PRIVACY NOTICE

This Privacy Notice will be effective from August 10, 2024.

Introduction

This EDGE POWER Privacy Notice (the “Privacy Notice” or “Notice”) is provided to help you understand our practices regarding how we collect, use, share, and protect personal data. In this Privacy Notice, “EDGE POWER” refers to EDGE POWER Interactive Ltd., Room 101A, 1/F, Public Industrial Building, 56 Hoi Yuen Road, Kwun Tong, Hong Kong. We may also refer to EDGE POWER as "we" or "us".

This Privacy Notice applies whenever you play Game (”Services”). We generally use the term ”Services” for the respective game, the game’s website or app. However, if certain processes apply only to your use of the game’s website (without accessing the game), we refer to the respective website as ”Service Website”.

By using the Services, you agree to the collection, disclosure, storage and use of personal data as described in this Privacy Notice. If you do not want EDGE POWER to collect, store, use or share the personal data you provide in the ways described in this Privacy Notice, you should not play EDGE POWER’s games or use our Services.

PERSONAL DATA WE COLLECT

When you use our Services, we may collect, use, store and transfer different kinds of Personal Data. As a general principle, under current law in most countries, the personal data we collect is not considered sensitive personal data.

The information we collect depends on which of our Services you use and how you use them. We may process the following types of your Personal Data:

Personal Data provided by you directly

When you use our Services, you may provide or be asked to give us certain information, including:

Age information: When you use our Services for the first time or sign up for an account, we ask you to enter your age for the purposes described below.
Your account information: When you create an account on our Services, we collect your log- in data (your nickname/avatar name and/or your email address and password) and may collect additional profile information (entry of this information is entirely voluntary and not necessary to sign up for an account. You can edit or delete your profile information at any time) provided by you to personalize your profile (such as your first name, your selection of the avatar’s gender, and your avatar). This information will be combined with your User ID. Please note that you can use our Services as a visitor. In that case, we only require your nickname and device identifier which will be combined with your User ID.
Data provided in relation to our customer service: When you contact support, we collect information about your request (subject and content of your request) and your contact details.
Data provided in response to surveys or another research we conduct;
Data submitted by participating in group communications or chats.
Other information that helps us make sure it’s you who is accessing your account, including as necessary for us to provide the support you request.

Personal Data you generate when using our Services.

When you use our Services, we may also process device-related information and information about how you interact with our Services, including:

Technical information: The information we obtain from your device(s) includes the type of your device, IP address, device IDs, game/site ID, geolocation data (based on your IP address), browser settings, screen resolution, battery status, free storage, and other technical information.
Your usage: We collect information about how you use our Services. This information includes the actions you take within the game (e.g. if you win or lose a game, your achievements (such as the level reached), the items purchased within our Service, the amount you spent in the game, your friend list), the time and duration of your activity. Part of this information will be stored in your account (such as your friends list and your progress). Furthermore, we collect information about the websites that led you to our Service.

Personal Data we get from third parties

In certain scenarios, we will also obtain your Personal Data from third parties. For example, your Personal Data may be provided by the following third parties:

