Privacy Policy

NETDRAGON WEBSOFT (HONG KONG) LIMITED, (herein "we" or "us", "ours"), including its subsidiaries and affiliates, understands the importance of protecting your personal information (the "Personal Information"). We have adopted this privacy policy (the "Policy") to explain how we collect, use, process, store and share the Personal Information that provide to us or we collect when you use our website (/), software applications, games or any other services provided by us (the "Service and Software").

We collect, use, process, store and transfer your Personal Information in accordance with applicable data protection legislation, including but not limited to the (EU) General Data Protection Regulation ("GDPR") and applicable national data protection legislation ( together with GDPR, "Applicable Laws"). Wherever we talk about Personal Information below, we mean any information that can either by itself identify you as an individual or that can be connected to you indirectly by linking it to your Personal Information. We also collect, use, process, store and transfer anonymised data, whether aggregated or not, to analyse and generate reports related to usage patterns, spending habits, demographics of users, etc. As an individual is not or no longer identifiable from such anonymous data, the use of such data will not be governed by this Policy.

You agree that we will engage other third parties and may transfer your Personal Information to such third parties in order to fulfil our purposes and obligations as set out in this Policy. You acknowledge that some of these third parties may be located outside the country of your residence where there may not have as strict privacy legislation as yours. We will only transfer your Personal Information to such countries if we are allowed to do so, please see section D for more information.

By downloading, installing, registering, accessing and/or using our Service and Software, you consent to our collection and use of your Personal Information in accordance with this Policy. IF YOU DO NOT AGREE TO THE POLICY, PLEASE DO NOT PROVIDE YOUR INFORMATION WHEN REQUESTED AND SHOULD REFRAIN FROM USING OUR SERVICE AND SOFTWARE.

A. COLLECTION OF YOUR PERSONAL INFORMATION

We collect Personal Information about you to provide you with our Service and Software.

The types of information that we may collect from you include, but are not limited to, the following:

(i) Personal Information

● Identification information, including but not limited to your surname and first name, date of birth, nominated nickname, identification we import from your linked social media accounts, gender, age, country of residence, user ID and profile picture.

● Contact information, including but not limited to your email address and mobile phone number

(ii) Data that may be collected automatically concerning how you use our Service and Software

● Data about your connection and device, including but not limited to, your open ID, device unique identifier, advertising ID, MAC address, Android ID, IDFV, IDFA, GAID, IMEI device name, operating system, browser type, hardware information and language, sensor information, device brand, device name, device model, device system type, device settings and version information, where applicable.

● Data about your network, including but not limited to, your device IP address, router identification (BSSID, SSID, MAC) and IP address, network operator information, network connection status and strength, where applicable.

● Data about your use of the website, including but not limited to browsing time, click-activity, referring website, date/time stamp for your visit and/or data we collect with cookies and similar technologies (Please see Section B for further information), where applicable.

● Data about your location, including general and precise geo-location data such as GPS location, where applicable.

● Data about your use of Service and Software, including but not limited to account history, usage/session time, preferences, audio or video recordings, gameplay data, game progress, crashes or bugs data, social media sharing and interactions, purchase history and billing history, IOS/Android Software application version and name and Bundle ID, where applicable.

● Data required to be collected for ensuring security and for the detection, investigation and prevention of fraud, cheating, misuse of our Service and Software or other violations to our End User Agreement or Applicable Laws.

(iii) Data that you may provide to us

● Data about processing payments, including bank card information such as name, issuer, card number, billing address, expiration date, security code, e-wallet account number, name or ID or other anti-fraud verification code.

● Data about your use of our Service and Software, including but not limited to messages, posts, comments, conversations transmitted or submitted through the Service and Software (such as chat logs and player support tickets).

● Data you choose to provide to us to request information or support from us or to purchase Service and Software or to participate in competitions or tournaments or respond to our questionnaires or surveys, including but not limited to personal data to identify a lost account, account number, email address, photographs, security questions and answers you created, contact information.

