PRIVACY POLICY

LAST UPDATED: May 24, 2024

Welcome to the game software "Home, Planet & Hunters", operated by Black Pearl Games Limited (registered at Room 605, 6/F., Easey Commercial Building, Nos. 253-261 Hennessy Road, Wanchai, Hong Kong. For inquiries related to personal information protection, contact: cs@blackpearlgame.com).

When using our software, we need to obtain some of your personal information, which includes information you provide voluntarily and information we obtain through device permissions, in order to serve you better. We fully understand the importance of your personal information and are committed to ensuring its security and reliability. To this end, we have established this Privacy Policy, which will help you understand the following:

1. How we collect and use your personal information

2. How we store your information

3. How we share, transfer, or publicly disclose your personal information

4. How we protect your personal information

5. Your rights

6. Special provisions for the personal information of minors

7. Amendments to this Privacy Policy

8. How to contact us

PLEASE CAREFULLY READ AND FULLY UNDERSTAND THE TERMS OF THIS PRIVACY POLICY BEFORE USING OUR SOFTWARE. IF YOU DO NOT ACCEPT THIS POLICY OR THE USER SERVICE AGREEMENT, YOU SHOULD NOT USE OUR SOFTWARE; LOGGING IN AND USING THE SOFTWARE OR RELATED SERVICES INDICATES THAT YOU HAVE UNDERSTOOD AND ACCEPTED THIS POLICY AND THE USER SERVICE AGREEMENT.

1. How We Collect and Use Your Personal Information

Personal information is various information related to an identified or identifiable natural person recorded electronically or by other means, excluding anonymized information. This policy will indicate in bold or uppercase the personal information that may be requested from you. Before providing any personal information to our software, please carefully consider whether such provision is appropriate and agree that your personal information can be processed for the purposes and in the manner described in this Privacy Policy.

With your consent, we collect and use your personal information to implement functionalities related to the services of this software, allowing you different choices regarding the collection and use of your personal information. However, refusing to use this information may affect your use of related functionalities.

We follow the principles of legitimacy, legality, and necessity to collect and use the personal information you provide actively or generate through the use of this software and services for the purposes described in this policy. If we wish to use your personal information for purposes not specified in this policy, or for other purposes than those for which the information was collected, we will inform you in a reasonable manner and seek your consent again before collecting and using such information.

1.1 Ensuring the Normal Operation of This Software, Maintaining Network and Operational Security

During your use of this software service, to provide you with basic functionalities and identify abnormal account statuses, understand and improve product adaptability, and ensure the network and operational security of this software service to maintain the normal functioning of the aforementioned functionalities, and protect the personal and property safety of you, other users, or the public from infringement, and better prevent phishing sites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusions, and various security risks, and more accurately identify violations of laws and regulations, we will collect, store information about the services you use and how you use them, device information, log information, account information, transaction information, and information shared by our affiliates and partners with your authorization or by legal means, and correlate these pieces of information to comprehensively judge your account and transaction risks, conduct identity verification, detect and prevent security incidents, and take necessary recording, auditing, analysis, and disposal measures as required by law:

(a) When you use this software service, we will collect your software log information: LOGIN LOGS, ITEM LOGS, OPERATION INFORMATION, LOGIN ACCOUNT, USER ID, IP ADDRESS, TYPE OF BROWSER, TELECOMMUNICATIONS OPERATOR, NETWORK ENVIRONMENT, LANGUAGE USED, ACCESS DATE AND TIME, PUSH NOTIFICATION OPEN RECORDS, and DURATION OF STAY.

(b) To ensure your normal use of this software service, maintain the normal operation of basic software functions, enhance the software experience, and ensure account security, we will receive and record information about the devices you use: OPERATING SYSTEM AND VERSION, CLIENT VERSION, DEVICE RESOLUTION, IP ADDRESS. To collect the aforementioned basic personal device information, we will request access to your device information permissions in necessary scenarios.

