Privacy Policy

Last updated: May 9, 2023

 

By using the Seasun Games Installer desktop app software (“Platform”)content, functionality, product and any related services, whether in whole or in part, provided by us (collectively, the "Services") , you are deemed to accept the terms of this Policy, and to expressly acknowledge and, where required, consent to our processing of the information you provide to us for the purposes outlined in, or otherwise in accordance with this Policy. If you do not agree with the terms of this Policy, please uninstall the applications immediately and do not continue to use the Services. Your access and use of Seasun Games Services is also subject to our Terms of Service, and all capitalized terms not defined in this Policy will have the meanings set forth therein.

 

Parental and Guardian Consent

 

ANYONE UNDER THE AGE OF 13 US/ 14 (KOREA )/16(EU,UK )OR THE MINIMUM AGE OTHERWISE DEFINED IN “COUNTRY / REGION SPECIFIC TERMS" UNDER THE APPLICABLE LAWS OF YOUR JURISDICTION (“MINIMUM AGE”) SHALL NOT USE SEASUN GAMES APPLICATIONS/SERVICE. WE WILL ALSO NOT KNOWINGLY COLLECT OR STORE ANY PERSONAL INFORMATION ABOUT CHILDREN UNDER THE AGE OF 13 US/ 14 (KOREA )/16(EU,UK ) WITHOUT PARENTAL PERMISSION.

 

IF YOU HAVE REACHED THE MINIMUM AGE BUT ARE UNDER THE AGE OF MAJORITY AS DEFINED UNDER THE APPLICABLE LAWS OF YOUR JURISDICTION (“MAJORITY AGE”), YOU MAY ONLY USE AND REGISTER A SEASUN GAMES APPLICATIONS/SERVICE ACCOUNT (“ACCOUNT”) THROUGH YOUR PARENT OR LEGAL GUARDIAN’S REPRESENTATION, AND YOUR PARENT OR LEGAL GUARDIAN HEREBY REPRESENTS YOU AND ACCEPTS THIS POLICY.

 

If you are a minor in your country or region, your use of Seasun Games Services may be subject to further age restrictions, whether imposed by us or third-party vendors in connection with the provision of certain Services. You may be unable to use those Services.

 

If you learn that a child under the Minimum Age has registered a Seasun Games Account or an Account of a child under the Majority Age was not registered under proper supervision, representation or guardianship, you may alert us at support@seasungames.com.We will promptly investigate, take steps to remove such child’s Account information from Seasun Games Services and terminate the child’s Account.

 

Summary of this Policy

This summary is not intended to substitute or replace any part of the Privacy Policy, but aiming to help you understand the core information contained in the Privacy Policy through a quick overview. We strongly recommend that each user carefully read the entire Privacy Policy and Terms of Service.

 

Data we collect

We collect the data provided to us by Seasun Games Services users, such as account information, content uploaded by users, etc. We may also collect data as you use our services, such as your activities on the Platform, your device, and internet information.

 

How data is used

We use the data we collect to deliver and maintain our services. and your queries to provide customer services. Your data may also be used for troubleshooting, improving our services.

We may use the data we collect from you to optimize user experience, Where it is necessary, we may also use your data to ensure security of the platform, detect and prevent fraud, or comply with our legal or regulatory obligations.

 

Storage and transfer

We store your data in our data center located in Singapore. We use and keep your data to the extent that is necessary to achieve the purposes for which it is collected, including to provide our services to you, to fulfil our legal obligations, or to protect our legitimate interests.

  

Your rights in relation to your data

You have certain rights in relation to your data, subject to applicable laws. Once you have completed your account registration and verification, you can review, modify, and delete your data. We may need to retain some of your data, like your initial registration information, for verification and security purposes.

 

You can also ask us to delete your account. This is an irreversible process as you will not be able to access your account upon deletion, and all data in relation to the account will be deleted or de-identified, subject to any statutory retention requirements under applicable laws and regulations.

For more help, please contact us with support@seasungames.com.

                                                                                                                 

If you reside or use Seasun Games Services in a country or region specifically mentioned under the Section "Country / Region Specific Terms" below, those terms and conditions under the relevant country/region shall specifically apply to you.

 

Unless otherwise indicated in the Section “Country / Region Specific Terms”, Seasun Games Pte.Ltd(“we”, “us”, “our”, “Seasun Games”, or the “Company”) serves as the legal entity controlling and operating Seasun Games Services . We value your privacy and data protection and are always committed to protecting user data in our day-to-day practices. This Privacy Policy (this “Policy”) describes how we collect your personal data (“Data”) when you use Seasun Games Services, and also explains how we use, store and share the Data we collect from you, as well as your rights in relation to the Data.

 

In this Policy, “you” or “your” refers to the authorized user of our Seasun Games Services.

