Privacy Policy

Last Updated: [2025-4-17]

Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Please note that this privacy policy (“Privacy Policy”) only applies to CFL, Crossfire: Legends (“Game”), Game Website, and Game activities (such as Surveys). If you use any other products or services, please refer to the privacy policy for that particular product or service.

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here.

For the purpose of data protection laws, the data controller of your personal information in relation to the Game is Proxima Beta Pte. Ltd.

SUMMARY

Here is a summary of the information contained in this Privacy Policy. You can find more detail by clicking ‘More Information’.

*What information do we need to be able to participate and/or be recruited for the Game?*	· For recruitment for the Alpha Test (“AT”) of the Game and use of the Game Website, we will collect your personal information as further mentioned in Section 3 (How We Process Your Personal Information) below. · If you register an account to access the recruitment survey for the Game, then we will need some information from you to set this up. If you register for a LEVEL INFINITE PASS Account, this includes a username and email address. Depending on your use of the Game and the jurisdiction where you are based, you may also need to provide some additional information to help us set up your account. To maintain the smooth operation of the Game and to provide the Game to you, we will process the datasets as mentioned in Section 3 ‘How We Process Your Personal Information’. · If you need to get in touch with us, we will retain some information (such as your email and any screenshots you send us) so that we can review and respond to your concerns.	More Information.
*How will we use your information?*	· We use your information to set up your account, enable you to use the Game, localise the Game experience, enable interaction between users of the Game, save your progress, ensure the safe and secure operation of the Game, address bugs, optimise and improve the Game, protect users, resolve user queries, and to comply with our legal obligations and enforce our legal rights, etc.	More Information.
*Who do we share your information with?*	· We may use third parties and work with our affiliates to help us deliver the best possible experience (such as surveys). · In some cases, we may be required by a court or be under a legal obligation (such as a valid search warrant or subpoena) to disclose certain information.	More Information.
*Where do we process your information?*	· Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy. · We have servers for the Game in Singapore, and the United States of America (USA). The servers applicable to your use of the Game will depend upon your location. We also have support, engineering and other teams who may support the Game, including from Singapore, and USA.	More Information.
*How long do we keep your information?*	· Unless otherwise required or permissible by applicable laws, we retain your information for the period during which you maintain an account for the Game, or for so long as the information is needed to fulfil the purpose for which it was collected (as further described in this Privacy Policy). We then delete or anonymise such data, in accordance with applicable laws. · Your information collected during the recruitment phase and through your use of the Game website will be stored for the lifetime of the Game and deleted 30 days thereafter.	More Information.
*How can I exercise my rights over my information?*	· Certain jurisdictions offer users specific rights with respect to their information, so you may have a right to access or receive a copy of your data, or to delete your data or restrict or object to our processing of your data.	More Information.
*How will we notify you of changes?*	· Changes to this Privacy Policy will be posted here. We will also notify you of changes in accordance with relevant legal requirements.	More Information.

1. Cookies

We use cookies and other similar technologies (“Cookies”) to enhance your experience using the Game Services. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities. For more information about our Cookies policy, click here.

2. Children

Children must not use the Game for any purpose, except where their parent or guardian has provided lawful consent (to the extent this option is available in your jurisdiction).

By children, we mean users under the age of 18 years old. For users located in certain regions, we have listed the relevant minimum age as of the date of this policy in the table below. You should in any case refer to the laws in your jurisdiction to ensure you are above the relevant legal minimum age.

Other than as provided above, we do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without lawful consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us.

