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Funtopia Privacy Statement
 
Last updated as of August 30, 2021
In this Privacy Statement, we, Funtopia Ltd., with principal office at 5F-6, No. 210 Gongyequ 38th Rd., Xitun Dist., Taichung 407277, Taiwan R.O.C., provide information about how we collect, use, disclose and otherwise process personal information in connection with our services, and the privacy rights that individuals have. This Privacy Statement only applies to services that we operate and that include a reference or link to this Privacy Statement (our “Services”), and may be supplemented by additional notices to you depending on the specific feature you are accessing or using. By “personal information” or “personal data”, we mean information that identifies you or can reasonably be used to identify you. If you reside in California, please also see our Supplemental California Consumer Privacy Act Privacy Policy further below at Section 10.
 
1. What Personal Information Do We Collect?
Depending on how you interact with our Services, we may collect the following types of personal information about you, which we have grouped together as follows:
  • Account Data, which may include any information about yourself that you share when creating an account on our Services and using our Services in connection with your Account. This includes data that we ask for when you register for an account (including username), data about how you interact with our Services, any information that you authorize third parties such as Facebook, Google or Apple to share with us if you create an account through their services, any communications you send to other users of our Services via your account, and any information that you voluntarily upload to your account profile. 
 
For example, we may collect and store some or all of the following information shared by the third party: 
  • your first and last name;
  • your profile picture or its URL;
  • your user ID number and profile information; 
  • your login e-mail provided to the third party; 
  • your physical location and that of the devices you use to access our Services; 
  • ​your gender;
  • your birthday and/or age range;
  • ​information about your activities through the third party; 
  • other publicly-available information provided by the third party; and/or 
  • any other information that the third-party shares with us.
 
You may also share information with us directly. Certain areas and features of the applications may require registration, account set-up and verification, including verification that you are over the age of 18 in order to complete your registration. You may be asked to give us some or all of the following information:
  • your age or birthday;
  • ​your first and last names;
  • your e-mail address; and
  • a password.
You may be able to take part in certain activities on our applications and through our Services that enable you to communicate or share information with us and other players. These include: 
  • participating in player forums and message boards;
  • posting public comments to player profiles or gameboards;
  • sending private messages or invitations to other players;
  • chatting with other players; and/or
  • posting photos.
 
You can also provide us personal data directly in a number of other ways, including:
  • in response to surveys or other research we conduct;
  • to participate in contests and sweepstakes; 
  • via social media;
  • by participating in group communications or chats;
  • at conferences, conventions, and other events. 
 
  • Technical and Usage Data, which may include your internet protocol (IP) address, the type of device you are using to access our Services, your browser type and version, time zone settings and location, browser plug-in types and versions, operating system and platform, and information about how you access and use our Services. Like many websites, we, our service providers and other parties may send cookies to your device when you access or view the Service. A cookie is a small data file that is transferred to your device for record-keeping purposes.  Information contained in a cookie may be linked to personal data. We use cookies for purposes such as improving the quality of our Service, tailoring recommendations to interests, and making the Service easier to use.

Third party advertisers on the Service may also use, place, or read cookies or other technologies as described below on your device, and those practices are subject to their own policies. For more information on how you can opt-out of or disable cookies, please see the Your Rights section below.

We and our service providers may also employ other technologies including (i) web beacons, which allow us to know if a certain page was visited or whether an e-mail was opened; (ii) tracking pixels, which allow us or our advertising partners to advertise more efficiently and effectively by excluding our current players from certain promotional messages, identifying the source of a new installation or delivering ads to you on other websites; and (iii) local shared objects, also known as flash cookies, which help us to reduce fraud, remember your in-game preferences, and speed up load times.

We, our service providers, and other parties may collect the following information via cookies and other technologies: 
  • ​your mobile device’s identifiers, like your MAC Address, Identifier for Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI);
  • your browser language;
  • the amount of time spent on particular pages;
  • game state and the date and time of activity on our websites or games.
  • the length of time you play our applications, and/or visit or use our website and Services. 
  • cookies, which are small pieces of data transferred to your mobile device or computer for record-keeping purposes;

We may obtain the billing and payment information that you provide when your purchase is processed by someone else (like Facebook, Apple or Google) such as when you purchase something in a game you play on a social network or that you downloaded on your mobile device. Our Terms of Service explain our policies and terms relevant to our charges, billing practices, third-party credits and virtual currencies.
 
If you purchase virtual currency or virtual items in our game, our third-party payment processor will collect the billing and financial information it needs to process your charges. This may include your postal address, e-mail address and financial information.
 
We do not collect or store credit card numbers. However, our payment processors may share information with us related to your purchases. We may use this information for purposes as described in this Privacy Notice.
 
