Last updated: November 01, 2024
Kenshen Game (“we” or “us”) fully respects and is committed to protecting the privacy rights of users (“users”, “you”) who visit our website, access or use Super Poker: Truco&Cacheta (our games), whether played on a mobile device, personal computer, our website or any other applicable platform and/or device, and access or use any services we provide, including but not limited to technical services, customer support, competitive gaming events, marketing and advertising (collectively, “our Services”).
This Privacy Policy (“Policy”) is designed to help you understand our practices related to the collection, use, storage and disclosure of information collected from or about you when you interact with us, your rights with respect to the information you provide to us, and how we transfer and protect such information.
Please be sure to read this Policy carefully to understand our practices with respect to your Personal Data (defined below) and visit this Policy frequently to learn about updates to this Policy. By downloading, accessing, using and or interacting with our Services, you agree and expressly consent to our collection, use and disclosure of the information you provide in accordance with this Privacy Policy. This Privacy Policy is incorporated by reference into the Terms of Service on https://www.kenshen.cn/sp/term.html (our “Terms of Service”) and is subject to the provisions of the Terms of Service. If you have any concerns about providing information to us or using that information as described in this Policy, you should not use our Services.
If we update this Policy, we will notify you through an in-game announcement to let you know about the changes we have made and ask for your consent again. By accessing or using our Services after we post such a notice, you will be deemed to have accepted the updated Policy. You can check when this Policy was last updated by checking the “Last Updated” date displayed at the top of this Policy. If applicable data protection law requires us to give you a more detailed notice or ask for your consent to any such changes, we will do so. Any revised Policy will supersede all previous Privacy Policies.
This Privacy Policy will help you understand the following:
Important definitions
Data we collect and use
Promotional information
How and why we use your personal information
How we store and protect your data
How we share, transfer and disclose your data
How your data is transferred across borders
How we handle children’s data
Your data protection rights
How to exercise your rights
Cookies and similar technologies
Third-party service providers and services
How to contact us
Additional help
Important definitions
“Personal Information” means any information that relates directly or indirectly to a living individual and that can be used to identify a living individual, in particular by an identifier, location, or factors specific to the physical, physiological, genetic, economic, cultural or social identity.
“Usage Data” means data collected automatically through the use of the Services or from the Service infrastructure itself.
“Cookies” are small data files stored on your hard drive or device memory that help us improve our Services and your experience and understand which areas and features of our Services are popular and count visits.
“Data Controller” means the natural or legal person who (alone, jointly or in common with others) determines the purposes and manner in which any personal data are or are to be processed. For the purposes of this Policy, we are the data controller of your data.
“Data Subject” means any living individual who is the subject of personal data.
II. Data We Collect and Use
In order to provide you with a better experience of our Services, we may ask you to provide us with certain personal data when you use our Services.
We may collect your personal information in the following ways:
Information you provide directly to us (for example, the nickname, avatar and phone number you provide to us when you register or log in to your account);
Information we automatically obtain during your use of our Services (for example, device information and usage data); or
Information we obtain from other sources.
We will only collect and use your personal information for the purposes described in this Policy. The following describes the personal information we collect about you and how we use it.
Data Collection and Purpose
When you use our Services for legitimate interests, we may collect some or all of the following information about you.
(1) Login Information
If you register using your email address/mobile phone number when creating an account in our game, you agree to provide some of your personal information, such as email address, verification code sent by email or SMS, and password.
If you register through a social network account (such as Apple ID, Facebook, or Google Play (“Social Network”)), we may collect information that you authorize the social network to share with us to register for our services. The specific information we receive from the social network may vary depending on your privacy settings on the social network, but generally includes your basic public profile information, such as your nickname, user name, and email address. If you refuse to provide your social network account information, you may not be able to register and log in through your social network account.
For some regions, you may be asked to provide us with your date of birth to verify whether you are eligible to access or use our services.
