Welcome to the games or mobile applications (hereinafter collectively referred to as the “APP”) provided by PandaUpStudio (hereinafter referred to as “we” or “us”). We recommend that you read this Privacy Policy in its entirety to understand how to protect your right to privacy. If you have any questions about this Privacy Policy, you may contact us through the contact information published on our platform.
We attach great importance to the protection of minors’ personal information. If you are a minor, we recommend that you ask your legal guardian to read this Privacy Policy carefully, and you may only use our services or provide us with information with the prior consent of your legal guardian.
This Privacy Policy is designed to help you understand in detail how we and our third-party partners collect, use, store, transmit, share, and protect your personal information, as well as how you can inquire about, access, delete, correct, and withdraw authorization for your personal information, primarily through the following sections:
- How We Collect and Use Your Personal Information
- How We Use Cookies and Similar Technologies
- How We Share, Transfer, and Disclose Your Personal Information
- How We Store Your Personal Information
- How We Protect Your Personal Information
- How You Can Manage Your Personal Information
- Terms for Minors
- Revisions and Notifications to This Privacy Policy
- How to Contact Us
1. How We Collect and Use Your Personal Information
1.1 Information You Voluntarily Provide
(1) Information you actively provide to us when accepting or using our services, including:
① Personal information you provide when registering as our user;
② Information you upload, publish, or provide when accessing specific services or functions of ours;
③ Information you submit when participating in our online or offline activities;
④ Information you provide to our customer service or other official channels.
(2) Information we obtain when you accept or use our services, including:
① Log Information: When you use our services, we may automatically collect relevant information and store it as service log data.
② Location Information: When you use our services or access specific functions within our services, we may collect the geographic location information of your device.
③ Other Information: To better provide you with services and improve the quality of our services, we may need to collect other relevant information about you with your consent.
(3) Information about you provided or shared with us by other parties:
① Information about you, or information that may contain content related to you, provided by other users when they use our services.
② Information about you generated, provided, or shared when you use the services of our third-party partners, which is shared with us by such partners. In such cases, please carefully read the user agreement or privacy policy of the third-party partner’s services. We will comply with both this Policy and the privacy policy of the third-party partner to achieve the goal of “minimizing utilization and maximizing protection” of your user information.
1.2 Information Collected and Used by Us or Our Cooperating Third-Party Platforms, and Permissions Obtained
To provide you with better products or services, we have integrated third-party services into the APP (including but not limited to real-name authentication, data analysis, third-party payment, and advertising delivery). When you use our products or services, to ensure the normal operation of the APP and optimize the user experience, we and our cooperating third-party platforms may collect certain device-related information and personal information by requesting device permissions during the installation and use of the APP (including: device information, external storage read/write permission, and location information).
- Device Identification Information (e.g., hardware model, operating system version, device settings, IMEI, necessary software list, etc.)To ensure your normal use of our products or services, realize the statistics and analysis of APP data, and enhance the security of your device account, our cooperating third-party platforms will, with your consent, collect information such as your device ID, device name, device type and version, system version, IP address, MAC address, IMEI, app ID, network connection status, software list, and the method and type of network access. Refusal to authorize our cooperating third-party platforms to obtain the above information may result in your inability to use our APP normally or subject you to corresponding restrictions during use.
- Storage PermissionTo ensure you can fully use all functions of the APP and save player data, we and our cooperating third-party platforms will, with your consent, obtain the storage permission of your mobile device. Refusal to authorize us or our cooperating third-party platforms to obtain the storage permission of your mobile device may result in your inability to use our APP normally or subject you to corresponding restrictions during use.
- Geographic Location InformationTo enrich the APP experience and achieve content diversity, our cooperating third-party platforms will, with your consent, collect your geographic location information. Refusal to provide geographic location information will only prevent you from using functions related to location information, but will not affect your normal use of other functions of our APP. You may also revoke the authorization for our cooperating third-party platforms to obtain your geographic location information at any time.
- Real-Name Identity InformationTo comply with the requirements of relevant laws, regulations, policies, and competent authorities, our game users are required to complete real-name authentication to continue using our games. Our cooperating third-party platforms will, with your consent, require you to provide your real-name identity information. Such information is classified as sensitive information. Refusal to provide real-name identity information may result in your inability to log in to our games or subject you to corresponding restrictions during use. If you wish to learn about the specific rules for the collection of personal information by third-party service providers, please refer to the privacy policy of the third-party payment service provider you choose.
