PRIVACY POLICY

PRIVACY POLICY

Last updated on [March 27, 2023]
 
This privacy policy (this “Privacy Policy”) explains how Seasun Games Corporation Limited and our Affiliates (“Seasun”, “we”, “our” or “us”) collect, use and disclose your personal data. This Privacy Policy applies to 【BIPHASE】(“Game”) and related services (collectively, our “Services”).
By downloading, accessing, using and/or interacting with our Services, you fully understand about our collection, use and disclosure of your personal data as described in this Privacy Policy. This Privacy Policy is incorporated by reference into the Seasun End User License Agreement available at [https://biphase.xoyo.games/show-181-12-1.html] (the “EULA”) and is subject to the provisions of the EULA. Capitalized terms used but not defined in this Privacy Policy shall have the meaning ascribed to such terms in our EULA.
 
This Privacy Policy will help you to understand:
  1. Who We Are
  2. What Personal Data We Collect and How We Use
  3. Cookies and Similar Technologies
  4. How We Entrust A Third-Party to Process, Share, Transfer and Disclose Your Personal Data
  5. How We Store Your Personal Information
  6. How Long We Keep Your Personal Data
  7. Children
  8. Your Rights
  9. Changes
  10. Contact Us
  11. Who We Are
Registration Information:
Company name: Seasun Games Corporation Limited
Company number: 1528170
Registered office: Suite 3208, 32/F., Tower 5 , The Gateway, Harbour City, Tsim Sha Tsui, Kowloon, Hong Kong
Contact & Complaints
In the event that you wish to make a complaint about how we process your personal information, please contact us immediately.
Email: [weiyao@kingsoft.com]
  1. What Personal Data We Collect and How We Use
We only collect and process your personal data in the minimum scope necessary for realizing the following purposes based on appropriate legal basis.
2.1 In order to improve our Services and correct bugs or errors that occur when you are playing the game, we will collect relevant information including but not limited to your behavioral data in the Game, device information and network status.
The processing activity for this purpose is based on our legitimate interests and will not override your legal rights and interests.
  1. Cookies and Similar Technologies
We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Services. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities.
We use cookies and similar technologies as below:
(1) To allow us to recognise you and your device, for example by identifying your IP address;
(2) To allow our Services to interact with a third party social network or platform (where you have chosen to allow such interaction);
(3) To provide you with more customized Services, for example to provide our Services in the correct language;
(4)To obtain data which will allow us to understand how people are using our Services so that we can improve them.
(5)By accessing our website(s) or using our Services you consent to our use of cookies in accordance with this Privacy Policy. You can disable cookies through your web or phone browser settings but you may find you are not able to enjoy all the features of our Services if you do so.
You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies, or instruct the device or web browser (as applicable) to provide notice at the time of installation of cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event that you refuse to install cookies, the Game may be unable to operate as designed.
Type of cookie What it does Cookies
Cookies necessary for essential services These cookies are essential to provide you with the Services and to use some of its features, such as to authenticate log-in and allow users to find friends who use the Services. Without these cookies, services you have asked for, like secure login accounts, would not be possible. Session_id
Performance/ Analytics/Tracking Cookies We use Google Analytics to statistically analyse how our website is performing in order to provide you with a better user experience and continually improve our service. _ga;_gac_
 
 
 
