Privacy Policy
Introduction
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 NetEase Interactive Entertainment Pte. Ltd (“NetEase”, “we” 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.
When you contract to use the Service, you accept our rules and policies regarding your personal
information and you expressly consent to us collecting, processing, using and storing your
personal information, as described in this policy.
You acknowledge that you have read and understood this privacy policy. If you do not agree with
this privacy policy, you must not use the Service. If you change your mind in the future, you may
withdraw your consent to use of your personal information in accordance with this policy.
If you have any comments, questions or complaints regarding the processing of your personal
information, you can contact us at gamegdpr@global.netease.com.
The Types of Personal Information We Use
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:
• Information you give us. You give us information about you:
(i) 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) when you set up your profile for the Service (including information you voluntarily elect to
provide in order to customize gameplay);
(iii) 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
(iv) when you make purchases in the Service (in which case we will process the information you
provide to us to facilitate the payment).
• Information we collect about you. We automatically collect certain data from you when you
use the Service, including your IP address and device information (such as device type, network
data, operating system) and information regarding your use of the Service, such as date and time
stamps of actions. We also collect and store your data each time you interact with us, for
example, when you use in-app support to communicate with us.
• Information you generate and display in the course of using the Service. You may provide
additional information as part of your profile. You may also provide or generate information
when you communicate with other users in the Service (e.g., chat log). You acknowledge and
agree that information generated within our Service should not be considered private and
communications within our Services may be viewed/heard by other users. Please avoid revealing
any personally identifiable or sensitive information during such commutations.
Cookies
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 functionality.
You have the option to permit installation of such Cookies or subsequently disable them. You may
accept all cookies, or instruct the device/web browser 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 of your refusal to install cookies, the Service may be unable to
operate as designed.
Children
Our Service is not intended for children and we do not knowingly collect information from
children. If you believe that we have unintentionally collected your children ’ s personal
information, you may request the deletion of the information by contacting us at
gamegdpr@global.netease.com. In some cases we may ask the user to provide us with their birth
date. If such information indicates the user is under the age stipulated by the applicable laws and
deemed as child under such laws, we will not collect further personal information from the child
until a parent/guardian‘s verifiable consent is obtained.
How We Use Your Personal Information
We will use the information in the following ways and in accordance with the following legal
bases:
• Registration Information (such as: ID on third-party accounts ,email address,nick name, avatar
and other information): We use Registration Information to set-up user accounts, allow users to
log-in to the Service by using the Registration Information and provide Services to users. We use
this information with your consent to this Privacy Policy.
• Device Information (such as: device ID, device type, operating system, CPU, RAM, IP address,
MAC address): We use this information to provide and improve the Service such as: to allow
users to download and install the software on their devices; to record and keep track of requests
from users of the Service; to detect the user network and device status when the user is using
the Service; and to correct bugs or errors that occur when the user is using the Service. Use of
Device Information is necessary to perform our contract with you to provide the Service.
• Contact Information (such as: name, email, address, phone number, instant messaging
account): We use this information to send notifications to users to inform them of our
promotional activities and any rewards they are entitled to. We use this information with your
consent to this Privacy Policy.
• User Profile (such as : age, photo and etc.): We use this information to provide customized
services to users such as personal information page. We use this information with your consent
to this Privacy Policy.
• Game Data (such as: level, heroes, scores, chat logs and etc.): We use this information to
provide Services to users as it is the basis of our Service. Use of Game Data is necessary to
perform our contract with you to provide the Service.
How We Store and Share Your Personal Information
In order to perform our contract with you, your personal information will be accessible from and
will be processed on our servers. Our servers are hosted on cloud servers such as Amazon Web
Services. Your information may be transferred to and processed in countries outside the country
you are located. We will take steps necessary to comply with applicable legal requirements, such
as using European Commission approved Standard Contractual Clauses to protect your
information. In particular, your information will be transferred to and processed in Japan where
our central database is based.
We share your personal information with selected third parties in and outside your country,
including:
• third-party vendors that provide services in support of the Service, such as Amazon Web
Services (“AWS”) for the purpose of hosting the Game, Apple and Google for the purpose of
providing payment services, Helpshift for the purpose of providing customer support, Facebook
and Appsflyer for the purpose of the evaluation of our marketing events. Those third party
vendors have limited access to your personal information and are contractually bound not use it
for other purposes.
