Volcano Force Privacy Policy
Last updated July 22th, 2022
PLEASE READ THIS
PRIVACY POLICY CAREFULLY. IT DESCRIBES DETAILS ABOUT HOW WE COLLECT, USE AND
DISCLOSE PERSONAL INFORMATION YOU SHARE WITH US. IF YOU ARE UNDER 16, DO NOT
PROVIDE ANY PERSONAL INFORMATION UNLESS YOU HAVE FIRST OBTAINED YOUR PARENT’S
OR GUARDIAN’S PERMISSION.
Thank you for reading
our Privacy Policy ("Policy"). We are Volcano Force Technology
Co., Limited, a company incorporated
under the laws of Hong Kong ( “Volcano Force”,
“we” or “us”), who are dedicated to optimizing our
products and services as well as protecting the privacy rights of our users
("users", “user” or “you”). This Policy has been crafted to inform users as to the ways we collect,
store, use, and process the information users provide during the use of any of
our games or applications ("Services").
It also describes your rights and available choices regarding your personal information.
"Personal
information" refers to any information relating to an identified or
identifiable natural person; an identifiable natural person is one who can be
identified, directly or indirectly, in particular by reference to an identifier
such as a name, an identification number, location data, an online identifier
or to one or more factors specific to the physical, physiological, genetic,
mental, economic, cultural or social identity of that natural person.
Our primary objective
in collecting users’ information is to provide and enhance the Services and to
enable users to easily navigate and enjoy the Service. By using our Services
and providing us with information, you agree to be bound by this Policy.
We reserve the right to
amend the Policy from time to time, and we encourage you to consult the Policy
regularly for the latest version.
Information
Collection and Purposes
Information Disclosure & Sharing
Your California Privacy Rights
The information we
collect and the purpose of the collection and processing are described below.
We use your personal
information to provide products and services you ask for, to communicate with
you, to improve our services, and for other purposes including those set out
below. From time to time we may change the information requested upon
registration or with respect to certain features or services and we will update
the information below in such case. Therefore, we recommend that you regularly
check this Policy.
For purposes of the
“General Data Protection Regulation” (“GDPR”) and other relevant laws,
the Volcano Force is the Controller for our online and mobile game applications
including, but not limited to, “Army Men Strike”. You may be entitled by the
privacy laws of your jurisdiction with the right to object to processing by contacting us as indicated in the “Contact Us” section of this Policy. When you are
in the European Union, the GDPR applies to our collection and processing of
your personal information.
Personal information
does not include “aggregate” information, which means collective data that
relate to the use of the Service or a group or category of products, services
or users and does not indicate individual identities of particular users.
Aggregate information helps us understand business trends and users’ needs so
that we can better update our products or tailor our Service for users. This Policy
in no way restricts or limits our collection and use of aggregate information.
Information You Voluntarily Provide:
You have two options to
log in to our Services:
- You may log in to our Services using social media accounts, such as
Facebook, Google, Apple Game Center, Amazon, Microsoft(“Social
Networks”).
- Alternatively, you may log in to our Services using an account you
already have create directly with us (“Volcano
Force ID”).
If you log in to our
Services using Social Network accounts, we process personal information you
authorized the Social
Networks to share with us to sign up for our Services. Exactly what information
we receive from the Social Networks may vary due to your privacy settings on
such Social Network, but it would typically include your basic public profile
information such as
- Username
- Profile
picture
- Information you have permitted the Social Networks
to share with us
- Information you have made public on the Social
Networks
Please be aware that such Social Networks are governed by their own privacy
policies, terms and end-user agreements. We are
not responsible for and have no control over, the sharing practices or policies
of the third parties that operate those sites.
If you log in
to our Services using a Volcano Force ID, we process the following personal
information:
-
E-mail
address
-
Password
-
Verification
code
We process
the same personal information, when you deactivate your account.
