Effective Date: 2022/11/25


This privacy policy informs you of your choices and our practices regarding any personal information you provide to us. Your use of the product(s), service(s) and related websites (“Service”) distributed by Shenzhen Huanyinli Network Technology Co., Ltd. (“MagicGravity”, “we” , “our” or “us”) involves the collection and use of your personal information. It is important for you to understand how this happens and how you may control it.


The minimum age to create a MagicGravity user account is 13 (“Account”). Insofar as certain countries or platforms apply a higher age of consent for the collection of personal data, MagicGravity requires parental or guardian consent before an Account is created and personal data associated with it is collected.


This Privacy Policy applies to any and all of the MagicGravity Services and describes why and how we collect, store, and use your personal data, and the choices and rights you have about the personal data you provide or we collect in connection with the MagicGravity Services. If you use MagicGravity Applications versions other than the versions distributed in specific countries/regions inclueds Mainland China, Japan and Korea, You acknowledge that you have read and understood this privacy policy. If you do not agree with this privacy policy(“this policy”), you must not use MagicGravity Services. If you change your mind in the future, you may withdraw your consent to use of your peronsal information in accordance with this policy.


In the event of a merger, acquisition, reorganization, bankruptcy or other similar event, we will make an announcement in advance, disclose the details of the event and information about the successor, and with the express consent of you and/or your parent and/or guardian (if applicable) again, your personal data may transfer to the successor of MagicGravity. MagicGravity may periodically modify, adjust or revise the terms of this Privacy Policy. We will announce to you the updated terms and obtain your consent (and/or the consent of your parent/guardian, if applicable) again. You acknowledge and agree to check the updated terms regularly. If major clause changes are involved, we will make an announcement in advance.




1.  What Data We Collect and Process


This section describes the different types of personal information we collect and how we collect it. We will collect and use the following information about you:


(1)  Information you provide us (either directly or through a third-party)


i.  Account Registration Information:  when you register for the Service and link social media or similar accounts (e.g. Facebook, Twitter or Apple) in order to set up your profile (we import from your connected social media your personal information which includes your name as it appears on your social media profile and your profile picture);


ii.  Date of Birth. We only receive this information if you voluntarily provide it when using our services in accordance with Article 2(4) on the legal basis that it is collected with your consent (with consent), and we use this information to verify your age if you are a user in certain regions. Since we cannot verify the authenticity of your age, your self-reported age will be deemed as the basis for judgment.


iii.  Telephone Number or Email Address. We only receive such information when you submit your contact details to us (including your name, email address and physical address) as part of promotional activities for the Service; and when you make purchases in the Service (in which case we will process the information you provide to us to facilitate the payment).


iv.  User Generated Content: Nickname, signature, and chat data (solely in the form of text). We use this information to deliver your messages to other users for social interaction in-game and facilitate your communication with them in accordance with Article 2(7) and 2(9) on the legal basis of Service Provision.


v.  User Service Information. Any information that you provide in communications with our support team when you seek our technical and/or customer service support and/or exercise any of your legal rights as the data subject; in case of receiving your request for support, we use such information to provide relevant support as you request and further improve our services in accordance with Article 2(10) on the legal basis of Service Provision; in case of receiving your request for data access as the data subject, we use such information to verify the requestors identity to ensure that he/she is the person legally entitled to make the data access request in accordance with Article 2(9) on the legal basis that it is necessary to perform our legitimate obligations as the data controller (Obligation Performance).


vi.  Survey Information. The content of your survey responses. If you agree to participate in such surveys, we use this information to improve our services in accordance with Article 2(8) with consent.


vii.  Sweepstakes Participation Information: Name, email address, telephone number, mailing address, UID, nickname, and country/region. If you agree to participate in such sweepstakes and win any prizes, we use your UID, address and other information as necessary to provide digital prizes and/or deliver physical prizes, as well as announce your UID and/or nickname in a partially-redacted format in accordance with Article 2(4) with consent. For users who have not won any prizes, we will not announce or display the above information in any form.


viii.  Internet Protocol (IP) Address. We use this information to allow you to connect to our servers in accordance with Article 2(1).


