Clash of Kings – The West
Global Mobile Privacy Policy
(Last Updated: Oct 25, 2021)
This Privacy Policy applies to the “Clash of Kings –
The West” app (the “App”). Unless otherwise stated when we collect your
personal information, it does not apply to information collected outside of the
App.
This Privacy Policy explains how we collect, store,
use, disclose, and manage your personal information.
*Please note that the App is not directed to or
appropriate for users under 18 years old.*
You can navigate to the relevant sections of this
Privacy Policy using the buttons below.
If you do not [agree] with our Terms of Service,
please do not access or use our Application.
WHO WE ARE +
NOTE TO PARENTS +
TYPES OF INFORMATION WE COLLECT +
CHAT CONTENT +
HOW WE USE YOUR INFORMATION +
LEGAL GROUNDS FOR USING YOUR INFORMATION +
HOW WE SHARE YOUR INFORMATION +
LINKS TO THIRD PARTY CONTENT +
SECURITY +
YOUR PRIVACY RIGHTS +
DATA RETENTION POLICY +
INTERNATIONAL DATA TRANSFER +
CHANGES TO THIS PRIVACY POLICY +
CONTACT US +
WHO WE ARE
Beijing Elex Technology Co., Ltd. (“ELEX,”“we,”“our” or “us”) is the
operator and controller of the App. We respect the privacy rights of our users (“you”,“users” and “user”).
We are a valid licensee and participating member of
the Entertainment Software Rating Board’s Privacy Certified Program (“ESRB
Privacy Certified”). To protect your privacy, we have voluntarily undertaken
this privacy initiative and have had the App reviewed and ESRB Privacy
Certified to meet established online information, collection, use, and
disclosure practices. As a licensee of this privacy program, we are subject to
audits of the Application and other enforcement and accountability mechanisms
administered independently by ESRB Privacy Certified.
<top>Back to top</top>
Types of Information We collect
ELEX collects information you may provide directly via
the Application, certain technical information automatically, and information
from third parties. Some of the information we collect may identify you
personally (whether alone or in combination). This is considered personal
information.
<top>Back to top</top>
TYPES OF INFORMATION WE COLLECT AND SOURCES OF
INFORMATION
We collect three main sources of personal information:
(1) information you provide by interacting with our App; (2) information provided
by your device, and (3) information from third-party sites or platforms that
you link with your registration account.
The categories of information we collect are
identifiers/contact information, demographic information (such as gender and
age), commercial information, Internet or other electronic network activity
information, geolocation data, audio, electronic, visual or similar
information, and inferences drawn from the above.
This includes:
· personal information you provide when you create an
account, contact us to request customer support or make a purchase, e.g. first name, surname, country of residence, email
address, username, password;
· other personal information you provide when
interacting with the App, e.g. information you provide
in one-to-one, group, Clan or State chats, photos that you upload as an avatar
or to customer support;
· personal information provided to us when you link to a
third-party service (e.g. Google/Facebook) with your
TWD account, e.g. encrypted ID information that allows us to save your game
progress, your name and your profile picture;
· information collected automatically from and about the
device(s) you use to access the Application (e.g. Internet Protocol (IP)
address, type of device, operating system, language settings, device IDs,
mobile advertising IDs (e.g., for Android users, the GPS ADID also known as the
“Google Play Services ID for Android”), usage data (including the features of
the App you use, and when and how often you use the App), and general location
(country and, at times, city). This information is collected automatically
using third-party SDKs or software development kits. An SDK is a code embedded
in an app that sends information about your use to a server. The SDKs
incorporated into the Application are as follows:
|
Third Party |
Category |
Privacy Statements and Opt-out Options |
|
Adjust |
Analytics |
|
|
AIhelp |
Customer Support |
|
|
Facebook (Sign-in) |
Functional; Advertising; Social |
|
|
Google (APIs, Analytics, DoubleClick, Firebase, Sign-in |
Sign-in; Analytics; Advertising; Functional |
https://policies.google.com/privacy https://firebase.google.com/support/privacy |
|
Microblog SDK |
Login and share |
v5/privacy |
|
Wechat SDK |
Login and share |
zh-cn/privacy-policy.html |
|
Branch SDK |
Share and invite |
https://branch.io/policies/privacy-policy/ |
You are not obliged to provide us with any personal
information. However, only those with an account on the App can use it. In
addition, some parts of the App may be unavailable or may not function as
intended without relevant personal information being provided (e.g. you will not be able to use the chat function without
providing content to the chat; you will not be able to play your game on
multiple devices without linking to a Facebook or Google account that is
accessible from those devices).
