Privacy Policy

  • Privacy Policy

    Last Updated: July 2024

    Huoli HK Limited develops and publishes games for players on web, mobile devices, and other platforms. This Privacy Policy ("this Policy") describes how Huoli ("we," "us," or "our company") collects, stores, uses, discloses, or otherwise processes the personal information of our users ("users" or "you") related to your use of our products or services, including our website at https://www.huoligames.com and Huoli games or any other Huoli products or services linked to this Policy on mobile platforms (each individually referred to as a "Service" and collectively referred to as "Services"). Additionally, this Policy outlines the rights and choices that may apply to your information. Should you have any questions or concerns about this Policy or our collection and use of personal information, please contact us as described in the "Contact Us" section.

    1. Information We Collect The categories of personal information we collect depend on the services you use and the requirements of applicable law.

    2. Information You Provide Directly to Us: When using our services, you may directly provide us with personal information, which we store in our system and process for the purposes described in this Privacy Policy. Depending on the service, the personal information we collect will include, but is not limited to, the following:

    • Contact information (such as name, email address, or phone number)
    • Player name or tag
    • Information you provide when participating in surveys, promotions, contests, and other activities
    • Billing and financial information collected by our third-party payment platform when you purchase virtual currency or items in Huoli games

    3. Information We Collect Automatically:

    • Account and game progress information, including an internally created account ID
    • IP address and mobile device identifiers (such as device or advertising IDs)
    • Device information, such as device name, operating system, browser type and language, internet service provider, and mobile carrier
    • Information collected using cookies and similar technologies (see below)
    • General location information (derived from IP address)
    • Usage information, such as gameplay information, purchase behavior, and interactions with other players in the services

    4. Information We Collect from Our Partners: We also use third-party partners, such as social networking sites, data analytics providers, and advertising networks, to supplement our understanding of you. This includes:

    • Information received from third-party tools linked with services (such as Facebook)
    • Non-identifiable demographic information (such as general location determined by your IP address)
    • Fraud prevention information (such as in-game chargeback abuse or ad click fraud)
    • Information from game operating platforms or payment service providers (such as payment verification information)
    • Information for advertising and analytics purposes (such as surveys)

    5. If you access our services from third-party platforms or link our services to third-party accounts, you should also read the terms of service and privacy policy of that platform.

    6. Advertising Feature Statement

    Currently, our application has not enabled the advertising feature. However, to maintain transparency and comply with privacy requirements when advertisements may be enabled in the future, we have included advertising-related data collection and usage information in our privacy policy.

    7. Why We Collect Your Information We use the information collected through the services for the purposes described in this Policy or in disclosures related to our services. This includes:

    8. Service Delivery:

    • Create your service account and allow access to our services
    • Identify and establish a connection with Huoli
    • Operate and improve our services
    • Understand your preferences to enhance your experience
    • Provide customer service and respond to your comments and questions
    • Provide and deliver the products and services you request
    • Send you relevant information, including confirmations, invoices, technical notices, updates, security alerts, and support messages
    • Conduct and manage surveys, user research projects, contests, and promotional activities you participate in
    • Prevent fraud or potential illegal activities and enforce our terms of use
    • Fulfill any other purposes for which you provide anonymized personal information

    9. Marketing and Advertising:

    • Deliver and target advertisements and marketing messages to you
    • Communicate with you via email and push notifications about promotions, contests, rewards, upcoming events, and other news about products and services offered by us and our selected partners, with your consent

    10. Research and Development:

    • Create aggregated or anonymized information from the personal information we process, which we may use and disclose for research, development, and other legitimate business purposes
    • Link or combine personal information with other information we obtain from third parties in an anonymized manner to help understand your preferences and provide you with better services
    • Analyze anonymized information to select for information related to Huoli surveys and user research projects to gain insights into how users engage with our services, improve our services, consider developing new products or services, and other legitimate purposes

    11. Compliance and Protection:

    • Comply with applicable laws, legal requests, and legal procedures, such as responding to subpoenas or requests from government authorities
    • Protect the rights, privacy, security, or property of us, you, or others (including by investigating, initiating, conducting, or defending legal claims)
    • Audit our internal processes to comply with legal and contractual requirements or our internal policies
    • Enforce the terms and conditions for managing services
    • Prevent, identify, investigate, and deter fraud, harmful, unauthorized, unethical, or illegal activities, including cyberattacks and identity theft, in a manner consistent with applicable laws and regulations

    12. Sharing of Your Information We may share the information we collect for the following purposes:

    13. Service Providers: Shared with service providers who perform services or enhance our services on our behalf, including hosting services, customer service, analytics services, and assisting us in marketing efforts in accordance with applicable data protection laws.

