Privacy Policy

Introduction

Thank you for using our products and services. We respect your concerns about privacy and much importance is attached to the privacy protection of users by Papergames, thus we are publishing this Privacy Policy on how we collect, use, disclose, share and store user information. We may collect and use your information when you use our services. We hope that this Privacy Policy will inform you on how we collect, use, store, share, access, update, control and protect your information when you use our services. This Privacy Policy applies to interactions between users and Papergames, user registration and use of Papergames services. We encourage you to go through this policy to help you understand how to maintain your privacy.

Your use or continuation of use of our services shall constitute consent to our collection, use, storage and sharing of your information according to this Privacy Policy. If you do not agree with this privacy policy, you must not use the Game Services. If you change your mind in the future, you may withdraw your consent to use of your personal information in accordance with this policy.

What Information We may Collect about You

The following information related to you may be collected, stored and used when we provide services. If you do not provide such information, you may not be able to register as a user, receive some of our services, or achieve the desired results of our services. The information we collect falls into three different categories: 1) Collecting information directly from you; 2) Collecting information automatically; and 3) Information collected from third parties.

1) Information directly from you

• Personal information provided to us when you register an account or use our services;

• Bank account or other accounts used for payment only if they are associated with your accounts when our services are made available to you;

• Shared information that you provide to other parties through our services and information stored when you use our services.

2) Information collected a utomatically

• Log, which means technical information that may be collected by cookies, web beacons or other means when you access our services, including:

• Device or software information, e.g. configuration information, your IP address, version of your mobile device and its identifier provided by your mobile device, web browsers or other programs used to access our services;

• Information searched for or viewed when you use our services, e.g. web search terms you use, URL address of social media pages you access, other information and details that you browse or are required to be provided when you access our services;

• Information on and of mobile applications and other software you have used;

• Information you communicate through our services, e.g. account number, time, data and length of communication;

• Information (metadata) contained in the data you share through our services, e.g. shared photos taken or uploaded, or when, what time or where they are taken.

• Location information, which means information on your location collected when you start the positioning function and use our location-based services, including:

• Information of your geographic location collected via GPS or WiFi when you use our services with your positioning-based mobile device;

• Real-time information containing your location provided by you or other users, e.g. your location contained in your account information, shared information uploaded by you or others showing your current or previous location, or geographic tags contained in photos shared by you or others;

3) Information collected from third parties.

We also use third-party partners, such as social networking sites, data analytics providers and advertising networks to supplement information we have about you, such as:

• Information we receive if you link a third party tool with the Service (such as Facebook or Google)

• Information to fight fraud (such as refund abuse in games or click fraud in advertising)

• Information from platforms that the games run on (such as to verify payment)

• Information for advertising and analytics purposes, so we can provide you a better Service

• Information that you have made available to us from a third party service (such as Google or Facebook) via your privacy settings

Children

Papergames recommends that any minor who participates in an online activity shall have prior consent from their parents or legal guardians. Papergames will protect information related to minors in accordance with relevant laws and regulations.

The Services are not directed to users under 13 years old in the European Economic Area.

The privacy of children is a priority for us and guardians are encouraged to provide guidance for minors under the age of 18 when using our services. We recommend that minors should encourage their parents or guardians to read this Privacy Policy and they should have consent and guidance from their parents or guardians before submitting their personal information. We do not intentionally collect or store personal information from Children. However, we do collect information, including personal information, from all users of the Services.

If we find we have inadvertently collected personal data about children under the age of 13 without permission from a parent or legal guardian, we will immediately take all necessary and reasonable measures to delete the information from our systems.

If you are a guardian and wish to review personal data collected from your child, or have that information modified or deleted, you may contact us as described in the Contact section. If we become aware that a child has provided us with personal data contrary to this privacy policy, we will delete any personal data we have collected, unless we have a legal obligation to keep it, and terminate the child’s account and/or revert them to the underage experience, as applicable.

Parents/guardians are jointly and severally liable for all acts (including purchases and payments in the Services) and omissions of their Children when using the Services.

How We Collect your information

For web users, we or our third-party partners may collect, use and store your information via cookies and web beacons.

We use cookies and web beacons to provide you with special experience and services and to:

• Remember your identity. For example, cookies and web beacons help us identify you as a registered user, or memorize your preferences or other information that you provide to us;

• Analyze your use of our services. For example, we can use cookies and web beacons to know in which activities you participate with our services, or which pages or services are most preferred by you;

• Advertising optimization. Cookies and web beacons help us provide you with advertisements that are relevant to you based on your information rather than general advertising.

