Privacy Policy

Welcome to CODEPULSE INTERACTIVE LIMITED (hereinafter referred to as "we", "us", "our", or "CODEPULSE"). We respect your privacy and are committed to protecting your personal data. As a company incorporated in the United Kingdom (Registered Address: 1ST FLOOR FRONT 36 GERRARD STREET LONDON ENGLAND W1D 5QA), we are dedicated to complying with the Data Protection Act 2018, the United Kingdom General Data Protection Regulation ("UK GDPR"), and other applicable privacy laws and regulations in the jurisdictions where we operate.

This Privacy Policy (hereinafter referred to as "this Policy") aims to inform you in detail how we collect, use, store, share, and protect your personal data when you visit our website, play our H5 games, use our mobile applications ("Apps"), or use other related services provided by us (collectively referred to as the "Services"). Furthermore, this Policy explains your rights as a data subject and how you can exercise those rights.

Please read this Policy carefully and ensure that you fully understand it before using our Services. By commencing the use of our Services, you acknowledge that you have understood and agreed to the contents of this Policy. If you do not agree with any term of this Policy, please discontinue the use of our Services immediately.

TABLE OF CONTENTS

Definitions and Interpretation

Data Controller and Contact Information

The Types of Data We Collect

Methods of Data Collection

Lawful Basis for Processing Data

How We Use Your Data

Use of Cookies and Similar Technologies

Data Sharing and Disclosure

International Data Transfers

Data Storage and Retention Period

Data Security Measures

Your Rights and Choices

Protection of Minors

Payment Information Processing

Third-Party Links and Services

Marketing and Communications

Updates and Amendments to this Policy

Dispute Resolution and Governing Law

1. DEFINITIONS AND INTERPRETATION

To ensure the clarity and accuracy of this Policy, the following terms are strictly defined:

"Personal Data" or "Personal Information": Means any information relating to an identified or identifiable natural person ("Data Subject"). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

"Usage Data": Refers to data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit, game clearance records, clickstream data).

"Processing": Means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

"Data Controller": Means the natural or legal person, public authority, agency, or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data. Under this Policy, CODEPULSE INTERACTIVE LIMITED is the Data Controller.

"Data Processor": Means a natural or legal person, public authority, agency, or other body which processes personal data on behalf of the Data Controller.

"Service": Refers to the websites, H5 games, mobile applications, and related technical support services operated by CODEPULSE.

"User" or "You": Refers to the individual using our Service, who corresponds to the Data Subject.

"Cookies": Small data files stored on the User's device (computer or mobile device).

2. DATA CONTROLLER AND CONTACT INFORMATION

The Data Controller for the Services is:

Company Name: CODEPULSE INTERACTIVE LIMITED

Registered Address: 1ST FLOOR FRONT 36 GERRARD STREET LONDON ENGLAND W1D 5QA

Email: [email protected]

If you have any questions, comments, or suggestions regarding this Privacy Policy, or if you wish to exercise any of your data rights, please contact our Data Protection Officer (DPO) or privacy team via the email address provided above. We will respond to your request within the timeframe prescribed by law.

3. THE TYPES OF DATA WE COLLECT

To provide you with a high-quality, personalized, and secure gaming experience, we may collect and process the following categories of data. Please note that the specific scope of collection depends on the Service functions you use and your interactions with us.

3.1 Data You Voluntarily Provide

When you register an account, contact customer service, participate in surveys, or purchase virtual goods, you may provide us with:

Identity Data: Such as username, nickname, date of birth (used for age verification).

Contact Data: Such as email address, telephone number.

Account Credentials: Such as passwords, password hint questions, and answers (stored in encrypted form).

Customer Support Data: Chat logs, email content, screenshots, and fault descriptions provided when you communicate with our customer support team.

User-Generated Content (UGC): Text, voice, images, and other content posted by you in in-game chats, forums, or message boards.

3.2 Data We Automatically Collect

When you access or use our Services, our systems automatically record certain information:

Device Data: Including device model, operating system version, unique device identifiers (such as IMEI, Android ID, IDFA, IDFV, etc.), screen resolution, mobile network information, device settings, language settings, and time zone.

Log Data: Including Internet Protocol (IP) address, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamps, and clickstream data.

Game Gameplay Data: Including game progress, level completion status, scores, achievements, acquisition and consumption records of in-game virtual items, session duration, and login frequency.

