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Privacy Policy

Latest Update：August 5th, 2022

Effective Date: August 5th, 2022

Introduction

This privacy policy informs you of your choices and our practices regarding any
personal information you provide to us. Your use of the product(s), service(s)
and related websites (“Service”) distributed by Pulsecraft Pte. Ltd. (“Epicoll”,
“we” or “us”) involves the collection and use of your personal information. It
is important for you to understand how this happens and how you may control it.

When you contract to use the Service, you accept our rules and policies
regarding your personal information and you expressly consent to us collecting,
processing, using and storing your personal information, as described in this
policy.json.

You acknowledge that you have read and understood this privacy policy.json. If
you do not agree with this privacy policy.json, you must not use the Service. If
you change your mind in the future, you may withdraw your consent to use of your
personal information in accordance with this policy.json.

If you have any comments, questions or complaints regarding the processing of
your personal information, you can contact us at pulsecraftgdpr@gmail.com.

The Types of Personal Information We Use

This section describes the different types of personal information we collect
and how we collect it. We will collect and use the following information about
you:

• Information you give us. You give us information about you:

(i) when you register for the Service using third-party social media or similar
accounts (e.g. Facebook, Twitter, Google or Apple, collectively “Social Media
Accounts”) in order to set up your profile (we import from your connected Social
Media Accounts your personal information which may include your
name/nickname/username as it appears on your social media profile, your profile
picture, your friend list, and your account ID);

(ii) when you register for the Service using email addresses (including your
email address and your name/nickname/username);

(iii) when you set up your profile for the Service (including information you
voluntarily elect to provide in order to customize gameplay, including but not
limited to your name/nickname/username, your gender, your age, etc.) and secure
your account for the Service (including information you provide to help secure
the account, including but not limited to your phone number, email address,
security questions, etc.);

(iv) when you submit your name, date of birth, domestic citizenship or foreign
status information for age verification or compliance with applicable laws and
regulations;

(v) when you submit your contact details to us (including your name, email
address and physical address) as part of promotional activities for the Service;

(vi) when you use location-based functions in the Service (“Location Services”)
(including GPS location information, cell-ID, Wi-Fi connection location); and

(vii) when you make purchases in the Service (in which case we will process the
information you provide to us to facilitate the payment).

(viii) when you provide your account details to receive payments from us (in
which case the information is provided to third party payments service providers
to facilitate the payment).

• Information we collect about you. We automatically collect certain data from
you when you use the Service, including your IP address and device information
(such as device type, network data, operating system) and information regarding
your use of and interaction with the Service, such as date and time stamps of
actions. We also collect and store your data each time you interact with us, for
example, when you use in-app support to communicate with us.

• Information you generate and display in the course of using the Service. You
may provide additional information as part of your profile. You may also provide
or generate information when you communicate with other users in the Service
(e.g., chat log). You acknowledge and agree that information generated within
our Service should not be considered private and communications within our
Service may be viewed/heard by other users. Please avoid revealing any
personally identifiable or sensitive information during such communications.

Cookies and Other Tracking Technologies

We use cookies and other similar technologies (e.g. web beacons, log files,
scripts and eTags) (“Cookies”) to enhance your experience on our websites.
Selected third parties may also use Cookies when you access your account using
Social Media Accounts. Cookies are small files which, when placed on your
device, enable us to provide certain features and functionality.

In some cases, you may have the option to permit installation of such Cookies or
subsequently disable them. You may accept all cookies, or instruct the
device/web browser to provide notice at the time of installation of cookies, or
refuse to accept all cookies by adjusting the relevant cookie retention function
in your device. However, in the event of your refusal to install cookies, the
Service may be unable to operate as designed.

Your browser settings may allow you to transmit a “Do Not Track” signal when you
visit various websites. Like many websites, our websites are not designed to
respond to “Do Not Track” signals received from browsers. To learn more about
“Do Not Track” signals, you can visit http://www.allaboutdnt.com/.

Children

Our Service is not intended for children and we do not knowingly collect
information from children. If you believe that we have unintentionally collected
your children’s personal information, you may request the deletion of the
information by contacting us at pulsecraftgdpr@gmail.com. In some cases, we may
ask the user to provide us with their date of birth date for age verification.
If such information indicates the user is under the age stipulated by the
applicable laws and deemed as child under such laws, we will not collect further
personal information from the child until a parent/guardian’s verifiable consent
is obtained.

If you are in the United States:

With parental consent, we may collect personal information from children under
the age of thirteen (13). If we learn that we have collected or received
personal information from a child under the age of thirteen (13) without
parental consent, we shall immediately take the necessary steps to ensure that
such information is deleted from our system’s database. Parents have the right
to review their child’s personal information; to have their child’s personal
information deleted; and to refuse further collection, use, and/or disclosure of
their child’s personal information by notifying us. As a parent, you understand
that Epicoll has a legitimate interest in providing your child’s personal
information collected via the Service to external providers for the purpose of
administering or providing the Service. Anyone under the age of thirteen (13)
must seek and obtain parent or guardian permission to use our Service. For
additional information, you may contact us at pulsecraftgdpr@gmail.com.