While cookies and web beacons are used for the purposes above, we may provide advising companies or other partners with non-personal identity information collected with cookies and web beacons and processed statistically in order to analyze how users use our services and use such information for advertising services.

Our products and services may have cookies and web beacons placed by our advertisers or other partners. These cookies and web beacons may collect non-personal identity information used to analyze how users use the services, to send you advertisements that may be of interest to you, or to evaluate performance of advertising services. These third-party cookies and web beacons collect and use such information without being governed by this Privacy Policy, but by the privacy policy concerning relevant users, so we are not responsible for third-party cookies or web beacons.

You may refuse or manage cookies or web beacons with help of your browser settings. However, please note that if you disable cookies or web beacons, you may not be able to enjoy the best service experience and some services may not work normally. Meanwhile, you will receive the same volume of advertising which are less relevant to you.

Cookies: Cookies are small pieces of data sent by a website to your computer while you are browsing the Internet. Cookies are used (whether by us or other companies) for a variety of reasons. For example, if you go to a website you have visited before, cookies send information to that website so it can "remember" you. You have the option to receive an alert from your computer when a website wants to send you a cookie. You can also block all cookies. The setting for this can be found in your browser (Chrome, Internet Explorer, Safari, Firefox, etc.). Web browsers are all different so we recommend you use your browser's Help menu to find out how to change your cookie settings. If you block all cookies, you may encounter problems with access or features of certain services.

Web beacons: Web beacons are objects embedded in images on our website pages and in the emails we send to you. We may use web beacons for technical purposes, such as analyzing browsing habits, traffic, customer interests and the effectiveness of our marketing initiatives. These technical methods may require information to be sent, either directly to us or to another party we have asked to collect information on our behalf.

In our mobile apps, we also use third-party software development kits (also known as SDKs) which collect information about your device(s) and use of the Services. These trackers help us to deliver the Services to you, to improve your user experience and to analyze traffic on and use of the Services. In addition, they are used for marketing and advertising, including to help us to measure the effectiveness of our marketing campaigns and potentially for interest-based advertising by third parties.

Third parties that provide support for internal operations, as well as marketing partners and analytics providers include the following:

No.	Name of SDK	Name of Third Party	Purposes of Use	Name of Information Shared	Method of Processing	Link
1	Google SDK	Google, Inc.	Used for account login, payment, and data monitoring	Unique device identifiers (IDFA, IDFV, GAID, Android ID), firebase app-instance ID, browser type and settings, device type and settings, operating system, mobile network information, application version number, IP address, crash reports, system activities and the date and time of the corresponding requests, referring source URLs and cookies, number of users and sessions, session duration, geography, first launches, app opens, app updates, in-app purchases	SDK Native Collection	https://policies.google.com/privacy#infocollect
2	iOS SDK	Apple, Inc.	Used for account login, payment	Account information (email address, device used for registration, account status and age), unique device identifier (device serial number, browser type), contact information, payment information, transaction information, browsing history, crash data, access to IDFA, notification rights	SDK Native Collection	https://www.apple.com/legal/privacy/en-ww/
3	twitter SDK	Twitter, Inc.	Used for account login, sharing	IP, browser type, device ID, advertising ID, operating system, carrier, language, memory, installed applications and battery level, log information, cookies, network status	SDK Native Collection	https://twitter.com/en/privacy#twitter-privacy-9.1
4	FacebookSDK	Meta Platforms, Inc.	Used for account login, sharing	Unique device identifier (device number, mobile advertiser number, or identifier provided by the games you play, apps you use, or accounts you have), device type, details about the operating system, details about hardware and software, battery level, signal strength, available storage space, browser type, name and type of apps and files, IP, cookie access network status	SDK Native Collection	https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0
5	AppsFlyer SDK	AppsFlyer Inc.	Used for advertising and data monitoring	Networking information, MAC address, unique device identifier (IMEI, IDFA, Android ID, hardware serial number of the device), advertising logo, operator information, get network status, modify network status, get IDFA	SDK Native Collection	https://www.appsflyer.com/legal/privacy-policy/
6	unity3D	Unity Software (Shanghai) Co., Ltd.	Used for provision of game engine services	Unique Device Identifier: IDFV, AndroidID, IDFA, Android Advertising ID; Software Information: Operating System and Version, CPU, Graphics Card (Type, Supplier, and Version), RAM, Screen Resolution, Sensor Mark, Application ID; Others: IP Address, Device Manufacturer and Model, Platform Type (such as iOS, Windows), Read/Write Storage Permission, Access to Microphone Recording Permission, Access to Camera Usage Permission, Access to Photo Album Permission.	SDK Native Collection	https://unity.cn/legal/privacy-policy
7	Aihelp SDK	ShareFun Network Limited	Used for provision of intelligent customer services	Platform, language, SDK version, area code, operator, network, device model, available storage space, total storage space, OS version, application information, server ID, custom fields	De-identified and encrypted before transmission and processing	https://aihelp.net/privacypolicy/

