PRIVACY POLICY

CLICKTOUCH TECHNOLOGY INTERNATIONAL COMPANY LIMITED and its affiliates (collectively "CLICKTOUCH" or "we") are committed to protecting your privacy. You should read and understand this Privacy Policy (the “Policy”) before use, especially the bold terms. This Policy applies to all CLICKTOUCH websites, products and services that are provided by or linked to it. If you read and agree to this Policy, you agree that we process your personal information for the purposes and in the manner as stated below.

CLICKTOUCH will review and modify this Policy from time to time. The most up to date version of this Policy will be published on our website . Please read and understand the lasted version. If you continue to use any of our services, you agree to comply with our revised policy.If there is a major change in the Privacy Policy, we may give you special reminders through one or more ways, such as internal emails, websites, pop-up windows, etc.

IF YOU ARE A MINOR（under the age of 18 IN HONGKONG or other LEGAL age defined as an adult in your jurisdiction）, YOU SHOULD READ THIS POLICY IN THE PRESENCE OF YOUR GUARDIAN BEFORE USING OUR PRODUCTS AND/OR SERVICES, AND USE OUR SERVICES AND PROVIDE YOUR INFORMATION ONLY AFTER YOU HAVE OBTAINED CONSENT FROM YOUR GUARDIAN. IF YOUR GUARDIAN DISAGREES IN YOUR USE OF OUR SERVICES OR PROVISION OF YOUR INFORMATION IN ACCORDANCE WITH THIS POLICY, PLEASE STOP USING OUR SERVICES AND NOTIFY US IMMEDIATELY【kf@dianchu.com】.

This Policy describes the way we collect and use your personal information, but may not cover all possible information processing scenarios. We may also supplement this Policy with additional terms about the collection of product/service-specific information, or publish them in the notices given when collecting information.

We provide this Policy to help you understand:

I. How We Collect and Use Your Personal Information

II. How We Use Cookies and Similar Technologies

III. What Information We May Share, Transfer or Disclose

IV. How We Retain, Store and Protect Your Information

V. How We Manage Your Information

VI. How We Process the Personal Information of Minors

VII. Notices and Amendments

VIII. How to Contact Us

I. How We Collect and Use Your Personal Information

We will only collect the information necessary to realize the function of our products on the basis of legality, legitimacy and necessity.

(I) How We Collect Your Information

When you use the CLICKTOUCH game service, we will collect through the following ways the information that you voluntarily provide when using the service or the information generated by your use of the service, in order to provide and optimize our service and protect your account security:

1. To help you create an account. When you register or use the CLICKTOUCH game service, we may collect your e-mail address（if any）, contact details（if any）, username and password with your consent or your initiative.And the account name and account ID information you imported through third-party social media (Facebook, Google Play or Game Center ) accounts.

2. To meet your requests regarding consumption function. We will collect your recharge and purchase records and other information, so that you can check your transaction records. Recharge and purchase records are sensitive information. We collect such information in order to enable the consumption function of CLICKTOUCH game products, otherwise the transaction could not be completed.

3. In order to ensure your use of our service, maintain the basic functions and optimize the performance of our game products, improve your game experience and protect your account security, we will collect information such as your IP address, device ID, device model, operating system type and version, software list unique device identifier (such as OAID、Android ID、UUID、IDFA、IDFV and other basic information describing your personal device), network type, device language, device hardware serial number,userAgent,Device sensors,Wi-Fi information,Application running list,Running processes,Carrier information,etc.

4. When you use the CLICKTOUCH game service, we will collect your game log information, including login log, item log, recharge log, binding information change log and in-game currency change log, so that you can view your game history and we can use the aforesaid information for statistical analysis of game operation, complaint handling and other game security analyses. We may also synchronize the aforesaid information to subsequent versions of the game to improve your game experience.

5. To protect your account security and create a fair, healthy and safe game environment, we will collect information, such as your game identity information, operating system information and breakdown records, for the purposes of fighting against behaviors that destroy the fair game environment or interfere with or disrupt the normal game services (such as scanning plug-ins, preventing cheating, etc.).

6. Information submitted by you through our customer service or when participating in our activities. We may collect the information submitted by you through our customer service or when participating in any of our activities, including your name, contact details and mailing address.

