1.4 The term “personal data” means, in accordance with the PDPA, data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access.
1.7 IF YOU DO NOT CONSENT TO OUR COLLECTION, USE, DISCLOSURE AND PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED HEREIN, PLEASE DO NOT ACCESS OR USE OUR SERVICES.
2. PERSONAL DATA WE COLLECT
2.1 The personal data we collect includes, but is not limited to:
2.1.1 personal information including names, date of birth and gender;
2.1.2 contact information including email addresses, residential addresses and phone numbers;
2.1.3 payment information including billing addresses, bank account information and payment information;
2.1.4 information in relation to our Services including passwords, avatars, nicknames, comments and how users use our Services;
2.1.5 information sent by or associated with the device(s) used to access our Services including hardware models, operating system version numbers, International Mobile Equipment Identity (IMEI), unique device identifiers, network device hardware addresses (MAC), IP addresses, software version numbers, network access methods and types and operation logs;
2.1.6 personal information provided to us by the users of our Services;
2.1.7 personal information required to be collected in accordance with the relevant laws and regulations; and
2.1.8 aggregate data on content users engage with.
2.2 The situations in which we may collect your personal data, including the personal data listed in Clause 2.1 above, includes, but is not limited to:
2.2.1 when you register and create accounts for our Games and related services;
2.2.2 when you provide identity verification documentations;
2.2.3 when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our Services or products;
2.2.4 when you interact with us, such as via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails;
2.2.5 when you use our electronic services or interact with us via our Services, including, without limitation, through cookies which we may deploy when you interact with our Services;
2.2.6 when you carry out any transactions through our Services;
2.2.7 when you provide us with feedback;
2.2.8 when you register for our contests, games or other events;
2.2.9 when playing our Games or using our Services in general; and
2.2.10 when you submit your personal data to us for any reason.
2.3 The above does not purport to be exhaustive and sets out some common types of personal data collected and instances of when your personal data may be collected.
2.4 You agree not to submit information which is inaccurate or misleading, and you agree to inform us of any inaccuracies or changes to such information accordingly. We reserve the right, at our sole discretion, to require from you further documentation to verify the information provided by you.
2.6 If you do not want us to collect the aforementioned information or personal data, you may opt out at any time by notifying our Data Protection Officer in accordance with Clause 13 below. Note, however, that opting out or withdrawing your consent for us to collect, use or process your personal data may affect your use and access of the Services.
3. COLLECTION OF OTHER DATA
3.1 As with most websites and mobile applications, your device sends information which may include data about you that gets logged by a web server when you use our Services. This typically includes without limitation your device’s Internet Protocol (IP) address, computer/mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, the address of a referring web site (if any), the pages you visit on our website and mobile applications and the times of visit, and sometimes a “cookie” (which can be disabled using your browser preferences) to help the site remember your last visit. If you are logged in, this information is associated with your personal account. The information is also included in anonymous statistics to allow us to understand how visitors use our Services.
4.1 We may from time to time implement “cookies” or other features to allow us or third parties to collect or share information that will help us improve our Services or help us offer new services and features. Cookies are identifiers we transfer to your computer or mobile device that allow us to recognize your computer or device and tell us how and when our Services are used or visited, by how many people and to track activity within our Services. We may link cookie information to your personal data. Cookies also link to information regarding items you have selected for purchase, pages you have viewed, and games you have played. Cookies are also used to deliver content specific to your interest and to monitor usage of the Services.