● Any other data that you provided to us as part of the Service and Software, or that we collected with your consent to provide you with the Service and Software or for specific purposes made known to you at the time of collection.

(iv) Data that may be provided to us by third parties

● Data about you from other third-parties who have obtained your consent or otherwise are permitted by Applicable Laws to share such data with us, including but not limited to your account information registered under other third-party applications (if you have linked such applications to our Service and Software or accessed such applications by using our social media features) and may include profile picture, email address, user name, gender, language, country, users ID and profile pictures of your followers, friends or contacts. The types of information we receive will depend on your settings with such third-party applications.

● Data which include attributes about you and your interests as further detailed in section B.

B. Use of Data

Purposes of Collection and Use

We collect and may use your Personal Information for the purposes including but not limited to the following:

● to facilitate the setting up of your Account and enable you to log-in to and top-up your Account and use the Software;

● to provide you with and maintain our Service and Software, including but not limited to our games, website and mobile applications;

● to evaluate, customise and improve the Service and Software and the user experience;

● to handle, process and execute any transactions related to the Service and Software;

● to provide you with our customer and/or technical support;

● to analyse the use and trends of the Service and Software;

● to seek your opinion about our Service and Software and conducting surveys on the Service and Software;

● to send or disseminate confirmation notices, updates, and security alerts;

● to manage any abusive, unlawful or dishonest uses of Service and Software or violation to our terms of service, such as managing player bans;

● to prepare and offer push ads, newsletters, promotions, rewards, and other types of content or features that match with your interests;

● to customise the Service and Software, in particular by providing features or ads which correspond to your interests and/or your preferences;

● to improve the safety and reliability of our Service and Software;

● to prevent malicious programs like viruses and trojans on your device when using our Service and Software;

● to research and develop other services; or any other purposes described in the Policy or for specific purposes made known to you at the time of collection.

Legal Basis

Under Applicable Laws, our use of your Personal Information must be justified under one of a number of legal bases. Our principal legal basis that justifies our use of your Personal Information are:

● Contract Performance: where it is necessary for us to perform our contract with you in providing you with our Service and Software;

● Legitimate Interests: where we collect and use your Personal Information for legitimate interests, such as for the purposes of our compliance with Applicable Laws, to ensure information security, to prevent fraud, etc. When we rely on a legitimate interest, we shall ensure that our interests do not override your interests or fundamental rights and freedoms;

● Your Consent: where you have consented to our collection and use of your Personal Information, for example, by agreeing to this Policy. You may withdraw your consent at any time; or

● Legal Requirement: where it is necessary for us to defend, prosecute or make a claim against you, us or a third party.

Analytics and optimisation

We use internal analytics technologies and other automatic tracking and analytic technologies provided by third parties to collect information through automated means in order to adapt our content to your interests as well as to provide and manage the use of the Service and Software.

(i) Cookies

Cookies, or similar technologies such as cookies, web beacons, web server logs, scripts, eTags or other similar technologies ("Cookies"), are small computer files stored on your hard drive. Various types of Cookies may be used to enable us to provide certain features and functionalities and they are placed on our websites either by us or by other third parties permitted by us. The information collected by Cookies enables us to monitor site traffics and users' interactions with other services. We may also use certain cookies that can only collect generic information in relation to browser configurations and personalize the appearance of our websites. We also use anti-cheat technologies that also use Cookies as described below.

You have the option to permit installation of such Cookies or subsequently disable them. You may accept or decline or instruct to be notified of the storage of Cookies by changing the configurations of your web browser (in the case of websites), the device (with respect to games or applications) or from such third-party cookies providers. However, if you decline to install Cookies, the Service and Software and/or certain features may not work properly as intended. For more information on cookies, please refer to the following website: http://www.allaboutcookies.org.

(ii) Third-party analytics tools

Third-party analytics tools may use cookies or visitor action pixels to track your behaviors while you are using our Service and Software. These tools may associate the information they collected in connection with the Service and Software with personal information that they had independently collected on other services, as governed by their respective privacy policies. We do not collect or access any data that may be independently collected by these third parties.

