Game Without Borders Privacy Policy

Summary

What information do we collect about you?

We collect various types of information when you set up your profile and during your use of the Service, as set out in this privacy policy. If you choose to set up your profile using a third party account, we also collect information from that account. More Information

How will we use the information about you?

We use your information to create your profile and provide the Service to you. More Information

Who do we share your information with?

We may share your information with our related group companies and as required by law. More Information

Where do we process your information?

Our servers are located in the People’s Republic of China (“PRC”) (for the purposes of this policy the term PRC excludes Taiwan, Hong Kong and Macau). Our support, engineering and other teams are located in our offices around the world. More Information

How long do we keep hold of your information?

We retain your information for the duration for which you hold your account and then delete such data in accordance with the retention policy set out in this privacy policy. More Information

How can I exercise my rights over my information?

You may have rights to access, receive a copy of, delete, or correct, your data or restrict or object to our processing of your data. More Information

Dispute Resolution

If you have any concerns or complaints, please contact us here

How will we notify you of changes?

If there are any significant changes to this privacy policy, we will post a notification of such change here. More Information

Contact Information

Data Controller: Tencent Mobile International Ltd.

EU Representative: Tencent International Game Europe B.V. Email: eudataprotection@tencent.com

INTRODUCTION

This privacy policy informs you of our practices and the choices you have regarding any personal information you provide to us. Your use of Game Without Borders (“Service”) involves the collection and use of your personal information. It is important for you to understand how this happens and how you may control it.

When you use the Service, you accept our rules and policies regarding your personal information and you expressly consent to us collecting, processing, using and storing your personal information, as described in this privacy policy.

You acknowledge that you have read and understood this privacy policy. If you do not agree with this privacy policy, you must not use the Service.

Tencent Mobile International Ltd. (“we” or “us”) is a company registered in British Virgin Islands with its office located at 29/F, Three Pacific Place, 1 Queen’s Road East, Wanchai, Hong Kong. Our representative in the EU for the purpose of EU data protection laws is Tencent International Game Europe B.V., a company registered in the Netherlands. Their registered address is 26.04 on the 26th floor of Amstelplein 54, 1096 BC Amsterdam, the Netherlands and can be contacted at eudataprotection@tencent.com. The data controller for the purpose of EU data protection laws is Tencent Mobile International Ltd.

If you have any comments, questions or complaints regarding the processing of your personal information, you can contact us at GWB_DPO@tencent.com .

The Types of Personal Information We Use

This section provides a high level overview of the different types of personal information we collect and how we collect it. Further detail on the information processed can be found in the section “How We Use Your Personal Information”.

You give us information about you when you register for an account with the Service, and when you register your game project.

Cookie

We use necessary cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) which are essential to provide you with the Service and to use some of its features. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.

You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies, or instruct your device to provide notice at the time of installation of cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event of your refusal to install cookies, the Service may be unable to operate as designed.

Children

If you are under 16 years old then unfortunately you are not permitted to use the Service.

We do not knowingly collect personal information from children under age 16 for any purpose. If you believe that we have personal information of a child under this age, please contact us at GWB_DPO@tencent.com and we will delete such information.

How We Use Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why. For users who live in the European Economic Area (“EEA”), it also identifies the legal basis under which we process your data.

Personal Information	Use	Legal Basis (only relevant if you are located in the EEA)
Account log in: Third party log in details (if you choose to log in via your social media account with these networks), including Google, Facebook and Twitter, open ID, name, profile picture and profile avatar	We use this information to set up your profile in accordance with your request.	Necessary to perform our contract with you to provide the Service.
To create an account: Email address, username, password, third party (including Google, Facebook and Twitter) log in details (if you choose to log in via your social media account with these networks), country, date of birth, account type (personal or company), website address of your game and your self-introduction	We use this information to create your account with GWB in accordance with your request.	Necessary to perform our contract with you to provide the Service.

