QINGDAO BLUEFIR Privacy Policy
Last updated July 28th, 2022
PLEASE READ THIS PRIVACY POLICY CAREFULLY. IT DESCRIBES DETAILS ABOUT HOW WE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION YOU SHARE WITH US. IF YOU ARE UNDER 16, DO NOT PROVIDE ANY PERSONAL INFORMATION UNLESS YOU HAVE FIRST OBTAINED YOUR PARENT’S OR GUARDIAN’S PERMISSION.
Thank you for reading our Privacy Policy (“Policy“). We are QINGDAO BLUEFIR INTERACTIVE ENTERTAINMENT TECH CO.,LTD, a company incorporated under the laws of People’s Republic of China ( “QINGDAO BLUEFIR ”, “we” or “us”), who are dedicated to optimizing our products and services as well as protecting the privacy rights of our users (“users“, “user” or “you”). This Policy has been crafted to inform users as to the ways we collect, store, use, and process the information users provide during the use of any of our games or applications (“Services“). It also describes your rights and available choices regarding your personal information.
“Personal information” refers to any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Our primary objective in collecting users’ information is to provide and enhance the Services and to enable users to easily navigate and enjoy the Service. By using our Services and providing us with information, you agree to be bound by this Policy.
We reserve the right to amend the Policy from time to time, and we encourage you to consult the Policy regularly for the latest version.
CONTENT
Information Collection and Purposes
Information Disclosure & Sharing
Your California Privacy Rights
Information Collection and Purposes
The information we collect and the purpose of the collection and processing are described below.
We use your personal information to provide products and services you ask for, to communicate with you, to improve our services, and for other purposes including those set out below. From time to time we may change the information requested upon registration or with respect to certain features or services and we will update the information below in such case. Therefore, we recommend that you regularly check this Policy.
For purposes of the “General Data Protection Regulation” (“GDPR”) and other relevant laws, the QINGDAO BLUEFIR is the Controller for our online and mobile game applications including, but not limited to, “Army Men Strike”. You may be entitled by the privacy laws of your jurisdiction with the right to object to processing by contacting us as indicated in the “Contact Us” section of this Policy. When you are in the European Union, the GDPR applies to our collection and processing of your personal information.
Personal information does not include “aggregate” information, which means collective data that relate to the use of the Service or a group or category of products, services or users and does not indicate individual identities of particular users. Aggregate information helps us understand business trends and users’ needs so that we can better update our products or tailor our Service for users. This Policy in no way restricts or limits our collection and use of aggregate information.
Information You Voluntarily Provide:
l Login Information
You have two options to log in to our Services:
– You may log in to our Services using social media accounts, such as Facebook, Google, Apple Game Center, Amazon, Microsoft(“Social Networks”).
– Alternatively, you may log in to our Services using an account you already have create directly with us (“QINGDAO BLUEFIR ID”).
If you log in to our Services using Social Network accounts, we process personal information you authorized the Social Networks to share with us to sign up for our Services. Exactly what information we receive from the Social Networks may vary due to your privacy settings on such Social Network, but it would typically include your basic public profile information such as
– Username
– Profile picture
– Information you have permitted the Social Networks to share with us
– Information you have made public on the Social Networks
Please be aware that such Social Networks are governed by their own privacy policies, terms and end-user agreements. We are not responsible for and have no control over, the sharing practices or policies of the third parties that operate those sites.
If you log in to our Services using a QINGDAO BLUEFIR ID, we process the following personal information:
– E-mail address
– Password
– Verification code
We process the same personal information, when you deactivate your account.
When first setting up a QINGDAO BLUEFIR ID or when you decide to deactivate your account, we will send you an e-mail to the e-mail address provided. This e-mail will include a verification code, which we will ask you to provide to verify the validity of your e-mail address and then set up or deactivate the QINGDAO BLUEFIR ID. After your confirmation, we will save the data you provided as well as the date and time of the confirmation e-mail.
