CATAPULT STAR Privacy Policy

Last Updated: 18 June 2020

Thank you for using our products and services!  We respect your concerns about privacy and appreciate your trust and confidence in us.

Here is a summary of the information contained in this privacy policy. This summary is to help you navigate the privacy policy and it is not a substitute for reading everything! You can use the hyperlinks below to jump directly to particular sections.

What information do we need to provide the Game Services?

If you register an account to use the Game then we will need some information from you to set this up. We will also process some information when you use the Game (e.g., to make sure your progress is saved) and when you buy items (e.g., to ensure you get the purchased content). 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. More Information.

How will we use your information?

We use your information to provide the many functions and services that comprise the Game Services. We also use your information for account verification, security purposes and to support and improve the Game Services. We do not share your information with any third parties, except where we need to in order to provide the Game Services (e.g., use local cloud providers or to back up your data; using our affiliates around the world to help us to deliver the Game Services) or monitor the success of our marketing and advertising programs,  or we are instructed to by a court, authority or compelled by law. More Information.

Who do we share your information with?

We use some third parties to help us deliver the best possible experience (e.g., cloud services to back up your data and support ticketing). When we use a third party, we only do this to process or store your information for the purposes described in this privacy policy. We also have affiliates around the world who help us deliver the Game Services and we may be required by a court or legal obligation to disclose certain information in some circumstances. More Information.

Where do we process your information?

Our servers are located in Singapore, Japan, Hong Kong SAR, the United States and the People’s Republic of China (for the purpose of this privacy policy, this term excludes Taiwan, Hong Kong SAR and Macau SAR). Our support, engineering and other teams are located in our offices around the world (including the United States and Hong Kong SAR). More Information.

How long do we keep hold of your information?

We generally retain your information for the period during which you maintain an account for this Game after which time your data is deleted (as further described in this privacy policy), unless otherwise required by applicable laws. More Information.

How can I exercise my rights over my information?

Depending on where you live, you may have certain rights with respect to your information, such as rights of access, to receive a copy of your data, or to delete your data or restrict or object to our processing of your data. More Information.

How to get in touch with us

If you have any questions about anything in this policy, or want to exercise any rights you may have, please contact us here.

How will we notify you of changes?

If there are any significant changes to this privacy policy, we will update the policy here. More Information.

Contact Information

Email: cs.catapultstar@avalongames.com

 




Welcome to CATAPULT STAR!

This privacy policy explains the when, how and why when it comes to processing of your personal information in connection with the mobile game CATAPULT STAR (“Game”) and the website for the Game (“Website”), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

If you do not agree to the processing of your personal information in the way this privacy policy describes, please do not provide your information when requested and stop using the Game Services. By using the Game or the Website (the “Game Services”) you are accepting our rules regarding your personal information as described in this privacy policy.

 

This Game has been developed by the Avalon Tech.Ltd (“we”, “us”, “our”). 

Please reach out to us if you have any questions or concerns regarding the processing of your personal information: you can contact us anytime at cs.catapultstar@avalongames.com.

The Types of Personal Information We Use

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled “How we use your personal information” below.

The following is a high level summary of the types of personal information we use:

1. Information you provide to us (either directly or through a third party). 

 

You give us information about you when you register for the Game (your nominated nickname, and information we import from your connected social media account (WeChat, Facebook, QQ, VKontakte, Twitter, Google Play, Game Center or LINE) in order to set up your profile, including your name as it appears on your social media profile, your user ID and your profile picture). You also provide us with information when you set up your profile for the Game (including region location and information you voluntarily elect to provide in order to customise gameplay, such as gender) or your nickname when you log-in as a ‘guest’ in order to use the Game.

 

You also provide us with information when you participate in a survey in the Game (in which case we will process the information you provide to us as part of the survey, including country, age, gender, profession and email address). When you participate in one of our sweepstakes events you provide us with information including email address, Open ID, phone number, mailing address and country); and when you register for an e-sports event we will collect your team name, your name, nationality, proof of residency, email address, phone number and character ID. If you qualify to attend in person the global final of an e-sports event, we will also ask you for your passport and/or proof of residency information.

