Overseas Privacy Policy
Last Updated:11 March 2026
"We" or the "Company" as referred to in this "Privacy Policy" refers to the provider that provides you with the online game and the platform game services, namely ZEN WORLD INTERACTIVE LIMITED and its partners, parent companies, subsidiaries, licensees, licensors, and affiliated entities. For users in the European Economic Area ("EEA") and the United Kingdom ("UK"), the data controller for the processing described in this Privacy Policy is the entity identified in Section 11, and, where required by applicable law, its appointed EU or UK representative.
Our company respects the privacy of its on-line visitors/users and recognize the importance of providing a secure environment for them. We have adopted an appropriate "Privacy Policy" (also referred to as this "Agreement") that explains how we collect, store, and use the information you provide us. The Privacy Policy applies to this website, applications, and the Game Services. Please note that when you click a link to other sites from our website and/or any of online products or services( “ the Game ” ), this Privacy Policy does not apply to, and cannot control the activities on, those other sites. We highly recommend that you read the privacy policy of any third party website and/or any of online products or servicesyou may be directed to before providing any personally identifiable information.
If you do not agree to this Privacy Policy, please do not use the Game. By accessing and using our website, applications, or by clicking the "Agree", "Accept", or "Next" buttons, or by registering to use the Game, you are deemed to have read and agreed to this Privacy Policy.This Privacy Policy may change from time to time, so please check back periodically to ensure that you are aware of any changes. If we make a material change to this Privacy Policy, we will notify you via an update announcement. Your continued use of the Game will be deemed as acceptance of such changes.
1. What personal information is collected and how we use it?
If you register an account to use the Game then we will need some information from you to set this up. If you choose to set up your Game profile using a social media account, we also collect information from that social media account. If you choose, you can provide certain other information to personalise the gaming experience and enable Game features, or participate in Game Services. If you need to get in touch with us then we will also retain some information so that we can get back in touch with you and address any concerns. The exact categories of personal information we collect depend on the features you use, the permissions you grant, the device and operating system you use, and the channel through which you access the Game (for example, app store, platform account, website, customer support channel, or community feature). Not every category listed below will apply to every user.
1.1 Information you provide to us (either directly or through a third party)may include some or all of the following information:
· Nickname and Name
We use this information to create your account for the Game in accordance with your request and to display your profile and account identity within the Game and related services.
Necessary to perform our contract with you to provide the Game.
· If you register an account using your Facebook/Google Play account: Name, Facebook/Google Play ID, Profile Picture, Email Address (optional) and other basic account information the relevant platform makes available to us in accordance with your privacy settings and authorization choices.
We use this information to create your account for the Game in accordance with your request and to enable sign-in, account binding, friend discovery, profile display, and account recovery where applicable.
Necessary to perform our contract with you to provide the Game. Where applicable, it is also in our legitimate interests to maintain the security and integrity of account registration and sign-in processes.
· Gender (if you elect to provide this information)
We only receive this information if you voluntarily provide it. It is used in order to customise gameplay or profile presentation where such feature is available.
Necessary to perform our contract with you to provide the Game with customised gender-specific features. Where this information is optional and not required to provide the core Game, we process it based on your request to use that feature and, where required by law, your consent.
· Region Location (manually selected by you)
We use this information to:(1) set up your gameplay on a regional server;(2)improve gameplay, language selection, regional matchmaking, event availability, and customer support handling where relevant.
Necessary to perform our contract with you to provide the requested online products or services and to route your account to the correct regional environment.
· Friends List (Facebook, Google Play)
If you choose to log-in using Facebook, Google Play ,Google Play, or another supported third-party platform account, we import the name of the friends from your social media profile so that you can connect with your friends inside the Game, subject to the permissions and settings you choose on that platform.
Necessary to perform our contract with you if you request that we connect you with your friends.
· Friends List (manually added by you or imported from your device contacts or address book, if you choose to use such feature and grant the relevant permission)
If you choose to add a user as a friend, we will store that information so that you can connect with that user. If you choose to grant access to your device contacts or address book, we will use that information only to help you identify and add contacts or friends who may already use the Game or who may be invited by you through a supported feature. We do not require device contacts for you to use the core Game. If you choose to provide GPS information, we will use it to allow you to connect with users nearby your location, or to provide location-related features that you actively request, but your GPS information is not shared with other users.