1.2 Account Registration, Authentication, Login

To provide you with continuous and stable services and ensure the security of your use of the software, you may need to provide YOUR REAL PHONE NUMBER OR EMAIL ADDRESS for registration and login. During registration, we will send a verification code to confirm the validity of your identity. Phone numbers and email addresses are sensitive information, and we will set clear indications to prompt you to fill them in.

You can also bind third-party accounts (such as Apple, Google, Facebook, QQ, WeChat, etc.) to log in to this software. If you log in using a third-party account, we will collect your THIRD-PARTY ACCOUNT'S NICKNAME AND AVATAR for displaying user information.

Depending on the laws and regulations of different countries and regions, you may need to provide YOUR REAL IDENTITY INFORMATION (REAL NAME, ID NUMBER, PHONE NUMBER) to complete real-name verification. This information is sensitive, and during the registration process or when you use features or services that require identity authentication, we will set clear indicators to remind you and obtain your explicit consent based on your input to obtain this information. If you do not provide this information, you will not be able to complete account registration or use certain features (such as recharging), but you can continue to use other services of the software.

1.3 Payments and Consumption

When you use the recharge and consumption functions of this software, during the payment process, we need to access the relevant payment tools on your device and COLLECT YOUR THIRD-PARTY PAYMENT ACCOUNT INFORMATION (INCLUDING BUT NOT LIMITED TO APPLE PAY, GOOGLE PAY, ALIPAY, WECHAT OR OTHER FORMS OF PAYMENT ACCOUNT INFORMATION), as well as your PURCHASE AND CONSUMPTION RECORDS, to facilitate subsequent service inquiries into your transaction records. We will do our utmost to protect the security of your virtual items. This information is sensitive, and we will obtain your explicit consent before collecting this information. Collecting the aforementioned information is necessary to implement the consumption functions of the software; otherwise, the transaction cannot be completed.

1.4 Interactions, Publications, Product/Service Marketing Promotions, and Satisfaction Survey Services

(a) When you use the services of this software to upload and/or publish information and engage in related interactive activities (speaking, posting, commenting, sharing, collecting, rewarding), we will collect the information you upload, post, or generate, and use YOUR NICKNAME, AVATAR, USER ID, AND POSTED CONTENT for display purposes. Please be aware that if the information you publicly post includes your personal information or sensitive personal information, since such information may be collected and used by others, consider carefully before posting. If your post involves another person's personal information, you should obtain their consent before posting. If you find that someone is improperly collecting or using your information, you can contact us through the feedback channels listed in the "How to Contact Us" section of this policy.

(b) If you copy information from the product to share or receive shared information in the product, participate in related activities, we need to access your CLIPBOARD to read SHARING CODES, PASSWORDS, LINKS, REDEMPTION CODES, AND OTHER RELEVANT INFORMATION in it to implement functions or services such as sharing information, obtaining benefits, and participating in activities. Your clipboard information will only be processed on your device, and we will only read information related to our services to complete relevant commands; we will not store your clipboard information. Unless otherwise stated and your consent obtained, we will not collect any other unrelated information from your clipboard.

(c) When you participate in marketing promotions and satisfaction surveys within the software product, depending on the type and purpose of the survey activity, upon your active completion, we may collect one or more of the following information: your name, gender, age, occupation, communication address, contact information, and other information you actively fill out, specifically as detailed on the activity page and the content of the questionnaire you receive.

1.5 Device Permission Calls

You understand and agree that during the use of the product, we will request access to your system permissions (the specific permissions vary depending on the model and system version of the device you use) to enable the collection and use of information related to these permissions. Before enabling permissions, we will inform you of the purpose of enabling the permissions and seek your consent. If you do not agree, we will not enable the related permissions, nor can we provide the services corresponding to those permissions.

(a) Once you agree to access storage permissions, you allow us to access your storage space, enabling you to download, upload, and save content or, through caching, implement corresponding services and functions such as publishing/sharing information content, editing/modifying avatars, customer service communication, and reporting/complaints.

1.6 Distribution of Physical Prizes

When you participate in various activities organized by this software and win physical prizes, we will need you to provide YOUR NAME, PHONE NUMBER, NICKNAME, AND ADDRESS to distribute the physical prizes to you. If you refuse to provide this information, we cannot distribute the corresponding physical prizes to you, but you can continue to use other services of this software.