1.3 Exceptions and Special Circumstances for the Collection and Use of Information
1.3.1 Exceptions
In accordance with relevant laws, regulations, and national standards, we or our cooperating third-party platforms may collect and use your relevant personal information without your prior authorization or consent in the following circumstances:
- Directly related to national interests such as national security and national defense security; directly related to major public interests such as public safety, public health, and public right to know;
- Directly related to criminal investigation, prosecution, trial, and the execution of judgments;
- Necessary to protect the vital legitimate rights and interests of you or other individuals, such as life, property, or reputation, where it is difficult to obtain the individual’s consent;
- The personal information collected is voluntarily made public by you to the general public;
- Collecting personal information from legally publicly disclosed information, such as legitimate news reports, government information disclosure, and other channels;
- Necessary for the conclusion and performance of a contract at your request;
- Necessary to maintain the safe and stable operation of the provided products or services, such as detecting and handling faults of the products or services;
- Necessary for conducting statistical or academic research in the public interest, and when the results of such research or descriptions are provided to the public, the personal information contained in the results has been de-identified;
- Other circumstances as stipulated by laws and regulations.
1.3.2 Special Circumstances
Please understand that the functions and services provided to you by us and our cooperating third-party platforms are constantly updated and developed. If a certain function or service we provide requires the acquisition of new permissions not mentioned in the above description, we will separately prompt you to choose whether to authorize it through a pop-up window in the APP, and update and explain it in the APP’s privacy policy. If a certain function or service provided by a third-party platform requires the acquisition of new permissions from you, the third-party platform may update and explain it in its published privacy policy. If you wish to learn about the latest status of the permissions obtained by third-party platforms, you may check the latest privacy policies of such third-party platforms.
2. How We Use Cookies and Similar Technologies
2.1 Cookies and similar technologies are commonly used in the Internet industry. When you browse, log in to, or use our APP, we or our cooperating third-party platforms may use relevant technologies to send one or more Cookies or anonymous identifiers to your device. These technologies are used to collect and store information about your access to and use of the APP, analyze your preferences for using our APP, and thereby optimize the user experience. We promise that we will not use Cookies for any purposes other than those stated in this Privacy Policy.
2.2 When using Cookies or similar technologies, we will strictly comply with the relevant laws and regulations on mobile Internet application security, and provide effective security measures to protect your personal information. If you wish to learn in detail how our cooperating third-party platforms use Cookies or similar technologies, you may refer to the privacy policies of such third-party platforms.
3. How We Share, Transfer, and Disclose Your Personal Information
We will strictly comply with relevant laws and regulations, keep your personal information confidential, and will not sell your personal information to any third party. We will only share, transfer, or disclose your personal data for legal, legitimate, necessary, specific, and clear purposes, and on the premise of adopting security protection measures that meet industry standards. The personal information used for sharing, transfer, or disclosure will be de-identified, and the third parties with whom it is shared will not be able to re-identify the natural person subjects to whom such information relates.
3.1 Sharing
We may share your personal information in the following circumstances:
- With your prior explicit consent or authorization;
- As required by applicable laws and regulations, or based on mandatory requirements from judicial or administrative authorities;
- Necessary to protect the legitimate rights and interests of you, other users, or other individuals, such as life and property, or the public interest, within the scope permitted by laws and regulations;
- As required by the legitimate request of your legal guardian;
- As provided for in the relevant agreements (including service agreements) signed with you or other legal documents;
- We may share your personal information with our affiliated companies based on your corresponding authorization. However, we will only share the necessary personal information, which will be subject to the purposes stated in this Privacy Policy. If an affiliated company intends to change the purpose of processing the personal information, it will promptly obtain your explicit consent.
3.2 Transfer
We may transfer your personal information in the following circumstances:
- With your prior explicit consent or authorization;
- As required by applicable laws and regulations, legal procedures, or mandatory administrative or judicial requirements;
- As provided for in the relevant agreements (including service agreements) signed with you or other legal documents;
- In the event of changes such as acquisition, merger, bankruptcy liquidation, or restructuring, if the transfer of personal information is involved, we will require the new company or organization that holds your personal information to continue to perform the responsibilities and obligations under this Privacy Policy. If the transferee intends to change the purpose of using the personal information, we will require it to obtain your explicit consent in advance.
3.3 Public Disclosure
We may publicly disclose your personal information in the following circumstances:
- Disclose the specific personal information you designate in the manner of disclosure you explicitly agree to, in accordance with your needs;
- We may publicly disclose your personal information as required by laws, regulations, or mandatory requirements from administrative or judicial authorities. When receiving such a disclosure request, we will legally require the requesting party to provide relevant legal documents, such as a subpoena or investigation letter. We will carefully review each disclosure request to ensure that it complies with relevant legal provisions. To the extent permitted by laws and regulations, we will encrypt and protect the documents containing the disclosed information.