When first
setting up a Volcano Force ID or when you decide to deactivate your account, we
will send you an e-mail to the e-mail address provided. This e-mail will
include a verification code, which we will ask you to provide to verify the
validity of your e-mail address and then set up or deactivate the Volcano Force
ID. After your confirmation, we will save the data you provided as well as the
date and time of the confirmation e-mail.
We collect
and process the login information for the purpose of creating your account in
our Services per your request. For users located in the EU (hereinafter “EU
users”), we consider the login information as necessary for the performance
of our Services in line with Art. 6 (1) (b) of the GDPR. Where the processing
is not necessary for the performance of our Services, your consent to such
processing will be requested to the extent required by applicable law. In this
case, we process your personal information in line with Art. 6 (1) (a) of the GDPR.
l Using our Services
without Logging in
You can use our Services
without logging in or creating an account with us, but
all data relating to the game will become unavailable to you, if you de- or
re-install the Services or replace, lose or damage the device on which you use
our Services. Under this circumstance, we may also collect your personal
information. Please refer to “Information You Voluntarily Submit” “Information
You Submit to Our Support Team” “Information We Automatically Collect” “In-Game
Information” “Information Collected to Prevent Cheating and Unauthorized Use”
“Information We Obtain from Third Party Sources” and other sections in this Policy for further
reference.
l Information You Voluntarily
Submit.
Within our
Services, you may opt to provide us with other personal information. For
example:
-
Birth Date: we
will send you in-game birthday gift via our in-game mail system according to
the birth date information you voluntarily submit. We will not use your Birth
Date information for any other purposes. We will not be able to send you such a
birthday gift without your birth date information, but it will not prevent you
from using our other Services.
We do not
collect such personal information about you except when you specifically
provide such information to us on a voluntary basis. For EU users, we collect
and process your birthdate to send you the in-game birthday gift in line with
art. 6.1(b) of the GDPR.
l
Information You Submit to Our Support Team.
We collect
and process the information you submit to our support team to provide technical
support, customer service support per your request so as to ensure the
continued smooth operation of our Services. For EU users, we consider such
information as necessary for the performance of our customer service, in line
with Art. 6 (1) (b) of the GDPR. Where processing is not necessary for the
performance of our Services, your consent to such processing will be requested to
the extent required by applicable law. In this case, we process your personal
information in line with Art. 6 (1) (a) of the GDPR.
Information We Automatically Collect:
l
Internet Protocol (IP) Address and Broad Geographic Location
Based on the IP Address
We collect
and process the IP Address and broad geographic location based on the IP
Address to ensure the continued smooth operation and security of our Services. For
EU users, we consider such information as necessary for the performance of our
customer service, in line with Art. 6 (1) (b) of the GDPR.
The IP
Address will also be used to measure our advertising effectiveness as
well as prevent fraud for our advertising campaigns. For EU users, we see such
collection and processing as the pursuit of our legitimate interests, in line
with Art. 6 (1) (f) of the GDPR. Where we
cannot rely on legitimate interests in a particular case, your consent to such
processing will be requested to the extent required by applicable law. In this
case, we process your personal information in line with Art. 6 (1) (a) of the
GDPR.
We will not
collect your precise location data unless you give us the permission to access
the location of your device.
l
Device Information.
We may collect the information
of your device type, producer, operating system, language or other technical
data for checking the device compatibility with our Services. We may also
collect device identifiers, such as the universally unique identifier (UUID) as
well as Advertising IDs. The device identifiers help you log in faster and
enhance your navigation through the Service. Some features of the Services may
not function properly if use or availability of device identifiers is impaired
or disabled.
For EU users, we see
such collection and processing as the pursuit of our legitimate interests, in
line with Art. 6 (1) (f) of the GDPR. Where we cannot rely on
legitimate interests in a particular case, your consent to such processing will
be requested to the extent required by applicable law. In this case, we process
your personal information in line with Art. 6 (1) (a) of the GDPR.
l In-game Information.