 

2. Information about you generated as part of the Game (and its in-Game services)

 

We automatically collect certain data from you when you use the Game Services, namely your open ID, IP address, device information (such as application version, battery level, WiFi strength, available space, network type, OS version, platform, carrier, country code, series ID, Android ID, MAC and IDFV), registration time, login time, and information regarding your use of the Game Services, such as date and time stamps of actions. We also collect and store your data:

 

·         each time you interact with us, for example, when you use in-app or in-Game support to communicate with us;

·         if you choose to log in using a social media service, we import the social media user ID and name of the friends (and in the case of Facebook, their Facebook nickname and profile picture) from your social media profile so that you can connect with your friends;

·         if you click on a link that advertises the Game, we store the Advertising ID for that advertisement and select device information with your profile;

·         if you enable chat services (audio and/or text and use them whether inside or outside a battle) then we will process such data in order to deliver your messages to other users;

·         if you conduct any transactions within the Game or via a third party other than Google Play or iOS App Store, we collect information to facilitate your transaction and to maintain transaction records (including Open ID and user information cost, currency, product purchased, purchase history, IP address, details of transactions linked to player ID, and device details such as OS version, phone model or type of device, internet connection);

·         if you contact our support team, we collect information including name (optional), Open ID, device ID, application version, battery level, WiFi strength, free space on device, network type, OS version, browser type, platform, carrier, country code, details of ticket, email address (optional if in-app/in-Game support) and any information that you provide in your communications. You also have the option of providing a photo to illustrate any errors; and

·         when you are using the Game Services our security feature collects (in addition to the categories of data listed above) device information including the IMEI number and available memory; information about your internet connection including if applicable the WiFi name and MAC address of the WiFi access point; and a list of installed APK and running apps.

3. Information you generate and display in the course of using the Game Services.

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 (chat log data and chat content, both audio and text). We generate an Open 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. If you participate in a sharing event, we will process your Game data (prop types, wins, ranking and Game play statistics) to prepare a report for you.

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 Services. 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 (in the case of the Game) or web browser (in the case of the Website) 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 Services may be unable to operate as designed.

For more information about our Cookies policy, click here.

Children

Our Game Services are not intended for children. Children must not use the Game Services 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.

Country in which the user is located

Minimum age of the user

Brazil

18

European Economic Area/Switzerland

16 (subject to the below)

Russia

14

Turkey

18*

India

18*


*Users located in India and Turkey and who are under the age of 18 are required to obtain parental/guardian consent prior to the playing of the Game.

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

We do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages, please contact us at cs.catapultstar@avalongames.com and we will delete such information.

How We Use Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why. For users who live in the European Economic Area (“EEA”), it also identifies the legal basis under which we process your data.

Personal Information

Use

Legal Basis (only relevant if you are located in the EEA)

Game

Information you provide to us (either directly or through a third party). 

Nickname

We use this information to create your account for the Game in accordance with your request.

Necessary to perform our contract with you to provide the Game.

Social Connect Information (if you choose to log in via your social media account with these networks):

·        WeChat: Open ID, profile photo, alias, gender, region

·        Facebook: Name, Facebook ID, profile picture

·        VKontakte: userID, nickname, first name, last name, profile picture

·        QQ: Open ID, profile picture, alias, gender, region

·        Twitter: userID, nickname, profile image

·        Google Play: UserID, nickname, profile image

·        Game Center: UserID, nickname, profile image

·         LINE: UserID, display name, profile image

 

We use this information to:

·       create your account for the Game in accordance with your request; and

·       share in-game photos on WeChat, Facebook, VKontakte, QQ, Twitter, Google Play, Game Center or LINE (as applicable) at your request.

Necessary to perform our contract with you to provide the Game.

Gender (if you elect to provide this information)

We only receive this information if you voluntarily provide it (other than users who log in via their QQ or WeChat social media account, when gender is also collected – please see above). It is used in order to customise gameplay.

Necessary to perform our contract with you to provide the Game with gender-specific content in accordance with your request.

