Last Updated: September 10, 2024
Right Works Limited ("we", "us", "our") is committed to respecting and safeguarding the privacy rights of our users ("you", "your") who visit our websites, play our games on mobile devices or other platforms ("our Games"), and use any services we offer, including but not limited to technology services, customer support, competitive gaming, marketing, and advertising ("our Services").
This Privacy Policy explains our practices regarding the collection, utilize, storage, and sharing of information we collect from or about you when you interact with us. It also outlines your rights concerning the information you provide and how we secure and transfer it.
Please read this Policy carefully to understand how we handle your Personal Data (as defined below) and review it regularly for updates. By downloading, accessing, using, or interacting with our Services, you agree to and explicitly consent to our collection, use, and disclosure of your information as described in this Privacy Policy. This Policy is incorporated into our Terms of Service, and is subject to those Terms. If you have any concerns about providing your information or how it is used as described in this Policy, you should not use our Services.
If we make any changes to this Policy, we will notify you through announcements in our Games and obtain your consent if required. By continuing to use our Services after such notice, you are deemed to accept the updated Policy. The "last updated" date at the top of this Policy indicates when it was last revised. If data protection laws require us to provide additional notice or obtain your consent for changes, we will comply. The revised Policy will replace all previous versions.
Table of Contents of Privacy Policy:
1. Significant Definition
2. Collection of Data and Information
3. Use of Data and Information
4. Storage and Security of Data and Information
5. How We Handle Data and Information
6. Data Protection Rights & Data Retention and Deletion
7. Third-Party Service Providers and Services
8. Contact Us
1. Significant Definition
1.1. **Personal Data**: This refers to any information that can directly or indirectly identify a living individual. Identification can occur through various means, such as an identifier, location data, or factors specific to the individual's physical, physiological, genetic, economic, cultural, or social identity.
1.2. **Usage Data**: Information collected automatically, either through your use of our services or from the service infrastructure itself.
1.3. **Cookies**: Small data files stored on your device's hard drive or memory that assist us in improving our Services and enhancing your experience. They help us identify which areas and features of our Services are popular and track visit counts.
1.4. **Data Controller**: A natural or legal person who determines the purposes and methods for processing Personal Data. For the purposes of this Policy, we act as the Data Controller of your data.
1.5. **Data Subject**: Any living individual whose Personal Data is being processed.
1.6. **The Game(s)**: Refers to any game provided by Inspire Interactive Limited, including PC games, web-based games, HTML5 (H5) games, mobile games, and other formats. When distributed as software, this also includes the related software and documentation.
1.7. **The Game’s Service**: Includes all online operational services related to the Games provided by Inspire Interactive Limited.
1.8. **You**: Also referred to as "player(s)" or "user(s)," this term designates any individual authorized to access and use the Game and its associated services.
2. Collection of Data and Information
Data collection and purpose: To offer you gaming entertainment and related services such as player interactions, purchases, and support, we need to collect certain information. This may include:
- Account Information
- Login Information
- Payment Information
- Device Information
- Advertising & Marketing Information
- Information you provide to our team
2.1. Account Information
When you use our Services, you have the option to provide various details on your Account, such as your profile picture, nickname, gender, date of birth, and location. While sharing this additional information is not mandatory, it can enhance your experience by helping others get to know you better. However, be mindful not to post or add any information to your profile that you wouldn’t want to be publicly accessible.
2.2. Login Information
When creating an account in our Games, you have the option to sign up using your email or mobile phone number. By doing so, you consent to provide certain Personal Data, such as your email address, a verification code sent via email or SMS, and a password.
Alternatively, you can register using social network accounts like Facebook, or Google Play ("Social Networks"). In this case, we may collect information that you have authorized the Social Networks to share with us, which typically includes basic public profile details such as your nickname, username, and profile picture. The specific information we receive may vary based on your privacy settings on those platforms. Please note that if you choose not to provide information from your Social Networks accounts, you may not be able to register or log in using those accounts.
In certain regions, you may also be required to provide your date of birth to verify your eligibility to access or use our Services.
2.3. Payment Information
When you purchase virtual currency or virtual items through our Services, we may collect and process your purchase and transaction information. This includes details about your device (such as Open ID, IP address, operating system version, device type, and internet connection), transaction specifics (including time, date, cost, purchased product, currency, and order ID), and transaction records (such as player ID, transaction time, country, email, phone number, purchase history, and payment card details). This information is necessary for us to fulfill our contractual obligations, facilitate your payments, and provide you with transaction details.