Necessary to perform our contract with you if you request that we connect you with your friends. Where we access device contacts or precise location information, we do so with your permission and, where required by applicable law, your consent.
Some of our websites and/or any online services require you to create an account with a third party service provider. The username and email address that you create through this platform are collected by the third party service provider and are subject to their privacy policy. Where you choose to use such third-party services to access or interact with the Game, we receive only the information reasonably necessary to authenticate you, provide the requested feature, and maintain the linked account relationship. In these types of instances, we strongly encourage you to also review the privacy practices of the third party prior to divulging any personal information.
Visitors purchasing products or services will be required to provide additional information such as payment-related information, transaction identifiers, order details, refund information, and, where purchases are made outside an app store or through a web channel, billing/contact details necessary to complete the transaction, comply with accounting and tax obligations, prevent fraud, and provide customer support. Depending on the purchase channel, payment card information may be collected and processed directly by the relevant payment processor rather than by us.
Please note that, depending on our website and/or any of online products or services that you are visiting, many of the activities listed above may not be available and, as such, personal information may not be collected may be collected only where the relevant feature is actually offered and used.
1.2 Information generated as part of the online products or services and how we use it:
· Real ID, User ID, Open ID, platform identifier, account identifier, or other internal identifier
We use this information to store your Game data (including level and progress) with your profile.
Necessary to perform our contract with you to provide the Game.
· Game Play Statistics (Level ,Score/s) and date
We use this information to provide you with feedback and information about your gameplay and progress, to operate core gameplay functions, rankings, achievements, mission progress, balancing, support handling, and feature optimization.
Necessary to perform our contract with you to provide the Game. It is also in our legitimate interests to improve game balance, troubleshoot issues, and maintain a stable player experience.
· IP Address
We use this information to allow you to connect to the Game server, secure the service, determine the approximate region from which the service is accessed, prevent abuse, investigate suspicious activity, and maintain logs necessary for troubleshooting and legal compliance.
Necessary to perform our contract with you to provide the Game. It is also in our legitimate interests to protect our services, users, and business operations against fraud, abuse, and security threats.
· Device ID and Device Information (depending on your device, operating system, app environment, SDK integrations, and permissions granted: for example device model, operating system and version, language, time zone, application version, network type, device identifiers made available by the operating system or platform, push token, crash data, performance data, and security signals; where technically available and lawfully collected, certain hardware, software, or network-related identifiers may also be processed for fraud prevention, anti-cheat, or compatibility purposes. Android: Device ID (IMEI), Series ID, Android ID, MAC address, device host, device hardware, RadioVersion, Google advertising ID; iOS: IDFV, Model, OS Version, Network, WiFI, MAC.)
We use this information:(1)to improve our services, including the functionality of the Game;(2)for security and verification purposes;(3)identify and address bugs and assess game function for optimisation; (4) manage updates and compatibility; and (5) support analytics and attribution activities described in this Privacy Policy.
It is in our legitimate interest to ensure the security of our services, manage registrations and improve our services. Where device-level permissions or identifiers require consent under applicable law, we will rely on your consent.
· GPS or other precise geolocation data, where you enable location-based features or grant location permissions
We use this information to allow you to connect with users nearby your location. Your GPS information is not shared with other users unless the relevant feature expressly requires such disclosure to function and you choose to use that feature. We do not require precise location information for you to play the core Game.
We use this information with your consent or other permission standard required by applicable law. You can disable location access through your device settings at any time, but some location-based functions may then no longer be available.
· Advertising ID and marketing analytics data (e.g. device ID, engagement data and search terms)
If you click on a link or interact with content that advertises the Game, we store the Advertising ID for that advertisement and certain marketing analytics data with your profile or other internal records.
It is in our legitimate interests to use this information to monitor the success of our advertising and marketing programs. Where required by applicable law, including in the EEA and UK for non-essential cookies or similar technologies and related advertising or analytics processing, we will obtain your consent before using such technologies or processing. Some disclosures to advertising or analytics partners may be considered a "sale," "sharing," or "targeted advertising" under certain U.S. state privacy laws; where applicable, you may opt out as described in Section 4.