- In-game profile picture, username and profile ID
-
Your access, participation, performance and achievements in the Services
-
The chat log and
message you communicated or posed in the Services
-
Purchase or
transaction record in the Services but no billing information
-
Log information and online records,
such as the date and time of your visit, click records, game metrics and usage
data, processand breakdown records, and other standard server log information.
We collect
and process the in-game information to keep the record of your account and to
enhance the functionality of our Services. For EU users, we see such collection
and processing as the pursuit of our legitimate interests, in line with Art. 6 (1) (f)
of the GDPR. Where we cannot rely on legitimate interests in a particular case,
your consent to such processing will be requested to the extent required by applicable
law. In this case, we process your personal information in line with Art. 6 (1)
(a) of the GDPR.
l
Information Collected to Prevent Cheating and Unauthorized Use. To detect cheating or unauthorized and malicious programs, when you use
our Service, we may access, collect, monitor information relating to purchase
and transaction history, in-game performance, modifications related to our game
functions, files or processes that enable or facilitate cheating, unfair
advantage or hacking of the games or Service. If circumstances
suggesting unauthorized or malicious programs are
detected, we will send the user a “Cease and Desist Letter” via in-game mail.
We collect and process
such information to investigate or prevent cheating, unauthorized use,
suspected fraud, infringement or other misconduct in any of our Services. For
EU users, we see such collection and processing as the pursuit of our
legitimate interest, in line with Art. 6 (1) (f) of
the GDPR. Where
we cannot rely on legitimate interests in a particular case, your consent to
such processing will be requested to the extent required by applicable law. In
this case, we process your personal information
in line with Art. 6 (1) (a) of the GDPR.
l
Information Collected to Measure Advertising Effectiveness. To measure advertising effectiveness as well as prevent fraud for our
advertising campaigns, we may use your IP address, your
in-game behaviors and your in-app purchases or transactions.
For EU users, we see
such collection and processing as the pursuit of our legitimate interests, in
line with Art. 6 (1) (f) of the GDPR. Where we cannot rely on legitimate
interests in a particular case, your consent to such processing will be
requested to the extent required by applicable law. In this case, we process
your personal information in line with Art. 6 (1) (a) of the GDPR.
Information We Obtain from Third Party Sources
We may
receive personal information about you from third-party sources. For example,
when you download
and install our Services and prior to the installation you have clicked an
advertisement to direct you to our Services, we will be provided with
information from which ad network and advertising campaign the install
originated from.
We collect
and process such information to market games to potential new users and measure
advertising effectiveness as well as prevent fraud for our advertising
campaigns. For EU users, we see such collection and processing as the pursuit
of our legitimate interest, in line with Art. 6 (1) (f) of the GDPR. Where we cannot rely
on legitimate interests in a particular case, your consent to such processing
will be requested to the extent required by applicable law. In this case, we
process your personal information in line with Art. 6 (1) (a) of the GDPR.
No Credit Card or Billing Information
Our Services enable
in-app purchases and we may collect your purchase and transaction record in the
Services to deliver the in-app products or services to you. However, we do not
process the payments for in-app purchase nor do we have any access to your credit
card information or billing information. Payment transactions for in-app
purchases in our Services are completed via Google or Apple or other app
stores/platforms. Any post-purchase processes are controlled by those app
stores/platforms and are subject to their specific terms. Please review the
privacy policy and terms of service of the app stores/platforms you choose.
Third Party Advertisements
We may include third
parties (“Advertising Company”) to distribute their advertisements in our
Services. We will not transfer or share any of your personal information with
such Advertising Company, as we do not collect or process any extra personal
information for the purpose of Advertising Company advertisement service.
Advertising Company is an independent controller of the personal data processed
in order to provide its advertisement service that it will individually
determine the purposes and means of processing such data. Such data refers to
any information or data that Advertising Company collects via its own tools
(e.g., Software Development Kits or “SDK”) implemented in our Services. Please
be aware that in no event will Advertising Company and us process personal data
as joint controllers.
