Last updated: January 01, 2024

This privacy policy (this “Privacy Policy”) explains how sunogame and our Affiliates (“we”, “our” or “us”) collect, use and disclose your personal data. This Privacy Policy applies to sunogame (“Game”) and related services (collectively, our “Services”), which informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Services and the choices you have associated with that data.

By downloading, accessing, using and/or interacting with our Services, you fully understand about our collection, use and disclosure of your personal data as described in this Privacy Policy. This Privacy Policy is incorporated by reference into the end user license agreement available at Terms of Service (the “EULA”) and is subject to the provisions of the EULA. Capitalized terms used but not defined in this Privacy Policy shall have the meaning ascribed to such terms in our EULA.

This Privacy Policy will help you to understand:

· What Personal Data We Collect and How We Use

· Cookies and Similar Technologies

· How We Entrust A Third-Party to Process, Share, Transfer and Disclose Your Personal Data

· How Long We Keep Your Personal Data

· The Security of Your Personal Data

· Children

· Your Rights

· Changes

· Addendum

· Contact Us

1. What Personal Data We Collect and How We Use

We offer a diverse mix of online H5 games created by independent developers, You can access our service without registering or logging in. Certain games on our website are controlled by third parties, including third parties located outside the EU/EEA, which shall be borne by its own privacy policy respectively. For those games hosting by us, we only collect and process your personal data in the minimum scope necessary for realizing the following purposes based on appropriate legal basis.

· 1.1

In order to provide some location-based services such as forming a team with people nearby, we may collect your IP address, GPS, RFID, your home address.

The processing activity for this purpose is based on your consent. We will ask for your consent when you turn on this feature and you have the right to withdraw your consent at any time.

· 1.2

In order to improve our Services and correct bugs or errors that occur when you are playing the game, we may collect relevant information including but not limited to your behavioral data in the Game, device information and network status.

The processing activity for this purpose is based on our legitimate interests and will not override your legal rights and interests.

· 1.3

In order to comply with applicable law (such as anti-money laundering regulations), we may collect your device and network information.

The processing activity for this purpose is necessary for compliance with the legal obligation we subject to.

2. Cookies and Similar Technologies

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Services. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities.

You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies, or instruct the device or web browser (as applicable) 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 that you refuse to install cookies, the Game may be unable to operate as designed.

3. How We Entrust a Third-Party to Process, Share, Transfer and Disclose Your Personal Data

We may share your personal data with the following categories of third parties in order to provide our Services to you

3.1 Affiliates

We are a global company and has affiliates all over the world. In order to provide our Services, we will share your personal data with our affiliates based on the respective legal basis and data processing agreements signed between us.

3.2 Advertising

This type of service allows User Data to be utilized for advertising communication purposes displayed in the form of banners and other advertisements on this Website, possibly based on User interests.

This does not mean that all Personal Data are used for this purpose. Information and conditions of use are shown below.

Some of the services listed below may use Cookies to identify Users or they may use the behavioral retargeting technique, i.e. displaying ads tailored to the User's interests and behavior, including those detected outside this Website. For more information, please check the privacy policies of the relevant services.

In addition to any opt out offered by any of the services below, the User may opt out of a third-party service's use of cookies by visiting the Network Advertising Initiative opt-out page .

（1）AdSense:

· -

Google AdSense is an advertising service provided by Google Inc. This service uses the "Doubleclick" Cookie, which tracks use of this Website and User behavior concerning ads, products and services offered.

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Users may decide to disable all the Doubleclick Cookies by clicking on: google.com/settings/ads/onweb/optout

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Personal Data processed: Cookies; Usage Data

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Place of processing: Ireland - Privacy Policy - Opt Out

3.3 Data Analytics

For purpose of better understand and providing more effective service, we may perform research and analysis on the collected Personal Data, such as your Game statistics, we may analyze, profile and segment such Personal Data. The research and analysis may be compiled and analyzed on an aggregate basis.

We may also use third-party Service Providers to monitor and analyze the use of our Service. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. For more information, please visit the privacy policies of the partners found here:

（1）Google Analytics:

· -

Google Analytics is a web analysis service provided by Google Inc. ("Google"). Google utilizes the Data collected to track and examine the use of this Website, to prepare reports on its activities and share them with other Google services.

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Google may use the Data collected to contextualize and personalize the ads of its own advertising network.

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Personal Data processed: Cookies; Usage Data

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Place of processing: Ireland - Privacy Policy - Opt Out

（2）Google Tag Manager:

· -

Google Tag Manager is a tag management service provided by Google Ireland Limited.

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Personal Data processed: Usage Data.

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Place of processing: Ireland - Privacy Policy.