· Log Data (purchasing actions, game results (e.g., win or lose), in-game performance)
We use this information to:(1)maintain a record of log-in and actions of your account;
(2)improve our services, including the functionality of the Game ;(3)for security and verification purposes; (4) investigate bugs, crashes, cheating, abuse, payment disputes, customer complaints, and refund requests; and (5) enforce our rules and protect the rights, safety, and property of users, us, and third parties.
Necessary to perform our contract with you to provide the Game and retain your record of progress. It is also in our legitimate interests and, where applicable, necessary to comply with legal obligations.
· Text Chat Data: Free Chat (users can communicate using their own, custom messages) and Quick Chat (users can communicate using only pre-determined messages set in a drop down menu in the Game), , as well as guild/community messages, friend messages, room messages, reports associated with such messages, and related metadata such as sender, recipient, channel, date/time, and moderation status.
We facilitate the posting of your communications with other users, the operation of social and community features, content moderation, safety review, abuse prevention, handling of reports and disputes, and compliance with applicable law.
Necessary to perform our contract with you to provide the Game where you seek to use chat services. It is also in our legitimate interests to maintain community safety, investigate misconduct, and enforce our rules.
· Transaction Records: payments on Apple Play or Google Play(Real ID, cost, product purchased, IP address, device details, email address (if web-based transaction)), or other supported purchase channels (Real ID or other internal account identifier, cost, product purchased, IP address, device details, email address (if web-based transaction), payment status, order number, refund and chargeback information, and related customer support records).
We use this information to maintain a record of your transaction history, provide purchased items or services, restore purchases where supported, administer refunds, detect fraud, handle disputes and chargebacks, maintain tax and accounting records, and comply with legal obligations.
Necessary to perform our contract with you to provide the Game, information about your in-game purchase history and to restore purchases of in-game items. We may also process this information to comply with legal obligations and for our legitimate interests in protecting our business and users against fraud and abuse.
· Security-Related Information: list of hack or cheating software, device operation system settings, device information including mobile phone brand, model, CPU structure, CPU model, kernel version, resolution, root/jailbreak status, emulator or virtual environment indicators, suspicious process information, memory or environment checks, integrity signals, abnormal operation data, bot indicators, network anomalies, and other signals reasonably necessary to detect cheating, fraud, abuse, or security risks.
We use this information:(1)To provide a fair Game environment;(2) To solve game crash and optimize compatibility; (3) to investigate, prevent, and respond to fraud, cheating, harassment, unlawful activity, and security incidents; and (4) where necessary, to support moderation or enforcement actions such as warnings, restrictions, suspensions, bans, or appeals review. We may use automated tools to flag suspicious behavior, but where required by applicable law we will provide additional safeguards, including information about relevant rights and the ability to request review, depending on the circumstances.
It is in our legitimate interests to use this information to protect the integrity of Game and improve its operation.
· Survey Information (In-Game Surveys): Real ID, IP address, age (optional), email address (optional), mobile number (optional), name (optional), address (optional), profession (optional), other information that you provide in your response to the survey.
If you agree to participate in a survey run by us, we use this information to improve our services, understand user preferences, support internal analytics, and, where stated at the point of collection, for additional specific purposes described in the survey notice.
We collect this information with your consent.
1.3 Information you generate and display in the course of using the Services and how we use it:
You may provide additional information as part of your profile (such as gender). You may also provide or generate information when you communicate with other users in the Game (e.g., chat content and log data). We also generate an Real ID and use this to store your Game data, and we collect and store your Game play statistics (e.g. level, scores) in order to provide you with feedback and information about your Game play and progress.Lastly, we may use your personal information for internal marketing, profiling, or demographic purposes, so we can adapt our products and services to better suit your needs. We do this to better understand and serve our customers.
Please be advised that personal information submitted by individuals acting solely in a business capacity (e.g., personal information contained in job applicant's resume) is not subject to the uses set forth above or to any other practices stated in this Privacy Policy.
2. What type of communications may you receive?
· Special Offers and Updates
We will occasionally send you information on products, services, special deals, and promotions. Out of respect for your privacy, we present the option not to receive these types of communications. Where required by applicable law, we will send such marketing communications only with your prior consent. You may opt out at any time by using the unsubscribe function in the communication, changing your in-app or account settings where available, or contacting us using the details in Section 11.
