Game User Personal Information and Privacy Protection Policy

You (also called as "user") are welcome to use the online game (hereinafter referred to as the "game" or "product") services provided by Pai Technology Co.,Ltd (hereinafter referred to as "we")! This Privacy Policy only applies to the game service of "POP BLOCKS" provided to global users.

Last update date: September 15, 2021.

This policy will help you understand the following:

·How we collect and use your personal information

·How we use cookies and similar technologies

·How we share, transfer, and publicly disclose your personal information

·How we protect your personal information

·Your rights

·How we handle children's personal information

·How your personal information is stored and transferred globally

·How this policy is updated

·How to contact us

 We are fully aware of the importance of personal information to you and will do our best to protect your personal information safe and secure. We are committed to maintaining your trust in us and abide by the following principles to protect your personal information: the principle of consistency of rights and responsibilities, the principle of clear purpose, the principle of choosing consent, the principle of least sufficiency, the principle of ensuring security, the principle of subject participation, the principle of openness and transparency, etc. . At the same time, we promise that we will take appropriate security protection measures to protect your personal information in accordance with mature security standards in the industry.

Please read and understand this Privacy Policy carefully before using our products.

1. How we collect and use your personal information

We will only collect and use your personal information necessary for the realization of product functions for the following purposes described in this policy and in accordance with the principles of lawfulness, fairness and necessity:

1.1 Game login

When you log in to the game, we may collect your login device information, including but not limited to IMEI number, Mac address or Openudid to mark or verify your game user identity. The collection of the above device information will be based on different types of devices or systems. The permissions are open and your authorization settings are obtained.

After you log in to the game, we encourage you to bind your GameCenter account to use this account to play games on multiple devices to protect your game progress; collect your email address when you turn on the account lock function and set an account security password by sending a verification code to protect your progress Your account is safe; you can also set up an associated mobile phone and associated email. The personal information provided by these bindings, associations and supplements is provided by you voluntarily, which will increase the security of your account and facilitate you to continue the game process when changing devices. If you refuse to provide it, it will not affect your enjoyment of game services.

If you are an Android version game user, since the Android version game is operated by a number of domestic game distribution channel providers, you will use the user registration and login systems of different Android channel providers to log in to the game according to different channels. The personal information submitted to the Android channel provider when you log in to the game, as well as the channel provider's collection scope, purpose of use and protection principles of your personal information, are subject to the privacy policy published by the channel provider, please read carefully. The channel provider collects your personal information and does not share it with us.

1.2 Real-name registration

If you are an IOS version game user, in order to meet the requirements of relevant laws, regulations, policies and regulatory authorities, you need to take the initiative to provide your ID number information to be collected and stored by us, and provided to the outside world at the request of regulatory authorities.

If you are an Android version game user, the channel provider is responsible for your real-name authentication and collects necessary information, subject to the privacy policy published by the channel provider. We will not take the initiative to ask channel providers to share your real-name authentication information unless otherwise required by regulatory authorities.

1.3 Consumption and Transactions

If you choose in-game consumption and transaction services:

1.3.1 If you purchase virtual currency in Dollar for IOS version game users, we will collect your recharge record information so that you can check your transaction records. For Android version game users, your recharge records are collected and used by the channel provider, and the specific privacy policy disclosed by the channel provider shall prevail.

1.3.2 For your consumption and transaction of virtual assets in the game, we will keep your consumption and transaction records so that you can inquire about relevant records, and at the same time protect the safety of your virtual assets to the greatest extent possible.

1.4 Game socialization

1.4.1 In the game, you can use the social functions of adding friends, instant messaging and information posting. When using these services, your personal information (such as nickname, gender, profile photo, etc.) will be queried or disclosed. In addition, you can interact with your friends through text, pictures, voice, video and other means in the game. You can also publish information in the form of text, pictures, audio and video in the game or in the game forum. Please pay attention when publishing information. Disclose private or sensitive information involving individuals with care. The content of your communications and postings will authorize us to store and review them for information security purposes.

1.4.2 If you want to interact with other game players, live broadcast or record video through voice or video, after your authorization and consent, the service will access the microphone and camera of your device to provide you with voice chat, live broadcast interaction, video recording, etc. Function.

