War and Order Privacy Policy
IMPORTANT! PLEASE READ CAREFULLY BEFORE YOUR REGISTRATION OF BEING ONE WAR AND ORDER GAME USER!
SUMMARY
This Privacy Policy (referred to as the 'Policy') is an integral part of the War and Order User Agreement. We thank you for choosing the War and Order game operated by the service provider HONG KONG KE MO SOFTWARE CO., LIMITED (herein 'Camel', 'we' or 'us'). We are a company with the registered address as Flexi-space 108, Unit 608-613, L6, Core C, Cyberport 3, 100 Cyberport Road, Hong Kong. We promise to care handle the personal information we collect from you, including your visits to our websites, use or access our games (whether played on mobile devices, PCs, websites or other approved platforms), and/or otherwise use or access any of our provided services (including but not limited to software systems, customer support, marketing and advertising, and community services), or information that you actively provide us (for example, when opening a game account or subscribing to our official media platforms). This Policy explains which personal information we collect from you and for what reasons; how we use, store, and transfer such data; and also how you can contact us to ask about your data and exercise your rights. We will collect, use, share, store, process, transfer, and delete (hereinafter referred to as "process") your personal information (hereinafter referred to as "data") in accordance with the relevant applicable information protection laws and regulations.
In the event of a merger, acquisition, reorganization, bankruptcy, or other similar events, we will make an announcement in advance, disclose the details of the event and information about the successor, and, with the express consent of you and/or your parent or legal guardian (if applicable), your data may be transferred to the successor. We may periodically modify, adjust, or revise the terms of this Policy. We will announce to you the updated terms. You acknowledge and agree to check the updated terms regularly. If major clause changes are involved, we will make an announcement in advance.
We only process your data in accordance with applicable data protection legislation, including but not limited to the (EU) General Data Protection Regulation (2016/679) and data protection legislation applicable to the country you are located in (referred to hereafter as "applicable law").
Depending on whether you are a website visitor, customer, and/or user of our services, we might process your contact details (email address, telephone number, and postal address), your username, passwords, payment-related details, and other data. We might also process information about your technical equipment, such as your hardware and software type, location data, and other information you provide us. For more content about how we process data, please see the sections below.
We will use your data for different purposes. We will, for example, use the data to provide you with the service you have requested, to improve our game and other services, to predict user trends, to make recommendations based on your usage, to process payments, and other behaviors. For more information about how we use your data, please read below.
When we collect personal information about you, you are entitled to the following rights under applicable law:
● The right to access and correct your data;
● The right to access and rectify your data;
● The right to restrict our processing of data;
● The right to demand that we delete your data; and
● The right to data portability.
You have the right to reject this Policy, but please be aware that once you reject this Policy, you may be unable to continue using or may not be able to continue with full use of our game services.
For more information about the relevant rights you have for your data, please contact us at: wao@camel4u.com. The following is a more detailed description of how we use data.
CONTENT
1. Who are we?
2. What we promise
3. What is personal information?
4. Reasons for processing your data
5. When do we collect your data?
6. What data do we collect?
7. How do we use your data?
8. Cookies or similar technologies
9. Who do we share your data with?
10. Can minors and children use our services?
11. Accessing and changing your data
12. Right to erasure
13. Right to object to the processing of your data
14. Right to restriction
15. How to get a copy of your data or receive a copy of your data?
16. How to enforce your rights?
17. If you choose not to share your data with us
18. How to withdraw your consent or delete your game account?
19. Data Storage and Transfer
20. How long will we keep your data?
21. Security measures to protect your data
22. Changes in the Privacy Policy
23. How to contact us and how to make complaints?
24. DPO contact information
1. Who are we?
We are Hong Kong Ke Mo software Co., Limited. This Policy applies to games and game services operated by us or any of our affiliated companies.
We are the controller of the personal information collected. If you have any questions or want to know more about how we use your data, please contact us through our in-game Contact Us feature or email us at wao@camel4u.com.