Location Data: Coarse geographic location information based on IP address (Country/City level) to allow us to provide localized services. We generally do not collect precise GPS geolocation unless you explicitly authorize it within specific features.

3.3 Data From Third Parties

We may obtain information about you from third-party partners, including:

Social Media Platforms: If you choose to log in to our Services via third-party social platforms (such as Facebook, Google, Apple, etc.), we will collect your public profile, friends list (if applicable), and email address, subject to your privacy settings on that platform.

Advertising and Analytics Partners: We may receive data regarding ad attribution and user profiling from advertising networks or data analytics service providers to optimize our marketing campaigns.

Payment Processing Partners: When you conduct a transaction, we receive transaction status confirmations, transaction IDs, and related information from payment service providers, but we do not directly collect or store your full credit card numbers or sensitive bank account information.

4. METHODS OF DATA COLLECTION

We collect data through the following channels:

Direct Interactions: Data you enter directly when filling out forms, registering accounts, subscribing to newsletters, or requesting support.

Automated Technologies: As you interact with our website or Apps, we automatically collect Technical and Usage Data utilizing Cookies, server logs, SDKs (Software Development Kits), and similar technologies.

Third-Party Sources: As mentioned above, we obtain supplementary data from lawful third-party sources via API interfaces, SDK integration, or data exchange protocols.

5. LAWFUL BASIS FOR PROCESSING DATA

In accordance with the UK GDPR and relevant laws, we only process your personal data where we have a lawful basis to do so. These bases include:

Performance of Contract: Processing data is necessary to provide the Services to you and to fulfill the user agreement between us and you (for example, ensuring the game runs correctly, processing your purchases of virtual items).

Legitimate Interests: For our legitimate commercial interests (such as improving services, ensuring network security, preventing fraud, conducting data analysis, and marketing), provided that these interests are not overridden by your fundamental rights and freedoms.

Legal Obligation: We need to process data to comply with applicable laws and regulations (for example, tax compliance, anti-money laundering regulations, cooperating with law enforcement investigations).

Consent: In specific circumstances (such as sending direct marketing emails, accessing your precise geolocation, or reading your contact list), we will seek your explicit consent in advance. You have the right to withdraw your consent at any time.

6. HOW WE USE YOUR DATA

We use the collected personal data for the following specific purposes:

6.1 Service Provision and Maintenance

To create and manage your game account. To allow you to use Service features, including entering the game world, saving progress, and restoring data. To process your transaction requests and deliver virtual goods or value-added services. To provide technical support and respond to your inquiries and complaints.

6.2 Service Improvement and Optimization

To analyze user behavior and trends to improve game mechanics, interface design, and user experience. To conduct internal research and development, and to test new features and products. To fix software bugs and resolve application crash issues.

6.3 Security and Compliance

To detect, prevent, and combat fraud, cheating, hacking, or other illegal activities. To verify user identity and ensure account security. To comply with legal and regulatory requirements and respond to inquiries from regulatory authorities.

6.4 Marketing and Personalization

To send you updates regarding our Services, security alerts, and administrative messages. To display personalized advertisements or send promotional information based on your preferences (subject to your consent). To evaluate the effectiveness and reach of advertising campaigns.

7. USE OF COOKIES AND SIMILAR TECHNOLOGIES

We and our third-party partners use technologies such as Cookies, Web Beacons, Tags, and Scripts.

7.1 Types of Cookies

Strictly Necessary Cookies: These are essential for the operation of the website or game and cannot be switched off in our systems. They are usually only set in response to actions made by you (such as logging in, filling in forms).

Performance/Analytical Cookies: These help us count visits and traffic sources so we can measure and improve the performance of our Services.

Functional Cookies: These allow us to provide enhanced functionality and personalization (such as remembering your language choice).

Targeting/Advertising Cookies: These may be set by our advertising partners to build a profile of your interests and show you relevant adverts on other sites.

7.2 Controlling Cookies

You can manage or refuse Cookies at any time through your browser settings. Please note that if you disable "Strictly Necessary Cookies," some parts of our Services may not function properly. For a specific list of Cookies we use and detailed management methods, please refer to our Cookie Policy.