Payment Providers: If you make an in-app or website payment, the transaction will be processed by a third-party payment provider and will be subject to third-party payment providers’ privacy policies. For these transactions, we do not receive any specific financial information (such as your credit card information) but may receive basic information which is related to your transaction, for example the payment amount and payment date.
Social Networks and connected third-party platforms: If you choose to connect our Service with your e.g. Facebook, Apple, Google account by using your e.g. Facebook, Google credentials within our log-in process, we may receive certain information about you like e.g. your name, you profile picture, your email address, and your friends list. If you enter our Services from a third-party platform, and you have created an account on the third-party platform or connected your game account with that platform, your username and your avatar may be shared with us to create your Service account. Furthermore, the third-party platform provider may share with us e.g. the platform ID, the avatar url, your email address, and your friends list. To manage the information we receive about you from those third-party platforms where you receive our Services you will need to follow the instructions for each such third- party platform for updating your information and changing your privacy settings. Any personal data that will be processed by that third-party platform are subject to that third-party platforms’ terms of service and privacy policy. For example, EDGE POWER may collect and store some or all of the following information shared by the third-party:
your first and last name;
your profile picture or its URL;
your user ID number (like your Facebook ID number), which may be linked to other information like your name and profile photo, and your friends’ identifiers;
your friends list, which includes the user ID number and other information of your friends, like their names and profile photos;
the login e-mail you provided to the third-party application;
your approximate physical location (the country/state you are located in) and that of the devices you use to access our Service;
your gender;
your birthday and/or age;
information about your activities on or through the third-party application;
other information you have shared on the third-party application;
any other information that you or the provider of the third-party application share with EDGE POWER.
User acquisition companies: If you click on our advertisements shown to you in a third-party network, we will receive campaign information (the campaign ID, clicks on our ads, creative views), information about installs of our Services, your country and language, and technical identifiers (Advertisement Device ID) from our user acquisition partners.
Other third parties: We may also receive information about your approximate geolocation (the country you are located in) from third parties (e.g. Google). We use this information to comply with our legal obligations applying to the processing of your Personal Data, customize certain services to your location, and for fraud or abuse prevention purposes.

COOKIES AND AUTOMATED INFORMATION COLLECTION

EDGE POWER, our service providers, and third parties may place cookies on your device when you access or browse the Service. A cookie is a small data file that is transferred to your device for record-keeping purposes. Information contained in a cookie may be linked to personal data. We may use cookies for purposes such as improving the quality of EDGE POWER’s Service, making the Service easier to use, tailoring recommendations to interests and serving targeted ads. Third party advertisers may also use, place, or read cookies or other technologies as described below on your device, and those practices are subject to their own policies.

As further described in our Cookie Policy (”Cookie Policy”), we use cookies and similar technology such as pixels or local storage and allow third parties to use cookies and similar technology for the purposes described below. The exact process of placing cookies, and the scope of the data that may subsequently be processed is set out in our Cookie Policy

HOW WE USE PERSONAL DATA

Depending on which Service you are using and which privacy settings you have selected, EDGE POWER may use personal data for a variety of business purposes as described in this Privacy Notice such as:

Provision and improvement of our Services

to allow you to use our Services.
to facilitate in-game communication via chat or web forum
to create and manage your account to restore your account if you ever lose access.
to communicate with you in context of account activation and password management, to simplify the registration process.
to facilitate your purchase, to verify and confirm your payment to facilitate content sharing on social networks.
to provide technical support and respond to your requests.
to identify and correct any bugs/errors.
to indicate the popularity of our Services to assess the quality of our Services.
to understand and improve your online experience.
to pay our business partners for the promotion of our Services
to understand usage of our Services across all our group companies to support strategy and growth.

Personalization of your game experience

to remember your preferred game settings
to remember you next time you visit one of our Services
to show you more engaging in-game promotions and offers
to provide you with a more personalized game experience

Marketing and analytics

to show you advertisements for our Services on other websites or apps
to measure the effectiveness of advertising and optimize it
to send you marketing communications, including newsletters and push notifications, informing you about new content and in-game offers
to acquire new users including on social media platforms

Prevention of fraud and illegal activity

Prevention of fraud and illegal activity
to enforce our policies and Terms of Use
to authenticate and/or verify individual identities.
to protect the safety and well-being of our players.
to protect EDGE POWER's rights and property in connection with our Service including to enforce our policies and Terms of Service.
to address technical issues and maintain and/or enhance network and information security.
to conduct audits, ensure internal quality control, and take safety precautions.

Compliance with our legal or regulatory obligation

to determine the legal requirements for processing of your Personal Data (based on your location and your age)
to maintain records related to purchases
to respond to your requests related to your data subject right
to comply with our legal obligations (e.g. tax and accounting obligations) to inform you about any changes to this Privacy Policy

Finally, we may use technologies that (a) may be considered automated decision-making or profiling, and/or (b) artificial intelligence to evaluate personal data that we collect including, for example, to create user segments, based on in-game activity (e.g. in-game purchase activity, the level reached in the game) for legitimate business purposes. We will not use these technologies in a way that has a legally significant impact on you, unless we have your consent, or we are otherwise legally permitted to do so.