ix.  Connected Social Media Account Information (Third-Party). Your social media account information (if you choose to log in to our services via your social media account(s) with the corresponding network(s)); in the case of Facebook, this refers to the username of your Facebook account; we use such information to create your account for using our services in accordance with your request, and to ensure that you may share in-game photos on the corresponding network(s) in accordance with Article 2(9) on the legal basis of Service Provision.


x.  Advertising Information. Advertising ID and select device information, we store the Advertising ID for that advertisement and the other device information with your profile to track the success of our advertising and marketing programs in accordance with Article 2(6) and 2(10) on the legal basis that it is in our legitimate interests to monitor the success of our advertising and marketing programs.


In order to better provide you with a complete gaming experience, we may merge and update our collected personal data with data from third-party contractors in order to update your data, perform market analysis, and/or otherwise improve our services.


When you use or interact with third-party services that may be available on our services, such as third-party social media widgets, share buttons, and/or login mechanisms, this Privacy Policy does not and will not extend to such features, which shall be subject to the respective third-party privacy policies.


Unless obtaining your express and additional consent in advance and for specific circumstances, we will not collect personally identifiable information (PII) or sensitive personal information (SPI), such as real name, address, and/or fax number. You acknowledge and agree that if you elect to submit any personal data, such personal data would be subject to this Privacy Policy and you agree with all the terms therein. Please note that any personal data submitted in business transactions will not be subject to this Privacy Policy, including but not limited to job applications, participation in events, and contract signings.


(2)  Data We Collect Only for System Functions


i.  Generated Open ID. We generate and use this information to store your game data (including level and progress) with your profile, and to allow you to connect to our servers in accordance with Article 2(1) on the legal basis of Service Provision.


ii.  IP Address. We use this information to allow you to connect to our servers in accordance with Article 2(1) on the legal basis of Service Provision.


iii.  Game Data. We use this information to provide you with feedback and information about your gameplay and progress in accordance with Article 2(4) and 2(9) on the legal basis that it is necessary to perform the Terms of Service.


iv.  Device Related Information. Device ID, device information (device name, device type, MAC address, IMEI, CPU, graphics card model, OS version and language, time zone, screen DPI, device resolution), registration time and login time; we use such information to improve our services including the functionality of our services in accordance with Article 2(9) and 2(10) on the legal basis that it is our legitimate interest to ensure service security, manage registrations and improve our services.


v.  Bugs, Errors, and Other Data About Crashes and Diagnosis Thereof (if the occasional system crash occurs in our services). Device information (name, model, memory size, and graphics card model) and in-game information (game version, user's UID, stacktrace); we use such information to conduct identity verification for security purposes, to identify and address bugs, and to evaluate and improve the functionality of our services in accordance with Article 2(3) and 2(4) on the legal basis that it is in our legitimate interest to ensure the security of our services, and to improve our services.


vi.  Security-Related Information. For the Android version: application information (APK name, version, startup time, process name), user account, device information (model, OS version, brand, CPU structure, root status, the unique identifier of ROM, screen resolution, system startup time, whether an emulator is being operated, the installed APK information, MAC address, network type, names of the running applications, list of file names in the cache directory of SD card application, and Wi-Fi name); for the PC version: application information, memory, executable module, system driver module, new thread, new load module, proxy, network, CPU, disk, and graphics card, account information, and device name, specific file types for specific directory, names of process windows, and name signature of suspicious process module; for the iOS version: application information (module and signature), root status of device; in accordance with Article 2(9) on the legal basis that it is our legitimate interest to ensure the security of our services.


You know and understand that since there are multiple versions of the game, the above information is collected for the purpose of adapting, developing and updating for devices of different versions.


vii.  Malicious Content Information. Nickname, signature, chat data (solely in the form of text); in order to ensure a harmonious and healthy online environment in the game, we collect the above information to avoid some words that may offend or distress others (which breaches the Terms of Service, e.g. pornographic content) via your signature, nickname, or chat data within our services in accordance with Article 2(9) on the legal basis that it is in our legitimate interest to ensure the security of our services and a harmonious online environment within our services.