Region Location (manually selected by you)

We use this information to:

·         set up your gameplay on a regional server;

·         provide you with your geographic ranking; and

·         improve gameplay.

Necessary to perform our contract with you to provide the Game.

Friends List (WeChat, Facebook, QQ, VKontakte, Twitter)

If you choose to log-in using a social media service, we import the social media user ID and name of the friends from your social media profile so that you can connect with your friends.

If you choose to log-in through Facebook, and connect with your friends that also have the Game, we will import the Facebook nickname and profile picture of those friends.

Necessary to perform our contract with you to provide the Game and connect you with your friends.

Friends List (manually added by you)

We use this information so that you can connect with your friends.

Necessary to perform our contract with you to provide the Game and connect you with your friends.

Information generated as part of the Game (and its in-Game services)

Generated Open ID

We generate this and use this to store your Game data (including level and progress) with your profile, and it allows you to connect to the Game server.

Necessary to perform our contract with you to provide the Game.

Game Play Statistics (Level, Score/s), date and time stamps of actions

We use this information to provide you with feedback and information about your gameplay and progress.

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 ID, Device Information (application version, battery level, WiFi strength, available space, network type, OS version, platform, carrier, country code, series ID, Android ID, MAC, IDFV, device language, screen DPI, device resolution, screen direction, brand, manufacturer, device model, RAM, ROM and CPU information), registration time and login time

We use this information:

·         to improve our services, including the functionality of the Game;

·         for security and verification purposes;

·         identify and address bugs and assess game function for optimisation; and

·         to combat users registering for multiple accounts.

It is in our legitimate interest to ensure the security of our services, manage registrations and improve our services.

Advertising ID and select device information (Open ID, Device ID, IP address, IDFV and engagement data and search terms)

If you click on a link that advertises the Game, we store the Advertising ID for that advertisement and select device information with your profile.

It is in our legitimate interests to use this information to monitor the success of our advertising and marketing programs.

Chat Data (audio and text, whether inside a battle (e.g. during actual gameplay) or outside a battle (e.g. in the game lobby)) and chat log data

If you enable chat services (audio and/or text) then we will process such data in order to deliver your messages to other users.

Necessary to perform our contract with you to provide the chat services in-Game.

Transaction Records (in-app): payments on Google Play or iOS App Store (Open ID, cost, product purchased, IP address, details of transactions linked to player ID, and device details including OS version, phone model, device root status).

We use this information to facilitate your payment and maintain a record of your transaction history.

Necessary to perform our contract with you to facilitate your payment and provide you with details of your transactions.

Transaction Records (third party other than Google Play or iOS App Store): user information (name, username, email address, Facebook nickname), device information (including Open ID, IP address, OS version, type of device, internet connection), transaction details (time and date, cost, product purchased, currency, order ID) and transaction records (including player ID, time of transaction, country, email, phone number, purchase history and payment card details).

We use this information to facilitate your payment and maintain a record of your transaction history.

Necessary to perform our contract with you to facilitate your payment and provide you with details of your transactions.

Customer Support Ticket ID & User Communications with Support: Name (optional), Open ID, device ID, application version, battery level, WiFi strength, free space on device, network type, OS version, browser type, platform, carrier, country code, details of ticket, email address (optional if in-app/in-Game support) and any information that you provide in communications with our support team. You also have the option of providing a photo to illustrate any errors.

We use this information to:

·         improve our services;

·         provide troubleshooting, such as addressing and remediating technical issues and bugs.

Necessary to perform our contract with you to provide and support the Game.

Security-Related Information: list of hack or cheating software, in-game screen information, device operation system settings, device information including mobile phone brand, model, CPU structure, CPU model, kernel version, resolution, application package of hack software; IMEI number and available memory; information about your internet connection including if applicable the WiFi name and MAC address of the WiFi access point; and a list of installed APK and running apps.

Security-Related Information (if you are using the game on a PC): basic hardware information, operating system information, machine codes for security authentication, user account information, network information, information of files, processes, modules, memory and driver which is related to the game running, user behaviour and status that may be related to plug-in use, image files, memory image and shellcode which is related to the game running, system API calls, method calls, system procedures and related data of active windows, information on in-game modules, game screenshots, external programs attempting to access private data which belongs to process of game application.