To the extent that the data we collect by Cookies or other third-party analytics tools is combined with personal information or otherwise such data can be used to identify an individual (whether directly or indirectly), we shall treat the combined data and such data as personal information in accordance with this Policy.

Direct Marketing and Advertising

If you consent to receive our direct marketing materials, newsletters and news releases, we will use your name and email address to send you messages regarding new features, updates, contests and events concerning our Service and Software or to show you promotions, services or products that might be of interest to you in connection with the Service and Software and other gaming products and services offered by us. You may opt-out of receiving direct marketing materials from us at any time by contacting us At service@eudemons.com.

You acknowledge and agree that if you opt-out of or do not consent to receiving interest-based or targeted advertising, we may not conduct direct marketing to you and provide your Personal Information to others for direct marketing purposes. You may however still see advertising which may or may not be related to our Service and Software, but the relevant advertising will not be targeted using your Personal Information.

We also use information about you to improve user experience and to ensure that you only see marketing materials that might be of interest to you. Our marketing partners use ads serving technologies for this purpose.

Ads Serving Technologies

Ads serving technologies, including interest-based ads, from our suppliers, involve the use of pixels and/or other similar technologies to collect data in order to determine what kinds of advertising you would prefer to see.

Data collected by these third parties may include, without limitation, (i) your age and/or sex, (ii) your IP address and/or country, (iii) the advertisements placed and their location in the Service and Software, (iv) the duration of visibility of an advertisement as well as the number of views, (v) the identifiers and settings of your device, (vi) your use of the Service and Software and/or other websites (including third party websites) you have viewed (as well as the date and the time of such viewing), and/or (vii) your responses to the advertisements, if any, to allow our suppliers to calculate the number of views of the advertisements or to present ads in a format that best suits your device. Advertisements may be tailored to your interests, for example, you could view an offer for a game or product that might interest you.

Third-party advertising service providers may associate Personal Information with data that they have collected independently from other services in accordance with their own privacy policies. We do not collect or access data that may be independently collected by these third parties. To learn more about some of these ad network practices, you can visit www.networkadvertising.org, www.aboutads.info/choices, or www.youronlinechoices.com.

The technologies deployed by us as described above are fundamental to our Service and Software. If you do not consent to the use of the abovementioned technologies, you should immediately stop using or accessing our Service and Software.

Anti-cheating services

Some of our Services (including our games) may have incorporated or implemented mechanisms to identify and curb users from taking unfair advantage over other users of such Services (such acts will be referred to as "Cheating" and such mechanisms shall collectively referred to as the "Anti-Cheat Tools").

The Anti-Cheat Tools may collect, store and disclose to us your Personal Information, account details, gameplay and any other unauthorised programs or techniques in Cheating for us to detect and manage Cheating behaviours and also to identify players who cheat in games and prohibit them from doing so. This objective is necessary to pursue our legitimate interests and to ensure the safety of you and other users of our Service and Software.

Social Media Features

You may be able to use our social media features for logging into our Service and Software, find out if your friends play our games, and invite them to join you in these games. If you choose to use social media features in some of our Service and Software or to create an account with us using your account with a certain social media platform, the social media platform will provide us with some of your Personal Information, such as your social media platform user ID, your profile picture (to create your avatar in certain games) and the user IDs and profile pictures of your followers, friends or contacts on such social media platform. You may determine the scope and extent of Personal Information that will be provided to us by modifying your sharing settings.

Public data, including user-generated content, online forums, blogs, chat and profiles

You may communicate Personal Information when you provide or otherwise create content by using or accessing our Service and Software, whether as part of games, online forums, blogs, discussion platforms, public user profiles or other similar forums available as part of our Service and Software (collectively, the "Forums"). Any Personal Information you disclose in the Forums would become public data and may be read or used by other users without your consent. If you decide to disclose Personal Information on the Forums, you will do so at your own risk and we shall not be responsible for held liable for any nauthorized use of such Personal Information by any third parties.