How We Use Your Personal Information

We will use the information in the following ways and in accordance with the
following legal bases:

• Registration Information (such as: ID on Social Media Accounts, email address,
nickname, avatar, username, password, phone number, security questions, date of
birth and other information): We use Registration Information to set-up user
accounts, allow users to log-in to the Service by using the Registration
Information, maintain and secure the user accounts with us, and provide Service
to users. We use this information with your consent to this Privacy Policy.

• Device Information (such as: device ID, device type, operating system, CPU,
RAM, IP address, MAC address): We use this information to provide and improve
the Service such as: to allow users to download and install the software on
their devices; to record and keep track of requests from users of the Service;
to detect the user network and device status when the user is using the Service;
and to correct bugs or errors that occur when the user is using the Service. Use
of Device Information is necessary to perform our contract with you to provide
the Service.

• Contact Information (such as: name, email address, physical address, phone
number, instant messaging account): We use this information to send
notifications to users to inform them of our promotional activities and any
rewards they are entitled to. We use this information with your consent to this
Privacy Policy.

• User Profile (such as: age, gender, photo and etc.): We use this information
to provide customized services to users such as personal information page. We
use this information with your consent to this Privacy Policy.

• Game Data (such as: level, heroes, scores, chat logs and etc.): We use this
information to provide Service to users as it is the basis of our Service. Use
of Game Data is necessary to perform our contract with you to provide the
Service.

• Payment Data (only the payment history and transaction data within the
Service). We use this information to provide Service to users and to record and
keep track of requests from users of the Service. Use of Payment Data is
necessary to perform our contract with you to provide the Service.

• Location Data (such as: GPS location information, cell-ID, Wi-Fi connection
location). With your consent, we use this information to provide Location
Services to users and to record and keep track of requests from users of the
Service. Use of Location Data is limited to the context of location-based
services. You can disable Location Services by turning off the relevant switch
in the settings of the Service or your device.

• We may associate all of the foregoing information with your account, the
device you use to access the Service, or email that you use to engage with us.
We use this information with your consent to this Privacy Policy.

• In addition to the specific uses of information described above, we may use
all of the above information to provide, improve and develop the Service,
including as we describe in our User Agreement, to comply with any applicable
legal obligations, to enforce any applicable terms of service, to protect or
defend the Service, our rights, the rights of our users, or others, for the
purpose of combatting fraud, or to otherwise operate our business.

How We Store and Share Your Personal Information

In order to perform our contract with you, your personal information will be
accessible from and will be processed on our servers. Our servers are hosted on
cloud servers such as Amazon Web Services. Your information may be transferred
to and processed in countries outside the country you are located. We will take
steps necessary to comply with applicable legal requirements, such as using
European Commission approved Standard Contractual Clauses to protect your
information. In particular, your information will be transferred to and
processed in Japan where our central database is based.

We share your personal information with selected third parties in and outside
your country, including:

• third-party vendors that provide services in support of the Service, such as
Amazon Web Services (“AWS”) for the purpose of hosting the game; Apple, Google,
Paymentwall, Coda, PayPal, Razer (Mol), UniPin, Xsolla, Pagsmile, Boku and
Checkout for the purpose of providing payment services; Helpshift for the
purpose of providing customer support; Facebook and Appsflyer for the purpose of
the evaluation of our marketing events. Those third party vendors have limited
access to your personal information and are contractually bound not use it for
other purposes.

• related group companies, with whom we share your information to operate the
Service. The transfers contemplated above are made pursuant to our contract with
you; and

• law enforcement agencies, public authorities or other judicial bodies and
organizations. We disclose information if we are legally required to do so, or
if we have a good faith belief that such use is reasonably necessary to: (i)
comply with a legal obligation, process or request; (ii) enforce our terms of
service and other agreements, policies, and standards, including investigation
of any potential violation thereof; (iii) detect, prevent or otherwise address
security, fraud or technical issues; or (iv) protect the rights, property or
safety of us, our users, a third party or the public as required or permitted by
law (including exchanging information with other companies and organizations for
the purposes of fraud protection).

The Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal
information no matter where it is stored. We have information security and
access policies that limit access to our systems and technology. We deploy a
firewall and other security measures (such as encryption) commensurate to
industry standards to prevent unauthorized access to your personal information.
Your personal information will remain subject to our technical and
organizational controls and our policies and procedures (including this Privacy
Policy). Unfortunately, the transmission of information via the internet is not
completely secure. Although we will do our best to protect your personal
information, we cannot guarantee the security of the information transmitted to
our services; any transmission of your information is at your own risk.

Data Retention

We will retain most of your personal information for the lifetime of your use of
the Service (i.e. until account deletion in accordance with your request) except
that Contact Information obtained from promotional activities will be retained
during the lifetime of such activities.