5. USE OF INFORMATION
5.1 We may collect, use, disclose, store and/or process your personal data for, but not limited to, the following purposes (the “Purposes”):
5.1.1 to consider and/or process your applications or transactions with us or your transactions or communications with third parties via the Services;
5.1.2 to allow you to complete the registration of your account for our Services as well as to log into such account and access our Services;
5.1.3 to manage, operate, provide and/or administer your use of and/or access to our Services (including, without limitation, your preferences), as well as your relationship and user account with us;
5.1.4 to respond to, process, deal with or complete a transaction and/or to fulfil your requests for certain products and services and notify you of service issues and unusual account actions;
5.1.5 to enforce our Terms of Service or any applicable end user license agreements;
5.1.6 to protect personal safety and the rights, property or safety of others and ourselves;
5.1.7 for identification and/or verification;
5.1.8 to enable you to use interactive features on our Services including, but not limited to, using voice and video to interact with other users of our Services;
5.1.9 to maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Services;
5.1.10 to deal with or facilitate customer service, carry out your instructions, deal with or respond to any enquiries given by (or purported to be given by) you or on your behalf;
5.1.11 to contact you or communicate with you via voice call, text message and/or fax message, email and/or postal mail or otherwise for the purposes of administering and/or managing your relationship with us or your use of our Services, such as but not limited to communicating and administrative information to you relating to our Services. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
5.1.12 to allow other users to interact or connect with you, including to inform you when another user has sent you a private message or posted a comment for you on our Services;
5.1.13 to conduct research, analysis and development activities (including, but not limited to, data analytics, surveys, product and service development and/or profiling), to analyse how you use our Services, to improve our Services or products and/or to enhance your experience;
5.1.14 to protect your gaming account and to create a fair, healthy and safe gaming environment for the users of our Services;
5.1.15 to allow for advertising and other audits and surveys to, among other things, validate the size and composition of our target audience, and understand their experience with our Services;
5.1.16 for marketing and, in this regard, to send you by various modes of communication marketing and promotional information and materials relating to products and/or services (including, without limitation, products and/or services of third parties whom we may collaborate or tie up with) that we (and/or our affiliates or related corporations) may be selling, marketing or promoting, whether such products or services exist now or are created in the future. You can unsubscribe from receiving marketing information at any time by using the unsubscribe function within the electronic marketing material. We may use your contact information to send newsletters from us and from our related companies;
5.1.17 to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on us or our related corporations or affiliates;
5.1.18 to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
5.1.19 to carry out due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;
5.1.20 to audit our Services or business;
5.1.21 to prevent or investigate any actual or suspected violations of our Terms of Service, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us;
5.1.22 to store, host, back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside of your jurisdiction;
5.1.23 to deal with and/or facilitate a business asset transaction or a potential business asset transaction, where such transaction involves us as a participant or involves only our related corporation or affiliate as a participant or involves us and/or any one or more of our related corporations or affiliates as participant(s), and there may be other third party organisations who are participants in such transaction. A “business asset transaction” refers to the purchase, sale, lease, merger, amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation;
5.1.24 any other purposes which we notify you of at the time of obtaining your consent; and/or
5.1.25 any other purposes that may be relevant or necessary to the provision of our Services to you.
5.3 As the purposes for which we may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted under the PDPA.
6. PROTECTION OF PERSONAL DATA
6.1 We take the security of your personal data very seriously and will endeavour to take reasonable security measures (both technical and administrative) to protect your personal data from misuse or unauthorised access, public disclosure, use, modification, damage, loss, or leak.
6.2 We will use reasonably practicable means to protect your personal data, such as using encryption technology and anonymisation, no less than that of our industry peers, and use security mechanisms to protect your personal information from malicious attacks.
6.3 We may establish a dedicated security department, security management system and data security procedures to protect your personal information. We adopt strict data usage and access systems to ensure that only authorised personnel have access to your personal information and conduct timely security audits of data and technology.
6.4 Although we may take reasonable and effective measures as described above and comply with the standards required by the relevant laws, please understand that due to technical limitations and the possibility of various malicious activities, it is not always possible to guarantee complete security of your personal in the Internet industry, even with all efforts to enhance security measures, and we will do our best to ensure the security of the personal data you provide to us. You are aware and understand that the systems and communication networks you use to access our services may have weaknesses due to factors outside of our control. Therefore, we strongly recommend that you take proactive measures to protect the security of your personal data, including but not limited to, using complex passwords, changing your password regularly, and not disclosing your personal data, such as your account password, to other parties.
7. RETENTION OF PERSONAL DATA
8. DISCLOSURE TO THIRD PARTIES
8.1 In conducting our business, we may disclose your personal data to third parties such as our service providers, agents and/or our affiliates or related corporations, and/or other third parties, whether situated in Singapore or outside of Singapore, for one or more of the Purposes and/or the purposes identified in Clause 8.2. Such third-party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the Purposes. Such third parties include, without limitation:
8.1.1 our subsidiaries, affiliates and related corporations;
8.1.2 other users of our Services;
8.1.3 contractors, agents, service providers and other third parties we use to support our business or our Services. These include but are not limited to those which provide administrative or other services to us such as mailing houses, telecommunication companies, information technology companies and data centres;
8.1.4 a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by us about our users is among the assets transferred; or to a counterparty in a business asset transaction that we or any of our affiliates or related corporations are involved in; and
8.1.5 third parties to whom disclosure by us is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes.
