Privacy Policy
What does this Privacy Policy Cover?
JOYPAC respects your privacy and is committed to protecting your Personal Data. We want to be
transparent with you about how we collect and use your Personal Data in making available our
games, (“Site”) and tell you about your privacy rights and how the law protects you. With that in
mind, this Privacy Policy is designed to describe:
Contents
Who we are and how to contact us
Your rights relating to your Personal Data
What Personal Data we collect
How we use your Personal Data and why
What happens when you do not provide necessary Personal Data?
Personal Data from Third Party Sources
How we use cookies & other tracking or profiling technologies
Who we share your Personal Data with
How we keep your Personal Data secure
How long we store your Personal Data
Our policy on children
Third party links
This Privacy Policy aims to give you information on how JOYPAC collects and processes your
Personal Data through your use of this Site, including any data you may provide through this Site.
The Privacy Policy is intended to meet our duties of Transparency under the “General Data
Protection Regulation” or “GDPR”. We will post any modifications or changes to this Privacy Policy
on this page.
Who we are and how to contact us.
WHO WE ARE.
For the purposes of the GDPR, either JOYPAC Ltd (for Android product) or Plusdot Technology
Limited (for iOS product) is the Controller of your Personal Data (referred to as either “JOYPAC”,
“we”, “us” or “our” in this Privacy Policy). Our address is: Suite 1701-02, 17/F, FWD Financial
Centre, 308 Des Voeux Road Central, Hong Kong
HOW TO CONTACT US.
You can contact us by emailing: privacy@joypac.cn.
OUR EU REPRESENTATIVE.
As JOYPAC does not have an establishment in the European Union, we have appointed a
representative based in England, who you may address to raise any issues or queries you may
have relating to our processing of your Personal Data and/or this Privacy Policy more generally.
Our EU representative can be contacted directly by emailing them at the following address:
EURep@joypac.cn.
Your rights relating to your Personal Data.
Under certain circumstances, by law you have the right to:
Request access to your Personal Data. This enables you to receive a copy of the Personal Data we
hold about you and to check that we are lawfully processing it.
Request correction of the Personal Data that we hold about you. This enables you to have any
incomplete or inaccurate information we hold about you corrected.
Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal
Data where there is no good reason for us continuing to process it (including legal requirements to
keep such data). You also have the right to ask us to delete or remove your Personal Data where
you have exercised your right to object to processing (see below).
Object to processing of your Personal Data. This right exists where we are relying on a Legitimate
Interest as the legal basis for our processing and there is something about your particular situation,
which makes you want to object to processing on this ground.
Request the restriction of processing of your Personal Data. This enables you to ask us to suspend
the processing of Personal Data about you, for example if you want us to establish its accuracy or
the reason for processing it.
Request the transfer of your Personal Data . We will provide to you, or a third party you have
chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that
this right only applies to automated information which you initially provided consent for us to use or
where we used the information to perform a contract with you.
Withdraw consent . This right only exists where we are relying on consent to process your Personal
Data (“ Consent Withdrawal ”). If you withdraw your consent, we may not be able to provide you
with access to the certain specific functionalities of our Site. We will advise you if this is the case at
the time you withdraw your consent.
How to exercise your rights.
If you want to exercise any of the rights described above, please contact us using the contact
details shown here. Typically, you will not have to pay a fee to access your Personal Data (or to
exercise any of the other rights). However, except in relation to Consent Withdrawal, we may
charge a reasonable fee if your request is clearly unfounded, repetitive or excessive, or, we may
refuse to comply with your request in these circumstances. We may need to request specific
information from you to help us confirm your identity and ensure your right to access your Personal
Data (or to exercise any of your other rights). This is a security measure to ensure that Personal
Data is not disclosed to any person who has no right to receive it. We may also contact you to ask
you for further information in relation to your request to speed up our response. We try to respond to
all legitimate requests within one month. Occasionally it may take us longer than a month if your
request is particularly complex or you have made a number of requests. In this case, we will notify
you and keep you updated.