• related group companies, with whom we share your information to operate the Services. The
transfers contemplated above are made pursuant to our contract with you; and
• law enforcement agencies, public authorities or other judicial bodies and organizations. We
disclose information if we are legally required to do so, or if we have a good faith belief that such
use is reasonably necessary to: (i) comply with a legal obligation, process or request; (ii) enforce
our terms of service and other agreements, policies, and standards, including investigation of any
potential violation thereof; (iii) detect, prevent or otherwise address security, fraud or technical
issues; or (iv)protect the rights, property or safety of us, our users, a third party or the public as
required or permitted by law (including exchanging information with other companies and
organizations for the purposes of fraud protection).
The Security of Your Personal Information
We are committed to maintaining the privacy and integrity of your personal information no
matter where it is stored. We have information security and access policies that limit access to
our systems and technology. We deploy a firewall and other security measures （ such as
encryption ） commensurate to industry standards to prevent unauthorized access to your
personal information. Your personal information will remain subject to our technical and
organizational controls and our policies and procedures (including this Privacy
Policy).Unfortunately, the transmission of information via the internet is not completely secure.
Although we will do our best to protect your personal information, we cannot guarantee the
security of the information transmitted to our services; any transmission of your information is at
your own risk.
Data Retention
We will retain most of your personal information for the lifetime of your use of the Services (i.e.
until account deletion in accordance with your request) except that Contact Information obtained
from promotional activities will be retained during the lifetime of such activities.
In the event that the processing and retention period have terminated, but personal information
is required to be retained continuously for other reasons including for the purposes as prescribed
under applicable laws, the relevant personal information will be stored and maintained
separately from other types of personal information. If you require us to destroy your personal
information before the end of its life cycle, we will destroy your personal information in
accordance with local laws.
TrueDepth APIs
The avatar room feature in our app provides a mode to drive the avatar's facial expression from
your facial movement in real time. When you grant us camera permissions, our app uses
TrueDepth APIs to render your avatar's facial expressions with your facial expressions. The avatar
room function acquires facial expression data using the TrueDepth API provided by Apple, but
does not use it for any purpose other than operating the avatar, saves the acquired data or sends
it to a third party. The data is used only for the facial expression rendering scenes mentioned
above (for example, if the user uses the avatar room feature, shake their head in front of the
smartphone and the system will collect facial expressions in real time and drive avatar to do the
same movement).
(1) If you refuse to grant the camera permission (AI face recognition), you will not be able to
drive the avatar with your face, but it will not affect the use of other functions. This feature is
turned off by default the first time you use Avatar Room and must be manually turned on to
activate the TrueDepth APIs.
(2) When using TrueDepth APIs, no data cache is generated on the client. It will not be stored in
any format on the database or cloud server or provided to third parties.
(3) If you don't want us to collect facial movements and facial expression information, you can
turn off AI face recognition in the room settings. Once turned off, we will stop collecting data
from you.
Your Rights
This section (“Your Rights”) applies to users that are located in the European Economic Area only.
For California Residents, please refer to https://www.neteasegames.com/privacy/02.html. For
users located in other territories, please refer to the privacy clauses in our User Agreement.
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 gamegdpr@global.netease.com. Please understand further
information may be required to verify your identity when exercising your rights.
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.
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).
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.
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 displaying the personal information or providing
links to the personal information to erase it too.
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.
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.
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.
Contact & Complaints
For the purposes of European Data Protection Law, the Data Controller is NetEase Interactive
Entertainment Pte. Ltd.
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: NetEase Interactive Entertainment Pte. Ltd
Mail: gamegdpr@global.netease.com
Designated EU representative and contact information:
GDPR-Rep.eu
Maetzler Rechtsanwalts GmbH & Co KG
Attorneys at Law
c/o NetEase Interactive Entertainment Pte. Ltd
Schellinggasse 3/10, 1010 Vienna, Austria
Please add the following subject to all correspondence:
GDPR-REP ID: 17942453
This is without prejudice to your right to launch a claim with the data protection authority in the
country in which you live or work where you think we have infringed data protection laws.
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.
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.