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Privacy Policy

Last Updated: December 27, 2024

Email of Data Protection Officer (DPO): funcradle@gmail.com

Data Controller: FUN CRADLE CO., LIMITED

This Privacy Policy explains how FUN CRADLE CO., LIMITED (hereinafter referred to as “we”) and our affiliates, as data controllers, collect, use, share, disclose, and protect your personal information when you use our products and/or services, as well as matters related to your data protection rights.

We may update this privacy policy from time to time and shall notify you in a reasonable manner if any change has been made. Your continued use of services from the effective date indicates your consent to be bound by this new privacy policy. If you do not agree with this "Privacy Policy", you should stop to access and/or use our products.

Please contact our data protection officer at funcradle@gmail.com if you have any questions about this privacy policy or how you might exercise your rights. We shall review your request and contact you within the period required by laws or regulations.

You can read the following content to help you understand specific matters:

1. How Do We Collect and Use Personal Information

The laws and regulations related to privacy and data protection vary across different jurisdictions. For example, if you are a user located in the European Union, we will protect your personal information in accordance with the European General Data Protection Regulation (GDPR). If you are a user located in the U.S., we will protect your personal information in accordance with California Consumer Privacy Act (CCPA), Children's Online Privacy Protection Act (COPPA) and Virginia Consumer Data Protection Act (VCDPA). If you are a user located in Brazil, we will protect your personal information in accordance with the General Data Protection Law (LGPD) of Brazil. If you are located in other regions, we will collect and process your personal information in accordance with the principles required by applicable local laws.

When you use our games and/or services, in order to ensure the normal functioning of the product, we may collect some of your personal information in the following ways:

1.1 Data collected via games

We will not collect any personal information from you when you play our games and/or use our services. Please be assured that we will seek your consent separately if we need to collect your personal information.

1.2 We might request device and app permissions

a. To ensure you can use our products normally, when you use our products and/or services, we may need to check your network connection status, request access to your network permissions, and obtain network status information and Wi-Fi status information.

b. To enable the normal use of the voice input function within our products, we may request the application to access the recording permission, so we can accurately capture your voice information, convert it into effective commands, and ensure privacy security.

c. We request the permission to allow the application to modify global sound settings so as to provide you with a better experience when using our products and/or services.

d. We request vibration permissions to provide haptic feedback or alert users, aiming to offer you a higher quality service experience.

e. We request the permission to read external storage so that you can open local files and use our products normally when using our products and/or services.

1.3 Information we collect from other sources

If  you contact us for purchase or use problems, or you have questions for this "Privacy Policy", we might need you to provide certain personal information in order to verify your identity and the specific reason, including your IP address, E-mail address, name, address, and telephone number. Your act of providing us with such information indicates your consent to our collecting, using, managing, and storing your information in accordance with this privacy policy.

Such information you provide will be protected in accordance with this "Privacy Policy". All information we collect will be anonymized and de-identified to ensure the security of your personal information.

2. Cookies and Similar Technologies

We use Cookies and similar technologies for the purpose of providing you with better products and/or services. With the help of these advanced technologies, we are able to track your game progress and learn about your game info so as to provide you with a smooth and high-quality user experience. We shall not apply the above-said technology for any other purpose that is not listed in this policy. Please understand that certain services can only be achieved with these above-said technologies. If your device or related program permits, you can turn off or delete the above-said technologies by changing settings or visiting those technology providers' websites. But this might affect your experience with our products/services.

3. Third Party Services

3.1 Third party payment service providers collect relevant personal information

You can acquire virtual products related to products and services, including games, game items, game currency, and game equipment. Please note that the above said payment service is provided by third parties. We only receive result verification information confirming that you have completed the payment process from the third party payment service providers so as to provide corresponding virtual products and services to you. If you wish to learn the specific rules as to how third party service providers collect personal information, please read their privacy policies.

3.2 Third Party SDK List

We will integrate third-party SDKs to provide you with better services. The personal information collected by these third party providers in accordance with their own privacy policy. You can refer to the list below to learn about the personal information collected by SDK providers. If you want to know more details, please refer to the their own privacy policy.

Third-Party SDK

Usage

Information they collect

Scope of usgae

Privacy Policy

Owner and its official website

BuglyAKA, Tencent Bugly SDK

Data Analysis

Device information, including IMEI, IMSI, AndroidID, IDFA, OpenUDID, GUID, OAID, GAID, ICCID, MAC address, and IP.

All channels and packages

https://privacy.qq.com/document/preview/fc748b3d96224fdb825ea79e132c1a56

Tencent Technology Shenzhen Co Ltdhttps://www.tencent.com/en-us

Access to network connection which might consume GPRS data; obtain network information status; obtain information of installed applications.

Allow programs to write to external storage.