Complaints
If you would like to make a complaint regarding this Privacy Policy or our practices in relation to
your Personal Data, please contact us at: privacy@joypac.cn. We will reply to your complaint as
soon as we can. If you feel that your complaint has not been adequately resolved, please note that
the GDPR gives you the right to contact your local data protection supervisory authority. You can
find your data protection regulator here: http://ec.europa.eu/justice/ar… (European Union Data
Protection Authorities)
What Personal Data we collect.
All the Personal Data we collect, both from you and from third parties about you, is outlined in the
table below. Before you read that table, it might be useful to explain what “Personal Data” is. The
GDPR definition of Personal Data can be found here. Essentially, it boils down to: information about
an individual, from which that individual is either directly identified or can be identified. It does not
include ‘anonymous data’ (i.e., information where the identity of individual has been permanently
removed). However, it does include ‘indirect identifiers’ or ‘pseudonymous data’ (i.e., information
which alone doesn’t identify an individual but, when combined with certain additional and
reasonably accessible information, could be attributed to a particular person).
Category of
Personal Data
Collected
Definition
Identity Data
Depending on the game you download, this may include your
first name, surname, last name, username, Game Centre ID,
social network ID such as Google+ (if you sign up that way),
or similar identifier, title, age and gender.
Contact Data
Your email address and telephone numbers.
Transaction
Data
Any details about payments to and from you and other details
of subscriptions and services you have purchased from us
(including in-game purchases). Data in respect of your
transactions with third parties, including payments [in relation
to the JOYPAC games] made through the app store. This
does not include your bank account or payment card details.
Behavioural
Data
Inferred or assumed information relating to your behaviour
and interests, based on your online (including in-game)
activity. This is most often collated and grouped into
“segments”.
Technical Data
Internet protocol (IP) address, your login data, app ID and
version, browser type and version, timestamp, time zone
setting and location, browser plug-in types and versions,
operating system and platform and other technology on the
devices you use to access this website or use our services.
User Content
Data
Any Personal Data that you post on our Site in user-generated
information and content, including in text, photos, videos,
private chats, and feedback.
Aggregated Data
We also collect, use and share “Aggregated Data” such as statistical or demographic data for any
purpose. Aggregated Data may be derived from your Personal Data, but once in aggregated form it
will not constitute considered Personal Data for the purposes of the GDPR as this data does not
directly or indirectly reveal your identity. For example, we may aggregate your Behavioural Data
and Technical Data to calculate the percentage of users accessing a specific Site feature. However,
if we combine or connect Aggregated Data with your Personal Data so that it can directly or
indirectly identify you, we treat the combined data as Personal Data which will be used in
accordance with this Privacy Policy.
No Special Categories of Personal Data
We do not collect any “Special Categories of Personal Data ” about you (this includes details about
your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions,
trade union membership, information about your health and genetic and biometric data). Nor do we
collect any information about criminal convictions and offences.
How we use your Personal Data and why.
We will only use your Personal Data for the purposes for which we collected it as listed below,
unless we reasonably consider that we need to use it for another reason and that reason is
compatible with the original purpose. If we need to use your Personal Data for an unrelated purpose,
we will update this Privacy Policy and we will explain the legal basis which allows us to do so.
What is our “legal basis” for processing your Personal Data?
In respect of each of the purposes for which we use your Personal Data, the GDPR requires us
toensure that we have a “legal basis” for that use. Most commonly, we will rely on one of
thefollowing legal bases: Where we need to perform a contract we are about to enter into or have
entered into withyou (“ Contractual Necessity ”). Where it is necessary for our legitimate interests
and your interests and fundamental rights do not override those interests (“ Legitimate Interests ”).
More detail about the specificlegitimate interests pursued in respect of each Purpose we use your
Personal Data for is set out in the table below. Where we need to comply with a legal or regulatory
obligation (“ Compliance with Law ”). Where we have your specific consent to carry out the
processing for the Purpose in question (“ Consent ”). Generally we do not rely on your Consent as a
legal basis for using your Personal Data. We have set out below, in a table format, the legal bases
we rely on in respect of the relevant Purposes for which we use your Personal Data.
Purpose
Category(ies) of
Personal Data
involved
Why do we do this
Our legal basis for this
use of data
Account
Creation
Identity Data
Contact Data
To register you as a
new customer.