1.5 Customer Service

In order to provide you with game services, our customer service staff and game MODs served by enthusiastic users in the game will use the email address, mobile phone number, etc. you provide to contact you. At the same time, in order to verify your identity and solve your customer service needs, we may also require you to provide your game account number, ID card information, consumption records, etc.

1.6 Providing game services

When you log in to your account to start the game, we will collect your game operation information, including login logs, item logs, game match information, friend records, consumption records, etc., so that you can view your game history on the client, and at the same time , we will also use this game operation information for statistical analysis of game operation, customer service complaint handling and other game security analysis.

From time to time, we may launch a series of activities within the game or outside the game (such as forums), such as user satisfaction surveys, user experience programs, invitations to participate in tests, participation in competition registrations or promotions, etc. Personal information is requested, including but not limited to age, gender, contact address, occupation, educational background, etc.

1.7 Security and improvement of products or services.

In order to ensure your normal use of our services, maintain the normal operation of basic game functions, optimize the performance of game products, improve your game experience and ensure the security of your account, and combat behaviors that damage the fair environment of the game or interfere with or disrupt the normal operation of game services, We will collect your device information or personal behavior information when using this service, including:

1.7.1 The software and hardware information of the device and the information you allow us to receive by opening the device settings, such as device model, operating system version, device identifier (such as IDFA or IDFV) and other information; software version number, browser type .

1.7.2 Device connection and network status information, such as language used or IP address.

1.7.3 Service log information. We will record the time and last time you use our products, as well as your viewing and staying information in our products, game progress and game crash records, so that we can optimize our products and services.

1.8 Device permissions

We will not obtain any device permissions from you when the game is installed. During the use of the game, if certain device permissions are required, we will explain the purpose to you and obtain your consent. By opening these permissions, you authorize us these information can be collected and used to implement corresponding functions. Including: We need to obtain the read-write storage permission of your device to store picture files; read your local number and device ID to ensure the security of account login, but we will not read your call status or dial other numbers or terminate the call; obtain your geographic location information to show your city in the game's social function; obtain microphone and camera permissions to enable voice chat, live interaction, video recording and other functions; if we need to install other applications in game, your consent will be asked for. You can cancel some authorizations through the device settings, but we cannot provide you with the functions corresponding to these authorizations mentioned above.

1.9 Others

1.9.1 Since the functions and services we provide to you are constantly updated and developed, if a function or service is not in the above description and your information is collected, we will notify you separately through page prompts, interactive processes, etc. Explain the content, scope and purpose of information collection to obtain your consent.

1.9.2 However, in accordance with relevant laws, regulations and national standards, we may collect and use your relevant personal information without your authorization and consent in the following situations:

a) related to our performance of obligations under laws and regulations;

b) those directly related to national interests such as national security and national defense security;

c) those directly related to public safety, public health, and major public interests;

d) Directly related to criminal investigation, prosecution, trial and execution of judgments;

e) In order to protect your or other personal life, property, reputation and other major legitimate rights, but difficult for us to obtain your personal consent;

f) The collected personal information is disclosed to the public by yourself;

g) Collecting personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;

h) Necessary to enter into and perform a contract at your request;

i) Necessary for maintaining the safe and stable operation of the products or services provided, such as finding and disposing of faults in the products or services;

j) necessary for legitimate news reporting;

k) When it is necessary to carry out statistical or academic research in the public interest, and when it provides the results of academic research or description to the public, the personal information contained in the results is de-identified;

l) Other situations stipulated by laws and regulations.

2. How we use cookies and similar technologies 

2.1 Cookies

To ensure the proper functioning of the website, we store small data files called cookies on your computer or mobile device. Cookies usually contain identifiers, site names, and some numbers and characters. With the help of cookies, we may be used to remember your identity, analyze your use of our services, and provide you with advertising optimization based on your behavioral preferences.

We will not use cookies for any purpose other than those described in this policy. You can manage or delete cookies according to your preferences. Please check AboutCookies.org for details. You can clear all cookies saved on your computer, and most web browsers have a cookie-blocking feature. However, if you do this, you will need to personally change your user settings each time you visit our website. At the same time, you will still receive ads, they will just be less relevant to you.

2.2 Do Not Track

Many web browsers have a Do Not Track feature that issues a Do Not Track request to a website. Currently, no major Internet standards organization has established policies governing how websites should respond to such requests. But if your browser has Do Not Track enabled, then all of our sites will respect your choice.

