Privacy Policy
Last Updated: January 23, 2024
Innovation Casualty Limited ("we" or "company") is serious about games. And we are serious about your privacy and data rights. We are committed to maintaining a relationship of trust and transparency with you. This Privacy Policy is written in plain language to make it easy to understand how we collect, use, store, and share information that is identifiable to you ("Personal Data" – “Personal Data” may, when the context indicates, also mean “Personal Information” as set forth in the California Consumer Privacy Protection Act of 2018 and / or the EU General Data Protection Regulation) when you access our websites, mobile applications, games or other services (collectively the "Services"). When you use a Service, you consent to each of the collections, uses and disclosures of information (including recording and tracking) described in this Privacy Policy. Please read it carefully. if you do not agree to this privacy policy, please do not use any service.
A. Information You Provide to Us Directly.
When you interact with our owned website, or download the Service from a third-party app store, we will collect and store information from you directly as described below, to the extent it is available to us. We collect the information that you give us, and the information may include your:
· Name
· E-mail address
· account information, such as unique user-name, ID or avatar
· We may also offer you the option to complete a user profile that is visible to other Service users. Your user profile may include: a profile image; one or more Service username(s); and a user ID number that is created by us and used to identify your profile.
· Payment or billing information
· Your messages to us or the Services (chat logs, customer support requests)
· Information that helps us verify it’s actually you, prevent fraud, develop and improve our Services
· IP Address
· General Location Data Device information (such as device type, model, operating system, browser version, or unique device identifiers for checking device compatibility and IDFA )
· IDFA means Identifier for Advertisers on Apple and GAID means Google Advertising Identity. These unique identifiers are non-permanent and non-personal, meaning they do not contain sensitive information about you but do allow for consistency across all apps and cross-app tracking. You can opt-out of sharing your device identifier by updating the settings on your device.
· Service communications (in-game messages, chat logs)
· Connection type
We may be given access to certain information collected from you by third parties, including your use of such third party’s services, applications, or other services.
We will create and assign to your device an identifier that is similar to an account number. We will also collect the following information about you, to the extent it is available, and if required, based on your consent:
· Game username;
· Device type; model; operating system; memory; storage;
· Telephone number;
· Country, region, city;
· User name, character name;
· Language;
· E-mail address; and
When you use our Services, we will collect information about the ways in which you use and interact with our Services, such as when and for how long your device is logged into our games, game features you access and other players you interact with, in-app purchases you make, progress or levels you achieve, and other gameplay activities.
We also collect pseudonymous usage statistics about your interactions with the Service. This information is typically collected through the use of server log files, mobile device software development kits and tracking technologies to collect and analyze certain types of technical information. Some of the cookies the Service places on your computer are linked to your user ID number(s).
When you use the Service, you will get access to the online gaming community within the Service which gives you the opportunity to communicate or share information not just with us, but also with other users of our Service through:
· Posting public comments to other users’ profiles or game boards;
· Sending private messages or invitations to other users, either directly on our websites or to their e-mail accounts;
· Chat with other users; and
· Posting web links.
When you participate in online gaming communities, we access and store information / Personal Data about you. The information we store varies by game / application and is affected by the privacy settings you and your friends establish in that game / application. You can control and find out more about these settings within the application. We will collect the following information:
· Your in-Service username;
· Your device advertiser ID;
· Depending on how you log into the Services, Facebook User ID;
· The IP address of your access devices;
· Your in-game chats and messages; and
· If provided by you, your e-mail address and phone number.
· Submitted Avatars
We will also collect some purchase information (which consists of transaction history, including what you have purchased, the price, and the date). Note that your in-game and/or in-app purchase transactions are processed by third-party payment processors, such as Apple (for purchases on iOS devices), Google (for purchases on Android devices). These third-party payment processors are the “merchant of record” for your purchases and do not share your financial information, like credit card numbers, with us.
When you ask for assistance from our Customer Support team, we will collect and store:
· Your name and e-mail address;
· Information about your activity on the Service;
· Your user name or ID number; and
· Any correspondence connected to the assistance provided to you
We use your Personal Data and non-personal information to:
· Communicate with you according to your preferences, and our Terms of Service.
