ColorBANG Privacy Policy

LAST UPDATED: 【 March 29th 2024 】

EFFECTIVE DATE: 【 March 29th 2024 】

Introduction

The “Personal Information and Privacy Protection Policy” (hereinafter referred to as the “Privacy Policy”) is jointly concluded by you (hereinafter referred to as “the user”) and [N2 PTE. LTD.] (hereinafter referred to as “ColorBANG” “ColorBANG Game” or “we,” with our registered address at [61 Club Street Singapore 069436]), and this Privacy Policy is legally binding.

Welcome to use the services we provide, including your use, access, or browsing of the games, web pages, websites, customer service, and other services provided by us or by third parties authorized by us (collectively referred to as the “Service”). We attach great importance to the protection of users’ personal information and privacy.This Privacy Policy has been specially formulated to explain to you how we collect, use, store, share, and transfer this information when you use our products or services, as well as the methods we provide for you to access, update, control, and protect this information.

To safeguard your legal rights, please carefully read and fully understand all the contents of this Privacy Policy, especially the provisions that exempt or limit our liability, restrict your rights, the terms of law application and dispute resolution, and any separate agreements related to the activation or use of a specific service.

The aforementioned provisions are typically highlighted in bold, color-coded, or by other reasonable means to draw your attention. Your acknowledgment of these provisions may result in you undertaking additional contractual obligations in specific situations.

Terms and Conditions Apply

We may revise the terms of this Privacy Policy from time to time, and once the revised terms of the Privacy Policy are published, they will replace the original terms. You can access the latest version of the Privacy Policy on our website. Please read the revised Privacy Policy carefully. If you do not agree to the changes, you should stop using our services immediately and may exercise your rights to revoke authorization and delete information through the methods specified in Article 5. If you continue to use our services, it means that you have accepted the revised Privacy Policy and are bound by it. If there are significant changes to the terms that affect your rights, we will provide advance notice.

After reading this Privacy Policy, if you have any questions or concerns, you can contact us through the “Contact Us” section of this Privacy Policy, and we will respond to you as soon as possible.

This Policy will help you understand the following contents:

How we collect and use your informationHow we use cookies and similar technologiesHow we entrust processing, share, transfer, and disclose your personal informationHow we store and protect your personal informationYour rights to manage personal informationProtection of minors’ informationApplicable law and dispute resolutionOtherContact us

What information we collect

This section will inform you of what personal information we collect from you. If you would like to know how we use your personal information, please refer to the "How we use your information" section below.

Information You Provide

a)When you use our services, you can choose to log in as a guest or with a third-party account. If you choose to log in as a guest, we will use Token technology to verify your login.

Please note: In guest login mode, if your device is lost, replaced, or if you click on log out, you will lose the data from your previous play. We recommend that you associate a third-party account in a timely manner to ensure the convenience of using your data.

If you use a third-party account to log in to ColorBANG, based on your consent, we may collect the unique identifier and account name of your relevant account to save your login information, so that you can log in on different devices. Such information obtained from third-party platform service providers will be added to your account information. If you do not agree to authorize such information, you will not be able to use third-party platform accounts to log in to our services.

Information Shared by Other Parties

a) Information shared by others when using our products or services;

b)We may obtain information generated or shared by you when using products or services from third-party partners. Please carefully read the user agreements or privacy policies of third-party partner products or services.

Information We Collect from You

When you use our game products or services, we may collect the following information based on the ways you use them:

a) During your use of our services, we will collect and use the information you actively provide or that is generated as a result of using the service in the following ways:

To maintain the normal operation of the service, optimize product performance, enhance your experience, and ensure the security of your account, we may collect information about your device or software, including device identifiers provided by your mobile device, web browser, or other programs used to access our products or services (Android devices: Android ID, device serial number, GAID; iOS devices: IDFV, IDFA), MAC address, IP address, device software characteristics (device model, device manufacturer, device model and version, operating system type and version), device hardware characteristics (memory and available memory, device resolution, CPU information), device settings information (time zone, language, device name), network type, carrier, application ID, application package name, application version number, timestamp, SD card information (internal/external SD card capacity), whether the device is rooted/jailbroken, device orientation information, ambient light sensor, clipboard information, pixel density, emulator information (Android only).

b) When you register/login to our service, we will collect and use your email, registration password, name, nickname, and country used by you. These pieces of information are collected to assist you in completing the account registration, generate your network identity in the product, and protect the security of your account.

c) When you log into our servers, to ensure you can play the game normally, we will collect and use information about your network type.

