Last Update: 11 October 2024

Holihigh Mobile Co., Ltd., and its subsidiaries that make up the Holihigh companies ("Holihigh", "we", "us" or "our"), is a leading developer, publisher and marketer of interactive entertainment. Please read this Privacy Policy carefully, and keep in mind that our practices and the data we collect may differ depending on how you use the Services. The Services are also subject to any other terms and policies included in our Services. This Privacy Policy supplements privacy disclosures provided with your software product and from your platform manufacturer.

Notice at Collection of Personal Information: Please see the Categories of Information Collected and How We Use Personal Information and Our Legal Grounds sections for an overview of what information we collect, and why, and the Data Rights section for information about how to exercise your privacy rights, including opting out of the sale or sharing of your personal information.

Categories of Information Collected

The type of information we collect depends on how you use the Services. Generally, we collect the following information:

• Identifiers / Contact Information: Name, user name, gamertag, postal and email address, phone number, unique IDs, mobile device ID, platform ID, gaming service ID, advertising ID (IDFA, Android ID) and IP address
• Protected Characteristics: Age and gender
• Commercial Information: Purchase and usage history and preferences, including gameplay information
• Billing Information: Payment information (credit / debit card information) and shipping address
• Internet / Electronic Activity: Web / app browsing and gameplay information related to the Services; information about your online interaction(s) with the Services or our advertising; and details about the games and platforms you use and other information related to installed applications
• Device and Usage Data: Device type, software and hardware details, language settings, browser type and version, operating system, and information about how users use and interact with the Services (e.g., content viewed, pages visited, clicks, scrolls)
• Profile Inferences: Inferences made from your information and web activity to help create a personalized profile so we can identify goods and services that may be of interest
• Audio / Visual Information: Account photos, images, and avatars, audio information via chat features and functionality.
• Sensitive Information: Precise location information (if you allow the Services to collect your location).

How We Use Information and Our Legal Grounds

We use the information we collect within App as follows, pursuant to various legal bases:

• Business Purposes: Provide the Services and support; fulfill orders and requests; improve the Services and our business; develop new products and services; enhance your experience on the Services; protect the security for our users, employees, facilities, and Services; and develop internal marketing and demographic studies
• Commercial Purposes: Market and advertise our and our business partners' products and services; send you promotional materials; and administer promotional activities or events

We also use your information as permitted by law.

We use information we collect for our business purposes, including to:

• Provide the Services
• Fulfill product orders and other requests, respond to your questions, and communicate with you
• Enhance and personalize your experience on the Services, including to recognize you, maintain your preferences and settings, connect you with other users and link to your third-party platform, gaming, and social networking accounts
• Provide technical and other support
• Review the use and operations of the Services, develop new products or services, and conduct analyses to enhance or improve our software, content, marketing, support, and Services
• Conduct internal marketing and demographic studies
• Address issues with the Services or other business needs
• To protect the security or integrity of the Services, users and our business such as by protecting against and preventing violation of our terms and policies, including combating fraud, piracy, cheating, tampering, unauthorized transactions, claims, and other liabilities, and managing risk exposure
• Interact on your behalf with the third-party platform, gaming, and social networking accounts you connect with our Services
• Participate in other processing that we inform you about when you provide your information or when you consent to such processing
• As permitted by law
• We use information we collect for commercial purposes, including to:
• Provide you and other users with customized content, targeted offers, and advertising on the Services, via email and text message, or on other sites, mobile applications, or social media on behalf of Holihigh or our business partners
• Contact you with information and promotional materials
• Administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners
• Analyze our users, in combination with other data, to assess our user base and target marketing at other similar groups

---Legal Reasons to Process Personal Data

If you are based in a location that requires us to establish legal grounds, we process your information on the following grounds:

• Establish and perform our contract with you (such as the terms applicable to our Services, or to take steps at your request, such as to complete transactions with you and to allow you to play our games online)
• Compliance with a legal obligation
• For our or our partners' legitimate interests, such as to improve our products and services; perform analytics to better understand our users; conduct direct marketing (when we do not need your consent); otherwise supporting our business, operations, and services; and enforce and prevent violations of our terms or policies

Sources of Information We Collect

How we obtain information depends on how you use the Services. For example, we collect information:

• you provide directly to us, such as when you set up an account, sign-up for marketing, or contact us
• about the games you play (automatically)
• from third-party platforms, such as when you play our games or access our Services with third-party accounts
• automatically, including through cookies and similar tracking technologies
• from third parties, such as advertising networks, business partners, third party information providers, and other players

---Information You Provide

You provide us with information when you use the Services, such as when you:

• create an account or use the Services
• subscribe to marketing and communications
• comment on our message boards, forums, chat rooms, feeds, sites, or other Services
• purchase or redeem one of our products or services, including physical items, virtual items, virtual currency, or add-ons
• download, install, or access demos, programs, or other software
• contact us for support or other purposes
• use our email or share features
• participate in events, contests, promotions, surveys, or playtesting
• participate in an activity where you provide your information

Depending on the Service or your activity, we collect information such as your name, email address, phone number, photo, mailing address / zip code, payment or purchase information, age, gender, password, platform ID, software products played, survey data, geolocation, and the systems or platforms you play on. We combine this information across devices that you use.

---Gameplay Information

When you use the Services, we automatically receive information about your gameplay. Gameplay information includes your platform ID or gaming service ID, game achievements, game scores and performance, IP address, MAC address or other device IDs, other platform / device information, and other information and statistics regarding your use of the Services. We collect gameplay information even if you do not register for the Services. We may combine gameplay information with other information we have about you. We also may use internal and third-party anti-cheat technologies to detect and prevent cheating within our Services.

---Platform, Gaming, and Social Networking Information

We collect information when you access our Services with third-party platform accounts, such as a gaming platform account, gaming network service account, or social networking service account. When you access our Services in this way, the third-party platforms provide us with information about you. For example, depending on your use of, or activity on the third-party platform, we receive your user name, your friends list, or account information necessary to provide the Services or a purchased in-game item. The third-party platform may allow you to control what information is provided to us. We are not responsible for the terms, policies, disclosures or actions of any third-party platforms.

---Cookies and Similar Technologies

We may use cookies, web beacons, pixel tags, Flash cookies, Internet log files, software developments kits and similar tracking technologies to improve and maintain the functionality of our Services; enhance security and fraud prevention; and provide you with targeted advertising. Our system may not respond to Do Not Track requests or headers from some or all browsers. The Manage Your Account, Communications, and Data section provides additional information about our use of cookies and similar technologies and your ability to manage cookies. You may also use the cookie preference tool, where available, or visit the Cookie Policy posted on the Service for more information.

---Information from Third Parties

We receive information from third parties to update the information that we collect about you. We may receive information from public databases, platform manufacturers, analytics providers, game developers, and other business partners and Holihigh companies involved in providing the Services to you, that includes demographic information and information about your interests. We may collect publicly available information, including from social media, to protect our users, employees, facilities, and Services, and to aid investigations. We also receive information from other individuals who use our Services. This may include information about you if you are mentioned in comments on the Services or an individual sends us a direct message.

When We Share Information

As detailed below, we share your information with:

• vendors that perform support and other services for us
• Holihigh members
• advertising service providers and partners
• other third parties (e.g., for collaborative offerings, legal and safety purposes, in connection with the sale or transfer of a business or asset, and other purposes with your permission)
• other users, such as when you participate in open communities or events, or information published on leaderboards

We do not sell or share personal information about persons that we know are under the age of 16 without their (or depending on age, their parent's) consent.

Data Rights

Depending on your location, you may have certain rights over your personal information, including the right to:

• Request access to or a copy of your personal information
• Request deletion of your personal information
• Request correction or modification of your personal information
• Be informed about the personal information we collect and/or process about you, the sources of personal information, and the third parties with whom information was shared or sold and for what purposes
• Withdraw consent, if processing is based on consent
• Opt-out of the sale or sharing of your personal information (including targeted advertising)
• Opt-in/out of financial incentives
• Limit the use and disclosure of your sensitive personal information

Data Retention

We'll keep your information for as long as necessary to provide you with the Services, fulfil our legal obligations, and/or exercise, defend or establish our rights.

We retain your information while your account is active, as needed to provide you Services, or to administer our Services. If you wish to delete your account or request that we no longer use your personal information to provide Services to you, contact us as identified in the Manage Your Account, Communications, and Data section. If your account is inactive, we will maintain your account for the length of time for which we reasonably expect you to reengage with our Services. After such period, we will delete personal information, including your email address and log-in credentials, and you may no longer be able to access your account. We may still retain some of your personal information in our files for a reasonable period of time to resolve disputes, enforce our terms and policies, administer our Services, comply with technical and legal requirements, and/or other constraints related to the security, integrity, and operation of our Services, after which we will take steps to delete or archive your personal information.

Children's Privacy

Generally, we direct our Services to a general audience and we do not knowingly collect personal information from children under 13 years old (or older, if applicable law provides for different protections). We may direct certain Services to an audience of all ages---including children. For these Services, we may restrict the collection of personal information on the Services from anyone, apply an age gate allowing children to use the Services while restricting the collection of personal information on the Services from children, or get a parent's permission to collect personal information from children. If we become aware that a child has provided personal information without a parent's permission, we will promptly delete this information. We encourage parents to instruct their children to never give out their real names, addresses, or phone numbers, without permission, when using the Internet.

Data Security

We follow generally accepted industry standards and maintain appropriate safeguards to help protect the security, integrity, and privacy of the information we collect about you. These security measures are designed to protect against the accidental or unlawful destruction, loss, misuse, alteration, and unauthorized disclosure of, or access to, the information under our control. However, no system can be 100% secure and we cannot guarantee our security measures.

Contact Us

If you have questions about this Privacy Policy, you may contact us by email at [email protected].

Changes to Privacy Policy

We reserve the right to make changes to this Privacy Policy. Please check back from time to time to review these changes. If we change this Privacy Policy in a material way, we will provide appropriate notice to you and, as appropriate, provide additional choices regarding such change. As permitted by applicable law, your continued use of the Services means that you accept these changes.