Umeng SDK

Data Analysis

Device information, including IMEI, IMSI, AndroidID, IDFA, OpenUDID, GUID, OAID, GAID, ICCID, MAC address, and IP.

All channels and packages

https://www.umeng.com/page/policy

Youmeng Tongxin (Beijing) Technology Co., Ltd.
https://www.umeng.com/page/about

Access to network connection which might consume GPRS data; obtain network information status; obtain information of installed applications.

Allow programs to write to external storage.

PICO Unity Integration SDK (v2.1.2)

Necessary for application publishing and Pico platform service usage

Players' account information on platform

Pico

https://www.picoxr.com/cn/terms/privacy.html

Beijing Xiaoniao Kankan Technology Co., Ltd.
https://www.picoxr.com/

Players' friend information on platform

Leaderboard data

Achievement data

Challenge data

Oculus Integration SDK (v69.0.0)

Receive, statisticize, use and transfer data

Avatar

Oculus

https://developer.oculus.com/policy/data-use/

Facebook Technologies, LLC.
(https://about.facebook.com/meta/)

Challenge data information

Deep link information

Information about in-app & out-app purchases.

Information about bringing users together in a virtual space.

Information about users, relationships between friends, and recently met people.

Access information about Matchmaking platform services.

Access information related to the user's platform services.

Access subscribed information.

Access user ID, Oculus username, and avatar.

Qiyu_Platform_SDK_v1.1.0

1. Support developers to implement account, social, income and other functions related to Qiyu platform in Unity.
2. For applications to be launched on Qiyu Store, the QIYU Platform SDK must be integrated.

Obtain the account status and information of Qiyu users in the application.

Qiyu Channel

https://app.iqiyi.com/tvguo/iprivacy.html

Beijing Mengxiangzhanfang Technology Co., Ltd.
https://www.iqiyismart.com/

Qiyu_UnityXR_SDK_v1.4.1

Support developers to develop Qiyu VR content in Unity.

Obtain device manufacturer, name, unique code and other information

Frame Refresh Rate

GSXR Unity SDK V_1.0.10 / XR V_1.0.4

Support developers to develop in the Unity engine.

 

Nolo Channel

https://api.nolovr.com:9080/agreements/privacyagreements.html

Beijing Lingyu Intelligent Control Technology Co., Ltd.
https://www.nolovr.com/

 

4. With Whom Will We Share Your Personal Data?

Under normal circumstances, we will not share your personal data without your consent. However, there are times when we may share your personal data with our affiliates, using any mechanisms that provide appropriate safeguards. All these recipients are obligated to comply with EU data protection regulations and other applicable laws and regulations regarding the protection of personal data and privacy. Beyond this, we will not sell or share your personal data with other third parties.

We will strictly abide by relevant laws and regulations and keep your personal data confidential. We will not share your personal data with others, except for the following circumstances:

(1) Your explicit consent or authorization has been obtained in advance;

(2) We are under a legal obligation or this is a mandatory requirement from relevant departments;

(3) We need to protect the legal rights and interests of you or other users or other individuals' lives, property, and other legal rights within the confines of laws and regulations;

(4) We have received a legal request from your guardian;

(5) This is in accordance with relevant agreements signed with you (including electronic agreements signed online and corresponding platform rules) or other legal documents;

Under normal circumstances, we will not disclose your personal data without your consent, except in legally permitted situations such as investigating, preventing, or taking actions regarding illegal activities, suspected fraud, infringement of our intellectual property, potential threats to the safety of any person, violations of our terms and conditions or other agreements, or as otherwise required by law.

5. How Do We Retain Your Personal Information

(1) Storage of Personal Data

We commit to strictly adhering to the applicable laws and regulations of each jurisdiction, properly and securely storing your personal information. We will employ stringent technical measures and management practices to ensure the confidentiality, integrity, and availability of your personal information, thereby maximizing the protection of your privacy rights.

We will only process your personal data within the necessary confines of the collection purpose related to the provision of services to you. Your personal data will not be retained by us for longer than necessary unless we have the legal right or obligation to retain the data for a longer period of time, or the data is necessary for the establishment, exercise, or defense of legal requirements.

(2) Transfer of Personal Data

All personal data we collect from you will be stored in accordance with the requirements of local applicable laws and regulations in the territory where we and our affiliates are located. When it is necessary to transfer the collected personal data across regions due to business needs, we will obtain your separate consent and ensure that such transfer is in compliance with relevant laws and regulations.

6. How We Protect the Security of Your Personal Information

We employ various security technologies and procedures to prevent the loss, misuse, unauthorized access, or disclosure of information. For example, in certain services, we use encryption technology to protect some of the sensitive information you provide to us. Please note that in the internet industry, even exhaustive security measures cannot guarantee 100% information security at all times. You need to be aware that the systems and communication networks you use to access our services may encounter issues due to factors beyond our control.