· Operate, develop, maintain, and improve our Services.
· Provide customer support for the Services.
· Resolve disputes and enforce our Terms of Service.
· Make special/promotional in-game offers available to you
· Collect fees, payments, and other amounts due in connection with the Services.
· Enable you to connect with other players.
· Create a user account to use the Services.
· Provide you with the appropriate version of the Services, including in your preferred language.
· Identify, fix, and troubleshoot bugs and service errors.
· Develop new services.
· Identify and/or prevent fraud.
· Identify and/or prevent Terms of Service violations, illegal activities or cheating.
· Verify user identities for customer support communications.
· Monitor, ensure and enhance the security of our network and information systems.
· Provide you with notices, personalized game experience and other offers.
· Communicate with you regarding your areas of interest and respond to your requests.
· Serve, optimize and measure the effectiveness of our marketing campaigns.
· Perform analytics for internal marketing and demographic studies to develop, improve or personalize the Services.
· Save, track your game attributes, progress and stats.
We also use your Personal Data and non-personal information to:
· Comply with legal obligations.
· Exercise, establish, or defend our Terms of Service and other legal rights.
· Instances in which we have a good faith belief of a need to protect the safety, financial or important interest of you, us or any other person.
Except as described below, we will not share your Personal Data with unaffiliated third parties without your consent. However, we may share non-personal data, including anonymized, aggregated, or pseudonymized data in accordance with this Privacy Policy. We may share your information, including Personal Data to third parties in the following instances:
We may contract with third parties to collect or process your information or Personal Data on our behalf to provide the Services such as hosting providers to store the personal data you provide and for disaster recovery services, as well as for the performance of any contract we enter into with you, email delivery services, and analytics companies (credit card processing, sending customer service e-mails). Our agreements with such third parties require them to protect the confidentiality and security of your Personal Data and information in line with this Privacy Policy. We do not share Personal Data with any third parties so they can market to you, without your consent.
We may share your information among our subsidiaries, parents, or affiliated companies to deliver and/or improve our Services and extend you personalized experience and offers.
If we are merged with a third party, acquired, purchased (in full or in part), experiences a divestiture, reorganization, bankruptcy, or similar event, information collected under this Privacy Policy may be shared with such third party. We will notify you if this happens.
We may disclose Personal Data if we have a good faith belief we are obliged to do so to:
· Comply with a legal obligation.
· Protect and defend the rights or property of us, users of the Services, or others.
· Protect the personal safety, financial or important interest of users of the Services or the public.
· Protect against legal liability.
· Monitor compliance with & enforce our Terms of Service, policies, or community rules.
· Respond to lawful requests by public authorities, including national security or law enforcement agencies.
We implement reasonable security measures to protect the security of your information both online and offline, and we are committed to the protection of customer/user information. While we take reasonable precautions against possible security breaches of our Services and our customer databases and records, we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. Unfortunately, the transmission of information over the Internet is never completely secure. Although we strive to protect your Personal Data, we cannot guarantee the security of your data while it is being transmitted to our site; so any transmission is at your own risk. We urge you to take steps to keep your personal information safe (including your account password), and to log out of your account after use. If your account is hacked, this may lead to unauthorized access to your account, so please keep your account information secure.
Personal Data we collect, is shared with us, or is processed under this Privacy Policy may be stored in the United States or any other country in which we, our subsidiaries/affiliates, or third-party service providers operate, including through the use of cloud storage. By using the Services, you consent to the transfer of your Personal Data and non-personal data to the United States and other countries which may not offer the same level of privacy protections as the laws in your country of residence or citizenship. As a result, your information could be accessed by foreign governmental authorities, or otherwise, in accordance with applicable local laws.
You have control over the collection and use of your Personal Data. You may at any time access or correct your Personal Data, restrict collection or processing of your Personal Data, and in some cases, request the deactivation or permanent deletion of your Personal Data. To request access, correction, restriction, deactivation, or deletion of your Personal Data, contact us at support@innovationcasualty.com. Before we process any request, we may ask that you verify your identity to protect your privacy. This may include communication via the Services platform or other methods of identity verification.