7.In order to facilitate the sharing of game fun and battles among players, the"rankings" functions in the game need to collect your user information (id, nickname)and game data.

8.Please understand that the functions and services we provide to you are constantly updated and developed. If any function or service is not listed above and your information is collected, we will explain to you the content, scope and purpose of such collection through prompts, website announcements or other ways in order to obtain your consent.

(II) How We Use Your Information

1. To provide services to you. We will provide you with functions and services, including basic game functions and consumption function, based on the information we collect.

2. Security protection. We will use your information for authentication, security protection, anti-fraud monitoring, archive backup, customer security services, etc.

3. Product development and service optimization.

When our system fails, we may record and analyze the information generated by such failure and optimize our service.

4. We may use your information while we are carrying out internal audit, data analysis and research, analyzing business operation efficiency, evaluating market share or improving our products or services.

5. We may send you Ads about products and services , invite you to participate in CLICKTOUCH 's activities (including promotional campaigns), market research or satisfaction survey, or send you marketing messages.  In order to push personalized advertisements to you, we need to retrieve the following information from you, we need to retrieve the information disclosed in article I. You can choose to agree or not to receive personalized advertisements. If you do not agree, we will ensure that personalized advertisements will not be pushed according to your behavioral preferences.

6. We will send you important notices regarding the update and installation of operating system or applications with your consent. If you do not agree, we may not provide you with relevant products or services.

7. We may use your information to comply with and enforce applicable statutory requirements and industrial standards.

(III) Third-party Providers and Their Services

If you want to use our functions of login, payment or statistics of game behaviors when using mobiles phones of MI, Huawei or other brands, CLICKTOUCH may access to SDK.The third parties' acquisition and processing of information, etc. are expected to comply with their own privacy policies, not with this Privacy Policy. As CLICKTOUCH has no control over the SDK operator, you should carefully read the SDK operator's privacy policy or statement before providing information to the SDK operator. However, we will conduct strict security monitoring and agree upon strict data protection measures with third parties in order to protect your data.  

To ensure a smooth experience, you may receive contents or URLs from third parties ("Third Parties") outside of CLICKTOUCH. CLICKTOUCH has no control over such Third Parties. You have the option to access any URLs, contents, products or services provided by such Third Parties.

Please note that we will share game data containing your personal information with the following partners/contractors in order to maintain the proper functioning of our current game services:

(IV) According to relevant laws, regulations and national standards, we may collect and use your information without your consent or authorization when we:

1. Perform our obligations or exercise our rights under this Privacy Policy or any other Agreements with you;

2. To the extent permitted by laws and regulations, exchange information with other companies or organizations in order to comply with laws and to protect the interests, property or safety of CLICKTOUCH or CLICKTOUCH's affiliates or partners, or you or other users, or the public;

3. Help you settle any controversy or dispute with others upon your reasonable request;

4. If required by administrative law enforcement or judicial authorities, disclose your information according to the type and disclosure manner of the information required to be disclosed;

5. Collect and use the information from any legal resources without the obligation of confidentiality, such as news report and government information publicity;

6. Sign any contract at your request;

7. Maintain the safe and stable operation of our products or services;

8. Provide your personal information to any academic research institutions that conduct statistics or academic research for public interests and de-identify your information contained their academic research or description results when they publish their results;

9. Provide your information at the request of your guardian; or

10. Collect and use your information in any other circumstances stipulated by laws and regulations or for public interests.

(V) Rules for Information Push（if any）

We may send you information about our activities, marketing, promotion and invitation to participate in market research or satisfaction survey, etc. If you do not want to receive such information, you may request us to stop the push.

II. How We Use Cookies and Similar Technologies

To improve your experience, we may use cookies, web beacons, log files, scripts, eTags or similar technologies (collectively "Cookies"). A Cookie is a plain text file saved on a computer or mobile device by a network server. The contents of a Cookie can only be retrieved or read by the server that has created it. Each Cookie is unique to your web browser or mobile application. A Cookie usually contains identifiers, website names, and some numbers and characters. With Cookies, we may save data such as your items and preferences in your device and generate small files, so that we can provide specific functions for you. You may turn on or turn off the Cookies through the settings of your device or browser. For details, visit About Cookies.org. However, if you turn off the Cookies, you may not be able to use some functions of our game service.