2.  Why We Collect and Process Your Personal Data


In order to provide services, perform the Terms of Service and/or any other agreements between you and MagicGravity, and/or perform the legal liabilities under the applicable laws, we collect and process your personal data to:


(1)  allow you to access or restrict your access to our services;


(2)  analyze and manage our services for system administration, user service, security, fraud-detection, checking the authenticity of an account owner, archival and/or backup purposes;


(3)  correct bugs or errors, improve our services and respond to customer desires and preferences, including language and location customization, personalized support and instructions, and other responses;


(4)  develop new services or products that user(s) request and improve the user experience;


(5)  verify and confirm payment;


(6)  deliver advertising that may be relevant to your interests (you can choose to turn this feature on or off in the device settings as stated hereunder);


(7)  communicate with other users and take action against violations;


(8)  personalize your experience, keep you up to date with the latest product announcements, provide software verification, upgrades and administration, notify of special events, offer to participate in our surveys or activities, and provide other information pertaining to our services;


(9)  protect the integrity, safety, and security of our services or users, comply with legal obligations, and enforce compliance with the Terms of Service or other restrictions placed on your use of our services; and/or


(10) track your process across our websites and applications to verify that you are not a bot and to optimize our services.


For the purposes set forth above, our affiliates may be commissioned to process your information, provided that such affiliates comply with the terms and conditions hereunder. Affiliates in this Privacy Policy shall mean an entity that directly or indirectly controls, is controlled by or is under common control with MagicGravity Limited hereto.


In all of the above cases and purposes, you acknowledge and confirm that we may analyze, profile, segment, merge and/or update all collected data (regardless of an aggregated or individualized manner) for the purposes of improving service quality and providing a better experience.


In specific cases, we may collect other personal data apart from the categories stated herein based on your consent. When this occurs, we will, upon requiring your additional consent, provide more information about any change to the way or purpose of our collection or processing which might be different from or not clarified in the details in this Privacy Policy.


Under any circumstance where our collection or processing of your personal data is based on your consent, you may withdraw such consent at any time with no impact on the validity and lawfulness of collection or processing based on the consent made before its withdrawal.




3.  Advertisements and Your Choices


For the purpose of providing personalized advertisements, you acknowledge and agree that based on your consent we may collect and process the data to:


(1)  deliver, target and improve our advertising; and/or


(2)  improve advertising and other marketing and promotional activities.


We may also use the data you provide to send you, or have our authorized contractors to deliver advertisements, market research or surveys. If you do not wish to receive any marketing or advertising information from us or our contractors, please do not provide your personal information.


Pertaining to the marketing or promotional communications, you may opt-out of receiving such communications in accordance with the instructions therein, such as SMS, email, online communication channels, or other contact methods provided by us. For example, you may opt-out of the out-of-game push notifications on mobile applications by checking the settings and turning off the allow notifications(iOS/Android).


 Without your consent, we ensure that we will not use your data for marketing purposes, and after granting permission, you may also withdraw such consent at any time while without impact on the validity and lawfulness of data usage prior to such withdrawal. For the avoidance of doubt, if we know that you are a registered user under the age of 13 (or 14/16, if applicable), we will not target you with advertising.




4.  Cookies or Similar Technologies


In order to measure the effectiveness of our services, we may use cookies, which are small text files for added functionality or for tracking site usage. We may use cookies and/or authorize a third-partys tracking-utility, from time to time, (a) to log your IP address in determining the path that users take on our sites and identifying repeated users of our sites, (b) to collect the websites or sources that linked or referred you to our services, and/or (c) to collect technical data about the devices and software you use to access our services, the operating system of your devices, and other similar technical data. Notwithstanding the foregoing, we do not link your IP address to your personal data. If you do not wish to accept cookies or want to be notified of when they are placed, you may set your web browser to do so, if your browser permits.