We collect and process the login information for the purpose of creating your account in our Services per your request. For users located in the EU (hereinafter “EU users”), we consider the login information as necessary for the performance of our Services in line with Art. 6 (1) (b) of the GDPR. Where the processing is not necessary for the performance of our Services, your consent to such processing will be requested to the extent required by applicable law. In this case, we process your personal information in line with Art. 6 (1) (a) of the GDPR.
l Using our Services without Logging in
You can use our Services without logging in or creating an account with us, but all data relating to the game will become unavailable to you, if you de- or re-install the Services or replace, lose or damage the device on which you use our Services. Under this circumstance, we may also collect your personal information. Please refer to “Information You Voluntarily Submit” “Information You Submit to Our Support Team” “Information We Automatically Collect” “In-Game Information” “Information Collected to Prevent Cheating and Unauthorized Use” “Information We Obtain from Third Party Sources” and other sections in this Policy for further reference.
l Information You Voluntarily Submit.
Within our Services, you may opt to provide us with other personal information. For example:
– Birth Date: we will send you in-game birthday gift via our in-game mail system according to the birth date information you voluntarily submit. We will not use your Birth Date information for any other purposes. We will not be able to send you such a birthday gift without your birth date information, but it will not prevent you from using our other Services.
We do not collect such personal information about you except when you specifically provide such information to us on a voluntary basis. For EU users, we collect and process your birthdate to send you the in-game birthday gift in line with art. 6.1(b) of the GDPR.
l Information You Submit to Our Support Team.
We collect and process the information you submit to our support team to provide technical support, customer service support per your request so as to ensure the continued smooth operation of our Services. For EU users, we consider such information as necessary for the performance of our customer service, in line with Art. 6 (1) (b) of the GDPR. Where processing is not necessary for the performance of our Services, your consent to such processing will be requested to the extent required by applicable law. In this case, we process your personal information in line with Art. 6 (1) (a) of the GDPR.
Information We Automatically Collect:
l Internet Protocol (IP) Address and Broad Geographic Location Based on the IP Address
We collect and process the IP Address and broad geographic location based on the IP Address to ensure the continued smooth operation and security of our Services. For EU users, we consider such information as necessary for the performance of our customer service, in line with Art. 6 (1) (b) of the GDPR.
The IP Address will also be used to measure our advertising effectiveness as well as prevent fraud for our advertising campaigns. For EU users, we see such collection and processing as the pursuit of our legitimate interests, in line with Art. 6 (1) (f) of the GDPR. Where we cannot rely on legitimate interests in a particular case, your consent to such processing will be requested to the extent required by applicable law. In this case, we process your personal information in line with Art. 6 (1) (a) of the GDPR.
We will not collect your precise location data unless you give us the permission to access the location of your device.
l Device Information.
We may collect the information of your device type, producer, operating system, language or other technical data for checking the device compatibility with our Services. We may also collect device identifiers, device sensor information (gyroscope, acceleration sensor, direction sensor, gravity sensor)，such as the universally unique identifier (UUID) as well as Advertising IDs. The device identifiers help you log in faster and enhance your navigation through the Service. Some features of the Services may not function properly if use or availability of device identifiers is impaired or disabled.
For EU users, we see such collection and processing as the pursuit of our legitimate interests, in line with Art. 6 (1) (f) of the GDPR. Where we cannot rely on legitimate interests in a particular case, your consent to such processing will be requested to the extent required by applicable law. In this case, we process your personal information in line with Art. 6 (1) (a) of the GDPR.
l In-game Information.
– In-game profile picture, username and profile ID
– Your access, participation, performance and achievements in the Services
– The chat log and message you communicated or posed in the Services
– Purchase or transaction record in the Services but no billing information
– Log information and online records, such as the date and time of your visit, click records, game metrics and usage data, processand breakdown records, and other standard server log information.
