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
Indonesia	18
Malaysia	18
Philippines	18
Singapore (Events only)	13
Thailand	20
Vietnam (Events only)	16

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.

LEVEL INFINITE PASS Account log-in information (if you choose to log-in via LEVEL INFINITE PASS Account): LI Pass Account, email address, password, user token, country, phone number, nickname, date of birth, country

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.

CFL Events Information: contact details (email address, phone number, whatsapp number), Level Infinite Pass log-in information, openid

We use this information to contact you regarding any prize, and to enable you to log in via Level Infinite.

Necessary to perform our contract with you to provide the Game.

User Viewing Information: IP Address

We use this information to analyze the page view and user view of players visiting the Website.

Necessary to perform our contract with you to provide the Game.

RUM Information: IP Address, Android version number, CPU version number, player statistical data

Please also see: https://www.tencentcloud.com/document/product/1131/49155

We use this information to view players’ collated statistical data for monitoring page performance (eg. anomalous requests).

Necessary to perform our contract with you to provide the Game.

Information you provide to us (either through a third party or directly) to participate in Game Events:

Log-In Information (via Level Infinite): (processed momentarily) email, user_id, nickname, user token

openid

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.

We also use this information to send you Game notifications (eg. Game related timelines).

Necessary to perform our contract with you to provide the Game.

User Viewing Information: IP Address

We use this information to analyze the page view and user view of players visiting the Website.

Necessary to perform our contract with you to provide the Game.

Contact Information: email address, whatsapp number, phone number

We use this information to contact you with regards to any prizes won during the Event.

Necessary to perform our contract with you to provide the Game.

Friends’ Invitations Information: Level Infinite email (hashed), record of successful/unsuccessful friend invitations

We use this information to inform you of the successful event invitations to in-Game friends, and for lucky draw attempts.

Necessary to perform our contract with you to provide the Game.

Lottery Information: historical rewards received, reward value, reward receipt history

We use this information to provide you a historical record of lottery rewards received.

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.

SmartLink Information: Contact information (eg. phone number, email address)

We use this information to send you newsletters, promotional offers, and advertising.

Necessary to perform our contract with you to provide the Game.

We collect and use this information with your consent.

Crashsight Information: diagnostic logs (user IDs, device identifiers, cpu, storage, network status, device identifiers (IDFV (iOS), UUID (for Android))

We use this information:

· For assisting the developer to pinpoint, analyze, and resolve abnormal issues (e.g. crashes, latency), and for diagnostic and crash reporting.

· For assisting the developer to do statistical calculations, such as determining the device crash rate and counting active devices.

Necessary to perform our contract with you to provide the Game.

We collect and use this information with your consent.

GCloud (Dolphin) Information: identity information (openid), device information (device name, device model), game version information, game source version

We use this information in order for you to access game resources and send you game pack version updates.

Necessary to perform our contract with you to provide the Game.

GCloud (Maple) Information: identity information (openid), device information (device name, device model), game server information (server url)

We use this information for maintaining the game area service information.

Necessary to perform our contract with you to provide the Game.

GCloud (Puffer) Information: identity information (openid), device information (device name, device model)

We use this information to provide you optional game resource updates.

Necessary to perform our contract with you to provide the Game.

GCloud (Core) Information: identity information (open id), device information (device name, device model), login channel id

We use this information to provide SDK management function and configuration distribution capabilities.

Necessary to perform our contract with you to provide the Game.

GVoice Information: Identity Information (OpenID), device information (device model, device brand, system time), SDK version, network type, regionID, texts, chat data (only text)

We use this information to facilitate your communications with other Game players.

Necessary to perform our contract with you to provide the Game where you seek to use Game communication features.

GCloud (TDM) Information: device information (Android ID, phone memory, device brand, device system version, device manufacturer, ROM, screen resolution, RAM, system time, device model, device name, CPU model, CPU architecture), SDK version, IP address, mobile network code, network type, application package name, application version

We use this information to:

· Perform data analysis of device’s performance

· Improve game user experience

Necessary to perform our contract with you to provide the Game.

We collect and use this information with your consent.

Midas Information: identity information (openID, roleID, country), device information (CPU model, device model), country, currency, SDK version, application version, network type, amount

We use this information to provide you Game in-app payment features.

Necessary to perform our contract with you to provide the Game.