Requests that are unverified, unreasonable or impractical may be rejected. To protect your account, requests for deactivation or deletion of Personal Data require additional verification. Once requests for deactivation or deletion are processed, they are permanent, and the Personal Data and account cannot be restored.
Our Services are not directed, or intended to be attractive, to children under the age of 18. We do not knowingly collect Personal Data, personal information, photos, videos, audio files, or location data of or from children under the age of 18 or knowingly use persistent identifiers to recognize children under the age of 18 over time and across different websites or online services. If you are under the age of 18, do not use our Services and do not submit any information to us. We encourage parents and legal guardians to monitor their children's Internet usage and to help enforce this Privacy Policy by instructing their children under the age of 18 never to use our Services. If you have reason to believe that a child under the age of 18 has provided Personal Data or personal information to us through our Services, please contact us at support@innovationcasualty.com , and we will take steps to delete that information as soon as possible.
This Privacy Policy applies only to Personal Data and information collected by us through your use of our Services. Third-party websites may be accessible through links when using our Services, or you may have reached, accessed, downloaded our Services through third-party websites. These third-party websites are governed by their own privacy policies and we are not liable or responsible for any content appearing on those websites or any privacy or security practices for those websites. To manage the information we receive where you use our Services, you will need to follow the instructions at that site for updating your information and changing your privacy settings. The privacy management tools for applications on Apple can be found at http://www.apple.com/privacy/manage-your-privacy/. The privacy management tools for Google can be found at https://www.google.com/safetycenter/everyone/start/. You can manage certain aspects of information collection and use by going to the settings of your (mobile) device and reviewing the permissions of each application.
We strive to retain only as much Personal Data as is necessary. When Personal Data is no longer required under this Privacy Policy, we will periodically delete it or de-identify it. When it is not commercially reasonable to delete or de-identify your Personal Data, we will remove your Personal Data from processing and securely store it until we are able to permanently delete it. Please note that we may retain information needed for legal and accounting purposes, to resolve disputes, enforce our user agreements, protect our legal rights, and comply with technical and legal requirements and constraints. For example, we may retain records pertaining to payments or customer service matters. If you have sent or posted content on the Service, we may not be able to delete it. Effective deletion may require actions on your part such as deleting apps and/or content related to the Service from your device and/or de-linking the Service from your Social Network(s) account(s). Please note that if you ask us to delete your account all your progress in the game and any unused virtual items will be permanently lost to you.
If you are located in a country in the European Union, the European Economic Area, or Switzerland, the following are the legal bases which we rely upon in processing your information.
· Contractual Necessity. This covers data used by us in order to provide you with Services that you have requested - and that we have agreed - to provide to you, such as our games, customer services;
· Legal Obligation. This covers data used by us to comply with legal obligations, such as to maintain records relating to tax or to respond to valid legal requests for certain data;
· Legitimate Interests. This covers data used by us for purposes that can be reasonably expected with your use of our Services and that we do not believe are harmful to your privacy, such as analytics to understand how our users navigate our websites and apps, to keep our websites and apps safe and secure, research and optimization of our Service, to provide a more personalized experience, marketing and advertising; and
Consent. In cases where we process data based on your consent, we will ask for your explicit consent. You may withdraw consent at any time, but that will not affect the lawfulness of the processing of your personal data prior to such withdrawal.
While you can withdraw your consent or object to certain types of processing at any time in the ways described in this Privacy Policy, please note that if you continue to use the Services after such request(s) we will resume collecting personal data about you and process it as otherwise described in this Privacy Policy. If you do not want us to collect any personal data about you at all, you should cease all game play and use of our Services.
If you are located in a country in the European Union, the European Economic Area, or Switzerland, you have certain rights in relation to the personal data we hold about you, which we detail below, and which are subject to exemptions under applicable data privacy laws. Some of these only apply in certain circumstances as set out in more detail below. We also set out how to exercise those rights. Please note that we may require you to verify your identity before responding to any requests to exercise your rights. We will respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further two months in certain circumstances). To exercise any of your rights, please send an email to support@innovationcasualty.com.
We may decline to process requests in certain circumstances, such as where requests are manifestly unfounded or excessive or requests that jeopardize the privacy of others.