4. How We Store Your Personal Information
4.1 We will only store your personal information for the period necessary to achieve the purposes stated in this Privacy Policy and the minimum time limit required by laws and regulations. If we terminate our services or operations, we and our cooperating third-party platforms will immediately stop collecting your personal information. At the same time, we will comply with the requirements of relevant laws and regulations to notify you in advance, and will delete or anonymize your personal information after the termination of services or operations, unless otherwise stipulated by laws, regulations, or regulatory authorities.
4.2 Personal information collected and generated by us during our operations within the People’s Republic of China (PRC) will be stored within the PRC, except in the following circumstances:
- Explicitly stipulated by laws and regulations;
- With your authorized consent;
- Currently, we will not transmit the above information outside the PRC. If we need to transmit it outside the PRC in the future, we will comply with the relevant national regulations or obtain your consent;
- For the above circumstances, we will ensure that your personal information is adequately protected in accordance with this Privacy Policy and the requirements of national laws and regulations.
5. How We Protect Your Personal Information
5.1 We will adopt strict security systems and industry-standard security technologies and procedures to ensure that your personal information is not lost, disclosed, damaged, or misused.
5.2 Our services will use encryption technologies, anonymization, and other reasonable means that meet industry requirements to encrypt and store your personal information, and isolate it through isolation technologies. We will also adopt strict data access permission control and multi-factor authentication technologies to protect personal information and prevent unauthorized use of data.
5.3 We will enhance employees’ security awareness and their understanding of the importance of information protection by establishing data security management specifications and adopting strict data access permission control.
5.4 We will only allow personnel who need to know such information to access personal information data, and have set up strict access permission control and monitoring mechanisms for this purpose. We also require all personnel who may have access to your personal information to fulfill corresponding confidentiality obligations. Failure to fulfill these obligations may result in legal liability or the termination of the cooperative relationship with us.
5.5 We will take all reasonably feasible measures to ensure that we do not collect personal information irrelevant to our APP services.
5.6 The Internet environment is not 100% secure, and we will make every effort to protect the security of your personal information. In the event of a security incident such as the leakage, damage, or loss of your personal information, we will, in accordance with the requirements of laws and regulations, promptly notify you of: the basic facts and possible impacts of the security incident, the disposal measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you. At the same time, we will promptly notify you of the relevant circumstances of the incident via email, letter, telephone, push notification, or other means. If it is difficult to notify each information subject one by one, we will adopt a reasonable and effective way to issue a public notice. In addition, we will also take the initiative to report the disposal of the information security incident to the regulatory authorities in accordance with their requirements.
5.7 When you obtain virtual products related to our APP through payment, the transaction will be processed by a third-party payment service provider. At that time, you will inevitably need to disclose your information to the counterparty or potential counterparty of the transaction, such as contact information, bank account, or email address. Please properly protect your information and only provide it to others when necessary.
5.8 If we detect that you are using our APP, services, and related information for fraudulent or illegal purposes, we will take corresponding measures, including but not limited to suspending or terminating your right to use our APP or services.
6. How You Can Manage Your Personal Information
6.1 Access, Update, and Delete Personal Information
We attach great importance to your right to manage your personal information. You may, in accordance with the guidelines within our APP, access, update, and delete your personal information in the APP or in the third-party services integrated into the APP. When accessing, updating, or deleting the aforementioned information, we may require you to complete identity verification to ensure information security.
6.2 Account Cancellation
If you wish to cancel your APP account, you may submit an account cancellation application in accordance with the guidelines in our APP, or contact us through the contact information listed in Section 9 of this Privacy Policy. We will provide you with detailed instructions on how to cancel your APP account.
6.3 Unless otherwise stipulated by laws and regulations, when you update or delete your personal information or apply for account cancellation, we may not immediately update or delete the corresponding information from the backup system, but we will update or delete such information when the backup is updated.
7. Terms for Minors
7.1 If you are a minor under the age of 18, you should read and agree to this Privacy Policy together with your parents or other legal guardians under their supervision and guidance before using our APP and related services.
7.2 We will protect the personal information of minors in accordance with the provisions of relevant national laws and regulations. We will only collect, use, store, share, transfer, or disclose the personal information of minors when it is permitted by law, explicitly agreed to by their parents or other legal guardians, or necessary to protect the minors. If we discover that we have collected the personal information of a minor without prior verifiable parental consent, we will take measures to delete the relevant information as soon as possible.
7.3 If you are the legal guardian of a minor, and you have any questions about the personal information of the minor under your guardianship, please contact us through the contact information published in this Privacy Policy.
8. How to Contact Us
8.1 We highly respect the privacy of each user and make every effort to protect users’ personal information. If you have any questions, comments, or suggestions about this Privacy Policy, you are welcome to contact us during working hours (9:00 – 18:00, Monday to Friday), and we will reply to you as soon as possible.
Customer Service Email: PandaUpStudio@gmail.com
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