Device File Storage Features

You may use our Software's device file storage features to save photos taken from the AR camera fun feature of the Software as well as screenshots taken from your use of our Software after logging into your Account to your device's gallery storage. If you intend to use our device file storage features, you may need to provide us with necessary information and grant essential device permissions such as device camera and photo gallery access to enable such features. You may modify your access permissions at any time by accessing the "Privacy Settings" in your Account. Enabling these permissions grants us authorization to collect and utilize your personal information to provide you with the aforementioned device file storage features. Disabling these permissions revokes the authorization, and consequently, we will discontinue the collection and usage of your personal information, rendering us unable to provide features associated with those permissions. Disabling these features may result in an inferior user experience. Please note that your disabling of these permissions shall not affect the lawfulness of how we have used or processed your Personal Information before your withdrawal.

In-Game Battle Microphone Features

You may use our Software's microphone features to participate in real-time voice communication with other Users during in-game battles. If you intend to use our in-game battle microphone features, you may need to provide us with necessary information and grant essential device permissions such as device microphone access to enable such features. You may go to the "Privacy Settings" in the Software to review and modify your device microphone access permissions for your personal information. Enabling these permissions grants us authorization to utilize your personal information to provide you with the aforementioned in-game battle microphone features. Disabling these permissions revokes your authorization, and consequently, we will discontinue the access to your personal information, rendering us unable to provide the aforementioned features associated with those permissions. Disabling these features may result in an inferior user experience. Please note that your disabling of these permissions shall not affect the lawfulness of how we have used or processed your Personal Information before your withdrawal.

Your device's microphone access will be used strictly to enable your use of our Software's in-game battle microphone features, and will not be collected or stored by us outside of the in-game battles, except where the information is evidence of violation of our EULA or the Applicable Laws. We do not disclose your chats to any third party unless we are required under law to do so.

You may choose not to provide certain Personal Information. However, you may not be able to use certain or all features of our Service and Software.

A. Personal Data Shared with Third Parties

We may, from time to time, engage independent subcontractors to provide us with certain services, such as sending e-mails, processing payments, hosting data, and providing customer support. We take reasonable contractual measures to ensure that these third parties adequately protect Personal Information.

We do not share Personal Information with other third-parties without your prior approval, except as necessary for providing the Service and Software, for our legitimate business needs, for carrying out your requests, and/or as may be required or permitted by Applicable Laws.

In particular, we engage third parties to collect and process your Personal Information on our behalf and for our benefits in order to provide the Service and Software, including but not limited to:

● Our holding companies, subsidiaries or affiliated companies in and/or outside of Hong Kong in order to operate the Service and Software globally

● Our authorized third party digital distribution services and platforms in order to offer and make accessible our Software and Service globally

● Independent contractors and/or service providers for them to provide their services to us information technology system providers, customer relationship providers, marketing research and profiling services providers, advertising partners, payment processing services providers

● Providers of cloud and network services that process or back up information identified in this Policy on their servers for the purposes of providing our Service and Software and other associated services

● Potential investors, valuers or such professionals in connection with any potential merger, acquisition, sale, assignment, financing or transfer of our business

● Insurance companies

● Regulators and law enforcement bodies for legal compliance purposes

We may share Personal Information that does not identify you directly, which is anonymized and/or aggregated, with third parties, for example, to analyze trends in the use of the Service and Software. In addition, we do not control the data sent by your web browser to third parties who receive this information in your normal course of activity on the Internet.

B. Location and Transfer of Your Personal Information

The Personal Information may be hosted and processed, for the purposes of the Policy, on servers operated by trusted partners that may or may not be located where you live. Our support, developers and other team members are located in different parts of the world and they may have access to your Personal Information from outside of where you live in order to provide timely support to constantly maintain our Service and Software. Unless otherwise specified, the servers of our games are located in Hong Kong, the United States, and Germany. These locations are either a jurisdiction with an adequate level of protection recognized by the European Commission or such transfers subject to appropriate safeguards as required by the Applicable Laws.

Some of our subcontractors described in Section C may be located in other countries, including outside the European Economic Area. By using the Service and Software and the games, you agree that your Personal Information may be processed by such subcontractors in countries that may not offer the same degree of data protection as your country. We will, however, only transfer the Personal Data in compliance with Applicable Laws.