The App should not be used to – and nor do we seek to
– capture any sensitive persona date, i.e. data
revealing racial or ethnic origin, political opinions, religious or
philosophical beliefs, trade union membership or criminal behavior; genetic
data, biometric data, health data; or data concerning a person’s sex life or
sexual orientation.
<top>Back to top</top>
CHAT CONTENT
Content that you choose to include in chats (e.g. one-on-one chats, State chats, Clan chats, group chats,
chats with Customer Service) will be visible to the audience included on your
chat. Please do not include anything in a chat that you do not wish the
relevant audience to see. [When users are added to an existing chat, they will
be able to see any earlier discussion threads.] Please take care whenever you
disclose personal information to other users or in non-private forums. We
cannot control the way in which others use the information you have posted in
these forums. If you believe that another user is improperly collecting or
using information about you or other users, please <jump=Contact Us>.
<top>Back to top</top>
HOW WE USE YOUR INFORMATION
We may use the personal information collected from you
or your device(s):
· to operate, manage, and provide
you with, the App;
· to process payments and perform
services requested by you;
· to communicate with you,
including in response to any customer service requests that you make;
· to send you technical notices,
updates, security alerts, information regarding changes to our policies, and
support and administrative messages;
· to monitor and analyze aggregate
trends, usage and activities;
· to improve the App or other ELEX
websites, applications, products, or services (including for internal research
and demographic studies);
· to send you messages or
personalized information about our games, your scores, new features, contests,
special offers, and more, including for marketing and promotional purposes;
· to provide you with targeted
advertisements, marketing and promotional materials and to measure their
effectiveness where lawful (N.B. you may still view non-targeted marketing
in-App even if you choose not to receive targeted marketing);
· to prevent and address fraud,
breach of policies or terms, and threats of harm;
· to share information with a third
party who takes over any or all of our assets (in which case personal
information we hold about you may be one of the assets the third party takes
over).
[If you choose to share your personal information with
us in connection with a customer service request, we will use that information
[solely] to address your customer service request. ]
We may also use this information for other purposes
from time to time. Where this is the case, we will only do so where those
purposes are compatible with the purposes set out above or (where applicable)
for which you provide affirmative consent.
<top>Back to top</top>
LEGAL GROUNDS FOR USING YOUR INFORMATION
We process your personal information for the purposes
set out in this Privacy Policy. We normally process personal information as
necessary to provide the services set out in a contract, when it is in our or a
third party’s legitimate interests or where it is required or allowed by
applicable laws. We must have a lawful reason for processing your Personal
Information. In the Europe, our legal basis will usually be one of the
following grounds:
· performance of a contract – where processing is necessary
to perform our contract with or provide services to you, for example,
processing that we carry out to comply with our obligations under our terms of
service;
· legitimate interests – we process your personal
information where it is in our or a third party’s legitimate interests and that
legitimate interest is not overridden by your interests or your fundamental
rights or freedoms. These legitimate interests include:
o responding to your queries and
questions;
o ensuring the proper functioning
and security of our websites, applications, products and services;
o improving, operating and managing
our business and the websites, applications, products and services that we
offer, including monitoring and analysing trends for
research and development;
o preventing fraud, abuse, online
grooming and other criminal activities;
o providing a personalized
experience, including tailoring content and resources to your preferences and
your device;
o effectively marketing, promoting
and advertising our business, our websites, applications, products and
services;
o meeting our corporate and social
responsibility objectives; and
o enabling our partners to
effectively market, promote and advertise their business, websites,
applications, products and services.
