Privacy Policy

Last updated: September 29, 2024

This Privacy Policy outlines our practices regarding the collection, use, and disclosure of your information when you utilize the Service, as well as your privacy rights and the protection provided by law.

By engaging with the Service, you consent to the collection and use of information in accordance with this Privacy Policy.

OVERVIEW OF PRIVACY POLICY

This FIGHTER TECH LIMITED User Privacy Notice ("Policy") provides detailed information on how FIGHTER TECH LIMITED ("FIGHTER TECH LIMITED", "we", "us", or "our") handles personal data in connection with our websites, mobile applications, progressive web applications, content, features, digital events, or products (collectively, the "Services"). This Policy is an integral part of FIGHTER TECH LIMITED's Terms of Service ("Terms"). "Personal data" refers to information that can identify you either directly or indirectly. This includes details such as your name, phone number, email address, device data, and usage information. This Policy does not cover third-party games accessed via our Services. The privacy policy of the respective game developer ("Game Partners") will apply to their games.

If you are under 18 years old, you are not permitted to use FIGHTER TECH LIMITED's applications.

We encourage regular review of this Policy for the latest updates. Changes will be communicated within the affected Services, and the "Last Updated" date will be revised accordingly. If you do not accept the current Policy or any applicable addendums, please refrain from using the Services.

1. INFORMATION WE COLLECT ABOUT YOU

As the controller of your personal data, FIGHTER TECH LIMITED is responsible for determining how it is used and processed. We collect your information directly (e.g., email or phone number when claiming rewards), indirectly (e.g., IP address when downloading our app), from public records, or from our partners or clients. The types of personal data we collect are detailed in Annex B, Table for Legal Processing Activities.

2. HOW WE SHARE PERSONAL INFORMATION ABOUT YOU

We share data with third parties that assist us in delivering and analyzing the Services. These third parties will also implement user protection measures equivalent to ours, including:

Corporate affiliates and transaction parties during business transactions
Law enforcement and regulators for legal and security reasons
Service providers to help deliver and secure our Services and conduct marketing
Advertising platforms and networks for campaign management
Marketing vendors for campaign support and event organization
Analytics providers for insights and trends
Game Partners for personalized content and marketing

We may also disclose aggregated or anonymized data that cannot identify individuals or devices, except where limited by law.

3. USE OF PERSONAL DATA

We may link or combine your personal data to deliver a tailored experience. Our use of personal data encompasses:

Delivering and enhancing our Services, including awarding Points
Customizing Services with recommendations for games, features, and events
Marketing our Services on external platforms
Conducting contests, sweepstakes, and online events
Addressing operational and business requirements, such as processing payments and distributing rewards
Authenticating identities to prevent fraudulent activities
Innovation and refining new products and updates for our Services
Generating reports and insights using aggregated or anonymized data
Engaging with you in accordance with your communication preferences
Diagnosing and resolving technical issues
Providing comprehensive technical and customer support

The legal grounds for processing your personal data may include:

Execution of our contract with Users
Adherence to legal and regulatory obligations
Our legitimate business interests, such as service enhancement and fraud prevention
Obtaining consent, as mandated by law

For further information on specific legal bases for processing activities, please refer to the pertinent regional notices.

4. HOW WE STORE, TRANSFER, AND SECURE PERSONAL INFORMATION ABOUT YOU

We maintain data on servers located in Hong Kong and might transfer it across different jurisdictions. We apply protective measures to secure your data, though privacy regulations may differ in other areas.

5. OTHER IMPORTANT INFORMATION

6.1 Children's Privacy: We comply with laws protecting children's privacy. Contact us if you believe we have information about a child.

6.2 Data Retention: We retain personal data as long as necessary for its intended purposes, as long as you engage with the Services, or as mandated by law. Your data may be expunged following extended inactivity or when you delete your account. For information held by Game Partners, please reach out to them directly.

By utilizing our Services, you recognize and agree to the practices and policies stipulated in this Privacy Policy.