· Service-related Announcements
We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email. Generally, you may not opt-out of these communications, which are not promotional in nature.
· Customer Service
Based upon the personally identifiable information you provide us, we will send you a welcoming email to verify your username and password. We will also communicate with you in response to your inquiries, to provide the services you request, and to manage your account. We will communicate with you by email or telephone, in accordance with your wishes.
· Recruit a Friend/E-cards/Share Wish List
If you choose to use our recruit-a-friend, Share Wish List, or e-card features, we will ask you for your friend ’ s name and email address. We will automatically send your friend a one-time email inviting him or her to visit the website and/or any of online products or services. we does not store this information and uses it for the sole purpose of sending this one-time email and to track the success of our referral program.
3. How we share your personal information?
· Only where necessary will we share your personal information with third parties. Situations where this occur are.
Third parties that provide services in support of the Game Services, including providers of cloud services that process information identified in this policy on their servers for the purpose of providing the Game Services, for the purpose of processing support communication, for the purpose of processing gameplay and game rendering data to provide game analytics to improve game play, and for the purpose of providing marketing and advertisements and monitor the success of our marketing and advertising programs. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.These parties act on our behalf or under their own privacy terms depending on the service and relationship. Where they process personal information for us as our service providers or processors, we require them by contract to process such information only on documented instructions, to implement appropriate security and confidentiality measures, and not to use the information for incompatible purposes.
When you are asked for information while on our game, you are sharing that information with us, our parent, and our various affiliates and sister companies, unless specifically stated otherwise. All related group companies may only use your personal information in accordance with this privacy policy.
A third party that acquires all or substantially all of us or our business. If we sell or buy any business, undergo a merger, enter into a partnership, or sell some or all of our assets we may disclose your information to the extent reasonably necessary to evaluate, complete, or implement the transaction, subject to confidentiality obligations and, where required by law, notice to you.
We reserve the right to disclose your personal information as required by law or in special cases when we have reason to believe that disclosing such information is necessary to identify, contact, or bring legal action against you if you are violating the Terms of Service or Use Agreements for our website or product, or may be causing injury to or interference (intentionally or unintentionally) with our rights or property, other users of our website or product, or anyone else who could be harmed by your activities. We may also disclose your information to courts, regulators, law enforcement authorities, administrative authorities, or other authorized third parties where we reasonably believe disclosure is required by applicable law, regulation, legal process, governmental request, or to establish, exercise, or defend legal claims.
Please be aware that we cannot control the activities of third parties to whom we provide data, and while we cannot guarantee that they adhere to the same privacy and security procedures as we do, we will take reasonable steps to assure that these third parties will provide sufficient protection of personal information.
Please be aware that advertisers or website and/or any of online products or services with links to and from our game may collect personal information about you. And remember, this Privacy Policy does not apply to, and cannot control the activities of, those other advertisers or website and/or any of online products or services. We encourage you to carefully read the privacy policy of any advertiser or website and/or any of online products or services you visit. If you choose to leave our services, click third-party links, participate in third-party offers, or connect your account with a third-party service, any personal information you provide directly to that third party will be governed by that third party’s own privacy notice and practices.
Our game may include certain social media features such as the Facebook "Like" button, and widgets such as the Share this button or interactive mini-programs that run on the Game . These features may collect your Internet Protocol ( “ IP ” ) address, which page you are visiting on our game , and may set a cookie to enable the feature to function properly. If you use such features, the relevant third-party provider may also receive information about your interaction with the feature in accordance with its own privacy notice.
Our website and/or any of games or services may also have message boards, forums, and/or chat areas, where users can exchange ideas and communicate with one another. When posting to a message board, forum, or chat area, please be aware that the information is being made publicly available on-line and the user does so at his or her own risk. For certain forums, anyone posting or replying to a post may be doing so using their Real ID -- that is, their full first and last name -- with the option to also display the name of their primary in-game character (see discussion regarding Real ID below). If your personal information is posted on one of our community forums, you may contact us at [ zenworld21@126.com ] . to request removal. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
Your personal information may be transferred to, stored in, or accessed from countries or regions other than the one in which you reside, including locations where our affiliates, service providers, platform partners, or systems are located. Where required by applicable law, we will take appropriate measures to ensure that such cross-border transfers are subject to adequate safeguards, which may include adequacy decisions, standard contractual clauses, the UK International Data Transfer Addendum or International Data Transfer Agreement, or other lawful transfer mechanisms.