· consent – if we are relying on consent,
we will always explain this to you and obtain a clear, affirmative indication
that you consent. Whenever we rely on consent, you have the right to withdraw
your consent at any time. If you would like to withdraw your consent to any
processing, please <jump=Contact Us>; and
· compliance with legal obligations – where processing is necessary
to meet our legal or regulatory obligations, such as in the case of disclosures
to governmental or regulatory authorities;
· legal claims – where we need to establish,
make or defend legal claims; and
· public information – we may process information
that you have made public, e.g. in open chat forums.
In limited circumstances, we may also process personal
information where it is necessary to protect the vital interests or safety of
you or someone else (for example, in the case of a threat of harm) or for
reasons that are in the public interest.
<top>Back to top</top>
HOW WE SHARE YOUR INFORMATION
We share personal information about you in the
circumstances set out below.
· Within Elex’s Group: We may share your information
with our related entities, including our parent and sister companies. For
example, we may share your information with our affiliates for customer
support, marketing, or technical operations. Where we share your personal information
with our affiliates, they handle your personal information in accordance with
this Privacy Policy.
· Third Party Providers. We share your information with our
third-party service providers, which may include agents, vendors, and
consultants, among others. Service providers assist us with operating the App
and provide us with other services, including marketing and promotional
services. We put in place terms with our third party providers to protect your personal information
in accordance with the law.
·
· Security and Compelled
Disclosure. We may
share your information to comply with the law or other legal processes, and
where required, in response to requests by public authorities, including to
meet national security or law enforcement requests. We may also share your
information in connection with an investigation of fraud, harassment,
intellectual property infringements, or other activity that is illegal, a
violation of our policies, or may expose you or us to legal liability. We may
also share your information to protect the rights, property, life, health,
security, and safety of us, the Application or a third party.
· Mergers or Acquisition. In the event of, or during negotiations
of, an actual or proposed merger, acquisition, reorganization, bankruptcy, or
other similar event, your information may be shared with ELEX's successors or
assigns or other third parties (including professional advisers) involved in
the event.
Marketing and Advertising We also share personal
information with our Marketing and Advertising Partners in order to market our
App and to present advertising in the App as follows:
• Marketing Partners. We share your information, including
personal information, with our partners in connection with offering you
co-branded services, marketing, promoting, advertising selling or distributing
our products or the products of our partners, or engaging in joint marketing
activities.
• Advertising Partners. We share
your information, including advertising IDs, with third parties for purposes of
providing you with advertisements. Our advertising partners include Facebook
and Google, but we may use other advertising partners as well.
If you do not want to receive personalized marketing
and advertising, you can:
• Ask Adjust to forget your
device: https://www.adjust.com/forget-device/
• Ask Appsflyer
to forget your device: https://www.appsflyer.com/optout
• Change your settings on Google
Play by opening the
Google settings app on your device (called Google
Settings or Settings, depending on your device) Scroll down and
tap Google Tap Ads Switch on Opt out
of interest-based ads or Opt
out of Ads Personalisation.
• Opt out of personalized ads from Unity Ads that
are presented in the game by click ing the privacy
icon in the left bottom corner of a Unity ad.
• Opt out of receiving personalized ads in your Facebook
account.
We may share aggregated information that does not
specifically identify you or de-identified information about you with third
parties or affiliates for any purpose, except as prohibited by law.
Except as set out above and in this Privacy Policy, we
do not disclose, sell or rent your personal information to any third parties.
<top>Back to top</top>
LINKS TO THIRD PARTY CONTENT
The App may contain links to third-party websites or
other online services. When you provide information to a third-party website or
other online service, that information may be separately collected by the third
party and is subject to the third-party site or platform’s privacy practices
(and not this Privacy Policy). Privacy choices you have made on the third-party
websites or other online services will not apply to our use of the information
we have collected directly through the App.
We are not responsible for the content or the privacy
policies or practices of any other websites or online services, or for the
actions of the companies responsible for those websites and online services.
