APPGURU TECHNOLOGY PTE LTD (hereinafter referred to as “AppGuru Technology Pte Ltd”, “AppGuru”, “our”, “we” or “us”) understands the importance of protecting your privacy and would show respect to this. We are devoted to maintain your trust with good products and services. At the same time, we will do our best to protect and respect users’ (hereinafter referred to as “user”, “users” or “you”) personal information and privacy.
This Policy clarifies how APPGURU TECHNOLOGY PTE LTD collect and process your personal information, please note this Policy might not include all possible situations. Terms about the collection and usage of specific information might be added in our complementary policies or posted via Notice whenever there is an information collection.
This policy is an indivisible part of Gaming License and Service Agreement of APPGURU TECHNOLOGY PTE LTD All other user-related issues that are not stated in this Policy are bound by the Gaming License and Service Agreement of APPGURU TECHNOLOGY PTE LTD
1. How we collect and use your personal information?
3. When we may share, transfer, or disclose your personal information?
4. How we retain, store and protect your personal information?
5. How we manage your information?
6. How to delete your data?
7. How we process minors’ personal information?
8. Third party services
9. Notices and modifications
10. How to reach us?
1.1 Information collection and usage situations that require your consent
1.1.1 Required information for account registration and login.
In order to help you register and login your account, we will collect your name, mobile phone number, ID number, email address, user name and other information that is provided by you or with your consent. Real-name identity information would be collected with your consent, as real-name authentication is needed by the requirements of relevant laws and administrations of your country. If you refuse to provide this information, we might not be able to provide you with relevant products or services, nor could we respond to or solve your problems.
1.1.2 Required information to fulfill your purchase request.
We would collect your payment and purchase information for account and transaction risk control, identity authentication, security incidents detection and prevention. Though this information is sensitive, we have to collect it to complete your purchase request and fulfill the payment function.
1.1.3 Required information for proper functioning.
In order to ensure and improve your game experience, maintain the basic functions, optimize your game performance and keep your account safe, we would collect your IP address, device ID, device model, operation system type, operation system and its version, device MAC address, UDID (i.e. IMEI/android ID/IDFA/IDFV), network type, system language of device, etc.
1.1.4 Required information during game playing.
We will collect your activity log information whenever you use services of APPGURU TECHNOLOGY PTE LTD, including login logs, item logs, payment logs, logs of binding information changes and virtual currency changes. We do this to enable you to check your game records anytime and improve your game experience, at the same time, we may synchronize the information to the following versions and use it for game analysis, customer complaint processing and other security analysis.
1.1.5 Necessary information to maintain a healthy game environment.
We may collect and retain your interactions with other players of any forms, including chat texts, images, sounds, videos, etc. We do this to filter any content related to sex, violence, politics, abuse, malvertisements so as to maintain a healthy game environment.
1.1.6 Necessary information for security and services.
We will collect and analyze your game ID, operating system information, game crash records to identify and process any actions that might interfere with or destroy the fair or normal environment of the service (i.e., we might use the information to scan hack, or for anti-cheat activities), thus ensure a fair, healthy and safe game environment.
1.1.7 Required information for transaction security.
In order to prevent safety risks caused by phishing sites, frauds, network bugs, computer viruses, cyber-attacks, network invasions, we may collect, use or integrate your account, payment, device, logs or other legally shared information to evaluate possible risks of your account and transaction.
1.1.8 Necessary information for customer service and after-sale function.
In order to reach you, help you solve your problem, or record the treatment plan and results of your problem, we may collect, retain your messages, call history and content, or information provided by you when you reach our customer service, including your name, contact information, address, etc.
1.1.9 Please note the functions and services we provide are constantly updating and developing. If any function or service collects your information out of the range of the above terms, we will make it clear to you about the content, range and purpose of the collection via page prompts or site notices so as to get your consent.
1.2 How do we use the collected information
1.2.1 We will provide you with functions and services based on the collected information, such as basic game functions, payment function, etc.
1.2.2 We would use your personal information for ID authentication, safety precautions, anti-fraud monitoring, archive backup, cheating behaviour processing, and other security services.