6. EXERCISING OF YOUR RIGHTS

You have the ability to update your preferences and exercise your rights under data protection laws by reaching out to us. Please note that changes in your preferences may impact your experience with our Service. Should there be any changes to your personal data, we request that you promptly update us.

Residents of certain regions may have specific rights, which are detailed in the Region-Specific Notices.

7. CONTACT US

For inquiries unrelated to this Policy or data privacy, you are welcome to contact our customer support team and submit a request. If you wish to exercise any applicable data protection rights or if you have comments regarding this Policy and our privacy practices, especially if you have rights as a data subject under the privacy laws applicable to you, please contact our data protection office at: FIGHTER TECH LIMITED, RM 509, 5/F THE CLOUD 111 TUNG CHAU ST TAI KOK TSUI HONG KONG or via email at [email protected].

ANNEX A: REGION-SPECIFIC NOTICES

We may choose or be compelled by law to provide different or additional information regarding the processing of personal data for residents of certain countries, regions, or states.

Europe and United Kingdom Notice

SPECIFIC RIGHTS FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA, SWITZERLAND AND THE UNITED KINGDOM (“EEA, SUI & UK”)

This Europe and United Kingdom Notice offers additional details for users in the EEA, SUI, and UK. Unless otherwise stated in this Europe and United Kingdom Notice, all other terms and principles in FIGHTER TECH LIMITED’s Privacy Policy remain applicable.

Users in the EEA and UK have certain privacy rights as outlined under applicable laws, including the General Data Protection Regulations (“GDPR”), Article 13 of the Swiss Constitution and Federal Act on Data Protection (DPA), and the UK Data Protection Act. The Policy and the privacy options we provide to all users are aligned with these regulations. As a resident of the EEA, SUI & UK, you also have specific rights concerning your personal data. You are welcome to exercise any of these rights by contacting us as detailed below:

Access. You have the right to request a copy of the personal data we process about you. However, there are exceptions to this right, and access may be restricted if, for instance, providing the information to you would negatively impact the rights and freedoms of another person, or if we are legally prohibited from disclosing such information.
Accuracy. We strive to keep your personal data accurate and up-to-date. We encourage you to inform us of any changes that you would like to see reflected in our records.
Objecting. Under certain circumstances, you have the right to object to the processing of your personal data. You may ask us to stop, delete, or restrict the use or other processing of your personal data.
Rectification. You have the right to request the correction of inaccurate personal data and, considering the purposes of processing, to have incomplete personal data completed.
Data Portability. Subject to further legal requirements, you have the right to request that some of your personal data be provided to you or transmitted to another provider, where technically feasible, should you decide to switch services, in a structured, commonly used, and machine-readable format.
Erasure. You have the right to have your personal data erased or to request that we erase it, provided legal requirements for erasure are met, such as when your personal data is no longer necessary for the purposes for which it was collected.
Automated Decision-Making. You have the right not to be subject to decisions based solely on automated processing, including profiling, which has legal or similarly significant effects on you, provided further legal requirements are met.
Complaints. You have the right to lodge a complaint with the relevant data protection authority.
For France, you also have the right to set directives concerning the retention, deletion, and communication of your personal data after your death.

The specific further legal requirements for exercising these rights depend on the applicable statutory data protection laws. For your safety, we respond only to requests for personal data associated with the email address you provide in your request, and we may need to verify your identity before fulfilling certain requests. As an EEA, SUI, or UK data subject, you may access your rights with respect to FIGHTER TECH LIMITED by communicating as directed in the Contact Us section of the Policy.

1. SUBMITTING COMPLAINTS

If you are a resident in the European Economic Area (EEA), you have the right to lodge a complaint at any time to your local regulatory authority. For information on how to contact your local regulator, please visit EDPB

For those residing in the UK, you can submit a complaint at any time to the Information Commissioner’s Office (ICO), the UK's supervisory authority for data protection issues. Complaints can be filed via the ICO’s website at ICO, where you will also find additional contact information for the ICO.

