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Privacy Policy

This Privacy Policy applies to the upcoming mobile game (hereinafter referred to as "the Product") developed and operated by ChillPlay Labs Inc (hereinafter referred to as "the Developer"). As a casual game company, the Developer is committed to providing users with high-quality gaming experiences while strictly protecting the security and privacy of your personal information. This Privacy Policy is intended to clearly inform you of how we will collect, use, store, share, and protect your personal information when you use the Product (after its official launch), as well as your rights and choices regarding your personal information. Please read this Privacy Policy carefully. Your use of the Product after its official launch shall constitute your consent to our collection and use of your information in accordance with the provisions of this Privacy Policy.

1. Information We Collect

The information we collect falls into two categories: information related to sensitive permissions and information related to general permissions. When collecting information, we strictly adhere to the principles of legality, necessity, and transparency, and we will never collect information beyond the scope necessary for providing services.

1.1 Collection of Information Related to Sensitive Permissions

Sensitive permissions refer to permissions that may involve your sensitive personal information and could harm your personal rights and interests if misused. Before obtaining each sensitive permission, we will clearly inform you of the purpose and scope of information collection through pop-up windows or other prominent means, and we will only collect relevant information after obtaining your explicit consent.

Location Permission: We may collect your precise location information only when you use location-based in-game features (e.g., regional battles) (after the Product’s official launch) and explicitly agree to grant the location permission. The collection method involves obtaining real-time location data of your device via the location service module of the device system. We will collect this information solely during your participation in location-based features and never at other times. Except for necessary cooperation with map service providers (e.g., Google Maps) to ensure the normal operation of location-based features, this information will not be shared with any third parties, and we will never profit from selling it.

 

Camera Permission: When you use the in-game avatar customization feature (generating avatars by taking photos) (after the Product’s official launch) and explicitly agree to grant the camera permission, we will collect image data captured by your device’s camera. The collection method involves obtaining real-time image data from the camera via the camera service interface of the device system. We will only collect image data necessary for generating avatars and will not store other irrelevant image data captured by the camera. This information will not be shared with any third parties, and we will never profit from selling it. During the avatar generation process, the collected image data will be temporarily stored in the device’s local cache; once the avatar generation is completed, the original image data will be automatically deleted from the local cache, and only the generated avatar data (non-original image data) will be uploaded to our game data server.

 

Microphone Permission: When you use the in-game voice chat feature (after the Product’s official launch) and explicitly agree to grant the microphone permission, we will collect audio data recorded by your device’s microphone. The collection method involves obtaining real-time audio data from the microphone via the audio recording service interface of the device system. We will collect this audio data only during the voice chat process and never at other times. This information will be transmitted in encrypted form during voice chat and will not be stored permanently; except for necessary cooperation with voice communication service providers (e.g., Twilio) to ensure the normal operation of the voice chat feature, it will not be shared with any third parties, and we will never profit from selling it. Temporarily transmitted audio data will be processed and cleared in real time on the communication server and will not be retained.

 

Permissions Related to Payment Information: When you make in-game purchases (e.g., buying game props or virtual currency) (after the Product’s official launch) and select payment methods such as credit cards, debit cards, or mobile payments (e.g., Apple Pay, Google Pay), we will collect necessary payment information (including cardholder name, card number, expiration date, CVV code, etc.) through third-party payment service providers (e.g., PayPal, Stripe). We will not directly collect or store your complete payment information; instead, the payment information will be collected and processed by third-party payment service providers in accordance with their own privacy policies and relevant laws and regulations. We will only obtain payment result notifications (e.g., successful payment, failed payment) from third-party payment service providers to confirm your purchase and distribute corresponding in-game items. Except for the third-party payment service providers involved in the payment process, your payment information will not be shared with any other third parties, and we will never profit from selling it. Payment result notification information will be uploaded to our transaction record server.

1.2 Collection of Information Related to General Permissions

General permissions refer to permissions necessary for the basic operation of the Product and do not involve sensitive personal information. We will obtain these permissions in accordance with the device system’s default settings or after obtaining your general consent (after the Product’s official launch).

Device Information Permission: We will collect basic information about your device, including device model, operating system version, unique device identifiers (e.g., IMEI, Android ID, UUID), device network status (e.g., Wi-Fi, 4G, 5G), and device storage space. The collection method involves obtaining relevant device parameter information via the device system interface. This information is used to ensure the Product’s compatibility with your device, optimize the game’s operating performance, and troubleshoot issues such as game crashes. We may share this information with technical support service providers (e.g., Firebase) for technical analysis and product improvement, but we will never profit from selling it. Collected device information will be uploaded to our device information server.