8. DATA SHARING AND DISCLOSURE

Unless stated otherwise in this Policy or required by law, we do not sell your Personal Data. We may share your data in the following circumstances:

8.1 Service Providers

We partner with trusted third-party service providers who perform partial business functions on our behalf. These service providers include:

Cloud Hosting Providers: For data storage and server hosting.
Payment Gateways and Processors: To assist in processing transactions via credit cards, debit cards, and other lawful payment methods.
Customer Support Tool Providers: For managing user tickets and feedback.
Data Analytics and Ad Attribution Partners: To assist us in understanding user behavior.

All service providers are bound by strict Data Processing Agreements (DPAs), may only process data in accordance with our instructions, and must implement appropriate security measures.

8.2 Affiliates

We may share data within the corporate group of CODEPULSE INTERACTIVE LIMITED, its subsidiaries, or affiliates for management and analytical purposes.

8.3 Legal Requirements and Law Enforcement

If we believe in good faith that disclosure is necessary to comply with legal obligations, court orders, or legal processes, or to protect our rights, property, or safety, or to protect the safety of users or the public, we may disclose your data to law enforcement agencies, regulators, or legal counsel.

8.4 Business Transfers

If we are involved in a merger, acquisition, asset sale, bankruptcy, or reorganization, your Personal Data may be transferred to the relevant third party as part of the transferred assets. We will notify you of any change in ownership or uses of your Personal Data via email or a prominent notice on our website.

9. INTERNATIONAL DATA TRANSFERS

Due to the global nature of our business, your Personal Data may be transferred to, stored in, or processed in jurisdictions other than your country of residence. Data protection laws in these countries may differ from those in your country.

Specifically, as a company registered in the UK, we store data in the United Kingdom, the European Economic Area (EEA), and other regions where our servers are located (such as the United States, Singapore, etc.).

When we transfer Personal Data outside the UK or the EEA, we implement appropriate safeguards to ensure that your data receives an equivalent level of protection, including:

Adequacy Decisions: Transferring to countries recognized by the UK Government or the European Commission as providing an adequate level of data protection.

Standard Contractual Clauses (SCCs) / IDTA: Entering into standard data protection clauses approved by the European Commission or the UK Information Commissioner's Office (ICO) with the recipient.

Other Safeguards: Implementing supplementary technical measures such as encryption and anonymization.

10. DATA STORAGE AND RETENTION PERIOD

We retain your Personal Data only for as long as is necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law.

Criteria for determining retention periods include:

The length of time we have an ongoing relationship with you and provide Services to you.

Whether there is a legal obligation to which we are subject (for example, tax laws require transaction records to be kept for a certain number of years).

Whether retention is advisable considering our legal position (such as regarding applicable statutes of limitations, litigation, or regulatory investigations).

Once the retention period expires, we will securely delete, anonymize, or destroy your Personal Data.

11. DATA SECURITY MEASURES

We utilize industry-standard technical, administrative, and physical security measures to protect your Personal Data from unauthorized access, loss, misuse, disclosure, or alteration.

These measures include but are not limited to:

Data Encryption: Using SSL/TLS encryption technology during transmission and AES encryption for data at rest.

Access Control: Strictly limiting access to Personal Data by employees and contractors, following the "principle of least privilege."

Security Audits: Regularly conducting internal and external security vulnerability scans and penetration tests.

Network Firewalls and Intrusion Detection Systems.

Physical Security: Data centers are equipped with 24/7 monitoring and strict physical access controls.

While we strive to protect your data, please understand that no method of transmission over the Internet or method of electronic storage is 100% secure. If you suspect that your account security has been compromised, please contact us immediately at [email protected].

12. YOUR RIGHTS AND CHOICES

Under applicable laws (including the UK GDPR and EU GDPR), you have extensive rights as a Data Subject:

Right to Access: You have the right to request confirmation as to whether we process your Personal Data and to obtain a copy of that data and related processing information.

Right to Rectification: If your Personal Data is inaccurate or incomplete, you have the right to request that we correct or supplement it.

Right to Erasure (Right to be Forgotten): Under certain conditions (such as when data is no longer needed for the original purpose or you withdraw consent), you have the right to request the deletion of your Personal Data.

Right to Restriction of Processing: In specific circumstances (such as during a period when you contest the accuracy of the data), you have the right to request that we suspend the processing of your data.

Right to Data Portability: You have the right to receive your Personal Data in a structured, commonly used, and machine-readable format and have the right to transmit those data to another controller.

