Privacy Policy

Updated Date: March 11, 2025
Effective Date: March 11, 2025

 

Introduction

Welcome to use the services provided by us. We deeply understand the importance of personal information. This policy will clearly explain how we collect, use, store, and protect your information. Please be sure to read the bold - faced terms carefully. Continuing to use this game means that you agree to all the contents of this policy.

 

Table of Contents

1. Scope of Application

2. How We Collect and Use Your Personal Information

3. Third - Party Services

4. Cookies and Similar Technologies

5. Information Sharing and Disclosure

6. Data Storage and Security

7. User Rights

8. Protection of Minors

9. Policy Updates

10. Contact Us

11. Specific Region - Specific Provisions

 

I. Scope of Application

Applicable Objects: All users who use the services or products provided by us.
Coverage: It includes, but is not limited to, the product itself, the official website, etc.

 

II. How We Collect and Use Your Personal Information

1. Information You Provide Actively

You can choose to directly enter the game. In this case, you can enter our game without registering an account and logging in.
You can also choose to quickly register and log in through third - party platforms such as Facebook, Line, WeChat, QQ, and Apple ID (hereinafter referred to as "third - party login"). This method can achieve cloud - based synchronous storage of account data. To ensure the security of your account, we may obtain the public information of your third - party account, such as avatar, nickname, account identification ID, and other information authorized by you. After completing the registration, you can complete basic information such as avatars and nicknames at any time (collectively referred to as "account information"). We will strictly protect the relevant personal information in accordance with the privacy policy. Special Note: Account information is optional, and your basic network activity functions will not be restricted due to incomplete information for the time being.

 

2. Information We Collect

During your use of the service, to ensure the normal operation of functions and the security of the operating environment, we may collect the following information after obtaining your authorization:

 

· Types of Information

· Device identification information: including advertising identifier IDFA, IDFV, MAC address;

· Network and logs: IP address, network status;

· Basic device information: device manufacturer name, device model, storage space size, device operating system type, operating system version, screen resolution;

· Other information: sensor information.

· Purposes of Information Collection
The main purposes of collecting the above - mentioned information are to ensure service stability and achieve data synchronization; prevent security risks such as cyber - attacks and phishing fraud; anonymously analyze user behavior to optimize the product experience; locate and fix abnormal problems such as app crashes or freezes; and verify and handle violations in accordance with the law to maintain the platform order.
Special Note: We will not actively collect any information when the product is in a silent state or running in the background.

 

3. Optional Permission Information (Requiring Explicit User Authorization)

· Camera permission: Only applied for when you actively trigger the shooting or video - recording function (if applicable);

· Photo album permission: Applied for when you need to upload local pictures or videos (if applicable);

· Notification permission: Used to push important reminders such as service updates and system maintenance;

· Advertising identifier IDFA permission: Used to ensure service security and optimize your service experience;

· Network permission: Used to detect the network operation status and ensure the normal operation of the service.
It should be noted that you can turn off the relevant permissions at any time through the device system settings (please refer to the device manufacturer's instructions or contact the vendor for specific operation methods), and you can also get assistance through the contact information we provide. It should be especially noted that turning off some permissions may limit the use of corresponding functions or services.
It should be emphasized that single - device information and other independent data usually cannot be directly associated with a specific individual identity. However, if such information is used to identify a specific individual identity or combined with your other personal information, during the period of data association and use, this information will be regarded as personal information in accordance with the law. Unless we obtain your explicit authorization or otherwise provided by law, we will anonymize or de - identify such information in compliance with relevant regulations.

 

4. Customer Service

If you have any questions, suggestions, or feedback regarding our products and services, personal information protection measures, or the privacy policy, please feel free to communicate with us through the contact information stated in this policy. To respond efficiently and handle your issues properly, we may need you to cooperate by providing the following necessary information: including but not limited to your account information, email address, contact number, device identifier (ID), system language settings, current application version number, and other related information that you voluntarily provide.

 

5. In - App Purchases

Our product provides the purchase services of virtual items or goods such as in - game props, ad - free features, and auto - renewal subscriptions, supporting in - app purchases. The payment transactions for in - app purchases are completed through your App Store account via the App Store. The payment process is directly handled by the App Store platform. We do not participate in the actual payment operation, nor do we store or obtain payment order information related to you. We will only obtain the payment - completed result information from Apple and then provide you with the in - app purchase items.

 

III. Third - Party Services

To ensure the normal operation of product functions and service optimization, we may integrate technical components (such as SDKs, APIs, etc.) provided by third - parties or achieve specific service scenarios through partners (such as advertising display, data statistics, social account login, etc.). It should be noted that the management of your personal information by such third - party service providers will follow their independently formulated privacy policies, not this policy.
We recommend that you carefully read the official privacy terms of third - party functions before using them. If you find any privacy risks in related services, please stop using them immediately and contact us through the customer service channel to jointly protect your legitimate rights and interests. You can refer to the "Third - Party Service Privacy Policy Links" attached at the end of this policy to learn in detail about the data collection rules and privacy protection mechanisms of each partner.