 

Game Account Information: When you register and log in to the Product’s game account (after the Product’s official launch) (registration can be done via email, Google Account, or Facebook Account), we will collect the information you provide during registration, such as your email address, username, and avatar (if you choose to upload one). If you log in via a third-party account (Google Account, Facebook Account), we will obtain the authorized basic information of your third-party account (e.g., account name, avatar) in accordance with the third-party platform’s authorization agreement. This information is used to identify your game account, manage your game data, and provide you with personalized game services (e.g., friend recommendations). Except for necessary cooperation with third-party login service providers (e.g., Google, Facebook) to ensure the normal operation of the login feature, this information will not be shared with third parties, and we will never profit from selling it. Collected game account information will be uploaded to our user account server.

 

Game Usage Data: During your use of the Product (after the Product’s official launch), we will collect your game usage data, including the time you log in to the game, the duration of each game session, the game levels you have completed, the game props you have purchased and used, the game scores you have obtained, and your interaction records with other players (e.g., friend requests, chat records). This information is used to analyze users’ gaming habits, optimize the game’s content and gameplay, provide you with game progress tracking and personalized game recommendations, and enhance the overall gaming experience. We may share this information with game data analysis service providers (e.g., Unity Analytics) for data analysis and research, but we will never profit from selling it. Collected game usage data will be uploaded to our game analytics server.

2. How We Protect Your Information

We attach great importance to the security of your personal information and have adopted a series of strict technical and management measures to prevent your information from being accessed, used, disclosed, modified, damaged, or lost without authorization (after the Product’s official launch).

Technical Security Measures: We use industry-leading encryption technologies (e.g., SSL/TLS encryption) to encrypt the transmission of personal information, ensuring that the information is not intercepted or tampered with during transmission. We adopt advanced access control technologies to set strict access permissions for servers storing personal information, and only authorize relevant personnel to access your information based on work requirements. We will regularly update security patches for servers and systems to prevent security vulnerabilities from being exploited by hackers; at the same time, we use data backup technologies to regularly back up your personal information, enabling quick data recovery in case of data loss or damage.

 

Management Security Measures: We have established a dedicated information security management department and formulated strict information security management systems, which clearly define the responsibilities and operating procedures of relevant personnel in the collection, use, storage, and protection of personal information. We regularly provide information security training to employees to enhance their awareness of information security and their ability to protect personal information. We sign confidentiality agreements with employees and third-party service providers who have access to your personal information, requiring them to strictly keep your information confidential; those who violate the agreement will bear corresponding legal responsibilities. We also regularly conduct internal and external information security audits to inspect and evaluate the implementation of information security measures and promptly rectify any problems identified.

3. Data Retention and Deletion Mechanisms

3.1 Data Retention Period

We will retain your personal information for the shortest period necessary to achieve the purposes stated in this Privacy Policy (after the Product’s official launch), unless laws require or permit a longer retention period.

For your game account information and game usage data, we will retain them for 2 years after you stop using the Product (i.e., no login records for 2 consecutive years); after the retention period expires, your information will be automatically deleted or anonymized.

 

For your payment information (payment result notifications), in accordance with the requirements of financial regulatory laws and regulations, we will retain it for 7 years to facilitate future inquiries and verification of transaction records; after the retention period expires, the relevant information will be deleted.

 

For temporarily stored information (e.g., original image data collected by the camera during avatar generation, audio data during voice chat), it will be deleted immediately after the corresponding service is completed (e.g., after avatar generation, after the end of a voice chat) and will not be retained.

3.2 Data Deletion Mechanisms

Automatic Deletion: As specified in the "Data Retention Period" section, after the retention period of your personal information expires, our system will automatically trigger the deletion process to completely delete your information from servers and related storage devices.

Active Deletion by Users: You may apply to delete your game account and all related personal information at any time (after the Product’s official launch). The specific operation steps are: log in to the Product, enter the "Settings" page, select "Account Management", and click "Delete Account". After you submit the deletion application, we will verify your identity within 7 working days; once verification is passed, we will delete your game account and all related personal information (except for information that must be retained in accordance with the law) within 15 working days, and send you a deletion completion notification via the email bound to your game account.

 

Legal Deletion: If we receive a legal document (e.g., a court judgment, an administrative penalty decision) requiring the deletion of your personal information, we will strictly delete the relevant information in accordance with the requirements of the legal document.