  1. How We Entrust a Third-Party to Process, Share, Transfer and Disclose Your Personal Data
We may share your personal data with the following categories of third parties in order to provide our Services to you.
4.1 Our affiliates
Seasun is a global company and has affiliates all over the world. In order to provide our Services, we will share your personal data with our affiliates who process your personal information in order to operate the Game Services based on the respective legal basis and data processing agreements signed between us. All related group companies may only use your personal information in accordance with this privacy policy.
4.2 Business partners and service providers
（1） Game developers
The Game developers can process certain data required for the Game’s and other Services’ further improvement.
4.3 Law enforcement / legal obligation
（1） Anti-cheat and anti-fraud companies
We may share the information required for our detection, investigation and prevention of cheating in the Game and EULA violations only for the purposes of detection, investigation and prevention of cheating in the Game.
（2） Public authorities and auditors
Some personal data shall be disclosed to public authorities, e.g., tax and customs authorities, auditors, and other competent parties in accordance with the applicable laws.
4.4 Sale or merger
A third party that acquires all or substantially all of us or our business. We will disclose information to a third party in the event that we sell or buy any business or undergo a merger, in which case we will disclose your data to the prospective buyer of such business. We will also disclose information to a third party if we sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, personal data may be among the transferred assets. You will be notified via email, in-app/in-game notice and/or notice on our website of any change in ownership or users of your personal data.
  1. How We Store Your Personal Information
In order to normally operate and maintain this product, we will store and process your personal data in our servers which located in various countries. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this privacy policy. You hereby acknowledge that you are fully aware your personal data will be accessible from and will be processed on our servers located in various countries (depending upon your location and the game server you select). Our servers are located in:
（1） Germany;
  1. How Long We Keep Your Personal Data
6.1 How we determine
We determine the retention period of your personal data taking consideration of the following elements:
  • period of the contractual relationship with you;
  • sensitivity of the personal data;
  • time elapsed since your last interaction with us;
  • security reasons;
  • applicable statutes of limitation;
  • ongoing or potential litigation or dispute;
  • regulatory or legal obligation to retain the personal data.
6.2 How long we keep your personal data
We will retain most of your personal data as long as needed to provide services or products to you, or as required or permitted by applicable laws.
When destroying personal data, measures will be taken to make the personal data irrecoverable or irreproducible, and electronic files which contain personal data will be deleted permanently using a technical method which makes the files irreproducible.
In the event that the processing and retention period have terminated, but personal data is required to be retained continuously for other reasons including but not limited to for the purposes as prescribed under applicable laws, the relevant personal data will be stored and maintained separately from other types of personal data. If you require us to destroy your personal data before the end of its life cycle (as set out in the retention policy above), we will destroy your personal data in accordance with local laws.
  1. The Security of Your Personal Data
We are committed to maintaining the privacy and integrity of your personal data no matter where it is stored. Our group companies have information security and access policies that limit access to our systems and technology. We also protect data through the use of technological protection measures such as encryption. Your personal data will remain subject to our technical and organizational controls and our policies and procedures (including but not limited to this Privacy Policy).
Unfortunately, the transmission of information via the internet is not completely secure. Although we will use commercially reasonable efforts to protect your personal data, we cannot guarantee the security of the information transmitted to our services; any transmission of your information is at your own risk.
In the case of a personal data breach, we will notify the personal data breach to the supervisory authority competent, where feasible, not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of you.
When the personal data breach is likely to result in a high risk to the rights and freedoms of you, we will communicate the personal data breach to you without undue delay.
  1. Children
You hereby represent that you are an “adult” (as defined in the applicable in your jurisdiction) and have the requisite power and authority to access and/or use our Services. If you are not an adult, you must obtain the consent of your parent or legal guardian to use the Services. Usually our Services are not intended for children under the age of 13 and we do not knowingly collect any personal data from such children. Children under the age of 13 should not use or attempt to use our Services, and if you are under 13, please do not attempt to use our Services. If you are between the ages of 13 and 18 (or the relevant age in your jurisdiction where you are considered a minor), you must obtain the consent of your parent or legal guardian to use the Services.
In the event that we learn that we have inadvertently gathered personal data from a child under the age of 13, we will take reasonable measures to delete such information from our records. Parents who believe that we might have gathered any information from or about a child under the age of 13 may submit a request to the email address set forth in the section “Contact & Complaints” below.
  1. Your Rights
9.1 The right to be informed
You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information in this Policy.
9.2 The right of access
You have the right to obtain access to your personal data. This is so you are aware and can check that we are using your personal data in accordance with applicable data protection laws.
Please contact us and submit a request to the email address set forth in the section “Contact Us” below.
9.3 The right to rectification
You are entitled to have your personal data rectified if they are inaccurate or incomplete. If you believe we hold any other personal data about you and that information is inaccurate, for information that you can change in your game settings, you can change it. And for information that you can't change, please contact us and complete the request form.
9.4 The right to erasure
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there is no compelling reason for us to keep using it. This is not an absolute right to erasure and exceptions apply.
You may request that we erase the personal data we hold about you in the following circumstances:
ž you believe that it is no longer necessary for us to hold such personal data; or
ž you believe the personal data we hold about you is being unlawfully processed by us.
We may need to retain personal data 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 data that has been made available publicly on the Services and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal data or providing links to the personal data to erase it too.
You can also exercise your right to restrict our processing of your personal data (as described below) whilst we consider your request.
9.5 The right to restrict processing
You have a right to require us to stop processing the personal data we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal data, 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 data, we will try to tell any third party to whom we have disclosed the relevant personal data so that they can stop processing it too.
You may request we stop processing the personal data we hold about you where:
ž you believe the personal data is not accurate for the period it takes for us to verify whether it is accurate;
ž you wish to erase the personal data as the processing we are doing is unlawful but you want us to retain the personal data but just store it instead; or
ž you wish to erase the personal data 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.
9.6 The right to data portability
You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your personal data easily between our IT systems and theirs safely and securely, without affecting its usability.
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).
9.7 The right to object to processing
You have the right to object to certain types of processing, including processing for direct marketing (which we perform only with your consent).
9.8 The right to lodge a complaint
You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection authority.
9.9 The right to withdraw consent
If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.
  1. Changes
If we make any material changes to this policy, we will post the updated policy here and notify our users. Please check this page frequently to see any updates or changes to this policy.
  1. Contact Us
If you need to contact us for any reason (including to exercise any of your rights in relation to your personal data as set out above) please send us your request at:[weiyao@kingsoft.com]
In the event that you wish to make a complaint about how we process your personal data, please send us your request at: [weiyao@kingsoft.com]
 
