Last modified: 12 March 2019

SUMMARY

What information do we collect about you?

We collect various types of information when you set up your Game account and during your use of the Game, as set out in this privacy policy. If you choose to set up your Game profile using Facebook, we also collect information from your Facebook account. If you choose, you can provide certain other information to personalise the gaming experience and enable Game features.

How will we use the information about you?

We use your information to create your account, provide the Game to you, and provide any Game features that you enable. We also use your information for account verification, security purposes and to support and improve the Game.

Who do we share your information with?

We use third parties for support services, such as cloud services and support ticketing. We use these third parties services solely to process or store your information for the purposes described in this privacy policy. We require the third parties (selected by us) with whom we share user data to provide the same or equal protection of user data as stated in this privacy policy. We also share your information with our related group companies and as required by law.

Where do we process your information?

Our servers are located in Hong Kong, the People’s Republic of China (excluding Taiwan, Hong Kong and Macau) and the United States. Our support, engineering and other teams are located in our offices around the world (including the United States and Hong Kong).

How long do we keep hold of your information?

We retain your information for the duration for which you hold your Game account and then, depending on the type of data, delete such data in accordance with the retention policy set out in this privacy policy.

How can I exercise my rights over my information?

You may have rights to access, receive a copy of, delete, or correct, your data or restrict or object to our processing of your data.

Dispute Resolution

If you have any concerns or complaints, please contact us here

How will we notify you of changes?

If there are any significant changes to this privacy policy, we will post a notification of such change in the Game.

Contact Information

Data Controller – Game App: Proxima Beta Pte. Limited. Email: hpludosuperstar@gmail.com

Data Controller – Facebook Instant Game: High Morale Developments Limited. Email: hpludosuperstar@gmail.com.

EU Representative (for both): Tencent International Service Europe B.V. Email: eudataprotection@tencent.com

INTRODUCTION

This privacy policy informs you of our practices and the choices you have regarding any personal information you provide to us. Your use of the LUDO SUPERSTAR app (“Game App”) or the LUDO SUPERSTAR Facebook Instant game (“Facebook Instant Game”, and together with the Game App, the “Game”) involves the collection and use of your personal information. It is important for you to understand how this happens and how you may control it.

When you use the Game, you accept our rules and policies regarding your personal information and you expressly consent to us collecting, processing, using and storing your personal information, as described in this privacy policy.

You acknowledge that you have read and understood this privacy policy. If you do not agree with this privacy policy, you must not use the Game.

In relation to the Game App, Proxima Beta Pte. Limited is a company registered in Singapore with its office located at 10 Anson Road #21-07 International Plaza, Singapore. In relation to the Facebook Instant Game, High Morale Developments Limited is a company registered in Hong Kong with its office located at 29 Floor, Three Pacific Place, 1 Queen’s Road East Wanchai, Hong Kong. Proxima Beta Pte. Limited and High Morale Developments Limited are together referred to as “we” or “us” in this Privacy Policy. Our representative in the EU for the purpose of EU data protection laws is Tencent International Service Europe B.V., a company registered in the Netherlands. Their registered address is 26.04 on the 26th floor of Amstelplein 54, 1096 BC Amsterdam, the Netherlands and can be contacted at eudataprotection@tencent.com. In relation to the Game App, the data controller for the purpose of EU data protection laws is Proxima Beta Pte. Limited. In relation to the Facebook Instant Game, the data controller for the purpose of EU data protection laws is High Morale Developments Limited.

If you have any comments, questions or complaints regarding the processing of your personal information, you can contact us at hpludosuperstar@gmail.com.

The Types of Personal Information We Use

This section describes the different types of personal information we collect and how we collect it. We will collect and use the following information about you:

• ●Information you give us.You give us information about you when you register for the Game (your player ID, nominated nickname, profile picture and age) or using your Facebook log in (your player ID, Facebook nickname, Facebook profile picture and age), in each case in order to set up your Game profile.
• ●Information we collect about you.We automatically collect certain data from you when you use the Game, namely your IP address and device information (such as model, application version, battery level, WiFi strength, available space, network type, OS version, screen resolution, platform, carrier, country code, series ID, device root status, Android ID, MAC and IDFV) and log data regarding your use of the Game. We also collect and store your data:
  • if you log in to the Facebook Instant Game using Facebook and you choose to link your Game account with your Facebook friends list, we import your user ID, Facebook nickname, Facebook profile picture and the user ID, name, nickname, profile picture, game behaviour data of your Facebook friends so that you can connect with them;
  • if you enable chat services, then we will process your player ID and nickname and the chat content (text) in order to deliver your messages to other users;
  • if you conduct any transactions in the Game App, we collect information to facilitate your transaction and to maintain transaction records (Open ID, cost, product purchased, IP address, details of transactions linked to your player ID, and device details); and
  • if you contact our support team or provide feedback, we collect your device details (such as your operating system and screen resolution), player ID, email address and any information that you provide in your communications in order to provide troubleshooting.
• ●Information you generate and display in the course of using the Game.We use your information to store your Game data, including your avatar, and we collect and store your Game play statistics in order to provide you with feedback and information about your Game play and progress. We also collect your Game log data (in the Game App this includes crash data) in order to facilitate your Game play and to improve our services.

Cookies

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Game. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.

You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies, or instruct the device to provide notice at the time of installation of cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event of your refusal to install cookies, the Game may be unable to operate as designed.

For more information about our Cookies policy. For the Facebook Instant Game, please click here. For the Game app, please click here.

Children

The Game is not intended for children. Children must not use either format of the Game for any purpose. By children, we mean users under the age of 13 years old; or in the case of users located in a country listed in the table below, the relevant age listed for that country. If you believe that we have collected information from a child under the age of 13 years old, please contact us and we will delete the information.

Country in which the user is located	Minimum age of the user
Brazil	18
European Economic Area/Switzerland	16 (subject to the below), or between 13 and 15 with the consent of the relevant parent or guardian
Russia	14
Turkey	18

In the case of users located in the European Economic Area and Switzerland, persons under the age of 16 may use the Game if parental/guardian consent is obtained prior to using the Game.

How We Use Your Personal Information

We will use the information in the following ways and in accordance with the following legal bases:

Personal Information	Use	Legal Basis for Processing (EU
Log in information: guest log in: player ID, nominated nickname, profile picture and age; or Facebook log in: player ID, Facebook nickname, Facebook profile picture and age	We use this information to set up your Game profile in accordance with your request.	Necessary to perform our contract with you to provide the Game.
IP address	We use this information to allow you to connect to the Game server.	Necessary to perform our contract with you to provide the Game.
Device information: model, application version, battery level, WiFi strength, available space, network type, OS version, screen resolution, platform, carrier, country code, series ID, device root status, Android ID, MAC and IDFV	We use this information: to improve our services, including the functionality of the Game; and to prevent users from registering for multiple accounts.	Necessary to perform our contract with you to provide the Game.
Advertising ID	If you click on a link that advertises the Game, we store the advertising ID for that advertisement with your profile.	It is in our legitimate interests to use this information to monitor the success of our advertising and marketing programs.
Game log data; in the Game App this includes crash data, game behaviour data such as game running status record.	We use this information to facilitate your Game play, for you to report problems to us and to improve our services, including the functionality of the Game.	Necessary to perform our contract with you to provide the Game.
Facebook friends information, if you log in to the Facebook Instant Game using Facebook and you choose to link your Game account with your Facebook friends list: user ID, name, nickname, profile picture of your Facebook friends	If this feature is enabled, we import this information so that you can connect with your Facebook friends.	Necessary to perform our contract with you to connect you with your friends and to allow you to interact with them in-Game.
Chat data, if you enable chat services: player ID and nickname, chat content (text)	If this feature is enabled, we process this information to deliver your messages to other users.	Necessary to perform our contract with you to provide the chat services in-Game.
Transaction information, if you conduct any transactions in the Game App: open ID, cost, product purchased, IP address, details of transactions linked to your player ID, and device details	We use this information to facilitate your transaction and maintain a record of your transaction history.	Necessary to perform our contract with you to facilitate your in-Game transactions. It is in our legitimate interest to maintain, and provide you with, details of your transaction history.
Support and feedback data: if you contact our support team: email address and any information that you provide in your communications; if you provide feedback: device details, player ID and any information that you provide in your communications	We use this information to provide troubleshooting, such as addressing and remediating technical issues and bugs, and to receive your feedback.	Necessary to perform our contract with you to provide and support the Game.
Game data: your avatar and Game play statistics (including level, score/s)	We use this information to provide you with feedback and information about your Game play and progress.	Necessary to perform our contract with you to provide the Game.