We use this information:

·         for security and verification purposes, including to detect cheating behaviours;

·         identify and address bugs and assess game function for optimisation;

·         solve game crashes and optimise compatibility of devices with the game; and

·         to combat users registering for multiple accounts.

It is in our legitimate interest to ensure the security of our services, manage registrations and improve our services.

Security-Related Information when transactions are conducted: whether certain billing security features of the Android SDK (security development kit) are installed on the device, and if so the version information.

We use this information when transactions are conducted on your account in order to detect fraudulent payment activity.

It is in our legitimate interest to ensure the security of transactions within our services.

Survey Information: Country, Age, Gender, Profession, Email, and content of survey responses.

If you agree to participate in a survey conducted by us, we use this information to improve our services.

We collect this information with your consent.

Sweepstakes Participation Information: email address, Open ID, phone number, mailing address and country.

If you participate in a sweepstakes event, we use this information to send you your prize if you win.

We collect this information with your consent.

E-sports Event Registration Information:

·        team name, your name, nationality, proof of residency, email address, phone number and character ID.

·         if you qualify to attend in person the global final of an e-sports event, we will also ask you for your passport information and/or proof of residency.

If you register for an e-sports event, we use this information to create a team for you in the tournament, to organise the tournament and to communicate with the team.

We use the passport/residency information of players who qualify to attend the global final of an e-sports event to verify that you are located within a country in your nominated Game region and to assist with travel arrangements.

We collect this information with your consent.

Sharing Event Report Information: Game data (prop types, wins, ranking and Game play statistics).

If you participate in a sharing event, we use this information to prepare a report for you.

We collect this information with your consent.

We may collect other personal information from you from time to time for specific reasons (such as a promotion in your country). When this happens, we will provide more information on any specific changes to the way we process that personal information that might differ to this privacy policy prior to collecting or processing any additional information. In some cases, that information may be shared with us with your consent – and if that is the case, we will provide you with further information on how we process that information and your rights.

How We Store and Share Your Personal Information

 

The Tencent group operates around the world. Pursuant to our contract with you to provide you with the Game Services, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this privacy policy. Our servers for the Game Services are located in:

·Canada;

·Hong Kong SAR;

·Singapore;

·the People’s Republic of China (“PRC”) (for the purpose of this privacy policy, this term excludes Taiwan, Hong Kong SAR and Macau SAR); and

·the United States.

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 privacy policy on their servers for the purpose of providing the Game Services (including the sharing of in-game photos on WeChat, Facebook, VKontakte, QQ, Twitter, Google Play, Game Center or LINE (as applicable)), for the purpose of processing customer support ticket IDs and support communication, for the purpose of providing marketing and advertisements and monitor the success of our marketing and advertising programs, and for the purpose of arranging e-sports events. 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.

·        Companies within the Avalon corporate group who process your personal information in order to operate the Game Services. All related group companies may only use your personal information in accordance with this privacy policy.

·        Regulators and judicial authorities and law enforcement agencies. There are circumstances in which we are legally required to disclose information, including to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users.

·        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 prospective buyer of such business. Under these circumstances, we will always require the prospective buyer to comply with 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. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we implement and maintain reasonable security 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.

Data Retention

Personal Information

Retention Policy

Nickname

 

Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days.

Social Connect Information:

·         WeChat

·         QQ

Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days or as otherwise required by law.

Social Connect Information:

·         VKontakte

·         Twitter

·         Facebook

·         Google Play

·         Game Center

·         Line

 

Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days.

Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.

Gender

Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days.

Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.

Region Location (manually selected by you)

Game Play Statistics (Level, Heroes, Score/s), date and time stamps of actions

Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days.

Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.

Chat Communications (Audio message) – outside a battle (e.g. in game lobby)

Stored for 7 days on our servers and deleted automatically upon expiry of such period.

Chat Communications (Audio message) – inside a battle (e.g. during actual gameplay)

We do not store this information. Your data is not transferred through our game servers, but it is transferred directly from client to client through a voice-enabled service node.