For specific information about the user segments we create, see the section with service specific information below.

We may use personal data for any other purposes communicated to you at the point of collection, or otherwise with your consent.

LEGAL BASIS

We process your Personal Data for the purposes described in this Privacy Policy, based on the following legal grounds:

Your consent: We process your Personal Data if you have provided your consent for a specific purpose. For example, when you use our Services, we ask for your consent for the data processing in the context of our newsletter. We may also show you just-in-time contextual notifications and consent pop-ups to obtain your consent for further processing activities. You have the right to withdraw your consent at any time, for example by changing your in-game settings. Please note that this will not affect any processing carried out before you withdraw your consent.
Performance of a contract: We process your Personal Data for the performance of a contract to which you are party, for example, where it is necessary for the creation and administration of your account, to process your in-game purchase and the associated payment, to support the operation of our games or facilitate the delivery of requested services.
Compliance with legal obligations: to which we are subject: We process your Personal Data to comply with legal obligations, for example, in order to verify your age, for tax and accounting purposes or legal disputes as well as any requests or claims from legal authorities.
Legitimate interests: We may also process your Personal Data to the extent that the processing is necessary for our legitimate interests. For example, we process your Personal Data for improvement of the Service provided to you, to provide you with a better user experience.

Please see for additional information the section with service specific information below.

HOW WE SHARE PERSONAL DATA

We may disclose your Personal Data to the following recipients or categories of recipients or allow the following third parties to collect your Personal Data in connection with your use of our Services:

External service providers: We may share your Personal Data with external service providers who perform services on our behalf, like customer support services, IT services, hosting and content delivery services, web/social analytics services, data management services, user notification and marketing services, analytics services and forum hosting services. Where we share your Personal Data with external service providers, we have appropriate agreements in place to ensure that your Personal Data is processed in compliance with applicable data protection laws.
Social networks and connected third-party platforms: If you wish to share certain content on social media, you will be asked to log-in with your social media platform credentials. In this case, the content you want to share (e.g. a screenshot from the game) will be sent to the respective social network or third-party platform. If you signed up with your third-party platform account, we would send your account identifier and request data (e.g. user name, e- mail, profile picture) from the third-party platform provider. We have included a Google Play Games and Apple Game Center login on our mobile Services to enable you to integrate with your gaming profiles as and when they see fit to do so. Such parties may capture some of your data once you logged in. Please note that logging-in to these services is not mandatory but available in order to offer you more interaction in the mobile environment. For example, when you accomplish Google Play Games or Apple Game Center achievements, this will be visible on your Google or Apple profile, and you earn “experience” points and can increase your level to compete with other Google or Apple users. These parties are controllers of the data for their own purposes, so we strongly advise you to review their privacy policies.

Furthermore, your Facebook ID and/or the advertisement ID may be shared with Facebook Inc. (Facebook) or Snap Inc. (Snapchat) in connection with Facebook’s and Snapchat’s ”Lookalike Audience” and ”Custom Audience” (re)marketing features which we may use for our Services. Learn more about our marketing activities in the service specific section below.
User acquisition companies: We may provide advertisements for our Services to user acquisition companies which show these advertisements on their websites or in their networks. If you click on advertisements shown to you on a third- party website or in a third-party network, you will be redirected to the app store where you can install our Service. The information about the installs of our Service, your country and language, the campaign ID, your user ID, and post install events (such as session time, reached level), including any purchase events and the purchase segment), may be shared with the user acquisition company.
Law enforcement, government authorities or courts: We may disclose your Personal Data in response to lawful requests from public authorities, including law enforcement, government authorities, supervisory authorities or courts. We may also disclose your Personal Data to legal authorities where we believe such disclosure is necessary for prevention of a crime, facilitation of an investigation related to public safety, protect the security or integrity of our Service, or enable us to take precautions against liability or to protect our rights. In addition, we may also disclose information to protect the rights or property of EDGE POWER and other applicable third parties, including to enforce our Terms of Service.

