Privacy Policy
1. INTRODUCTION
1.1 This Privacy Policy (“Policy”) sets out the basis which Artyfact Ltd. (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our users in accordance with the Applicable privacy laws and regulations (“Privacy Laws”). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organizations which we have engaged to collect, use, disclose or process personal data for our purposes.
1.2 We take its obligations under applicable privacy laws and regulations ("Privacy Laws") seriously and is committed to respecting the privacy rights of all users of ours' products, websites and mobile applications ("Websites") (collectively, the "Services" or the “Game”).
1.3 User means an individual who registers for an account or otherwise uses or accesses the Services through the platform or means provided by us (individually and collectively, "User", "you" or "your");
1.4 We recognize the importance of the personal data you entrust to us
and consider it our responsibility to properly manage, protect and
process your personal data. This Policy is intended to help you
understand
- When will we collect your personal data;
- Categories of information we collect;
- Cookies
- How we use your information;
- How we share, transfer and disclose your personal information;
- Withdrawing your consent;
- Access to and correction of personal data;
- Protection of personal data;
- Accuracy of personal data;
- Retention of personal data;
- Information about children;
- Your rights. (intended to help users residing in the European Union
("EU") understand their applicable data privacy rights that exist under
the EU General Data Protection Regulation when using the Services.)
- Transfer personal data outside country, where our company is
registered; and
- Revision of the Policy, Dispute Resolution and Contact.
2. WHEN WILL WE COLLECT YOUR PERSONAL DATA
2.1 We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after we notify you of the purposes for collecting the information and (ii) obtain your (or your authorized representative's) written consent, or (b) collection and use of personal data without consent is permitted or required by the PRIVACY LAWS or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
2.2 We may collect your personal data:
(a) when you register for the Services (including your nominated
nickname, or accounts and information we import from your connected
social media account (Facebook, Google, etc.) in order to set up your
profile, including your name as it appears on your social media profile
and your profile picture);
(b) when you log-in as a ‘guest’ in order to use the Services (your
nickname);
(c) when you participate in a survey in the Services (in which case we
will process the information you provide to us as part of the
survey);
(d) when you transact through our Services (if applicable) or with our
third party payment service providers authorized by us.
(e) when you link your Account with Your Social Media Accounts
(Facebook, Google, etc.) or other external accounts or use other social
media functions in accordance with Provider's policies.
(f) when you use our Services, or interact with other users and/or us
through our Services. This includes, but is not limited to, the cookies
that may be generated when you interact with us.
3. CATEGORIES OF INFORMATION WE COLLECT
3.1 We will/may collect and use your personal data:
(a) Account Creation Information: Upon creating a Account, we may gather
details such as username, birthdate, age, gender, email address, phone
number, password, verification code, and open id, to assist in
establishing and managing your account for our Services, offering game
login Services, and for additional purposes outlined in this Policy.
(b) Personal Profile Data: You have the option to create personalized
profiles (where applicable) in our Services by selecting a nickname,
crafting a personal signature, uploading an avatar, and providing other
relevant details based on our service setup.
(c) Chat Records: If you utilize chat functions in our Services (e.g.,
in-game chat), we may process the communication log and apply end-to-end
encryption to safeguard your information.
(d) Survey Responses: If you participate in our surveys, we will gather
your responses.
(e) Participation Information for Events and Promotions: If you choose
to take part in any events or promotions organized by us (such as
campaigns), we may collect information related to your participation,
including your name, your user id, email address, mobile phone number,
nickname, and country/region. In case you win any prizes, you may also
need to provide us with your mailing address so that we can send you the
prize. Your participation information may be added to your Account.
(f) Game Data: We collect information about your in-game experience
points, game progress, your level, score, and user statistics, and other
similar data generated while using our Services. This information helps
us understand your gaming preferences, provide personalized feedback,
and enhance your overall experience with our Services.