4. Your Rights

During your use of the Product (after the Product’s official launch), you have the following rights regarding your personal information, and we will provide convenient channels for you to exercise these rights.

Right of Access: You have the right to access your personal information collected and stored by us, including game account information, game usage data, and the permission settings you have granted. You can view this information by logging in to the Product and accessing the "Personal Center" and "Settings" pages; if you need to obtain a copy of your personal information, you can send an email to our customer service email (see Section 7 for details), specifying your game account and the type of information you need. We will provide you with a copy of the relevant information within 10 working days after verifying your identity.

 

Right of Correction: If you find that the personal information about you collected and stored by us is incorrect or incomplete (e.g., an incorrect username or wrong email address), you have the right to request us to correct or supplement it. You can directly correct the information through the "Personal Center" page of the Product (e.g., modify your username, update your email address); for information that cannot be corrected directly through the Product, you can contact customer service via email, provide relevant supporting materials, and apply for correction. We will verify the information within 7 working days and promptly complete the correction if the information is confirmed to be incorrect.

 

Right to Withdraw Consent: You have the right to withdraw the consent you have granted to us (e.g., withdraw the location permission or camera permission), which can be done by modifying the Product’s permission settings in the device system settings. After you withdraw your consent, we will no longer collect the corresponding information, but the withdrawal of consent will not affect the validity of information collection and use activities that have already been carried out based on your previous consent.

 

Right of Objection: If you believe that we have collected or used your personal information in violation of this Privacy Policy or relevant laws and regulations, you have the right to object to our information collection and use activities. You can contact customer service via email to raise an objection and provide relevant evidence. We will review your objection within 15 working days and provide you with a written response; if the objection is valid, we will promptly take corresponding measures (e.g., stop using the information, delete the information).

 

Right of Complaint: If you are dissatisfied with our handling of your personal information (e.g., refusal to fulfill your request for access, correction, or deletion), you have the right to file a complaint with the relevant regulatory authority (e.g., the Federal Trade Commission (FTC) of the United States), and we will actively cooperate with the regulatory authority in the investigation and handling process.

5. Use of Cookies

5.1 What Are Cookies

Cookies are small text files stored on your device (computer, mobile phone, tablet) when you visit a website or use an application. They can record your browsing habits, preferences, and other information to help the website or application provide you with a better user experience.

5.2 How We Use Cookies

When you use the Product (including accessing our official website and using the mobile game client) (after the Product’s official launch), we may use Cookies to collect and store relevant information about you for the following specific purposes:

Authentication: Cookies can help us identify your game account identity when you log in to the Product, so you do not need to re-enter your account password when accessing the Product again, improving login efficiency.

 

Personalized Services: Cookies can record your game preferences (e.g., game language settings, screen brightness settings) and game progress, allowing us to provide you with personalized services (e.g., restoring game progress, displaying the game interface in your preferred language) when you use the Product next time.

Data Analysis: Cookies can collect information about your use of the Product (e.g., the pages you visit, the time you spend on each page, the features you use), which helps us analyze user behavior and usage habits, optimize the Product’s content and functions, and enhance the user experience.

5.3 Your Choices Regarding Cookies

You have the right to choose to accept or reject Cookies, and you can modify Cookie settings in your browser or device system to disable Cookies. However, please note that if you disable Cookies, some features of the Product may not function properly (e.g., you may need to log in to your account again every time you use the Product, and you may not be able to receive personalized services).

6. Policy Updates

We may update this Privacy Policy from time to time in accordance with changes in laws and regulations, adjustments to the Product’s features, and changes in user needs. When updating this Privacy Policy, we will post the updated version on our official website (https://www.chillplaylabs.com) and the Product’s login page (after the Product’s official launch), and indicate the effective date of the updated version. If the update involves major changes (e.g., adjustments to the scope of information collection, changes to the method of information sharing), we will notify you of the updated content via a pop-up window in the Product or an email sent to the email bound to your game account 30 days before the effective date of the updated version. Your continued use of the Product after the effective date of the updated Privacy Policy shall constitute your consent to the updated Privacy Policy. We recommend that you regularly check the latest version of this Privacy Policy on our official website or the Product.

7. Contact Information

If you have any questions, suggestions, or complaints regarding this Privacy Policy or the collection, use, storage, and protection of your personal information (after the Product’s official launch), you may contact us through the following channels:

   Email Address: info@chillplaylabs.com

   Company Address: 4770 Baseline Road, Boulder, Co 80303

We will respond to your message within 15 working days of receiving it and provide you with a satisfactory solution.

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