 

IV. Cookies and Similar Technologies

To optimize the service experience and ensure the operation of functions, we may use cookies and similar technologies to record your usage progress and obtain relevant service data. It should be noted that such technologies are only used for the purposes clearly stated in this policy and will not be used for any other purposes.
It should be reminded that some core functions rely on the above - mentioned technologies. You can disable or clear relevant technologies by adjusting privacy settings or accessing third - party technology service pages according to the support of your device or browser. However, please note that such operations may prevent you from using some related functions or services normally.

 

V. Information Sharing and Disclosure

Generally, we will not share or transfer the personal information you provide actively or that we collect to any third - party, nor will we collect your personal information on behalf of third - party service providers, except as required by laws and regulations.
It should be noted that according to relevant laws and regulations, when sharing or transferring personal information that has been anonymized and cannot be re - identified as a specific subject through technical means, such behavior does not fall within the category of external provision of personal information. In this case, we will process such data in accordance with technical desensitization standards and do not need to inform you separately or obtain additional authorization.

 

VI. Data Storage and Security

Storage Period

We will only retain your information for the shortest necessary period to achieve the goals described in this policy and ensure the normal operation of product functions and services. Unless required by laws and regulations to delete or you actively request deletion, we will store data in accordance with the above - mentioned period. If the product or service operation needs to be terminated for some reason, we and our affiliated third - party platforms will immediately stop the collection of personal information and delete or anonymize the collected information in accordance with the law (except for special circumstances required by laws, regulations, or regulatory authorities).

 

Cross - Border Transmission

We may store the collected personal information in countries or regions outside the country or region where our business is located. It should be noted that the legal protection standards in some regions may differ from those in your jurisdiction. However, we will always take necessary measures to ensure the security of data transmission. It should be emphasized that some countries/regions (such as EU member states) have developed strict data export regulatory frameworks with special compliance requirements for cross - border transmission. You can refer to the specific region - specific provisions section at the end of this policy for detailed information.

 

Security Measures

We always prioritize the protection of user personal information and privacy security. We deploy technical and management measures that comply with international standards (such as encrypted data storage and transmission, a reliable security protection system, etc.) to minimize the possibility of data leakage, tampering, abuse, or unauthorized access. It should be noted that due to the technical limitations of the Internet environment, no security system can guarantee 100% absolute security currently.

 

VII. User Rights

1. Right to Refuse Processing

You have the right to refuse our use of your personal information based on legitimate interests. You can send an email to us to terminate our subsequent collection of your personal information.

 

2. Right to Information and Access

You have the right to query the content of the personal information we hold. If you need to exercise this right, please contact us through the channels specified in this policy and clarify your requirements. We will provide the relevant information after verifying your identity (if it involves the personal information of others, we cannot provide it) and respond within one month after receiving the request or within the time limit required by law.

 

3. Right to Correction

We are committed to ensuring the accuracy of information. If you find that the information is incorrect, please submit a correction application to support@winlonpte.com, and we will handle it in a timely manner.

 

4. Right to Delete

You can request the deletion of the personal information we hold. After submitting a request to support@winlonpte.com, we will execute the deletion within one month (or as required by law) after completing the identity verification. However, data may be retained in the following situations: fulfilling legal obligations, maintaining legitimate rights and interests requires retention, or the data has been anonymized.

 

5. Right to Data Portability

In applicable scenarios, you have the right to obtain a copy of your personal information in a structured and common format and transfer it to another data controller. Please submit an application to support@winlonpte.com.

 

6. Right to Restrict Processing

Under specific circumstances, you can request to restrict the scope of use of your personal information.

 

7. Account Cancellation

For products with an account function, if you decide to terminate the use of our products or services, you can apply for account cancellation. We will respond within one month (or as required by law). To ensure operational security, necessary identity verification and account security confirmation are required before cancellation. Once the account is cancelled, it will take effect immediately. We will simultaneously terminate the processing of personal information and delete or anonymize the relevant data in accordance with laws and regulations (except for relevant legal retention requirements). It should be especially reminded that cancellation is an irreversible operation. The account and associated data will be permanently deleted and cannot be restored. Please confirm that you have properly handled all associated services and data before the operation.

 

8. Withdrawal of Consent to Personal Information

Within the scope required by relevant laws and regulations, you can contact us to withdraw the authorization and consent you provided to us for certain data processing activities. However, please note that we may not be able to continue to provide you with the expected services or functions as a result.