 
SUPPLEMENTAL JURISDICTION-SPECIFIC TERMS
 
Some jurisdictions’s laws contain additional terms for users of the Game Services, which are set out in this section.
 
If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you.
 
California
This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).
 
Collection and Disclosure of Personal Information
 
Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device set forth in the section “The Types of Personal Information We Use” and the section “Cookies”.
 
We collect your personal information for the following purposes:
 
We will collect your personal information for the purpose set forth in the section “How We Use Your Personal Information”
 
We disclose personal information to the following types of entities:
 
We will disclose personal information to entities set forth in the section “How We Store and Share Your Personal Information”.
 
In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” in the CCPA.
 
Indonesia
Consent
By accepting and consenting to this privacy policy, you agree that we may collect, use and share your personal information in accordance with this privacy policy, as revised from time to time. If you do not agree to this privacy policy, you must not access or use our services and we have the right to not provide you with access to our services.
Parental and Guardian Consent
If you are under the age of 21, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game Services.
 
Data Subject Rights
You have the right to access your personal information stored in our Game from time to time in accordance with applicable data privacy laws and regulations in Indonesia.
Data Breach
In the event we fail to maintain the confidentiality of your personal information in the Game, we will notify you through the contact information provided by you or via the Game, to the extent required by local laws and regulations, at the latest 14 days since we acknowledge the breach of confidentiality.
 
Data Retention
Notwithstanding the provision on the erasure of personal information, to the extent required by local laws and regulations, we will retain your personal information, at the latest for five years.
Notification to Amendment of this Privacy Policy
 
In the event we amend this policy, we will ask you to acknowledge the changes through a pop-up notification or the splash screen on our mobile app. If you fail to explicitly express your objection to the amended policy within the above notification period, you will be considered as accepting the changes and agreed to the new policy. However, you may stop using or accessing our Service by unsubscribing at any time, if you cease to agree with the changed policy.
 
Data Accuracy and Third Party Consent
You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).
 
Malaysia
Parental and Guardian Consent
In the event you are agreeing to this privacy policy in order for a minor to access and use the Game Services, you hereby consent to the provision of personal information of the minor to be processed in accordance with this privacy policy and you personally accept and agree to be bound by the terms in this privacy policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor’s compliance with this privacy policy.
 
Rights of Data Subjects
Right of access: You have the right to request access to and obtain a copy of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law.
 
When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.
 
Right of correction: You may request for the correction of your personal information. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.
 
Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details provided above. However this may affect our provision of the Game Services to you.
 
Singapore
 
By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, the People’s Republic of China (for the purpose of this Privacy Policy, this term excludes Taiwan, Hong Kong SAR and Macau SAR).
 
Thailand
By clicking “accept” or by proceeding with the sign up process, you acknowledge that you have read, understood, and agree to this privacy policy. If you do not agree with this privacy policy, you must not use the Game Services.
You may withdraw your consent to the processing of your personal information. You may request us to provide access to, make any correction to, discontinue, restrict the use or provision of, erase any and all of your personal information and/or provide you such information which is stored by us in a machine readable format as well as file a complaint to a relevant authority, to the extent provided by the Act on the applicable data privacy laws and regulations in Thailand, When you wish to make such requests, please contact us.
We will ask you to acknowledge any material changes to this privacy policy through a pop-up notification or the splash screen of our mobile app, and give you an opportunity to reject such changes, failing which the changes will become effective as stated in the notice.