4. What choices do you have regarding the collection, use, and distribution of your personal information?
We allows you to control the way that we use personally identifying information that we might obtain. At the time you provide personal information, we may give you the option of declining any future offers or information about new products, promotions, or services. In addition, many of the "mailings" we may send you, such as newsletters, have procedures within them to cancel the receipt of any future mailings. Lastly, you may be given the opportunity to "opt-out" of certain features or functionality (e.g. Real ID). See the applicable feature's FAQ or information page for more details.
Where applicable under the laws of the EEA and UK, you may have the right to request access to personal information we hold about you, request rectification of inaccurate personal information, request erasure, request restriction of processing, object to certain processing (including processing based on legitimate interests and direct marketing), request data portability, withdraw consent where processing is based on consent, and request not to be subject to certain decisions based solely on automated processing where the law so provides.
Where applicable under certain U.S. state privacy laws, including California law, you may have rights to know/access certain personal information we have collected about you, request deletion, request correction of inaccurate information, opt out of certain processing that may constitute sale, sharing, targeted advertising, or profiling as defined by applicable law, and, where applicable, limit certain uses or disclosures of sensitive personal information. We will not unlawfully discriminate against you for exercising applicable privacy rights.
Where required by applicable U.S. law, we may recognize opt-out preference signals, such as Global Privacy Control, with respect to relevant browser- or device-based requests, to the extent technically supported and legally required.
To exercise applicable privacy rights, you or, where permitted by law, your authorized agent, may contact us using the details in Section 11. We may take reasonable steps to verify your identity and authority before acting on your request, and we may decline or limit a request to the extent permitted by applicable law.
Your browser may allow you to set a Do Not Track (DNT) signal indicating that you do not wish your online activity to be tracked. Because there is not yet a universally accepted standard for how to respond to DNT signals, our systems may not respond to all such signals. However, where required by applicable law, we will process legally recognized browser-based opt-out preference signals as described above.
5. What about Children?
By children, we mean users under the age of 13 years old.We do not knowingly collect or store any personally identifiable information from children under 13.
If we become aware that we have collected personal information from a child under 13, or from a user below another age threshold where parental or guardian authorization is required by applicable law, we will take appropriate steps to delete or otherwise handle such information in accordance with applicable law, which may include disabling the relevant account or restricting access to the service.
If parents believe that we have unintentionally collected their children ’ s personal information, they may request the deletion of the information by contacting us at [ zenworld21@126.com ] .
6. What is Real ID?
Real ID friends can see each other ’ s real-life name and can see each other ’ s characters across all our game. By participating in Real ID, you will have the option of making your real name visible to your friend ’ s friends, who will also be able to invite you to become friends. Where the Game offers an optional "Real ID" or similar real-name or cross-profile social feature, participation in that feature is entirely voluntary. Such feature may allow mutually connected users to view certain profile identity information, friend status, or cross-game/account presence information, depending on the feature design.
When you and a friend mutually agree to become Real ID friends, you will have access to a number of additional features, including the following:
Display of profile identity information for matched friends, cross-game or cross-service presence, communication features, and related social functionality, where available.
Real Names for Friends: Your Real ID friends will appear under their real-life names on your friends list, when chatting, communicating in-game, or viewing a character's profile. You should use this feature only if you are comfortable sharing such information with that specific person. We may retain certain related records as necessary for service operation, dispute handling, safety review, and legal compliance.
7. What are tracking technologies and how are they used?
As is true with most website and/or any ofthe Game, we gather certain information automatically and store it in log files. This information may include a unique identifier such as your Internet Protocol (IP) address and non-personal information such as your browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. Depending on the service and platform, we may use cookies, SDKs, pixels, tags, local storage, scripts, software development kits, and other similar storage or access technologies.
We and our partners, such as marketing partners and analytics providers (listed here), may use tracking technologies such as cookies, beacons, tags and scripts. These technologies are used in analyzing trends, administering the website and/or any of online products or services, tracking users ’ movements around the website and/or any of online products or services, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.
