Privacy Policy

Updated on: [3/15/2022]

 

Welcome to [Moving Castle]!

This Privacy Policy is concluded between you ("you") and [JJWORLD NETWORK TECHNOLOGY LIMITED] ("we") and applies to [Moving Castle] products and Ancillary Services (collectively the "Products"). JJWORLD NETWORK TECHNOLOGY LIMITED is the service provider and operator of the Products.We fully respect your privacy and are committed to protecting it by complying with the Policy and applicable laws and regulations.

It is important to note that the Policy does not apply to products, services, websites or content provided by third parties ("Third Party Services"). We encourage you to read and review the privacy statement of each Third Party Service that you may choose to use.

Please be sure to read the Policy carefully to understand our practices regarding your personal information. If there are significant updates to this Policy, we will notify you in advance to let you know of the updates we have made in order to obtain your consent again. With respect to routine updates, you are deemed to have accepted the updated Privacy Policy by accessing or using our services.

We respect the protection of personal information of minors and children. Since we do not provide the Services to minors and children under the age of [18] (or other ages required by law in your country, such as 16 in the European Union, 13 in the United States and 14 in countries such as Japan), we do not knowingly collect, store, or otherwise make available to minors and children under the age of [18] (or other ages required by law in your country). If you are a minor or child under the age of [18], please stop registering for the Service immediately and do not provide us with any personal information about you; if you are the guardian of a minor and have reason to believe that we are storing information about the pupils under your guardianship, please contact us as soon as possible by the means set forth in the Agreement and we will promptly verify and process the information; if you are not the guardian of a minor or child, you are kindly advised to give us feedback on the situation in a timely manner.

This Policy will explain the following:

I. Information collection and use

II. How we store and protect your information

III. We may share, transfer or disclose your personal information

IV. How we deal with the personal information of minors

V. How to exercise your rights related to personal information

VI. Cookies and similar technologies

VII. Amendments to the Policy and notices

VIII. How to contact us

I. Information collection and use

1. In order to ensure your smooth use of the Products, we may ask you to provide us with certain personal information when using our services, and we will collect and use your personal information only for the purposes described in the Policy. We may collect personal information from you in the following ways:

(1) Information you voluntarily provide to us, such as your nickname, avatar, etc.;

(2) Information we obtain through the Products when you use it, such as login information, device information, usage data, transaction information, interaction information, etc.;

(3) In accordance with the laws, regulations and standards of related countries/regions, we may collect and use your personal information without your consent in the following cases:

1) Necessary for the conclusion or performance of a contract to which an individual is a party, or for the implementation of human resources management in accordance with the labor rules and regulations established by law and the collective contract signed by law;

2) Necessary for the performance of statutory duties or legal obligations;

3) Necessary to respond to public health emergencies or to protect the life, health and property of natural persons in emergency situations;

4) For the implementation of news reporting, public opinion monitoring and other acts in the public interest; provided however that, personal information is handled within a reasonable range;

5) Handle personal information that has been disclosed by individuals themselves or otherwise legally disclosed within a reasonable range in accordance with relevant national/regional laws, regulations and standards;

6) Other circumstances stipulated by laws and regulations.

2. In order to ensure that you can fully use our products, we will automatically collect information about your device or your use of the Products, including:

(1) Device information: When you begin using the Products, we will collect information about your device (such as a unique device identifier) based on your specific actions within the Products and the specific permissions you grant us during the installation and use of the Products;

(2) Usage data: When you use our services, we will collect detailed information about your use of our services as usage data, including your visitor account, IP address, network information, and other usage data generated when you use the Products, etc.

Please note that some of the above information cannot be used to identify a specific natural person on its own, and therefore cannot be considered personal information. Only when such non-personal information is used in combination with other information to identify a specific natural person, or in combination with personal information, will such information be considered personal information for the duration of the combination, in which case we will anonymize and delete such type of information, except with your consent or as otherwise required by law or regulation. The above information is essential to the provision of the Services. If you choose not to provide them, we may not be able to provide you with the Services in connection with the Products.

Please note in particular: We strongly recommend that you do not upload any information in the game that is identical to or associated with your real personal information or that of others, such as using your real name as a game nickname, providing your cell phone number or contact information in your profile, etc. Please aware that this action will have a very high possibility of leaking your personal information and privacy.