 

9. Right to Complaint

If you have any objections to data processing, you have the right to file a complaint with the regulatory authorities in your country/region. It is recommended that you first contact us (support@winlonpte.com) to file your complaint so that we can help you solve the problem as soon as possible.

 

10. Right to Non - Discrimination

Exercising privacy rights will not affect your rights and interests in enjoying services. We will not reduce the service quality or set differential treatment because of this.

 

11. Special Rights for California Residents

You have the right to refuse the sale or third - party sharing of your personal information. You can contact us (support@winlonpte.com) to exercise this right.

 

VIII. Protection of Minors

We strictly abide by the guidelines for protecting minors. In principle, we will not deliberately collect the personal information of users under 16 years old. If you are under 16 years old, please carefully read and confirm the content of this clause under the guidance and supervision of your parents or other legal guardians. Special Reminder: If you belong to the above - mentioned group of minors, please do not submit personal information such as your name, contact information, and address to us in any form without the explicit authorization of your guardians. If we accidentally find that we have retained the personal information of users under 16 years old, we will immediately initiate the deletion process. If you are aware that we may retain such information, please contact us through the official channels as soon as possible, and we will handle it properly in accordance with the law.

 

IX. Policy Updates

We may timely revise this privacy policy to continuously protect user rights and interests and respond to changes in laws, regulations, and the technical environment. When major changes such as data processing methods are involved, we will update them in a timely manner. Please regularly check the latest version of the policy. The updated terms will come into effect from the date of publication and serve as the basis for service implementation.

 

X. Contact Us

If you have any questions about the content of the privacy policy, your rights related to personal information, or if you want to file a complaint or need our customer service support, please contact us through the following email address.
Email: support@winlonpte.com

 

XI. Specific Region - Specific Provisions

1. Special Provisions for California Residents (Applicable to CCPA)

· Data Collection and Use
In the past 12 months, we have not sold/shared any user personal information, including the data of minors under 16 years old. In the past 12 months, we have also not collected the sensitive personal information of users.

· Your Rights

· Right of Access: You can apply to obtain details of data collection in the past 12 months (sources, purposes, recipients, etc.).

· Right of Correction and Deletion: You can request to correct inaccurate information or delete data (except for legal exceptions).

· Anti - Discrimination Protection: Exercising your rights will not affect the service quality.

· Restriction on Automated Decision - Making: You can refuse automated decision - making analysis based on data.

· Right to Refuse "Sale" or "Sharing": You can refuse the "sale" or "sharing" of your personal information through the specified channels.

· Response Mechanism: We will complete the processing of requests within 45 days after verifying your identity (which can be extended to 90 days). Authorized agents are supported to submit requests (written authorization certificates are required).

 

2. Special Notice for Residents of the European Economic Area, Switzerland, and the UK (Regions Applicable to GDPR)

In addition to the rights described in Section VII "User Rights" of this policy, residents in this region also enjoy:

 

· Feedback and Complaint
You have the right to object to our processing of personal data, including for marketing purposes based on analysis and/or automated decision - making. Within the scope permitted by the GDPR, we may still continue to process your information even if you disagree. You can also inform us of your questions, comments, or complaints through the contact information we provide.

· Transmission of Personal Information Outside the EU
If we transmit personal information outside the EU, we will adopt technical and physical security measures to protect your personal information and strictly comply with the requirements of relevant EU laws and regulations. If you have any questions about the personal information transmission mechanism related to your personal information, please contact us. We will only collect, use, or store your personal information in the following situations:

· Information you voluntarily and actively provide to us.

· To provide you with the services you request.

· To protect the vital interests of you or others.

 

3. Special Provisions for Virginia Residents (Applicable to VCDPA)

· Personal Rights
Exercise the rights of data access, deletion, and correction (except for legal exceptions); prohibit reducing the service quality due to exercising rights.

· Sensitive Personal Information
We have not collected sensitive personal information.

· Appeal Mechanism
If you are dissatisfied with our processing decision, you can file a reconsideration through the channels in the policy.

 

4. Special Provisions for Brazilian Residents (Applicable to LGPD)

In addition to the rights described in Section VII "User Rights" of this policy, residents in this region also enjoy:

 

· Protection of Minors
If you have not reached the legal age of adulthood (under 18 years old), you must obtain the explicit permission of your parents or legal guardians before using this service to ensure that they have read and agreed to the terms in this policy. We promise that without the necessary consent, we will not deliberately collect any information of minors. If you suspect that we may hold the personal information of minors without the above - mentioned consent, please contact us immediately, and we will immediately verify (and delete) such personal information.

· Cross - Border Transmission Statement
Accepting this privacy policy means that you agree to our collection, use, and processing of your personal information within the scope specified in this policy, including disclosing to third - parties and transferring outside Brazil when necessary.

 

Appendix: Third - Party Service Privacy Policy Links