(g) IP Address, Location Information, and related Device Information: We
collect information like IP address, location data such as geographical
location, network status information, and device information such as
device ID, device name, device type/model, MAC address, IMEI data, CPU
data, graphics card model, OS version and language, time zone, screen
DPI, device resolution, memory data, and graphics card model.
Additionally, we gather information related to bugs, errors, crashes,
and diagnostics, including registration/login time, game version, stack
trace, crash reports, and abnormal process data to better understand
your device, usage patterns, and location.
(h) Advertisement ID: We store the Advertising ID and select device
information for each advertisement, along with your profile, to monitor
the effectiveness of our advertising and marketing campaigns.
Furthermore, we may use your de-identified email address, including
those collected from third-party social media providers when you log in
via your social media account(s), to track the success of our
advertising and marketing campaigns after implementing appropriate
technical security measures.
(i) Transaction Information: If you choose to make purchases using your
Account, we may need to collect your payment data and the data generated
from such transaction information, such as points and membership level,
to process the purchase(s) and related activities, which could include
your name, bank/debit/credit card number, card expiration date, billing
address (country, city, postal code, address), and CVV.
(j) Customer Support Ticket ID & User Communications with Support: We
collect information related to your support requests, including ticket
ID and your communication history with our support team, to better
assist you and improve our Services.
(k) Marketing and Communication Data: We collect information about your
preferences for receiving marketing materials, your communication
preferences, and your communication history with us and our service
providers, to tailor our communications with you and enhance your user
experience.
(l) Security-Related Information: We collect, and process data related
to the security of your account and our Services, such as password
changes and login history, to ensure the safety and integrity of our
platform.
(m) Anti-Cheating and Fraud Detection: We may collect certain data and
utilize various methods to detect and analyse instances of cheating or
fraud within the Services. These methods include but are not limited to
monitoring the presence of external programs that may affect the
Services, identifying attempts by external programs or plugins to access
the Services, and other similar techniques aimed at ensuring the
integrity of gameplay. The collected data is used solely for the purpose
of detecting and preventing cheating and fraud, with the objective of
providing a fair gaming experience for all users.
(n) Other Information: We may collect additional information as required
by specific Services or features within our platform. In such cases, we
will provide separate privacy notices detailing the collection and usage
of this information.
In order to provide you with a comprehensive gaming experience, we may
merge and update our collected personal data with data from third-party
contractors to update your profile (e.g., the information of your
connected third-party accounts), perform market analysis, and/or for
other purposes set forth in Policy, with your prior consent or where we
have other legal grounds permissible under applicable laws.
When you use or interact with third-party Services that may be available
on our Services, such as third-party social media widgets, share
buttons, and/or login mechanisms, this Policy does not and will not
extend to such features, which shall be subject to the respective
third-party privacy policies.
3.2 Data we collect from our partners:
(a) If you opt to access our Services using your social media
account(s), we might receive your social media account data from
third-party social media providers. The information obtained will be
integrated with your account information.
(b) Demographic data (such as to determine the coarse location of your
Ip address)
(c) Data to fight fraud (such as refund abuse in games or click fraud in
advertising)
(d) Data from platforms that the games run on (such as to verify
payment)
(e) Data for advertising and analytics purposes, so we can provide you a
better Service
4. COOKIES
We use cookies and other similar technologies (e.g., web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Services. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality. You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies, or instruct the device (in the case of the Game) to provide notice at the time of installation of cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event of your refusal to install cookies, the Game may be unable to operate as designed.