TEG Customer Support Information: zn zone name, z zone id, platid platid, role name (user nickname), role icon role avatar, lang_type, openid, safe smartphone screen notch location, scene_id, area_id, app_id, country id, country, channel id

Log-In Verification data (encodeparam, gameid (INTL), channelid, OS terminal identifier, timestamp, SDK version, sequence number)

User Game Query Data: game account information (registered user name, social account, mobile phone registration time, vip level), game character information (role name, role id, game duration, historical record), in-game data (items, currency, penalties, logins, activities, recharge, purchases, in-game friend relationships, game match data, props, user reports (match data, in-game chat information))

User Initiated Communications information: (text) chat logs, email descriptions, user descriptions, email addresses

Store Channels Information: review id, nickname, satisfaction star rating, reviews

Reporting Plug-Ins Information: penalties, log-in streams, (text) chat logs, players’ Information, report, game data, in-game chat messages, report processing time, report processing results, reasons

We use this information:

· In general, overseas customer support service (eg. player’s in-game record query and reports)

· For player log-in verifications

· To verify the reports by and of any Game players

· To provide the in-game user interface

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, and Game Events	Stored for the duration of the OBT 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.
All Personal data collected when you participate in Game Events	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.

Our Representatives in Certain Jurisdictions

Jurisdiction	Representative	Address	Contact details
Thailand	Tencent (Thailand) Company Limited	T-One Building, Bangkok, Thailand	dpo_cfl@proximabeta.com

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.

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Game, which are set out in this section. If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.

Indonesia

By accepting and consenting to this Privacy Policy, you agree that we may collect, use and share your personal information in accordance with this Privacy Policy, as revised from time to time. If you do not agree to this Privacy Policy, you must not access or use our services and we have the right to not provide you with access to our services.

If you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game, and the Website.

In the event we fail to maintain the confidentiality of your personal information in the Website and the Game, we will notify you through the contact information provided by you or via the Website and the Game, to the extent required by local laws and regulations.

You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

Malaysia

In the event you are agreeing to this Privacy Policy in order for a minor to access and use the Game and the Website, you hereby consent to the provision of personal information of the minor to be processed in accordance with this Privacy Policy and you personally accept and agree to be bound by the terms in this Privacy Policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor’s compliance with this Privacy Policy.

Right of access: You have the right to request access to and obtain a copy of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law. When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

Right of correction: You may request for the correction of your personal information. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.

Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details provided above. However, this may affect our provision of the Website and the Game to you.

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

Our data protection officer, responsible for the management and safety of your personal information

Telephone: +603-22872388
Contact: as set out in Section 8 (Contact)

Philippines

Minimum Age

You must be at least 18 years of age to be able to use the Game services.

Your Rights

You are entitled to the following rights:

Right to be informed. You may in certain circumstances have the right to be informed whether personal data pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.
Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for direct marketing, automated processing or profiling.
Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.
Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.
Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.

Consent

By consenting to this Privacy Policy, you consent to us:

· collecting and processing your personal information as described in the section “How We Process Your Personal Information” above;

· sharing your personal information with third parties, companies within our corporate group, and a third party that acquires all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and

· transferring or storing your personal information in destinations outside the Philippines as described in the section “How We Store and Share Your Personal Information” above.

Singapore

By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, the locations specified in Section 4 (How We Store and Share Your Personal Information).

You have the right to access your personal information, how we use it, and who we share it with. You have the right to correct any of your personal information that is inaccurate.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted as set out in Section 8 (Contact).

Thailand

By clicking "accept", you acknowledge that you have read, understood, and agree to the Privacy Policy. If you do not agree with the Privacy Policy, you must not use the Game and the Website.

If you are under the age of 20, you undertake that you have obtained your parent or legal guardian’s consent to register an account on and use the Game and the Website.

To the extent provided for by the Thai Personal Data Protection Act (PDPA), you may:

· withdraw your consent to the processing of your personal data (only where the legal basis for our processing is consent); however, please note that where consent is required to process your personal data, we may not be able to deliver the expected service without it;

· request us to provide you access to, make any correction to, cease any automated processing or profiling (if applicable), discontinue, restrict the use or provision of and/or erase your personal data;

· request us to provide you or a third party with your personal data which is stored by us in a machine readable format; and/or

· lodge a complaint to a relevant authority.

Where you wish to make such requests, please contact us as set out in Section 8 (Contact).

The contact details of our designated local representative in Thailand for the purposes of compliance with the PDPA is as set out in Section 8 (Contact)and can be contacted via email. Please include the word “Thailand” in the subject line of your email.

Vietnam

By accepting this Privacy Policy, you expressly agree and authorise us to collect, use, store, and process your personal information, including, lawfully disclosing and transferring it to third parties, as described in this Privacy Policy.

Where we permit any third parties to collect and use your personal information, we shall take reasonable measures to ensure that the third parties do not further disclose the personal information.

You have the right to access, correct, and erase the personal information we hold about you. You also have the right to withdraw your earlier provided consent to collect, store, process, use and disclose your personal information and to request us to stop providing your personal information to a third party.

*What information do we need to be able to participate and/or be recruited for the Game?*	· (Where relevant) For recruitment for the upcoming Open Beta Test (“OBT”) 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’. · To provide you with Game Events, we process various information such as your social media log-in information, user viewing information, friends’ invitation information, lottery information and contact information, etc. For more information, please refer to 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, to organize promotional activities and events, 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 Events and 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.	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.