2. TRANSFERS OF PERSONAL DATA

For users based in the EEA, Switzerland (SUI), and the UK, we may transfer your personal data outside of the EEA, for instance, to countries where we operate or where our service providers are located, such as the United States, where our affiliated corporation and hosting provider are situated. By agreeing to the transfer of your personal data outside of your country of residence, you understand that your information may be sent to recipients in the United States and other nations that might not provide the same level of data protection as the laws in your country of residence or citizenship.

Some non-EEA countries have been deemed by the European Commission to provide an adequate level of data protection in line with EEA standards. For transfers to countries not recognized by the European Commission as having adequate protection, we have implemented appropriate safeguards, such as standard contractual clauses approved by the European Commission, to ensure the protection of your personal data. In certain situations, courts, law enforcement, regulatory bodies, or security authorities in countries outside the EEA may have the right to access your personal data. If you wish to obtain a copy of the safeguards we have put in place (where possible), please contact us as indicated in the Policy.

Specific Notice for Residents of the United States

1.ADDITIONAL DISCLOSURES FOR RESIDENTS OF CALIFORNIA, USA

This section is specifically for residents of California and supplements the other sections of FIGHTER TECH LIMITED's Privacy Policy, which remain applicable.

Collection and Use of Personal Information: Over the past 12 months, we have collected the following categories of personal information about you:

CATEGORY	EXAMPLES	SOURCE	BUSINESS PURPOSE
Identifiers	Name, email, unique personal identifier, other accountId,online identifier, IP address, account name, and phone number	User provided on upon redeeming coins using online catalog; related and third-party sources to verify user supplied information;	Operational purposes including customer service; fraud & security incident detection; website improvement; award prize winners; and deliver our Services to you, including personalized recommendations and advertisements
Internet or other similar network activity	Browsing and searching history, or information about your interaction with a website, application, or advertisement	System-collected activity logs and cookies	To determine performance of media content and analytics purposes and to secure our Services
Approximate geolocation data	Country	Identified using IP address	To recommend games based on your country and to secure our Services

Please note that we use and disclose sensitive personal information only for purposes expressly permitted under California law. Personal data does not include publicly available information from government records and de-identified or aggregated consumer information.

Disclosure of Personal Information: We may disclose your personal information to third parties for the business purposes outlined in our Privacy Policy. In the past 12 months, we may have disclosed your personal information for a business purpose or at your direction. For more details on third parties we share data with, see the "How We Share Personal Information About You" section of this Policy. Although we do not "sell" personal information in exchange for money, some of our sharing of personal information as part of our Services may be classified as a "sale" under applicable California laws. We do not knowingly sell or share the personal information of anyone under the age of 16.

Retention of Your Data: FIGHTER TECH LIMITED will retain personal data only as long as necessary for providing the Services, as required by law, or for as long as it is needed for the purposes for which it was collected. For instance, account balances or rewards earned as of termination must be preserved for a period to allow for billing and tax reporting. Under our Terms, if a user does not use the Service for at least one hundred eighty days, the user’s inactive account may be terminated, units earned may expire, subject to the Terms of Use, and the user’s personal data may be destroyed.

Notice of Financial Incentive: Under California law, the Rewards Program that allows you to earn Units may be considered a financial incentive provided in exchange for the collection and retention of personal information. While FIGHTER TECH LIMITED does not assign a monetary value to the data we collect, the value received from the insights and the Rewards Program is estimated to be reasonably equal to or greater than the value received from the use of this information. We use the information to better understand how you use our Services, improve our products and Services, and enhance our user analytics. Participation in the Rewards Program is entirely voluntary, and you can withdraw at any time. For further details of the Rewards Programs and its terms, including how to withdraw or terminate your participation, please refer to the Terms.