CHILDREN’S PRIVACY

In accordance with the Terms of Service, you may not use the Service if you are under 21 years old.

EDGE POWER is committed to complying with laws protecting children. If you believe that your child has submitted personal data to EDGE POWER, please contact us at privacy@EDGE POWER.com. EDGE POWER will take reasonable steps to delete such information as soon as possible.

Cookies: While you cannot use our Services without registration, you can still enter the Service Websites which may allow us to collect your Personal Data through the use of cookies. When you access our Game game for the first time via Service Websites, you will be asked to confirm your age. For this age-confirmation method, we will also use your device or browser language data for presenting the age-gate in the correct language.

SECURITY

We have implemented appropriate technical and organizational security measures designed to protect your Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We update and test our security standards on an ongoing basis. In addition, we take reasonable steps to assure that third parties to whom we transfer your Personal Data provide sufficient protection of Personal Data.

We take reasonable steps designed to protect personal data; however, no system or network can be guaranteed to be 100% secure and therefore we cannot guarantee the security of data. To the fullest extent permitted by law, we do not accept liability for unauthorized disclosure.

RETENTION

We may retain personal data for as long as you use the Services and as necessary to fulfill the purposes for which it was collected, or as necessary to comply with our business requirements and applicable laws; to comply with any legal, accounting or reporting obligations; to resolve disputes; to protect our assets; to efficiently run our business; and to enforce our agreements.

Afterwards, we will delete or anonymize your Personal Data. Additional information on how long your Personal Data is stored by our service partners can be found in the respective third- party list available.

YOUR RIGHTS

Depending upon the applicable law where you live, you may have the right to make requests with respect to personal data that EDGE POWER processes about you, for example to request:

information.
access.
correction (or rectification) of personal data that you think is incorrect;
erasure (or deletion).
an electronic copy (or portability).

Object to certain processing activities.

You may withdraw your consent at any time if your Personal Data is processed with your consent. Please note that this will not affect the processing based on consent before its withdrawal.

You can exercise these rights by sending a request to the contact details set out below, providing your name, your email address as well as a description of your request.

If you believe we have not complied with our obligations under applicable data protection laws and regulations, you can lodge a complaint with a competent data protection authority in the place (country and/or state) where you live.

A. Manage Information We Get from Platforms

To manage the information EDGE POWER receives about you from a third-party platform where you play our games, like Facebook, Apple, Amazon, etc. you will need to follow the instructions for the relevant third-party application(s) for updating your information and changing your privacy settings.

B. Choosing not to receive Promotional Communications

If you want to stop receiving Promotional Communications, you can click on the "unsubscribe" link in any promotional email from EDGE POWER. If you want to stop receiving texts or SMS messages from us, you can also use the “unsubscribe” link or reply “STOP” to any promotional message. Please note that it may take us some time for your opt-out to become effective.

C. Choosing not to receive Facebook messages.

If you want to stop receiving messages through our game pages on Facebook, you can turn off all messages through your Facebook “settings”.

D. Choosing not to receive Push Notifications

When you install our apps on your mobile device, you can choose to receive push notifications, which are messages an app sends you on your device even when the app is not on. You can turn off notifications by visiting your mobile device’s “Settings”.

E. Choosing not to apply Cookie Tracking

On EDGE POWER websites that use cookies, you can use the cookie banner or click on the “Cookies Settings” link, to choose your preferences.

You can set your web browser to warn you about attempts to place cookies on your device or limit the type of cookies you allow.

If you disable cookies, you may lose some of the features and functionality of our Service.

F. Do Not Track

Note that EDGE POWER does not currently respond to Do Not Track signals, whether that signal is received on a computer or on a mobile device.

HOW CAN YOU CONTACT US?