We use cookies for various purposes including our shopping cart, to remember users ’ settings (e.g. language preference), and for authentication. Users can control the use of cookies at the individual browser level. If you reject or disable cookies or similar technologies, some features or functionality of the services may be unavailable, reduced, or not function as intended.
We may also use clear gifs in our HTML-based emails to let us know which e-mails have been opened by recipients. This allows us to gauge the effectiveness of certain communications and the effectiveness of our marketing campaigns where such processing is permitted and, where required, consent has been obtained.
We, and third parties with whom we partner to provide certain features on our website and/or any of online products or services or to display advertising based on your web browsing activity, use Local Shared Objects such as Flash cookies, and Local Storage such as HTML5, to store content information and preferences. Various browsers may offer their own management tools for removing HTML5.
We partner with third party ad networks to either display advertising on our website and/or any of the Game or to manage our advertising on other sites. Our ad network partners may use tracking technologies to collect information about your activities on this and other website and/or any of online products or services to provide you targeted advertising based upon your interests. Where required by applicable law, we will provide you with choices and obtain consent before engaging in such processing. Under certain U.S. state laws, some of these disclosures may constitute "sale," "sharing," or "targeted advertising," and you may opt out as described in Section 4.
8. What are Internet Protocol addresses?
An Internet Protocol ("IP") address is the unique number assigned to your server or Internet Service Provider ("ISP"). We may track such IP addresses for system administration, to report aggregate information, site tracking, security purposes, or to prevent our servers from being abused. See tracking technology discussion above. We may also use IP address information to help determine the approximate region from which the services are accessed, prevent abuse, investigate fraud or cheating, and comply with legal obligations.
9. What do you do if you want to correct or delete your personal information?
Should you have any questions or concerns regarding our use of your personal information, or if you wish to correct or request deletion of such personal information, please contact us via email at: [zenworld21@126.com]. We will respond to any such request within thirty (30) days.
Under certain circumstances, we may be unable to delete your personal information and will retain and use such information to fulfil our legal obligations, resolve disputes, and/or enforce our agreements, prevent fraud or abuse, protect security and integrity, complete transactions requested by you, or exercise/defend legal claims. We may also need to verify your identity before processing your request and may deny or limit the request to the extent permitted by applicable law.
Please note that once your data is deleted, your account and all related services will be terminated. Certain information may remain in backups for a limited period, in aggregated or de-identified form, or where retention is otherwise required or permitted by law. Content you have posted publicly or in community-facing areas may remain visible to others unless and until it is separately removed.
10. How secure is my personal information?
We place great importance on the security of personal information. In order to ensure the safety and integrity of all information collected, measures have been implemented accordingly. Therefore, access to all personal information is strictly controlled.
When transmitting credit card information, we adhere to industry standards and implement dual protection for the personal information you submit to us—covering both the transmission process and the period after receipt.
In addition, we will take reasonable steps to assure that third parties to whom we transfer any data will provide sufficient protection of personal information. Where such third parties process personal information for us, we require them by contract to implement appropriate protections and to process the information only for authorized purposes.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted to our services; therefore we do not assume any responsibility for any transmission of your information which you do at your own risk.
We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, including to provide the Game and related services, maintain accounts, process transactions, handle refunds, respond to customer support requests, investigate complaints and appeals, maintain security and anti-cheat systems, comply with legal obligations, and establish, exercise, or defend legal claims. Retention periods may vary depending on the category of information and the applicable legal or operational requirements.
If you submit the following information to us, we will retain it for you for as long as your account remains active and thereafter for a reasonable period as necessary for backups, dispute handling, fraud prevention, legal compliance, and recordkeeping:(1) User nickname or name;(2) If registering via Facebook/Google Play account: Name, Facebook/Google Play account ID, profile picture, email address (optional);(3) Gender;(4) Manually selected region/location;(5) Real-name authentication information;(6) Game statistics (level, score/seconds);(7) Friend list (from Facebook, Google Play, iOS Game Center);(8) IP address, Device ID and device information;(9) Advertising ID and marketing analytics data (such as Device ID, user engagement data, and search terms);(10) Log data;(11) Security-related information.