3.4 Remarketing and behavioral targeting

This type of service allows this Website and its partners to inform, optimize and serve advertising based on past use of this Website by the User.

This activity is facilitated by tracking Usage Data and by using Trackers to collect information which is then transferred to the partners that manage the remarketing and behavioral targeting activity.

Some services offer a remarketing option based on email address lists.

In addition to any opt-out feature provided by any of the services below, Users may opt out by visiting the Network Advertising Initiative opt-out page .

Users may also opt-out of certain advertising features through applicable device settings, such as the device advertising settings for mobile phones or ads settings in general.

（1）Google Ads Remarketing (Google Ireland Limited)

· -

Google Ads Remarketing is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the activity of this Website with the Google Ads advertising network and the DoubleClick Cookie. Users can opt out of Google's use of cookies for ads personalization by visiting Google's Ads Settings .

· -

Personal Data processed: Cookies; Usage Data.

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Place of processing: Ireland - Privacy Policy - Opt Out

（2）Remarketing with Google Analytics (Google Ireland Limited)

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Remarketing with Google Analytics is a remarketing and behavioral targeting service provided by Google Ireland Limited that connects the tracking activity performed by Google Analytics and its Cookies with the Google Ads advertising network and the Doubleclick Cookie.

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Personal Data processed: Cookies; Usage Data.

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Place of processing: Ireland - Privacy Policy - Opt Out

3.5 Traffic optimization and distribution

This type of service allows this Website to distribute their content using servers located across different countries and to optimize their performance.

Which Personal Data are processed depends on the characteristics and the way these services are implemented. Their function is to filter communications between this Website and the User's browser.

Considering the widespread distribution of this system, it is difficult to determine the locations to which the contents that may contain Personal Information of the User are transferred.

（1）Cloudflare (Cloudflare Inc.)

· -

Cloudflare is a traffic optimization and distribution service provided by Cloudflare Inc.

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The way Cloudflare is integrated means that it filters all the traffic through this Website, i.e., communication between this Website and the User's browser, while also allowing analytical data from this Website to be collected.

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Personal Data processed: Cookies; various types of Data as specified in the privacy policy of the service.

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Place of processing: United States - Privacy Policy.

3.6 Law enforcement / legal obligation

（1） Anti-cheat and anti-fraud companies

we may share the information required for our detection, investigation and prevention of cheating in the Game and EULA violations only for the purposes of detection, investigation and prevention of cheating in the Game.

（2） Public authorities and auditors

Some personal data shall be disclosed to public authorities, e.g., tax and customs authorities, auditors, and other competent parties in accordance with the applicable laws.

3.7 Sale or merger

A third party that acquires all or substantially all of us or our business. We may 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 may also disclose information to a third party if we sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, personal data may be among the transferred assets. You will be notified via email, in-app/in-game notice and/or notice on our website of any change in ownership or users of your personal data.

4. How Long We Keep Your Personal Data

4.1 How we determine

We determine the retention period of your personal data taking consideration of the following elements:

· period of the contractual relationship with you;

· sensitivity of the personal data;

· time elapsed since your last interaction with us;

· security reasons;

· applicable statutes of limitation;

· ongoing or potential litigation or dispute;

· regulatory or legal obligation to retain the personal data.

4.2 How long we keep your personal data

We may retain most of your personal data as long as needed to provide services or products to you, or as required or permitted by applicable laws.

When destroying personal data, measures will be taken to make the personal data irrecoverable or irreproducible, and electronic files which contain personal data 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 data is required to be retained continuously for other reasons including but not limited to for the purposes as prescribed under applicable laws, the relevant personal data will be stored and maintained separately from other types of personal data. If you require us to destroy your personal data before the end of its life cycle (as set out in the retention policy above), we will destroy your personal data in accordance with local laws.

5. The Security of Your Personal Data

We are committed to maintaining the privacy and integrity of your personal data 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 data will remain subject to our technical and organizational controls and our policies and procedures (including but not limited to this Privacy Policy).

Unfortunately, the transmission of information via the internet is not completely secure. Although we will use commercially reasonable efforts to protect your personal data, we cannot guarantee the security of the information transmitted to our services; any transmission of your information is at your own risk.

In the case of a personal data breach, we will notify the personal data breach to the supervisory authority competent, where feasible, not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of you.

When the personal data breach is likely to result in a high risk to the rights and freedoms of you, we will communicate the personal data breach to you without undue delay.

6. Children

You hereby represent that you are an “adult” (as defined in the applicable in your jurisdiction) and have the requisite power and authority to access and/or use our Services. If you are not an adult, you must obtain the consent of your parent or legal guardian to use the Services. Usually our Services are not intended for children under the age of 16(this age requirement may vary in your country and is set forth in the table below) and we do not knowingly collect any personal data from such children. Children under the age of 16 should not use or attempt to use our Services, and if you are under 16, please do not attempt to use our Services.