You will find a list of
advertising SDKs implemented in our Services and we recommend you read and
learn more about such Advertising Company’s privacy policy:
l
Google AdMob
AdMob is an advertising service provided by Google Inc. For more information on how AdMob uses the collected information, please visit the Privacy Policy of Google.
You can also opt-out from AdMob by Google service by following the instructions described by Google.
Cookies are small text
files in which information is stored in connection with the Internet pages
called up and stored by your browser on your system for their respective
lifetime when you visit our websites. We use cookies to offer our service in a
functional and user-friendly form. These cookies are strictly necessary for
enabling your movement and providing our website service. These cookies do not
gather information about you that could be used for marketing purposes and do
not remember where you have been on the internet.
We use a cookie notice
banner that informs you of our cookies and request your consent if applicable
when you visit our website. Strictly Necessary Cookies should be always active
so that we can save your preferences for cookie settings. You can disable this
cookie in the settings of browsers. If you disable this cookie, we will not be
able to save your preference and you may not use some functions in our websites.
In so far as personal information
are processed by cookies, the associated processing serves to safeguard our
legitimate interests (Art. 6 (1) (a) of the GDPR) in the provision of our
services and their optimization.
For more
information about our use of cookies, please refer to our Cookie Policy.
To fully provide you
with successful operation and all functions of our Services, we must share
collected information with third parties under certain circumstances. We may share collected
information with third parties for the purpose of developing and delivering our
Services, conducting analysis and research and for measuring our advertiser’s ad campaign
performance. We
will share third parties with your personal information only in the ways that
are described in this Policy. From time to time, we may also share third
parties with your personal information when you give us your consent to do so.
For the performance of
a contract with you,
compliance with your consent, or based on our legitimate interests, we may disclose/share
your personal information:
With Our Service Providers
We may share personal
information with vendors,
consultants and other service providers
(“Service Providers”) such as our customer support providers, content
pull-in service providers, internet access services providers and cloud service
providers who are engaged by or working with us in connection with the operation of the Service and who need access to such
information to carry out their work for us. We provide the personal information
to other trusted partners to process it for us, based on our instructions and
in compliance with appropriate confidentiality and security measures.
With Our Analytics Providers
We use third-party
analytics such as Adjust (You may refer to the privacy policy of Adjust at https://www.adjust.com/terms/privacy-policy/) as our data processor for the purposes of analyzing the effectiveness
of the advertising campaign, such as installs tracking.
We use the following Firebase
services or features provided by Google, Inc. (You may refer to the privacy
policy of Firebase at https://firebase.google.com/support/privacy) :
-
Google Analytics for Firebase: helps us understand our users and how they use our apps
including information about interactions with the Services. Google Analytics
for Firebase uses the data to provide analytics and attribution information.
-
Google Cloud Messaging: enables us to send push notifications to your
mobile device to provide game updates and other relevant messages.
-
Firebase Crashlytics: provides us crash data associated with
specific instances of the Services.
We use Bugly provided by Tencent (You may refer to the privacy policy of Tencent at https://bugly.qq.com/v2/contract) for
crash reporting and crash log collection to help us quickly identify and
resolve anomalies.
With Our Affiliates
We may share personal information
with our parent company and affiliated
companies. Such companies will use your personal information in the same way as we can describe
under this Policy.
Due to Merger, Acquisition and Other Similar Change of Ownership Events
In the event
of a merger, acquisition, reorganization, bankruptcy, or other similar event,
information we collect, including the personal information, may be transferred
to our successor or assignee, if permitted
by and done in accordance with applicable law.