3. In order to provide you with a better service experience, we will collect and use your information for the following purposes, including the "required information or permission" column, which requires your express consent (such as active provision) or authorization; if you refuse to provide or refuse to authorize, you will not be able to use the corresponding functions. In addition, you may cancel or withdraw the authorization of the relevant permission by yourself or by contacting us, but your cancellation or withdrawal may affect the use of the Products or service functions.

No.	Services we provide	Purpose of use	Information or permission required
1	Application networking	Connecting to the network and logging into the game	Network information
2	Purchase goods, top-up record	So that you can purchase or recharge or provide the corresponding services	Unique device identification code, purchase/recharge history
3	Storage, sharing	Help users to store and share moments	Storage card content related to products or services
4	Update software	Download apk updates	Storage card content related to products or services
5	Associated game records	Read and store game data	Storage card content related to products or services

4. To improve the security of your use of our services, to protect you, other users or public safety and property from harm, to better prevent security risks, and to more accurately identify violations of laws, regulations or relevant agreements, we may use or integrate information about your device and usage data to help you conduct security risk detection, prevent security risks and take the necessary recording, auditing, analysis and disposal measures.

5. To the extent permitted by law, we may also use other methods to collect other information about you, your device, or your use of the Services, which will be explained to you at the time of collection and we will obtain your consent.

II. How we store and protect your information

1. The information we collect will be stored in accordance with the laws and regulations governing the protection of personal privacy data.

2. Currently, the personal data we collect from you may be stored on servers located in [Amazon, Singapore] and [Amazon, US West].

3. We generally retain your personal data for as long as we need to provide our services to you, which include data provided to us by you or others, as well as data generated or inferred from your use of our services. If there is a violation of the Policy, the terms of service, other relevant rules or applicable laws and regulations, we will close your account or give the penalty of suspension as appropriate. Please refer to the Service Agreement and relevant announcements for specific measures. If the account is closed, we will delete or de-identify your relevant information.

4. The security of your personal information is important to us, and we implement security measures designed to protect your personal information and regularly monitor the system for possible vulnerabilities and attacks. We are constantly improving these safeguards to ensure the security of your personal data.

5. We need to remind you, however, that no method of transmission or electronic storage over the Internet is 100% secure. We will endeavor to use commercially acceptable means to protect your personal information, and only with your full cooperation will we be able to achieve the best possible security of your personal information under the available technology and conditions.

III. We may share, transfer or disclose your personal information

We attach great importance to the protection of your personal information; therefore, we will only provide your personal information to third parties out of the principle of minimization, necessity and legality. Under normal circumstances, we will not share, transfer or disclose your personal information externally. We will share, transfer and disclose your personal information according to the following rules to the extent permitted by applicable laws and regulations, and in order to provide you with better service:

1. How we share your personal information with third parties

(1) We do not sell any personal information to third parties. We may share your personal information with our affiliates in order to improve and optimize our services;

(2) You acknowledge and agree that we may use your personal information for the purpose of improving the quality of our web services, conducting profile testing, product analysis, event planning, etc. and may provide your personal information to our affiliates and to vendors or independent third-party providers who work to advance the content of our web services.

Such third-party providers may be local operating partners in your area or technical support partners in countries other than your own that provide support for the web services, such as Facebook, Google, Apple and others. After the end of the service, they will be denied access to all such information, including all such information to which they previously had access. We promise not to provide, sell, rent, share or trade your personal information to any unrelated third party, unless we have your prior consent.

Providers of the aforementioned third party services (such as social media platforms, third party payment platforms, advertising partners, fraud detection service providers, anti-cracking and anti-fraud service providers, social sharing tool providers, customer support partners, etc.) may use cookies, web beacons and/or other tracking technologies to collect or receive data about you in accordance with their own privacy policies, and we have no control over the information collected by these third parties or their use of such information. Therefore, we strongly recommend that you review their privacy policy on their official website to learn more about their treatment of your personal information. If you become aware that any third party is collecting or processing your personal information unlawfully or in a manner that causes you concern, we encourage you to contact us and we will provide you with reasonable assistance to help you with the process. The list of third party providers we work with is as follows:

Please be aware that if you do not provide relevant information, you will not be able to use such services (such as for account binding, etc.). During your use of the Products, you may receive links to third-party websites or third-party offers containing content and services, and some third-party products or services can be accessed in the form of SDKs and other forms in order to provide you with some of the features in the Products, and you can decide for yourself whether to access or accept third party websites, products and services. Our Privacy Policy does not apply to products and services offered by any third parties. Since we do not substantially control third parties, the policies of third parties regarding the collection and processing of your personal information are governed by their respective privacy policies.