We have taken reasonable contractual measures to ensure that our subcontractors would process your Personal Information in accordance with our directions and for our purposes as set forth in this Policy. Our subcontractors are prohibited from using your Personal Information for any other purposes without your consent.

C. Retention Period of Personal Information

We keep your Personal Information for a period not exceeding what is required for the purposes for which the Personal Information is collected and in accordance with Applicable Laws.

Your data will be kept in our active database:

● for the time as long as necessary to provide the Service and Software; or

● for the duration necessary to solve your technical problems or your request; or

● for the time needed to compile game statistics; and

● for 30 days for IP addresses and logs.

At the end of this period, your Personal Information will be deleted or anonymized by us, or archived in an intermediate database, if necessary, for legal, operational, or legitimate reasons, and for the legally prescribed period. The retention period may be changed upon your cancellation of or re-enrollment in the Service and Software, or in accordance with Applicable Laws.

D. Safeguards of your Personal Information

We take different measures to secure your Personal Information. We follow generally accepted rules in the video game industry, as well as Applicable Laws, to protect any loss, destruction, alteration, or unauthorized, unlawful or abusive use of Personal Information. We strive to use appropriate organizational and technical means to protect your Personal Information. For example, we will use encryption technologies (such as TLS, SSL), firewalls, anonymization, restrictions on unauthorized access, de-identification and other means to protect your personal information. We consistently enhance software security capabilities, such as locally encrypting specific information on the device to strengthen secure transmission. Furthermore, we analyze information about applications installed on your device and running processes to prevent malicious programs like viruses and trojans.

We have established a specialized management, process and organization system to ensure information security. For example, we strictly restrict the scope of personnel who can access information and require them to comply with their contractual confidentiality obligations and be subject to regular audits. In the event of a data breach or other security incident of Personal Information, we will activate an emergency response plan to prevent the expansion of such security incident and notify you in the form of push notifications, public announcements, etc.

However, you acknowledge that no security measures are 100% effective. To the extent permitted by Applicable Laws, we shall not be held liable for any direct or indirect loss, damages or costs sustained or incurred by you in the event of a data breach or if the Personal Information is subject to unauthorized use or access.

If you have any questions regarding the security of your Personal Information, please contact us by email at service@eudemons.com.

E. Your Rights and Choices on Your Personal Information

You enjoy the below rights with respect to your Personal Information that is in our possession or under our control under Applicable Laws. Nothing under this section shall restrict your entitlement to the rights granted under the Applicable Laws in your relevant jurisdiction.

The right to be informed

You have the right to be informed about the collection and use of your Personal Information by us. This Policy sets out the types of information we collect, the purposes for processing your Personal Information and the legal basis for doing so as well as the transfer, storage and handling by us of your Personal Information.

We strongly suggest you review this Policy carefully before using our Service and Software.

The right of access

You have the right access to Personal Information that is in our possession or under our control. The right of access also includes your right to know how we use your Personal Information in practice and who we share such information with.

For Service and Software for which you have created an account with us, you can access any of your Personal Information at any time by logging into the relevant Service and Software and adjusting your account settings.

The right of rectification

You have the right to rectify any of your Personal Information that is in our possession or under our control. Similar to the above, you may revise or supplement any of your Personal Information at any time by logging into the relevant Service and Software and adjusting your account settings.

The right to erasure and the right to restrict processing to storage

You have the right to request us to delete your account, to remove your Personal Information or to restrict the processing of your Personal Information where there are no compelling reasons for any continued processing. To do so, you may log in into the relevant Service and Software accounts or for any other information, you can contact us to request for erasure or restricted processing.

The right to erasure is however subject to our legitimate rights afforded under Applicable Laws to retain Personal Information for our legitimate purposes. An example is for enforcement of our legal rights.

If you require us to restrict the processing of your Personal Information other than for storage purposes, please note that we may use such Personal Information again if there are valid reasons under Applicable Laws for us to do so.