3. How we entrust the processing, sharing, transfer and public disclosure of your personal information

3.1 Delegated processing

Some specific modules or functions in this business function are provided by external suppliers. For example, we may engage service providers to assist us in providing customer support.

For companies, organizations and individuals that we entrust to process personal information, we will sign strict confidentiality agreements with them, requiring them to process personal information in accordance with our requirements, this personal information protection policy and any other relevant confidentiality and security measures.

3.2 Sharing

We will not share your personal information with any companies, organizations and individuals other than our company and authorized companies, except in the following cases:

3.2.1 Sharing with explicit consent: After obtaining your explicit consent, we will share your personal information with other parties.

3.2.2 We may share your personal information externally in accordance with laws and regulations or the mandatory requirements of government authorities.

3.2.3 Sharing with our affiliates: Your personal information may be shared with our affiliates. We will only share personal information that is necessary and subject to the purposes stated in this Privacy Policy. If the affiliated company wants to change the purpose of processing personal information, it will ask for your authorization again.

3.2.4 Sharing with authorized partners: Some of our services will be provided by authorized partners only for the purposes stated in this policy. We may share some of your personal information with our partners to provide better customer service and user experience. Currently, our authorized partners include the following types: 

a) Authorized partners for advertising and analytics services. Based on legally collected personal information, we authorize third-party advertising or analysis service partners to implement labeling or image processing through information systems, algorithms and other non-manual automatic decision-making technologies, so as to make automatic decision-making decisions (such as commercial information push) ), if you do not wish to participate in such targeted advertising information push, please ask us for an explanation through the contact information in Section IX, and we will provide appropriate remedies.

b) Suppliers, service providers and other partners. We send information to suppliers, service providers and other partners who support our business globally, including providing technical infrastructure services, analyzing how our services are used, measuring the effectiveness of advertising and services, providing customers Services, payment facilitation, or the conduct of academic research and surveys. For example: providers that provide us with domestic information distribution and caching services and international server rental services. We encourage you to support our games by liking or subscribing on Facebook, Twitter, YouTube or VK platforms. If you like or subscribe, your basic account information will be shared with these platforms. We will share your transaction information with ApplePay, which provides payment channels and functions.

c) Other situations of accessing third-party services. For example, in order to achieve the purposes stated in this policy, we may access third-party SDK services, and share some of your personal information that we collect in accordance with this policy to such third parties or the third-party SDK directly collects your information personal information in order to provide better customer service and user experience. These third-party services are operated by the relevant third parties, but we will conduct security monitoring of the access SDK to protect the security of your personal information. Your use of these third-party services (including any information you provide to such third parties) is subject to the third-party terms of service and privacy policy, and you need to read their terms carefully. This policy applies only to the personal information we collect, and does not apply to any third-party services or third-party information usage rules. If you find that these third-party services are at risk, it is recommended that you terminate the relevant operations or contact us immediately to protect your legitimate rights and interests. Please see 3.2.5 for the third-party SDK services used by our services.

3.2.5 Third-party SDK catalog

sdk name Partner name Purpose Collect personal information fields sdk privacy policy

Adjust Statistical System Adjust: The Mobile Measurement Company Optimize game operations and ad placement Network information, device information  https://www.adjust.com/terms/privacy-policy/

3.3 Transfer

We will not transfer your personal information to any companies, organizations and individuals, except in the following cases:

3.3.1 Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties;

3.3.2 When a merger, acquisition or bankruptcy liquidation is involved, if it involves the transfer of personal information, we will require new companies and organizations that hold your personal information to continue to be bound by this Privacy Policy, otherwise we will require the company, The organization re-requests your authorization consent.

3.4 Public disclosure

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

3.4.1 After obtaining your consent;

3.4.2 Disclosure based on law: We may publicly disclose your personal information when required by law, legal process, litigation or government authorities.

4. How we protect your personal information

4.1 We have used industry-standard security safeguards to protect the personal information you provide against unauthorized access, public disclosure, use, modification, damage or loss. We will take all reasonably practicable steps to protect your personal information. For example, the exchange of data (such as credit card information) between your device and the "server" is protected by SSL encryption; we also use encryption technology to ensure the confidentiality of data; we use trusted protection mechanisms to prevent malicious data from being malicious Attacks; we will deploy access control mechanisms to ensure that only authorized personnel can access personal information; we will understand and analyze the application information installed on your device and the running process information to prevent viruses, Trojans and other malicious programs.