Personal Information

Use

Legal Basis (only relevant if you are located in the EEA)

Account log in:

Third party log in details (if you choose to log in via your social media account with these networks), including Google, Facebook and Twitter, open ID, name, profile picture and profile avatar

We use this information to set up your profile in accordance with your request.

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

To create an account:

Email address, username, password, third party (including Google, Facebook and Twitter) log in details (if you choose to log in via your social media account with these networks), country, date of birth, account type (personal or company), website address of your game and your self-introduction

We use this information to create your account with GWB in accordance with your request.

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

In order to perform our contract with you, your personal information will be accessible from and will be processed on our servers (depending upon your location and the game server you select). Our servers are located in the People’s Republic of China (“PRC”) (for the purposes of this policy the term PRC excludes Taiwan, Hong Kong and Macau).

Our support, engineering and other teams are located in our offices around the world.

Please note that when your personal information is transferred outside your jurisdiction of residence, it will be subject to the laws of the country in which it is situated.

To the extent permitted by applicable law, we share your personal information with selected third parties in and outside your country only to the extent allowed by applicable law, including:

related group companies with whom we share your personal information to operate the Service;
law enforcement agencies, public authorities or other judicial bodies and organisations. We disclose information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to:
- comply with a legal obligation, process or request;
- enforce our terms of Service and other agreements, policies, and standards, 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 (including exchanging information with other companies and organisations for the purposes of fraud protection); and
a third party that acquires all or substantially all of us or our business. We will disclose information to a third party in the event that we sell or buy any business or undergo a merger, in which case we will disclose your data to the prospective buyer of such business. We will also disclose information to a third party if we sell, buy, merge or partner with other companies or businesses, undergo a reorganisation, bankruptcy, or liquidation; or otherwise undertake a business transaction or sell some or all of our assets. In such transactions, user information may be among the transferred assets.

We require the third parties with whom we share user data to provide the same or equal protection of user data as stated in this privacy policy.

Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. Our group companies have information security and access policies that limit access to our systems and technology. We also protect data through the use of technological protection measures such as encryption. Your personal information will remain subject to our technical and organisational controls and our policies and procedures (including this privacy policy).

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the information transmitted to the Service; any transmission of your information is at your own risk.

Data Retention

We will retain your personal information as described below (except if otherwise required to be retained by applicable law).

Personal Information	Retention Policy
Account log in: Third party log in details(if you choose to log in via your social media account with these networks), including Google, Facebook and Twitter, open ID, name, profile picture and profile avatar	Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then deleted within 7 working days or as otherwise required by law.
To create an account: Email address, username, password, third party (including Google, Facebook and Twitter) log in details (if you choose to log in via your social media account with these networks), country, date of birth, account type (personal or company) , website address of your game and your self-introduction	Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then deleted within 7 working days or as otherwise required by law; or deleted within 7 days of a lawful request from you to delete the data. We do not store your date of birth.

Personal Information

Retention Policy

Account log in:

Third party log in details(if you choose to log in via your social media account with these networks), including Google, Facebook and Twitter, open ID, name, profile picture and profile avatar

Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then deleted within 7 working days or as otherwise required by law.

To create an account:

Email address, username, password, third party (including Google, Facebook and Twitter) log in details (if you choose to log in via your social media account with these networks), country, date of birth, account type (personal or company) , website address of your game and your self-introduction

Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then deleted within 7 working days or as otherwise required by law; or deleted within 7 days of a lawful request from you to delete the data.

We do not store your date of birth.

Personal Information is kept until the end of its life cycle (as set out in the retention policy above). When destroying personal information, measures will be taken to make the personal information irrecoverable or irreproducible, and electronic files which contain personal information will be deleted permanently using a technical method which makes the files irreproducible.

In the event that the processing and retention period have terminated, but personal information is required to be retained continuously for other reasons including for the purposes as prescribed under applicable laws, the relevant personal information will be stored and maintained separately from other types of personal information. If you require us to destroy your personal information before the end of its life cycle (as set out in the retention policy above), we will destroy your personal information in accordance with local laws.

