(vi) Nickname, email, login information, time zone settings, APPLE IDFA, game platform, game version, mobile and hardware identifiers, device event information, crash reports, subtitle settings, game score, game metrics, achievements, rankings, game time, feature usage, scores and progress, purchase status, timestamp, session time, status of sending challenges or gifts to other users, and platform number of friends.

(vii) Data received when logging in with a third-party platform account: nickname, username, friends list, email address, location information, language, device ID and purchase history.

(viii) Cookies and similar technologies (see more below).

(ix) Game scores and achievements, and other information and inferences to better understand your preferences, and as reasonably required to offer and enhance our services.

(3)Data we get from our contractors

We may receive information about you if you use any of the other websites we operate or the other services we provide. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment, and delivery services, advertising networks, analytics providers, search information providers, and credit reference agencies) and may receive information about you from them.

(i) Data to fight cheating (such as refund abuse)

(ii) Data from payment methods that help the QCPLAY run (such as to verify and confirm payment)

(4) Cookies

In order to measure the effectiveness of our services, some pages on our websites may use cookies, which are small text files for added functionality or for tracking site usage. We and our authorized contractors may use cookies and/or authorize third party’s tracking-utility, from time to time, (a) to log your IP address in determining the path that users take on our sites and identifying repeat users of our sites, (b) to collect the websites or sources that linked or referred you to our services, and/or (c) to collect technical data about the devices and software you use to access our services, the operating system of your devices, and other similar technical data.

Notwithstanding the foregoing, we and our authorized contractors do not link your IP address to your personal data. If you do not wish to accept cookies or want to be notified of when they are placed, you may set your web browser to do so, if your browser permits.

Depending on the services you use, we and our authorized contractors may also use these technologies to collect information about how you view and use our services and content, and to link your activities to other information we have stored about you. Some of these contractors include but are not limited to ironsource, unity, admob and meta. You can click on the name of each contractor to learn more about their privacy policy.

We and our authorized contractors use cookies, web beacons and similar technologies to personalize your experiences on our services and for various other purposes, including:

(i) remembering you: cookies, web beacons and similar technologies can help us identify you as a registered user or keep the preferences or data that you have previously provided;

(ii) analyzing how you use our services: we can use cookies, web beacons and similar technologies to understand what visitors (including users) are doing on our services, or what pages or sections are most popular;

(iii) serving advertising: cookies, web beacons and similar technologies help us provide you with advertising that we believe is relevant to you or of interest to you, on the basis of your provided data; and/or

(iv) other related functions or purposes mentioned in Section 2.

We and our authorized contractors may use cookies and similar technologies to provide and personalize the services, prevent fraud and for other purposes mentioned above. Please note you can disable cookies in your browser settings, while some parts of the QCPLAY services may then not function properly.

2. WHEN WE COLLECT AND PROCESS DATA

We will/may collect data from you:

(i) When you register and/or use our services, games or websites or open an account with us.

(ii) When you submit forms, including but not limited to application forms or other forms relating to any of our products and services, whether online or in physical form.

(iii) When you enter into an agreement or provide documents or other information in connection with your interaction with us or use of our products and services.

(iv) When you interact with us, for example, by telephone (which may be recorded), post, fax, face-to-face meetings, social media platforms and email, including when interacting with our customer service staff.

(v) When you use our electronic services or interact with us through games or websites or use our services. This includes but is not limited to, any cookies we may use when you interact with our games or websites.

(vi) You allow information to be shared with our applications, games or websites on your device.

(vii) If you associate your QCPLAY account with a social media account or other external account or use other social media accounts in accordance with the policies of the third-party application.

(viii) If you make transactions through our games or websites (as applicable) or third-party authorized payment services.

(ix) When you provide us with feedback or complaints.

(x) When you register for a particular competition, game or event; or

(xi) In the course of your gaming; and

(xii) If you provide us with your personal information for any reason.

3.WHY DO WE COLLECT YOUR PERSONAL DATA

To make the services compliant with local regulatory requirements.

To fulfill legal processes or to comply with applicable law and the requirements of competent national authorities or the requirements of any jurisdiction.

To make the Service work.

To perform the contract, we process data necessary to

(i) Operate the Service

(ii) Verify and confirm payments

(iii) Send you Service-related communications

To make the Service more suitable for our players.

To provide a great Service to our players, we have a legitimate interest in collecting and process necessary data to:

(i)Develop and improve services, update player profiles, manage our relationship with you, customize your service experience, respond to your comments and questions, and provide player support

(ii)Provide QCPLAY offers to you in the service and other websites and services, as well as by email

(iii)Send you relevant information, such as updates, security alerts, and support messages

(iv)Understand how you interact with our services, personalize product experiences and content (including advertising and messaging campaigns), and provide discounts or personalized pricing in accordance with applicable laws

(v)Send you news and/or marketing communications (by email) based on your marketing preferences and choices, including information about QCPLAY or third-party products that we speculate you might be interested in

4.WHO MAY ACCESS YOUR PERSONAL DATA

In addition to QCPLAY and/or its affiliates, other parties may also access your personal data in the following situations. You acknowledge that you have foreseen and agreed to the occurrence of such disclosure when you provide your personal data.