2. What we promise
We promise to keep your data safe and not sell your data to third parties. We promise to grant you the right to access and delete your data, to provide you with various ways to manage and review your marketing choices, and any other information (for example, newsletters) you get from us.
3. What is personal information?
Personal information can be any information relating to an identified or identifiable natural person. In other words, it can be any information that could allow us to identify you both directly and indirectly (for example, your name, email address, IP address, or contact address).
4. Reasons for processing your data
We will only use and process data about you if we have one of the following reasons to do so:
● Necessary to enter and fulfill a contract (for example, when you make purchases in the game);
● When it is our legal duty or legal obligation (for example, to identify your age and make sure we are not collecting data from minors and children, for record keeping purposes, or to fulfill the requirements in relation to regulatory bodies);
● When necessary in response to sudden public health events or to protect the life, health, and financial security of the natural person in emergency situations;
● When implementing news reports for the public good, media scrutiny, and other behaviors to handle your data within a reasonable range;
● When you consent to it (for example, when binding a specific game account to a third-party account); or
● When it is in our legitimate interest (for example, to enforce our policies, manage our everyday business, use in an anonymized and aggregated way to perform statistical analysis, for personalized marketing purposes, to ensure information security, to prevent fraud, or to transfer the data to a different part of the organization when necessary). When we process your data based on our legitimate interests, we conclude that doing so doesn't violate your interests or fundamental rights and freedoms. If you have any objection to this, you are welcome to contact us to learn more about how we have reached this conclusion.
5. When do we collect your data?
We will collect data about you when you use our services, including the following situations:
● When you register a game account
● When you play our games
● When you use our websites, apps, or games
● When you use a relevant function
● When you purchase an in-game product
● When you register on and use our forums
● When you contact our support services, via emails or letters
● In customer surveys
● If you participate in user research initiatives
● If you participate in a playtest or pre-release test, such as alpha/beta/etc.
● If you take part in our competitions or promotions
● When you enroll in or participate in our events
● When you send us a game pitch
● When you click on one of our ads or in our newsletters
● When you subscribe to receive our press releases, messages, or notifications
● When you log in to our game services using a third-party account
● When you work for us. In such a case, please contact our Human Resources department separately for more information.
6. What data do we collect?
We collect data that you have explicitly provided to us in different situations. We also collect data generated by your device or when you use our services. The data types are further explained below.
(1) When you register our game account, subscribe to our press releases or messages, and when using the third-party bind feature, the data you expressly provide us with:
● The user account information in the forum or game (account ID, name, avatar, cover, bio, signature, authentication information, and others)
● Country or IP address
● Name, mobile phone number, email, and identification
● Passwords created to access parts of the services
● Device and configuration information
Important Note: For the visible information, such as your account name, avatar, chat content, and other information posted in our product to other players and users, this information may be collected and used by others. Therefore, please post this information with caution. If it's because you post personal information yourself, which causes personal information to be leaked, we won't assume any liability. If you discover improper collection or use of your personal information in the game service by other players or other third-party services outside of the game service, please contact us promptly through the contact info published in this Policy.
(2) In addition to the above, when purchasing a game product or enrolling in an event, you may have to provide us with the following data:
● Physical address
● Telephone number
● Billing receipt information
● Third-party account info such as email address, Facebook name, etc.
● Purchase order number
(3) Data we collect when you use our games or game services:
● Profile and usage data. This includes the profile you create to clearly identify yourself when using our game services, and the Internet Protocol address that may uniquely identify you when you use our games. It also includes data about how you use our game services and other game data. We gather this data from devices you use, such as computers, smartphones, and tablets.
● Payment and transaction data
● Platform type (Android, iOS)
● Preferred language
● Gender
● Information about your device, device serial number, device ID, device information (device name, device type, MAC address, IMEI, CPU, graphics card model, OS version and language, time zone, screen DPI, device resolution), hardware, and software.