(2) Account Information
When you use our services, you can choose the information you provide in your account, such as your profile picture, nickname, location. You do not have to provide additional information in your profile; however, profile information can help you get more from our services, including allowing others to better understand you. Please do not post or add other information in your profile that you do not want to be public.
(3) Payment Information
When you purchase virtual currency or virtual items in our Services, we may collect and process your purchase and transaction records in the Services, including device information (including Open ID, Internet Protocol (IP) address, operating system version, device type, Internet connection), transaction details (time and date, cost, purchased products, currency, order ID) and transaction records (including player ID, transaction time, country, email, phone number, purchase history and payment card details) to perform our contract with you, facilitate your payment and provide you with transaction details.
All purchases and withdrawals are processed by payment processing companies. We do not process any payments and do not access your credit card information or billing information.
(4) Any information you submit to our support team
If you encounter any problems while using our Services, you can contact us and seek help through our technical and/or customer service. In the case of receiving your support request, we may collect the content of your inquiry, your device information, contact information or other contact information you leave for us in order to contact you or help you solve the problem, or record the problem and its solution. If you choose not to provide such information, we may not be able to provide you with the service, but it will not affect your use of other features of our services.
(5) Advertising Information
If you click on an advertisement in our Services, we may store the advertisement’s advertising identifier (such as Android ADID and Apple IDFA information) and device information together with your personal data in order to track the success of our advertisements.
In order to provide you with personalized advertisements, promotions and marketing information, we may collect and process the following information, such as age, gender, email address, geographic location, device type, in-game information (such as your habits and preferences in our games), and other information you choose to provide to us in any survey or investigation, based on your choices and consent.
We may also use the information you provide to send you advertisements, market surveys or research via email. If you do not want to receive such information from us, you can choose not to receive such information (see “Promotional Information” below).
Please note that when you choose not to receive interest-based or targeted advertising, you will still see advertisements posted by us or on our online services, but these advertisements will not be targeted using your personal data.
If we know that you are a registered user who has not reached the legal age of majority, we will not serve advertisements or send such messages to you in accordance with applicable laws in certain jurisdictions where you access or use our services.
(6) Data we collect automatically
During your use of our services, we will automatically collect information about your device or your use of our services in order to improve our services and ensure the security of our services, including:
Internet Protocol (IP) address. We collect and process this information to allow you to access or restrict your access to our services.
Device information. When you start using our services, based on your specific actions in our services and the specific permissions you grant us during installation and use of our services, we will collect information about the mobile device you use to ensure service security, manage registration and improve our services, such as UUID, APK name, application version, device approximate and precise location information (Internet Protocol (IP) address, GPS location and WLAN connection, Bluetooth and base station information that provides location information).
Usage data. To fulfill our terms of service, we will collect detailed information about your use of our services when you use our services and save it as usage data, including your login account, IP address, provider information, Internet connection environment, WIFI status information and other usage data generated when you use our services.
Please note that some of the above information alone cannot be used to identify a specific natural person and therefore does not constitute personal information. Only when such non-personal information is used in combination with other information to identify a specific natural person, or when it is used in combination with personal information, will such information be considered personal information in the process of combination. In this case, we will anonymize and de-identify such information, unless you agree or otherwise required by laws and regulations. The above information is essential for the provision of services. If you choose not to provide it, we may not be able to provide you with our services.
(7) Survey information
We may also collect other information about you that we reasonably need to improve our products or services, including any feedback you provide when you contact customer service and any questionnaires you send back to us when you participate in a survey. We may combine information from one service with information from another service to provide you with better services.
(8) Other circumstances in which your information may be collected
To the extent permitted by law, we may obtain your personal information from other individuals, business entities, public sources or other third parties acting in accordance with your instructions, partners who work with us to provide products and services and assist us with information security and fraud prevention, and other legitimate sources. We will explain to you and obtain your consent when collecting.
We may also use other methods to collect other information about you, your device or your use of the Services, which will be explained to you at the time of collection and before we ask for your consent.
