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This Privacy Policy is provided by EFUN Platform (hereinafter referred to as "we," "us," "our," or "the Company").The Company respects and protects the personal privacy of all service users. In order to provide you with a more accurate and more personalized service, the Company will use and disclose your personal information in accordance with the provisions of this Privacy Policy. However, the Company will treat such information with a high degree of diligence and discretion. Except as otherwise provided in this Privacy Policy, without your prior consent, the Company will not disclose such information to any third party. The Company will continue to update this privacy policy. At the time you agree to the Company's Service Agreement, you are deemed to have agreed to all of the contents of this Privacy Policy, which belongs to an integral part of the Service Agreement.
1. Information We Collect
When using the EFUN Platform, we may collect the following categories of data:
· Basic information: Name, telephone number, email address, and in-game ID. Only when strictly required by applicable local laws (e.g., for real-name authentication) or for processing specific payment disputes, we may collect your ID card number or other identification information.
· Accounting information: Account numbers of financial institutions, credit card numbers, transaction information, and other financial information.
· Device Information: Installing the application will obtain basic information on the user's mobile phone for tracking problems, including but not limited to model, system version, user MAC, etc.
2. Purpose of Collection
The main purposes of collecting personal data are as follows:
· To verify the identity of the platform user.
· To provide services and support, including using contact information to provide you with the latest game information and services.
· To ensure the quality of game service and track technical problems.
· To collect email addresses or names when you post comments in discussion boards or respond to surveys.
· To conduct data statistics and comprehensive analysis to formulate the most suitable content for users.
· For marketing purposes, including contacting or notifying you of the latest news.
3. Information Sharing and Disclosure
We will maintain full control and strict security standards over your information and will not disclose them to third parties, except for the following persons, organizations, or situations:
· Authorized employees of the Company who have received formal training to handle customer data.
· Third-party service providers supporting our services who are contractually bound to adhere to these privacy standards.
· According to applicable laws, government, or regulatory requirements.
· Institutions you trade with through our platform, such as cash flow services, banks, or financial institutions.
· When necessary to identify or contact you; when your actions violate terms or cause damage/interference to our website, products, or other users; or when we have sufficient reason to believe you are involved in fraud or illegal breaches of contract.
Note: Any advertisers or other third-party websites linked to our site may also collect your personal information. This privacy policy does not cover the information you provide directly to third parties.
4. Information Storage, Transfer, and Retention
Your information and data collected by the Company will be stored on the Company's servers and/or its affiliates' servers. Such information and data may be transferred to, accessed, and stored in foreign countries outside the country or region in which you are currently located. The platform utilizes your profile region as global.
We will retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, typically for the duration your account is active. Upon your request for account deletion, we will erase or anonymize your data within a reasonable time frame, unless a longer retention period is required or permitted by tax, accounting, or other applicable laws.
5. Information Administration and Cookies
Without disclosing user's privacy information, the company is entitled to the technical analysis of the entire user database, and use it for commercial purposes (including utilizing user access volume, access time, and preferences).
We may use cookies to collect user data to improve service function, help the login process operate faster, and store data between calls. You may disable cookies in your browser, but this may make using our service more complicated and affect some features of the Company's services.
6. The Impact of Not Providing Information
You can freely choose whether to provide personal information. However, if the information provided is insufficient, false, or prevents us from confirming the authenticity of your identity (especially if your account is fraudulently used or stolen), the platform will suspend services to you and will not be able to process your requests or provide specific products.
7. Your Data Privacy Rights
Depending on your jurisdiction, you have the following rights regarding your personal data:
· Right to Access & Rectification: You can request access to or correct your inaccurate personal data.
· Right to Erasure (Deletion): You have the right to request the deletion of your personal data. Please be aware that deleting your personal data might affect your continuous use of this app and its function, or lead to account termination.
· Right to Withdraw Consent: You may withdraw your consent for us to process your data for marketing or other specific purposes at any time.
How to Exercise Your Rights:
You can exercise your rights by contacting our Data Protection Officer (DPO) via our dedicated privacy email: cs@efun.com. We promise to respond to your request within 30 days after receipt. In complex cases, to completely erase your personal data stored in our backup systems, this process might take up to 90 days. If we need more time, we will let you know.
8. Children's Privacy
Our games and services are generally not directed to children under the age of majority in your jurisdiction (e.g., under 16 in Vietnam, under 20 in Thailand). We do not knowingly collect personal data from children without verifiable parental consent.
If you are a minor, you must obtain consent from your parent or legal guardian before using our services. If we become aware that we have inadvertently collected personal data from a child without legal guardian consent, we will take immediate steps to delete such information from our records. Parents or guardians who believe their child has provided us with personal information can contact us at cs@efun.com to request deletion.
9. Privacy Policy Update
The Company reserves the right to revise the terms of the Privacy Policy at any time. Without prior notice to individual users, we may publish revisions on the corresponding web pages. If a user continues to use any service provided by the Company, the user is deemed to have accepted the revised content.
10.Third-Party SDKs and Services
To ensure the stable operation of our games and provide you with specific functions (such as third-party login, payment processing, advertising, and data analytics), we may integrate Software Development Kits (SDKs) or similar applications provided by authorized third parties. We strictly require these third parties to process your data lawfully. Below are examples of the main third-party SDKs we may use. For specific data collection practices, please refer to their respective privacy policies:
· Login & Social (e.g., Facebook, Google, Apple): Used for quick login and sharing. Data collected: Open ID, avatar, nickname.