How We Store and Share Your Personal Information

In order to perform our contract with you, your personal information will be accessible from and will be processed on our servers (depending upon your location and the game server you select). Our servers are located in:

• ●Hong Kong;
• ●the People’s Republic of China (“PRC”) (excluding Taiwan, Hong Kong and Macau); and
• ●the United States.

Please note that when your personal information is transferred outside your jurisdiction of residence, it will be subject to the laws of the country in which it is situated.

To the extent permitted by applicable law, we share your personal information with selected third parties in and outside your country only to the extent allowed by applicable law, including:

• ●third parties that provide services in support of the Game,including providers of cloud services;
• ●related group companieswith whom we share your personal information to operate the Game;
• ● law enforcement agencies, public authorities or other judicial bodies and organisations. We disclose information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
  • comply with a legal obligation, process or request;
  • enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof;
  • detect, prevent or otherwise address security, fraud or technical issues; or
  • protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection); and
• ●a third party that acquires all or substantially all of us or our business. We will disclose information to a third party in the event that we sell or buy any business or undergo a merger, in which case we will disclose your data to the prospective buyer of such business. We will also disclose information to a third party if we sell, buy, merge or partner with other companies or businesses, undergo a reorganisation, bankruptcy, or liquidation; or otherwise undertake a business transaction or sell some or all of our assets. In such transactions, user information may be among the transferred assets.

We require the third parties (selected by us) with whom we share user data to provide the same or equal protection of user data as stated in this privacy policy.

Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. Our group companies have information security and access policies that limit access to our systems and technology. We also protect data through the use of technological protection measures such as encryption. Your personal information will remain subject to our technical and organisational controls and our policies and procedures (including this privacy policy).

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the information transmitted to our services; any transmission of your information is at your own risk.

Data Retention

We will retain your personal information as described below (except if otherwise required to be retained by applicable law).

Personal Information	Retention Policy
Log in information: guest log in: player ID, nominated nickname, profile picture and age; or Facebook log in: player ID, Facebook nickname, Facebook profile picture and age	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 7 working days or as otherwise required by law. Where you do not request for account deletion, such data will be retained for 2 years after the Game has ceased to operate, before it is deleted.
IP address	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 7 working days or as otherwise required by law. Where you do not request for account deletion, such data will be retained for 2 years after the Game has ceased to operate, before it is deleted.
Device information: model, application version, battery level, WiFi strength, available space, network type, OS version, screen resolution, platform, carrier, country code, series ID, device root status, Android ID, MAC and IDFV	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 7 working days or as otherwise required by law. Where you do not request for account deletion, such data will be retained for 2 years after the Game has ceased to operate, before it is deleted.
Advertising ID	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 7 working days or as otherwise required by law. Where you do not request for account deletion, such data will be retained for 2 years after the Game has ceased to operate, before it is deleted.
Game log data; in the Game App this includes crash data	Game log data will be stored for 90 working days before it is deleted.
Facebook friends information, if you log in to the Facebook Instant Game using Facebook and you choose to link your Game account with your Facebook friends list: user ID, name, nickname and profile picture of your Facebook friends	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 7 working days or as otherwise required by law. Where you do not request for account deletion, such data will be retained for 2 years after the Game has ceased to operate, before it is deleted.
Chat data, if you enable chat services: player ID and nickname, chat content (text)	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 7 working days or as otherwise required by law. Where you do not request for account deletion, such data will be retained for 2 years after the Game has ceased to operate, before it is deleted.
Transaction information, if you conduct any transactions in the Game App: open ID, cost, product purchased, IP address, details of transactions linked to your player ID, and device details	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 7 working days or as otherwise required by law. Where you do not request for account deletion, such data will be retained for 2 years after the Game has ceased to operate, before it is deleted.
Support and feedback data: if you contact our support team: email address and any information that you provide in your communications; if you provide feedback: device details, player ID and any information that you provide in your communications	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 7 working days or as otherwise required by law. Where you do not request for account deletion, such data will be retained for 2 years after the Game has ceased to operate, before it is deleted.
Game data: your avatar and Game play statistics (including level, score/s)	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 7 working days or as otherwise required by law. Where you do not request for account deletion, such data will be retained for 2 years after the Game has ceased to operate, before it is deleted.

Personal Information is kept until the end of its life cycle (as set out in the retention policy above). When destroying personal information, measures will be taken to make the personal information irrecoverable or irreproducible, and electronic files which contain personal information will be deleted permanently using a technical method which makes the files irreproducible.