d) When you chat in our game, we need to access your clipboard locally on the device to read relevant information for functions such as assisting in quick chat input. If you refuse authorization, you will not be able to copy and paste clipboard content. We will only read information related to the ColorBANG service to complete relevant instructions and will not store such information. We will not collect other irrelevant information from your clipboard.

e) If you wish to capture or share highlights from your gameplay via screenshots or videos, after obtaining your authorization, the ColorBANG game will access your photo album storage and/or network functions to provide you with functions such as saving and uploading screenshots or videos. If you refuse authorization for photo album storage or network functions, you will not be able to save or upload images or videos from the game, nor share them with third-party software. However, this does not affect your normal use of other functions in our game, and you can revoke the aforementioned permissions at any time.

f) If you wish to display game data of your location and the leaderboard of that area, after obtaining your authorization to use location permissions, we will collect your location information and administrative district information for player data display purposes, etc. Refusing to provide this information will only result in you being unable to display location data and the leaderboard of that area, but it will not affect your normal use of other functions in our game, and you can revoke your location authorization at any time.

g) When you interact with other players in the game through text or emojis, we may collect and save the information you send for filtering inappropriate content such as pornography, violence, politics, insults, and malicious advertisements to purify the game environment.

h) When you contact us, we may collect your communication/call records and content or the contact information you leave behind to contact you or help you solve problems, or record the solutions and results of related issues.

i) Depending on your account management operations, we may send you SMS or EMAIL messages or emails, including verification codes, system notifications, account information changes, etc. In cases where you agree, we may push notifications to you about testing new products, launching new products, and related promotional activities. If there are significant changes to the services you are using, such as important versions, feature updates, or termination of operational services, you authorize us to determine whether to actively push relevant information to you based on the actual situation.

j) You acknowledge and agree that to fulfill basic operational functions, we may, when necessary (e.g., announcing cheating methods prohibited in games, maintenance, service suspension, etc.), issue announcements related to the service to you. Such announcements are unilateral notifications. If you have any questions about the announcements, you can contact us through the customer service system to obtain further information. The aforementioned announcements do not contain any advertising components, are part of this "Privacy Policy," and have the same legal effect as the terms of this "Privacy Policy."

How We Use Cookies and Similar Technologies

We may collect and use your information through cookies or similar technologies (referred to as "cookies" below) and store such information. Our cookies are applicable for the following purposes:

a) Remembering Your Identity: Cookies help us identify you as our registered user or save other information you provide to us about yourself.

b) Caching game data generated when you play games.

Third-party partners may place cookies on our products and services. These cookies may collect non-personally identifiable information related to you for analyzing how users use such services or for evaluating the effectiveness of advertising services. We strictly require third-party partners to comply with the relevant provisions of this policy. You can refuse or manage cookies through browser settings.

Please note that you can disable cookies or modify settings by clearing them manually or logging out. However, disabling cookies may prevent you from enjoying the corresponding service experience, and some services may not function properly.

How We Share, Transfer, and Disclose Your Personal Information

Sharing

We only share your information for legitimate, lawful, necessary, specific, and explicit purposes. If we or our affiliates share your personal information with any third party, we will endeavor to urge such third party to comply with this Privacy Policy and other appropriate confidentiality and security measures we require them to adhere to, and sign privacy protection-related agreements. Except for the following circumstances, we will require such third parties to seek your authorization and consent again:

a) Providing our products or services to you;

b) Achieving the purposes described in the "How We Collect and Use Your Information" section;

c) Fulfilling our obligations and exercising our rights under this Privacy Policy or other agreements we have reached with you regarding our games;

d) Understanding, maintaining, and improving our products or services;

e) Providing based on your or your guardian's legitimate requests;

f) Providing in accordance with the requirements of laws and regulations or competent authorities.

Our privacy policy does not apply to products or services provided by third parties. Depending on the products or services you use, third parties may include third-party accounts, security-related services, etc. Please note that third parties may access through SDKs, APIs, etc., and we are not responsible for how third parties use information or able to control its use. Therefore, we strongly recommend that you read the privacy policies of third parties. The third parties we are involved with may include: [List of third parties].

Disclosure

We will only disclose your personal information in the following circumstances:

a) After obtaining your explicit consent;

b) Disclosures required by laws, regulations, or regulatory authorities.

Situations Without Prior Consent

According to the relevant laws, regulations, and national standards of the location where you use our products and services, and in accordance with warrants issued by administrative or judicial authorities, we may share, transfer, or disclose your personal information without obtaining your consent.

You acknowledge and agree that we may use the information collected for de-identification and anonymization to optimize service performance, enhance user experience, and improve service quality through big data analysis.