Your CCPA Rights: The California Consumer Privacy Act (CCPA) provides California consumers with the following rights regarding their personal information:

Right to Know. You have the right to know what personal information we have collected about you, including the categories of personal information, the sources from which it is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
Right to Delete. You have the right to request that we delete any of your personal information that we have collected and retained, subject to certain exceptions.
Right to Correct. You have the right to request that we correct inaccurate personal information that we maintain about you.
Right to Opt Out of Sales and Sharing. You have the right to opt out of sales of your personal information to third parties and to opt out of the disclosure of your personal information to third parties for cross-context behavioral advertising, if applicable.
Right to Limit Use or Disclosure of Sensitive Personal Information. You have the right to limit the use and disclosure of your sensitive personal information to certain specific business purposes.
Right to Non-discrimination. You have the right not to receive discriminatory treatment for exercising any of your CCPA rights.

Exercising Your Rights:

You may opt out of sales and/or sharing or exercise your right to limit the use/disclosure of your sensitive personal information by sending a request to [email protected]. We also honor opt-out requests submitted via privacy preference signals, such as Global Privacy Control (GPC). (For more information on the GPC and how to use a browser or browser extension incorporating the GPC signal, visit GPC)

You may submit requests to access, delete, or correct your personal information by contacting us as outlined in the Policy. To make such a request, please include the phrase "Personal Information Privacy Request" in the subject line, specify the Service you are inquiring about, and provide your name, address, and email address. If we receive a request to delete your data, we will confirm whether you wish to have your personal information completely removed or if you prefer to be placed on a list of individuals who do not wish to be contacted in the future (for a specified period or indefinitely). Once we delete your personal information, we cannot maintain a record of your details, so you may be contacted again by us if we obtain your personal information anew at a later time. We aim to respond to requests for access and deletion within 45 days; if we require additional time, FIGHTER TECH LIMITED will inform you of this extension.

The California Consumer Privacy Act (CCPA) allows California residents to designate an authorized agent to make requests for disclosure or deletion of their personal information under the CCPA on their behalf. We will comply with requests from an authorized agent to make requests for disclosure or deletion of their personal information under the CCPA on their behalf. We will comply with requests from an authorized agent as long as: i) you provide written consent for the authorized agent to act on your behalf and we can verify your identity, and ii) the agent provides us with proof of your authorization.

Browser "Do Not Track" Signals. Most web browsers include a "do-not-track" feature. When activated, this feature signals to websites that the user does not want their personal information and online behavior to be tracked or used, for instance, for targeted advertising purposes. In accordance with California law, we are obliged to inform you that, like many websites, we do not change our practices in response to a "do-not-track" signal in the web browser.

1. ADDITIONAL DISCLOSURES FOR RESIDENTS OF COLORADO, CONNECTICUT, AND VIRGINIA, USA:

This section pertains to the personal data of residents of Colorado, Connecticut, and Virginia and complements the other sections of this Policy.

For information on the categories of personal data that we collect, the purposes for which we process that personal data, and how we disclose that personal data, please refer to the "Information We Collect About You," "Use of Personal Data and Legal Basis for Processing," and "How We Share Personal Information About You" sections above, as well as the "Table for Legal Processing Activities" below. For an explanation of the types of information we share with third parties, please refer to the Disclosures of Personal Information section in the Additional Disclosures for Residents of California notice above.

In some cases, we may share your information with third parties who may use your information for their own purposes, including for marketing and advertising. These disclosures may be considered "sales" or "targeted advertising" under applicable privacy laws. For more information about the categories of personal data that we may sell to or share with third parties and the categories of such third parties, see the Disclosure of Personal Information subsection in the Additional Disclosures for Residents of California, USA section above.

Depending on where you reside, and subject to certain exceptions, you may have the following rights with respect to your personal data:

Access: You may have the right to request that we confirm whether we process your personal data and that we provide you access to such personal data.
Data Portability: You may have the right to request that we provide a copy of your personal data in a portable and, to the extent technically feasible, readily usable format.
Correction: You may have the right to request that we correct inaccuracies in the personal data that we process.
Deletion: You may have the right to request deletion of your personal data.
Opt Out of Sales and Targeted Advertising: You may have the right to request that we not process your personal data for the purposes of targeted advertising, sales, or profiling in furtherance of decisions that produce legal or similarly significant effects, as those terms are defined by applicable state law.
Opt Out of Profiling: You may have the right to request that we not process your personal data for the purpose of profiling in furtherance of decisions that produce legal or similarly significant effects.