5. HOW WE USE YOUR PERSONAL INFORMATION
5.1 We will/may use the information for the following purposes:
5.1.1 to create your account for the Game in accordance with your
request;
5.1.2 generate username and open id, to store your Game data (including
level and progress) with your profile;
5.1.3 To contact or communicate with you by telephone, SMS and/or fax
messages, email and/or postal mail or other means to manage and/or
administer your relationship with us or your use of our services;
5.1.4 to maintain a record of your transaction history;
5.1.5 to manage, operate, provide and/or administer your use of and/or
access to our Services (including, without limitation, your
preferences), as well as your relationship and Account with us;
5.1.6 for identification and/or verification; (where applicable)
5.1.7 to conduct research, analysis and development activities
(including, but not limited to, data analytics, surveys, product and
service development and/or profiling), to analyse how you use our
Services, to improve our Services or products and/or to enhance your
customer experience;
5.1.8 If you enable chat services (audio or text) then we will process
such data in order to deliver your messages to other users;
5.1.9 for security and verification purposes; identify and address bugs
and assess game function for optimize action; anti-hacking, solve game
crashes and optimize compatibility of devices with the game; and to
combat users registering for multiple accounts;
5.1.10 To provide country/region leader board rankings or any other
similar features or functions, we may determine your country/region
based on your IP address.
5.1.11 to store, host, back up (whether for disaster recovery or
otherwise) of your personal data, whether within or outside of your
jurisdiction;
5.1.12 to carry out due diligence or other screening activities
(including, without limitation, background checks) in accordance with
legal or regulatory obligations or our risk management procedures that
may be required by law or that may have been put in place by us;
5.1.13 to respond to legal processes or to comply with or as required by
any applicable law, governmental or regulatory requirements of any
relevant jurisdiction, including, without limitation, meeting the
requirements to make disclosure under the requirements of any law
binding on us or related corporations or affiliates;
5.1.14 for marketing and, advertising for any marketing activities where
permissible under applicable law, and in this regard, to recommend
products and/or services relevant to your interests, to send you by
various mediums and modes (including email or SMS) of communication
marketing and promotional information and materials relating to products
and/or services (including, without limitation, products and/or services
of third parties whom We may collaborate or tie up with) that We (and/or
its affiliates or related corporations) may be selling, marketing or
promoting, whether such products or services exist now or are created in
the future. You can unsubscribe from receiving marketing information at
any time by using the unsubscribe function within the electronic
marketing material. We may use your contact information to send
newsletters or marketing materials from us and from our related
companies;
5.1.15 other purposes which are permissible under applicable law and
which we notify you of at the time of obtaining your consent.
5.2 Such purposes may not be the case because the purposes for which we
will collect/may collect, use, disclose or process your personal data
depend on the circumstances at hand. However, unless Privacy Laws permit
processing of applicable data without your consent, we will notify you
of other purposes at the time we obtain your consent.
6. HOW WE SHARE, TRANSFER AND DISCLOSE YOUR PERSONAL INFORMATION
6.1 Share
We value the protection of your personal information, which is an
important basis and part of the products and services we provide to you.
We will only collect and use your personal information for the purposes
and within the scope of this Policy or as required by law and
regulations, and will keep it strictly confidential. In general, we will
not share your personal information with any company, organization or
individual, except in the following cases:
(a) with your prior consent;
(b) where the sharing of your personal information is required by
applicable law, regulation, legal process, governmental compulsion or
judicial decision;
(c) to the extent required or permitted by law, it is necessary to
provide your personal information to third parties in order to protect
us, its users or the public from harm to their interests, property or
safety;
(d) your personal information may be shared among our affiliated
companies. We will only share personal information that is necessary and
such sharing is subject to the stated purposes of this Policy. If an
affiliate wishes to change the purpose of processing personal
information, it will again seek your authorized consent;
(e) in order to provide you with improved, quality products and
services, some of our Services will be provided by authorized partners.
We may share some of your personal information with our partners in
order to provide better customer service and user experience. We will
only share your personal information for purposes that are legal,
legitimate, necessary, specific, and explicit, and only as much personal
information as is necessary to provide the services. We also require our
partners to handle your personal information in accordance with our
instructions, this Policy, and any other relevant confidentiality and
security measures. Our partners are not authorized to use the personal
information shared for any other purpose. If you refuse to allow our
partners to collect the personal information necessary to provide the
service, you may not be able to use that third party service on our
platform.
