DEFINITIONS AND INTERPRETATION
“Ordinance” means the Personal Data (Privacy) Ordinance (Cap. 486) of the Laws of the Hong Kong Special Administrative Region.
“Personal Data” means any personal data held by the Company including all information provided by customers such as creating game account & data provided during game event participation. Personal Data may or may not include transactional records (meaning the transactional data which we receive from our channels).
OUR COMPANY POLICY
3. We pledge to meet fully, and where possible exceed, internationally recognised standards of personal data privacy protection in complying with the requirements of the Ordinance. In doing so, we promise to:
(i) collect adequate, but not excessive, Personal Data by lawful and fair means for lawful purposes directly related to our functions and activities;
(ii) take all reasonably practicable steps to ensure that all Personal Data collected or retained are accurate, having regard to the purposes for which they are to be used;
(iii) ensure that Personal Data are not used where there are reasonable grounds for believing that they are inaccurate, having regard to the purposes for which they are to be used;
(iv) erase Personal Data which are no longer necessary for the fulfillment of the purposes for which they are to be used;
(v) use Personal Data only for purposes for which the data were to be used at the time of the collection of the data, unless you have given your express consent for a change of use or such use is required or permitted by the Ordinance or the law of Hong Kong Special Administrative Region (“Hong Kong”);
(vi) take all reasonably practicable steps to ensure that Personal Data are protected against unauthorized or accidental access, processing, erasure or other use;
(vii) take all practicable steps to ensure that you can be informed of the kinds of personal data we hold and the main purposes for which the data are to be used; and
(viii) allow you to access and request correction of your Personal Data held by us in a manner prescribed by the Ordinance. We may charge you a fee as permitted by the Ordinance in complying with your data access request.
STATEMENT OF PRACTICES
TYPES OF PERSONAL DATA COLLECTED AND HELD
4. For the purpose of conducting the Company’s business (including relevant online services), we may collect from you and hold some or all of the Personal Data such as, but not limited to, the following to enable us to provide the game or other related service to you:
a. Your name;
b. Your Gender;
c. Your preferred language for communications;
d. Contact details, including contact name, telephone number and email address;
e. Information for the verification of identity, including identification document type and identification number;
f. Your age and date of birth;
PURPOSES OF KEEPING PERSONAL DATA
7. Personal Data of the Holder held by us may be used for the following purposes:
a. processing an application for our services;
b. management, operation and maintenance of the payment system, including audit, and exercising our and your rights under the Conditions;
c. designing new or improving existing services provided by us, our subsidiaries and our affiliates (that is, our direct holding company and its subsidiaries);
d. communication by us to you;
e. investigation of complaints, suspected suspicious transactions and research for service improvement;
f. prevention or detection of crime;
g. disclosure as required by laws, rules, regulations, codes or guidelines.
DISCLOSURE OF PERSONAL DATA
8. All Personal Data will be kept confidential by us but in accordance with the Conditions, we may, for the purpose(s) set out in paragraph 7 above, transfer or disclose such Personal Data to the following parties within Hong Kong (except that the parties set out in paragraphs 8(a) and 8(b) below may be located outside Hong Kong):
a. our agents or contractors under a duty of confidentiality to us who provide administrative, telecommunications, computer, payment, data processing or other services to us in connection with the operation of our business (such as professional advisors, call centre service providers, debt collection agencies (in the event you owe us any money), gift redemption centres or data entry companies);
b. our subsidiaries, and/or our affiliates which owe a duty of confidentiality to us; and
c. any law enforcement agencies and/or regulatory bodies for compliance with applicable laws, rules, regulations, codes and/or guidelines and/or any person or entity to whom we, our subsidiaries, and/or our affiliates are under a binding obligation to make disclosure under the requirements of any law, rule, regulation, code and/or guideline and/or order of any competent court of law, law enforcement agencies and/or regulatory bodies, but such disclosure will only be made under proper authority.
SECURITY OF PERSONAL DATA
9. We treat security as our top priority. We will strive to ensure that Personal Data will be protected against unauthorized or accidental access, processing or erasure. In doing so, we have implemented appropriate physical, electronic and managerial measures and controls to safeguard and secure the Personal Data.
10. Our web servers are protected by appropriate firewalls which will be kept up-to-date.
11. We will not keep Personal Data longer than is necessary for the fulfillment of the purposes (including any directly related purpose) for which they are, or are to be, used. We will purge unnecessary Personal Data from our system in accordance with our internal procedures.
ACCESS AND CORRECTION OF PERSONAL DATA
12. You have the right to ask us if we hold any Personal Data about you and if so, to request a copy of some or all of your Personal Data. If you would like to make such a request, please contact our Customer Service Officer. We may charge you a fee at a level permitted by the Ordinance for this service.
13. You also have the right to ask us to correct your Personal Data which you consider as inaccurate by contacting our Customer Service Officer.
14. We will allow your data access request or correction request unless we consider that there is a sound reason under the Ordinance or other relevant law to reject the request.
15. We will allow your virtual game data access request or correction request unless we consider that there is a sound reason under the Ordinance or other relevant law to reject the request.
16. Our Customer Service Officer email: firstname.lastname@example.org
LINKS TO OTHER WEBSITES
CHANGE OF PERSONAL DATA POLICY