● Your device’s IDFA (if you’re an iOS user) or Google Advertising ID (if you’re an Android user) or other platform information, such as your IP address.
● In-game activity includes but is not limited to what games you play, own, how you play, how often, and for how long.
● Game crash reports and error dump information from your device. Bugs, errors, and other data about crashes and diagnosis thereof (if the occasional system crash occurs in our services). Device information (name, model, memory size, and graphics card model) and game information (game version, user UID, stacktrace); we use such information to conduct identity verification for security purposes, to identify and address bugs, and to evaluate and improve the functionality of our services in accordance on the legal basis that it is in our legitimate interest to ensure the security of our services, and to improve our services.
● For the Android version: application information (APK name, version, startup time, process name), user account, device information (model, OS version, brand, CPU structure, root status, the unique identifier of ROM, screen resolution, system startup time, whether an emulator is being operated, the installed APK information, MAC address, network type, names of the running applications, list of file names in the cache directory of SD card application, and Wi-Fi name).
● For the PC version: application information, memory, executable module, system driver module, new thread, new load module, proxy, network, CPU, disk and graphics card, account information and device name, specific file types for a specific directory, names of process windows, and name signature of a suspicious process module, game version, game identification information, hardware and operating system information, application program list, current running task information, security authentication machine code, game and non-game abnormal process information, game operation-related calling methods and information, whether there are other external programs on the game interface, the record and data of the game attempted/accessed by the external program, the plug-in and file information related to the operation of the game, and the impact of the external program information on the game.
● For the iOS version: application information (module and signature) and root status of the device.
● The activity carried out within our game application, including installing, uninstalling, and updating event information.
● We will always ask for your consent to give us your location data.
(4) Finally, any other data you actively provide us with when:
● You contact support or seek help from us
● You take our surveys or join our playtests
● You enter a contest. If you win, we might need additional information about you according to the specific contest. We will, however, only collect such information with your consent.
● You apply for a job with us and provide information relevant to the application. For more information on how we use data in that respect, please refer to the Privacy Policy available on our job applications website.
Important Note: When you contact our support team, depending on the situation, we might require you to provide the necessary personal information to verify your user identity to safeguard the security of your account and relevant information. If you refuse to provide or the provided information is erroneous, we have the right to refuse to provide the relevant support services.
(5) We might obtain your data from third parties or partners, such as Facebook, Google, and AppsFlyer. We might also obtain information from third parties (such as game agencies) to supplement the information that you provide us. This will help us to place relevant advertisements for you, prevent fraud and/or abuse, and collect your geographical location for tax purposes.
7. How do we use your data?
We use the data we collect from you and from your use of our game services to provide, maintain, protect, and improve the game and game services and to develop new ones. Unless you have told us not to do so (choose to disable), we also use the data to offer you tailored content, such as placing more relevant ads and informing you about game releases you might be interested in. We will not use your data for any purpose other than the purpose for which the data is originally collected.
(1) To operate our business and enhance your gaming experience, the following is how we use information:
● To operate, improve, develop, and provide you with our games, apps, and game services
● To provide you with recommendations and promote games and products that you may like
● To respond to inquiries or comments from you
● To verify your identity to prevent unauthorized access
● To provide you with software updates
● To understand trends in usage
● To calculate marketing conversion rates and other elements of advertising performance
● To help track and correct errors and bugs in games and services
● To customize your user experience
● To maintain the integrity and security of the game services
● To process transactions and communicate with you regarding these transactions"
● To maintain or administer your account, including contacting you to update your game if necessary
● To administer and perform playtests and beta tests that you have signed up for
● To create reports, analyses, or similar content for the purpose of research and business intelligence, and be able to track potential problems, behavior, and trends
● To enforce our terms and conditions, such as our War and Order User Agreement, announcements, notifications, rules of conduct, and this Policy
● To send you newsletters, promotional notices, and offers, for which you have previously given consent
● To keep our services fair, investigate and prevent fraud and illegal behavior
● To comply with applicable laws and regulations
● To provide events and competitions
● To provide such personal data to any third party using the methods described in this Policy; and
● Any other purposes incidental to any of the foregoing items.