The collection and processing of information by our partners is subject
to their own privacy policy or related statements, which do not apply to
this Policy. In order to maximize the security of your information, we
recommend that you review the privacy policy of any third party service
before using it. To protect your legitimate rights and interests, if you
find that the relevant third-party services have risks, we recommend
that you immediately terminate the relevant operations and contact us in
a timely manner. We currently have access to the following third-party
partner permissions:
6.2 Transfer
We will not transfer your personal information to any company,
organization or individual, except for the following:
(a) Transferring with obtaining explicit consent: after obtaining your
explicit consent, we will transfer your personal information to other
parties;
(b) Provision in accordance with applicable laws and regulations,
requirements of legal proceedings, and mandatory administrative or
judicial requirements as may be necessary;
(c) In the event of a merger, acquisition, transfer of assets,
bankruptcy and liquidation or similar transaction involving the transfer
of personal information, we will require the new company or organization
holding your personal information to continue to be bound by this Policy
before we require the company or organization to seek your authorized
consent again.
6.4 Without Your Prior Consent
In accordance with relevant laws and regulations and national standards,
we may share, transfer, and publicly disclose personal information
without obtaining your prior authorized consent in the following
cases:
(a) In connection with the performance of our obligations under laws and
regulations;
(b) Directly related to national security and national defence
security;
(c) Directly related to public safety, public health, and significant
public interests;
(d) Directly related to crime investigation, prosecution, trial and
execution of judgments, etc.;
(e) For the purpose of safeguarding the life, property and other
significant legitimate rights and interests of the subject of personal
information or other individuals but where it is difficult to obtain his
or her consent;
(f) Personal information disclosed to the public by the subject of the
personal information himself/herself;
(g) Personal information collected from information that is legally and
publicly disclosed, such as legal news reports, government information
disclosure and other channels.
In accordance with the law, sharing, transferring or publicly disclosing
personal information that has been de-identified to the extent that the
data recipient is unable to recover and re-identify the information
subject shall not be deemed as sharing, transferring or publicly
disclosing personal information, and such data shall be stored and
processed without notice to or consent from you.
7. WITHDRAWING YOUR CONSENT
7.1 The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
7.2 Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within thirty (30) business days of receiving it.
7.3 Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing Services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in Provision 15.4.
7.4 Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under Applicable Laws.
8. ACCESS TO AND CORRECTION OF PERSONAL DATA
8.1 If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
8.2 Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
8.3 We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the Privacy Laws).
9. PROTECTION OF PERSONAL DATA
9.1 To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, data anonymisation, up-to-date antivirus protection, regular patching of operating system and other software, securely erase storage media in devices before disposal, web security measures against risks, usage of one time password(otp)/2 factor authentication (2fa)/multi-factor authentication (mfa) to secure access, and security review and testing performed regularly.
9.2 You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
10. ACCURACY OF PERSONAL DATA
We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
11. RETENTION OF PERSONAL DATA
11.1 We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
11.2 We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
12. INFOMATION ABOUT CHILDREN
12.1 This service is not targeted at children under the age of 13. We do not knowingly collect or maintain personal data or non- personally identifiable information about any person under the age of 13, nor is any part of our website, games or other services targeted at them.
12.2 As a parent or legal guardian, please do not allow any child in your care to submit personal data to us. Please also consult our Terms of Service for more information.
12.3 If personal data of a child under the age of 13 years in your care is disclosed to us, you hereby consent to the processing of the child's personal data and accept and agree to be bound by the terms of this Policy on behalf of the child.
12.4 If you do not in fact consent to the processing of personal data of a child under the age of 13 in your care, please contact our Data Protection Officer. We will close any account used exclusively by such a child and delete and/or delete any personal data submitted by such a child without parental consent, or as otherwise required by applicable law.
13. YOUR RIGHTS
13.1 This section (“Your Rights”) applies to users that are located in the European Economic Area only. For user located in other territories, please refer to the privacy clause in this Policy and Terms of Service.