(1)Competent Authorities

We may provide a certain portion of your personal data to judicial or administrative authorities as so requested. Besides, we may disclose a certain portion of your personal data within a strictly limited scope of recipients when we reasonably think it is necessary to protect us, our users or a portion of the public.

In addition to being required by applicable laws, we reserve the right to disclose your personal data in the cases if we, in our good faith, believe that disclosing such data is necessary to identify, contact, or bring legal action against you, if (a) you are violating any agreements between us, such as the Terms of Service and this Privacy Policy or otherwise damage us; (b) you are infringing third parties’ rights and interests (including but not limited to intellectual property rights); and/or (c) we believe that it is necessary to prevent fraud or other illegal activities.

(2)Third-Party Contractors

QCPLAY works with a number of (if any) social media contractors, advertising serving contractors, analyzing contractors, payment contractors, fraud-detection contractors and other third-party contractors on or through our services. We do not sell your personal data and only share non-personally identifiable, aggregated, and public data with third parties.

Besides, such contractors may use cookies, web beacons, and/or other tracking technologies to collect or receive data about you and might claim controller rights over your personal data. For example, users purchasing products or services will be required to provide additional data to third-party payment contractors. Such third-party payment contractors may collect, process, and retain your data to process payments and resolve subsequent payment disputes and inquiries.

Please be aware that we cannot control the activities of such third parties, and we cannot guarantee that they adhere to the same privacy policy as we do. Since those contractors may access your data as data controller and operate under their own privacy policies, we strongly encourage you to check their privacy policies on their official websites and learn more about their data processing practices.

List of third-parties:

Name of the SDKPurpose of personal data collecting and processingPrivacy policy
FacebookTo log in our services and share your game experiencehttps://www.facebook.com/about/privacy/previous
To gain game revenue
To place advertisement
GoogleTo log in our services and payhttps://policies.google.com/privacy
To place advertisement
To gain game revenue
AppleTo log in our services and payhttps://www.apple.com/legal/privacy/en-ww/
To log in our services
LINETo log in our serviceshttps://line.me/en/terms/policy/
AIHelpTo contact with our customer servicehttps://aihelp.net/privacypolicy/
AppsflyerTo distinguish usershttps://www.appsflyer.com/legal/privacy-policy/
TwitterTo log in our service and share your gaming experiencehttps://twitter.com/en/privacy
TikTokTo share your gaming experiencehttps://www.tiktok.com/legal/privacy-policy
InstagramTo share your gaming experiencehttps://help.instagram.com/519522125107875
ThinkingDataTo share game behaviorhttps://docs.thinkingdata.cn/ta-manual/latest/installation/installation_menu/privacy.html#children-s-privacy
ironSourceTo place advertisementhttps://developers.is.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/#step-1
FirebaseTo distinguish users and place advertisementhttps://firebase.google.com/policies/app-indexing#privacy_and_security
JPushTo push In-game messageshttps://www.jiguang.cn/license/privacy
UnityTo place advertisementhttps://unity.com/cn/legal/developer-privacy-policy
AdmobTo place advertisementhttps://policies.google.com/privacy?hl=zh&gl=CN
MetaTo place advertisementhttps://www.facebook.com/privacy/policy
LiftoffTo place advertisementhttps://www.facebook.com/privacy/policy

5.DATA RETENTION

The user data we collected above is stored in

1.United State of America

2.Singapore.

We will only store your information as long as necessary to fulfill the purposes for which the information is collected and processed or — where the applicable law provides for a longer storage and retention period — for the storage and retention period required by law. After that your Personal Data will be deleted, blocked or anonymized, as provided by applicable law.The above list of addresses where our servers are stored is subject to change according to the development of our business and the optimization of our services.

6.INTERNATIONAL DATA TRANSFERS

Our Service is global by nature and by accepting this Privacy Policy, you are aware and agree that your personal information may be transferred to, stored in, and processed by affiliated companies, subcontractors and/or QCPLAY partners, located in third countries/outside the country where you live or work. Different countries may have different data protection laws than your own country. We will take steps according to applicable laws and regulations in your country to ensure that your personal information is adequately protected within the data process location in accordance with this Privacy Policy and applicable laws.

7.SECURITY OF YOUR PERSONAL INFORMATION

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. Our group companies have information security and access policies that limit access to our systems and technology. We also protect data through the use of technological protection measures such as encryption. Your personal information will remain subject to our technical and organizational controls and our policies and procedures (including this Privacy Policy).

We have set up a dedicated department responsible for data security and a data protection officer (“DPO”) to contract [qcplay@hkqingcheng.com]. In the event of a data leakage or security breach, we will take timely measures to deal with such incidents and promptly notify you in an appropriate manner, including by means of messages or announcements.

We will endeavor to ensure that, by default, we only collect and process your data needed to provide Our Service. We also apply this principle to our data privacy and protection controls into our processing activities. This means that we will neither publish nor share your data by default.

