1. Company Information
This Privacy Policy is issued by Beijing Zhuohai Wenyi Technology Co., Ltd. (referred to as "we", "us", or "our"). We act as the data controller for the personal information collected through our mobile applications, games, and official website.
Registered Address: No.206-034, No.7, Juyuan W. Road, Mapo Town, Shunyi District, Beijing, 100000 China.
Contact Emails:
2. Data We Collect
We collect and process various types of data to provide and improve our services. This information is categorized as follows:
- Identity Data: Includes usernames, nicknames, or avatars provided by you or retrieved through third-party sign-in services.
- Account Data: Information required for account creation and management, including login credentials and profile settings.
- Technical & Device Data: Includes IP address, device model, operating system version, hardware specifications, unique device identifiers (e.g., IDFA, AAID/GAID), and mobile network information.
- Usage & Analytics Data: Details on how you interact with our apps/games, such as features used, time spent, levels achieved, and crash logs.
- Location Data: Coarse location information derived from your IP address (e.g., country or city level) to provide regional content.
- Advertising Attribution Data: Data related to how you discovered our application (e.g., which ad campaign or referral source led to the install).
- Support & Communication Data: Records of your correspondence with us, including support tickets and feedback.
- Payment Information: Transaction history and purchase details. Note: All financial transactions are processed by the respective App Stores; we do not store credit card numbers.
3. How We Use Data
We process your data based on Legal Basis such as contractual necessity, legitimate interest, or explicit consent. Specific uses include:
- Service Delivery: To operate, maintain, and provide the functional features of our apps and games.
- Performance Improvement: To debug, optimize code, and enhance user experience through data-driven insights.
- Security & Fraud Prevention: To protect our systems and users from unauthorized access, cheating, or abusive behavior.
- Customer Support: To respond to your inquiries and resolve technical issues.
- Personalized Advertising: To serve ads that are relevant to your interests (subject to your consent where required).
- Internal Analytics: To understand market trends and user demographics for business planning.
- Legal Compliance: To comply with applicable laws, regulations, and requests from law enforcement.
- Marketing Communications: To send updates about new features or promotional offers (with an opt-out option).
- Research & Development: To test new concepts and develop next-generation mobile technologies.
- Billing & Transactions: To manage in-app purchases and verify subscription statuses.
4. Advertising & Ad Platform Disclosure
4.1 Ad Network Partners
We integrate third-party Advertising SDKs to support our free services. These partners may collect device identifiers to serve targeted ads. Our primary partners include:
- Google AdMob, Meta Audience Network, Unity Ads, ironSource, AppLovin
- Vungle, Mintegral, Liftoff, Pangle (TikTok for Business), Fyber
- Chartboost, InMobi, Tapjoy, Smaato, AdColony
4.2 Ad Formats
You may encounter the following ad formats within our applications:
- Splash Ads: Shown during app launch.
- Interstitial Ads: Full-screen ads shown at natural transition points.
- Rewarded Video Ads: Optional videos you watch to earn in-game rewards.
- Banner Ads: Small rectangular ads at the top or bottom of the screen.
- Native Ads: Integrated ads that match the look and feel of the app content.
4.3 Personalization & Consent Management
We use Consent Management Platforms (CMP) to allow users in regulated regions to choose between personalized and non-personalized advertising. You can adjust these settings at any time within the app settings or your device's privacy menu.
4.4 Authorized Digital Sellers (app-ads.txt)
We strictly support the IAB Tech Lab's app-ads.txt initiative. This standard prevents unauthorized ad inventory selling and ensures transparency. Our authorized sellers list is publicly available at bjzhuohai.com/app-ads.txt for programmatic buyers to verify.
5. App Store Specific Policies
5.1 Google Play Compliance
We strictly follow the Google Play Developer Program Policies, including the Data Safety requirements. We provide transparent declarations regarding data collection and encryption practices as required by the Google Play Console.
5.2 Apple App Store Compliance
We adhere to Apple's App Privacy Labels and App Tracking Transparency (ATT) framework. We will only track your activity across other companies' apps and websites for advertising purposes if you grant explicit permission via the iOS system prompt.