Chat Communications (Text) – outside and inside a battle

Stored for 7 days on our servers and deleted automatically upon expiry of such period.

Open 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 30 days.

Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, 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 30 days.

Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.

Device ID, Device Information, registration time and login time

Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days.

Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.

Friends List (WeChat, Facebook, QQ, VKontakte, Twitter)

 

Stored for the duration of each session on the Game and deleted within 1 hour after you log out.

Friends List (manually added by you)

Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days.

Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.

Advertising ID and select device information (Open ID, Device ID, IP address, IDFV and engagement data and search terms)

Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days.

Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.

Transaction Records (in-app)

Transaction Records (third party other than Google Play or iOS App Store)

 

Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then for the duration of any retention periods for which such data must be retained in order to comply with our legal obligations.

Customer Support Ticket ID & User Communications with Support

Support data is deleted within 30 days of a lawful request from you for the erasure of such data (see the Erasure section of this privacy policy).

Security-Related Information

Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days.

Security-Related Information (if you are using the game on a PC)

We generally retain this data for no longer than 90 days with the exceptions listed below.

·         File sample collection and memory sample collection related to confirmed malicious activities: up to 10 years;

·         In-game process information and system information: up to 10 years;

·         Security authentication: up to 5 years.

Upon a deletion request, we will delete the data within 30 days except where they relate to confirmed malicious activities.

Survey Information

Stored for: (a) if you provide your email as part of the survey, up to 6 months (in order for us to follow up with you) and then the data is anonymised; or (b) if you do not provide your email as part of the survey, up to 1 month and then the data is anonymised.

Sweepstakes Participation Information

Stored for the duration of the sweepstakes event and then deleted within 10 days.

E-sports Event Registration Information.

 

Stored for up to 3 months from the conclusion of the tournament.

Sharing Event Report Information

Stored for the duration of the event and then deleted within 10 days.

 

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.

Your Rights

Some jurisdictions’ laws grant specific rights to users of the Game Services, which are set out in this section.

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

The sub-sections entitled “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 cs.catapultstar@avalongames.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. If you believe we hold any other personal information about you, please contact us at cs.catapultstar@avalongames.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 above in the section “How We Use Your Personal Information”. You have the right to receive this personal information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer it to another party, with certain exceptions. We will provide further information to you about this if you make such a request. 

Correction

You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your Game account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at cs.catapultstar@avalongames.com. 

Erasure

If there is any personal information you believe we process that you would like us to erase, please contact us at cs.catapultstar@avalongames.com.

 

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, 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 Services and there are grounds for erasure, we will use reasonable steps to try to tell others who 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 (for example, 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.

Objection

You have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below by contacting us at cs.catapultstar@avalongames.com.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at cs.catapultstar@avalongames.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, 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

We welcome questions, comments and requests regarding this privacy policy. Please address them to cs.catapultstar@avalongames.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 cs.catapultstar@avalongames.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 consider we have infringed data protection laws.

Changes

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




SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Game Services, which are set out in this section.

If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you.

Brazil

In order to use the Game Services, 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.

California

This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).

 

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:

· Identifiers, such as your name as it appears on your social media profile, open ID / user ID, IP address, device ID, device token, phone number, mailing address, email address, nickname or a related advertising ID and device information. If you qualified for certain e-sports events, we also collected your passport and/or proof of residency. This information is collected directly from you and your device and from social media platforms if you choose to sign up using a social media account.

· Internet or other electronic network activity information, such as your information regarding your use of the Game Services, including level, score, date and time stamps of actions, and log-in and clickstream data. This information is collected directly from you and your device.

· Commercial information about any transactions in the Game or via a third party such as what products were purchased and how much they cost. This information is collected directly from you and your device and the Google Play or Apple iOS store or the third party where you made the purchase.

· Geolocation data such as your region location when you set up your profile for the Game. This information is collected directly from you.

· Audio and visual information such as your social media profile picture, photos shared in the Game, and audio messages. This information is collected directly from you and from social media platforms if you choose to sign up using a social media account.