We may use your personal information to send you updates about our Services, including exclusive offers, promotions or new services. We have a legitimate interest in using your personal information for promotional purposes. This means that we do not usually need your consent to send you promotional information. However, if your consent is required, we will ask for it separately and explicitly. We will always treat your personal information with the utmost respect and will never sell it to other organizations for marketing purposes.
You have the right to opt out of receiving promotional information at any time by:
Contacting us (see “How to Contact Us” below); or
The “Unsubscribe” link in the email.
We may ask you to confirm or update your marketing preferences if you instruct us to provide further services in the future, or if there are changes in law, applicable regulations or our business structure.
Under data protection law, we can only use your personal information where we have a legitimate reason to do so, such as:
Comply with our legal and regulatory obligations;
For the performance of our contract with you or to take steps at your request before entering into a contract;
For our legitimate interests or those of a third party;
Where you have given us your consent.
A legitimate interest means we have a business or commercial reason to use your personal data, as long as this is not overridden by your own rights and interests.
We may use your personal information for:
To provide you with services in order to perform our contract with you or to take steps at your request before entering into a contract;
To prevent and detect fraud against you in order to meet our legitimate interests or the legitimate interests of a third party, i.e. to minimise fraud that could cause damage to us and you;
To carry out checks to identify our customers and verify their willingness to comply with our legal and regulatory obligations;
To ensure the confidentiality of commercially sensitive information in order to safeguard our legitimate interests or those of a third party, i.e. to protect trade secrets and other commercially valuable information and comply with our legal and regulatory obligations;
To analyse statistical data to help us manage our business, for example about our financial performance, customer base, product range or other efficiency measures in order to meet our legitimate interests or those of a third party, i.e. to provide you with the best possible service as efficiently as possible;
To prevent unauthorised access to and modification of systems in order to meet our legitimate interests or those of a third party, i.e. to prevent and detect criminal activity that could cause damage to us and you and comply with our legal and regulatory obligations;
To perform our contract with you or take steps at your request before entering into a contract, comply with our legal and regulatory obligations and safeguard our or third parties’ legitimate interests, update and enhance customer records, such as ensuring we can keep in touch with customers about existing orders and new products;
and market our services and the services of selected third parties to:
(i) existing and former customers;
(ii) third parties who have previously expressed an interest in our services; and third parties with whom we have no previous transactions, in order to safeguard our or third parties’ legitimate interests, namely to promote our business to existing and former customers.
We will not use your personal data for any automated decision-making purposes.
Personal information may be stored in our offices and the offices of our third-party service providers or representatives and agents (see “How we share, transfer and disclose your information” below). Your information collected by us will be stored in accordance with the personal privacy data protection laws and regulations of the relevant country. You acknowledge and agree that your information will be processed on our servers to the extent permitted by local laws and regulations, which These servers may not be located in your country of residence and may be accessed by our support, engineering and/or our affiliates around the world. Your information that we collect may be stored and processed in any other country in which we, its subsidiaries or third-party agents operate for the purposes set out in this Privacy Policy. Regardless of where our servers are located, we endeavor to put in place appropriate safeguards to guarantee your rights consistent with this Policy and any applicable laws.
We will retain your personal information for as long as you have an account with us or we provide you with services. Thereafter, we will retain your personal information for as long as necessary to:
respond to any questions, complaints or claims made by you or on your behalf;
demonstrate that we treat you fairly;
keep records as required by law.
We will not retain your personal information for longer than is necessary for the purposes set out in this Policy. Different retention periods apply to different types of personal information:
Login information – we will retain this information for as long as necessary to provide the services or as required by law.
Account information – we will store this information for as long as necessary to provide the services or as required by law.
Payment information – we will store this information for as long as necessary to provide the services or as required by law.
Information submitted to our support team – we store this information as long as it is needed to provide the service or as required by law.
Advertising information – stored for as long as it is needed to provide the service or as required by law.
Information collected automatically – stored for as long as it is needed to provide the service or as required by law.
Survey information – we store this information as long as it is needed to provide the service or as required by law.