(2) Special information about marketing:
Special marketing information: We use your data to inform you about relevant products and offers, e.g., provide you with targeted marketing. The data we collect in such cases contains data you willfully provide to us, the data we collect when you use our services, or from third parties we work with. We analyze this data to understand what we think you might want or need, or what may be of interest to you. You can, at any time, object to our use of your data for marketing purposes, including personalized analysis for marketing purposes, and we will immediately stop using your data for such purposes after you object.
8. Cookies or similar technologies
We may use cookies or similar technologies to store data, improve functionality, or track site usage at times. We may allow third parties to set and use cookies or other similar technologies to enhance your experience using the service. Including:
● Estimate the number of users and statistics on user preferences or data for commercial analysis, market analysis, or academic purposes.
● Our authorized third parties might use cookies or similar technologies to provide personalized service, prevent fraud, and fulfill the other purposes mentioned above, such as advertisement services needed to identify data, information, and other indicators and data for evaluation. This information is only used for analysis, to evaluate the effects of promotional and marketing activities, and for improvements.
9. Who do we share your data with?
(1) We will not provide your data to any third party without obtaining your prior consent, except in cases where:
● Such provision is made in accordance with the laws and regulations;
● Such provision is necessary to protect human life, body, or property, and where it is difficult to obtain your consent;
● Such provision is particularly necessary for the enhancement of public health or the promotion of the sound development of children, and where it is difficult to obtain your consent.
● It is necessary for us to cooperate with a state organ, local government, or any entrustee thereof in performing duties prescribed under the laws and regulations, and where the performance of such duties may be obstructed, by obtaining your consent;
● Your data is provided to any third party in relation to the outsourcing to such party of the processing of such data within the scope necessary for us to achieve the purposes of use; or
● Your data is shared due to joint use described below.
(2) Notwithstanding the foregoing, to be able to provide you with the services and the best possible experience, we will share your data with other companies and organizations. We will only do so if our partners can provide the same level of security to keep your data safe as implemented by us, and if our partners can ensure that they comply with applicable laws and privacy regulations. We may share your information with the following partners:
|
Service Name |
Provider Acquired |
Types |
Partner Websit |
|
Google AdWords iOS App conversion tracking |
Google Inc. |
Advertisements |
|
|
Google Pay |
Google LLC |
Payment Processing |
|
|
Google Login |
Google LLC |
Login Functions |
|
|
Google Ads |
Google LLC |
Analytics; Advertising |
|
|
Google Play Core |
Google LLC |
Functional |
|
|
Firebase |
Google LLC |
Functional |
|
|
Facebook |
Facebook, Inc. |
Functional; Advertising; Social |
|
|
Appsflyer |
AppsFlyer Ltd. |
Analytics; Advertising |
|
|
Unity |
Unity Technologies |
Analytics; Functional |
|
|
AWS |
Amazon Web Services, Inc. |
Cloud Provider |
|
|
Apple pay |
Apple Inc. |
Payment Processing |
https://www.apple.com/legal/privacy/ |
● Game distribution platforms (for example, Google, Apple, and Amazon)
● Please note that our games or products may be advertised in other applications. If you click on one of these advertisements and install our game, you will become a user of our services. To prevent fraud and verify the installation of the game, we may share your IDFA (iOS) and/or Advertiser ID (Android) with the relevant advertiser.
● We may release your data when we are required to by a court order, according to law, or in the event of a bankruptcy or other similar unfortunate event.
● We may also share and acquire your data with future subsidiaries or companies if we choose to sell, transfer, or merge parts of our business. We will, however, only transfer the data if we must and if these companies comply with applicable privacy regulations and can guarantee that your data will be kept safe.