In Response to Our Legal Obligations
Please note that we are
not required to question or contest the validity of any search warrant,
subpoena or other similar governmental request that we may receive. We reserve
the right to disclose your personal information when required to do so by law,
such as to comply with legal process, including but not limited to a search
warrant, subpoena, statute, or court order, or to protect our rights and property, or that of the
public, regardless of whether the public authorities are within or outside
your country of residence. We may disclose part or all of the personal
information in the good faith belief that such disclosure is reasonably
necessary to avoid liability in order to investigate, prevent, or take action
regarding illegal activities, suspected fraud, situations involving potential
threats to the physical safety of any person, violations of our Terms
and Conditions, or as otherwise
required by law.
Your personal information
will be accessible from and will be stored and processed in our server in the United
States. As our Services are available to worldwide users, your personal
information may be transferred to and/or processed in countries or regions other than the country
where you reside. Although the data protection laws of such countries or
regions may be of lower standard than that of the European Union. We will, however,
ensure that your personal information set out in this Policy will remain
protected in accordance with this Policy. Where we transfer personal
information from inside the European Union to outside the European Union, we
may be required to take specific additional measures to safeguard the relevant personal
information. We will establish legal grounds justifying such transfer, such as
EU Commission-approved model contractual clauses, or other legal grounds
permitted by applicable legal requirements.
The Services may
contain links to other websites or be accessible from third-party platforms.
The fact that the Services link to a website does not mean that we endorse or
authorize that third party, nor is it a representation of our affiliation with
that third party. We are not responsible for the privacy policies of other
websites to which users choose to access or platforms from which the Service is
accessible. We encourage you to learn about their privacy and security
practices and policies before providing them with your personal information.
When we update or
“patch” any of our games or other software, we may utilize a patch routine to
verify whether the most recent version is installed on your device. If not, the
most recent version may automatically be downloaded to your device, and you
hereby consent to, and waive any further notice of, such upload. When you
download a game, in order to be able to use the game, the software may monitor
and communicate information from your device relating to hardware capacity.
We may send push
notifications to your mobile device to provide game updates and other relevant
messages. You can manage push notifications from your mobile device’s settings
page for the relevant game and/or from the settings page within the relevant mobile game. We may also
send local notifications to your mobile device to provide game updates and
other relevant information. You can manage local notifications from your mobile
device’s settings page for the relevant game and/or from the settings page
within the relevant mobile game.
Furthermore,
we may notify you via e-mail of our special offers, game news, event
information and other promotional information about our products and services. If
you do not want to receive such emails, you can opt-out by clicking the
unsubscribe links included in each promotional email. However, this shall not
affect our ability to send you service and account related emails or to use
your personal information as otherwise described in this Policy.
You may be able to
adjust the privacy settings of your device for push notifications, and other information
or features within the Services or the access permissions to your device. You
can
find more information under “Push Notifications” and the settings of your
device.
Please keep in mind that you may be
required to create a Google account or an Apple Game Centre ID or other app
marketplaces account in order to use certain functions of the Services. Your
personal information will be processed as described in the privacy policies of
such app marketplaces. You have the right to request from such app marketplaces
access to and rectification or erasure of your personal information collected
by such app marketplaces.
You may be entitled with rights in
connection with your personal information by the privacy laws of your
jurisdiction. Such rights often vary by jurisdiction,
which may include:
l
Right to access. You have the right to
access the personal information we hold about you and other relevant usage and
processing information.
l
Right to rectify. You have the right to
correct the personal information we hold about you that is inaccurate.
l
Right to erasure. You can delete your
account, or remove certain personal information that we hold about you.
However, please note that we may be required to retain some personal
information by data protection laws or laws in other fields (e.g., for the
defense of legal claims).
l
Right to object. You have the right to
object to our processing of personal information about you. You also have the right to lodge a complaint about our
processing activities carried out by us before the competent supervisory
authority.
l Right to
restrict processing and withdraw your consent. 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 that the withdrawal of your consent does not
affect the lawfulness of any processing activities based on such consent before
its withdrawal. If we stop processing the personal information, we may use it
again if there are valid grounds other than your consent, for example, when the
processing is necessary to fulfil the obligations of a contract, processing is
necessary to protect the vital interest of you or another natural person, or
other legitimate reasons under data protection laws.
l Right to
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 or pursuant to our contract with you, as described in the section “Information
Collection and Purposes”. However, 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).
