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Morizero ("us", "our" or "we") greatly recognizes and values the privacy rights of our users ("users" or "you"). This Privacy Policy (the "Policy") describes the ways we collect, store, use, and manage the information, including personal information, that you provide or we collect in connection with our websites, including milthm.com (the "Sites") or any Morizero game (collectively, the "Services"). Please note that the scope of this Policy is limited to the information collected or received by Morizero through your use of the Services. Morizero is not responsible for the actions of third parties, the content of their sites, the use of the information you provide to them, or any products or services they may offer.

By using the Services, you agree to this Policy and the processing of your data, including your personal information, in the manner provided in this Policy. If you do not agree to these terms, please do not use the Services.

To the extent permitted by applicable law, children under the age of 13 (or other age threshold required by local laws) are not allowed to access the Services. If you are above 13 but are considered a minor in your country (e.g. under 18 years old in some jurisdictions), you must have your parent or legal guardian read through this Privacy Policy with you and you represent that you have obtained the permission of your parent or guardian to create your Account.

If you are a parent or legal guardian of a minor in your country, please make sure that you have read this Privacy Policy before allowing your children to create their accounts or to use the Services. You agree that you will be subject to this Privacy Policy and be responsible for your children’s activities while using the Services. You agree to supervise your children’s use of the Services and make sure that your children only view the contents that are age-appropriate to your children.

This Privacy Policy informs you of the following information:
1. What Information do we collect
2. How do we use your information
3. Cookies and Similar Technologies
4. How do we share your information
5. What rights do you have about processing your information
6. How do we store and transfer your information
7. How long will we keep hold of your information
8. How to contact us
9. Supplemental Terms – Jurisdiction-Specific

Ⅰ. What Information do we collect

We automatically collect certain information when you use the Services. More information about the categories and sources of information is provided below. In this Policy, “Information” means any information relating to an identified or identifiable individual.

For example:
- Information for registration: such as your nickname, email address, password, phone number, and information we import from your connected social media account (WeChat, Facebook, QQ, VKontakte, Twitter, Google Play, Game Center, or LINE) to set up your profile, including your name as it appears on your social media profile, your user ID and your profile picture. For certain regions, you may also be asked to provide us with your date of birth (stored device-side only) to verify your age and for administration of the gameplay management system.
- Identifiers and device information: such as your device type, operating system type, browser type, device ID, Internet Protocol (IP) address, and other software including type, version, language, settings, and configuration.
- Usage data: such as what website you were on that brought you to our Sites when you used the Services and for how long, what pages and content you accessed, and what features you used on the Services.
- Geolocation data: with your consent, the Services may access precise geolocation data on your mobile device to enable features and deliver content based on your current location.
- Customer support: If you contact us directly, we may receive additional information about you. For example, when you contact us for support, we may receive your name, email address, phone number, the contents of a message that you may send to us, and other information you choose to provide.

We may use SDKs and other similar technologies to collect the information listed above. For more information about the lists of SDKs we use, please see “How do we share your information” below.

Ⅱ. How do we use your information
We use your Information to the extent reasonably necessary to fulfill your requests in performing our contract with you, or based on consent where we have requested it or where required by law, and for our legitimate business objectives, including for the following business purposes:
- Business Operations: to provide you with and operate, maintain, optimize, and improve our products, services, operations, and the security of our services, including performing operational tasks such as billing, accounting, communicating, and fulfilling your transactions for products and services.
- Product and Service Delivery: to personalize content and experiences on our services, including providing you recommendations based on your preferences and interests;
- Marketing: to deliver and personalize your notifications, communications, newsletters, advertisements, offers, event notices, and promotions for products and services of Morizero Ltd. and our third-party partners;
- Product Improvement, Development, and Research: to develop information to understand you based on demographics, your activity on our services, responses to surveys, or activity on third-party websites and applications, including for purposes of troubleshooting and improving our services; to conduct market research and perform statistical, demographic, and marketing analyses of users of our services and their purchasing patterns;
- Security of Services: to detect, investigate, and prevent unauthorized activities that may violate our terms and policies, or may be illegal, such as fraudulent activity or security violations;
- Customer Support: to provide customer support and reply to your questions submitted to us.