Contractual Necessity.
Game
Operations
Identity Data
Contact Data User
Content Data
Behavioural Data
To allow you to
interact with other
users of our Sites.
To keep improving
our Sites, games,
Legitimate Interests. We
have a legitimate interest
in improving, and
ensuring the proper
operation of, our
our services and
associated systems.
services, Sites and
associated IT services
and networks.
In- game
Purch ase
Identity Data
Contact Data
Transaction Data
To process and
deliver your orders
including manage
in-game purchases.
Contractual Necessity.
Fraud
Prevention
Identity Data
Contact Data
Technical Data
To keep our website,
our services and
associated systems
operational and
secure.
Legitimate Interests. We
have a legitimate interest
in ensuring the ongoing
security and proper
operation of our
services, website and
associated IT services
and networks.
Troubleshoo
ting
Technical Data
To track issues that
might be occurring
on our systems.
Legitimate Interests. It is
in our legitimate interests
that we are able to
monitor and ensure the
proper operation of our
Sites and associated
systems and services.
What happens when you do not provide necessary Personal Data?
Where we need to process your Personal Data either to comply with law, or to perform the terms of
a contract we have with you and you fail to provide that data when requested, we may not be able
to perform the contract we have or are trying to enter into with you (for example, to provide you with
the functionalities of the Site). In this case, we may have to stop you using our Site.
Personal Data from Third Party Sources
In addition to the Personal Data that we collect directly from you (as described in the section
immediately above this one), we also collect certain of your Personal Data from third party sources.
These sources are broken down in the table below, together with a description of whether they are
publicly available or not.
Third party data source
Publicly
available?
Social Media Sites
Yes
Analytics Providers
No
Game Developers – where you
did not download the game
from the JOYPAC sites
No
How we use cookies & other tracking or profiling technologies.
What are cookies? We may collect information using “cookies”. Cookies are small data files stored
on the hard drive of your computer or mobile device by a website. We may use both session
cookies (which expire once you close your web browser) and persistent cookies (which stay on your
computer or mobile device until you delete them) to provide you with a more personal and
interactive experience on our Site. We use two broad categories of cookies: First party cookies,
served directly by us to your computer or mobile device; and Third party cookies, which are served
by our partners or service providers on our Site.
Cookies we use.
Our Site uses the following types of cookies and other tracking technologies for the purposes set
out below:
Type of Cookies
Purpose
Essential
Cookies
These cookies are essential to provide you with services
available through our Site and to enable you to use some of
its features. Without these cookies, the services that you
have asked for cannot be provided, and we only use these
cookies to provide you with those services.
Functionality
Cookies
These cookies allow our Site to remember choices you make
when you use our Site, such as remembering your language
preferences, remembering your login details and
remembering the changes you make to other parts of our
Site which you can customize. The purpose of these cookies
is to provide you with a more personal experience and to
avoid you having to re-enter your preferences every time you
visit our Site.
Analytics and
Performance
Cookies
These cookies are used to collect information about traffic to
our Site and how users use our Site. The information
gathered via these cookies does not “directly” identify any
individual visitor. However, it may render such visitors
“indirectly identifiable”. This is because the information
collected is typically linked to a pseudonymous identifier
associated with the device you use to access our Site. The
information collected is aggregated and anonymous. It
includes the number of visitors to our Site, the websites that
referred them to our Site, the pages they visited on our Site,
what time of day they visited our Site, whether they have
visited our Site before, and other similar information. We use
this information to help operate our Site more efficiently, to
gather broad demographic information and to monitor the
level of activity on our Site. We use Google Analytics for this
purpose. Google Analytics uses its own cookies. It is only
used to improve how our Site works. You can find out more
information about Google Analytics cookies here. You can
find out more about how Google protects your data here. We
also use Baidu Tongji for this purpose. You can find out more
information about how Baidu Tongji cookies here. You can
find out more about how Baidu Tongji protects your
data here . For more information on our use of the Baidu
Tongii services, please contact us here.