Unfortunately, the internet is not completely secure. We will make every effort to protect your personal information to the maximum extent possible using the security solutions allowed by available technology and notify Users of a data breach pursuant to applicable laws. If you do not agree to these risks and conditions, you must discontinue your use of Our Service.

8.YOUR RIGHTS

According to the applicable laws and regulations in the country or region where you live or work, you may have a right to access, rectify, erase, object, or restrict processing for all your personal data processed by QCPLAY, as well as the right of data portability. Pertaining to the marketing or promotional communications, you may opt out of receiving such communications in accordance with the instructions therein, such as email provided to us. You can contact us supersnailofficial@gmail.com if you want to exercise any of these rights through our contact information.We will not conduct the above activities on minors.

8.1 Right of Consent.

By accepting and consenting to this privacy policy, you agree that we may collect, use and share your personal 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 not to provide you with access to our services.

If you are not deemed to be a full civil capacity person under the laws of where you reside, you undertake that you have the consent of your parent or legal guardian to register an account on the Game and use the Game services.

8.2 Right to Withdraw Consent.

You may withdraw the consent you gave us to collect, hold, use and/or disclose and/or delete your personal data by emailing [supersnailofficial@gmail.com]. We will process your request in accordance with this Privacy Policy and our obligations under applicable privacy laws. However, withdrawal of your consent and/or your request to delete your personal data held or controlled by us may mean that we will not be able to continue to provide our services to you, and we may have to terminate our relationship with you and/or the contract you have entered into with us.

8.3 Right of Access.

You have the right to access your Personal Data that we hold about you, i.e., the right to require (i) information whether your Personal Data is retained, (ii) access to and/or (iii) duplicates of the Personal Data retained. You can use the right to access your Personal Data through the Privacy Dashboard. If the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request.

8.4 Right to Rectification.

If we process your Personal Data, we shall endeavor to ensure by implementing suitable measures that your Personal Data is accurate and up-to-date for the purposes for which it was collected. If your Personal Data is inaccurate or incomplete, you can change the information you provided via the Privacy Dashboard.

You may request access to and/or rectification of your personal data that we currently hold or control by submitting a written request to us. We will need sufficient information from you to ascertain your identity and the nature of your request to process your request. Please express your request by emailing our officers at the following email address [supersnailofficial@gmail.com].

Where allowed by laws, we reserve the right to refuse certain requests and/or may also charge you a reasonable fee to process your request. In such cases, we will notify you and provide an estimated fee in writing via [supersnailofficial@gmail.com]. In accordance with applicable law, we will provide you with the requested personal data within a reasonable time after you have paid the reasonable fee.

8.5 Right to Erasure.

You have the right to obtain deletion of Personal Data concerning you if the reason why we could collect it (see section 3. above) does not exist anymore or if there is another legal ground for its deletion.

We will keep your data for as long as your account is active unless deletion is in accordance with your request.

In the case you request to remove or delete your personal data, we will retain your data as long as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and/or enforce the agreements between us. Please note that the removal or deletion of any of your data may result in the termination of some of our applicable services.

Due to technical limitations, we cannot delete only part of your personal information. If you exercise the right to delete, we will delete all your personal information under the account, which cannot be recovered. We will delete your personal information without undue delay within one month of receipt of the request. For details, see [8.9 Right to Cancel Your Account]

8.6 Right to Object

When our processing of your Personal Data is based on legitimate interests according to this Privacy Policy, you have the right to object to this processing.If you object, we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing as described in applicable laws; in particular if the data is necessary for the establishment, exercise or defense of legal claims. You also have the right to lodge a complaint with a supervisory authority.

8.7 Right to Restriction of Processing of Your Personal Data

You have the right to obtain restriction of processing of your Personal Data under the conditions set out in applicable laws.

8.8 Right to Personal Data Portability

You have the right to receive your Personal Data in a structured, commonly used and machine-readable format and have the right to transmit that data to another controller under the conditions set out in applicable laws. QCPLAY makes your Personal Data available in structured HTML format through the Privacy Dashboard as described above.

8.9 Right to Cancel Your Account

You can ask us to delete your Account, which is an irreversible process as you will not be able to access your Account upon deletion, and all data in relation to the Account will be deleted or de-identified, subject to any statutory retention requirements under applicable laws and regulations. If you want to delete your account, you can use the "[Delete account]" in-app setting to send a deletion notification, or send a Delete Email to the appropriate mailbox in "11.CONTACT AND COMPLAINTS" according to your region.

Due to the particularity of game products, the game account contains your game experience, game level, game virtual items, etc. In order to avoid malicious logout caused by the theft of your game account, we provide you with a way to cancel your account. If you meet and agree with the terms of the condition to cancel your account and the relevant laws and regulations.

AFTER YOUR ACCOUNT IS CANCELLED, WE WILL STOP PROVIDING YOU WITH ALL OR PART OF OUR SERVICES, AND WILL DELETE OR ANONYMIZE YOUR PERSONAL INFORMATION ACCORDING TO YOUR REQUEST, UNLESS OTHERWISE PROVIDED BY LAWS AND REGULATIONS. ONCE THE RELEVANT INFORMATION IS DELETED OR THE ACCOUNT IS CANCELLED, IT CANNOT BE RECOVERED, PLEASE OPERATE WITH CAUTION.