2. How Do We Collect Personal Information?
We collect personal information directly from you, such as when you create or edit an account with us, submit personal information to us, or upload personal information to our Services. As you interact with our Services, we will also automatically collect Technical and Usage Data about your equipment, browsing actions and patterns. We collect this personal information by using cookies, server logs and other similar technologies. Please see the section “How Do We Use Cookies” below for more information.
 
3. How Do We Use Your Personal Information?
We use your personal information for the following purposes including but not limited to:
  • ​Determine whether you are eligible to use our Services and, if so, create an account for you on the Services. 
  • Develop, operate, manage, secure, update, provide and customize our Services. 
  • ​Respond appropriately to your comments, questions, requests and inquiries. 
  • Update you regarding your account and send you technical notices, updates, security alerts and support and administrative messages relating to our Services. 
  • ​Exercise our rights and discharge our obligations to you under any contract we may have with you.
  • ​Exercise our legal rights, defend our legal interests, protect against fraudulent and illegal activity, protect the safety, rights or property of our customers, the public or us and our affiliates, and comply with applicable laws. 
  • If we take steps to enter into a reorganization, restructuring, merger, acquisition or transfer of assets (“Business Transfer”), we may also use your personal information as reasonably necessary to give effect to that Business Transfer.
  • conduct research, including by using personal data to create de-identified and/or aggregated data. De-identified and aggregated data are not personal data and we may use and share such data for any legally permissible purposes.
  • ​To better understand how users access and use our applications and Services, both on an aggregated and individualized basis, in order to improve our applications and Services, analyze player traffic and activity, respond to user desires and preferences, and for other research and analytical purposes.
4. What Personal Information Do We Disclose?
We do not disclose your personal information to others, except in the following circumstances and in accordance with applicable law:
  • Other Users at Your Request: Some of our Services allow you to interact and communicate with other users of our Services. In particular, when you enter a chat room, the information in your profile will be available to others, and if you send a message to another user, the information in that message will be available to the users you message.
  • ​Our Service Providers: We disclose personal information with our affiliated and unaffiliated service providers, who act on our behalf and under confidentiality agreements to deliver services to us, including to process payments, analyze data, optimize gameplay, enhance players’ experience, deliver emails, provide IT and hosting services, and manage and deliver advertisements.
  • Government Agencies, Regulators and Professional Advisors: Where permitted or required by applicable law, we may also transfer your personal information to government agencies and regulators to comply with our legal obligations, and to external professional advisors as necessary to defend our legal interests.
  • ​Organizations Involved in Business Transfers: In the event of a merger, reorganization, dissolution or similar corporate event, or the sale of all or substantially all of our assets, we expect that the information that we have collected, including personal information, will be transferred to the surviving entity in a merger or the acquiring entity. Such information will be transferred in accordance with applicable law.
5. How Do We Protect Your Personal Information?
We have taken steps intended to protect your personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. For example, when players login to our Services, our servers use SSL encryption on all information processed during the communication. 
While we have sought to create a secure and reliable online experience for users, the confidentiality or accuracy of any communication or material transmitted to or from us over the Internet cannot be guaranteed. It is your responsibility to safeguard the credentials that you use to access our Services, and to notify us immediately at the contact information below if you ever suspect that your credentials have been compromised.
 
6. How Long Do We Retain Personal Information?
We store personal information as long as necessary to provide you with the Services that you requested and to fulfil the other purposes set forth in this Privacy Statement, as appropriate. Otherwise, we will only store your personal information in accordance with storage periods as required or permitted by applicable laws and regulations (e.g., to account for statutory periods of limitation).

7. Your Rights
Under applicable laws, you may have rights to access, update, rectify, port or erase certain personal information that we have about you or restrict or object to certain activities in which we engage with respect to your personal information. If you have such rights and your request complies with the requirements under applicable laws, we will give effect to your rights as required by law. 
 
To exercise any rights you may have under applicable privacy laws, please contact us using the details in the “Contact Us” section below.  We may need to request specific information from you to help us confirm your identity. This is a security measure to ensure that we only grant requests regarding personal information from individuals who are authorized to exercise rights regarding that personal information. We may also contact you to ask you for further information in relation to your request to speed up our response.

8. Collection of Personal Data from Children.
We do not knowingly collect personal information from children under the age of 13, and we do not knowingly market the Services or any goods or services to such children.

9. Effective Date and Changes to Privacy Statement.
We reserve the right to change this Privacy Statement. If we make a material change to how we collect, use, or disclose personal information, we will prominently post an updated Privacy Statement in connection with our Services. Where required to do so by law, we may seek your prior consent to any material changes we make to this Privacy Statement. If you disagree with our Privacy Statement changes, you must discontinue using our Services.