Please review the privacy policies of those websites or online services before
providing them with any personal information.
<top>Back to top</top>
SECURITY
The security of your information is important to us.
We take steps designed to protect the security and integrity of information you
provide to us. [We regularly assess our security procedures and implement
appropriate new technology and safeguards.] Nevertheless, transmission via the
internet is not completely secure and no security measures are impenetrable.
Please also remember that you are responsible for
maintaining the secrecy of your passwords and account information. Please be
careful and responsible whenever you are online.
<top>Back to top</top>
YOUR PRIVACY RIGHTS
Under laws in certain countries (which include countries
within the European Economic areas), you may have the following rights:
· Access: you may request details of your
personal information and a copy of that personal information.
· Rectification: you may have inaccurate
information about you corrected or removed.
· Erasure: you may require certain
personal information about you to be deleted from our records.
· Restriction: you may ask us to use your
personal information for restricted purposes only.
· Objection: you may object to us processing
your personal information where we process your information for our or a third
party’s legitimate interests. In addition, you have
the right to object to our use of your personal information for purposes of
targeted or interest-based advertising at any time, or in certain circumstances
where we rely on legitimate interest as the legal basis for our processing. For
more information on interest-based advertising and opt-out options, see
https://youradchoices.com/learn.
· Data portability: you may ask us to transfer the
personal information you have given us to you or to someone else in a format
that can be read by computer.
· Withdraw consent: You may withdraw any consent you
have given us to handle your personal information. If you withdraw your
consent, this may impact your ability to use the App or related services, and
it will not impact any processing of your personal information that has already
taken place.
Please note: Other than your right to object to us using your information
for direct marketing, your rights are not absolute. This means they do not
always apply in all cases, and if this is the case we
will let you know when we respond to your request.
You may exercise or find out more about these rights
by using the information in the <jump=Contact Us> section below.
CALIFORNIA RESIDENTS
California Consumer Privacy Act
This Privacy Policy complies
with the California Consumer Privacy Act (CCPA), which requires that we provide
California residents with notice that they have certain rights, how to exercise
those rights and that you will not be discriminated against if you exercise
these rights.
•
You have the right to know about personal
information we collect, disclose or sell.
This Privacy Policy contains
information regarding the sources from which we collect personal information,
which can be found above in the section titled “Type of Information We Collect and Sources of
Information”; business and commercial purposes for which
we collect your personal information, which can be found above in the section
titled “How We Use Your Information”; and categories of
recipients with whom personal information is shared or sold, which can be found
in the section titled “How We Share Your Information.”
You may request a copy of the
personal information we have collected from you and the categories of
businesses we have transferred it to by contacting us at cokwest@elex.com or by submitting a request at <http://c3aok.elexapp.com/copi211025.html>.
We may verify your identity before providing personal information to
you.
•
You have the right to opt-out of the sale of
personal information.
California residents have the right to opt
out of the sale of personal information, which is defined in a way that may
include the transfer of data to third parties to personalize the ads you see in
the App or to market our Apps others. As described above in “How We
Share Your Information", we transfer personal data including identifiers/contact information,
demographic information (such as gender and age), commercial information,
Internet or other electronic network activity information, geolocation data,
audio, electronic, visual or similar information, and inferences drawn from the
above to our Marketing and
Advertising partners listed in “Marketing and Advertising” and you may
opt-out directly through those partners as described.
You or your authorized agent may also opt
out of the ‘sale’ of your information by contacting us at cokwest@elex.com or by submitting a request at <http://c3aok.elexapp.com/dns211025.html>, and we will not transfer your personal
information after you opt-out to our advertising
partners. You will still see ads in the game, they will just be less relevant
to you.
•
You may request deletion of personal
information
You can delete all personal
information we have about you by accessing the settings in your game or by
submitting a request at <http://c3aok.elexapp.com/copi211025.html>
•
You will not be treated with discrimination
should you exercise these rights.