8.10 Right to Complain, Report and Sue.

You have the right to lodge a complaint, report or initiate legal proceedings in accordance with the applicable law. You also have the right to file a complaint with the supervisory organization.

8.11 Right to Compensation.

You have the right to claim compensation in case of violating laws and regulations on personal data protection unless otherwise provided for in this Privacy Policy or by the applicable law.

To exercise any of these rights, please contact us in writing. Otherwise provided by the applicable law, we will respond to such requests promptly. We may ask that you provide further information or complete a form in connection with a request. We will work with third parties to which we have transferred your personal information as appropriate to fulfill your request. We may not be able to fulfill requests that would interfere with the rights of others (e.g., where providing personal information would reveal information about another person) or our rights (e.g., where we have an independent basis for processing, or the information includes our trade secrets or intellectual property).

In the event of a failure of personal data protection, we will notify you or/and the Personal Data Protection institution in writing within the time required by the applicable law.

* If there are special provisions provided by applicable laws (including but not limited to PDPA, Electronic Information Law, etc.) and regulations in the country where you live or work, we will process your personal data in accordance with local applicable laws.

9. CHILD PRIVACY

9.1 The services are not intended for children. We do not knowingly collect or store any personal data from children; no part of our platform, games or other services is appropriate for them. Parents or guardians of children are encouraged not to allow children in their custody to submit personal information to us. Please also see the QCPLAY Terms of Use for more information.

9.2 If you (parents and guardians) disclose information about a child in your custody to us, you are hereby consenting to our processing of that child's personal data and accepting the terms of this Privacy Policy on behalf of that child. If you do not actually consent to our processing of personal data about a child in your custody, please contact us (SuperSnailOfficial@gmail.com) to delete the personal data relating to your child/children.

9.3 Children are defined as users under the age of 16, or in regions where the minimum age for processing personal information varies, such varying ages. In all cases, you should refer to the laws of your jurisdiction to ensure that you are over the minimum age required by the relevant law.

10. INTEREST-BASED ADVERTISING

We may share some of your information with certain third-party authorized contractors to make advertising more relevant, measure its effectiveness, and help identify your device for ad serving. As mentioned above, we or they may also use cookies or similar technologies to ensure you receive appropriate advertising and a personalized experience.

If you wish to opt out of using your online viewing behavior for interest-based advertising, you have the choice to opt out. Similarly, if you prefer not to have information about your mobile app usage utilized for interest-based advertising, you can also achieve this through the settings on your device. This may be represented as "Allow Apps to Request Tracking" on iOS, and "Opt Out of Ad Personalization" on Android. Please note that even if you disable personalized advertising, you may continue to receive ads that are not based on your preferences.

QCPLAY services may include links to other websites or advertisements for other websites. Other websites may also refer to, promote, or link to QCPLAY. Please understand that we do not control these websites and are not responsible for the privacy practices or content of such other sites. To protect your privacy, we recommend that you review the applicable privacy policy of any website you access through the QCPLAY services.

11.CONTACT AND COMPLAINTS

If you have questions or wish to make a complaint about how we process your personal information, please contact us and we will endeavor to deal with your request as soon as possible.

Email address: supersnailofficial@gmail.com

12. CHANGES

If we make any material changes to this policy, we will post the updated policy here and notify our users.

If you cease to agree with the amended Privacy Policy, you may stop using or accessing QCPLAY services by unsubscribing or ceasing your use of the QCPLAY services at any time.

Your use of the Services after QCPLAY changed this Privacy Policy shall signify that you agree with these changes unless there are significant changes regarding your rights, in which case we will notify you in advance and acquire your consent. If you do not accept changes made to this Privacy Policy, please refrain from using the Services.



SUPPLEMENTAL JURISDICTION-SPECIFIC TERMS



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

If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our privacy policy above.

Argentina


Your rights

If you are dissatisfied with our response to your request for access to, correction, or erasure of your personal information or your privacy complaint in respect of your personal information, you may contact the Agency for Access to Public Information at: supersnailofficial@gmail.com


Data transfers

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, by providing us your personal information and by using the Game Services, you consent to the transfer of your personal information to a jurisdiction where privacy laws may not offer the same level of protection as the laws that may apply in Argentina.

Australia


Overseas Recipients

We take reasonable steps to ensure that third party recipients of your personal information located outside Australia handle your personal information in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third-party recipients.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at supersnailofficial@gmail.com

Correction

You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your Game account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at supersnailofficial@gmail.com

Children

If you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game.

Transacting Anonymously

Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the Game Services. You acknowledge that if you do not provide us with your personal information, we may be unable to provide you with access to certain features or sections of the Game Services, including social media integration and in-Game purchases.

Data Transfers

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third-party recipients and so cannot guarantee that they will comply with those privacy laws.