Region in which the user is located	Minimum age of the user
Philippines	18

3. How We Process Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why. Personal Information	Use	Legal Basis (where applicable)
Information you provide to us (either through a third party or directly) to participate in the Recruitment for the Game and/or during the use of the Game Website
Website related information: Running Page/ User View Statistics: page views, user views, IP address Player Recruitment: Questionnaire/Survey Information (including Age range, WhatsApp number, email address, Game experiences, device model, gender, operating system) Real User Monitoring: IP address, Android version, CPU version (i.e. iOS version)	We use this information to: · Conduct statistical analysis on players’ website page views/user views ; · To assess players’ eligibility to participate in the Game’s AT · To monitor the performance of web apps and mini programs, obtain performance insights into the speed and performance of user pages, APIs, and CDNs, and troubleshoot errors	Necessary to perform our contract with you to provide the Game.
Information you provide to us (either through a third party or directly) to use/access the Game
INTL SDK Data: xwid (android users only in this test) : android_id (only for android users), when detection simulator, use system file information （build.prop）include ro.build.fingerprint，ro.product.device，ro.product.model，ro.product.brand，ro.product.name，ro.product.manufacturer，ro.hardware，ro.product.cpu.abi (The above is only processed locally on players’ device, and the information will not be stored on Game’s servers) Common information: gameid, client_source, session_id, event time, client_ip, country, province, city, carrier_id, openid, event_name, os, os_version, sdk_version, network_type, bundle_id, app_version, login_channelid, device_model, device_brand, screen_width, screen_height, cpu_name, cpu_core, cpu_freq, gpu_name, ram_total, rom_total, system language，uaid，comm_c_xsx_app_specific_device_id, comm_c_new_xwid, comm_c_vm_type Data monitoring: errorcode , error message, sdk name , sdk version, request url , response body, seq_id, stage, log, Common information for data reporting Log-in Services: · (Guest) guestid, openid · (Facebook) UID, name, profile picture, user token, openid, token_for_buiness(Bid) · (Google) userid, nicknames, profile picture, user token, openid In-game Notifications / Announcements: openid, device_id (Idfa, gaid) Communications (through email and phone): email, region, phone number User Acquisition related data IP Address Game Update Service: ROM (only processed and not stored) System Notification: Device Token and FCM (Firebase Cloud Message) Token	We use this information to: · (In respect of XWID) Device fingerprinting, app analytics (for debugging), for using the application in guest mode (without account registration), and for fraud detection · Provide log-in services (through the various social media log-ins) · Provide in-game notifications/ announcements · Detect your country via IP address, in order to provide you the Game · Provide version updates for the Game · For user acquisition · Generally provide you the Game service	We collect and use this information with your consent.
LEVEL INFINITE PASS Account log-in information (if you choose to log-in via LEVEL INFINITE PASS Account): UID, token, email, password, username Please also see: https://account.levelinfinite.com/privacypolicy.html	We use this information to link your game account to your LEVEL INFINITE PASS Account and to enable you to access the Game in accordance with your request.	Necessary to perform our contract with you to provide the Game.
IDIP SDK Data: OS requests (including openid, nickname, game level, gold coins, game area, community, and country)	We use this information to provide you the game interface, and real time data access support for in-game events/ activities.	Necessary to perform our contract with you to provide the Game.
ACE Android APK Data: Operating system version number, installation package path, application name, native library, installation directory, internal file cache directory, application package name, independent installation package path, adb connection status, usb connection status, list of loaded memory modules, in-app class name, install package, hash System, boot time, specified file path	We use this information to prevent unauthorized manipulation of the Game.	Necessary to perform our contract with you to provide the Game.
ACE/ TSS SDK Data: device identifiers, device model, operation system, application activities, system performance data	We use this information to ensure a fair gaming environment, and to prevent cheating behavior within the Game.	Necessary to perform our contract with you to provide the Game.

4. How We Store and Share Your Personal Information

Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy.

We have servers for the Game in Singapore, and the United States of America (USA). The servers applicable to your use of the Game will depend upon your location. We also have support, engineering and other teams who may support the Game, including from Singapore and USA.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

· Third parties that provide services in support of the Game, including providers of services that process information identified in this policy for the purpose of providing the Game, and for user acquisition purposes (eg. Appsflyer Limited, Facebook Analytics) . All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Game (i.e., for the purpose(s) described above).

· Companies within our corporate group who process your personal information solely for the purpose of providing the Game to you. All such group companies may only use your personal information in accordance with this Privacy Policy.

Regulators, judicial authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you, such as to comply with legal obligations or processes. In complying with the terms of valid legal processes, such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in advance of such disclosure.
Third parties to ensure safety, security, or compliance with laws. We may disclose your information to:

enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
detect, prevent or otherwise address security, fraud or technical issues; or
protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (such as exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).

A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

5. The Security of Your Personal Information

We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Game or otherwise via the Internet; any transmission is at your own risk.

6. Data Retention

We do not keep your data for longer than is necessary to fulfil the relevant purpose described above unless we are required or permitted to do so under law. If we retain your information beyond the retention periods set out below, for example to comply with applicable laws, we will store it separately from other types of personal information.

For further details on how long we keep your data, please refer to the time periods set out below.

Personal Information

Retention Policy

All Personal Data as set out in Section 3 (“How We Process Your Personal Information”), save for the personal data that we collect when you participate in the Game Recruitment/ use of the Game Website

Stored for the duration of the AT and deleted 30 days thereafter. You may also request for your data to be deleted at any time and we will do so within 30 days of the request.

All Personal data collected when you participate in the Game Recruitment/ use of the Game Website

Stored for the lifetime of the Game and deleted 30 days thereafter. You may also request for your data to be deleted at any time and we will do so within 30 days of the request.

7. Your Rights

Please refer to the Supplemental Jurisdiction-Specific Terms, or the applicable laws in your jurisdiction, for an overview of specific rights that apply to persons subject to data protection laws in the listed jurisdictions and how these can be exercised.

You may have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). You can exercise some of these rights directly by accessing and updating the information in your account. If you believe we hold any other personal information about you, please contact us.

Access

You may have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account.

Portability

You may have the right to receive a copy of certain personal information we process about you. For example, in certain jurisdictions this can comprise personal information we process on the basis of your consent (e.g., survey information) or pursuant to our contract with you (e.g., account name), as described above in the section “How We Process Your Personal Information”. We will provide further information to you about transferring this data if you make such a request.

Correction

You may have the right to correct personal information we hold that is inaccurate.

Erasure

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

Restriction of Processing to Storage Only

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

Objection

You may have the right to object to our processing of your personal information. If you wish to do so, please contact us at here or using the contact details set out below, and we will consider your request.

Consent Withdrawal

To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us here Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.

8. Contact

Please get in touch with us if you have any questions. You can reach us in the first instance at this link.

Mailing Address:

International Privacy & Data Protection Centre

30 Raffles Place #18-01

Singapore 048622

We will endeavour to deal with your request as soon as possible. This is without prejudice to any right you may have to launch a claim with a data protection authority in the region in which you live or work where you think we have infringed data protection laws.

9. Changes

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here and notify you in accordance with relevant legal requirements.