13.2 You have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please email us at [email protected]
13.3 Access. You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your Game account and by contacting [email protected] . If you believe we hold any other personal information about you, please email us at [email protected]
13.4 Portability.
13.4.1 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 (e.g., certain
survey information) or pursuant to our contract with you, as described
in the section “How We Use Your Personal Information “You have the right
to receive this information in a structured, commonly used, and
machine-readable format. You also have the right to request that we
transfer that personal information to another party.
13.4.2 If you wish for us to transfer such personal information to a
third party, please ensure you detail that party in your request. Note
that we can only do so where it is technically feasible. 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).
13.5 Correction. You have the right to correct any personal information held about you that is inaccurate. You can access the personal information you have made available as part of your account by logging into your Game account. If you believe we hold any other personal information about you and that information is inaccurate, please email us at [email protected]
13.6 Erasure.
13.6.1 You can delete your account, or remove certain personal
information, by logging into your Game account. If there is any other
personal information you believe we process that you would like us to
erase, please email us at [email protected]
13.6.2 You may request that we erase the personal information we hold
about you in the following circumstances:
(a) you believe that it is no longer necessary for us to hold such
personal information;
(b) you believe the personal information we hold about you is being
unlawfully processed by us.
13.6.3 You can also exercise your right to restrict our processing of
your personal information (as described below) whilst we consider your
request.
13.6.4 We may need to retain personal information if there are valid
grounds under data protection laws for us to do so (e.g., for the
defence of legal claims or freedom of expression) but we will let you
know if that is the case. Where you have requested that we erase
personal information that has been made available publicly on the Game
Services and there are grounds for erasure, we will use reasonable steps
to try to tell others that are displaying the personal information or
providing links to the personal information to erase it too.
13.7 Restriction of Processing to Storage Only.
13.7.1 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, however, that if we stop processing the
personal information, we may use it again if there are valid grounds
under data protection laws for us to do so (e.g., for the defense of
legal claims or for another’s protection). As above, where we agree to
stop processing the personal information, we will try to tell any third
party to whom we have disclosed the relevant personal information so
that they can stop processing it too.
13.7.2 You may request we stop processing and just store the personal
information we hold about you were:
(a) you believe the personal information is not accurate for the period
it takes for us to verify whether it is accurate
(b) you wish to erase the personal information as the processing we are
doing is unlawful, but you want us to retain the personal information
but just store it instead;
(c) you wish to erase the personal information as it is no longer
necessary for our purposes, but you require it to be stored for the
establishment, exercise or defense of legal claims.
13.8 Objection. You have the right to object to our processing of personal information about you. We will consider your request in other circumstances as detailed below by emailing us at [email protected]
13.9 Announcements. We may from time to time send you announcements when we consider it necessary to do so (such as when we temporarily suspend Game access for maintenance, or security, privacy, or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.
14. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
14.1 We generally do not transfer your personal data to countries outside of Marshall Islands. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the Personal Data Protection Act (“PDPA”).
14.2 If you are a user in India, your personal data will be processed and stored on our servers in India or Singapore. We will transfer your information overseas only in accordance with Privacy Laws, and you hereby consent to such transfer and processing.
14.3 If you are a resident of the European Union, an additional term shall be applied to you about your rights of personal data. Kindly refer to Section “YOUR RIGHTS” in this Policy.
15. MISCELLANEOUS
15.1 This Policy applies in conjunction with any other Policies, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
15.2 We may revise this Policy from time to time without any prior Policy. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
15.3 This policy and any action related thereto will be governed by the laws of Marshall Islands without regard to its conflict of law’s provisions. Any dispute arising out of or in connection with this Agreement, including any question regarding its existence, validity, or termination, shall be referred to and finally resolved by Arbitration Rules of the Marshall Islands for the time being in force, which rules are deemed to be incorporated by reference in this clause. The seat of the arbitration shall be Marshall Islands. The language of the arbitration shall be English.
15.4 Contact and complaints. You may contact us if you have any
enquiries or feedback on our personal data protection Policy and
procedures, or if you wish to make any request, in the following
manner:
Name: Data Protect Officer Email Address: [email protected]
Effective date : 28/12/2022 Last updated : 25/08/2023