Brazil


Exercise of data protection rights

Brazilian law provides certain rights to individuals with regard to their personal data. Thus, we seek to ensure transparency and access controls in order to allow users to benefit from the mentioned rights.

We will respond and/or fulfill your requests for the exercise of your rights below, according to the applicable law and when applicable, to the Brazilian General Data Protection Law - LGPD:

a)confirmation of whether your data are being processed;

b)access to your data;

c)correction of incomplete, inaccurate or outdated data;

d)anonymization, blocking or erasure of data;

e)portability of personal data to a third party;

f)object to the processing of personal data;

g)information of public and private entities with which we shared data;

h)information about the possibility to refuse providing personal data and the respective consequences, when applicable;

i)withdrawal of your consent.

j)request a review of decisions made solely based on automated processing of personal data affecting your interests, including decisions made to define your personal, professional, consumer or credit profile, or aspects of your personality.

We encourage you to contact us if you are not satisfied with how we have responded to any of your rights requests. You also have the right to lodge a complaint with the Brazilian Data Protection Authority (ANPD).

Verifying your identity

For your safety and to allow us to make sure that we do not disclose any of your personal data to unauthorized third parties, in order to verify your identity and guarantee the adequate exercise of your rights, we may request specific information and/or documents from you before we can properly respond to a request received concerning your data. All data and documents received from you in the process of responding to your requests will be used for the strict purposes of analyzing your request, authenticating your identity, and finally responding to your request.

International Transfers

International data transfers are necessary for us to provide our services. If you are located in Brazil, we will always rely on one of the international data transfer mechanisms under applicable data protection laws and regulations.

Limitations to your rights

In certain situations, we may have legitimate reasons not to comply with some of your requests. For instance, we may choose not to disclose certain information to you when a disclosure could adversely impact our business whenever there is a risk of violation to our trade secrets or intellectual property rights. In addition, we may refrain from complying with a request for erasure when the maintenance of your data is required for complying with legal or regulatory obligations or when such maintenance is required to protect our rights and interests in case a dispute arises. Whenever this is the case and we are unable to comply with a request you make, we will let you know the reasons why we cannot fulfill your request. You can contact us at [SupersnailOfficial@gmail.com].

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 may collect and disclose the following categories of personal information from or about you or your device:

  • Identifiers, such as your name as it appears on your social media profile, open ID / user ID, player/team UID, IP address, device ID, device token, phone number, mailing address, email address, nickname or a related advertising ID and device information. If you participated in one of our game-based events and won any physical prize, we processed your name (as shown on your passport), email address, telephone number, mailing address and postal code. If you registered for one of our tournaments, we processed your name, email address, country/region and player UID. If you registered for an e-sports event, we collected your team’s name, registration region, team logo, your name, nationality or residency, email address, Discord ID (if applicable) and character ID. If you qualified to attend in person an esports event, we also collected your ID or passport information, date of birth, gender, home address, phone number, photo and social media profile. If you have received bans for cheating or otherwise violating tournament or esports event rules, we collect your name and date of birth. For data subject requests, we collected your alias, email address, screenshot of Game avatar, account ID, and if applicable, name of requester, email address of requestor, proof of requestor's identity and proof of user's identity. This information is collected directly from you and your device, from social media platforms if you choose to sign up using a social media account and, if applicable, the data subject request requestor on your behalf.
  • Internet or other electronic network activity information, such as your information regarding your use of the Game Services, including level, score, date and time stamps of actions, and log-in and clickstream data. If you have poor network connection, we collected your IP address and network speed. This information is collected directly from you and your device.
  • Commercial information about any transactions and refund requests in the Game or via a third party such as what products were purchased, how much they cost and if they were used. This information is collected directly from you and your device and the Google Play or Apple iOS store or the third party where you made the purchase.
  • Geolocation data such as your region location when you set up your profile for the Game and your province and city if you choose to use region-specific features. This information is collected directly from you.
  • Audio and visual information such as your social media profile picture, avatar, photos shared in the Game, in-Game screenshots, replay videos, 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 Game services, including offering the Game, maintaining your account, providing customer service, providing region-specific features, generating highlights replay videos, processing payments and refunds, facilitating your sharing of screenshots on social network, and delivering audio and text messages;
  • To register you for and arrange esports events and tournaments;
  • To process surveys and administer sweepstakes;
  • To display battle replay videos of top players;
  • To verify eligibility for participation in our Beta test;
  • To send you your prize if you win any during one of our game-based events;
  • For data subject requests, to verify your identity, your rights and to process the requests;
  • To improve our services, including the functionality of the Game;
  • To monitor the success of our advertising and marketing programs;
  • To ensure the integrity of the Game, to protect users from prohibited conduct and to maintain a fair gaming environment within the Game;
  • 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 the chart in the main portion of the privacy policy.