6. Country-Specific Policies
We respect regional privacy laws and provide specific protections for users in:
- EU/EEA & UK: Compliance with GDPR and UK GDPR. You have the right to lodge a complaint with a supervisory authority.
- California (USA): Compliance with CCPA/CPRA. We do not "sell" your personal information in the traditional sense.
- United States: Compliance with COPPA for children's privacy protection.
- Canada: Adherence to PIPEDA principles for personal information protection.
- Australia: Compliance with the Privacy Act 1988 and Australian Privacy Principles (APPs).
- Thailand & Singapore: Compliance with PDPA requirements for data processing and transfer.
- Brazil: Compliance with LGPD for data protection rights.
- South Africa: Adherence to the Protection of Personal Information Act (POPIA).
7. Children's Privacy & Age Restrictions
Protecting the privacy of young children is especially important. Our services are generally not directed to children under 13 (or 16 in some jurisdictions). We do not knowingly collect personal data from children. If we discover we have inadvertently collected such data, we will take immediate steps to delete it from our servers. We use Age Gates in certain applications to ensure compliance.
8. Data Sharing & International Transfers
8.1 Third-party Sharing
We may share your data with the following categories of recipients:
- Cloud Service Providers: For hosting and data storage (e.g., AWS, Google Cloud).
- Advertising Partners: To facilitate the delivery of ads as described in Section 4.
- Analytics Providers: To help us understand app performance (e.g., Firebase, AppsFlyer).
- Legal Authorities: When required by law or to protect our legal rights.
- Business Transfers: In the event of a merger, acquisition, or sale of assets.
8.2 Cross-border Data Transfers
As a global technology team, your information may be transferred to and processed in countries other than where you live, including China and the United States. We implement Standard Contractual Clauses (SCCs) and other legal mechanisms to ensure that your data remains protected according to this policy, regardless of where it is processed.
9. Data Retention
We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements. When data is no longer required, we perform Secure Deletion or Irreversible Anonymization.
10. User Rights
Depending on your location, you may exercise the following rights regarding your data:
- Right of Access: Request a copy of the data we hold about you.
- Right to Rectification: Request correction of inaccurate or incomplete data.
- Right to Erasure: Request deletion of your data (the "Right to be Forgotten").
- Right to Restrict Processing: Request that we limit how we use your data.
- Right to Object: Object to our processing of your data for specific purposes.
- Right to Data Portability: Request transfer of your data to another service.
- Right to Withdraw Consent: Revoke your permission at any time.
- Right to Opt-out: Disable targeted advertising through app or device settings.
Note on Identity Verification: To protect your privacy and security, we will take reasonable steps to verify your identity before granting access to your personal data or complying with any requests to exercise your rights. This may involve requesting specific account information or device identifiers.
11. Cookies & Tracking
We use Cookies on our website and Local Storage (such as SharedPreferences on Android or NSUserDefaults on iOS) within our apps. These technologies help us remember your preferences, maintain session security, and analyze traffic patterns. You can manage cookie preferences through your browser settings.
12. Security
12.1 Technical Measures
We implement robust technical and organizational measures to protect your data:
- Encryption: Data is encrypted in transit using TLS/SSL and at rest using industry-standard algorithms.
- Access Control: We enforce Role-Based Access Control (RBAC) to ensure only authorized personnel can access sensitive data.
- Continuous Monitoring: We perform regular security audits and vulnerability scans to identify and mitigate risks.
12.2 User Self-Protection
While we take industry-standard precautions, no system is 100% secure. We encourage you to take steps to protect your personal information:
- Use strong, unique passwords for your accounts.
- Do not share your login credentials or account verification codes with others.
- Regularly update your operating system and applications to receive the latest security patches.
- Enable two-factor authentication (2FA) where available.
13. Contact & Data Protection
If you have any questions about this policy or wish to exercise your rights, please contact our Data Protection Officer at privacy@bjzhuohai.com.
For corporate legal or governance matters, please contact governance@bjzhuohai.com.
We may update this Privacy Policy from time to time. We will notify you of any significant changes by posting the new policy on this page and updating the "Last Updated" date.