1.7 Customer Service

If you contact our customer service, we may need you to provide necessary personal information for identity verification to ensure the security of your account. To provide services based on your needs, after your authorization, human customer service personnel need to query or verify your relevant information within the scope of your authorization. We will take technical and managerial measures to ensure the security and confidentiality of your information and use it within the necessary scope. We may also store your contact information (your phone number, email, social media accounts, or other contact methods you use or provide), your communication records and content with us, and other necessary information to provide and record customer service.

1.8 Exceptions to Obtaining Authorization and Consent

According to relevant laws and regulations, in the following situations, processing your information does not require your authorization or consent:

(a) Necessary for the establishment or fulfillment of a contract to which you are a party;

(b) Necessary for compliance with legal obligations or duties;

(c) Necessary to respond to public health emergencies or to protect the life, health, and property safety of you or others in emergency situations;

(d) For legitimate news reporting or public opinion supervision within a reasonable scope;

(e) Involves handling personal information that you have made public or is already legally public;

(f) Other circumstances stipulated by laws and regulations.

1.9 Third-Party Features

When using certain specific functions or services of the software, we may use software service tools provided by third-party service providers with the necessary business qualifications and capabilities (referred to as "SDK") to serve you. These SDKs may collect and use your personal information, which we will obtain after your authorization and consent. The software will conduct strict security checks on SDK or similar applications and require third-party service manufacturers to adopt stringent data protection measures to effectively safeguard your lawful rights.

Please be particularly aware that if we intend to use your personal information for purposes not specified in this policy or to collect additional personal information not mentioned, we will obtain your consent through page prompts, pop-ups, or other methods as required by law. If information cannot be used alone or in combination with other information to identify your personal identity, it does not constitute personal information legally; however, during the period of combined use, if your information can be identified alone or in combination with other information or we use data that cannot be associated with any specific personal information together with other personal information of yours, such information will be treated and protected as your personal information according to this privacy policy.

2. How We Store Your Information

2.1 Modes of Information Storage

We store your information securely, including local storage (e.g., using the APP to cache data), databases, and server logs.

2.2 Duration of Information Storage

As long as you use this software and have registered an account with it, we need to continuously record and store your personal information to provide you with software services, until you cancel your account. We commit to always keeping the storage duration of your personal information within a reasonable and necessary limit. For personal information that exceeds the period required to achieve the purposes of providing software services or is prescribed by laws and regulations, we will immediately delete or anonymize such information.

2.3 Handling After Termination of Operations

In the event that our products or services cease to operate, we will inform you through methods such as push notifications and announcements, and within a reasonable period, delete or anonymize your personal information, except for content that must be retained for a certain period as stipulated by relevant laws and regulations.

2.4 International Data Transfers

The information we collect may be transferred to countries/regions outside your country/region for the purposes specified in this privacy policy. You understand that these countries/regions (including South Korea, Japan, and the United States) may not provide the same level of data privacy protection as the European Union/European Economic Area or your home country. By explicitly agreeing to this policy, you expressly consent to the transfer of your information to these countries/regions, which is crucial for providing our services and fulfilling the terms of service and end-user license agreement.

3. How We Share, Transfer, or Publicly Disclose Your Personal Information

3.1 Sharing

We conduct personal information security impact assessments in advance and adopt effective measures to protect the rights of personal information subjects based on the assessment results. We are committed to confidentiality obligations and will not share any of your information, except in the following circumstances:

(a) With explicit consent obtained: We will inform you in advance about the purpose of sharing personal information, the types of data recipients, and possible consequences, and after obtaining your explicit consent, we will share your personal information with other parties;

(b) We will share your personal information externally according to legal or regulatory requirements, or as mandated by government authorities; if your personal information involves sensitive information, we will also inform you of the types of sensitive personal information involved, the identity and data security capabilities of the data recipients, and obtain your explicit consent before sharing;

(c) Necessary for maintaining the legal rights, public interest, property, or safety of our company, our partners, other users, or the public;

(d) Sharing with trusted authorized partners: To provide you with more comprehensive and high-quality products and services, as well as for the operational needs of the software itself, our services such as third-party account registration, sharing, push notifications, crash collection, live streaming, etc., are provided by authorized partners;

(e) Necessary for handling disputes or conflicts between you and others;

(f) Necessary if you violate relevant laws, regulations, or the related agreements or rules of this software, requiring us to disclose to third parties.