Targeted and
Advertising
Technologies
These tracking technologies track your browsing habits to
enable us to show advertising which is more likely to be of
interest to you. They use information about your browsing
history to group you with other users who have similar
interests. Based on that information, and with our
permission, third party advertisers can place cookies and/or
similar technologies to enable them to show adverts which
we think will be relevant to your interests while you are on
third party websites or mobile applications . See “Mobile
Advertising Identifiers” below, for further information on the
targeted and advertising technologies we use on your mobile
applications.
Social Media
Cookies
These cookies are used when you share information using a
social media sharing button or “like” button on our Site or you
link your account or engage with our content on or through a
social networking website such as Facebook, Twitter or
Google+. The social network will record that you have done
this.
Disabling cookies
You can typically remove or reject cookies via your browser settings. In order to do this, follow the
instructions provided by your browser (usually located within the “settings”, “help”, “tools” or “edit”
facility). Many browsers are set to accept cookies until you change your settings. If you do not
accept our cookies, you may experience some inconvenience in your use of our Site. For example,
we may not be able to recognise your computer or mobile device and you may need to log in every
time you visit our Site. Further information about cookies, including how to see what cookies have
been set on your computer or mobile device and how to manage and delete them, visit
www.allaboutcookies.org. In particular, you can disable cookies which remember your browsing
habits and target advertising at you by visiting the Your Online Choices website. If you choose to
remove targeted or advertising cookies, you will still see adverts but they may not be relevant to you.
Even if you do choose to remove cookies by the companies listed at the above link, not all
companies that serve online behavioral advertising are included in this list, and so you may still
receive some cookies and tailored adverts from companies that are not listed. You can also prevent
the use of Google Analytics relating to your use of our Site by downloading and installing the
browser plugin available here.
Web Storage: Local Storage
We may also use local Storage which is a way to store persistent data, such as tracking ID, locally
on your web browser (i.e. information is not transferred to the server). This technology fulfills a
similar purpose as cookies, but is more secure and allows the storage of larger amounts of data.
Blocking/Clearing Local Storage
Same as Cookies.
Clearing Cache and Local Storage:
Chrome Safari Firefox Mobile Advertising Identifiers
We, or third party Ad Networks, may collect, and may associate information with, mobile advertising
IDs (such as iOS Advertising Identifiers and Google’s Advertising IDs) on the Sites. These are
unique identifiers (which are resettable) set by the applicable mobile operating system provider
(“Mobile Advertising IDs”).
How to opt-out of / reset Mobile Advertising IDs
iOS Go to ’Settings’ Scroll down to ‘Privacy’ Scroll down to ‘Advertising’ Shift the ‘Limit Ad Tracking’
slider to the right. Reset your iOS Advertising Identifier: if at any time you wish to reset your iOS
Advertising Identifier, you can do so by replacing the final step with “Click on ‘Reset Advertising
Identifier’”. Android Go to ‘Settings’ Scroll down and click on ‘Google’ Scroll down and click on ‘Ads’
Shift the ‘Opt out of Ads Personalisation‘ slider to the right. Reset your Android Advertising ID: if at
any time you wish to reset your Android Advertising ID, you can do so by replacing the final step
with “Click on ‘Reset advertising id’”. We provide access to our Sites third party Ad Networks and
they will directly collect and process information via the above cookies and other tracking
technologies. This is so Ad Networks can serve you with content that is tailored to your preferences.
Ad Networks are controllers of the Personal Data that is collected in that way (i.e. they decide of the
purposes and means of processing such data, independently of our instructions). For more
information on such AdNetworks’ collection and processing of your Personal Data, please see the
relevant Ad Networks’privacy policies. For ease of reference, we provide here links to such Ad
Networks privacy policies: Unity Ads Admob Vungle AdColony AppLovin Tapjoy Inmobi Facebook
Chartboost Supersonic/ ironSource Mobvista Chance Tencent Redmobi Zplay Adview Kingsoft For
more information on our use of Ad Network services, please contact us here.
Do Not Track Signals
Some Internet browsers may be configured to send “Do Not Track” signals to the online services
that you visit. We currently do not respond to do not track signals. To find out more about “Do Not
Track,” please visit the All About DNT website.