III. What Information We May Share, Transfer or Disclose

(I) Sharing

We will not share your personal information with any company, organization or individual, except for the following circumstances:

1. We may share your personal information with other parties with your express consent.

2. We may share your personal information according to laws and regulations or the mandatory requirements set out by competent government authorities.

3. To the extent required or permitted by law, we may share your personal information with a third party in order to protect the interests, property or safety of CLICKTOUCH or CLICKTOUCH's users or the public.

4. We may share your personal information with any of CLICKTOUCH's affiliates.

5. For the purposes stated in this Policy only, we may share your personal information with any of CLICKTOUCH's authorized partners when services are provided by partners authorized by CLICKTOUCH. We may share some of your personal information with our partners to provide better customer service and better user experience. For example, we might provide your personal information to a third party engaged by CLICKTOUCH for data statistics and analysis, provided that such a third party must comply with our data privacy and security requirements. We will share your personal information for legal, legitimate, necessary, specific and clear purposes only, and will share your personal information to the extent necessary to provide services.

We will sign strict confidentiality agreements with the companies, organizations and individuals with whom we share your personal information, requiring them to handle your personal information in accordance with our instructions, this Policy and all other relevant confidentiality and security measures.

6. We may share your personal information in order to perform our obligations or exercise our rights under this Privacy Policy or any other agreements with you.

7.In order to facilitate the sharing of game fun and battles among players, the "rankings" functions in the game need to collect your user information (id, nickname) and game data .The above information is shared with other players. Since these functions are basic functions, they cannot be turned off. If you do not agree, you can refuse to proceed to the next step of registration or cancel your account.

(II) Transfer

We will not transfer your personal information to any company, organization or individual except for the following circumstances:

1. We may transfer your personal information with your express consent;

2. In case of merger, acquisition or bankruptcy liquidation where the transfer of your personal information is required, we will require the new company or organization holding your personal information to continue to be bound by this Policy, or we will require such company or organization to seek your consent or authorization again.

(III) Disclosure

We will disclose your information under the following conditions only and in compliance with relevant security measures:

1. We may disclose your personal information at your request and in the manner expressly agreed by you;

2. We may disclose your personal information in accordance with laws and regulations or the mandatory requirements set out by competent administrative or judicial authorities; or

3. In case of any reorganization, merger, bankruptcy or liquidation proceedings where CLICKTOUCH is involved, we may disclose your personal information to the counterparty.

IV. How We Retain, Store and Protect Your Information

(I) Retention of Information

We will retain your personal information for the period required to achieve the purposes stated in this Policy, unless otherwise required or extended by law. The retention period may vary for different scenarios and products or services. The criteria we use to determine the retention period include: the time required to retain personal information to achieve the service purpose, including providing products or services, maintaining corresponding transaction and business records, controlling and improving the performance and quality of products or services, protecting the safety of systems, products and services, responding to possible user inquiries or complaints, problem locating, etc.; whether the user agrees to a longer retention period; and whether there are any requirements in any law or contract for data retention, etc. We will also retain your registration information as long as it is necessary for your use of your account.

(II) Storage of Information

1. Manner and Period of Storage

We will store your personal information in a safe manner, including storing it locally or in the database, etc.

In general, we will only store your personal information for the period required to achieve the purpose of providing our services or as required by laws and regulations.

2. Territory of Storage

Depending on your location and game server, Game data is stored in HONGKONG,CHINA，User personal information is stored in BEIJING, CHINA.

3. Terminal Notice of Products or Services

Where the operation of a product or service is terminated, we will make a public announcement in accordance with relevant laws and regulations, and will protect your legitimate rights and interests.

(III) Protection of Information

CLICKTOUCH attaches great importance to the security of personal information. We will take appropriate physical, administrative and technical measures to protect your personal information from unauthorized access, disclosure, use, modification, damage or loss. For example, we will use appropriate encryption technology to keep your information confidential; we will use a proper protection mechanism to prevent malicious attacks on your information; we will deploy access control mechanism to ensure that only authorized personnel can access your personal information; and we will hold security and privacy training courses to enhance employees' understanding of the importance of protecting personal information.