We use the cookies, web beacons and similar technologies to personalize your experiences on our services and for various other purposes, including:


(1)  remembering you: cookies, web beacons and similar technologies help us identify you as a registered user and keep the preferences or data that you have previously provided;


(2)  analyzing how you use our services: cookies, web beacons and similar technologies help us understand what visitors (including users) are doing on our services, or what pages or sections are most popular;


(3)  deliver advertising: cookies, web beacons and similar technologies help us provide you with advertising that we believe is relevant to you or of interest to you, on the basis of the data you provide; and/or


(4)  other related functions or purposes mentioned in Article 2 herein.


We or our authorized contractors may use cookies and similar technologies to provide and personalize services, prevent fraud and fulfil other purposes mentioned above. Please note you can disable cookies in your browser settings, while some parts of our services may then not function properly.




5.  Who May Access Your Personal Data


In addition to MagicGravity and/or its affiliates, other parties may also access your personal data in the following situations. You acknowledge that you have foreseen and agreed to the occurrence of such disclosure when you provide your personal data.


(1)  Other In-Game Users of Our Services


Other users may, for example, in a group challenge, access your in-game activities in the process of such group challenge. Other users may also see your displayed data and read the messages you have posted on or through our services. You acknowledge and agree that our services may also include message boards, communities, forums, and/or other chat areas, where users may exchange ideas or communicate with other users, and that any data you post to any communication area is publicly viewable. We strongly recommend that all users avoid posting personal or sensitive data at any time on or through our services.


(2)  Competent Authorities


We may provide a certain portion of your personal data to judicial or administrative authorities as so requested. Besides, we may disclose certain portion of your personal data within a strictly limited scope of recipients when we reasonably think it is necessary to protect us, our users or a portion of the public.


In addition to be required by applicable laws, we reserve the right to disclose your personal data in the cases if we, in our good faith, believe that disclosing such data is necessary to identify, contact, or bring legal action against you, if (a) you are violating any other agreement(s) between you and us, such as the Terms of Service, this Privacy Policy or otherwise damage us; (b) you are infringing third-partiesrights and interests (including but not limited to intellectual property rights); and/or (c) we believe that it is necessary to prevent fraud or other illegal activities.


(3)  Third-Party Contractors


MagicGravity works with a number of (if any) third parties on or through our services to help us provide services and functionalities to you. We do not sell your personal data and only share data that is non-personally identifiable on its own, aggregated, or public with third-parties under the following necessary circumstances, and such third-parties thereof are prevented from processing (including but not limited to accessing, storing, using, or disclosing) your personal data except for achieving the purpose of their cooperation with us:


i.  Social networking portals who provide login and/or content-sharing service to and in our services;


ii.  Logistics service providers who provide shipping services such as delivering physical prizes to users;


iii.  Information communication service providers who provide SMS-messaging services;


iv.  Payment service providers who provide payment services, such as assisting our services to run on, facilitating userspayment, and maintaining a record of the userstransaction history;


v.  Advertising service contractors who provide marketing and advertising activities, including conducting the programs, tracking the success, and analyzing the effect thereof; and


vi.  Other contractors if any for the purpose of providing our services to you.


Besides, such contractors may use cookies, web beacons, and/or other tracking technologies to collect or receive data about you and might claim the data controller rights over your personal data. For example, users purchasing and/or subscribing products or services will be required to provide additional data to third-party payment contractors, such as a valid credit card number and expiration date. Such third-party payment contractors may collect, process and retain your data to process payments and resolve subsequent payment disputes and inquiries. We may also receive, process and store the provided information from you and/or such third-party payment contractors to confirm payment, record purchase history and/or protect our legitimate interest when resolving subsequent payment disputes and inquiries. Notwithstanding the foregoing, if you make any payments in using our services, any of your payment details are fully handled by the relevant payment service provider. We do not, however, receive and/or process any of your actual payment details such as card number or security code. We only keep the data concerning transaction date, currency, cost, and product(s) purchased.


Each third-party has its own privacy policy and security measures for processing data and information, so when specific third-parties are involved in collecting data and information, please participate in their privacy policies. Since those contractors may access, collect, or process your data as the data controller and operate under their own privacy policies, please refer directly to their privacy policies on their official websites and learn more about their data processing practices.