Please note that all purchases and refunds are processed by third-party payment processors. We do not process payments directly, nor do we have access to your credit card or billing information.
2.4. Device Information
When you use our services, we automatically collect certain information about your devices and how you interact with our services. This data collection is essential for improving our services and ensuring their security. The types of information we collect include:
- Internet Protocol (IP) Address: We gather and process your IP address to manage and control your access to our services.
- Device Information: Upon starting our services, and based on the specific permissions you grant during installation and use, we collect various details about your mobile device. This includes your UUID, IMEI, IDFA, device model, operating system version, app version, device display resolution, device settings, CPU and storage information, battery status, time zone settings, and device location (which may include IP address, GPS location, WLAN, Bluetooth, and cell site information). This data helps us ensure the security of our services, manage registrations, and improve user experience.
- Usage Data: To fulfill our Terms of Service, we collect and store details about how you use our services. This includes your login account, IP address, internet provider information, connection environment, WIFI status, and other data generated during your interaction with our services.
Please note that some of this information, when considered alone, does not identify you as an individual and thus is not classified as Personal Data. However, when this non-personal data is combined with other information that can identify you, or when it is used alongside your Personal Data, it is treated as Personal Data. In such cases, we will anonymize and de-identify the information unless you have provided consent or laws require otherwise. This data is critical for providing our services, and if you choose not to provide it, we may be unable to offer you our services.
2.5. Advertising & Marketing Information
We may store advertising identifiers, such as Android ADID, along with your device information, and link these to your profile to monitor the effectiveness of our ads when you interact with them in our Services.
To offer personalized ads, promotions, and marketing communications, we may collect and process certain information with your consent. This information may include your age, gender, email address, geographic location, device type, in-game behavior (such as your preferences and habits), and any additional details you provide through surveys or inquiries.
We may also use this information to send you advertisements, market surveys, or research invitations via email. If you prefer not to receive these communications, you can opt out (refer to "Promotional Communications" below).
Please note that opting out of interest-based or targeted advertising does not remove all advertisements from our Services or online platforms; however, the ads you see will not be personalized based on your Personal Data. Additionally, if we determine that you are under the legal age of majority according to the laws in your jurisdiction, we will not target you with advertising or send you related messages.
2.6. Information you provide to our team
We may collect additional information about you to enhance our products and services, including feedback you provide when contacting customer support or completing surveys. This information helps us improve your experience, and we may combine it with data from other services to serve you better.
If you experience any issues while using our Services, you can contact our customer support team for assistance. When you submit a support request, we may collect the content of your inquiry, details about your device, and any contact information you provide. This information is used to communicate with you, resolve your issue, and document the problem and its solution. If you choose not to provide this information, we may be unable to offer you support, but it will not affect your ability to use other features of our Services.
To the extent permitted by law, we may obtain your Personal Data from other individuals, business entities, public sources or other third parties acting at your direction, our partners who work with us to provide our products and services and assist us in information security and fraud prevention, and from other lawful sources. We will explain it to you at the time of such collection and obtain your consent.
Under data protection laws, we are authorized to use your Personal Data only when we have a valid reason, such as complying with legal and regulatory obligations, fulfilling a contract with you or taking steps at your request before entering into a contract, and pursuing our legitimate interests or those of a third party, provided your interests and fundamental rights are not overridden. We may also use your data with your consent. Legitimate interests arise when we have a commercial or business reason to use your data without infringing on your rights. We may use your Personal Data to provide services, prevent and detect fraud, conduct identity verification, protect confidential business information, perform statistical analysis, maintain system security, update customer records, and market our services and those of selected third parties. Importantly, we do not use your Personal Data for automated decision-making.
3. Use of Data and Information
We can use your Personal Data only if there is a valid reason, such as:
- Complying with legal and regulatory obligations;
- Fulfilling our contract with you or taking steps at your request before entering into a contract;
- Pursuing our legitimate interests or those of a third party; or
- Where you have given consent.
A legitimate interest refers to a business or commercial reason to use your Personal Data, provided it does not override your rights and interests.
We use your Personal Data for several purposes:
- Providing Services: To fulfill our contractual obligations with you or to take necessary steps before entering into a contract.