1.2.3 We may use the collected users’ information for internal audit, data analysis, study and analyse our business efficiency and measure our market share, etc.
1.2.4 With your consent, we may send you update and installation notifications of the application or different versions. If you do not agree, we might not be able to provide you with relevant products and services.
1.2.5 Your information may be used to obey or implement the requirements of applicable laws or industry standards.
1.2.6 The information we collect about you will be de-identified and could not identify its subject afterwards. Please understand this and agree that we have the rights to use such information, analyze user databases and utilize them for commercial purposes without disclosing your personal information.
1.2.7 Please note your authentication to us will always be effective whenever you use our products and/or services, unless you delete or refuse our collection via system settings.
1.2.8 We will summarize usage situation of our products and/or services and may share it to the public or third parties to show the overall usage trends of our products and/or services. The statistics does not include any of your identity information.
1.2.9 When it is needed to show your personal information, we will adopt forms such as content replacement, anonymization to protect your information.
1.2.10 We will ask for your permission when we are about to use your personal information in the ways not stated in this Policy, or use the collected information for other purposes via page prompts, interactions, notices or other forms. If you agree, the additional usage will be regarded as part of this Policy and the additional information is applicable to this Policy.
1.3 We can collect and use your information without your consent in the following situations:
1.3.1 According to applicable laws, regulations, policies, or compulsory requirements of administrative or judicial departments of Singapore, anything that is related to national interest, national security, public security, public health, major public interest and illegal criminal activities, etc.
1.3.2 For the purpose of safeguard information subject or other individual’s major legitimate rights and interests regarding life and property, which is hard to get your approval.
1.3.3 Anything that is already public to the society by yourself.
1.3.4 Anything that is collected from publicly disclosed information, such as legitimate news report, public information of the government, etc.
1.3.5 Anything that is necessary to perform the contract according to your request.
1.3.6 Anything that is necessary to maintain the security and stable operation of our products or services, such as identify, process the bugs of our products or services.
1.3.7 Anything that is necessary for legal news reports.
1.3.8 Anything that is necessary for academic institutions to conduct statistics or academic studies for the sake of public interest. They will de-identify the information contained in the results when they provide their study results or describe the results to others;
3.1 Information sharing
3.1.1 Normally, APPGURU TECHNOLOGY PTE LTD would not share your personal information with any third parties, except when:
A. Your prior consent or authentication is given.
B. Required by relevant Chinese laws, regulations, policies, or compulsory requirements of administrative or judicial departments;
C. Necessary and legal to protect the interest, property rights or security of AppGuru Technology Pte Ltd, its affiliated companies or partners, users or the public.
D. The core functions of our products or services can only be fulfilled with your shared personal information.
E. For the purpose of personal disputes or arguments according to your demand.
F. In accordance with related agreements (including online electronic agreements and corresponding platform rules) and other legal documents signed by you.
G. For academic studies.
H. Legal usage for public interest.
3.1.3 We may share with our partners your order information, account information, device information, location information to ensure the completion of our services only based on legal, justified, necessary, specific and certain purposes and whenever necessary. Our partners do not have the right to use the shared information for any other purposes. For instance, we would hire a third-party company for data statistics and analysis, they might need to collect and visit your personal data. They must comply with our requirements on privacy and data security. We will only share necessary personal information to a third-party service provider based on legal, justified, necessary, specific and certain purposes and whenever necessary. We would sign non-disclosure agreements with companies, organizations and individuals that receive our shared personal information. They are required to process the information based on our instructions, this Policy and other related non-disclosure and security measures.
3.1.4 In the process of fulfilling our rights or duties stated in this Policy or other agreements.
3.2 Information transfer
We would not transfer your personal information to any companies, institutions, or individuals, except when:
3.2.1 Your explicit consent is given.
3.2.2 In mergers, acquisitions, or bankruptcy liquidations, we will continue protecting your personal information according to related laws and regulations and notify you via pushes, notices or other forms, or we will ask the new administrators to continue protecting your personal information based on this Policy.