 

1. Data We Collect

 

We may collect the following categories of Data from and about you:

 

(1) Registration and contact information, such as email address, user name and other information you choose to provide when creating a profile or submitting a request;

(2) Device information, in order provide our Services and correct bugs or errors that occur when you are using the Platform, we will collect relevant devices information including but not limited to device ID, device Model, Device language and version, OS name, OS version, time zone, IP, MAC Address, System logs at the time of the crash, Server Access log.

The categories and scope of Data we collect about you may vary from time to time, depending on your choice of and interaction with Seasun Games Services, as well as the country or region where you use Seasun Games Services.

2. How We Use Your Data

We may use your Data for a number of purposes associated with operating our business and providing Seasun Games Services to you, including:

 

(1) Identification and authentication: We use your Data to verify your identity or eligibility across Seasun Games Services when you access and use our services, such as receiving rewards or prizes, or otherwise engaging with us, and to protect the security of your data. In some instances, we use your data to verify your age in order to provide certain services to you in order to fulfill your request in relation to your Data.

(2) Service provision: We process your data to provide Services that you request, to respond to your queries, or to contact you about changes to the Platform. This may also include managing the content ecosystem across the Platform, enabling application features or special effects, facilitating third party partnerships or integrations across Seasun Games Services, monitoring and testing Seasun Games Services, troubleshooting.

(3) Service and development, and research: We inspect and analyze usage information and statistics to maintain and improve Seasun Games Services. We may also use your data to support customer services and user feedback, conduct survey or research and develop new services.

(4) Exercising our rights: We may use your data to exercise our rights where it is necessary to do so, for example to detect, prevent, investigate and respond to security incidents or breaches, data scrapping, fraud, abuse, intellectual property infringement claims, financial crimes, other violations of law, or violations of our Terms of Service

(5) Fraud Prevention & Anti-Cheat: Providing users with a fair, balanced, and competitive experience on the Seasun Games Services is extremely important to us. We strictly enforce prohibitions against cheating, hacking, account stealing, and any other unauthorized or fraudulent activity on the Seasun Games Service. We use a variety of anti-cheat and fraud prevention technologies to help us identify and prevent malicious activity. These services may collect and analyze data about your computer and the software on your computer to detect cheating and may be provided by us or by service providers.

(6) Complying with our obligations: We may process your data to comply with legal or regulatory obligations, including without limitation our legal obligation to prevent users under the Minimum Age from accessing the platform, to respond to lawsuits, damages or investigations, within or outside of your country or region or in any instance of mergers, acquisitions, sales and asset transfers, insolvency proceedings, corporate restructuring, winding up or liquidation. We may also aggregate and/or de-identify your data and may use such aggregate or deidentified information for any other purposes.

 

 

3. Our Legal Basis for Processing Data

 

In order to process your data, we will rely upon the legal bases afforded by applicable laws and regulations. In addition to your consent, which will always be limited to specific processing activities and include relevant, detailed information required for you to fully understand what you are consenting to, these legal bases may also include our compliance with legal obligations, the performance of an agreement with you, and our legitimate interests.

 

4. Data Storage and Retention

 

(1) We store your data on our servers located in Singapore. We also have support, engineering, content moderation, and other functional teams located around the world to support Seasun Games Services provided to you. We have rigorous internal control measures in place to strictly limit data access to designated personnel only.

(2) We will retain your data for as long as necessary: (i) to achieve the purposes as set out in this Policy; (ii) as required by applicable laws and regulations, including any requirements to retain data for a certain period of time, taking into account the statute of limitations under applicable laws and regulations; (iii) for our legitimate and lawful purposes, including for our business, and provision of Seasun Games Services; and/or (iv) to defend against any actual, threatened or potential claims or disputes.

(3) We will not retain your data for longer than necessary or beyond the end of the purposes for which you provided your data to us, unless we are required to do so under applicable laws.

 

5. Data Security and Protection

(1) We will take appropriate technical and organizational measures to help protect and secure your data. We will endeavor to protect your data against unauthorized or unlawful processing, accidental loss, destruction, or damage through these measures, including:

(i) using encryption techniques;

(ii)   establishing specialized systems and procedures, such as strictly limiting the scope of personnel with access to your data, and requiring those who have such access to comply with relevant confidentiality obligations; and

(iii) forming a specialized department in charge of information security. In the event of incidents such as information leakage or data or security breach, we will take timely measures to handle such incidents, and we will notify you promptly in an appropriate manner, including through messages or announcements.

(2) We will endeavor to ensure that, by default, we only collect and process your data needed to provide Seasun Games Services. We also apply this principle to our data privacy and protection controls into our processing activities. This means that we will neither publish nor share your data by default.

(3) While we are committed to protecting your data, no electronic data transmission or storage of information can be completely secure. If you do not agree to these risks and conditions, you must discontinue your use of Seasun Games Services.