You may enforce such
rights via the methods provided under the heading of “Contact Us”. To help us
verify that you are the subject of the personal information and realize your
rights above, we may require you to provide sufficient proof of identification as we request, and we
reserve the right to deny access to any user if we believe there is a question
about your identity. We aim to respond to all access requests within one month or
such other period provided for by law and will let you know with the reason if
we need more time to respond to your request.
Our retention periods
for personal information are based on business needs and legal requirements. We
retain your personal information for as long as is necessary for the processing
purpose(s) for which the information was collected or until we discontinue our
Services, whichever occurs earlier. For example, we may retain certain
transaction details and correspondence until the time limit for claims arising
from the transaction has expired, or to comply with regulatory requirements
regarding the retention of such data. When personal information is no longer
needed, we either irreversibly anonymize the data (and we may further retain
and use the anonymized information) or securely destroy the data.
We follow generally
accepted standards to protect the personal information submitted to us, both
during transmission and once we receive it. However, we cannot guarantee that unauthorized
third parties will never be able to overcome those measures or use users’
personal information for improper purposes. Also
please note that email and messaging systems are not considered secure, so we
discourage users from sending us personal information through these mediums.
Children under the age
of 16 are not eligible to use our Services. The Services are not directed to children
under 16. If we discover that we have inadvertently collected information from
children under 16, we will delete the child’s information from our systems as
soon as possible in accordance with applicable law. If you become aware that personal information
about a person under 16 has been provided to us, please immediately Contact Us.
If you have any unresolved
privacy concern that we have not addressed satisfactorily in this Policy or any
question, comment on this Policy or wish to realize any of your right described in this
Policy, please contact us at:
E-mail: privacy@volcano-force.com
Please include the relevant information such as game name,
server number (if any, e.g., battlefield in Army Men Strike) and your nickname
in your email, so that we could provide you more timely and appropriate
support.
California
Consumer Privacy Act. While
we have tried to fully describe our data practices elsewhere in this Privacy
Policy, this section supplements the description of our information collection and sharing practices elsewhere in this
Policy to provide certain disclosures to certain California residents whose
personal information Volcano Force processes pursuant to the California
Consumer Privacy Act (“CCPA”).
During the preceding 12 months, Volcano
Force has collected, used, and shared the categories of personal information
described in the section of our Privacy Policy entitled, “Information
Collection and Purposes” For example, depending on the Services you use, this
may include
your identifiers (e.g., IP addresses and mobile device identifiers), commercial
information, visual information (e.g., photos of yourself if you upload them), registration
information (e.g., email address), Internet and other electronic activity
information as well as inferences we draw from the other information we
collect.
As described in our Privacy Policy,
we disclose personal information to third parties for various business
purposes, including without limitation, for purposes of advertising, marketing,
and other services performed
on our behalf, to protect against fraud and malicious activity, and for other
business purposes described in this Policy. In addition, your information may
be accessible to third parties with whom you interact or direct us to share
your information through our services. While your information is shared in
these ways,
we do not share information in a manner that we consider a “sale” of personal
information for purposes of the CCPA.
We provide you certain of the rights
described in the section, “Your Choices and Control” above in accordance with state law, including the right to access your
data, the right to correct your data, the right to have your data deleted and
the right to take your data with you. We
will not charge you different prices or provide different quality of services
unless those differences are related to your information or otherwise permitted
by law. Please submit your request by sending an email to privacy@volcano-force.com. Once we
receive your request, we may verify it by requesting information sufficient to
confirm your identity, including by asking you to verify information about your
use of the Service. If you would like to use an agent registered with the
California Secretary of State to exercise your rights, we may request evidence
that you have provided such agent with power of attorney or that the agent
otherwise has valid written authority to submit requests to exercise rights on
your behalf.