We disclose personal information to the following types of entities:

  • Other companies within our corporate group who process your personal information in order to operate the Game Services.
  • Other companies that provide services on our behalf are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing their services to us.
  • Regulators, judicial authorities, law enforcement agencies and other third parties were reasonably necessary to comply with a legal obligation; enforce our terms and conditions; detect and prevent fraud or security issues; and to protect ours and others’ rights, property or safety.
  • 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:
    • othe categories of personal information about you that we collected;
    • othe categories of sources from which the personal information was collected;
    • othe purpose for collecting personal information about you;
    • othe 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
    • othe 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 fulfil 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 also exercise your rights, if any, regarding other data by contacting us at supersnailofficial@gmail.com.

Canada

Your Rights

Subject to limited exceptions under applicable law, you have the right to access, update, rectify and correct inaccuracies in your personal information and to withdraw your consent to our collection, use and disclosure of your personal information. To exercise these rights, you may contact us using the contact information set out below. We may require certain personal information for the purpose of verifying the identity of the individual making the request or that they are authorized to act on behalf of another individual in such matters.

Your Choices

For more information about managing your account and privacy settings, please visit Privacy Settings in Settings.
Internal Policies and Access Controls. We implement and maintain internal policies and technical measures to restrict access to your personal information within our organization. Access to personal information within our organization is limited to employees who need the information to perform their job functions. For example, our customer support team may have access to certain types of information during our interactions with you, such as responding to complaints and inquiries. Similarly, our content moderators may access certain information to enforce our Terms of Service, Community Guidelines, and other conditions and policies.

Transfer Outside Your Jurisdiction

We and our service providers (including members, subsidiaries, or affiliates of our corporate group) may access, store and otherwise process personal information outside of Canada (and, for residents of Quebec, outside of Quebec). For information about how we or our service providers (including service providers outside Canada) process personal information, please contact us using the contact information set out below. We and our service providers may disclose your personal information if we are required or permitted by applicable law or legal process, which may include lawful access by foreign courts, law enforcement or other government authorities in the jurisdictions in which we or our service providers operate.

You can contact us at supersnailofficial@gmail.com.

Colombia

Language

This Privacy Policy is provided in Spanish for users located in Colombia. In case of dispute, the Spanish version of this Privacy Policy shall prevail.

How We Use Your Personal Information

From the entry into force of this Privacy Policy, at the time of the collection of your personal data, we will request your prior authorization, by informing you about the specific purposes of the processing of your personal data for which such consent is obtained under the Privacy Policy.

Your authorization may be expressed (i) by writing, (ii) orally or (iii) through unequivocal conducts that allow us to reasonably conclude that your authorization was granted, such as the act of accepting the Privacy Policy. We may keep evidence of said authorizations, while respecting the principles of confidentiality and privacy of information.

Your Rights

As a data subject you have certain rights, including (i) to access, update and rectify your personal data; (ii) to request a copy of the consent you have given us; (iii) to be informed about how we have processed your personal data; (iv) to file claims before your country’s data protection authority; (v) to revoke the consent you have given us to process your personal data, unless the processing is based on compelling legitimate grounds or is needed for legal reasons; (vi) to ask for the suppression of your personal data (right to erasure); and (vii) to freely access your information.

You can contact us supersnailofficial@gmail.com if you want to exercise any of these rights through our contact information of this Privacy Policy. 

Proceedings For Exercise of Your Rights

Queries (rights to access): You can file queries regarding the processing of your personal data by us.

Claims (right to correction and erasure): You have the right to file claims in relation to the processing of your personal data by clearly describing the facts that give rise to your claim.

EU/UK

IF YOU ARE EU or UK RESIDENTS, you have the right:

a)To request access to or a copy of any personal data which we hold about you;

b)To rectification of your personal data, if you consider that the information we are holding is inaccurate;

c)To ask us to delete your personal data, if you consider that we do not have the right to hold it;

d)To withdraw consent to our processing of your personal data (to the extent such processing is based on previously obtained consent);

e)To ask us to stop or start sending you marketing messages as described below in the marketing section;

f)To restrict processing of your personal data;

g)To data portability (moving some of your personal data elsewhere) in certain circumstances;

h)To object to your personal data being processed in certain circumstances; and

i)To not be subject to a decision based on automated processing and to have safeguards put in place if you are being profiled based on your personal data.

Any request from you for access to or a copy of your personal data must be in writing and we will endeavour to respond as soon as we can after verify your identity in compliance with data protection legislation. We will comply with our legal obligations as regards your rights as a data subject.

For EU, UK residents, we shall provide information on action taken on a request under GDPR Articles 15 to 22 to the you without undue delay and in any event within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We will inform you of any such extension within one month of receipt of the request, together with the reasons for the delay. If for legitimate reasons, we cannot provide you with the information you need, we shall inform you without delay and at the latest within one month of receipt of the request of the reasons for not taking action.

By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for 6 tax years plus current tax year after they cease being customers for tax purposes.