- Preventing and Detecting Fraud: To minimize fraud that could impact both us and you, based on our legitimate interests or those of a third party.
- Conducting Checks: To verify your identity and comply with legal and regulatory requirements.
- Protecting Confidential Information: To safeguard trade secrets and other commercially sensitive data, and to meet legal obligations.
- Statistical Analysis: To manage our business effectively, such as evaluating financial performance and improving operational efficiency, which supports our legitimate interests.
- Maintaining Security: To prevent unauthorized access and detect criminal activities, ensuring system integrity and compliance with legal obligations.
- Updating Customer Records: To keep in touch with you about existing orders and new products, fulfilling our contract with you, and complying with legal and regulatory obligations.
- Marketing: To promote our Services to current and former customers, individuals who have shown interest, and new prospects, based on our legitimate business interests.
We do not use your Personal Data for automated decision-making purposes.
4. Storage of Data and Information
We store your Personal Data at our offices and those of our third-party service providers, representatives, and agents. This data is handled in compliance with applicable data protection laws and regulations. You should be aware that, unless local laws prohibit it, your data may be processed on servers located outside your country of residence and accessed by our global support, engineering teams, or affiliates. Your information may be stored and processed in locations such as Hong Kong, Singapore, or other countries where we or our third-party agents operate. Despite the server locations, we implement appropriate safeguards to protect your rights according to this Policy and applicable laws.
We retain your Personal Data for as long as you have an account with us or while we provide services to you. After this period, we will keep your data only as necessary to:
- Address any questions, complaints, or claims you or others make on your behalf.
- Demonstrate that we have treated you fairly.
- Maintain records as required by law.
Different types of Personal Data have specific retention periods:
- Login information: Retained as long as needed to provide our Services or as legally required.
- Account information: Retained as long as needed for service provision or legal requirements.
- Payment information: Retained for the duration required to provide our Services or as legally necessary.
- Support team information: Retained as long as needed for service provision or legal requirements.
- Advertising & Marketing information: Retained as needed for service provision or legal requirements.
- Device information: Retained as necessary for providing our Services or as legally required.
- Other information we may collect: Retained as long as necessary for service provision or legal requirements.
If your account is canceled or terminated, we will either delete or anonymize your Personal Data.
We prioritize the security of your Personal Data and use measures designed to protect it. Our systems are regularly monitored for vulnerabilities and threats, and we continuously enhance these security measures. However, please note that no method of internet transmission or electronic storage is completely secure. While we employ commercially acceptable practices to safeguard your Personal Data, we cannot guarantee absolute security.
5. How We Handle Data and Information
We adhere to principles of minimization, necessity, and legality when sharing, transferring, or disclosing your Personal Data. Except as detailed below, we do not disclose your Personal Data externally:
5.1. How We Share Your Personal Data
- No Sale of Personal Data: We do not sell your Personal Data to third parties. We share it only when necessary, including with:
- Service Providers: These include cloud and network service providers who assist with services such as user authentication, customer support, crash analysis, performance improvement, marketing, translations, content moderation, payment processing, and fraud detection. These providers are bound by contracts to use your data solely for their intended purposes and are prohibited from retaining or using your data for other purposes.
- Affiliated Companies: Our corporate group companies that process data to operate our services. They must adhere to this Policy when handling your data.
We ensure that our service providers implement appropriate safeguards to protect your Personal Data and comply with contractual obligations. However, their privacy policies govern their use of your data, and this Policy does not cover third-party products, services, or websites.
5.2. How We Transfer Your Personal Data
- With Your Consent: We will transfer your data only with your explicit consent.
- In Business Transactions: In the event of a merger, acquisition, or sale of assets, we will notify you via email, our website, or other means about any changes in ownership and your data rights.
- Policy Notification: We may also transfer your data as described in this Policy or through other notifications to you.
5.3. How We Disclose Your Personal Data
- Legal Requirements: We may disclose your data when required by law, subpoena, or other legal processes, or when necessary to:Investigate or prevent illegal activities, assist enforcement agencies, enforce agreements, defend against claims, protect our services' security, or safeguard users and others.
- Additional Disclosures: We may also share your data with:
- Professional Advisors: Our attorneys, accountants, or consultants for professional advice.
- Investors and Third Parties: Relevant parties in the context of sales or other transactions involving our group.