4.2 Our data security capabilities: We have built a strong data security protection system, including the identification of user information, encrypted storage, and division of data access rights; we have formulated internal data management systems and operating procedures, from the acquisition, use, and destruction of data. There are strict process requirements to avoid illegal use of user privacy data; determine the safety management responsibilities of various departments and their responsible persons who contact users' personal information; establish workflow and safety management systems for the collection, use and related activities of users' personal information; Staff and agents implement authority management, review batch export, copy, and destruction of personal information, and take anti-leakage measures; properly keep paper media, optical media, electromagnetic media and other carriers that record users' personal information, and take corresponding security measures Storage measures; implement access review to the information system that stores users' personal information, and take anti-intrusion, anti-virus and other measures; regularly carry out relevant training on personal information protection for employees.

4.3 We will take all reasonably practicable measures to ensure that irrelevant personal information is not collected. We will only retain your personal information for the period necessary for the purposes described in this Privacy Policy, unless an extension of the retention period is required with your consent or permitted by law.

4.4 The internet environment is not 100% secure and we will endeavour to ensure or guarantee the security of any information you send to us. If our physical, technical, or management protection facilities are damaged, resulting in unauthorized access, public disclosure, tampering, or destruction of information, resulting in damage to your legitimate rights and interests, we will bear the corresponding legal responsibility.

4.5 In the event of an unfortunate personal information security incident, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, and you can prevent and reduce risks on your own. advice, remedies for you, etc. We will promptly notify you of the relevant information of the event by email, letter, telephone, push notification, etc. When it is difficult to inform the subject of personal information one by one, we will take a reasonable and effective way to publish an announcement.

At the same time, we will also proactively report the handling of personal information security incidents in accordance with the requirements of regulatory authorities. 

4.6 If you find that your personal information is leaked, please contact us immediately via the contact information stipulated in this Privacy Policy, so that we can take corresponding measures in a timely manner.

5. Your rights

We will strive to ensure that you exercise the following rights over your personal information:

5.1 Access to your personal information.

You can view your personal information via "Settings - Account". If you cannot access personal information via the aforementioned channels, you can contact us at any time via the contact information in Section IX, and we will respond to your request for access within a reasonable period of time.

5.2 Correction of your personal information.

You can change your bound account information and personal information by "Settings - Account". If you cannot change your personal information through the aforementioned channels, you can contact us at any time through the contact information in Section IX, and we will respond to your request for correction within a reasonable period of time.

5.3 Delete your personal information.

In the following circumstances, you may contact us at any time via the contact information in Section IX to request us to delete your personal information:

5.3.1 If our processing of personal information violates laws and regulations;

5.3.2 If we collect and use your personal information without your consent;

5.3.3 If our processing of personal information violates our agreement with you;

5.3.4 If you no longer use our products or services, or you log out of your account;

5.3.5 If we no longer provide you with products or services.

If we decide to respond to your deletion request, we will also notify the entities that have obtained your personal information from us and require them to delete it in a timely manner, unless otherwise required by laws and regulations, or these entities obtain your independent authorization. 

When you delete information from our services, we may not delete the corresponding information from the backup system immediately, but will delete the information when the backup is updated.

5.4 Change the scope of your authorization and consent.

For the collection and use of additionally collected personal information, you may give or withdraw your consent at any time. You can change the scope of authorization and consent by changing the access rights of the camera, microphone, address book, etc. in the mobile phone device, or changing the browser function settings, changing the setting options of the product, or sending a notification to our contact information in Section IX. When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the previous processing of personal information based on your authorization.

5.5 Cancellation of accounts by the subject of personal information

You can apply for cancellation of your account at any time through the contact information in Section IX. After canceling your account, we will stop providing you with products or services, and will delete or anonymize your personal information at your request, unless otherwise provided by laws and regulations.

Please note that if you have issues that require you to perform your obligations when you cancel, and to the extent permitted by laws and regulations, your application for cancellation will not be immediately supported. After you confirm that the cancellation is successful, account information, personal ID information, transaction records, etc. will not be restored or provided; however, you should still be responsible for your actions before the cancellation of your account and during the use of platform services.