· Payment (e.g., Google Play Billing, App Store In-App Purchases): Used for processing in-game purchases. Data collected: Transaction details (We do not collect your full credit card info directly).
1. Information We Collect
When using the EFUN Platform, we may collect the following categories of data:
· Basic information: Name, telephone number, email address, and in-game ID. Only when strictly required by applicable local laws (e.g., for real-name authentication) or for processing specific payment disputes, we may collect your ID card number or other identification information.
· Accounting information: Account numbers of financial institutions, credit card numbers, transaction information, and other financial information.
· Device Information: Installing the application will obtain basic information on the user's mobile phone for tracking problems, including but not limited to model, system version, user MAC, etc.
2. Purpose of Collection
The main purposes of collecting personal data are as follows:
· To verify the identity of the platform user.
· To provide services and support, including using contact information to provide you with the latest game information and services.
· To ensure the quality of game service and track technical problems.
· To collect email addresses or names when you post comments in discussion boards or respond to surveys.
· To conduct data statistics and comprehensive analysis to formulate the most suitable content for users.
· For marketing purposes, including contacting or notifying you of the latest news.
3. Information Sharing and Disclosure
We will maintain full control and strict security standards over your information and will not disclose them to third parties, except for the following persons, organizations, or situations:
· Authorized employees of the Company who have received formal training to handle customer data.
· Third-party service providers supporting our services who are contractually bound to adhere to these privacy standards.
· According to applicable laws, government, or regulatory requirements.
· Institutions you trade with through our platform, such as cash flow services, banks, or financial institutions.
· When necessary to identify or contact you; when your actions violate terms or cause damage/interference to our website, products, or other users; or when we have sufficient reason to believe you are involved in fraud or illegal breaches of contract.
Note: Any advertisers or other third-party websites linked to our site may also collect your personal information. This privacy policy does not cover the information you provide directly to third parties.
4. Information Storage, Transfer, and Retention
Your information and data collected by the Company will be stored on the Company's servers and/or its affiliates' servers. Such information and data may be transferred to, accessed, and stored in foreign countries outside the country or region in which you are currently located. The platform utilizes your profile region as global.
We will retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, typically for the duration your account is active. Upon your request for account deletion, we will erase or anonymize your data within a reasonable time frame, unless a longer retention period is required or permitted by tax, accounting, or other applicable laws.
5. Information Administration and Cookies
Without disclosing user's privacy information, the company is entitled to the technical analysis of the entire user database, and use it for commercial purposes (including utilizing user access volume, access time, and preferences).
We may use cookies to collect user data to improve service function, help the login process operate faster, and store data between calls. You may disable cookies in your browser, but this may make using our service more complicated and affect some features of the Company's services.
6. The Impact of Not Providing Information
You can freely choose whether to provide personal information. However, if the information provided is insufficient, false, or prevents us from confirming the authenticity of your identity (especially if your account is fraudulently used or stolen), the platform will suspend services to you and will not be able to process your requests or provide specific products.
7. Your Data Privacy Rights
Depending on your jurisdiction, you have the following rights regarding your personal data:
· Right to Access & Rectification: You can request access to or correct your inaccurate personal data.
· Right to Erasure (Deletion): You have the right to request the deletion of your personal data. Please be aware that deleting your personal data might affect your continuous use of this app and its function, or lead to account termination.
· Right to Withdraw Consent: You may withdraw your consent for us to process your data for marketing or other specific purposes at any time.
How to Exercise Your Rights:
You can exercise your rights by contacting our Data Protection Officer (DPO) via our dedicated privacy email: cs@efun.com. We promise to respond to your request within 30 days after receipt. In complex cases, to completely erase your personal data stored in our backup systems, this process might take up to 90 days. If we need more time, we will let you know.
8. Children's Privacy
Our games and services are generally not directed to children under the age of majority in your jurisdiction (e.g., under 16 in Vietnam, under 20 in Thailand). We do not knowingly collect personal data from children without verifiable parental consent.
If you are a minor, you must obtain consent from your parent or legal guardian before using our services. If we become aware that we have inadvertently collected personal data from a child without legal guardian consent, we will take immediate steps to delete such information from our records. Parents or guardians who believe their child has provided us with personal information can contact us at cs@efun.com to request deletion.
9. Privacy Policy Update
The Company reserves the right to revise the terms of the Privacy Policy at any time. Without prior notice to individual users, we may publish revisions on the corresponding web pages. If a user continues to use any service provided by the Company, the user is deemed to have accepted the revised content.
10.Third-Party SDKs and Services
To ensure the stable operation of our games and provide you with specific functions (such as third-party login, payment processing, advertising, and data analytics), we may integrate Software Development Kits (SDKs) or similar applications provided by authorized third parties. We strictly require these third parties to process your data lawfully. Below are examples of the main third-party SDKs we may use. For specific data collection practices, please refer to their respective privacy policies:
· Login & Social (e.g., Facebook, Google, Apple): Used for quick login and sharing. Data collected: Open ID, avatar, nickname.
· Payment (e.g., Google Play Billing, App Store In-App Purchases): Used for processing in-game purchases. Data collected: Transaction details (We do not collect your full credit card info directly).