If you submits the information about the Date and time stamps of actions to us, we shall store such operational or security logs generally for at least 30 days and longer where reasonably necessary for security, fraud prevention, troubleshooting, complaint handling, legal compliance, or legal claims.
If you submits the information about your GPS to us, we shall delete or de-associate it when the relevant location-based function is completed, upon logout where applicable, or earlier when it is no longer necessary for the relevant feature, subject to legal, security, or dispute-related retention needs.
If you submits the information about your Transaction Records (Open ID, cost, product purchased, IP address, device details, email address (if web-based transaction)) to us, we shall store such records for the life of the account and thereafter for any additional period required or reasonably necessary for tax, accounting, audit, chargeback, refund, fraud prevention, legal compliance, or legal claims purposes.
If you submits your Survey Information (In-Game Surveys) to us, we shall store for two years following receipt of the data. The data is deleted upon the expiry of such period or within 30 days of a lawful request from you for the erasure of such data (see the section of this privacy policy) (whichever is sooner).
If your submits your Survey Information (surveys placed on third party platforms including social media),we shall store for two years following receipt of the data. The data is deleted upon the expiry of such period or within 30 days of a lawful request from you for the erasure of such data (see the section of this privacy policy) (whichever is sooner).
If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.
11. What if you have a question or complaint?
If you have any questions or wish to file a complaint, please feel free to e-mail us at:[ zenworld21@126.com ].
For EEA users, where required by applicable law, you may also contact our EU representative at: [zenworld21@126.com].
For UK users, where required by applicable law, you may also contact our UK representative at: [zenworld21@126.com].
If you are located in the EEA or UK, you may also have the right to lodge a complaint with the competent supervisory authority in your country or region, or, for UK users, with the UK Information Commissioner’s Office, without prejudice to any other rights or remedies you may have under applicable law.
12. Clipboard function
This application stores clipboard data so that users can acces the content when needed. Where the Game uses clipboard-related functionality, such access is used only to support the specific feature you request, such as copy-and-paste or code/token recognition initiated by your use of the application. We do not use clipboard data for unrelated purposes, and clipboard access may depend on your device settings and permissions.
13. Dispute Resolution and Class Action Waiver
13.1 The conclusion, validity, performance and interpretation of this Agreement and resolution of disputes in connection herewith shall be governed by the laws of the Hong kong (excluding the applicable conflict of law rules).However, nothing in this Article excludes or restricts any non-waivable rights or remedies to which you are entitled under applicable mandatory consumer protection, privacy, or data protection laws. If you are a "Specifying Regional User" as defined in Article 13.3, Articles 13.3 to 13.9 shall apply to the maximum extent permitted by law.
13.2 In the event of any dispute or controversy , the parties shall in the first place use their best efforts to settle such dispute or controversy through amicable negotiation. You agree that any dispute or controversy which cannot be settled by negotiation, shall be submitted to and finally resolved by the Hong Kong International Arbitration Centre for arbitration,The arbitration site is Hong Kong. However, if you are a "Specifying Regional User " as defined in Article 13.3, this Article 13.2 shall not apply to you, and the parties shall handle disputes in accordance with Articles 13.3 to 13.9. Nothing in this Article prevents you from raising a complaint with a competent supervisory authority or regulator where such right cannot lawfully be waived.
13.3 Specifying Regional User: For the purposes of Articles 13.3 to 13.9, a "Specifying Regional User" means a user who, at the time you click "I have read and agree"/check the agreement to this Agreement or at the time the dispute arises (Based on either of the two time points), resides in or primarily accesses/uses the Services from the United States, Canada, or Australia; If mandatory laws in the location of the Specifying Regional User stipulate otherwise regarding consumer dispute resolution mechanisms that cannot be excluded, such mandatory provisions shall prevail, and this Article shall apply only to the maximum extent permitted by law.