Other information – we store this information as long as it is needed to provide the service or as required by law.
If your account is cancelled or terminated in accordance with the Terms of Service, we will delete or anonymize your personal data.
The security of your personal information is of great importance to us, and we have implemented security measures designed to protect your personal information and regularly monitor our systems for possible vulnerabilities and attacks. We are constantly working to improve these safeguards to ensure the security of your personal information.
However, we need to remind you that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.
When sharing, transferring and disclosing your personal information, we adhere to the principles and requirements of minimization, necessity and legality. We will not share, transfer or disclose your personal information externally except as described below:
We will not sell any personal information to third parties. We will only share your personal information with third parties when necessary. This happens when:
Third parties that provide services to support the Service, including cloud and network service providers, who process or back up the information specified in this Policy on their servers to provide the Service, perform user authentication, handle customer support and support communications, analyze crashes and improve the performance of the Service, provide marketing and advertising and monitor the success of our marketing and advertising programs, provide you with updates and information about the Service, provide translations, detect whether user-generated content violates applicable laws, our terms or community rules, provide payment processing services (including security and fraud detection), and notify and improve the refund process when you request a refund. All companies that provide services to us are prohibited from retaining, using or disclosing your personal information for any purpose other than providing us with services that support the Service.
Companies within our group that process your personal information for the purpose of operating the Service. All relevant group companies may only use your personal information in accordance with this Policy.
We only allow our service providers to process your personal information if we are satisfied that they have taken appropriate measures to protect your personal information. We also impose contractual obligations on service providers to ensure that they can only use your personal information to provide services to us and you. Your personal information received by these third-party service providers may be subject to their own privacy policies or statements, and this Policy does not apply to any products, services, websites or content provided by third parties. We are not responsible for the collection, use and/or processing of your personal information by third-party service providers.
We will not transfer your data to any other party, except as follows:
We have obtained your explicit consent.
If we are involved in a merger, acquisition or sale of all or a portion of our assets that may affect your personal information, we will notify you of any changes in ownership of your personal information and your rights, as well as any choices you may have regarding your personal information, by posting a prominent notice via email and/or our website or other appropriate means.
We have explained in this Policy that we will transfer personal information to third parties or have notified you by other means.
We may need to disclose your data if required by law, subpoena, or other legal process, or if we believe in good faith that disclosure is reasonably necessary to:
(1) investigate, prevent, or take action regarding suspected or actual illegal activity or to assist government enforcement agencies;
(2) enforce our agreements with you;
(3) investigate and defend ourselves against any third-party claims or allegations;
(4) protect the security or integrity of our Services; or
(5) exercise or protect the rights and safety of our Services, our users, employees, or others. Unless prohibited by law or court order, or in emergency circumstances, we will attempt to notify users of lawful requests for their personal data when we deem appropriate. We may object to requests when we determine, in our sole discretion, that the request is overbroad, vague, or lacks proper authority, but we do not promise to object to every request.
In addition, we may share your data with:
When we ask our attorneys, legal officers, accountants, auditors, or similar advisors to provide professional advice.
Investors and other relevant third parties, if an actual or potential sale or other corporate transaction occurs and is related to an entity within our group.
Other third parties, such as disclosing specific information with your authorization and consent.
For the purposes described in this Policy, to the extent permitted by applicable local laws and regulations and with your authorization and consent, we may transfer your personal information to our servers as specified in Section V of this Policy (How we store and protect your personal information) for storage or processing. We may also transfer your personal information to third-party service providers and business partners, and your data may therefore also be transferred to other countries or regions.
When we transfer personal information outside your jurisdiction, whether to our affiliates or third-party service providers, we will comply with relevant applicable laws. We will take appropriate security measures and safeguards to ensure that all such transfers comply with the requirements of applicable local data protection laws.
Our services are not intended for children under the age of thirteen (13) or the minimum age in the relevant region (if over thirteen (13) years old) (hereinafter referred to as “children”), and we do not intentionally collect any personal information from such children. Children should not use or attempt to use our Services, and if you are a child, please do not attempt to use our Services or send any information about yourself to the Company.