● We may collect some or all of your data to be jointly processed with our affiliated companies in accordance with the clauses of this Policy and used within the scope of the intended use of the clauses of this Policy.
10. Can minors and children use our services?
Our games and game services are not for minors and children. We will also not purposefully collect or ask for the data of "minors or those under 13 years of age" (in accordance with the higher requirements that certain countries and platforms have on the age of consent for collecting personal data, which are subject to the requirements of those countries or platforms). If you are a minor or under the age of 13, please do not attempt to register for our game services or send us any of your relevant personal information. If you believe that a minor or a person under the age of 13 may have given us personal information, please contact us and report this by email. We strongly recommend that parents or guardians instruct their children not to disclose any data when online. Parents or guardians who are concerned about the transfer of data are welcome to contact us at wao@camel4u.com. If we know for certain that we have collected data from a minor or under the age of 13, we will promptly delete this data, unless we are legally obligated to retain such data.
11. Accessing and changing your data
When you use our services, we strive to provide you with ways to quickly access or correct data that you have actively provided.
You have the right to access data related to you, including the right to be informed whether the data related to you was processed, what data was processed, and the purpose of processing it. You also have the right, upon your request, to access information about any evaluation or assessment of the balancing test we are required to conduct when we process your data based on our legitimate interest. In addition, if your data is inaccurate or incomplete, you have the right to edit or add to the data. Once we discover that we have processed any inaccurate data, we will immediately edit it and notify you of the corresponding situation.
12. Right to erasure
You are entitled to request that we erase data related to you. The precondition is that this data is no longer necessary to implement the relevant functions of our game or game services (for example, you cannot require all data about you to be erased and still receive services from us). Unless we have a legal obligation to continue storing your data, we will erase your data immediately upon your request.
13. Right to object to the processing of your data
You are also entitled to object to the processing of your data on grounds related to your particular situation. Please note, however, that we must still process some of your data to provide the services to you. This means that you cannot object to all our use of data and still require us to provide services to you.
14. Right to restriction
You have the right to require us to restrict our processing of your data under the following situations:
● If you contest the accuracy of the data.
● If the data processing is unlawful, but you still do not want us to erase the data.
● The data is no longer required for the original intention, or you notify us that you don't believe we have a legitimate interest to process some data. Under these circumstances, you have the right to request that we restrict the processing of your data.
15. How to get a copy of your data or receive a copy of your data?
You can request a copy of your data by logging into your game account and contacting us through the in-game Contact Us feature, or by emailing us at wao@camel4u.com. If you request access to data about yourself that you yourself have provided, and if the data is being processed automatically and in accordance with a contract between you and we or based on your consent, you may request that the data be provided in a structured, commonly used and machine-readable format and you may also request that the aforementioned data is transmitted to another controller if this is technically realizable.
16. How to enforce your rights?
You can log in to your game account and use the Contact Us feature or send an email to wao@camel4u.com to contact us at any time and obtain the list of all data that we have collected from you, erase such data, or exercise other rights explained above. However, please note that when you contact us to apply for a data rights response, we may verify your identity, account security status, and other information to safeguard your account and data. If we cannot confirm or guarantee who you are, we may request that you provide additional information or may request that you log in to your game account. If we are unable to verify that you are the legitimate owner of the data, we will not process any data or satisfy your request. However, we will always do our best to help you. At the same time, please understand that we may be unable to respond to your application under such circumstances that exceed the scope of our data storage, reasonable limits, or responding to your request would cause severe damage to our or other third parties' legitimate interests. We will try our best to reply to your request promptly, but please note that we may need several days. Thank you for your patience and understanding.