Ⅲ. Cookies and Similar Technologies
To measure the effectiveness of our services, we may use cookies, which are small text files for added functionality or for tracking site usage. We may use cookies and/or authorize a third party’s tracking-utility, from time to time, (a) to log your IP address in determining the path that users take on our sites and identifying repeated users of our sites, (b) to collect the websites or sources that linked or referred you to our services, and/or (c) to collect technical data about the devices and software you use to access our services, the operating system of your devices, and other similar technical data. If you do not wish to accept cookies or want to be notified of when they are placed, you may set your web browser to do so, if your browser permits.

We use cookies, web beacons, and similar technologies to personalize your experiences on our services and for various other purposes, including:
1. remembering you: cookies, web beacons, and similar technologies help us identify you as a registered user and keep the preferences or data that you have previously provided;
2. analyzing how you use our services: cookies, web beacons, and similar technologies help us understand what visitors (including users) are doing on our services, or what pages or sections are most popular;
3. deliver advertising: cookies, web beacons, and similar technologies help us provide you with advertising that we believe is relevant to you or of interest to you, based on the data you provide;
4. other related functions or purposes mentioned in Section 2.

We or our authorized contractors may use cookies and similar technologies to provide and personalize services, prevent fraud, and fulfill other purposes mentioned above. Please note you may be able to disable cookies in your browser settings, but if you do so some parts of our services may then not function properly.

Ⅳ. How do we share your information

In addition to Morizero, other parties may also access your personal data in the following situations. You acknowledge that you have foreseen the occurrence of such disclosure when you provide your personal data.
- Business Partners. We share information with third-party partners and service providers, including payment processing and gateway companies, platform services, game developers, game publishers, game console providers, customer support services, cloud storage, and hosting providers, social media companies (who may collect information when you use the Services or when you connect the Services to your social media accounts) and analytics and advertising companies, to help us provide and improve the Services and operate our business. For more information about these business partners, please contact us.
- Other Users. Your profile, including your username and the picture that you may provide, and information about your activities on the Services may be visible to other users of the Services or third-party sites and services. For example, your game results, scores, and profile information may be viewed by other users of the Services and, if you choose to link to social media sites like Facebook, viewed by users of such sites.
- Legal Purposes. We may provide your information to third parties when we believe that doing so is required by law or to cooperate with regulators or law enforcement authorities. We may disclose your information to protect the rights or property of Morizero, including enforcing our End User License Agreement, and others, or when we believe that there is an emergency that poses a threat to the health or safety of you, another person, or the public.
- Corporate Transaction. If Morizero is involved in a corporate transaction, such as a merger, or acquisition by another company, we may transfer your information to the successor organization in such transaction under applicable law.
- With Your Consent. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent.

If you access our Services through third-party devices or platforms, these third parties may be able to collect and process information about you, including information about your activity on the Services, and they may notify your connections on the third-party services, in accordance with their own privacy policies.

Ⅴ. What rights do you have about processing your information
Subject to the applicable laws and regulations, you may have the following data protection rights as a user of our services and to withdraw your consent. You also have the right to complain to the local authorities.

To exercise any applicable rights below or to exercise any other statutory data subject rights you may enjoy under applicable laws and regulations, you may contact us using the contact details.

To protect the security of your Account and your personal data, we may ask you to provide certain additional information before we respond to your requests. Under some circumstances, we may refuse to comply with your request as permitted by applicable laws and regulations. We may also charge a reasonable fee for complying with your request in accordance with applicable law, e.g. if your request is clearly repetitive or excessive.

1. Right to Know about Personal Data Collected or Disclosed

You may have the right to access your personal data that we hold about you, i.e. ,(i) information whether your personal data is collected or disclosed, (ii) categories of your personal data which has been collected or disclosed, (iii) categories of sources from which your personal data is collected, (iv) business or commercial purpose for collecting or disclosing your personal data (if any); and you have the right to require us to provide a duplicate of your personal data undergoing processing, subject to submitting a verifiable request to us using the contact information below. You may also be able to exercise the right to access some of your personal data through the privacy setting available in the services (e.g. profile page or privacy dashboard), where applicable.

2. Right to Rectify

If we process your personal data, we shall endeavor to ensure by implementing suitable measures that your personal data is accurate and up to date for the purposes for which it was collected. If your personal data is inaccurate or incomplete, you may have the right to request for rectification of your inaccurate personal data according to applicable laws and regulations and you can modify the information in the privacy setting of the services (if available).