If you have any questions, comments or concerns about our Privacy Notice or any other privacy issue please contact funplayworld@outlook.com.

If you have any questions or concerns that you think we have not adequately addressed, you may have the right to bring your question.

UPDATES

EDGE POWER reserves the right to amend the Privacy Notice from time to time, and EDGE POWER encourages you to consult the Privacy Notice regularly for changes.

If we make material changes to our Privacy Notice, we will tell you by placing a notice on this website or its equivalent in-game, or, if and as required by law, by sending you a notice to the e-mail address we have on file for you, prior to the change becoming effective. We may supplement this process by placing notices on game blogs, social network pages, and/or forums and on other EDGE POWER websites. You should periodically check this privacy page for updates.

LINKS TO OTHER SITES/APPS

The Services may include links to other websites and/or applications that are owned and/or operated by others. Any information you provide on such websites and/or apps are subject to the privacy policy on such website or app, and EDGE POWER is not responsible for the content, privacy policy, terms of use, or security practices of such site and/or app. You should review

SERVICE SPECIFIC INFORMATION

In this part of our Privacy Notice, you will find specific information on how your Personal Data is processed. For general information about data processes, please see above.

Hosting and content delivery

Game is hosted by external companies providing web servers and web content delivery. Every time you make a request, for example by clicking on a link on our platform, the information allowing this request (e.g. device information and information on requested content) will be sent to the external servers. This data is used to show you the content you requested in a faster way. We process this data on the basis of our legitimate interest, to provide and improve our service and ensure its functionality.

Age gating and consent

When you visit Game for the first time, we will ask you to fill in your age. We use your age data to ensure that only adults play Game and that no personal data belonging to minors is processed except for that data that is strictly necessary to make the Service Websites work. Data about your exact age is not stored in this context.

For iOS applications, with iOS 14.5 update, Apple introduced App Tracking Transparency Framework (ATT) which requires apps to ask for the permission of users if the app will access IDFA (“The Identifier for Advertisers”) of the users for the purposes of tracking. Such permission is requested from users via a pop-up (ATT pop-up). When you start the Game iOS app for the first time, you will see the ATT pop-up. Based on your choice we can receive your IDFA from Apple or not. The pop-up is managed by Apple and we can only change the information you see on the ATT pop-up. Therefore, if you would like to learn more about how ATT pop-ups work, we recommend you read Apple's policies. Please note that we still show our own consent pop-up in the iOS app after the ATT pop-up in order to ask your consent for additional purposes and to inform you in a more detailed way about our data collection practices.

Creation/administration of your account

In order to play Game, you have to create an account. We store your log-in data (your nickname, email address and password) to allow you to log in on different devices, based on the performance of a contract. If you choose to register using your e.g. Facebook, Plinga, Apple, Google, Microsoft, Samsung Galaxy or Huawei account, or enter our game from a third-party platform (e.g. Facebook or Google), we may receive certain information about you from the respective third-party provider like e.g. your name, your authentication token, you profile picture, your email address, and a list of your friends that also play the game. This information will be stored in your Game account. If the third-party platform has an achievements system to measure and show you your achievements in the games you play, and only if you have provided your consent to the third-party platform provider, we will send event data (for example, that you reached a certain level in Game) to the third-party platform provider so that this information will also be stored in your profile on the third-party platform. Please note that you can use our Services as a visitor. In that case, we do not ask for an email address, we only require your nickname and device identifier which will be combined with your account ID.

You can delete your Game account at any time, for example by submitting a deletion request to our support team using the contact feature within the game, use the account deletion button made available in the iOS application or support page on our website or by contacting our Data Protection Officer by email to funplayworld@outlook.com.

Customer service

If you contact us for customer support using the contact feature within the game, an external customer service provider will process the content of your request. As a first step, we will try to provide you with general information from our “Frequently Asked Questions” feature (FAQ), based on the keywords from your request. For example, if you have asked for information related to your account (e.g. on how to make changes in your account settings), we will suggest articles from our FAQ which contain account-related information (e.g. on why your account was blocked or on how to disconnect your Game account from Facebook). If the suggested articles from our FAQ do not contain the information you were looking for, we may ask you to provide your name and your email address in order to help you with your request.