For any questions or concerns
about our Privacy Policy or practices, please contact us
at privacy@elex.com
California Shine the Light Law
If you are a resident of California, section 1798.83
of the California Civil Code allows you to request information about the
disclosure of your personal information to third parties for their direct
marketing purposes. You may submit
such a request in writing to:
ELEX
97 E. Brokaw Road, Suite 310, Room M
San Jose, CA 95112
ATTN: Privacy
DO NOT TRACK
Your browser may allow you to set a "do not
track" (DNT) signal indicating that you do not wish your online activity
to be tracked. Currently, our system does not support DNT signal headers that
we may receive. However, the choices that we provide you concerning collection
and use of your personal information will continue to operate as described in
this Privacy Policy.
<top>Back to top</top>
DATA RETENTION POLICY
We set retention periods for personal information
taking into account the following criteria:
the purpose for which it was collected;
· how long it is reasonable to keep
records to show we have met the obligations we have to you and by law;
· any time limits for making a
claim or for relevant proceedings; and
· any retention periods for
information that are required or permitted by law or recommended by regulators,
industry bodies or associations.
[If you have not logged into or used the Application
for two (2) consecutive years, we will generally either delete it or anonymize
it so that it cannot be linked back to you. Any personal information you
provide in connection with a customer service request or inquiry will be
generally deleted by our third-party service provider one year from the date of
your request or inquiry.]
<top>Back to top</top>
INTERNATIONAL DATA TRANSFER
Our games are played online by players around the
world, using global platforms and systems. This means that your personal
information may be transferred outside of your home country, including outside
the European Economic Area (EEA).
Not all countries will have data-protection laws in
place that are similar to those in your home country. For example, if you are
in Europe, your data may be transferred to a country that the European
Commission does not recognize as providing an adequate level of data
protection.
Personal data collected from individuals, including
those in the EEA, is stored on servers located in the United States and the
Netherlands. [We have verified that our Cloud Service Provider and data
processors (where applicable) are certified under the EU-U.S. Privacy Shield
Framework. For additional information, please click <ibm=here>.]
When we transfer your personal information to another
country, we take steps to ensure that appropriate protections are in place in
line with data-protection laws. Often, this protection is set out under a
contract with the organization who receives that information. If you would like
more details about the safeguards in place to ensure appropriate protection for
international transfers of personal information, please <jump=Contact
Us>.
<top>Back to top</top>
CHANGES TO THIS PRIVACY POLICY
We may revise this Privacy Policy from time to time.
The Privacy Policy will indicate the date it was last updated. If we make a
material change in the way we handle your personal information, we will provide
you with additional notice by sending you an email at the last email address we
have for you, if any, or by prominently posting notice of the change on the
App. If you do not agree with any changes we make to the Privacy Policy, please
stop using the App.
<top>Back to top</top>
CONTACT US
If you have any comments, questions or complaints
regarding this Privacy Policy or our privacy practices, or other GDPR-related
matters in the EU please contact us using any of the following methods:
ELEX
97 E. Brokaw Road, Suite 310, Room M
San Jose, CA 95112
Customer Service: support__app__252@mail.aihelp.net
Privacy Issues: cokwest@elex.com
EU/EEA Representative
The nominated Representative for data protection
matters within the EEA, pursuant to Article 27 of Regulation (EU) 2016/679 (the
General Data Protection Regulation, or GDPR) is:
Adaptant Solutions AG
Rosenheimer Str. 139
81671 Munich
Germany
compliance-elex@adaptant.io
Inquiries may also be submitted through Adaptant’s contact form at
https://www.adaptant.io/contacts-locations/.
ESRB Privacy Certified and Supervisory Authorities
As previously mentioned, ELEX is a licensee of the
ESRB’s Privacy Certified Program. If you believe we have not adequately
responded to your privacy-related inquiry or complaint, you may contact ESRB
Privacy Certified at: ESRB, privacy@esrb.org.
You also have a right to make a complaint to your
local based in the country or territory where you live, you work or the matter
you are complaining about took place. A list of the European Union’s privacy
supervisory authorities can be found here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
<top>Back to top</top>