3.2 Transfer

Unless we receive your explicit consent, we will not transfer your personal information to any company, organization, or individual. Moreover, in the event of mergers, acquisitions, or bankruptcy liquidations, personal information may be involved in a transfer; in such cases, we will require the new entity that holds your personal information to continue to be bound by this privacy policy, or we will ask the company or organization to seek your authorization and consent anew. If there is bankruptcy without a successor, we will delete the data.

3.3 Public Disclosure

Except with your explicit consent, we will not publicly disclose your personal information. Additionally, based on legal processes, litigation, or mandatory requirements from government authorities, we may disclose your personal information to competent authorities. We ensure that in such circumstances, we verify the authenticity of the disclosure request and the requester, and when necessary, we require the requester to provide corresponding valid legal documents and take security measures compliant with legal and industry standards to protect the disclosed information.

3.4 Exceptions for Sharing, Transferring, or Publicly Disclosing Personal Information

3.4.1 Please be fully aware that in the following situations, sharing, transferring, or publicly disclosing your personal information does not require your authorization or consent:

(a) Directly related to national security or national defense security;

(b) Directly related to public safety, public health, or significant public interests;

(d) When it is difficult to obtain consent from the person to protect the significant legal rights and interests of the subject of personal information or other individuals;

(e) Personal information that the subject has disclosed to the public;

(f) Collecting personal information from legally public information, such as lawful news reports, government information disclosure channels;

(g) Necessary measures have already been taken in response to violations of legal regulations or breaches of agreements with our software, which you have committed;

(h) Necessary for contract performance requested by the subject of personal information;

(i) Necessary for maintaining the secure and stable operation of the provided products or services, such as detecting and handling product or service faults;

(j) The personal information controller is a news unit and the collection is necessary for lawful news reporting;

(k) The personal information controller is an academic research institution, conducting statistical or academic research in the public interest is necessary, and when providing academic research or descriptive results externally, the results containing personal information are de-identified;

(l) Other circumstances stipulated by laws and regulations.

3.4.2 Moreover, according to relevant standards, sharing, transferring de-identified personal information that ensures data recipients cannot reconstruct or re-identify the subject of personal information does not constitute external sharing, transferring, or public disclosure of personal information, and the storage and processing of such data will not require additional notification and consent from you.

4. How We Protect Your Personal Information

4.1 We employ industry-standard security measures to protect the personal information you provide and to prevent it from unauthorized access, public disclosure, use, modification, or loss. We take all reasonable and feasible measures to protect your personal information. For example, data exchanged between your device and our servers is protected by SSL encryption; we use encryption technology to ensure data confidentiality; we employ trusted protection mechanisms to prevent data from malicious attacks; we deploy access control mechanisms to ensure that only authorized personnel have access to personal information; and we organize security and privacy protection training courses to enhance employees' awareness of the importance of protecting personal information.

4.2 We take all reasonable and feasible measures to ensure that no irrelevant personal information is collected. We retain your personal information only for the duration necessary to fulfill the purposes outlined in this policy, unless an extended retention period is required or permitted by law.

4.3 The internet is not an absolutely secure environment, and electronic mail, instant messaging, and other communication methods with users are not encrypted. We strongly advise against sending personal information via these methods. Please use complex passwords to help us ensure the security of your account. We also strive to ensure the security of any information you send to us.