· Professional or employment-related information such as your profession if you choose to provide it in a survey. This information is collected directly from you.

· Other information described in subdivision (e) of Section 1798.80, including information about your gender, nationality, or age. This information is collected directly from you in the context of being our consumer.

 

We collect your personal information for the following purposes:

· To provide you the Game Services, including offering the Game, maintaining your account, providing customer service, processing payments, and delivering audio and text messages;

· To register you for and arrange e-sports events;

· To process surveys and administer sweepstakes;

· To improve our services, including the functionality of the Game;

· To monitor the success of our advertising and marketing programs;

· For security and verification purposes, including to prevent and detect fraudulent activity;

· To address and remediate technical issues and bugs.

 

For additional information about what each type of personal information is used for, see this chart in the main portion of the Privacy Policy.

 

We disclose personal information to the following types of entities:

· Other companies within the Tencent corporate group who process your personal information in order to operate the Game Services

· Other companies that provide services on our behalf who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing the services to us

· Regulators and judicial authorities and law enforcement agencies

· Entities that acquire all or substantially all of our business

 

In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” in the CCPA.

 

Rights under the CCPA

 

If you are a California resident, you have the right to:

· Request we disclose to you free of charge the following information covering the 12 months preceding your request:

o the categories of personal information about you that we collected;

o the categories of sources from which the personal information was collected;

o the purpose for collecting personal information about you;

o the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and

o the specific pieces of personal information we collected about you;

· Request we delete personal information we collected from you, unless CCPA recognizes an exception; and

· Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.   

 

We aim to fulfill all verified requests within 45 days pursuant to the CCPA.  If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

 

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may exercise your rights, if any, to other data by contacting us at cs.catapultstar@avalongames.com. 

 

Canada

SERVICE PROVIDERS

 

If a user located in Canada wishes to obtain written information about our policies and practices with respect to our service providers located outside Canada, they may contact us at cs.catapultstar@avalongames.com. Our privacy experts who monitor this email address are also able to answer any questions users may have about the collection, use, disclosure or storage of personal information by our service providers.

 

Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.

 

India

 

SHARING OF YOUR PERSONAL INFORMATION

 

Where we permit any third parties to collect and use your Personal Information, we shall take reasonable measures to ensure that the third parties do not further disclose the Personal Information.

 

AGE RESTRICTIONS

 

Children under the age of 18 are not allowed to execute online contracts with us or sign up for our services. Parental consent is required for children under the age of 18 years to avail our services.

Russia

If you are using the Game Services 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 in accordance with this privacy policy of your information. 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 SAR, the United States, Singapore, Canada and the People’s Republic of China (for the purpose of this privacy policy, this term excludes Taiwan, Hong Kong SAR and Macau SAR).

Turkey

Our Data Controller Representative in Turkey for the purpose of compliance with Turkish Law on Personal Data Protection Law and its secondary regulations can be contacted at cs.catapultstar@avalongames.com. Please include the word “Turkey” in the subject line of your email.

You have legal rights in relation to the personal information data we hold about you. As a Turkish data subject, you may have right to (and to the extent permitted under applicable laws and regulations):

a) learn whether or not your personal data has been processed;

b) request information about processing if your personal data has been processed;

c) learn the purpose of processing of your personal data;

d) know the third parties in the country or abroad to whom personal data has been transferred;

e) request rectification in the event personal data is incomplete or inaccurate;

f) request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the Personal Data Protection Law (Turkey);

g) object to certain processing of data, and seek certain remedies in accordance with the Personal Data Protection Law (Turkey).

United Arab Emirates

You consent to the collection, use, disclosure, transfer and storage of your Personal Information.

We may voluntarily report a cyber-security incident where it constitutes a crime under UAE law (e.g. under the UAE Cybercrime Law). The incident can be reported to the relevant authorities for the purpose of investigations. Please note also that voluntary reporting of a cyber-security incident can also be made to the UAE Computer Emergency Response Team (“CERT”). CERT is a security awareness organisation that provides a process for logging incidents and advising on known cyber security threats in the UAE.