The right to data portability

If you reside in the European Economic Area, you have the right to receive a copy of the Personal Information we process about you. You may also request us to transfer it to another party, except under certain exceptions.

The right to object

You have the right to object to our collection, use or processing of your Personal Information at any time. In particular, you can also object to our use of your Personal Information for direct marketing purposes.

If you wish to contact us regarding the processing of your Personal Information, or to have access to it in an electronic format, correct it, erase it, change how we process it (if applicable), or withdraw your consent (if applicable), or transfer them to another online provider (where technically possible), you may email us at service@eudemons.com. Please note that the withdrawal of your consent shall not affect the lawfulness of how we have used or processed your Personal Information before your withdrawal.

In the case of an email request, you agree to provide us with your contact information, the subject of the request and the Personal Information in question for our further action. We reserve the right to ask you for any information about you to confirm your identity.

Please note that if you choose to delete your Personal Information, you will no longer have access to the Service and Software associated with your internal and/or external identifier.

We reserve the right to reject deletion requests if there is a legal obligation on us to retain the Personal Information due to legal claims or as required by any Applicable Laws.

Your request will be processed within thirty (30) days of receipt, with the understanding that we reserve the right as permitted by Applicable Laws to extend this period to two (2) months due to the complexity and number of requests. We reserve the right to impose a reasonable administration fee for complying with a data access request.

You may also contact your local data protection authority for any questions relating to the collection and use of your Personal Information.

F. Children

Most of our Service and Software (including some of our games) are not directed to Children ("Controlled Service and Software"). WE DO NOT KNOWINGLY COLLECT, SOLICIT, MARKET TO OR REQUIRE THE PERSONAL INFORMATION BELONGING TO CHILDREN. IF YOU ARE BELOW THE MINIMUM APPLICABLE AGE IN YOUR COUNTRY, DO NOT SEND YOUR PERSONAL INFORMATION TO US AND DO NOT USE SUCH CONTROLLED SERVICES. If we obtain actual knowledge that we have collected data from Children, we will promptly delete it, unless we are legally obligated to retain such data.

For the purpose of this Section, by Children, we mean users under the age of 18 years old, or in the case of a country where the minimum age for processing Personal Information differs such different ages. The table below sets out the minimum relevant age specified in Applicable Laws:

Your Country

Minimum relevant age

Brazil

18

China

14

Egypt

18

European Economic Area/Switzerland

16

India

18

Indonesia

21

Kingdom of Saudi Arabia

18

Malaysia

18

Philippines

18

Russia

14

Singapore

18

Thailand

20

Turkey

18

United Arab Emirates

21

United Kingdom

13

United States

13

We require the parents' and/or legal guardians' personal information to create any user accounts for their Children to access our Controlled Service and Software. Such information may include full name and email address. We may also require the parent's and/or legal guardian's separate consent and acknowledgement to this Policy before allowing the creation of an account and/or access to our Controlled Service and Software.

Parents or legal guardians who are concerned about our use of data are welcome to contact us at service@eudemons.com

G. Third party services

Our Service and Software may contain advertisements or links to third-party websites such as X (formerly, Twitter), Facebook and/or YouTube. The presence of these links on our Service and Software does not constitute an approval, authorization, or affiliation with the websites in question. If you click on these links or use the services of a third party, you will leave our Service and Software and you must consult the privacy policy of the website in question before sharing your Personal Information.

Certain products and/or services are offered to you as part of our Service and Software in partnership with third parties and you may be required to provide Personal Information to them in order to register and access their products or services. The identity of these third parties will be indicated at the time of registration. If you choose to register, you will transmit your Personal Information to these third parties and their use of your Personal Information will be subject to their privacy policies.

We are not responsible for the use of your Personal Information by such third parties and we cannot guarantee that they have the same level of data protection policy as us.