When your information is transferred outside of your country of residence, our partners will use adequate safeguards, which may amongst others include EU-approved standard contractual clauses, which are available on the EU Commission website. (https://commission.europa.eu/law/law-topic/data-protection_fr).

the information of our DPO is as followed. If you are unsatisfied with how your request is being handled. To get in touch with him or her for any information concerning our processing of Personal Information, please contact our EU DPO:

Email:[qcplay@hkqingcheng.com]

Address: [RM 604, 6/F EASEY COMM BLDG, NOS 253-261 HENNESSY RD, WANCHAI, HONG KONG]

If you have any concerns about our use of your information, you may also have the right to make a complaint to the Data Protection Authority in your country according to applicable laws. You can refer to this page for more information:

https://ec.europa.eu/info/law/law-topic/data-protection/reform/what-are-data-protection-authorities-dpas_en

You can contact us at [supersnailofficial@gmail.com].

France

Your Rights

Instructions for the processing of your personal data after your death

You have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal data after your death.

The specific instructions are only valid for the processing activities mentioned therein and the processing of these instructions is subject to your specific consent.

You may amend or revoke your instructions at any time.

You may designate a person responsible for the implementation of your instructions. This person will be informed of your instructions in the event of your death, and be entitled to request their implementation from us. In the absence of designation or, unless otherwise provided for, in the event of the death of the designated person, their heirs will have the right to be informed of your instructions and to request their implementation from us.

When you wish to make such instructions, please contact us at supersnailofficial@gmail.com.

New Zealand

This section applies to users located in New Zealand:

Overseas Recipients

We take reasonable steps to ensure that third party recipients of your personal information located outside New Zealand handle your personal information in a manner that is consistent with New Zealand privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third-party recipients.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at supersnailofficial@gmail.com

Correction

You have the right to request the correction of any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at supersnailofficial@gmail.com.

Children

If you are under the age of 16, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game Services.

Your Rights

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the New Zealand Privacy Commissioner (www.privacy.org.nz).

Data Transfers

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third-party recipients and so cannot guarantee that they will comply with those privacy laws.





ACCOUNT CANCELLATION AGREEMENT


[update]2024/06/12


Before you officially start the next account cancellation process, please read, fully understand and agree to this Agreement (hereinafter referred to as "this Agreement"), especially the bold terms. When you click the next step, it is deemed that you have agreed to and abide by the entire content of this agreement.

YOU SHALL HAVE THE CIVIL CAPACITY REQUIRED BY YOUR ISSUING REGION OR YOUR ISSUING REGION IN ACCORDANCE WITH THE CONDUCT OF YOUR SIGNING THIS AGREEMENT. IF YOU DO NOT HAVE THE APPROPRIATE CAPACITY FOR CIVIL CONDUCT, PLEASE READ AND ACT ACCORDINGLY IN THE COMPANY OF YOUR GUARDIAN, AND MAKE SURE THAT THE GUARDIAN AGREES WITH ALL YOUR ACTIONS. IN THIS CASE, YOU AND YOUR GUARDIAN SHALL BEAR ANY AND ALL CONSEQUENCES ARISING THEREFROM IN ACCORDANCE WITH THE RELEVANT PROVISIONS OF THE LAW.

In order to ensure the smooth completion of the logout, please do not use this account to log in to the products and services associated with the account during the processing of the account cancellation application stipulated in this agreement, otherwise you will be deemed to have revoked the account logout.

1. Consequences of Cancellation of the Account

You understand and agree that any and all consequences that may arise after the cancellation of your account will be borne by you, including but not limited to:

1.1. AFTER THE ACCOUNT IS CANCELLED, YOU WILL NO LONGER BE ABLE TO LOG IN/USE ANY PRODUCTS AND SERVICES ASSOCIATED WITH THIS ACCOUNT, NOR RETRIEVE ANY CONTENT AND INFORMATION ADDED OR BOUND THROUGH THIS ACCOUNT, AND YOU WILL NO LONGER BE ABLE TO REGISTER WITH THE SAME REGISTRATION INFORMATION (MOBILE PHONE NUMBER, THIRD-PARTY ACCOUNT, ETC.) WITHIN 15 DAYS AFTER THE ACCOUNT IS CANCELLED. 15 DAYS LATER AFTER YOUR ACCOUNT IS CANCELLED, IT CANNOT BE RECOVERED. EVEN IF YOU APPLY FOR REGISTRATION WITH THE SAME REGISTRATION INFORMATION (MOBILE PHONE NUMBER, THIRD-PARTY ACCOUNT, ETC.), THE ACCOUNT AT THIS TIME WILL BE DEEMED AS A NEW REGISTRATION BY DEFAULT. we kindly remind you to back up the content and information that need to be backed up before applying for cancellation.

1.2. Except as otherwise provided by laws and regulations of your country/region or this Agreement, after the account is canceled, all content, information, data and records under all products and services you log in and use through the account will be deleted or anonymized. You will not be able to retrieve the above-mentioned content, information, data and records, nor will you have the right to ask us to do so. Such content, information, data or records include but are not limited to: (1) your personal information under the account, including mobile phone number, password protection and other personal information; (2) the company's related products / services you have used under this account, including but not limited to game characters, virtual props, avatars, nicknames, achievements, recharge and consumption records, geographic location, chat records, etc.; and (3) all other contents, information, data and records under the account.