You may opt out of sales and/or targeted advertising using information as directed in the Policy. Where required, we also honor requests to opt-out submitted via privacy preference signals recognized under applicable local law, such as Global Privacy Control (GPC).

You may submit requests to exercise your other rights as directed in the Policy. Please include the phrase "Personal Information Privacy Request" in the subject line, the Service you are inquiring about, along with your name, address, and email address. If we receive a request to delete your personal data, we will ask you if you want your personal data to be removed entirely or if you want to be kept on a list of individuals who do not want to be contacted in the future (for a specified period or otherwise). We cannot maintain a record of individuals whose personal data we have deleted, so you may be contacted again by us, should we come into possession of your personal data at a later date.

You may also have the right to appeal a refusal to take action on your request as directed in the Policy.

Depending on where you reside, you may also use an authorized agent to act on your behalf to submit requests to exercise your rights. We will honor a request from an authorized agent provided that: i) you provide written authorization to the authorized agent to act on your behalf and we can verify your identity, and ii) the agent submits proof of authorization.

ANNEX B: TABLE FOR LEGAL PROCESSING ACTIVITIES

PROCESSING PURPOSE	CATEGORIES OF DATA USED	SOURCES
Account creation, and to provide access to and deliver our Services.	IP address (including approximate location and country), mobile device identifier, advertising identifier (e.g.Google advertising ID) or other unique identifiers, data about your operating system, device model, device timezone, and device language, user agent, carrier, battery level, log data (e.g. network connection type, applications connected to the platform including the site you came from, go to next, and the web page(s) you access during your session in the platform). (“Device Data”).	Processing is necessary for the performance of a contract with the User (i.e. the account creation). Without this information, we will not be able to provide the service you have requested. User consent
To maintain and improve the Services	IP address (including approximate location and country), mobile device identifier, advertising identifier (e.g.Google advertising ID) or other unique identifiers, data about your operating system, device model, device timezone, and device language, user agent, carrier, battery level, log data (e.g. network connection type, applications connected to the platform including the site you came from, go to next, and the web page(s) you access during your session in the platform). (“Device Data”).	It is in our legitimate interest to maintain and improve our Services in order to provide you with the best possible Service. Where required by applicable laws we will obtain your consent.
Enabling you to redeem rewards earned in our Services or claim prizes on our Promotions	Device Data Directly or indirectly we collect data related to software or applications when you play our games. We also collect in-game purchase information, including name,phone,email,other accountId Information(“ Personal Data”). - Session ID, information on how you access the Services (including frequency, what time, how long, and from which device(s)), and your approximate location or the country from which you are accessing the Services (“Usage Data”).	Processing is necessary for the performance of a contract with the User (i.e. providing you with the reward or prize from Promotions we run). Without this information, we will not be able to provide the service you have requested. Where required by applicable laws, we will rely on User consent.
Personalization of ads and targeted advertising	Device Data	It is in our legitimate interest to show you advertisements that are tailored to your interests. Where required by applicable laws we will obtain your consent.
Personalization of the Service and building User profiles	Device Data Personal Data Usage Data	It is in our legitimate interest to provide you with a service personalized to your needs. Where required by applicable laws, we will obtain your consent.
Monitor and analyze usage and activity trends, including measuring the effectiveness of our services and marketing campaigns	Device Data Usage Data	It is in our legitimate interest to monitor and analyze the use and effectiveness of our Services in order to improve our Services. Where required by applicable laws, we will obtain your consent.
Customer service, including when contacting us by phone, email or otherwise	Device Data	It is in our legitimate interest to provide you with customer support. Where required by applicable laws, we will obtain your consent.
Security and fraud prevention	Personal Data Device Data Usage Data	It is in our legitimate interest to keep our platform safe and secure and to protect our Services from fraud, and to protect your personal data and our systems from any security incidents or personal data breaches. Where required by applicable laws, we will obtain your consent.