4.4 In the unfortunate event of a personal information security incident, we will inform you promptly in accordance with the requirements of laws and regulations: the basic circumstances and potential impact of the security incident, measures we have taken or will take to address the incident, suggestions for you to independently prevent and reduce risk, and remedial measures for you. We will inform you of the incident-related circumstances by email, letter, phone, push notification, or other means. If it is difficult to inform personal information subjects individually, we will use reasonable and effective methods to make an announcement. Additionally, we will proactively report the handling of personal information security incidents to the regulatory authorities as required.

5. Your Rights

In accordance with the provisions of relevant laws and regulations, as well as common practices in other countries and regions, we ensure that you have the following rights regarding your personal information:

5.1 Access to Your Personal Information

You have the right to access your personal information, except in cases exempted by law. If you wish to exercise your data access right, you can consult, edit the personal information provided by this software, payment information, change your password, add security information, etc., on your personal information page.

If you need to access other personal information used by this software, we will provide it under reasonable requests. You can contact us through the customer service contact methods we have made public, and we will respond within fifteen days after verifying your identity.

5.2 Correction of Your Personal Information

If you find that your personal information is incorrect or incomplete, you can correct the personal information you provided through the methods listed in 5.1. If you cannot correct your personal information through the aforementioned methods, you can contact us through our publicly available customer service contacts, and we will respond within fifteen days after verifying your identity.

Please note: If you have completed real identity verification through the identity authentication function, your real identity is bound to the authenticated account and cannot be changed unless you provide valid evidence that your identity authentication information is incorrect.

5.3 Change the Scope of Your Authorization and Consent

You can grant or withdraw your authorization and consent for us to process your personal information at any time. You can perform the relevant operations on the settings page of this software or operate in the system of your personal device to grant or withdraw the authorization and consent for various permissions; the display and closure of permissions may vary across different devices, for which you should refer to the explanations or guidance provided by the device and system developers. Please understand that each function of this software requires the corresponding collection of necessary personal information to function (see Part 1 of this policy), and withdrawing your authorization for processing this information may result in you being unable to use the corresponding software function or software.

Special note: When you withdraw relevant authorization, we will no longer process the corresponding personal information. However, please understand that your decision to withdraw consent will not affect the processing of personal information based on your authorization before the withdrawal.

5.4 Deletion of Your Personal Information

In the following situations, you can request us to delete your personal information; you can contact us through the customer service contacts we have made public, and we will respond within fifteen days after verifying your identity:

5.4.1 If our handling of personal information violates laws and regulations;

5.4.2 If we collect and use your personal information without obtaining your consent;

5.4.3 If our handling of personal information violates the agreement with you;

5.4.4 If you believe we have violated legal regulations or our agreement in sharing, transferring, or publicly disclosing your personal information to a third party.

If we decide to respond to your deletion request, we will also notify entities that have obtained your personal information from us to delete it promptly, unless otherwise stipulated by law or these entities have obtained your independent authorization.

When you delete information from our services, we may not immediately delete corresponding information from backup systems, but it will be deleted when the backup is updated. Special note: Deleting certain personal information may lead to your inability to use this software or certain functions/services of this software. If deleting your personal information results in your inability to continue using this software, you may initiate the account cancellation process.

5.5 Account Cancellation

If you need to cancel your account, you can contact us through our publicly available customer service contacts, and we will provide you with account cancellation services after verifying your identity and confirming that you meet the cancellation conditions.

If you need to cancel your account registered through official channels, you may send an email to our customer service at cs@blackpearlgame.com to request account cancellation.

If you need to cancel your account registered through channel partners, you need to apply to cancel the account or revoke the authorization to log into our software through that channel. Canceling an account means that we will cease providing services through the channel partner's account, and once the account you use to log into our service is canceled, it cannot be restored. Please back up all relevant information and data before proceeding.

To provide you with more convenient cancellation methods, we will continue to optimize our products and inform you through in-software notifications.

After canceling an account, we will stop providing you with products or services, permanently delete your account, and your registration information, all data within your account, and your usage traces will be deleted or anonymized, except for content that must be retained for a certain period as stipulated by relevant laws and regulations.

5.6 Obtaining a Copy of Personal Information

You have the right to obtain a copy of your personal information. You can contact us through the customer service contacts we have made public, and we will respond within fifteen days after verifying your identity.