How We Use Your Information

We may use the information collected in the course of our services to:

• Provide services to you;

• Verify identity, provide customer service, ensure safety, monitor fraud, file and copy such information to ensure safety of our products and services;

• Help us design new services and improve our existing service;

• Help us better know how you access and use our services in order to meet your special needs, e.g. language settings, location settings, special assistance and tips, or respond otherwise to your and other users' requirements;

• Provide you with relevant advertisements in place of common ones;

• Assess and improve performance of advertising and other promotions in our service;

• Certify software or upgrade management software;

• Engage you in our product and service surveys.

How We Share Your Information

Except for the following circumstances, we and our affiliates will not share your personal information with any third party without your consent:

• We and our affiliates may share your personal information with our affiliates, partners, third-party service providers, contractors and agents (e.g. communication service providers who send emails or give notices on our behalf, or map service providers that provide us with location data, which may not be in your jurisdiction) to:

o Provide you with our services;

o Achieve the purposes as mentioned in the section "How to use";

o Fulfill our obligations and exercise our rights as set forth in this Privacy Policy or other agreements between you and Papergames;

o Understand, maintain and improve our services.

If we or our affiliates share your personal information with any third party as above mentioned, we will endeavor to ensure that such third parties comply with this Privacy Policy and take appropriate security and confidentiality measures we require when using your personal information.

• With the development of our business, we and our affiliates may conduct mergers, acquisitions, asset transfers or other transactions, and your personal information may be transferred accordingly. We will keep you informed before such transfer.

• We or our affiliates may also retain, store or disclose your personal information:

• To disclose it with your consent or authorization;

• To comply with applicable laws and regulations;

• To comply with court orders or other legal procedures;

• To comply with requirements of relevant governmental authorities;

• For purposes as reasonably needed to comply with applicable laws and regulations, safeguard public interest, or protect personal and property safety or legal interests of our customers, Papergames, our group companies, other users or employees;

• For other purposes as set forth in provisions or statements of Papergames Services, or deemed necessary by Papergames.

Publicly Posted Information

Please remember that whenever you are willing to disclose your personal information

online (for example on message boards, public profiles, and in chat areas), that information is stored by us and becomes publicly available, subject to the collection and use of third parties (e.g., other users). Papergames is not responsible for the subsequent use of that information by third parties. Please take caution whenever you disclose personal information in a public manner. If you encounter any Papergames user who is improperly collecting or using information about you or other users, please contact us using the information in the Contact section below.

Third Party Link

Our service may include or link to social media or other service (including websites) provided by third parties. Example:

• You transfer certain content to our service with the "Share" button, or you log in to our service with a third-party link. Your information (including your log) may be collected with these functions and cookies may be installed to your computer to perform such functions;

• We provide you with links on advertisements or other means of our service, so that you can access third-party services or websites.

Such third-party social media or other services may be operated by third parties or us. Your use of such third-party social media service or other services (including any personal information you provide to such third party) is subject to the third party's service provisions and privacy policy (not this Privacy Policy), so you shall go through them carefully. This Privacy Policy does not apply to services or information provided by any third party, but only to information we collect. We are not responsible for any third party's use of information provided by you.

How We Protect Your Information

We retain your personal information only for a period necessary to meet the purposes as described in this Privacy Policy, or a period required by law.

We employ security technology and procedures to prevent loss, misuse, unauthorized access or disclosure of such information. For example, we will use encryption technology (e.g. SSL) to protect your personal information in certain services. However, please understand that due to technical limitations and potential existence of malicious means, we cannot warrant 100% security even if we have tried our best to take security measures. You need to understand that the system and communication network that you use to access our services may fail due to some factors beyond our control.