In some circumstances, you may request that we erase some of the personal data we hold about you. Should you wish to have your Personal Data deleted, please contact us at support@innovationcasualty.com.
Please note that in order to process your request and ensure deletion you must delete our apps/games from your mobile devices and clear our cookies from any device where you have played our games. When we delete any information, it will be deleted from our active databases . Please note, however, we may still retain some or all of that information for other purposes such as maintaining financial records, protecting or enforcing legal rights, maintaining marketing suppression lists or for technical reasons such as maintaining technical security or our database integrity. We may also retain your information in an anonymized form. See “Data Retention Impact of Deletion” above for more information about requests for deletion.
You have a right to know what information we hold about you and, in some cases, to have the information communicated to you. If you wish to exercise this right, please contact us at support@innovationcasualty.com and let us know that you wish to exercise your right of access and precisely what information you are requesting. Please note that we may not be able to provide all the information you ask for, for instance if the information includes personal information about another person.
In some circumstances, you may request the data we process based on consent or to perform our contract with you in a structured, commonly used and machine-readable format . Your rights are subject to exemptions under applicable data privacy laws.
We also may not provide you with certain data if providing it would interfere with another’s rights (e.g. where providing the personal data we hold about you would reveal information about another person or our trade secrets or intellectual property) as permitted under applicable data protection rights.
You have the right to correct any Personal Data we have that is inaccurate. Where you request correction, please explain in detail why you believe the Personal Data we hold about you to be inaccurate or incomplete so that we can assess whether a correction is required.
You have a right to require us to stop processing the Personal Data we hold about you other than for storage purposes in certain circumstances, e.g. while we are considering whether it should be corrected or deleted or, based on your objection, whether we should permanently stop processing. Please note, however, that if we stop processing the Personal Data, we may use it again if there are valid grounds for us to do so (e.g. for the defense of legal claims or for another’s protection).
You have the right to object to our processing of data about you other than where required to perform under our Terms of Service.
You also have the right to object to our processing of data about you by emailing us at support@innovationcasualty.com if we are processing the data we hold about you on the basis of our legitimate interest and you object to such processing. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims.
If you wish to make a complaint about how we process your Personal Data, please contact us at support@innovationcasualty.com and we will endeavor to respond to your concerns. This is without prejudice to your right to launch a claim with the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.
Effective January 1, 2020, if you are a California resident, and upon your verifiable consumer request, you have the rights listed below (however, these rights are subject to certain exceptions permitted by law):
· Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months: the categories of “Personal Information” (as contemplated by the CCPA) that we have collected; the categories of sources from which we collected Personal Information; the business or commercial purpose for collecting and/or selling Personal Information; the categories of third parties with whom we share Personal of information so that we can provide our Services to you. If you ask us to delete some or all of your information, you may no longer be able to access or use the Services.
· Nondiscrimination. You are entitled to exercise the rights described above free from discriminatory practices prohibited by California law.
Exercising your rights. You may exercise your California privacy rights described above by emailing us at support@innovationcasualty.com, or the in-game contact methods from time to time. We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with reasonably sufficient detail to allow us to understand and respond to it.
Response Timing. We aim to respond to a consumer request for access or deletion within 45 days of receiving that request. If we require more time, we will inform you of the reason and extension in writing.
Personal Information that we collect, use and share. We describe the sources from which we collect Personal Information and the business and commercial purposes for which we collect this information in this Privacy Policy above.
We do not sell your Personal Information to third parties. We do share Personal Information with third parties for the business and commercial purposes described in this Privacy Policy, including without limitation advertising and marketing of our Services.
From time to time, we may update this Privacy Policy to maintain our commitment to privacy. Updates apply going forward, and never retroactively. When we make changes, we will update the date at the top of this page and make reasonable efforts to notify you if the changes are material. We encourage you to visit this page frequently to keep current with any changes.
We will provide an individual opt-out or opt-in choice before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your Personal Data, please submit a written request to support@innovationcasualty.com.
If you have any questions regarding this Privacy Policy, you may email us by any of the following means:
support@innovationcasualty.com.
Innovation Casualty Limited Address: FLAT B5, 1/F., MANNING IND.BUILDING, 116-118 HOW MING STREET, KWUN TONG, KOWLOON HONG KONG