13.4 Mandatory Individual Arbitration and Class Action/Class Arbitration Waiver (Important): Except for the exceptions listed in Article 13.5, any dispute, claim, or controversy arising from or relating to this Agreement, the Services, or the relationship between us and you, shall be finally resolved by binding individual arbitration, rather than in court; to the maximum extent permitted by law, both parties waive the right to participate in any class action, class proceeding, representative action, or class/consolidated arbitration as a plaintiff or member, and the arbitrator has no authority to conduct any arbitration on a class, representative, or consolidated manner, nor to grant any relief other than that provided for under the individual arbitration procedure. The arbitrator (and not any court) shall have authority to rule on issues related to the formation, validity, scope, and enforceability of this arbitration clause. For U.S. users, this arbitration clause is governed by and shall be construed in favor of arbitration to the maximum extent permitted by the principles of the Federal Arbitration Act (FAA) of the United States. For the avoidance of doubt, this Article does not limit any right to lodge a complaint with a regulator or supervisory authority where such right cannot lawfully be waived.
13.5 Exceptions: Notwithstanding the provisions of Article 13.4, (a) if a dispute meets the filing standards of the small claims court in your place of residence, either party may choose to bring or defend a claim on an individual basis in that small claims court; (b) either party may apply to a court of competent jurisdiction for interim injunctive or other equitable relief necessary to maintain the status quo or for intellectual property infringement, and such application shall not affect the resolution of the remaining disputes through individual arbitration pursuant to Article 13.4; (c) if mandatory law requires that certain types of public injunction relief cannot be excluded by mandatory arbitration, such mandatory requirement shall prevail, and related requests shall be heard by a court of competent jurisdiction, while the remaining disputes shall still be resolved through individual arbitration pursuant to this Article; and (d) nothing in this Article shall prevent a user from submitting a complaint to a competent privacy or data protection regulator where such right exists under applicable law.
13.6 Pre-Dispute Notice and Consultation: Before either party initiates arbitration, both parties agree to first engage in a good faith informal dispute resolution process. The party raising the dispute shall send a "Dispute Notice" to the other party, briefly stating the factual basis of the dispute and the relief requested, and providing a contact email for communication. For at least 30 days (or a longer period if required by mandatory law) after the Dispute Notice is delivered, both parties shall attempt to resolve the dispute through good faith consultation; except for preserving rights or applying for interim relief, neither party may initiate arbitration before the expiration of this period.
13.7 Arbitration Institution, Rules, and Costs: For U.S. users, arbitration shall be administered by the American Arbitration Association (AAA) in accordance with its rules and fee schedule applicable to consumer disputes; for Canadian and Australian users, arbitration shall be administered by a neutral arbitration institution reasonably accessible for service in your place of residence (e.g., ADR Institute of Canada or Australian Disputes Centre or their successors) and governed by the rules of that institution; if the relevant institution refuses to administer or is unable to administer, the parties shall negotiate to select an alternative institution; failing agreement, the court of competent jurisdiction shall appoint one. We will bear the administrative fees and arbitrator fees that the enterprise party is required to bear under applicable rules and mandatory law to the maximum extent permitted by law, and ensure that the cost burden for a Specifying Regional User to initiate individual arbitration remains reasonable.
13.8 Opt-out Mechanism: If you are a Specifying Regional User, you may opt out of the mandatory individual arbitration and class action/class arbitration waiver arrangements described in Articles 13.3 to 13.7 by sending a written opt-out notice to the email [zenworld21@126.com] within 30 days of your initial agreement to this Agreement. The opt-out notice must contain at least your account identifier/user ID, registration/contact email, and a clear statement that you choose to opt out of the arbitration and class waiver provisions of this Article. Upon your effective opt-out, related disputes may be resolved through litigation in a court with jurisdiction (the requirements regarding jurisdiction and procedure are subject to mandatory legal provisions). Your withdrawal does not affect your other obligations and rights under this agreement.
13.9 Severability and Survival: If any part of this Article is found to be invalid or unenforceable, that part shall be modified to the minimum extent necessary to be effective within the limits permitted by law, closest to its original intent, or severed without affecting the validity of the remainder; but if a court of competent jurisdiction ultimately determines that the "Mandatory Individual Arbitration and Class Action/Class Arbitration Waiver" described in Article 13.4 is unenforceable with respect to a particular dispute, then, as to that unenforceable part, such dispute shall be heard by a court of competent jurisdiction (and not arbitration), and the remaining disputes shall still be resolved through individual arbitration pursuant to this Article. This Article shall survive the termination of this Agreement and continue to bind both parties.