In the event that the processing and retention period have terminated, but personal information is required to be retained continuously for other reasons including for the purposes as prescribed under applicable laws, the relevant personal information will be stored and maintained separately from other types of personal information. If you require us to destroy your personal information before the end of its life cycle (as set out in the retention policy above), we will destroy your personal information in accordance with local laws.

Your Rights

This section (“Your Rights”) applies to users that are located in the European Economic Area only.

The sections titled “Access”, “Correction”, and “Erasure” also apply to users that are located in Brazil, Canada, India and Russia.

You have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please email us at hpludosuperstar@gmail.com.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your Game account and by contacting hpludosuperstar@gmail.com. If you believe we hold any other personal information about you, please email us at hpludosuperstar@gmail.com.

Portability

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent or pursuant to our contract with you, as described in the section “How We Use Your Personal Information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party.

If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (e.g., where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

Correction

You have the right to correct any personal information held about you that is inaccurate. You can access the personal information you have made available as part of your account by logging into your Game account. If you believe we hold any other personal information about you and that information is inaccurate, please email us at dpo@proximabeta.com or at hpludosuperstar@gmail.com.

Erasure

You can delete your account, or remove certain personal information, by logging into your Game account. If there is any other personal information you believe we process that you would like us to erase, please email us at hpludosuperstar@gmail.com.

You may request that we erase the personal information we hold about you in the following circumstances:

• ●you believe that it is no longer necessary for us to hold such personal information; or
• ●you believe the personal information we hold about you is being unlawfully processed by us.

You can also exercise your right to restrict our processing of your personal information (as described below) whilst we consider your request.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (e.g., for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Game and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (e.g., for the defence of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

You may request we stop processing and just store the personal information we hold about you where:

• ●you believe the personal information is not accurate for the period it takes for us to verify whether it is accurate;
• ●you wish to erase the personal information as the processing we are doing is unlawful but you want us to retain the personal information but just store it instead; or
• ●you wish to erase the personal information as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims.

Objection

You have the right to object to our processing of personal information about you. We will consider your request in other circumstances as detailed below by emailing us at hpludosuperstar@gmail.com.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (such as when we temporarily suspend Game access for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.

Contact & Complaints

Questions, comments and requests regarding this privacy policy, including our policies and practices related to the use of service providers outside your jurisdiction of residence, are welcomed and should be addressed to hpludosuperstar@gmail.com.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at hpludosuperstar@gmail.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws.

Changes

If we make any material changes to this privacy policy, we will post the updated privacy policy here and notify our users within the Game. Please check this page frequently to see any updates or changes to this privacy policy.

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

If you are a user located in one the following countries, the terms set out below that apply in your country apply to you.

Brazil

In order to use the Game, you represent that you are at least 18 years old and, therefore, legally capable of entering into binding contracts.

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORIZE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL DATA, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

Japan

You may request us to notify purposes of use of, to disclose, to make any correction to, to discontinue the use or provision of, and/or to delete any and all of your personal information which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contact us at hpludosuperstar@gmail.com.

Republic of Korea

How We Store and Share Your Personal Information

Delegation of Processing

For the performance of Services, we delegate the processing of your personal information to the following professional service providers:

Delegatee	Descriptions of Delegated Services
Tencent America LLC	Internal data and infrastructure services.
TOriental Power Holdings Limited
Shenzhen Tencent Computer Systems Company Limited

Your Rights

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, etc. pursuant to applicable laws such as the Act on Promotion of Utilization of Information and Communications Network (the “Network Act”).

You may also exercise these rights through your legal guardian or someone who has been authorized by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Enforcement Regulations of the Network Act.

Upon your request, we will take necessary measures without delay in accordance with applicable laws such as the Network Act.

You can also withdraw you consent or demand a suspension of the personal information processing at any time.

Contact

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

In relation to both the Game App and the Facebook Instant Game:

• ●Data Protection Officer, responsible for the management and safety of your personal information
• ●+86 0755 8376 5566
• ●hpludosuperstar@gmail.com

Russia

If you are using the Game in Russia, you consent(for the purposes of the Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (as amended) or any replacement regulations) to the processing of your information in accordance with this privacy policy. You also consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to Hong Kong, the United States and the People’s Republic of China (excluding Taiwan, Hong Kong and Macau).

The Data Controller, Proxima Beta Pte Limited (in relation to the Game App) and High Morale Developments Limited (in relation to the Facebook Instant Game), is the Person Responsible for Data Processing. To exercise any applicable rights, please email: hpludosuperstar@gmail.com.