YOU SHOULD UNDERSTAND THAT THE INTERNET IS NOT AN ABSOLUTELY SECURE ENVIRONMENT, AND THAT THE WAYS USED TO COMMUNICATE WITH OTHERS, SUCH AS E-MAIL AND INSTANT MESSAGING, CANNOT BE DETERMINED TO BE FULLY ENCRYPTED. WE SUGGEST THAT YOU DO NOT SEND PERSONAL INFORMATION IN THESE WAYS. YOU HAVE THE OBLIGATION TO KEEP YOUR ACCOUNT AND PASSWORD INFORMATION CONFIDENTIAL. PLEASE KEEP IT CAREFULLY AND PROPERLY.  IF YOU FIND THAT YOUR PERSONAL INFORMATION, ESPECIALLY YOUR ACCOUNT OR PASSWORD, IS DISCLOSED, PLEASE CONTACT OUR CUSTOMER SERVICE IMMEDIATELY, SO THAT WE CAN TAKE APPROPRIATE ACTIONS. PLEASE USE A COMPLEX PASSWORD AND PAY ATTENTION TO PROTECT YOUR INFORMATION.

ALTHOUGH WE STRIVE TO PROTECT YOUR PERSONAL INFORMATION, PLEASE UNDERSTAND THAT, DUE TO THE LIMITATIONS IN TECHNOLOGY AND RISK PREVENTION, WE CANNOT ALWAYS GUARANTEE FULL SECURITY OF YOUR INFORMATION. YOU SHOULD FURTHER UNDERSTAND THAT THE SYSTEM AND COMMUNICATION NETWORK THROUGH WHICH YOU ACCESS OUR SERVICE MAY FAIL FOR REASONS BEYOND OUR CONTROL.

In case of any unfortunate security incident, we will promptly inform you of the basic information and possible effects of the incident, the measures we have taken or will take, the suggestions on your risk prevention and reduction, the remedial measures for you, etc. according to laws and regulations. We will also promptly inform you of other incident-related information by e-mail, letter, telephone, push notification, etc. When it is difficult to notify the information subject one by one, we will make a public announcement in a reasonable and effective manner.  Meanwhile, we will report the disposal of such security incident according to the requirements of competent regulatory authorities.

V. How We Manage Your Information

1. Inquiry, Access, Copy, Transfer, Correction, Supplement and Deletion

During your use of CLICKTOUCH Game services, we will provide you with corresponding operation settings for managing your personal information according to the specific conditions of each game product, so that you can inquire, access, copy (obtain a copy), transfer, correct, supplement, Delete or withdraw your relevant personal information.

(1)You can inquire and access your basic account information (account avatar, nickname, and other personal information you choose to fill in by clicking [Avatar] - [set]-[Basic Information] in the CLICKTOUCH Game products you use, depending on specific the game setting function shall prevail), game history information (such as game ID, Total Power, Monarch Lv or game information specific to each product), and correct and supplement your basic account information according to specific circumstances.

(2)If you have any other query, access, copy (obtain a copy), transfer, correction, supplement or deletion, or you have doubts or difficulties in using the corresponding functions of the game product, you can click the customer service icon or [Avatar]-[set]-[Contact Us] button to contact customer service, or you can choose to contact us through the feedback channels listed in the "How to Contact Us" section of this policy. We will receive your question and verify your user identity. We will process your request within 15 days.

Unless otherwise required by laws and regulations, when you correct, supplement, delete your personal information or apply for account cancellation, we may not immediately correct, supplement or delete the corresponding information from the backup system, but we will no longer update the relevant information. process and will correct, supplement or delete this information when the backup is updated. Once the relevant information is deleted or the account is cancelled, it cannot be recovered, please operate with caution.

2.Open and share

Some features of CLICKTOUCH Games allow you to not only expand your social network, but also publicly share information about you with all users who use the feature, for example, the information you upload or post, the information you upload or post to others response to the information. As long as you do not delete the information you have disclosed or shared, the relevant information may remain in the public domain; even if you delete the shared information, the relevant information may still be independently cached, copied or stored by other users or third parties not controlled by us, or kept in the public domain by other users or such third parties. Therefore, we remind and ask you to carefully consider whether to disclose or share your information through the above channels.

