Overseas Privacy Policy
Last Updated: 9 June 2023

Our company and its affiliate companies respect the privacy of its on-line visitors and recognize the importance of providing a secure environment for them. We have adopted a company-wide On-Line Privacy Policy ( “ Privacy Policy ” ) that explains how we collect, store, and use the information you provide us. This Privacy Policy details how we safeguards the privacy of its on-line visitors and does not apply to information we collected off-line. Please note that when you click a link to other sites from our website and/or any of online products or services( “ the Game ” ), this Privacy Policy does not apply to, and cannot control the activities on, those other sites. We highly recommend that you read the privacy policy of any third party website and/or any of online products or servicesyou may be directed to before providing any personally identifiable information.

By using the Game , you signify your assent to this Privacy Policy. If you do not agree to this Privacy Policy, please do not use our Game. This Privacy Policy may change from time to time, so please check back periodically to ensure that you are aware of any changes. If we make a material change to this Privacy Policy, we will notify you by posting the change in this Privacy Policy and, if necessary, give you additional choices regarding such change prior to the change becoming effective. Your continued use of the Game will signify your acceptance of these changes.

1. What personal information is collected and how we use it?

If you register an account to use the Game then we will need some information from you to set this up. If you choose to set up your Game profile using a social media account, we also collect information from that social media account. If you choose, you can provide certain other information to personalise the gaming experience and enable Game features, or participate in Game Services. If you need to get in touch with us then we will also retain some information so that we can get back in touch with you and address any concerns.

Information you provide to us (either directly or through a third party).

2.1.1 · Nickname and Name

We use this information to create your account for the Game in accordance with your request.

Necessary to perform our contract with you to provide the Game.

2.1.2 · If you register an account using your Facebook/Google Play account: Name, Facebook/Google Play ID, Profile Picture, Email Address (optional).

We use this information to create your account for the Game in accordance with your request.

Necessary to perform our contract with you to provide the Game.

· Gender (if you elect to provide this information)

We only receive this information if you voluntarily provide it. It is used in order to customise gameplay.

Necessary to perform our contract with you to provide the Game with customised gender-specific features.

· Region Location (manually selected by you)

We use this information to:(1) set up your gameplay on a regional server;(2)improve gameplay.

Necessary to perform our contract with you to provide the your online products or services.

· Friends List (Facebook, Google Play)

If you choose to log-in using Facebook, Google Play , we import the name of the friends from your social media profile so that you can connect with your friends.

Necessary to perform our contract with you if you request that we connect you with your friends.

· Friends List (manually added by you)

If you choose to add a user as a friend, we will store that information so that you can connect with that user. If you choose to provide GPS information, we will use it to allow you to connect with users nearby your location, but your GPS information is not shared with other users.

Necessary to perform our contract with you if you request that we connect you with your friends.

Some of our websites and/or any online services require you to create an account with a third party service provider. The username and email address that you create through this platform are collected by both us and the third party. In these types of instances, we strongly encourage you to also review the privacy practices of the third party prior to divulging any personal information.

Visitors purchasing products or services will be required to provide additional information such as a valid credit card number, expiration date, and shipping and billing addresses.

Please note that, depending on our website and/or any of online products or services that you are visiting, many of the activities listed above may not be available and, as such, personal information may not be collected.

Information generated as part of the online products or services and how we use it.

· Real ID

We use this information to store your Game data (including level and progress) with your profile.

Necessary to perform our contract with you to provide the Game.

· Game Play Statistics (Level ,Score/s) and date

We use this information to provide you with feedback and information about your gameplay and progress.

Necessary to perform our contract with you to provide the Game.

· IP Address

We use this information to allow you to connect to the Game server.

Necessary to perform our contract with you to provide the Game.

· Device ID and Device Information (Android: Device ID (IMEI), Series ID, Android ID, MAC address, device host, device hardware, RadioVersion, Google advertising ID; iOS: IDFV, Model, OS Version, Network, WiFI, MAC)

We use this information:(1)to improve our services, including the functionality of the Game;(2)for security and verification purposes;(3)identify and address bugs and assess game function for optimisation.

It is in our legitimate interest to ensure the security of our services, manage registrations and improve our services.

· GPS

We use this information to allow you to connect with users nearby your location. Your GPS information is not shared with other users.

We use this information with your consent.

· Advertising ID and marketing analytics data (e.g. device ID, engagement data and search terms)

If you click on a link or interact with content that advertises the Game, we store the Advertising ID for that advertisement and certain marketing analytics data with your profile.

It is in our legitimate interests to use this information to monitor the success of our advertising and marketing programs.

· Log Data (purchasing actions, game results (e.g., win or lose), in-game performance)

We use this information to:(1)maintain a record of log-in and actions of your account;

(2)improve our services, including the functionality of the Game ;(3)for security and verification purposes.

Necessary to perform our contract with you to provide the Game and retain your record of progress.

· Text Chat Data: Free Chat (users can communicate using their own, custom messages) and Quick Chat (users can communicate using only pre-determined messages set in a drop down menu in the Game).

We facilitate the posting of your communications with other users.

Necessary to perform our contract with you to provide the Game where you seek to use chat services.

· Transaction Records: payments on Google Play(Real ID, cost, product purchased, IP address, device details, email address (if web-based transaction)).

We use this information to maintain a record of your transaction history.

Necessary to perform our contract with you to provide the Game, information about your in-game purchase history and to restore purchases of in-game items.

· Security-Related Information: list of hack or cheating software, device operation system settings, device information including mobile phone brand, model, CPU structure, CPU model, kernel version, resolution.

We use this information:(1)To provide a fair Game environment;(2) To solve game crash and optimize compatibility.

It is in our legitimate interests to use this information to protect the integrity of Game and improve its operation.

· Survey Information (In-Game Surveys): Real ID, IP address, age (optional), email address (optional), mobile number (optional), name (optional), address (optional), profession (optional), other information that you provide in your response to the survey.

If you agree to participate in a survey run by us, we use this information to improve our services.

We collect this information with your consent.

1.1 Information you generate and display in the course of using the Services and how we use it.

You may provide additional information as part of your profile (such as gender). You may also provide or generate information when you communicate with other users in the Game (e.g., chat content and log data). We also generate an Real ID and use this to store your Game data, and we collect and store your Game play statistics (e.g. level, scores) in order to provide you with feedback and information about your Game play and progress.Lastly, we may use your personal information for internal marketing, profiling, or demographic purposes, so we can adapt our products and services to better suit your needs. We do this to better understand and serve our customers.

Please be advised that personal information submitted by individuals acting solely in a business capacity (e.g., personal information contained in job applicant's resume) is not subject to the uses set forth above or to any other practices stated in this Privacy Policy.

2. What type of communications may you receive?

· Special Offers and Updates

We will occasionally send you information on products, services, special deals, and promotions. Out of respect for your privacy, we present the option not to receive these types of communications. Please see the “ Choice ” section below.

· Service-related Announcements

We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature.

· Customer Service

Based upon the personally identifiable information you provide us, we will send you a welcoming email to verify your username and password. We will also communicate with you in response to your inquiries, to provide the services you request, and to manage your account. We will communicate with you by email or telephone, in accordance with your wishes.

· Recruit a Friend/E-cards/Share Wish List

If you choose to use our recruit-a-friend, Share Wish List, or e-card features, we will ask you for your friend ’ s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the website and/or any of online products or services. we does not store this information and uses it for the sole purpose of sending this one-time email and to track the success of our referral program.

3. How we share your personal information?

· Only where necessary will we share your personal information with third parties. Situations where this occur are.

Third parties that provide services in support of the Game Services, including providers of cloud services that process information identified in this policy on their servers for the purpose of providing the Game Services, for the purpose of processing support communication, for the purpose of processing gameplay and game rendering data to provide game analytics to improve game play, and for the purpose of providing marketing and advertisements and monitor the success of our marketing and advertising programs. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.

When you are asked for information while on our game, you are sharing that information with us, our parent, and our various affiliates and sister companies, unless specifically stated otherwise. All related group companies may only use your personal information in accordance with this privacy policy.

A third party that acquires all or substantially all of us or our business. If we sell or buy any business, undergo a merger, enter into a partnership, or sell some or all of our assets we may disclose your information to the prospective buyer of such business. Under these circumstances, we will always require the prospective buyer to comply with this privacy policy.