6.  Data Retention


We will keep your data only for as long as your account is active or only for as needed to provide you the MagicGravity game services unless deleted in accordance with your request or as otherwise required by law.


You acknowledge and agree that your data will be processed on our servers which may not be located in your country of residence and can be accessed by our support, engineering and/or our affiliates around the world. No matter where our servers are located, we will make great efforts to take the appropriate safeguards to guarantee your rights in conformity with this Privacy Policy and any applicable laws.


In the case you request to remove or delete your personal data, we will retain your data as long as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and/or enforce the agreements between you and us. Please note that the removal or deletion of any of your data may result in the termination of some of our applicable services.


We will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or where the applicable law provides for longer storage and retention period. Upon the expiration of such period, your personal data will be deleted, blocked or anonymized, as provided by applicable law.




7.  Your Rights


You have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at (填入邮箱). Please understand further information may be required to verify your identity when exercising your rights.


(1)  Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. If you believe we hold any other personal information about you, please contact us and complete the corresponding request form.


(2)  Portability

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent or pursuant to our contract with you, as described in the section “How We Use Your Personal Information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party.


If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (e.g., where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).


(3)  Correction

You have the right to correct any personal information held about you that is inaccurate. If you believe we hold any other personal information about you and that information is inaccurate, please contact us and complete the request form.


(4)  Erasure

You can delete your account, or remove certain personal information. If there is any other personal information you believe we process that you would like us to erase, please contact us and complete the request form.

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


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


• you believe the personal information we hold about you is being unlawfully processed by us.

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


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


(5)  Restriction of Processing to Storage Only

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, 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 information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.


You may request we stop processing and just store the personal information we hold about you where:

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

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

• you wish to erase the personal information 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.


(6)  Objection

You have the right to object to our processing of personal information about you. We will consider your request in other circumstances as detailed below by contact us and completing the request form.


(7)  Announcements

We may from time to time send you announcements when we consider it necessary to do so (such as when we temporarily suspend The Service access for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.



8.  Securing Your Data


Pertaining to your use of our services, we have endeavored to take reasonable measures to prevent unauthorized access to or improper use of your personal data, such as organizational controls, technical protection and other protection measures.


 Unfortunately, the transmission of information via the internet is not completely secure. While we strive to protect your personal data, we also remind you to be aware of hacking, cyber-attacks, and other risks on the Internet.


Therefore, we strongly urge you to take every possible precaution to protect your personal data when using our services, including but not limited to changing your passwords from time to time, not reflecting your real name or other personal data in registration, using a combination of letters and numbers when creating passwords, using a secure browser and/or taking other possible security measures. Please note that for security reasons, we store passwords in encrypted form.


Please be aware that advertisers or websites with links to and/or from our websites may collect personal data about you and this Privacy Policy does not apply to, and cannot control the activities of, those other advertisers or websites. We highly recommend that you read the privacy policy of such third-party websites which you may be directed to before providing any personal data.




9.  Age Limits and Children Protection


You represent that you are an adult or older in your country of residence (or at other age in your jurisdiction where you are classified as a majority) when using our services. If you are a minor child or under the legal age of majority (Minoror Children), please do not send any personal data about yourself to us, including your name, address, telephone number, or email address.


Notwithstanding the foregoing, we recognize that we have a special obligation to protect children in regards to the collection and processing of personal data, and we do not and will not knowingly collect personal data from children without consent from their parents or guardians. We strongly urge parents and guardians to instruct their children never to disclose or give out their personal data when using our services without the prior permission of their parent/guardian. If we learn that we have collected personal data about a child, we will delete that data as quickly as possible. Also, if you believe that we might have any data from or about a child, please contact us at our DPOs email.




10. Change


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.




11.  Language


This Agreement may be translated into the local language in the relevant territory. In the event of a conflict between this Agreement in the English language version and the localized version, the English language version shall prevail.




11.  Contact and Complaints


In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance.


--Contact Information--

Name: Shenzhen Huanyinli Network Technology Co., Ltd.

Mail: service@yinligame.com