3.3 Information Disclosure
With safe protection measures, we will disclose your information only in the following situations:
3.3.1 We will disclose your specified information with your explicit consent and in accordance with your request.
3.3.2 We may disclose your personal information when legally compelled to do so by the Singapore laws and regulations, judicial offices or administrative departments.
3.3.3 In corporate restructuring, mergers or bankruptcy liquidations, your personal information may be disclosed to the counter-party.
3.4 Exceptions of prior permission in information sharing, transfer and disclosure.
3.4.1 According to applicable Singapore laws, regulations, policies, or compulsory requirements of administrative or judicial departments of Singapore, anything that is related to national interest, national security, public security, public health, major public interest and illegal criminal activities, etc.
3.4.2 For the purpose of safeguard information subject or other individual’s major legitimate rights and interests regarding life and property, which is hard to get your approval.
3.4.3 Anything that is already public to the society by yourself.
3.4.4 Anything that is collected from publicly disclosed information, such as legitimate news report, public information of the government, etc.
3.4.5 Anything that is necessary to perform the contract according to your request.
3.4.6 Anything that is necessary to maintain the security and stable operation of our products or services, such as identify, process the bugs of our products or services.
3.4.7 Anything that is necessary for legal news reports.
3.4.8 Anything that is necessary for academic institutions to conduct statistics or academic studies for the sake of public interest. They will de-identify the information contained in the results when they provide their study results or describe the results to others.
4.1 Information retention
4.1.1 We will retain your personal information as long as it is within the lower limit of the required time limit to fulfill the purposes stated in this Policy and related laws.
4.1.2 We will stop collecting your personal information and inform you in advance in accordance with the laws whenever we our services or operations is terminated. Your personal information would then be deleted or anonymized, if there is any other regulations by the law or supervision department is not included.
4.1.3 The collected personal information and data about you will be stored in the servers of APPGURU TECHNOLOGY PTE LTD and/or its associated companies. This information and data might be transferred to your country or region, or the location where such data is collected. It will be visited, stored and displayed where it is collected.
4.2 Information protection
4.2.1 Technical measures
We will adopt safety protection measures that can meet industry standards to avoid data damage or loss, including the establishment of reasonable system, safety technology to prevent unauthorized visit, usage, amendment of your personal information.
4.2.2 System measures
We have established a comprehensive security control system via non-disclosure agreement, monitor and audit mechanisms. Training courses about data security and privacy protection will be hold to enhance the awareness of our employees about security and its importance.
Only the employees and partners that must have access to this information would be allowed to do so. We thus set strict access permission and monitoring mechanism. At the same time, all the staff that might have access to your personal information is required to carry out their confidentiality obligations, if they fail to do so, they might be held accountable by the law, or their partnership with us might be terminated.
4.2.3 Special notice
Please note the internet is not recognized as a secure environment, nor is email or instant messenger confirmed as a fully encrypted medium of communication. Therefore, it is suggested to use complicated password and take care of your personal information. We will do our best to protect your personal information, but please note no security method is perfect because of the limits of technology and risk control. You should be aware that problems might happen out of our controllable range when you access interactive service system and networks.
4.3 Treatment to security incidents
According to the requirements of related laws and regulations, we will keep you informed whenever an information security incident occurs, including the basic information, possible consequences, the measures we have taken or about to take, suggestions for self-prevention and risk reduction, remedial measures, etc. At the same time, we will inform you of incident progress via email, letter, call, push notifications, etc. If it is difficult to inform each and every individual, we will post notifications in a rational and effective way. Meanwhile, we will voluntarily report incident state to the supervision department according to their requirements.
You should make sure all your submitted data are accurate. AppGuru will then do our best to maintain the accuracy and integrity of your personal information, and update it in time.
5.1 Visit, update and deletion of personal information.
5.1.1 You have the right to visit specific personal information we hold about you.
5.1.2 You have the right to require us update or amend your inaccurate personal information.
5.1.3 Change your scope of authority.
5.1.4 You have the right to require us delete your personal information.
5.2 You can choose whether or not to disclose information
Part of the information is necessary for the services, but you have the right to decide whether or not allow us to use most other information. You can change the scope of your authority or withdraw your authentication via information deletion or device function closing. For instance, in order to fulfill additional functions and services of APPGURU TECHNOLOGY PTE LTD, we might offer you interest-based products, advertising, invitation of market survey or customer satisfaction survey. You can opt out if you do not wish to receive such messages.