In the event that the processing and retention period have terminated, but
personal information is required to be retained continuously for other reasons
including for the purposes as prescribed under applicable laws, the relevant
personal information will be stored and maintained separately from other types
of personal information. If you require us to destroy your personal information
before the end of its life cycle, we will destroy your personal information in
accordance with local laws.

Your Rights

This section (“Your Rights”) applies to users that are located in the European
Economic Area only. For California Residents, please refer to
https://protocol.unisdk.easebar.com/release/latest_v475.html. For users located
in other territories, please refer to the privacy clauses in our User Agreement.

You have certain rights in relation to the personal information we hold about
you. Some of these only apply in certain circumstances (as set out in more
[campaignId] below). We must respond to a request by you to exercise those
rights without undue delay and at least within one month (though this may be
extended by a further two months in certain circumstances). To exercise any of
your rights, please contact us at pulsecraftgdpr@gmail.com. Please understand
further information may be required to verify your identity when exercising your
rights.

Access

You have the right to access personal information we hold about you, how we use
it, and who we share it with. If you believe we hold any other personal
information about you, please contact us and complete the corresponding request
form.

Portability

You have the right to receive a copy of certain personal information we process
about you. This comprises any personal information we process on the basis of
your consent or pursuant to our contract with you, as described in the section
“How We Use Your Personal Information”. You have the right to receive this
information in a structured, commonly used and machine-readable format. You also
have the right to request that we transfer that personal information to another
party.

If you wish for us to transfer such personal information to a third party,
please ensure you [campaignId] that party in your request. Note that we can only
do so where it is technically feasible. Please note that we may not be able to
provide you with personal information if providing it would interfere with
another’s rights (e.g., where providing the personal information we hold about
you would reveal information about another person or our trade secrets or
intellectual property).

Correction

You have the right to correct any personal information held about you that is
inaccurate. If you believe we hold any other personal information about you and
that information is inaccurate, please contact us and complete the request form.

Erasure

You can delete your account, or remove certain personal information. If there is
any other personal information you believe we process that you would like us to
erase, please contact us and complete the request form.

You may request that we erase the personal information we hold about you in the
following circumstances:

• you believe that it is no longer necessary for us to hold such personal
information; or

• you believe the personal information we hold about you is being unlawfully
processed by us.

You can also exercise your right to restrict our processing of your personal
information (as described below) whilst we consider your request.

We may need to retain personal information if there are valid grounds under data
protection laws for us to do so (e.g., for the defence of legal claims or
freedom of expression) but we will let you know if that is the case. Where you
have requested that we erase personal information that has been made available
publicly on the Service and there are grounds for erasure, we will use
reasonable steps to try to tell others that are displaying the personal
information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only

You have a right to require us to stop processing the personal information we
hold about you other than for storage purposes in certain circumstances. Please
note, however, that if we stop processing the personal information, we may use
it again if there are valid grounds under data protection laws for us to do so
(e.g., for the defense of legal claims or for another’s protection). As above,
where we agree to stop processing the personal information, we will try to tell
any third party to whom we have disclosed the relevant personal information so
that they can stop processing it too.

You may request we stop processing and just store the personal information we
hold about you where:

• you believe the personal information is not accurate for the period it takes
for us to verify whether it is accurate;

• you wish to erase the personal information as the processing we are doing is
unlawful but you want us to retain the personal information but just store it
instead; or

• you wish to erase the personal information as it is no longer necessary for
our purposes but you require it to be stored for the establishment, exercise or
defense of legal claims.

Objection

You have the right to object to our processing of personal information about
you. We will consider your request in other circumstances as detailed below by
contact us and completing the request form.

Announcements

We may from time to time send you announcements when we consider it necessary to
do so (such as when we temporarily suspend The Service access for maintenance,
or security, privacy or administrative-related communications). You may not
opt-out of these service-related announcements, which are not promotional in
nature.

Contact & Complaints

For the purposes of European Data Protection Law, the Data Controller is
Pulsecraft Pte. Ltd.

In the event that you wish to make a complaint about how we process your
personal information, please contact us in the first instance.

--Contact Information--

Name: Pulsecraft Pte. Ltd.

Mail: pulsecraftgdpr@gmail.com

Designated EU representative and contact information:

GDPR-Rep.eu

Maetzler Rechtsanwalts GmbH & Co KG

Attorneys at Law

c/o Pulsecraft Pte. Ltd.

Schellinggasse 3/10, 1010 Vienna, Austria

Please add the following subject to all correspondence:

GDPR-REP ID: 17942453

This is without prejudice to your right to launch a claim with the data
protection authority in the country in which you live or work where you think we
have infringed data protection laws.

Changes

If we make any material changes to this policy.json, we will post the updated
policy.json here and we may notify our users through their account. Please check
this page frequently to see any updates or changes to this policy.json.

Language

This Agreement may be translated into the local language in the relevant
territory. In the event of a conflict between this Agreement in the English
language version and the localized version, the English language version shall
prevail.




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