We collect and process the in-game information to keep the record of your account and to enhance the functionality of our Services. For EU users, we see such collection and processing as the pursuit of our legitimate interests, in line with Art. 6 (1) (f) of the GDPR. Where we cannot rely on legitimate interests in a particular case, your consent to such processing will be requested to the extent required by applicable law. In this case, we process your personal information in line with Art. 6 (1) (a) of the GDPR.
l Information Collected to Prevent Cheating and Unauthorized Use. To detect cheating or unauthorized and malicious programs, when you use our Service, we may access, collect, monitor information relating to purchase and transaction history, in-game performance, modifications related to our game functions, files or processes that enable or facilitate cheating, unfair advantage or hacking of the games or Service. If circumstances suggesting unauthorized or malicious programs are detected, we will send the user a “Cease and Desist Letter” via in-game mail.
We collect and process such information to investigate or prevent cheating, unauthorized use, suspected fraud, infringement or other misconduct in any of our Services. For EU users, we see such collection and processing as the pursuit of our legitimate interest, in line with Art. 6 (1) (f) of the GDPR. Where we cannot rely on legitimate interests in a particular case, your consent to such processing will be requested to the extent required by applicable law. In this case, we process your personal information in line with Art. 6 (1) (a) of the GDPR.
l Information Collected to Measure Advertising Effectiveness. To measure advertising effectiveness as well as prevent fraud for our advertising campaigns, we may use your IP address, your in-game behaviors and your in-app purchases or transactions.
For EU users, we see such collection and processing as the pursuit of our legitimate interests, in line with Art. 6 (1) (f) of the GDPR. Where we cannot rely on legitimate interests in a particular case, your consent to such processing will be requested to the extent required by applicable law. In this case, we process your personal information in line with Art. 6 (1) (a) of the GDPR.
Information We Obtain from Third Party Sources
We may receive personal information about you from third-party sources. For example, when you download and install our Services and prior to the installation you have clicked an advertisement to direct you to our Services, we will be provided with information from which ad network and advertising campaign the install originated from.
We collect and process such information to market games to potential new users and measure advertising effectiveness as well as prevent fraud for our advertising campaigns. For EU users, we see such collection and processing as the pursuit of our legitimate interest, in line with Art. 6 (1) (f) of the GDPR. Where we cannot rely on legitimate interests in a particular case, your consent to such processing will be requested to the extent required by applicable law. In this case, we process your personal information in line with Art. 6 (1) (a) of the GDPR.
No Credit Card or Billing Information
Our Services enable in-app purchases and we may collect your purchase and transaction record in the Services to deliver the in-app products or services to you. However, we do not process the payments for in-app purchase nor do we have any access to your credit card information or billing information. Payment transactions for in-app purchases in our Services are completed via Google or Apple or other app stores/platforms. Any post-purchase processes are controlled by those app stores/platforms and are subject to their specific terms. Please review the privacy policy and terms of service of the app stores/platforms you choose.
Third Party Advertisements
We may include third parties (“Advertising Company”) to distribute their advertisements in our Services. We will not transfer or share any of your personal information with such Advertising Company, as we do not collect or process any extra personal information for the purpose of Advertising Company advertisement service. Advertising Company is an independent controller of the personal data processed in order to provide its advertisement service that it will individually determine the purposes and means of processing such data. Such data refers to any information or data that Advertising Company collects via its own tools (e.g., Software Development Kits or “SDK”) implemented in our Services. Please be aware that in no event will Advertising Company and us process personal data as joint controllers.
You will find a list of advertising SDKs implemented in our Services and we recommend you read and learn more about such Advertising Company’s privacy policy:
l Applovin
Applovin is an advertising service. For more information on how Applovin uses the collected information, please visit the Privacy Policy of Applovin: https://www.applovin.com/privacy/
Cookies
Cookies are small text files in which information is stored in connection with the Internet pages called up and stored by your browser on your system for their respective lifetime when you visit our websites. We use cookies to offer our service in a functional and user-friendly form. These cookies are strictly necessary for enabling your movement and providing our website service. These cookies do not gather information about you that could be used for marketing purposes and do not remember where you have been on the internet.