Right to Object: You have the right to object to our processing of your data based on legitimate interests, or to object to the use of your data for direct marketing, based on your particular situation.

Rights related to Automated Decision Making: You have the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal effects concerning you or similarly significantly affects you.

Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

How to Exercise Your Rights:

You can submit your request by sending an email to [email protected]. To protect your privacy and security, we may need to verify your identity before processing your request. We typically respond within one month of receiving a request. If the request is complex, we may extend the response period and will notify you of the reason for the extension.

13. PROTECTION OF MINORS

Our Services are primarily intended for adult users. We do not knowingly collect Personal Data from children under the age of 16 (or other minimum age defined by your jurisdiction).

Age Restriction: If you have not reached the legal age, please do not register an account or provide any personal information.

Parental Control: We encourage parents or guardians to guide minors in their use of the Internet and to monitor their online activities.

Data Deletion: If we discover that we have collected Personal Data from a child without verified parental consent, we will take steps to delete that information as soon as possible. If you believe we might hold any information from or about a child, please contact us immediately.

14. PAYMENT INFORMATION PROCESSING

When you make a purchase within our Services, all financial transactions are processed by third-party payment processors that are PCI-DSS (Payment Card Industry Data Security Standard) compliant.

Non-Sensitive Storage: CODEPULSE INTERACTIVE LIMITED does not collect, store, or access your full credit card number, bank account passwords, or CVV codes.

Partners: Our payment channels include, but are not limited to, globally recognized credit card networks (such as Visa, MasterCard), bank transfer service providers, and lawful digital wallet providers. Please note that we rigorously screen our partners to ensure compliance. We strictly prohibit the use of any unauthorized or high-risk payment methods in our business operations.

Transaction Records: For order fulfillment, customer service, and tax purposes, we retain basic transaction information (such as order ID, transaction time, item purchased, amount, and transaction status returned by the payment channel).

15. THIRD-PARTY LINKS AND SERVICES

Our Services may contain links to third-party websites, plug-ins, or applications (e.g., advertisement links). Clicking on those links or enabling those connections may allow third parties to collect or share data about you.

We do not control these third-party websites and are not responsible for their privacy statements or data processing practices. When you leave our Services, we encourage you to read the privacy policy of every website you visit. This Privacy Policy applies solely to data collected by us.

16. MARKETING AND COMMUNICATIONS

Service Notifications: We may send you important announcements related to the Service (such as system maintenance, security alerts, terms updates). You generally cannot opt-out of these communications as they are integral to the use of the Service.

Marketing Messages: Only where you have opted-in or where it fits within legitimate interests, will we send you promotional information via email or in-app messages.

Unsubscribing: You can opt-out of receiving marketing communications at any time by clicking the "unsubscribe" link at the bottom of marketing emails or by adjusting your notification preferences in your account settings.

17. UPDATES AND AMENDMENTS TO THIS POLICY

We may update this Privacy Policy from time to time to reflect changes in our business, legal or regulatory requirements, or technological advancements.

Notification Method: For material changes to this Policy, we will notify you via significant means such as email, website announcements, or in-app pop-ups.

Effectiveness: The updated Privacy Policy will be effective as of the date of publication (unless otherwise stated). Your continued use of our Services after the effective date of the updated Policy constitutes your acceptance of the revised Policy. We encourage you to review this page periodically for the latest information on how we protect your information.

18. DISPUTE RESOLUTION AND GOVERNING LAW

The interpretation of this Privacy Policy and the resolution of any disputes shall be governed by the laws of England and Wales, without regard to its conflict of law principles.

Amicable Negotiation: In the event of any dispute, the parties shall first attempt to resolve it through amicable negotiation.

Regulatory Complaint: If you believe that our processing of your Personal Data infringes data protection laws, you have the right to lodge a complaint with the relevant data protection supervisory authority. In the UK, the supervisory authority is the Information Commissioner's Office (ICO). We would, however, appreciate the chance to deal with your concerns before you approach the regulator, so please contact us in the first instance at [email protected].

CODEPULSE INTERACTIVE LIMITED

Address: 1ST FLOOR FRONT 36 GERRARD STREET LONDON ENGLAND W1D 5QA

Contact Email: [email protected]

By using our Services, you acknowledge that you have read, understood, and agree to be bound by all terms and conditions set forth in this Privacy Policy.