Transfer

In addition to the aforementioned situations, we will only transfer your personal information in the following circumstances:

a) After obtaining your explicit consent;

b) Transfers required by laws, regulations, or regulatory authorities;

c) With the continuous development of our business, and the possibility of mergers, acquisitions, asset transfers, or similar transactions involving us and our affiliated companies, your personal information may be affected. We will inform you of the relevant circumstances through push notifications, announcements, etc., and will continue to protect your personal information according to the standards required by laws and regulations, not lower than those stipulated in this policy, or require the new administrator to continue protecting your personal information.

How We Store and Protect Your Personal Information

Storage

We will securely store your information, including local storage (such as data caching using the app) and storage in cloud databases.

Unless otherwise provided by the laws and regulations or regulatory authorities of the location where you use our services, and for the reasonable and necessary purposes to maintain public interests, or to protect the personal and property safety or legitimate rights and interests of our customers, us, our affiliated companies, other users, or employees, we will only store your personal information for the necessary and shortest period required for the purposes stated in this policy.

In order to provide you with the best possible service, our group adheres to the concept of diversity and globalization, with businesses located around the world. According to the service contract we have with you, your personal information may be processed on servers located outside of your place of residence when necessary. Regardless of the location of the servers, we will take appropriate measures to protect your rights in accordance with this privacy policy.

Our current servers are located in the following regions:

Singapore and Malaysia servers: Singapore. Thailand server: Bangkok. Taiwan server: Japan or Hong Kong. Indonesia and Philippines servers: Jakarta.

We will continuously improve the content of our products and services. During this period, the locations of the above-mentioned servers may be adjusted and changed based on the further optimization of our services.As a global gaming company, we have suppliers around the world. In compliance with the principles of necessity and minimization, and after anonymization, we may access some of your information from anywhere. You fully understand and agree that our support team, engineering team, and other teams around the world may access and process your information from places outside your place of residence (such as Singapore).If we terminate our services or operations, we will promptly cease the collection of your personal information and, in compliance with relevant laws and regulations, notify you in advance. After the termination of services or operations, we will delete or anonymize your personal information, unless otherwise required by laws, regulations, or supervisory authorities. If you request to delete your account, voluntarily delete personal information, or the information exceeds the necessary retention period, we will delete or anonymize your personal information, except for cases where the laws and regulations of the location of the server where your account is registered require a retention period.If the information we collect needs to be transmitted across borders, we will ensure that sufficient protection is provided for your personal information in accordance with the laws and regulations of the country of origin and the requirements of the relevant regulatory authorities.

Security Measures

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We will adopt reasonable and necessary security measures in accordance with mature industry standards to reduce the risks of information loss, improper use, unauthorized access, or disclosure. These measures include but are not limited to:

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Please understand that due to technological limitations and the potential existence of various malicious methods, even though we have strengthened security measures as much as possible, we cannot guarantee the security of information one hundred percent. You need to understand that the systems and communication networks you use to access our services may experience issues due to factors beyond our control.

In the event of a personal information security incident, we will promptly inform you in accordance with legal requirements, including: the basic situation of the security incident and its potential impacts, the measures we have taken or will take to address the incident, recommendations for you to independently prevent and reduce risks, and remedial measures for you. We will promptly notify you of the incident through email, letters, phone calls, push notifications, etc. If it is difficult to inform each individual information subject, we will issue public announcements in a reasonable and effective manner. At the same time, we will proactively report the handling of personal information security incidents in accordance with regulatory requirements.

Cross-border Transfer of Personal Information

For the purpose of game behavior analysis and improving game services, we may provide your game behavior data collected in accordance with this policy to publishers. Before providing your personal information to overseas recipients, we will obtain your separate consent in accordance with legal requirements.

Data Protection Officer

We have established a department specifically responsible for data security and appointed a dedicated Data Protection Officer (“DPO”). If a data breach or security vulnerability occurs, we will take measures in a timely manner and promptly notify you in appropriate ways, including messages or announcements. When you contact us via email, your inquiries regarding personal data will be automatically directed to the data protection department.

Your Rights to Manage Personal Information

We understand your concerns about personal information and endeavor to ensure that you have full access to your rights to access, correct, delete, and withdraw authorization for your personal information, so as to fully protect your privacy and security. Your rights include:

Right to access your personal information

You can access your personal information provided to us through the relevant instructions (or settings) of our products and services. This includes: [ID, email, third-party linked accounts (if any), etc.]. If you encounter any problems during the access process and need to obtain other personal information that is not readily available, you can contact us through the methods provided in this privacy policy.