We use a cookie notice banner that informs you of our cookies and request your consent if applicable when you visit our website. Strictly Necessary Cookies should be always active so that we can save your preferences for cookie settings. You can disable this cookie in the settings of browsers. If you disable this cookie, we will not be able to save your preference and you may not use some functions in our websites.
In so far as personal information are processed by cookies, the associated processing serves to safeguard our legitimate interests (Art. 6 (1) (a) of the GDPR) in the provision of our services and their optimization.
For more information about our use of cookies, please refer to our Cookie Policy.
Information Disclosure & Sharing
To fully provide you with successful operation and all functions of our Services, we must share collected information with third parties under certain circumstances. We may share collected information with third parties for the purpose of developing and delivering our Services, conducting analysis and research and for measuring our advertiser’s ad campaign performance. We will share third parties with your personal information only in the ways that are described in this Policy. From time to time, we may also share third parties with your personal information when you give us your consent to do so.
For the performance of a contract with you, compliance with your consent, or based on our legitimate interests, we may disclose/share your personal information:
With Our Service Providers
We may share personal information with vendors, consultants and other service providers (“Service Providers”) such as our customer support providers, content pull-in service providers, internet access services providers and cloud service providers who are engaged by or working with us in connection with the operation of the Service and who need access to such information to carry out their work for us. We provide the personal information to other trusted partners to process it for us, based on our instructions and in compliance with appropriate confidentiality and security measures.
With Our Analytics Providers
We may use or link to third-party platforms or other services, including websites or other forms of service:
1. You can use “Share” button to share some of our products or services with third-party services. These functions may collect your information, including your log information, and may install COOKIES in your device to function properly;
2. We provide you with links through advertisements or other types of our services so that you can link to third-party services or websites;
3. Other situations of accessing third-party services. For example, in order to achieve the purposes stated in this policy, we may access third-party SDKs or other similar applications, such as embedded codes, plug-ins, etc., to provide you with better customer service and user experience. At present, the SDKs we use mainly include the following types:
(1) Advertising-related services, including advertising display, advertising data monitoring/statistics, etc.;
(2) Message push function, including mobile phone manufacturer push, specific event reminder, personalized content recommendation, etc.;
(3) Payment-related services, including order payment, transaction behavior verification, income settlement, payment information summary statistics, etc.;
(4) Collecting device location permissions, device information and log information, etc. with your consent;
(5) Third-party authorized services, including third-party account login, sharing relevant content to third-party products, etc.;
(6) Data statistical analysis services, including collecting device identification information, device model, operating system version, etc.;
(7) Supporting product functional modules, including voice recognition, intelligent customer service, content storage, experience web browsing and video viewing services, etc.;
(8) Sharing and pushing functional services, including identifying device identification information, network-related information, geographic location and other information;
(9) Optimizing product performance, including monitoring client crashes, abnormal pages, improving hardware distribution network capabilities, reducing server costs, and hot-fixing functions;
(10) Account security and product reinforcement related services, including network monitoring, domain name resolution, anti-hijacking, anti-spam and anti-cheating, encryption and decryption services, etc.
Some third-party SDKs or similar applications that we access may collect your personal information. For example, when you use such third-party services in our services, you agree that your information will be directly collected and processed by them. We will evaluate the legality, legitimacy, and necessity of personal information collected by such third-party services, require such third parties to take protective measures for your personal information, and strictly abide by relevant laws, regulations and regulatory requirements. The following are third-party service providers that we may use, and you may refer to details of the services they provide at the corresponding websites. You may also contact us through the feedback channels listed in the “Contact Us” section of this policy, and we will respond to you as soon as possible.
- AppsFlyers: https://www.appsflyer.com/legal/privacy-policy/
- Facebook: https://www.facebook.com/about/privacy/previous
- Google Pay: https://policies.google.com/privacy
The services of the above third-party platforms are operated by the relevant third parties. Your use of such third-party social media services or other services, including any information you provide to such third parties, is subject to the third party’s own terms of service and information protection statement (not this Policy). You need to carefully read its terms. This Policy applies only to the personal information we collect and does not apply to the information usage rules of any third-party platform. If you find that these third-party platforms have risks, it is recommended that you terminate the relevant operations to protect your legitimate rights and interests and contact us.