 

6. To Whom We May Share Your Data

(1) We will not share any of your data to any third parties except as explicitly provided in this Policy. We will only share your data with third parties in the following circumstances:

(i) when approved or authorized by you or subject to the “Parental and Guardian Consent” section, your parent or legal guardian;

(ii) as required for administrative or judicial purposes, including any requirements of competent authorities, courts and regulatory bodies;

(iii) in any legal proceedings (including arbitrations) against you in which we aim to protect our legal rights;

(iv) where expressly allowed by the Terms of Service;

(v) in order to protect the interests of the Company, you or the public against harm; or

(vi) pursuant to the agreements made by you with any other third parties.

(2) We may share your data with our corporate affiliates, group members, and the following third parties (“Details”), who will only use your data in accordance with this policy to facilitate the provision of Seasun Games Services to you or for other purposes as indicated below.

(i) In the context of a transaction including mergers, acquisitions or asset sales: We may transfer your data to another legal entity for the purposes of a collaboration, joint venture, corporate reorganization, change of legal form or other similar event. In order to develop our business, we may engage in transaction such as mergers, acquisitions, sales and asset transfers. In these circumstances, we will inform you of the related transactions, and will continue to protect or require the successor to protect your data in accordance with applicable laws and regulations and this Policy.

(ii) Third parties in support of Seasun Games Services: We may engage or cooperate with third parties to perform functions or provide services. We share your data with these service providers for purposes such as hosting or operating our Services, payment and transaction processing, rewards, vouchers and commercial goods delivery (where applicable), cloud services, e-mail communication, research, survey, marketing and data analysis services. We will only share your data on a need-to-know basis with third parties in order for them to perform corresponding functions and services, and we will request such parties to maintain appropriate security measures to protect such data from unauthorized access or processing.

(iii) Legal, regulatory or government authorities: We may in limited cases transfer game data to local (where you reside) or overseas authorities such as legal, regulatory, law enforcement, government and tax authorities, to satisfy our obligations or those of third parties (when they receive a request from an authority empowered by law to do so), pursuant to applicable laws and regulations.

(iv) Promotions: If you choose to register for a promotion, such as a competition, sweepstakes, lucky draw, contest, reward program for user or creators, your data may be disclosed to third parties for the purposes of administering such promotion.

(v)  Other business partners: Where shopping features are available, our business partners may offer goods or services to you through Seasun Games Services. When you interact with or order such goods and/or services, we will share your data such as your user ID with such business partners to facilitate your transactions and to show you the status of orders made through Seasun Games.

(3) Except as otherwise provided in this Policy, we will not disclose any of the data collected from your use of Seasun Games Services to the public. If public disclosure is required by applicable laws and regulations, we will inform you of the purpose of the disclosure and the type of information disclosed.

 

7.  International Data Transfer

 

We may transfer your game data and to other countries or regions solely for the purposes set out in this Policy, in accordance with this Policy and applicable laws and regulations. Data disclosure as referred to in this Policy may involve a transfer of your data to countries and regions that provide different levels of data protection. Applicable legal and regulatory requirements are taken into consideration before any cross-border transfer of your data takes place and our policies are as follows:

 

(1) We may share your data with our other group entities in other jurisdictions for internal, business and operational purposes in order to provide Seasun Games Services. We will ensure, by way of appropriate contractual guarantees which will also be in compliance with applicable laws and regulations, that all such entities with which we share your data maintain appropriate security measures to protect your data from unauthorized access or processing and will not share this your data with any third party unless you expressly agree otherwise.

(2) In order to provide Seasun Games Services to you, we may need to transfer your data internationally to non-affiliated entities, which will only occur pursuant to the international transfer mechanisms available under applicable laws and regulations. If the country or region to which your data is being transferred does not provide an adequate level of protection to your personal data as required by applicable laws and regulations, your data may be transferred internationally based upon your prior consent, our exercise of a legal right, our compliance with a legal obligation, or the performance of a contract with you, among other mechanisms available under applicable laws and regulations.

 

8. Data Access and Management

(1) Once you have completed your Account registration and put in place reasonable and necessary authentication measures, you can review, modify, and delete the data you have submitted to us by using the contact information provided in “Contact Information” of this Policy. In general, you can browse, modify, and delete your own information at any time, but you may not be able to modify certain initial registration information and verification information provided at the time of registration for security and identification purposes.

(2) You may have the following rights to the extent applicable under local laws and regulations which you can exercise by using the contact information provided in this Policy:

(i) You have the right to be informed in a concise, transparent, intelligible and easily accessible form of the way in which your data is processed. You also have the right to obtain confirmation as to whether or not data concerning you is being processed, and, where that is the case, to access such Data and obtain a copy thereof.