5.6 Personal information subjects obtain copies of personal information

Under the premise of technical feasibility, such as data interface matching, we can also directly transmit a copy of your personal information to a third party designated by you upon your request.

5.7 In response to your above request

For security, you may be required to provide a written request or otherwise prove your identity. We may ask you to verify your identity before processing your request. We will generally respond to your rights request within thirty days. If you are not satisfied, you can also make a complaint through the contact information in Section IX.

For your reasonable requests, we do not charge fees in principle, but for repeated requests that exceed reasonable limits, we will charge a certain cost as appropriate. For those that are unnecessarily repetitive, require excessive technical means (eg, need to develop new systems or fundamentally change existing practices), pose risks to the legitimate rights and interests of others, or are highly impractical (eg, involve backing up information stored on tapes). requests, we may refuse them.

Please note that our response to your above request is only for personal information collected and generated by us in accordance with this Privacy Policy. If the personal information is collected and used by the channel provider, please claim your rights to the channel provider in accordance with the channel provider's published privacy policy.

5.8 In the following cases, we will not be able to respond to your request in accordance with laws and regulations:

5.8.1 Those directly related to national security and national defense security;

5.8.2 Directly related to public safety, public health and major public interests;

5.8.3 Directly related to criminal investigation, prosecution, trial and execution of judgments;

5.8.4 There is sufficient evidence to show that you have subjective malice or abuse your rights;

5.8.5 Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;

5.8.6 Involving commercial secrets.

6. How we handle children's personal information

6.1 We attach great importance to preventing minors from indulging in games and the protection of minors' personal information. Our services are only available to users over the age of 16. If you are under the age of 16, please stop using our services immediately. We will determine whether the real-name information of the relevant account is a minor through the verification of real-name identity and other information.

6.2 We will regard minors under the age of 14 as children, children do not belong to our user scope, and we will not collect and process children's personal information.

6.3 You should clearly understand that if we discover or suspect that you are under the age of 16 during the service, we may suspend or terminate the service to you at any time until you provide us with proof that you are over 16. If we discover that we have unknowingly collected personal information from children, we will try to delete the data as quickly as possible.

7. How your personal information is stored and transferred globally

7.1 We only keep your personal information for as long as necessary to provide our services. In general, we will retain your personal information for the duration of your account and for a reasonable statute of limitations after account cancellation. After the necessary period, we will delete or anonymize your personal information.

7.2 Based on the nature of this game, it is an international simulation game, we may transmit your personal registration information and records or log information generated in the game (such as login logs, item logs, etc.) to overseas servers. At that time, we will follow the requirements of the relevant laws and regulations of the country of departure to ensure that your personal information is adequately and equally protected,  including but not limited to fulfilling the personal information security impact assessment requirements required by the regulatory authorities, and filing procedures as required. , implement security measures such as data de-identification before cross-border data transfer, etc.

8. How this policy is updated

8.1 Please understand that due to the continuous updating and development of our game services, we will strive to implement the concept of "privacy protection design", improve our product design, and promptly explain the collection of personal information to you through page prompts, announcements or interactive processes, etc. the content, scope and purpose of this Privacy Policy as a necessary supplement to this Privacy Policy.

8.2 We will not reduce your rights under the Privacy Policy without your express consent. We will post an updated version of the Privacy Policy. For material changes, we will also provide a more prominent notice (including, for some services, we will send a notice by email explaining the specific changes to the Privacy Policy).

8.3 Significant changes to the Privacy Policy include, but are not limited to:

8.3.1 Significant changes to our service model. Such as the purpose of processing personal information, the type of personal information processed, the way of using personal information, etc.;

8.3.2 Significant changes have taken place in our ownership structure and organizational structure. Such as changes in owners caused by business adjustments, bankruptcy mergers and acquisitions, etc.;

8.3.3 The main objects of personal information sharing, transfer or public disclosure have changed;

8.3.4 Significant changes in your rights to participate in the processing of personal information and the manner in which it is exercised;

8.3.5 When our responsible department responsible for handling personal information security, contact information and complaint channels change;

8.3.6 When the personal information security impact assessment report indicates that there is a high risk.

9. How to contact us

9.1 If you have any questions, comments or suggestions about the Privacy Policy, please contact us via the following ways, under normal circumstances, we will reply within fifteen working days. 

Email: paibusiness1@bloks.com

Pai Technology Co.,Ltd