With Our Affiliates
We may share personal information with our parent company and affiliated companies. Such companies will use your personal information in the same way as we can describe under this Policy.
Due to Merger, Acquisition and Other Similar Change of Ownership Events
In the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, information we collect, including the personal information, may be transferred to our successor or assignee, if permitted by and done in accordance with applicable law.
In Response to Our Legal Obligations
Please note that we are not required to question or contest the validity of any search warrant, subpoena or other similar governmental request that we may receive. We reserve the right to disclose your personal information when required to do so by law, such as to comply with legal process, including but not limited to a search warrant, subpoena, statute, or court order, or to protect our rights and property, or that of the public, regardless of whether the public authorities are within or outside your country of residence. We may disclose part or all of the personal information in the good faith belief that such disclosure is reasonably necessary to avoid liability in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms and Conditions, or as otherwise required by law.
Data Transfers
Your personal information will be accessible from and will be stored and processed in our server in the People’s Republic of China. As our Services are available to worldwide users, your personal information may be transferred to and/or processed in countries or regions other than the country where you reside. Although the data protection laws of such countries or regions may be of lower standard than that of the European Union. We will, however, ensure that your personal information set out in this Policy will remain protected in accordance with this Policy. Where we transfer personal information from inside the European Union to outside the European Union, we may be required to take specific additional measures to safeguard the relevant personal information. We will establish legal grounds justifying such transfer, such as EU Commission-approved model contractual clauses, or other legal grounds permitted by applicable legal requirements.
Links
The Services may contain links to other websites or be accessible from third-party platforms. The fact that the Services link to a website does not mean that we endorse or authorize that third party, nor is it a representation of our affiliation with that third party. We are not responsible for the privacy policies of other websites to which users choose to access or platforms from which the Service is accessible. We encourage you to learn about their privacy and security practices and policies before providing them with your personal information.
Game Updates
When we update or “patch” any of our games or other software, we may utilize a patch routine to verify whether the most recent version is installed on your device. If not, the most recent version may automatically be downloaded to your device, and you hereby consent to, and waive any further notice of, such upload. When you download a game, in order to be able to use the game, the software may monitor and communicate information from your device relating to hardware capacity.
Notifications
We may send push notifications to your mobile device to provide game updates and other relevant messages. You can manage push notifications from your mobile device’s settings page for the relevant game and/or from the settings page within the relevant mobile game. We may also send local notifications to your mobile device to provide game updates and other relevant information. You can manage local notifications from your mobile device’s settings page for the relevant game and/or from the settings page within the relevant mobile game.
Furthermore, we may notify you via e-mail of our special offers, game news, event information and other promotional information about our products and services. If you do not want to receive such emails, you can opt-out by clicking the unsubscribe links included in each promotional email. However, this shall not affect our ability to send you service and account related emails or to use your personal information as otherwise described in this Policy.
Your Choices and Control
You may be able to adjust the privacy settings of your device for push notifications, and other information or features within the Services or the access permissions to your device. You can find more information under “Push Notifications” and the settings of your device.
Please keep in mind that you may be required to create a Google account or an Apple Game Centre ID or other app marketplaces account in order to use certain functions of the Services. Your personal information will be processed as described in the privacy policies of such app marketplaces. You have the right to request from such app marketplaces access to and rectification or erasure of your personal information collected by such app marketplaces.