Right to correct/modify your personal information

If you find errors, incompleteness, or updates in the personal information you provided to us, you can correct/modify your personal information in our products and/or services. Please note: in order to protect the security of user accounts, if there are suspicions of abnormal login or other unusual circumstances, we may randomly request you to provide relevant identification materials to verify that the requested modifications are authorized by the account owner.

For certain personal information, we provide operating settings on the relevant functional pages of our products, allowing you to directly correct/modify your information. For example, you can modify your login password, change the associated email, or bind/unbind third-party accounts through the [Game Settings - Bind/Unbind] option.

If you encounter difficulties in exercising the above rights, or if we are unable to provide online self-correction/modification services, we have the right to correct or modify inaccurate or incomplete information, and in specific cases, especially in the event of data errors, you can submit your correction/modification request to us through the feedback/error reporting/customer service measures published by us. However, you may not be able to modify certain initial registration information submitted during registration for security and identity verification purposes.

Right to delete your personal information

You can directly request us to delete your personal information by emailing us at [[email protected]] when the following circumstances occur, except when the information has been anonymized or as otherwise required by laws and regulations:

a) When our handling of personal information violates laws and regulations;

b) When we collect or use your personal information without your consent;

c) When our handling of personal information violates our agreement with you;

d) When you deactivate your ColorBANG account;

e) When we terminate our services and operations.

To ensure the security of your account, if you request deletion due to suspicious activities such as abnormal login, we may require you to provide specified identification materials to verify that the request is made by the account owner. You can obtain specific requirements from the relevant email or official website guidance when you make the request.

If we decide to honor your deletion request, we will also notify the entities that have obtained your personal information from us to promptly delete it, unless otherwise required by laws and regulations, or unless these entities have obtained independent authorization from you. After you delete information from our services, we may not immediately delete the corresponding information from our backup systems, but we will delete this information when the backups are updated.

Right to withdraw all or part of your authorization for personal information

Even if we have collected or processed your personal information with your consent, you have the right to withdraw your consent at any time. However, you should understand that after you withdraw your authorization, we may not be able to continue providing you with the specific functions and/or services associated with the withdrawn authorization. The decision to withdraw your consent will not affect the processing of personal information conducted based on your previous authorization.

Right to deactivate your account

You can apply to deactivate your ColorBANG account through customer service or the “Delete Account” path in the in-game settings. After deactivating your account, you will no longer be able to log in or use our products and services with that account. Furthermore, any unused benefits or future overdue benefits generated during the use of all products and services under the ColorBANG account will be cleared. The content, information, data, records, etc. under the account will be deleted or anonymized (except as otherwise provided by laws and regulations or as required by regulatory authorities). Once the deactivation of the ColorBANG account is completed, it cannot be restored. For more information about the deactivation process, conditions, and other matters related to ColorBANG accounts, please visit the relevant page or contact us at [email protected].

Right to obtain a copy of your personal information

You have the right to obtain a copy of your personal information. You can contact us at any time through the methods provided in this privacy policy, and we will respond to your request within 15 working days.

Restriction on automated decision-making in information systems

In certain business functions, we may make decisions solely based on non-human automated decision-making mechanisms such as information systems and algorithms. If these decisions significantly affect your legal rights, you have the right to request an explanation from us, and we will also provide appropriate remedies.

How we respond to your aforementioned rights requests

We will respond to your request as soon as possible within 15 working days after receiving it and verifying your user identity. If you have any questions about the handling of your personal information, you can communicate with us to resolve them through the contact information provided in the “Contact Us” section of this privacy policy. However, in cases where the laws and regulations or enforcement orders of the administrative and judicial authorities in the region where you use our products and services prohibit us from responding, we will be unable to do so.

Some of your requests may need to be processed by the app store, and we may be unable to respond to your requests until the app store completes the corresponding processes or responses.

Protection of Minors’ Information

We believe that the protection of minors is in the common interest of users in all countries and regions. Therefore, we will take stricter and more cautious measures and attitudes toward the protection of children and minors.

You hereby confirm again that the confirmation and understanding of this policy stem from the legal or designated guardian of the child or minor, with no reading and understanding barriers. As a guardian, you will provide full supervision during the child or minor’s use of our products and services, and you also have the obligation to ensure the information security of other children or minors who are our users.

You agree that the sensitivity of minors’ information constitutes an irrevocable authorization for us to take any necessary measures or legal means to maximize the protection of children and minors’ information security. This includes, when necessary, imposing complete restriction measures on your account. The aforementioned requirements also apply to all modifications or changes to this “Privacy Policy.”

If you are a minor, or if you have any questions about the specific application of any provision in the “Privacy Policy” related to minors’ use of our products and services, please feel free to contact our Commissioner for the Protection of Minors at the following email address: Email: [[email protected]]

Applicable Law and Dispute Resolution

This “Privacy Policy” is governed by Singapore law and is to be interpreted in accordance with it, excluding its conflict of law principles. The United Nations Convention on Contracts for the International Sale of Goods will not apply. You agree and acknowledge that any disputes related to this “Privacy Policy” or ColorBANG should be resolved through peaceful negotiation first (any disputes requiring negotiation should be notified to us in writing using the contact information provided in this “Privacy Policy”). If no effective solution can be reached through negotiation within thirty days, any claims or legal actions between you and us should be unconditionally submitted to the Hong Kong International Arbitration Center (HKIAC) for arbitration, which shall be conducted in accordance with the arbitration rules of the said committee. The arbitration award shall be final and binding on both parties. If the above arbitration clause is unenforceable for any dispute, both parties agree to submit such disputes to the courts of Singapore. You hereby agree and waive any objections to lack of personal jurisdiction and/or forum non conveniens, whether by arbitration or judicial judgment.

Under applicable laws and regulations, both parties confirm that any dispute resolution, whether through arbitration or the courts, shall be conducted solely on an individual basis, and not in the form of collective or representative litigation. If you do not accept this provision, please terminate the use of our services or send us a written notice wishing to opt out of the arbitration within 30 days.

Other

Severability

If any provision of this “Privacy Policy” is deemed invalid for any reason or declared illegal, invalid, or unenforceable, such provision shall be separated and removed from this “Privacy Policy,” while the remaining parts of this “Privacy Policy” shall remain unaffected and valid. Despite the above provision, if the waiver of class action rights is found to be invalid, unenforceable, or illegal, you agree that the waiver may not be separated. In other words, arbitration cannot be carried out in any case without our prior express written consent.

Non-Assignment

Without our prior express written consent, you may not transfer, charge, or subcontract any rights or obligations under this “Privacy Policy” through legal or other means. Otherwise, we may decide to terminate the provision of any services to you without further notice. If, according to the laws of your country or place of residence, limitations on transfer are unenforceable, then this “Privacy Policy” will be binding on you and any recipients. Despite the above provision, we reserve the right to transfer, charge, or subcontract all or any rights or obligations under this “Privacy Policy” at any time.

The titles of all provisions in this “Privacy Policy” are for convenience only and have no actual meaning in themselves, and should not be used as a basis for interpreting the meaning of this “Privacy Policy” and its related provisions.Our failure to exercise, or delay in exercising, any right under this “Privacy Policy” or under applicable law shall not be considered as a waiver of such right, and shall not affect our exercise of that right in the future. Affiliates referred to in this “Privacy Policy” means entities that are directly or indirectly controlled by, under the control of, or jointly controlled with us. We may translate this “Privacy Policy” into other languages. In the event of any discrepancies between the English version and versions in other languages, the English version shall prevail, unless otherwise provided by local laws and regulations. Except for any other limitations as may be provided herein, we shall not be responsible for any delays or failures resulting from reasons beyond our reasonable control (such as actions by government authorities, natural disasters, or other events beyond our reasonable control). You declare that you have voluntarily confirmed all the contents of this “Privacy Policy” and are willing to be bound by them. Besides the compensation explicitly granted in this “Privacy Policy,” you irrevocably agree to waive any other compensation claims.If this “Privacy Policy” conflicts with the local laws of your country or place of residence, the local laws shall prevail. Except for specific explicitly stated services, this “Privacy Policy” applies to all our services. Specific privacy statements or rules for certain specific services will more specifically describe how we use your information in such services. The specific privacy statements or rules for these specific services form part of this “Privacy Policy.” If there are any inconsistencies between the specific privacy statements or rules for specific services and this “Privacy Policy,” the specific privacy statements or rules for the specific services will apply.

Contact Us

We have established a department dedicated to personal information protection, and have appointed a Data Protection Officer. We will protect your personal information in accordance with this policy. If you have any questions, comments, or suggestions regarding this policy, our privacy measures, or your information, you can contact us or our Data Protection Officer through the following means.

Email: [[email protected]]

Address: [N2 PTE. LTD. 61 CLUB STREET SINGAPORE (069436)]

In general, we will respond to your inquiries, comments, or suggestions within 15 working days after receiving them and verifying your user identity, unless local laws and regulations in the location where you use our products and services provide otherwise.