Updated Date：December 11, 2023

INTRODUCTION

This privacy policy informs you of your choices and our practices regarding any personal information you provide. Your use of the video game, application, software, their associated upgrades, patches, and the updates of related services (the “Game”) and any other product, online service or website (individually and collectively “QCPLAY Services") distributed by QCPLAY Group or any of its subsidiaries and affiliates (collectively, “QCPLAY”, “we”, or “us”) involves the collection and use of your personal information. You need to understand how this happens and how you may control it.

QCPLAY’S GAME PRODUCTS AND SERVICES ARE TYPICALLY RENDERED EXCLUSIVELY TO INDIVIDUALS WHO HAVE ATTAINED THE STATUTORY AGE OF MAJORITY AND POSSESS UNFETTERED LEGAL CAPACITY TO CONDUCT CIVIL MATTERS (GENERALLY 18 YEARS OLD) OR OTHERWISE SPECIFIED BY THE LAWS AND REGULATIONS OF YOUR COUNTRY OR REGION OF RESIDENCE. IN THE EVENT THAT BOTH THE LEGAL GUARDIAN AND THE WARD PROVIDE THEIR JOINT CONSENT, WE ARE ALSO ABLE TO OFFER SERVICES TO MINORS WITHIN THE LEGALLY PERMISSIBLE RANGE AS STIPULATED BY THE APPLICABLE LAWS IN THE USER’S JURISDICTION. WE WILL NOT KNOWINGLY COLLECT PERSONAL DATA FROM MINORS BELOW THE AGE AS PERMITTED BY THE LAWS AND REGULATIONS OF THE USER’S COUNTRY OR REGION. 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 NEVER TO GIVE OUT PERSONAL INFORMATION WHEN ONLINE.

You acknowledge and agree that the normal use of the game and services relies on the collection, use, and management of personal data. Therefore, prior to using QCPLAY’s products and services, you have confirmed that you do not fall under the category of minors whose personal information collection is prohibited by the laws and regulations of your country or region. If you have a legal guardian, you confirm that the aforementioned terms have been consented to by your legal guardian, who has provided you with full disclosure. You also agree to these terms.

In the event of a merger, acquisition, reorganization, bankruptcy or other similar events, we will announce 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 Transfer 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 significant clause changes are involved, we will announce them in advance.

1.WHEN WE COLLECT AND PROCESS DATA

We will/may collect data from you:

The above is not exhaustive and only lists typical circumstances in which your personal data may be collected.

2. WHAT DATA WE COLLECT AND PROCESS

3. WHY DO WE COLLECT YOUR PERSONAL DATA

To make the Services compliant with local regulatory requirements

(i) to fulfil 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 the data necessary to

To make the Service more suitable for our players

To provide an excellent Service to our players, we have a legitimate interest to collect and process necessary data to

4. WHO MAY ACCESS YOUR PERSONAL DATA

In addition to QCPLAY and/or its affiliates, other parties may 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

As requested, we may provide some of your personal data to judicial or administrative authorities. Besides, we may disclose a specific 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 be 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 Use 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 several (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 controllers 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：

5. DATA RETENTION

We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or — where the applicable law provides for a more extended 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 applicable law provides.

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 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 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 will take appropriate technical and organizational measures to help protect and secure your data. We will endeavor to protect your data against unauthorized or unlawful processing, accidental loss, destruction, or damage through these measures, including:

(i)using encryption techniques;

(ii)establishing specialized systems and procedures and requiring those who have such access to comply with relevant confidentiality obligations; and

(iii)forming a specialized department in charge of data security. In the event of incidents such as data leakage or data or security breach, we will take timely measures to handle such incidents, and we will notify you promptly in an appropriate manner, including through messages or announcements;

(iv) Appointing a Data Protection Officer to to ensure that any personal data we collect from you is handled properly and kept secure. If you would like to contact our Data Protection Officer, please send an email at feedback.global.play@gmail.com.

Unfortunately, the internet is not completely secure. Although we will do our best to protect your personal information, any such transmission of your information is at your own risk. We will try 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 under applicable laws.

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 and 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 the email provided to us.

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 [feedback.global.play@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 free of charge (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 User Center or contacting Customer Service. 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 (considering 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 endeavour 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 User Center or contacting Customer Service.

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 [feedback.global.play@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 [feedback.global.play@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.

If 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 removing or deleting any of your data may result in terminating 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

Unless otherwise provided by the applicable law, you have the right to object to processing your personal data by personal data controllers and personal data processors to prevent or limit the disclosure or use of personal data for advertising and marketing purposes. If you object, we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing described in applicable laws, particularly if the data is necessary to establish, exercise, or defend legal claims. You also have the right to complain to 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 User Center or contacting Customer Service as described above.

8.9 Right to Cancel Your Account

Due to the particularity of game products, the game account contains your game experience, game level, game virtual goods, etc. 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 organisation.

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 get in touch with us. Otherwise provided by the applicable law, we will respond to such requests promptly. Please 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 fulfil your request. We may not be able to fulfil 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 special provisions are provided by applicable laws (including but not limited to Personal Data Protection Act, Electronic Information Law, etc.) and regulations in the country where you live or work, we will process your personal data per locally 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 to delete the personal data relating to your child/children.

10. 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 endeavour to deal with your request as soon as possible. Subject to applicable law, we will respond to your request within the period of time required by applicable law from receipt of your request.

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

11. Changes

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

If you fail to explicitly express your objection to any amended version of this privacy policy within seven (7) days of the date the relevant amended version is made available, you will be considered as having accepted the changes and agreed to the new Privacy Policy. However, 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 this case, we will notify you in advance and acquire your consent. If you do not accept changes to this Privacy Policy, please refrain from using QCPLAY Services.

[update]December 11, 2023

Before officially starting the following 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.

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 consequences that may arise after the cancellation of your account will be borne by you, including but not limited to:

2.Requirements for cancellation

Before you apply/continue to apply for cancellation from us, 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:

3. How to cancel the account

4. Miscellaneous