In the event that we learn that we have inadvertently gathered personal data from a child under the age of 16, we will take reasonable measures to delete such information from our records. Parents who believe that we might have gathered any information from or about a child under the age of 16 may submit a request to the email address set forth in the section “Contact Us” below.

7. Your Rights

7.1 The right to be informed

You have the right to be provided with clear, transparent and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information in this Policy.

7.2 The right of access

You have the right to obtain access to your personal data. This is so you are aware and can check that we are using your personal data in accordance with applicable data protection laws.

Please contact us and submit a request to the email address set forth in the section “Contact Us” below.

7.3 The right to rectification

You are entitled to have your personal data rectified if they are inaccurate or incomplete. If you believe we hold any other personal data about you and that information is inaccurate, for information that you can change in your game settings, you can change it. And for information that you can't change, please contact our Email.

7.4 The right to erasure

This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there is no compelling reason for us to keep using it. This is not an absolute right to erasure and exceptions apply.

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

· you believe that it is no longer necessary for us to hold such personal data; or

· you believe the personal data we hold about you is being unlawfully processed by us.

We may need to retain personal data if there are valid grounds under data protection laws for us to do so (e.g., for the defense 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 data that has been made available publicly on the Services and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal data or providing links to the personal data to erase it too.

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

7.5 The right to restrict processing

You have a right to require us to stop processing the personal data we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal data, we may use it again if there are valid grounds under data protection laws for us to do so (e.g., for the defense of legal claims or for another’s protection). As above, where we agree to stop processing the personal data, we will try to tell any third party to whom we have disclosed the relevant personal data so that they can stop processing it too.

You may request we stop processing the personal data we hold about you where:

· you believe the personal data is not accurate for the period it takes for us to verify whether it is accurate;

· you wish to erase the personal data as the processing we are doing is unlawful but you want us to retain the personal data but just store it instead; or

· you wish to erase the personal data as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defense of legal claims.

7.6 The right to data portability

You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your personal data easily between our IT systems and theirs safely and securely, without affecting its usability.

7.7 The right to object to processing

You have the right to object to certain types of processing, including processing for direct marketing (which we perform only with your consent).

7.8 The right to lodge a complaint

You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection authority.

7.9 The right to withdraw consent

If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.

7.10 The right not to be subject to automated decision making

You have the right not to be subject to a decision based solely on automated processing (including profiling) which produces legal (or similarly significant) effects to you.

We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for：baseless or excessive/repeated requests; or further copies of the same information. Alternatively, we may be entitled to refuse to act on the request.

Please consider your request responsibly before submitting it. We will respond as soon as we practically can, generally within one month from when we receive your request but, if the request is going to take longer to deal with, we will come back to you and let you know.

We will also cooperate with the third-parties who have data interaction with us to ensure your rights pursuant to applicable laws and regulations.

8. Changes

If we make any material changes to this policy, we will post the updated policy here and notify our users. Please check this page frequently to see any updates or changes to this policy.

9. Addendum

· 10.1 Brazil Addendum

If you are located in Brazil, you acknowledge that we are bound by the Brazil’s General Data Protection Law (Lei Geral de Proteção de Dados Pessoais, LGPD). If you have any questions, concerns or complaints about this Privacy Policy, or how we handle your Personal Data, please contact us at the address as shown in section “Contact Us” below.

· 9.2 Columbia Addendum

If you are located in Columbia, you acknowledge that we are bound by the Statutory Law 1581 of 2012 (Law 1581). If you have any questions, concerns or complaints about this Privacy Policy, or how we handle your Personal Data, please contact us at the address as shown in section “Contact Us” below.

· 9.3 Turkey Addendum

If you are located in Turkey, you acknowledge that we are bound by the Law on Protection of Personal Data, Law No. 6698 (LPPD). If you have any questions, concerns or complaints about this Privacy Policy, or how we handle your Personal Data, please contact us at the address as shown in section “Contact Us” below.

· 9.4 Peru Addendum

If you are located in Peru, you acknowledge that we are bound by The Personal Data Protection Law N° 29733 (PDPL) and the Supreme Decree N° 003-2013-JUS-Regulation of the PDLP (Regulation). If you have any questions, concerns or complaints about this Privacy Policy, or how we handle your Personal Data, please contact us at the address as shown in section “Contact Us” below.

10. Contact Us

If you want to lodge a complaint about how we handle your personal data, or need to contact us for any other reason (including exercising any rights related to the above personal data), please send your request to: [email protected]