(ii) You have the right to request rectification of your data. You also have the right to have incomplete data completed.

(iii) Where you have provided your consent, you may withdraw your consent. If you withdraw your consent, we may continue processing your data to the extent permitted by applicable laws and/or set out in this Policy.

(iv) You may also have other rights as described under the "Country / Region Specific Terms" section below or otherwise under the local laws.

(3) We will verify your identity first before we can fulfill your request. We will respond to your request within the timeframe as required by local laws.

(4) You may also be able to change your cookie settings as described in the section below to manage the data we collect using cookies.

(5) You can prevent us from obtaining your data by suspending certain functions provided by our Services.

(6) You can ask us to delete your Account, which is an irreversible process as you will not be able to access your Account upon deletion, and all data in relation to the Account will be deleted or de-identified, subject to any statutory retention requirements under applicable laws and regulations. If you wish to have your account deleted, you can contact us by using the contact information provided in “Contact Information” of this Policy or through the in-app setting “Account Protection – Account Deletion”.

 

9. Cookies

Cookies are pieces of information that any website or app may transfer to your browser that are then stored in your computer or mobile system. For example, the deposit of cookies enhances your online experience by allowing us to save your preferences.

 

We use cookies and automatically collected information to:

 

(1) Monitor aggregate site usage metrics such as total number of visitors and pages viewed; and

(2) Track your entries, submissions, and status in any activities offered through our Services (services adapted to your profile). Tracking technology also helps us manage and improve the usability across Seasun Games Services.

 

If you do not want us to collect your data through the use of cookies, you can set your web browser to reject cookies from Seasun Games Services. Each browser is different, so you should check your browser’s menu to learn how to change your cookie preferences. Please note that if you reject or block cookies from Seasun Games Services, Seasun Games Services may not function as intended.

 

10.   Changes to the Policy

 

We may update, change or modify the terms hereof from time to time, and such changes shall form a part of this Policy. We will notify you about those changes through general announcements on our services or by sending a notification to you when you log into or update the app. Unless otherwise indicated, any update, change or modification will become effective on the same day of notification and apply to all of your data.

 

11.   Contact Information

 

If you have any complaints, suggestions or questions regarding this Policy or in relation to the collection, usage, storage, protection and other functions of your Data, please contact us via the in-app feedback or complaints functions or by email to support@seasungames.com. If a data protection officer is required under the local law of your jurisdiction, you may also contact the data protection officer using the contact details provided in the "Country / Region Specific Terms" section below. We will review the issues involved as soon as possible and reply to you in a timely manner as required by applicable laws. If you have any concerns regarding how we are handling your Data, please contact us. We will endeavor to address your concerns promptly.

12.  Country / Region Specific Terms

California residents

The California Consumer Privacy Act or “CCPA” grants consumers residing in California certain rights with respect to their personal information. We are committed to respecting the following rights and complying with the CCPA. If you are a California resident, you may have the right to: (i) request to know more about the categories and specific pieces of personal information we collect, use, and disclose; (ii) request deletion of your personal information; (iii) opt out of sale of your personal information (if any); and (iv) not be discriminated against for exercising these rights.

For details about the precise data we may collect and the categories of sources where we got that information during the past 12 months, please see “Data We Collect” above. We collect personal information for the purposes described in “How We Use Your Data” above.

To learn more about asking us to delete your personal information. Please note that your request to delete data may impact your use of the our service in some cases, and we may decline to delete information for reasons set forth in this Privacy Policy or as permitted by the CCPA.

Seasun Games do not sell the personal information we collect and have not done so during the past 12 months. However, we may disclose personal information as described in “How we share, transfer and disclose your personal information” above.

We will not discriminate against you if you exercise your rights under the CCPA.

Residents of the European Economic Area, the United Kingdom and Switzerland

We are committed to respecting the following rights and complying with the GDPR. If you are located in the European Economic Area (EEA), United Kingdom (UK) or Switzerland, UK or Switzerland, you may have the right to: (i) access, correct or delete the personal information we collect about you through our services; (ii) obtain a portable copy of the personal information you provide and to object or restrict the processing of your personal information, for example for direct marketing; (iii) withdraw your consent to our processing of data; and (iv) lodge a complaint with us by contacting your local data protection supervisory authority (if such an authority is located in your country).

The legal basis on which we process your personal information depends on the services you use and how you interact with them.

You have the right to object to our processing of your personal information. We will no longer process your personal information after your objection unless there are compelling and prevailing legitimate grounds for the processing in accordance with applicable law.

You also have the right to lodge a complaint at a supervisory authority. However, before you contact the data protection supervisory authority, we would like to have the opportunity to address your concerns and ask that you first lodge a complaint with us. Please see the "Contact Us" section below for more information on raising any related concerns with us.