3. Right to Request Deletion of Personal Data

You may have the right to request the deletion of your personal data, if the reason as stated in Article 2 of this Privacy Policy does not exist anymore, or if there is another legal ground for its deletion, subject to submitting a verifiable request to the contact details below.

You acknowledge and agree that as a result of deleting your Account, you will lose access to game related services, including the account information, subscriptions and game-related information linked to such Account and lose the possibility to access other services through the Account.

4. Right to Opt-out of Marketing Communications

You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing messages we send you.

5. Right to Complain

You may have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority where applicable.

6. Right to Withdraw Your Consent

If we have collected and processed your personal data with your consent, you can withdraw your consent in accordance with applicable laws. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted in reliance on lawful processing grounds other than consent. In many circumstances, we need to use your personal data in order for us to provide you with our services which you require. If you do not provide us with the required personal data, or if you withdraw your consent to our use and/or disclosure of your personal data for these purposes, it may not be possible for us to continue to serve you or provide you with the services that you require.

Ⅵ. How do we store and transfer your information

Morizero may transfer your personal data to ourselves, third-party service providers, and partners that operate around the world, which are located in countries other than the country in which you are resident (e.g. China). These countries may have data protection laws that are different from the laws of your country.

Where we transfer your personal information to countries and territories outside of the European Economic Area and the UK, which have been formally recognized as providing an adequate level of protection for personal information, we rely on the relevant “adequacy decisions” from the European Commission, where applicable.

Where the transfer is not subject to an adequacy decision, we have taken appropriate safeguards to require that your personal information remain protected in accordance with this Privacy Policy. The safeguards we use are the European Commission’s Standard Contractual Clauses as issued on 4 June 2021, including the UK Addendum, and/or the UK International Data Transfer Agreement permitted under Article 46 of the UK GDPR. This is how transfers of personal information between us and other companies will be safeguarded. All companies are required to protect the personal information that they process from Europe in accordance with European Union data protection law. Transferred personal information includes basic information such as your name or contact information such as your email address.

Ⅶ. How long will we keep hold of your information

Morizero will only store your Information as long as necessary to fulfill the purposes for which Information is collected and processed or where the applicable law provides for longer storage and retention periods for the storage and retention period required by law. After that, your personal data will be deleted.

In particular:

If you withdraw your consent on which a processing of your personal data is based, Morizero will delete your personal data without undue delay to the extent that the collection and processing of the personal data was based on the withdrawn consent.

If you exercise a right to object to the processing of your personal data, Morizero will delete your personal data that Morizero processed for the purpose to which you objected without undue delay, unless another legal basis for processing and retaining this data exists or unless applicable law requires us to retain the data.

Ⅷ. How to contact us

If you have any requests, concerns, or questions about us, this Privacy Policy, or how we process your personal data, or you want to make any complaints or want to exercise your data subject rights, please contact us as soon as possible by emailing us at support+in-game@morizero.com.

We will notify you when we update the Policy. We recommend you regularly review the Policy to stay informed of our privacy practices.


Ⅸ. Supplemental Terms – Jurisdiction-Specific
9.1 Additional Information for California Residents
If you are a California resident, you have certain rights with respect to the Information we collect. You have a right to request access to or deletion of the Information we have collected about you, and to receive additional information about our collection, use, disclosure, or sale of such Information. To provide or delete specific pieces of the Information, we will need to verify your identity to the degree of certainty required by law. Because users do not have to authenticate themselves during the use of the Services, for much of the Information we collect, such as the device information and usage data described above, there is no reasonable method by which we can verify your identity as the person to whom that data relates.

To make requests, please contact us at the email address provided at the bottom of this policy. You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide necessary proof that you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

You also have a right to opt-out from sales of Information. However, as noted above, we do not sell Information collected from the Services and have not done so in the past 12 months. Finally, you have a right to not be discriminated against for exercising these rights set out in the CCPA.

9.2 Additional Information for the EEA and UK residents
In addition to the information set out in the What rights do you have about processing your information section in the Privacy Policy above, you have the right to:
- ask us to restrict the processing of your personal data,
- data portability,
- to object to the processing of personal data.

Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity and/or your account details.

To make such requests, please contact us at the email address provided at the bottom of this policy. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.