This information will be processed together with your user ID (including segment), the last steps taken within the game, and device data (such as device model, battery status, free storage, device language, operating system version, carrier and platform). The request history will be stored in order to solve newer requests based on the information related to your previous request. Please note that if the request and correspondence with customer support is considered to be necessary for prevention of a crime, facilitation of an investigation related to public safety, protection of the security or integrity of our Service, or enable us to take precautions against liability or to protect our rights, we may store and share your request based on legal obligation. We process this data on the basis of the performance of a contract in order to provide you with our customer service.

Analytics

We use analytics services to understand which features you like in Game and how you use them. For this purpose, we process purchase events (the amount spent within the game), the purchase segment, the level you reached within the game, your session time, which saloons you played in, how many hands you played, whether you won or lost the game, the features you used (e.g. teams or chats), and how many friends you have in the game. We combine this information with campaign data (including the advertisement device ID, install data, your country and language, the campaign ID, and your user ID) to get an insight into campaign results and to create user segments for new user acquisition and remarketing purposes.

The use of analytics services also helps us to improve the game for you, to find crashes and issues in the game, and to improve the performance of our websites/apps. For this purpose, we process crash information, ANR information (the situation if the game freezes), and device information (battery, Wifi situation, CPU, memory). When you play Game from Microsoft Store, Microsoft can provide us data about the performance of the game and any problems you experience, including error reports. Error reports (also known as “crash dumps”) can include details of your software or hardware related to an error. This data will be used solely for finding and fixing bugs and errors and improving the game overall. Please note that we receive crash dumps from other platforms that our game is offered (e.g. Apple App Store and Google Play Store).

We also use Facebook Insights, an analytics service provided by Facebook and implemented through the Facebook SDK (SDK is a collection of software programs for the purpose of creating applications across web and/or mobile platforms for a particular operating system) which allows Facebook to collect your Personal Data when you play Game. Facebook’s analytics service combines your in-game data (such as the level you reached and the amount you spent within the game), the purchase segment, campaign data (creative views of and clicks on advertisements, advertisement Device ID, installs, your country and language, the campaign ID and your user ID), the session amount and session time, with Facebook's data about demographic data (for example your age, gender, country or language and likes) that Facebook knows from your Facebook profile. Facebook Insights provides us with aggregated information about our users which help us to improve our game and to adapt our services and ads to our target audience.

We also process your IP address and user id to determine the number of unique users of our Services within our group companies. We process your personal data in connection with this activity based on legitimate interest.

Social media sharing service

You may share content from Game with your friends via social media by clicking on the social media share button and using your social media platform credentials. Following your request, a screenshot from the game will be shared with the social media platform you wish to share your content with. We process this data based on your consent, which you provide by choosing to use the option to share content from Game via social media.

Data management service

We may create user segments and use these user segments for new user acquisition and remarketing purposes. The user segments are created based on your in-game behavior (such as your in- game purchases, your sharing activity, and the level you have reached within the game). For this purpose, your Personal Data, including your in-game behavior, your country, game language, segmentation, and the advertisement ID are collected and sent to a data management service provider.

Payments

If you make in-game purchases, you will be redirected to an external payment provider for the transaction of your payment. While we do not collect and do not receive any financial data (such as your bank account data), we collect or may receive from third-party payment providers basic information related to your transaction such as: the quantity of the product you purchased, the product name, your user ID, the payment ID, the price, the currency symbol, your country, the receipt, product ID (sku), and the operating system. When you play Game on a third-party platform (e.g. Facebook, Apple, Google), any purchases you make will be processed by that third-party platform and subject to that third-party platform’s terms of service and privacy policy. For these purchases as well, we do not receive your financial information, but may receive non-financial information related to your purchases as listed above.

We process your Personal Data in connection with your payments on the basis of the performance of a contract in order to facilitate your in-game purchase.