5.7 Restrictions on Automatic Decision-Making in Information Systems

In some functions, we may make decisions based solely on non-human automatic decision mechanisms, such as information systems and algorithms. If these decisions significantly affect your legal rights, you can contact us through the customer service contacts we have made public, and we will review and handle them according to relevant regulations.

5.8 Responding to Your Requests

For security reasons, you may need to provide a written request or otherwise prove your identity. We may first ask you to verify your identity before processing your request. We will respond within fifteen days after receiving your request.

In the following situations, in accordance with legal and regulatory requirements, we will not be able to respond to your requests:

(a) Related to your fulfillment of obligations stipulated by laws and regulations;

(b) Directly related to national security or national defense security;

(d) Directly related to criminal investigations, prosecutions, trials, and the execution of judgments;

(e) When it is difficult to obtain your consent to protect the significant legal rights and interests of you or other individuals;

(f) Responding to your request would cause serious harm to the legal rights of you or other individuals or organizations;

(g) Involving trade secrets;

(h) We have sufficient evidence to indicate that you have malicious intent or are abusing rights.

5.9 Accessing the Privacy Policy

You can view the entire content of this privacy policy in the software's "Settings - Privacy Agreement" section.

6. Special Provisions for the Personal Information of Minors

Our software and services are primarily aimed at adults. We do not recommend the use of our software by users under the age of 18. If you are under 14 years old, PLEASE READ THE "CHILDREN'S PRIVACY PROTECTION POLICY" UNDER THE SUPERVISION OF A GUARDIAN, AND USE OUR SOFTWARE ONLY AFTER OBTAINING YOUR GUARDIAN'S CONSENT AND PROVIDING YOUR PERSONAL INFORMATION AS A REGISTERED USER. ADOLESCENTS AGED 14 TO 18 SHOULD READ AND AGREE TO THIS PRIVACY POLICY AND INFORM THEIR GUARDIANS TO READ IT AS WELL, AND CONTACT US WHEN REVOKING SERVICES OR RAISING ISSUES.

If your guardian does not consent to your use of our software, services, or to providing us with information according to this policy, please immediately stop using our services and notify us promptly; we will quickly delete relevant data.

Without the consent of a guardian or as permitted by applicable law, we do not intentionally collect or sell the personal information of children under the age of 14 (or other age as stipulated by applicable laws). If we discover that we have collected personal information from a child under the applicable age through our services, we will delete this information and any associated accounts. If you believe that we have collected information from a child under the applicable age, please contact us.

7. Amendments to This Privacy Policy

We may revise this Privacy Policy from time to time; such revisions form part of this policy. Without your explicit consent, we will not reduce your rights under this policy. We will post any changes to this policy on this page.

For significant changes to this privacy policy, we will notify you through a pop-up notice when updating this agreement; you must accept these changes to continue using our software. If you do not agree with the revised privacy policy, you have the right and should immediately stop using our software.

Significant changes referred to in this policy include, but are not limited to:

(a) Significant changes in our service model, such as changes in the purposes for processing more personal information, types of personal information processed, and how personal information is used;

(b) Significant changes in our ownership structure, organizational structure, etc., such as business adjustments, bankruptcy mergers, and acquisitions leading to changes in owners;

(d) Significant changes in your rights to participate in the processing of personal information and how to exercise those rights;

(e) Changes in the department responsible for handling personal information security, contact methods, and complaint channels;

(f) When a personal information security impact assessment report indicates the existence of high risks.

We will also archive older versions of this policy for your reference.

8. How to Contact Us

If you have any questions, comments, or suggestions regarding this Privacy Policy, please email us at [cs@blackpearlgame.com] or contact our customer service staff through the feedback function built into the software.

If you have any concerns about the security of your personal information, please email [cs@blackpearlgame.com] to contact our personal information protection staff.

For security reasons, we may first ask you to verify your identity before handling your request. You may need to provide a written request or otherwise prove your identity.

We will review the issues involved as soon as possible. Generally, we will respond within fifteen days after verifying your identity.