3. Account cancellation

Due to the particularity of game products, the game account contains your game experience, game level, game virtual items, etc. In order to avoid malicious logout caused by the theft of your game account,We provide you with a way to cancel your account. If you meet and agree with the terms of our "Account Cancellation Notice" and the relevant laws and regulations, you can :

[1]click the [Avatar] - [set]-[Basic Information] - [Account Cancellation]

[2][Support] button to submit the account cancellation request.

In order to the security of your account we will receive your request and verify your user identity.

You may also choose to contact us through the feedback channels listed in the "How to Contact Us" section of this policy, and we will process your request within fifteen days of receiving your question and verifying your user identity.

AFTER YOUR ACCOUNT IS CANCELLED, WE WILL STOP PROVIDING YOU WITH ALL OR PART OF THE TOUCH GAME SERVICES, AND WILL DELETE OR ANONYMIZE YOUR PERSONAL INFORMATION ACCORDING TO YOUR REQUEST, UNLESS OTHERWISE PROVIDED BY LAWS AND REGULATIONS. ONCE THE RELEVANT INFORMATION IS DELETED OR THE ACCOUNT IS CANCELLED, IT CANNOT BE RECOVERED, PLEASE OPERATE WITH CAUTION.

4.Change the scope of authorization and consent

You can choose whether to provide us with personal information. You can change the scope of your authorization to continue to collect information or withdraw your authorization by deleting information, turning off device functions, Third-party social media account unbinding,and canceling your account. You can also contact us by clicking the customer service icon or [Support] button in the game to withdraw the authorization.

When the authorization is withdrawn, we cannot continue to provide you with the services corresponding to the withdrawn authorization, and we will no longer process your corresponding information. However, your decision to withdraw the authorization will not affect the previous information processing based on your authorization.

VI. HOW WE PROCESS THE PERSONAL INFORMATION OF MINORS

WE WILL ONLY USE OR DISCLOSE THE PERSONAL INFORMATION OF A MINOR COLLECTED WITH THE CONSENT OF HIS/HER PARENT OR LEGAL GUARDIAN IF PERMITTED BY LAW, OR EXPRESSLY AGREED BY SUCH PARENT OR GUARDIAN, OR NECESSARILY REQUIRED TO PROTECT SUCH MINOR.

IF YOU ARE THE GUARDIAN OF A MINOR AND HAVE ANY QUESTIONS ABOUT THE USE OF OUR SERVICES OR THE USER INFORMATION PROVIDED TO US BY THE MINOR UNDER YOUR GUARDIANSHIP, PLEASE CONTACT US. WE WILL PROTECT THE CONFIDENTIALITY AND SECURITY OF MINOR USERS' INFORMATION IN ACCORDANCE WITH THIS POLICY AND RELEVANT LAWS AND REGULATIONS. IF WE FIND THAT WE HAVE COLLECTED THE PERSONAL INFORMATION OF ANY MINOR WITHOUT THE PRIOR CONSENT OF HIS/HER PARENT OR LEGAL GUARDIAN, WE WILL DELETE THE RELEVANT INFORMATION AS SOON AS POSSIBLE.

VII. Notices and Amendments

We may amend Privacy Policy from time to time. When any terms or conditions of this Privacy Policy have been amended, we will inform you of the amended policy in a proper way at the time of version update. You should read the amended Privacy Policy carefully. If you continue to use the CLICKTOUCH game service, you agree that we collect, process or use your personal information in accordance with the updated Privacy Policy.If there is any major update, we will announce it in advance by means of internal letter, email, etc.

VIII. How to Contact Us

When CLICKTOUCH processes your personal information in accordance with this Policy, the CLICKTOUCH entity that responds to your request, contacts you, provides you with products or services, or has entered into or will enter into a contract with you is the actual controller of the relevant personal information.

If you have any doubts, suggestions or questions, please contact us by e-mail to kf@dianchu.com.

We will respond within 15 days after receiving your doubts, suggestions or questions and verifying your user identity.