If we learn that we have inadvertently collected personal information from a child, we will take reasonable steps to delete such information from our records. Parents who believe that we may have collected any information from or about a child may submit a request to delete such information to the email address listed in Section 13 (How to Contact Us) below.
You have certain rights with respect to your personal information, which are described in this section. You or an authorized agent acting on your behalf may exercise your personal information rights by submitting a verifiable request or through our Platform (see “How to Exercise Your Rights” below). If an authorized agent submits a request to know or delete your personal information, we require that you:
provide your authorized agent with a signed permission to exercise your rights and choices;
verify your identity directly to us; and
confirm directly to us whether your authorized agent has the authority to submit the request.
You have the following data protection rights:
The right to access or delete the data we hold about you. You have the right to access the personal data we hold about you. If you request a copy of your personal data, we will provide you with a copy in an electronic format after going through our verification process. Subject to certain exceptions permitted by applicable law, upon receipt of a verifiable request, we will delete your personal data from our records and instruct our service providers, contractors or other third-party affiliates to delete your personal data from their records, unless they have obtained your separate consent to process it. However, if you choose to delete any personal data, certain features that require such data may no longer be available, and you acknowledge and agree that we may retain your personal data as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and enforce our agreements.
Right to rectification. If you believe that the personal information we hold about you is inaccurate or incomplete, you have the right to have your personal information corrected without delay.
Right to object and restriction. You have the right to object to our processing of your personal data (for example, object to our processing of your personal data for direct marketing at any time) or request that we restrict the processing of your personal data. You can ask us to stop using all or some of your personal data (for example, if we have no legal right to continue using it) or to restrict our use of it (for example, if your personal data is inaccurate or unlawfully held).
Right to data portability. You have the right to obtain a copy of the data we hold about you in a structured, machine-readable and commonly used format.
Right to withdraw consent. You also have the right to withdraw your consent at any time where we rely on your consent to process your personal information. You can withdraw consent you previously granted to us for a specific purpose, including the collection, use and/or disclosure of your personal information that we manage or control, by deleting your data, turning off device features and contacting us to request withdrawal of consent (see “How to Contact Us” below). If you withdraw your consent, you may no longer be able to benefit from some and/or all of our services. Withdrawing your consent or authorization will not affect the validity of the processing activities we previously carried out based on your consent.
Right to control your privacy settings. You have the right to control your privacy settings and limit our collection, use, disclosure or processing of your personal information through such privacy settings. For example, you can choose to turn on or off permissions for “Location Access” or “Storage”; you can get detailed data about the security status of your device or change such status in the “Privacy Settings” on your device.
The right to close your account. You can close your account through the instructions in our services, or contact us for help. Please understand that for security reasons, your account cannot be closed unless you follow our instructions. We would like to remind you that if you want to close your account, such closure may prevent you from using our services, and such closure is irreversible. Once you close your account, we will delete or de-identify your relevant data. If you log in to your account through a third-party account (e.g., through Apple ID, Facebook, Google ID), you need to apply to the third party to close your account.
Under the applicable laws of some jurisdictions, you may have additional data subject rights. Please refer to the jurisdiction-specific supplementary terms at the end of this policy.
To easily access, review, update, correct, delete or port your personal data, or update your subscription preferences, please log in to your account and visit “Personal Information” or contact our customer service. If we rely on consent to collect and use information about you, you may withdraw your consent at any time. If you request deletion of your personal data and that data is necessary for the services you purchased, we will honor that request only to the extent that the data is no longer necessary for any services we purchased or for legitimate business purposes or legal or contractual recordkeeping requirements.
To exercise the access, data portability, correction, and deletion rights described above, please submit a verifiable request to us at the email address listed in Section 13 (How to Contact Us) below.
Only you or a person legally authorized to act on your behalf may make a verifiable request related to your personal data. You may also make a verifiable request on behalf of your minor child.