You may be entitled with rights in connection with your personal information by the privacy laws of your jurisdiction. Such rights often vary by jurisdiction, which may include:
l Right to access. You have the right to access the personal information we hold about you and other relevant usage and processing information.
l Right to rectify. You have the right to correct the personal information we hold about you that is inaccurate.
l Right to erasure. You can delete your account, or remove certain personal information that we hold about you. However, please note that we may be required to retain some personal information by data protection laws or laws in other fields (e.g., for the defense of legal claims).
l Right to object. You have the right to object to our processing of personal information about you. You also have the right to lodge a complaint about our processing activities carried out by us before the competent supervisory authority.
l Right to restrict processing and withdraw your consent. You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. If we stop processing the personal information, we may use it again if there are valid grounds other than your consent, for example, when the processing is necessary to fulfil the obligations of a contract, processing is necessary to protect the vital interest of you or another natural person, or other legitimate reasons under data protection laws.
l Right to portability: You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent or pursuant to our contract with you, as described in the section “Information Collection and Purposes”. However, please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (e.g. where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).
You may enforce such rights via the methods provided under the heading of “Contact Us”. To help us verify that you are the subject of the personal information and realize your rights above, we may require you to provide sufficient proof of identification as we request, and we reserve the right to deny access to any user if we believe there is a question about your identity. We aim to respond to all access requests within one month or such other period provided for by law and will let you know with the reason if we need more time to respond to your request.
Data Retention
Our retention periods for personal information are based on business needs and legal requirements. We retain your personal information for as long as is necessary for the processing purpose(s) for which the information was collected or until we discontinue our Services, whichever occurs earlier. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. When personal information is no longer needed, we either irreversibly anonymize the data (and we may further retain and use the anonymized information) or securely destroy the data.
Security
We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. However, we cannot guarantee that unauthorized third parties will never be able to overcome those measures or use users’ personal information for improper purposes. Also please note that email and messaging systems are not considered secure, so we discourage users from sending us personal information through these mediums.
Policy Regarding Children
Children under the age of 16 are not eligible to use our Services. The Services are not directed to children under 16. If we discover that we have inadvertently collected information from children under 16, we will delete the child’s information from our systems as soon as possible in accordance with applicable law. If you become aware that personal information about a person under 16 has been provided to us, please immediately Contact Us.
Contact Us
If you have any unresolved privacy concern that we have not addressed satisfactorily in this Policy or any question, comment on this Policy or wish to realize any of your right described in this Policy, please contact us at:
E-mail: support@kunpo.cc
Please include the relevant information such as game name, server number (if any) and your nickname in your email, so that we could provide you more timely and appropriate support.
Your California Privacy Rights
California Consumer Privacy Act. While we have tried to fully describe our data practices elsewhere in this Privacy Policy, this section supplements the description of our information collection and sharing practices elsewhere in this Policy to provide certain disclosures to certain California residents whose personal information QINGDAO BLUEFIR processes pursuant to the California Consumer Privacy Act (“CCPA”).
During the preceding 12 months, QINGDAO BLUEFIR has collected, used, and shared the categories of personal information described in the section of our Privacy Policy entitled, “Information Collection and Purposes” For example, depending on the Services you use, this may include your identifiers (e.g., IP addresses and mobile device identifiers), commercial information, visual information (e.g., photos of yourself if you upload them), registration information (e.g., email address), Internet and other electronic activity information as well as inferences we draw from the other information we collect.
As described in our Privacy Policy, we disclose personal information to third parties for various business purposes, including without limitation, for purposes of advertising, marketing, and other services performed on our behalf, to protect against fraud and malicious activity, and for other business purposes described in this Policy. In addition, your information may be accessible to third parties with whom you interact or direct us to share your information through our services. While your information is shared in these ways, we do not share information in a manner that we consider a “sale” of personal information for purposes of the CCPA.
We provide you certain of the rights described in the section, “Your Choices and Control” above in accordance with state law, including the right to access your data, the right to correct your data, the right to have your data deleted and the right to take your data with you. We will not charge you different prices or provide different quality of services unless those differences are related to your information or otherwise permitted by law. Please submit your request by sending an email to support@kunpo.cc. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity, including by asking you to verify information about your use of the Service. If you would like to use an agent registered with the California Secretary of State to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf.