privacy policy
Introduction
Jingxi (Minhou) Information Technology Co., Ltd (“Jingxi Information”, “we” or “us”) is dedicated to protecting the privacy rights of our online users (“users” or “you”). this privacy policy (“privacy policy”) serves to inform our users on how we collect, store, process, use and manage the information you provide us when using our games or applications (“services” or “service”), whether you use them through our direct channels (such as our website) or through third-party platforms where these are embedded.
the scope of this privacy policy is limited to the information collected by Jingxi Information and is not applicable to information other third parties collect in websites or mobile applications where Jingxi Information is the owner of those applications or websites nor is responsible.
by using the service, you are agreeing to the collection and use of your personal information as outlined in this privacy policy. we may amend the privacy policy from time to time, and we encourage you to consult the privacy policy regularly for changes.
Controller and contact details
Jingxi (Minhou) Information Technology Co., Ltd, acts as the data controller in the terms set out in this Privacy Policy.
If you have any questions about this Privacy Policy or any other matter regarding personal data, Jingxi Information has appointed a Data Protection Officer for these and other matters so please contact us through our dedicated contact form in our website here or by sending us a letter to the address included in the previous paragraph.
service@jxmg926.cn
Definitions
For a better understanding of this Privacy Policy, we provide you with a list of definitions:
“Personal data”: any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier, such as a name, electronic identifiers or email of that natural person;
“Processing”: the operation or set of operations carried out on personal data, whether by automated or non-automated procedures, such as the collection, registration, organization, structuring, conservation, adaptation or modification, recovery, consultation, use, dissemination by transmission, diffusion or any other form of availability, comparison or interconnection, limitation, erasure or destruction;
“User” or “Data subject”: the natural person who uses our Services and who, for some reason, personal data is processed;
“Data controller”: the natural or legal person, the public authority, the agency or other body that, individually or in conjunction with others, determines the purposes and means of processing personal data. For the purposes of this Policy, Jingxi Information is the personal data controller;
“Data processor”: natural or legal person, the public authority, agency or other body that processes personal data on behalf and in accordance with the instructions of Jingxi Information;
“Personal data recipient”: natural or legal person, public authority, agency or other body that receives personal data provided by Jingxi Information;
“Supervisory Authority”: means an independent public authority that is established by an EU Member State.
General Principles applicable
Regarding general principles applicable to the processing of personal data, Jingxi Information ensures that this data is:
• Subject to lawful, fair and transparent processing;
• Collected for specific, explicit and legitimate purposes, not being later processed in an incompatible manner with those purposes;
• Adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
• Accurate and updated whenever necessary, taking all appropriate measures so that the inaccurate data, taking into account the purposes for which it is processed, is erased or rectified;
• Kept in a way that allows the identification of the user only for the period necessary for the purposes for which the data is processed;
• Processed in a way that guarantees data’s safety, including protection against its unauthorized or unlawful processing and against its accidental loss, destruction or damage, implementing appropriate technical and organizational measures.
Personal Data
Jingxi Information primary objective in collecting user information is to provide and enhance the Service and to enable users to easily navigate and enjoy the Service.
When you install any of the Jingxi Information games or applications, we may collect and record the information you provide us voluntarily through third parties such as www.facebook.com (“Facebook”) in accordance with the policies and terms of such third parties.
We may collect, process, store and transfer different types of data grouped by the following categories:
• Identification data such as first name, last name, gender, username, display name, city / region of the world (retrieved from IP address), unique ID (Facebook ID; Apple ID; Jingxi Information ID) and global user ID (when it is possible to associate different types of IDs from different games and platforms), other advertisement IDs (IDFA; GAID);
• Contact data such as email address;
• Game data such as events, play session ID, play session time, days elapsed, games, among other;
We note that most of this information is treated without us knowing who the user is. This means that we cannot associate directly who is playing our games to a single person even though we receive information from third parties, we do not actively process identifiable data. We do however process personal data in games such as Worlds.
In the case of Facebook we might have access to your first name and Facebook profile photo URL but note that this information is not processed actively by us and we do not use it for other purposes than to send push messages through Facebook. Other information collected is last name, gender and names of Facebook, friends and Messenger connections that you provide us.
Sources of data
Jingxi Information collects two types of data on our users: passive and active.
Passive sources data
Passive collection is data collected when users play games, whether on their mobile device or the web. This data contains the following information:
• City/region based on your IP address;
• Session duration;
• In-game activity - we may collect aggregated information including but not limited to internet protocol addresses, browser type, browser language, referring / exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, and the date and time of this activity. We use this information to better tailor the Service to your interests, to provide you more efficient customer support, and to overall enhance the Service.
This data does not contain any personally identifying information.
Active sources data
Our active data collection is currently limited to gameplay information such as high scores or game session duration.
In the cases where users can and choose to provide information when using their Facebook account to log in, we store:
• User Access Token: we simply use this token to identify a user from one play session to the next. We do not gain access to any details about the user;
• If you use Facebook Instant Games and provide consent for such actions, we process your first name and Facebook photo URL to send push messages for our games through bot messages. We do not process this information in the same way we process users’ game data and we do not track or identify our users through these data points. Users can turn off notifications as we explain in section XIV “User’s rights”.
We may also collect data based on direct interactions you have with us such as:
• Contact enquiries: when you send us an email with an enquiry about a game or other type of questions we may process your contact details, such as your email.
• Newsletter: you can subscribe to our newsletter through our website. When you do, you are providing us your consent to send you information regarding our Services. Your consent can be revoked at any time.
Jingxi Information may also invite you to share other information about yourself that may include but is not limited to your:
• Name and surname;
• Email;
• Age or date of birth;
• Gender;
• Information about the hardware you may own;
• Favorite websites, friend information and fan pages.
Finally, any time you access the Service, we may collect aggregate information including but not limited to internet protocol addresses, browser type, browser language, referring / exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, and the date and time of this activity. We use this information to better tailor the Service to your interests, to provide you more efficient customer support, and to overall enhance the Service.
Once again, we do not store any data that can be used to identify and track an individual. However, if non-personal information is collected, for an activity that also requires personal information, Jingxi Information may combine your non-personal information with your personal information to provide you with a better user experience, to improve the quality and value of the Services and to analyse how our Services are used.
Other Disclosure of Your Personal Information
You understand and agree that we may be required to disclose any personal information if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to avoid liability, to comply with legal process, including but not limited to a search warrant, subpoena, statute, or court order, or to protect our rights and property, or that of the public. Note that Jingxi Information is not required to question or contest the validity of any search warrant, subpoena or other similar governmental request that Jingxi Information may receive.
Additionally, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, customer information may be transferred to Jingxi Information successor or assignee, if permitted by and done in accordance with applicable law.