10. Supplemental California Consumer Privacy Act Privacy Policy
In this Supplemental California Consumer Privacy Act Privacy Policy (“CCPA Privacy Policy”), we disclose information about our data processing practices as required by the California Consumer Privacy Act of 2018 (“CCPA”). This CCPA Privacy Policy was last updated on August 27, 2021. 
 
A. Scope
If you reside in California and access our Services or otherwise provide us with your personal information, this CCPA Privacy Policy applies to you. This Statement does not reflect our processing of California residents’ personal information where an exception under California law applies.
 
B. Right to Know About Personal Information Collected, Disclosed or Sold
The Cash Journey Privacy Statement and this CCPA Privacy Policy describe how we collect, use and disclose California residents’ personal information. You have the right to request that we disclose what personal information we collect, use, disclose and sell about you specifically (“right to know”). To submit a request to exercise your right to know, please submit an email request to [email protected] and include “CCPA Request to Know” in the subject line. Please specify in your request the details you would like to know, including any specific pieces of personal information you would like to access. We will ask that you provide certain information to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. We will respond to your request in accordance with the CCPA. If we deny your request, we will explain why.
 
C. Our Personal Information Handling Practices over the Past 12 Months
We set out below the categories of personal information we have collected about California residents in the past 12 months and the business or commercial purposes for which we collected the information. We collect this information directly from California residents who use our Services. 
 
(A) Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, WiFi location, email address, account name, or other similar identifiers. (Sources of the personal information: our players, our players’ devices, social networks, (for example, Facebook), third parties (e.g., marketing partners, data or analytics services) 
 
(B) Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, his or her name, address, telephone number, credit card number, debit card number, or any other financial information. “Personal information” does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. (Sources of the personal information: our players, our players’ devices, social networks, (for example, Facebook), third parties (e.g., marketing partners, data or analytics services)
 
(C) Characteristics of protected classifications under California or federal law, including race, national origin, age (40 and older), gender identity and gender expression.  (Sources of the personal information: our players, our players’ devices, social networks, (for example, Facebook), third parties (e.g., marketing partners, data or analytics services)
 
(D) Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. (Sources of the personal information: our players, our players’ devices, social networks, (for example, Facebook), third parties (e.g., marketing partners, data or analytics services)
 
(E) Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement. (Sources of the personal information: our players, our players’ devices, social networks, (for example, Facebook), third parties (e.g., marketing partners, data or analytics services)
 
(F) Geolocation data. (Sources of the personal information: our players, our players’ devices, social networks, (for example, Facebook), third parties (e.g., marketing partners, data or analytics services)
 
(G) Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. (Sources of the personal information: our players, our players’ devices, social networks, (for example, Facebook), third parties (e.g., marketing partners, data or analytics services)
 
We use the above categories of personal information for the purposes outlined in Section 3 (How Do We Use Personal Information?) above. We disclose or may disclose this personal information to the categories of recipients outlined in Section 4 (What Personal Information Do We Disclose?) above. 
We do not sell California residents’ personal information. We do not have actual knowledge that we sell the personal information of minors under 16 years of age. Although we do not "sell" your personal data, we do let advertising and other service providers collect IP addresses, cookie IDs, advertising IDs, mobile IDs through our sites and apps when you use our Services.
 
D. Right to Request Deletion of Personal Information
You have the right to request the deletion of personal information that we collect or maintain about you. To submit a request to delete personal information, please submit an email request to [email protected] or mail our physical address and include “CCPA Request to Delete” in the subject line. Please specify in your request the details you would like to have deleted. We will ask that you provide certain information to verify your identity. The information that we ask you to provide to verify your identity will depend on your prior interactions with us and the sensitivity of the personal information at issue. Once we have verified your identity, we may ask you to confirm that you wish to have your personal information deleted before completing your request. We will then respond to your request in accordance with the CCPA. If we deny your request, we will explain why.
 
E. Right to Opt-Out of the Sale of Personal Information
You have the right to opt-out of the sale of your personal information by a business. We do not sell your personal information.
 
F. Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
You may not be discriminated against because you exercise any of your rights under the CCPA.
 
G. Authorized Agent
You can designate an authorized agent to make a request under the CCPA on your behalf in certain circumstances. If you use an authorized agent for this purpose, we may ask you to verify your identity or that you provided the authorized agent signed permission to submit a request under the CCPA on your behalf. If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.
 
11. Contact Us
If you have any questions or concerns regarding this Privacy Statement or would like to exercise your privacy rights, you may contact us by writing to: service@funtopiagames.com or Funtopia Ltd., 5F-6, No. 210 Gongyequ 38th Rd., Xitun Dist., Taichung 407277, Taiwan R.O.C.

 

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