No Cross Device Tracking
Although we collect information via the various “tracking technologies” referred to above – we do
not engage in ‘cross-device tracking’ . This means that we do not link information collected via
multiple identifiers across your different devices and browsers to create a consolidated picture of
your cross-device online activity or behaviour.
Who we share your Personal Data with.
The table below describes who we share your Personal Data with, what we share and why we
share it. Recipients Category(ies) of Personal Data we share. Why we share it Location(s) Game
Developers Identity Data Contact Data Transaction Data Behavioural Data Technical Data Content
Data Game Developers use the JOYPAC services, including to understand how users use their
games, how their games perform, and to optimise their revenue. We share your data with
developers for these purposes. We may also provide support services to game users, in which case
we share data with Game Developers to provide such support. Worldwide Ad Networks Identity
Data Contact Data Behavioural Data Technical Data Content Ad Networks provide us with
advertisement that is tailored to your preferences based on your online behaviour, and JOYPAC
sends them data about you to improve their ability to tailor their offering to you. Worldwide Service
Providers Identity Data Contact Data Technical Data Transaction Data Behavioural Data User
Content Data Our service providers provide us with IT and system administration services. China
USA Japan Hong Kong Professional advisers Identity Data Contact Data Technical Data
Transaction Data Behavioural Data User Content Data Our lawyers, bankers, auditors and insurers
provide consultancy, banking, legal, insurance and accounting services. China Hong Kong
Singapore Revenue & Customs, regulators and other authorities Identity Data Contact Data
Technical Data Transaction Data Behavioural Data User Content Data Authorities may require
reporting of processing activities in certain circumstances. Within Europe China Data transfers
Although we do not have an establishment within the European Economic Area (“Europe”),
because we target the Site at individuals who are located in Europe, the GDPR (which is a
European piece of data protection legislation) applies to us. For this reason, we take appropriate
steps to ensure that when we process your Personal Data (despite the fact that we are not based in
Europe) we do so in accordance with the GDPR. In addition, where we transfer your Personal Data
to any of the third parties outlined above, we also take appropriate steps to ensure that we have
implemented appropriate safeguards to ensure that such protection is maintained and is not
undermined as a result of that disclosure.
How we keep your Personal Data secure.
We have put in place appropriate security measures to prevent your Personal Data from being
accidentally lost, used or accessed in an unauthorized way, altered or disclosed. We limit access to
your Personal Data to those employees and other staff who have a business need to have such
access. All such people are subject to a contractual duty of confidentiality. We have put in place
procedures to deal with any actual or suspected Personal Data breach. In the event of any such
breach, we have systems in place to work with applicable regulators. In addition, in certain
circumstances (e.g., where we are legally required to do so) we may notify you of breaches
affecting your Personal Data.
How long we store your Personal Data.
We will only retain your Personal Data for so long as we reasonably need to use it for the purposes
set out above here, unless a longer retention period is required by law (for example for regulatory
purposes). The table below shows our standard retention practices: Category of Personal Data
Retention Period Behavioural Data To the extent there is any Personal Data in Behavioural Data:
two months from the date on which we collected or received it. However, we only store Behavioural
Data that constitutes Aggregated Data and/or anonymous data, and keep this record forever.
Please refer to our Ad Networks ’ privacy policies for further information on how long they keep your
Personal Data (if any) – see Mobile Advertising Identifiers. Contact Data Identity Data For so long
as retention is necessary to fulfill the Purposes/Use for which it is used here. Transaction Data User
Content Data For 12 months following the discontinuation of the applicable game, or upon request
from the Game Developer (if earlier), unless a longer period is required by law. Technical Data Two
months from the date on which we collected or received it.
Our policy on children.
This Site is not intended for children below 13 and we do not knowingly collect data relating to such
children.
Third party links.
This Site may include links to third-party websites, plug-ins and applications. Clicking on those links
or enabling those connections may allow third parties to collect or share your Personal Data. We do
not control these third-party websites and are not responsible for their privacy statements. When
you leave our Site, we encourage you to read the privacy policy of every site you visit. JOYPAC Ltd,
2019