Your Rights

This section (“Your Rights”) applies to users that are located in the European Economic Area and Switzerland only.

You 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). To exercise any of your rights, please email us at GWB_DPO@tencent.com.

Access

You 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 and by contacting GWB_DPO@tencent.com. If you believe we hold any other personal information about you, please email us at GWB_DPO@tencent.com.

Portability

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent or pursuant to our contract with you, as described in the section “How We Use Your Personal Information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party.

If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (e.g., where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

Correction

You have the right to correct any personal information held about you that is inaccurate. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please email us at GWB_DPO@tencent.com.

Erasure

You can delete your account, or remove certain personal information, by logging into your account. If there is any other personal information you believe we process that you would like us to erase, please email us at GWB_DPO@tencent.com.

You may request that we erase the personal information we hold about you in the following circumstances:

you believe that it is no longer necessary for us to hold such personal information; or
you believe the personal information we hold about you is being unlawfully processed by us.

You can also exercise your right to restrict our processing of your personal information (as described below) whilst we consider your request.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (e.g., 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 that has been made available publicly on the Service 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 have a right to require us to 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 (e.g., for the defence of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

You may request we stop processing and just store the personal information we hold about you where:

you believe the personal information is not accurate for the period it takes for us to verify whether it is accurate;
you wish to erase the personal information as the processing we are doing is unlawful but you want us to retain the personal information but just store it instead; or
you wish to erase the personal information as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims.

Objection

You have the right to object to our processing of personal information about you. We will consider your request in other circumstances as detailed below by emailing us at GWB_DPO@tencent.com.

Please note that if you are a user located in the EEA, we must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances).

Announcements

We may from time to time send you announcements when we consider it necessary to do so (such as when we temporarily suspend access to the Service for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these Service-related announcements, which are not promotional in nature.

Contact & Complaints

Questions, comments and requests regarding this privacy policy, including our policies and practices related to the use of Service providers outside your jurisdiction of residence, are welcomed and should be addressed to gwbcontact@tencent.com .

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at GWB_DPO@tencent.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws.

Changes

If we make any material changes to this privacy policy we will post the updated privacy policy here. Please check this page frequently to see any updates or changes to this privacy policy.

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of this App, which are set out in this section.

If you are a user located in a jurisdiction listed below, then the terms set out below under the name of your jurisdiction apply to you.

California

This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:

Identifiers, such as your email address, username, password, date of birth, account type (personal or company) and your self-introduction. If you use a third party account log-in (e.g. Google, Facebook, Twitter and Open ID): your third party login details, name, profile picture and profile avatar as they appear on your third party profile. This information is collected directly from you and your device and from third party platforms if you choose to sign up using a third party account.
Geolocation data such as the location you enter when you create an account for the Services. This information is collected directly from you.
Visual information such as your third party account profile picture. This information is collected from third party platforms if you choose to sign up using a third party account.
Other information described in subdivision (e) of Section 1798.80, including information about your age. This information is collected directly from you in the context of being our consumer.

We collect your personal information for the following purposes:

To create your account or set up your profile in the Services in accordance with your request.

For additional information about what each type of personal information is used for, see this chart in the main portion of the Privacy Policy.

We disclose personal information to the following types of entities:

Other companies within the Tencent corporate group who process your personal information in order to operate the Services
Regulators and judicial authorities and law enforcement agencies
Entities that acquire all or substantially all of our business

In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” in the CCPA.

Rights under the CCPA

If you are a California resident, you have the right to:

Request we disclose to you free of charge the following information covering the 12 months preceding your request:
- the categories of personal information about you that we collected;
- the categories of sources from which the personal information was collected;
- the purpose for collecting personal information about you;
- the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and othe specific pieces of personal information we collected about you;
Request we delete personal information we collected from you, unless CCPA recognizes an exception;
Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.

We aim to fulfill all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may exercise your rights, if any, regarding other data by contacting us at GWB_DPO@tencent.com.