We reserve the right to disclose your personal information as required by law or in special cases when we have reason to believe that disclosing such information is necessary to identify, contact, or bring legal action against you if you are violating the Terms of Service or Use Agreements for our website or product, or may be causing injury to or interference (intentionally or unintentionally) with our rights or property, other users of our website or product, or anyone else who could be harmed by your activities. We also reserve the right to disclose your personal information if we have a good faith belief that it is necessary to prevent fraud or other illegal activities.

Please be aware that we cannot control the activities of third parties to whom we provide data, and while we cannot guarantee that they adhere to the same privacy and security procedures as we do, we will take reasonable steps to assure that these third parties will provide sufficient protection of personal information.

Please be aware that advertisers or website and/or any of online products or services with links to and from our game may collect personal information about you. And remember, this Privacy Policy does not apply to, and cannot control the activities of, those other advertisers or website and/or any of online products or services. We encourage you to carefully read the privacy policy of any advertiser or website and/or any of online products or services you visit.

Our game may include certain social media features such as the Facebook "Like" button, and widgets such as the Share this button or interactive mini-programs that run on the Game . These features may collect your Internet Protocol ( “ IP ” ) address, which page you are visiting on our game , and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on our game. Your interactions with these features are governed by the privacy policy of the company providing it.

our website and/or any of games or services may also have message boards, forums, and/or chat areas, where users can exchange ideas and communicate with one another. When posting to a message board, forum, or chat area, please be aware that the information is being made publicly available on-line and the user does so at his or her own risk. For certain forums, anyone posting or replying to a post may be doing so using their Real ID -- that is, their full first and last name -- with the option to also display the name of their primary in-game character (see discussion regarding Real ID below). If your personal information is posted on one of our community forums, you may contact us at [game@hstargame.com] . to request removal. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

4. What choices do you have regarding the collection, use, and distribution of your personal information?

we allows you to control the way that we use personally identifying information that we might obtain. At the time you provide personal information, we may give you the option of declining any future offers or information about new products, promotions, or services. In addition, many of the "mailings" we may send you, such as newsletters, have procedures within them to cancel the receipt of any future mailings. Lastly, you may be given the opportunity to "opt-out" of certain features or functionality (e.g. Real ID). See the applicable feature's FAQ or information page for more details.

Your browser may allow you to set a Do Not Track (DNT) signal indicating that you do not wish your online activity to be tracked. Currently, our system does not support and cannot act on DNT signal headers that we may receive. However, the choices that we provide you concerning the collection and use of your personal information will continue to operate as described in this Privacy Policy.

5.1 This service is not targeted at children under the age of 13. We do not knowingly collect or maintain personal data or non- personally identifiable information about any person under the age of 13, nor is any part of our website, games or other services targeted at them.

5.2 As a parent or legal guardian, please do not allow any child in your care to submit personal data to us. Please also consult our Terms of Service for more information.

5.3 If personal data of a child under the age of 13 years in your care is disclosed to us, you hereby consent to the processing of the child's personal data and accept and agree to be bound by the terms of this Policy on behalf of the child.

5.4 If you do not in fact consent to the processing of personal data of a child under the age of 13 in your care, please contact our Data Protection Officer. We will close any account used exclusively by such a child and delete and/or delete any personal data submitted by such a child without parental consent, or as otherwise required by applicable law.

6. What is Real ID?

Real ID friends can see each other ’ s real-life name and can see each other ’ s characters across all our game. By participating in Real ID, you will have the option of making your real name visible to your friend ’ s friends, who will also be able to invite you to become friends.

When you and a friend mutually agree to become Real ID friends, you will have access to a number of additional features, including the following:

Real Names for Friends: Your Real ID friends will appear under their real-life names on your friends list, when chatting, communicating in-game, or viewing a character's profile.

7. What are tracking technologies and how are they used?

As is true with most website and/or any ofthe Game, we gather certain information automatically and store it in log files. This information may include a unique identifier such as your Internet Protocol (IP) address and non-personal information such as your browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you. We do this to improve the services we offer you, to improve marketing, analytics, or website and/or any of the Game functionality.

we and our partners, such as marketing partners and analytics providers (listed here), may use tracking technologies such as cookies, beacons, tags and scripts. These technologies are used in analyzing trends, administering the website and/or any of online products or services, tracking users ’ movements around the website and/or any of online products or services, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We use cookies for various purposes including our shopping cart, to remember users ’ settings (e.g. language preference), and for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our website and/or any of online products or services, but your ability to use some features or areas of our website and/or any of the Game may be limited.