17. If you choose not to share your data with us
We may need to collect data to fulfill our legal obligations, or fulfill the terms of a contract we have with you, or even display the game services. If you choose not to provide us with this data, we might not be able to fulfill our corresponding obligations, which may also mean that we cannot provide the required or full game services necessary to run your game account or that we cannot implement the relevant policies. It may also mean that we have to cancel the product or game services you have with us.
18. How to withdraw your consent or delete your game account?
You can contact us to withdraw your consent or delete your game account. However, if you withdraw your consent or your game account is deleted, we may be unable to provide you with some or all services, and your game experience may be affected. Deleting your game account will result in the loss of all of your game progress, virtual currency, virtual items, and ability to access the game.
19. Data Storage and Transfer
We will collaborate with other companies to realize the stated purposes and obligations in this Policy, and we will transmit your data to countries outside the European Union (EU) and the European Economic Area (EEA). We understand that the data protection acts of different countries/regions may vary. Therefore, we will take adequate safeguard measures to protect your data. We will only transmit your data to these countries/regions where permitted. To realize the purpose of our provided services within the scope permitted by laws and regulations, we will store your information through secure methods, including local storage, databases, and server logs. After the storage date expires, we will delete or anonymize your data.
20. How long will we keep your data?
If you're a player, we will retain your data.We may retain your information longer for research or statistical purposes. If we retain your information for this purpose, we will ensure that it is anonymized and cannot be traced back to you. We may also retain your information for an extended period if we are unable to delete it for legal or regulatory reasons. However, we will delete data that is no longer needed after a reasonable period of time.
21. Security measures to protect your data
We maintain physical, electronic, and procedural safeguards to help guard your data in compliance with applicable privacy regulations. If transactions are offered on the services, transaction information is transmitted to and from the service in encrypted form using industry-standard Transport Layer Security (TLS, which used to be known as SSL) connections to help protect such information from interception. We strictly restrict authorized access to your data only to those persons who have a legitimate purpose to access it. We also have security measures in place to protect the loss, misuse, and alteration of the data we process. Please contact our support department by logging into your game account and using the Contact Us feature or email for details of such security measures.
Also, please understand that we try our best to ensure the data's security, but the internet environment isn't 100% safe. Due to technical restrictions and risk prevention limitations, even if we do our best to strengthen security measures, we are unable to guarantee the absolute safety of the data. Therefore, we hope you understand that your data may have problems arising due to circumstances out of our control. If the above situations arise, we will activate the contingency plan to prevent the expansion of the security incident. At the same time, after security incidents arise, we will notify you about the basic information (such as the types, causes, and possible damages caused by data leaks, tampering, and losses) of the security incident through announcements, push notifications, SMS, and other forms, the processing measures and remedial measures that we are about to or have already taken, our suggestions for you, and our contact information.
22. Changes in the Privacy Policy
This Policy may change from time to time. Any changes to this Policy can be checked at any time in the in-game Privacy Policy. If the changes are significant, we will provide you with a more noticeable notice, such as by sending emails, in-game pop-ups, on the official game website, or other methods of notifying you of changes to this Policy. If you received notifications of content changes to this Policy and decline to do so, you may not be able to continue using our services with full functionality. If you continue to use our services, it indicates that you accept our changes and agree to the collection and processing of your data in accordance with our updated Policy.
23. How to contact us and how to make complaints?
If you have any questions related to data protection or when you need to make inquiries or complaints while using our services, you can contact our data protection staff through the in-game Help > Contact Us or send an email to wao@camel4u.com.
When we receive your requests, opinions, and suggestions, we will reply to you quickly after verifying and confirming your user identity. If we encounter special or complex circumstances, our feedback time may be prolonged. In addition, you understand and are aware that in cases where laws and administrative regulations stipulate that confidentiality shall be maintained or do not require disclosure, we will be unable to process your request, but we will explain the specific reason to you.
24. DPO contact information
DPO contact: Monica Lee
Email address: wao@camel4u.com
Hong Kong Ke Mo software Co., Limited
Effective Date: 2016/01/25