You may only make two verifiable requests for access or data portability within a twelve (12) month period. A verifiable request must:
Provide sufficient information (including your account name, password, email address, and other information reasonably requested by the Company) to allow us to reasonably verify that you are the person about whom we collected personal information or an authorized agent;
Describe your request in detail so that we can properly understand, evaluate, and respond to it.
If we cannot verify your identity or authority to make the request and confirm that the personal data relates to you, we will not be able to respond to your request or provide you with personal data.
If you lose your account, you can reset your password by SMS or email verification or by contacting customer service. However, in the process, you will need to provide some personal information to verify your identity. When retrieving your password, we may ask you to provide your usual login location, usual login device, usual listening content, registration time and city information.
You do not need to create an account with us to make a verifiable request. We only use the personal data provided in a verifiable request to verify the requester’s identity or authority to make the request.
We strive to respond to any verifiable request within one (1) month of receiving it. If we need more time, we will inform you in writing of the reason and the extension period required. We will send you a confirmation of receipt of any verifiable request within ten (1) months
(10) business days from the date of receipt.
If you have an account with us, we will send a written response to that account. If you do not have an account with us, we will send a written response to the method you submitted your request.
If we cannot comply with a verifiable request, we will explain our reasons to you in writing, if applicable. For data portability requests, we will select a format to provide your personal data , which is easy to use and should allow you to transfer information from one entity to another without hindrance.
Generally, you do not need to pay a fee to access your personal data or exercise any privacy rights. However, except in cases related to withdrawal of consent, we may charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive. If we determine that the request is worth charging, we will tell you why we made that decision and provide you with a fee estimate before completing the request. In this case, we may also refuse to comply with your request.
In the following circumstances, in accordance with applicable laws and regulations, we may refuse to execute your request:
Related to our obligations under laws and/or regulations;
Related to national security and national defense security;
Related to public safety, public health, and major public interests;
Related to criminal investigation, prosecution and trial;
There is sufficient evidence that you have subjective malice or abuse of rights;
Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals and organizations;
Involving trade secrets;
Other conditions stipulated by laws and regulations.
Cookies are small text files that are used to ensure that our software works properly and that you can access it conveniently. Cookies usually contain an identifier, a site name, and some numbers and characters. We may use Cookies and other similar technologies, such as Pixel Tags and Web Beacons. We generally treat information collected through Cookies and similar technologies as non-personal information because they do not contain any of your personally identifiable information. However, if the Internet Protocol (IP) address or similar identifier is considered personal information by the laws of the relevant country, we will also comply with the laws of the relevant country.
We and our partners may use Cookies and similar technologies (such as pixels and ad tags) to collect data (such as device IDs) to recognize you and your device when you use our services. You can manage or delete Cookies according to your preferences.
Because consumers are generally unaware that their “Do Not Track” beacons are active, “Do Not Track” signals generally do not reflect the actual preferences of our users. We do not respond to “Do Not Track” signals. In the meantime, you can opt out of certain types of tracking, including certain analytics and customized advertising, by changing your cookie settings.
During your use of our services, you may receive links to third-party websites or content and services provided by third parties other than us. Some third-party products or services can be accessed through SDKs and other forms to provide you with certain functions and features, such as third-party login, notifications and user analysis (collectively referred to as “third-party services”).
You can choose whether to access or accept such third-party services. We encourage you to read and review the privacy statement of each third-party service you may choose to use.
In order to better and more effectively establish personal information protection, we, as the data controller, designate a data protection officer to oversee and implement personal information protection policies and ensure that our processing of personal information complies with the necessary legal requirements stipulated by applicable laws. If you have any comments, questions or concerns about our privacy policy or personal information protection practices, please contact our data protection officer at [email protected].
All requests must be marked as “Privacy Policy Request” in the subject line of the email so that we can better assist you. We will review your privacy or personal information request and respond to you as soon as possible after verifying your user identity. If your request itself involves any complex or major issues, we may ask you to provide more information.