We may also use clear gifs in our HTML-based emails to let us know which e-mails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns. For this reason, these types of clear gifs are tied to personally identifiable information.

We, and third parties with whom we partner to provide certain features on our website and/or any of online products or services or to display advertising based on your web browsing activity, use Local Shared Objects such as Flash cookies, and Local Storage such as HTML5, to store content information and preferences. Various browsers may offer their own management tools for removing HTML5. To manage Flash cookies, please click here.

We partner with third party ad networks to either display advertising on our website and/or any of the Game or to manage our advertising on other sites. Our ad network partners may use tracking technologies to collect information about your activities on this and other website and/or any of online products or services to provide you targeted advertising based upon your interests.

8. What are Internet Protocol addresses?

An Internet Protocol ("IP") address is the unique number assigned to your server or Internet Service Provider ("ISP"). We may track such IP addresses for system administration, to report aggregate information, site tracking, security purposes, or to prevent our servers from being abused. See tracking technology discussion above.

9. What do you do if you want to correct or delete your personal information?

If for any reason you are concerned with the way we are using your personal information, or would like to correct or request that we delete such personal information, please contact us by e-mail at [game@hstargame.com] . We will respond to any request for access within 30 days.

In some cases, we may not be able to delete your personal information and will retain and use our information as long as necessary to comply with our legal obligations, resolve disputes, and/or enforce our agreements.

Please note that the deletion of your data will lead to the termination of your account and all applicable services.

10. How secure is my personal information?

The security of your personal information is important to us. We has taken steps to assure that all information collected will remain secure and in its original form, i.e. free from any alteration. As such, access to all personal information is strictly controlled. When credit card information is transmitted. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received.

In addition, we will take reasonable steps to assure that third parties to whom we transfer any data will provide sufficient protection of personal information.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted to our services; therefore we do not assume any responsibility for any transmission of your information which you do at your own risk.

· If you submits the following information to us, we shall store for the lifetime of your use of the Game (or until account deletion in accordance with your request):(1) Nickname or Name;(2)If you register an account using your Facebook/Google Play account: Name, Facebook/Google Play ID, Profile Picture, Email Address (optional);(3)Gender;(4)Region Location (manually selected by you);(5)Real ID;(6)Game Play Statistics (Level, Score/s)

;(7)Friends List (Facebook, Google Play, iOS Game Centre);(8)IP Address, Device ID, Device Information;(9)Advertising ID and marketing analytics data (e.g. device ID, engagement data and search terms);(10)Log Data;(11)Security-Related Information.

· If you submits the information about the Date and time stamps of actions to us, we shall store for 30 days. · If you submits the information about your GPS to us, we shall delete after you log out.
· If you submits the information about your Transaction Records (Open ID, cost, product purchased, IP address, device details, email address (if web-based transaction)) to us, we shall store for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then for the duration of any retention periods for which such data must be retained in order to comply with our legal obligations. · If you submits your Survey Information (In-Game Surveys) to us, we shall store for two years following receipt of the data. The data is deleted upon the expiry of such period or within 30 days of a lawful request from you for the erasure of such data (see the section of this privacy policy) (whichever is sooner). · If your submits your Survey Information (surveys placed on third party platforms including social media),we shall store for two years following receipt of the data. The data is deleted upon the expiry of such period or within 30 days of a lawful request from you for the erasure of such data (see the section of this privacy policy) (whichever is sooner).

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.

11. What if you have a question or complaint?

If you have any questions or wish to file a complaint, please feel free to e-mail us at [game@hstargame.com] .

12. The conclusion, validity, performance and interpretation of this Agreement and resolution of disputes in connection herewith shall be governed by the laws of the Hong kong (excluding the applicable conflict of law rules). In the event of any dispute or controversy , the parties shall in the first place use their best efforts to settle such dispute or controversy through amicable negotiation. You agree that any dispute or controversy which cannot be settled by negotiation, shall be submitted to and finally resolved by the Hong Kong International Arbitration Centre for arbitration , The arbitration site is Hong Kong.