If we subcontract all or part of the processing of personal data to processors, we will require that its processors provide contractual guarantees on the security and confidentiality of personal data by means of technical data protection measures and appropriate human resources.

You also have a role to play in keeping your personal information safe. If you are asked to create a unique password to secure access to your account, choose one that would be impossible to guess and make sure you never share it with anyone. It is your responsibility to ensure your password and account information is always confidential. If you use a public or shared computer, turn off all settings and options that remember your login credentials and ensure you always log out of your account before leaving the computer.

Data Retention Policy

We retain your data for as long as your account is active or as needed to provide you the Service. We may for example periodically de-identify unused game accounts, and we may regularly review and de-identify unnecessary data.

Note that if you ask us to remove your personal data, we will retain your data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.

Your Privacy Rights

Papergames encourages users to update and modify their personal information for it to be effective. Users of Papergames Services can easily access and modify their personal information any time. Users can modify or delete their information at their own discretion.

We will take appropriate technical measures to ensure that you can access, update and correct your registration information or other personal information provided when you use our services. When accessing, updating, correcting or deleting such information, we may check your identity in order to protect your account.

The following rights ("Your Rights") applies to users that are located in the European Economic Area only.

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 contact us at nikkisupport@playpapergames.com.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. If you believe we hold any other personal information about you, please contact us.

Portability

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent (e.g., gender information) or pursuant to our contract with you (e.g., game play statistics), as described in the section "How to use". 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.

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).

Correction

You have the right to correct any personal information held about you that is inaccurate. If you believe we hold any other personal information about you and that information is inaccurate, please contact us.

Erasure

You can delete your account, or remove certain personal information. If there is any other personal information you believe we process that you would like us to erase, please contact us.

You may request that we erase the personal information we hold about you in the following circumstances:

• you believe that it is no longer necessary for us to hold such personal information; or

• you believe the personal information we hold about you is being unlawfully processed by us.

You can also exercise your right to restrict our processing of your personal information (as described below) whilst we consider your request.

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 defense 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.

Restriction of Processing to Storage Only

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.

You may request we stop processing and just store the personal information we hold about you where:

• you believe the personal information is not accurate for the period it takes for us to verify whether it is accurate;

• 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; or

• 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.

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 contact us.

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.

Contact & Complaints

For the purposes of European Data Protection Law, the Data Controller is Nikkigames HK Limited.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance.

International Transfer of Your Information

Our Service is global by nature and your data can therefore be transferred to anywhere in the world. Because different countries may have different data protection laws than your own country, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Policy. Adequate safeguards that we may use include standard contractual clauses approved by EU Commission and other lawful safeguards.

Personal data may be transferred to, and stored in, a country operating outside the European Economic Area (EEA). Under Regulation (EU) 2016/679, the transfer of personal data to a country outside the EEA may take place where the European Commission has decided that the country ensures an adequate level of protection. In the absence of an adequacy decision, we may transfer personal data provided appropriate safeguards are in place.

Personal data collected from individuals, including those in the EEA, is stored on servers in compliance with relevant legal provisions. We have verified that our Cloud Service Provider and data processors (where applicable) are certified under the EU-U.S. Privacy Shield Framework.

Change to this Privacy Policy

This Privacy Policy may be amended from time to time and the amendment shall be integral to this Privacy Policy. If such amendment causes substantial loss of your rights under this Privacy Policy, we'll let you know by giving a notice prominently or informing you otherwise before the amendment takes effect. In this event, your continuing to use our services shall constitute your consent to observe the amendment of this Privacy Policy.

We encourage you to check our Privacy Policy every time you access Papergames.

Jurisdiction

Controlling Law and Jurisdiction of this policy and any action related thereto will be governed by the laws of People's Republic of China without regard to its conflict of laws provisions. Any dispute arising from or in connection with this Policy shall be submitted to Shanghai International Economic and Trade Arbitration Commission/Shanghai International Arbitration Center ("SHIAC") for arbitration, which shall be conducted in accordance with SHIAC's arbitration rules in effect at the time of applying for arbitration. The seat of arbitration shall be Shanghai, China. The language to be used in the arbitral proceedings shall be Chinese. The arbitral award is final and binding upon both parties.

Contact Us

If you have questions about data protection, or if you have any requests for resolving issues with your personal data, we encourage you to primarily contact us at: nikkisupport@@playpapergames.com.