8.2 Some of the purposes, in addition to the Purposes, for disclosing personal data to third-parties may include, without limitation:
8.2.1 to ensure consistency in the services you receive between our Services and those of our affiliates, and to facilitate the consistent management of your information;
8.2.2 to enable programmatic ad delivery;
8.2.3 to help them increase the effectiveness of advertising without identifying you personally;
8.2.4 to fulfil our business with third parties for the purpose of aggregating statistics and analysing features and preferences through algorithms to form indirect demographic profiles that can be used to make recommendations to you, to display or deliver information that may be of interest to you, or to deliver specific features, services or commercials that are more suitable for you;
8.2.5 to ensure that you receive a consistent experience at joint events, or to engage third parties to redeem rewards to you in a timely manner.
8.3 This may require, among other things, disclosing your gaming history and/or disclosing records showing which games were viewed by which IP addresses. We will also share statistical and demographic information about our users and their use of the Services with suppliers of advertisements and programming.
8.4 Additionally, you may elect to export your user activity feeds as RSS feeds which may be subscribed to by other users, which may include information regarding your game play, installation of games, connections with other users and other information about your account activity which is published as a feed on our Services.
8.5 For the avoidance of doubt, in the event that the PDPA or other applicable laws permit us to collect, use or disclose your personal data without your consent, such permission granted by the laws shall continue to apply.
8.6 Third parties may unlawfully intercept or access personal data transmitted to or contained on our Services, technologies may malfunction or not work as anticipated, or someone might access, abuse or misuse information through no fault of ours. We will nevertheless deploy reasonable security arrangements to protect your personal data as required by the PDPA; however there can inevitably be no guarantee of absolute security such as but not limited to when unauthorised disclosure arises from malicious and sophisticated hacking by malcontents through no fault of ours.
9. INFORMATION ON CHILDREN
10. INFORMATION COLLECTED BY THIRD PARTIES
10.2 We, and third parties, may from time to time make software applications downloads available for your use on or through the Services. These applications may separately access, and allow a third party to view your personal data, such as your name, your user ID, your device’s IP address or other information such as what game you are playing during any given session, and any cookies that you may previously have installed or that were installed for you by a third party software application or website. Additionally, these applications may ask you to provide additional information directly to third parties. Third party products or services provided through these applications are not owned or controlled by us. You are encouraged to read the terms and privacy policies published by such third parties on their websites or otherwise.
11. DISCLAIMER REGARDING SECURITY AND THIRD-PARTY SITES
12. TRANSBORDER DATA FLOWS
12.1 In using our Services, you understand, acknowledge and consent to the transfer of your personal data out of Singapore where such transfer is necessary for the provision of access to our Services or any of the Purposes.
12.2 Where your personal data is transferred out of Singapore, we will take the appropriate steps to ensure that the standard of protection accorded to your personal data transferred abroad is comparable to the protection that is accorded to it under the PDPA.
13. WITHDRAWAL OF CONSENT, REQUEST OF ACCESS TO AND CORRECTION OF INFORMATION PROVIDED
13.2 You acknowledge that withdrawing your consent in accordance with Clause 13.1 above, may affect your user experience on our Services mean or even lead to the cessation of your use of our Services, especially where provision of access to our Services is reliant on the collection, use or disclosure of your personal data.
14. ACCESS RIGHTS AND CORRECTION OR UPDATE OF PERSONAL DATA
14.1 It is of utmost importance to use that your personal data is accurate and up to date. If any of the information that you have provided us has changed, please inform or update our DPO at email@example.com or if you have an account with us, you may personally correct your personal data currently in our possession or control through the Account Settings page or tab on the Site or our Games.
14.2 Subject to the exceptions referred to in Section 21(2) of the PDPA, you have the right to request from us information regarding your personal data in our possession or control and the manner in which your personal data had been used or disclosed within a year prior to the request.
14.3 We may charge you a reasonable fee for the handling and processing of your requests to access your personal data. If we so choose to charge, we will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.
15. DATA BREACH
15.1 In the event of a data breach in which the confidentiality of your personal data was compromised, we will notify you through the contact information provided by you, to the extent required by the PDPA.
16. CONTACT US
16.1 If you have any questions, concerns or complaints about our privacy practices, please contact our DPO at firstname.lastname@example.org.
17. GOVERNING LAW AND DISPUTE RESOLUTION