- Authorized Parties: With your permission for specific information disclosures.
5.4. How Your Data Is Transferred Internationally
To provide services as outlined in this Policy and with your consent, we may transfer your Personal Data to our servers or third-party service providers located in other countries or regions. We ensure that such transfers comply with applicable local data protection laws and implement appropriate security measures to protect your data throughout these transfers.
6. Data Protection Rights & Data Retention and Deletion
6.1. Data Storage and Protection
Your Personal Data is stored at our offices and those of our third-party service providers, representatives, or agents. It is managed according to the privacy laws of relevant countries. Your data may be processed on servers outside your country of residence and can be accessed by our global support, engineering teams, and affiliates. Data may be stored and processed in locations such as Hong Kong, Singapore, or other countries where our subsidiaries or third-party agents operate. Regardless of server location, we implement strong safeguards to protect your data in line with this Policy and applicable laws.
6.2. Data Retention
We retain your Personal Data as long as you have an account with us or while we provide services. Afterward, data is kept only as necessary for:
- Addressing questions, complaints, or claims.
- Demonstrating fair treatment.
- Meeting legal record-keeping requirements.
Different types of data have different retention periods:
- Login, Account, Payment, Support, Advertising, Automatically Collected, Survey, and Other Information**: Retained only as necessary to provide services or as required by law.
If your account is canceled or terminated, we will delete or anonymize your data.
6.3. Data Security
We prioritize the security of your Personal Data and employ safeguards to protect it, regularly monitoring for vulnerabilities and potential threats. Despite our efforts, no method of online transmission or storage is entirely secure. While we strive to use industry-standard protections, absolute security cannot be guaranteed.
6.4. Your Data Protection Rights
You have several rights concerning your Personal Data:
- Access or Delete: You can access or request deletion of your data. After verifying your identity, we will provide a copy or delete your data, subject to legal exceptions and potential impacts on service functionality.
- Rectification: You can request corrections to inaccurate or incomplete data.
- Object or Restrict: You can object to or request restrictions on the processing of your data.
- Data Portability: You have the right to receive a copy of your data in a structured, machine-readable format.
- Withdraw Consent: You can withdraw consent where it was previously given for processing.
- Privacy Settings Control: You can manage privacy settings on your device to control the collection, use, and disclosure of your data.
- Delete Account: You can close your account, which will lead to deletion or anonymization of your data. Note that this action is irreversible and may affect your use of our services.
To exercise these rights, submit a verifiable request via our platform or contact our support. If you use a third-party account for access, you must request closure through that service.
7. Third-Party Service Providers and Services
7.1. Cookies and Similar Technologies
Cookies are small text files that help ensure the proper functioning of our software and enhance your access to it. These files typically contain identifiers, site names, and various characters. We use cookies and similar technologies such as pixel tags and web beacons to collect information. Generally, this information is treated as non-personal data since it does not directly identify you. However, if IP addresses or similar identifiers are considered personal data under applicable laws, we will handle them accordingly. We and our partners may use these technologies to gather data like device IDs to recognize you across different services and devices. You have the option to manage or delete cookies based on your preferences. While we do not respond to "Do Not Track" signals due to their frequent misrepresentation of user preferences, you can opt out of specific types of tracking, including certain analytics and personalized advertising, by adjusting your cookie settings.
7.2. Third-Party Services
During your use of our Services, you may encounter links to third-party websites or access content and services provided by entities other than us. Some third-party products or services may be integrated into our Services via SDKs and similar tools to offer additional features such as third-party logins, notifications, and user analysis (collectively referred to as "Third-Party Services"). You have the choice to visit or use these Third-Party Services, and we encourage you to review their privacy statements carefully.
8. Contact Us
For the purpose of establishing the Personal Data protection in a better and more efficient way, we, as the Data Controller, designate a Data Protection Officer (in short, "DPO") who is responsible for the oversight and implementation of the Personal Data protection strategy and ensures our processing of Personal Data is in compliance with necessary legal requirements stipulated in the applicable laws. If you have any comments, questions or concerns with respect to our Privacy Policy or Personal Data protection practices, please contact us at info@rightwork.games (All requests must be labeled "Privacy Policy request" on the email subject line for us to better assist you).
We will review your privacy or Personal Data requests and respond to you as soon as possible after verifying your user identity. If your request itself involves any complicated or significant issue, we may ask you for more information.