(3) We may also share your data with third parties in order to provide evaluation, analysis or other business services.

2. How we transfer your personal information

The Products do not transfer your information to any other parties, except for the following:

(1) With your express consent;

(2) If the Products are involved in a merger, acquisition or sale activity, which may affect your personal information, we will notify you of the change and your related rights to your personal information by email and/or on our website or other appropriate method;

(3) Where the Policy has explained or otherwise notified to you.

3. How we disclose your personal information

(1) We may need to disclose your information when requested to do so by a judicial or other competent authority;

(2) In addition, we may share your personal information with:

1) Our lawyers, accountants, auditors or similar advisors, when we ask them for professional advice;

2) Other third parties, for example, through your authorization to disclose certain information.

4. For the purposes described in the Policy, and as permitted by applicable laws and regulations and with your consent, we may transfer your personal information to the servers specified in Section II of the Policy for storage or processing. We will take appropriate security measures and safeguards to ensure that all such transfers comply with applicable local data protection laws.

IV. How we deal with the personal information of minors

1. Our services are not directed to minors under the age of [18] (or such other age as required by local law), and we do not knowingly collect personal information from minors.

2. If you are a guardian and wish to review the information we have collected from your guardian, or to correct or delete such information, you may contact us at any time. If we become aware that a minor has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we are legally obligated to retain the information and close the minor's account.

V. How to exercise your rights related to personal information

When you use the Products, you have the following rights with respect to the information you provide or we collect:

1. The right to access, update, supplement or delete your information. However, if you choose to delete such information, then some of the features of the Products may no longer be available;

2. Right to object and restrict. You have the right to object to our processing of your personal data or to ask us to restrict our processing of your personal data. You can ask us to stop using all or part of your personal data (for example, if we do not have the legal right to continue using it) or to limit our use (if your personal data is inaccurate or unlawfully held).

3. Right to withdraw consent. You have the right to withdraw your consent at any time, and you may do so by requesting withdrawal of consent by deleting information, turning off device features, etc. If you withdraw your consent, you may not be able to continue to use some or all of the features of the Products. Withdrawal of your consent or authorization will not affect the validity of our prior processing activities based on your consent.

4. Right to control your privacy settings. You have the right to control your privacy settings and to limit our collection, use, disclosure or processing of your personal information through such privacy settings. For example, you can choose to turn Location Access or Storage permissions on or off, and you can obtain details about the security status of your device or change that status in the Privacy Settings on your device.

VI. Cookies and similar technologies

1. Our website, the Products or other information services may use cookies and other similar technologies, such as pixel tags and web beacons. We generally treat the information collected by cookies and similar technologies as non-personal information since it does not contain any personally identifiable information about you. However, if an Internet Protocol (IP) address or similar identifier is considered personal information under the laws of the country in question, we will also comply with the laws of the country/region in question.

2. We and our partners may use cookies and similar technologies (such as pixel and ad tags) to collect data (such as device ids) to identify you and your device. You can manage or delete cookies according to your preferences.

VII. Amendments to the Policy and notices

We may revise this Privacy Policy from time to time, but we will update it in real time by posting it on the Services' official website or through a webmail or email. In such cases, by continuing to use our services, you agree to be bound by this Privacy Policy as amended, unless it is a material change involving your rights and interests, in which case we will obtain confirmation from you or your legal guardian again in the form of a pop-up window when you log back into the Services.

VIII. How to contact us

1. If you have any comments, questions or concerns about our privacy policy or personal information protection practices or to assert your rights, complaints or inquiries to us, you may contact our personal information protection staff at the following way: email [castle@service.jj.cn] so that we can better assist you.

2. We will review your request for privacy or personal information as soon as possible after receiving your request or suggestion, and will respond within [15] days after confirming your user status. In case of special or complicated circumstances, our feedback may be extended accordingly, and if your request itself involves any complex or significant issues, we may ask you to provide more information. In addition, you understand and are aware that we will not be able to respond to your request in cases where laws or administrative regulations require confidentiality or that you are not required to be informed, and that we will provide you with specific reasons for this within the time limit.

If you are a resident of Malaysia, we will respond to your request within 21 days, or if we are unable to do so on time, we may extend the corresponding processing period by written notice to you, but the final processing duration will not exceed 35 days.