1.3. Please be aware that if the account is canceled, all income / rights and interests under the account will be cleared, except as otherwise provided by laws and regulations of your country/region. Accordingly, we would like to remind you that before you cancel this account, please properly deal with your game revenue or make sure that the relevant game revenue has been settled. Once you cancel this account, if there is still game revenue under this account (including the game revenue generated during the use of this game and possibly generated in the future), you are deemed to have voluntarily waived the game income / rights and interests, and we have the right to remove all game revenue / rights under this account, and any and all consequences arising therefrom shall be borne by you.

You understand and agree to waive the income / rights generated but not yet consumed during the use of the relevant products and services under this account and the expected benefits / rights that may be generated in the future by canceling your account, you agree that we will not be required to restore or compensate for such benefits / rights, including but not limited to:

(1)game membership rights and interests, grades. All data related to the growth and upgrading of game characters (including, but not limited to, experience, honor, reputation, titles, etc.);

(2)virtual items such as virtual currencies and virtual props that have not yet been used in online games (such as card coupons, gold coins, diamonds, props, etc.)

(3)purchased services that have not yet expired;

(4)revenue from other games that have been generated but not consumed or expected game revenue in the future, etc.;

(5)future income / rights and interests of your published content under this account; and

(6)any other rights and interests that have been generated but not yet consumed under this account or expected benefits that may arise in the future.

1.4. Upon cancellation of this account, the user agreement you signed with us relating to the game will be terminated (except for those that have been agreed to continue to take effect). However, the termination of these agreements does not affect your liability for using the game service before the account is canceled. You are still responsible for the use of this game service before the cancellation of your account, including, but not limited to, liability for breach of contract, liability for damages and performance obligations.

1.5. Other (possible) consequences arising from account cancellation.

2.Requirements for cancellation.

Before you apply / continue to apply for cancellation from us, in order to protect your account security and related rights and interests, you need to check and ensure and promise that the account you apply for cancellation has met the following conditions at the same time, including, but not limited to:

2.1. The account is legally owned and logged in by you, and complies with the user agreement and the relevant rules and regulations on the account.

2.2. The account is in a safe state:

(1)the account is in normal use and is not in the period of illegal handling (meaning that the account is blocked and other measures taken for violating game-related agreements and rules). And there is no risk of being stolen or blocked;

(2)there are no outstanding complaints or reports during the period of applying for cancellation;

(3)the account is not illegally checked or restricted during the period of applying for cancellation; and

(4)the account has no abnormal login record and no other security risks within 30 days prior to the date of account cancellation.

2.3. There are no assets (or negative equity) in the account, and the game income has been settled or properly disposed of, including but not limited to coupons, diamonds, gold coins, props, experience cards, members' rights and interests and other game income. Please handle your game revenue properly.

2.4. There are no outstanding orders in this account:including, but not limited to, orders related to virtual currencies, virtual props and peripheral goods of online games based on this account. If the account has enabled the "Auto Renewal / Auto subscription" function,PLEASE MAKE SURE THAT YOU HAVE CANCELED THE "AUTO RENEWAL / AUTOMATIC SUBSCRIPTION".

2.5. There are no unresolved disputes in the account and its contents, including but not limited to complaints and reports, investigation by issuing local authorities, arbitration, litigation and other disputes.

2.6. Other conditions that should be met.

You can try to solve the above problems by yourself. If you can't handle it or have any doubts during the process, you can contact our company's customer service for assistance.

Southeast Asia: feedback.global.play@gmail.com

North America, European, UK: supersnailofficial@gmail.com

3. How to cancel the account

3.1. You are required to log out on the relevant function settings page in the game in accordance with our official logout procedures and operating guidelines.

3.2. You have agreed to all the contents of this Agreement; at the same time, you have checked and confirmed that all the conditions necessary for cancellation under Article 2 of this Agreement have been met.

3.3. After you have completed paragraph 2 of Article 3 above, in order to further protect your relevant legitimate rights and interests, we have the right to verify whether you meet some or all of the cancellation conditions stipulated in Article 2 of this Agreement as appropriate. In order to protect your account security and property rights and interests, we have the right to authenticate the cancellation application to determine that you are the authorized user of the account. If, after a comprehensive judgment, we find that the account does not meet the requirements for cancellation, or if the authentication fails, your logout may fail, you can follow our guidelines or contact customer service for assistance. Even if we judge that you meet the conditions for cancellation, it is based on your promise (that is, your own commitment to ensure that your account meets the above conditions for cancellation). It is still your own responsibility to ensure that your account meets the above conditions for cancellation, and we do not bear the corresponding legal liability.

4. Miscellaneous

4.1. This Agreement is an integral part of TERMS OF USE and applies to all products and services of QCPLAY. Matters not covered in this Agreement shall apply to the TERMS OF USE. At the same time, you acknowledge and agree that even if your account of the game is canceled, it will not reduce or relieve you of your (possible) liability under relevant laws and regulations, relevant agreements, rules, etc.

4.2. If there are any problems you can't handle during the account cancellation process or if you have any doubts about the process, please feel free to contact our customer service for assistance

Email address: supersnailofficial@gmail.com