7. Your Rights

In accordance with the relevant laws and regulations of each jurisdiction (including but not limited to GDPR, CCPA, COPPA, VCDPA, etc.), we fully respect and protect your rights to your personal data. You have the following rights with regard to your personal data. If you wish to exercise these rights or have any questions about exercising your rights, please contact us at funcradle@gmail.com. We will process your request within the timeframe specified by the laws and regulations of your location, and no later than 15 working days.

7.1 Right to View, Access, and Be Informed

You have the right to inquire and access how we collect, use, and to whom we share, disclose, or sell your personal information. You can send an email to funcradle@gmail.com to contact us to exercise your rights. We will accept and process it within the time specified by the laws and regulations of your location, which will not exceed 15 working days.

7.2 Right to Correct

You have the right to correct or update inaccurate personal data about you to ensure your information is up-to-date and correct.

7.3 Right to Delete

Under certain circumstances, you have the right to delete your personal data, such as:

a. The personal data is no longer necessary for the purposes for which it was collected or otherwise processed;

b. If you have withdrawn your consent and there is no other legal basis for processing;

c. If you object to its processing and there are no reasonable grounds for its processing;

d. Personal data must be deleted in order to comply with legal obligations under relevant laws;

e. Personal data has been unlawfully processed or;

f. Personal data collected are in connection with the provision of information society services.

Please note that this right is not absolute. If the data is necessary to comply with legal obligations or to establish, formalize or defend legal claims, you right might be restricted. You may request deletion of personal information collected about you by contacting our Data Protection Officer via the contact details we provide by sending an email to funcradle@gmail.com. After receiving your request to delete personal information, we will accept and process it within the time specified by the laws and regulations of your locality, which shall not exceed 15 working days. We will take measures such as checking the deletion of your personal information to protect your personal information.

7.4 Right to Restrict Processing

You have the right to restrict the processing of your personal data in certain circumstances. But we will only process your personal data with your consent for important reasons, such as establishing, exercising or defending legal claims or protecting personal or public interest.

7.5 Right to Object

When we process your personal information based on your consent, contractual requirements, or legitimate interests, you have the right to object to our processing at any time in accordance with applicable laws.

7.6 Right to Withdraw Consent

You have the right to withdraw your consent regarding your personal information at any time. If you withdraw consent, we will stop processing the personal data for which you have withdrawn consent unless we have a legal obligation to retain part or all of your data. Please note that withdrawing your consent does not affect the legality of processing based on your consent before its withdrawal.

7.7 Right to Data Portability

In certain circumstances, you have the right to receive your personal information that we hold in a structured, commonly used, and machine-readable format, so you can transfer this personal information to another entity. Please contact us to facilitate this request.

7.8 Right to Lodge a Complaint with Data Protection Authorities

Without prejudice to any other administrative or judicial remedies, you have the right to lodge a complaint with the regulator in your jurisdiction in accordance with applicable laws. You may also directly contact us to file a complaint, and we will do our utmost to resolve your issue.

8. Minor Protection

Minors under the age of 13 should read this privacy policy in the company of parents or legal guardians. Under no circumstances are minors allowed to use our services without parents' or legal guardians' consent to this privacy policy.

We will not intentionally collect or solicit personal data about minors under the age of 13,  direct them to interest-based advertisements, or intentionally allow such people to use our services unless laws and regulations permit us to collect and process such information without parents' consent. If you are a minor under the age of 13, please do not send us any personal data about you, including your name, address, phone number, or email address. If we learn that we have collected any personal data about minors under the age of 13, we will apply every reasonable method to delete that data. Please contact us if you believe that we might have data from or related to minors under the age of 13. We shall apply every reasonable means to delete that from our system.

This policy follows the definition of minors of the marjority of countries/regions and defines minors in this policy as children under the age of 13. If the definition of minors in your jurisdiction is different from this policy, please refer to the regulations in your jurisdiction. We will still protect children's personal information as described in this article.

9. Updates of Privacy Policy

This Privacy Policy may be updated at any time. We will notify users on this page or possibly in this application and/or by any available means where technically and legally feasible. It is strongly recommended that you check this page frequently and refer to the last updated date listed in this privacy policy to make sure you understand our processing rules concerning your personal information. If you do not agree with this Privacy Policy, please do not access and/or use our products.

10. Contact Us

During the use of our products and/or services, if you have any questions, complaints, or suggestions regarding this Privacy Policy, you can contact our Data Protection Officer by sending an email. We will review the issues involved as soon as possible and respond to your request within 15 working days or the timeframe stipulated by laws and regulations.

Email address: funcradle@gmail.com