H. Conditions of use of our Service and Software

The terms of this Policy are incorporated into our End User Agreement which you may refer to at the following link: https://www.eudemons.com/read.shtml

I. Changes to the Policy

We reserve the right to change the Policy at any time. If we change the Policy, we will communicate the changes to you through the landing page or other similar page under the Service and Software, or any other appropriate means, for example, by email or with a pop-up notice in our games or on your account page, so that you will be fully informed of such changes. Any changes to the Policy will take effect thirty (30) days after such changes have been communicated to you. Your continued use of our Service and Software will be deemed as an acceptance of the changes to the Policy.

J. Severance

If any part or provision of this Policy is prohibited or deemed to be void or unenforceable, that part or provision shall be ineffective to the extent of such prohibition or unenforceability without invalidating the remaining provisions hereof.

K. Governing Law

This Policy shall be governed by, and construed in accordance with, the laws of Hong Kong Special Administrative Region ("Hong Kong"). Any dispute, controversy, difference or claim arising out of or relating to these Terms and Conditions, including the existence, validity, interpretation, performance, breach or termination thereof or any dispute regarding non-contractual obligations arising out of or relating to it shall be referred to and finally resolved by arbitration administered by the Hong Kong International Arbitration Centre (HKIAC) under the HKIAC Administered Arbitration Rules in force when the Notice of Arbitration is submitted. The seat of arbitration shall be Hong Kong. The number of arbitrators shall be one. The arbitration proceedings shall be conducted in English.

The United Nations Convention on Contracts for the International Sale of Goods do not apply to this Policy.

L. Jurisdiction specific provisions (California, United States of America)

If you are using our Service and/or Software to which this Policy applies from the State of California in the United States of America, the following terms will also apply to you. In the event of any inconsistency between any provision set out in this Section N and the rest of the Policy, the provisions hereunder in Section N will take precedence to the extent as permitted by Applicable Laws.

For the purposes of this section, "personal information" and "sensitive personal information" have the same meanings given in the California Consumer Privacy Act of 2018 ("CCPA").

For detailed information on what categories of Personal Information from or about you or your devices that we collect and disclose over the past twelve (12) months, see section A of this Policy. We collect and disclose your Personal Information for the business and legal purposes as set out in section B of this Policy.

In the past twelve (12) months, we have not sold or shared Personal Information of residents in California within the meaning of "sold" and "shared" in the CCPA, nor do we have any knowledge of any sale or sharing of Personal Information of Users under sixteen (16) years of age.

We do not use or disclose sensitive personal information for any purpose other than to deliver the services reasonably anticipated by the typical consumer who makes a request for those services. In the past twelve (12) months, the following category of sensitive personal information may have been collected from you: in-game chat data.

Your rights as a resident in California include:

● Requesting disclosure, free of charge, of the following information in the past twelve (12) months:

▪ categories of Personal Information that we collect about you;

▪ the business and/or legal purpose for collection;

▪ the categories of sources from which the Personal Information was collected;

▪ the categories of third parties to which we disclose such Personal Information;

● Subject to certain exemptions under the CCPA, requesting the deletion or erasure of the Personal Information collected about you;

● Requesting the correction of inaccurate personal information retained by us about you;

● Be free from unlawful discrimination for exercising your rights under the CPPA.

Pursuant to the requirements of the CCPA, we aim to fulfil all valid requests within forty-five (45) calendar days from the date of receipt of such request.

To exercise your rights under the CCPA, you must provide your notice of request to us via our customer service email address at service@eudemons.com with a clear statement setting out your request, with details of your name, Account ID, postal address and where applicable, your telephone number, fax number and email address linked to your Account. We may take steps to verify your identity before complying with your request and may decline to fulfil your request if your identity cannot be verified. If you choose to designate an agent to make such requests on your behalf, you must provide us with a proof of written permission. We may require the agent to verify their own identity and to confirm that they have duly obtained your authorization to make the request on your behalf.

M. Communicate with Us

If you have any questions or concerns regarding this Policy, please contact us using information as follows:

Name: Game Operations Officer

Address: Unit 2001, 20/F, Harbour Centre, 25 Harbour Road, Wan Chai, HK

Email Address: vip@eudemons.com

Telephone Number: 2850 7215