5.3 Contact & Inquiry
In order to keep the information safe, we may ask for identity authentication when you visit, amend, update, change and delete the above-mentioned information. If needed, you can contact our customer service via the official site of APPGURU TECHNOLOGY PTE LTD, and we will reply you within reasonable period of time.
Also, please note in accordance with technology limits, lawful or supervising requirements, we will refuse your requests if we suppose they are deceptive, inaccessible, or would cause invasion of privacy on rational basis.
5.4 Authentication withdrawal
According to the requirements of applicable laws or policies, you have the rights to withdraw your consent anytime when AppGuru Technology Pte Ltd is processing your data based on your prior consent. This withdrawal will not affect the legitimacy and validity of our processing heretofore, nor our processing your personal information based on other appropriate justifiability.
6.1 Data Subject Access Requests
You may ask us for a copy of the information we hold about you at any time, and request us to modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this unless permitted by law. If you request further copies of this information from us, we may charge you a reasonable administrative cost. Where we are legally permitted to do so, we may refuse your request. If we refuse your request, we will always tell you the reason for doing so.
6.2 Right to erasure
You have the right to request that we “erase” your personal data in certain circumstances. Normally, this right exists where:
6.2.1 The data are no longer necessary;
6.2.2 You have withdrawn your consent to us using your data, and there is no other valid reason for us to continue;
6.2.3 The data has been processed unlawfully;
6.2.4 It is necessary for the data to be erased in order for us to comply with our obligations under law;
6.2.5 You object to the processing and we are unable to demonstrate overriding legitimate grounds for our continued processing.
6.2.6 We would only be entitled to refuse to comply with your request for erasure in limited circumstances and we will always tell you our reason for doing so. When complying with a valid request for the erasure of data we will take all reasonably practicable steps to delete the relevant data.
6.3 Request for erasure of data
If you wish to exercise any of your data subject rights described above, please contact us by sending an email at firstname.lastname@example.org. We will respond to all requests in accordance with applicable laws.
In order to protect your privacy, we may take additional steps to verify your identity before fulfilling your request such as but not limited to:
1. Past purchase receipt
2. IGN (In-game Name)
3. Character ID
5. Questions regarding to activities made on our services
Once you have verified your identity, you may also designate an authorized agent to exercise your rights on your behalf by providing the agent’s contact information to our customer support staff, as required by applicable law.
We will protect minors’ personal information in accordance with applicable laws and regulations.
If you are a minor that is prescribed by the law of your country, you should read this Policy with your parent or guardian and make sure their consent is given in advance. if they do not agree, please stop using our service immediately and inform us in time.
If you are the parent or guardian of a minor, please reach us whenever you have any questions about the services we provided or the information the minor provided to us. If we find out that we have collected a minor’s information without verified prior consent of their parents or statutory guardian, we will delete related data as soon as possible.
APPGURU TECHNOLOGY PTE LTD might offer links to social media or other services provided by third parties (including websites and other service forms), including:
8.1 The “Share” button can share certain content to a third-party service provider, or you can login via a third-party service. In order to fulfill the above-mentioned functions, your information (including your logs) might be collected, cookies might be stored on your computer as well.
8.2 Links that connect a third-party service or websites are provided via advertisements or other forms of our services.
8.3 Other situations that would connect a third-party service. For instance, to fulfill the stated purposes of this Policy, we might connect a third-party SDK service and share some of your personal information to this service provider so as to provide better customer service and user experience to you.
8.4 Social media or other service providers of those kinds are operated by themselves and have their own Service Terms and Information Protection Notices (not this Policy), please read their terms carefully. This Policy is only applicable to the personal information collected by ourselves, not the services or information collectors from a third party. If you feel the social media platform or other services is risky, it is suggested to terminate your operations to protect your legal interests.
We will reply you within 15 working days upon receiving your questions or suggestions and after confirming your identity.