    14. Payment Processors: Shared with third-party payment processors who process payments you make on our platform, in compliance with necessary security and privacy standards.

    15. Advertising Partners: Advertisers, ad exchanges, and other advertising technology companies that require information to select and display relevant advertisements to you and others, and assist us in marketing. These partners typically collect information through their own tools (Software Development Kits or "SDKs"). You will find a list of ad SDKs implemented by our partners in our applications, along with their service privacy policies, which describe their practices and allow you to exercise rights directly with them, provided they comply with applicable data protection regulations.

    16. Our partners' privacy policies may include additional terms and disclosures regarding their information collection and use practices. We encourage you to review these privacy policies to learn more about their information collection and use practices.

    17. Professional Advisors: Shared with lawyers, auditors, bankers, and insurance companies as professional advisors when necessary in the course of professional services, while respecting confidentiality obligations.

    18. Authorities: Shared with law enforcement and public authorities for the purposes of compliance and protection mentioned above, as well as to comply with applicable laws and regulations.

    19. Business Transfers: Shared with acquirers and other relevant participants (and their advisors) in business transactions involving the divestiture, merger, consolidation, acquisition, restructuring, sale, or other disposition of all or any part of our business or assets (or the negotiation or due diligence of such transactions), provided that appropriate confidentiality agreements and legal safeguards are in place.

    20. Designated Recipients: We may disclose personal information to certain other third parties or publicly, upon obtaining their consent or instructions, in accordance with applicable data protection laws.

    21. Security of Your Information We implement reasonable and appropriate technical and organizational measures to protect the security of your personal information and prevent accidental or illegal destruction, loss, alteration, or damage, in accordance with industry standards and applicable data protection laws. However, no security system is impenetrable, and we cannot guarantee the security of your personal information. Any transmission is at your own risk.

    22. Data Retention We retain your personal information as long as necessary to provide the services, unless required by law to delete it or we receive your deletion request in accordance with applicable law. We also retain and use your personal information to comply with our legal obligations, resolve disputes, and enforce our agreements, in accordance with relevant data retention regulations. When we no longer need your personal information, we seek to delete or anonymize it, or, if that is not possible (for example, because your personal information has been stored in backup archives), then we apply security measures to your personal information and isolate it from any further processing until it can be deleted. If we anonymize your personal information (making it no longer associated with you), we may use this information indefinitely without further notice to you.

    23. Children's Privacy To comply with applicable data protection laws, our services are not directed at or intended for children. For this purpose, we use the term "children" to refer to individuals who are: (a) under 13 years of age or (b) between 13 and 18 years of age and below the age at which they can provide lawful consent to the processing of personal information under applicable data privacy laws. Huoli strives to follow the different minimum age guidelines set by regional laws to determine the age at which children can access certain functions of our services. Children may not use these services, and we do not knowingly collect any children's personal information. Although our services are not primarily targeted at children, we may collect age information before allowing users to continue using certain services. For users who identify themselves as children on our age-restricted services, if we allow children to use the services, we will provide a version of the services that does not collect, use, or disclose "personal information" (as defined by the Children's Online Privacy Protection Act ("COPPA")) unless permitted by COPPA or other applicable privacy laws (if applicable), or with the legally valid consent of a parent or guardian in accordance with the relevant regulations. If we become aware that we have unintentionally collected personal information from children not exempted by COPPA or another applicable privacy law, we will take immediate measures to delete such information from our records and implement necessary measures to prevent such occurrences in the future.

    24. Your Rights The following explains your privacy rights, which may vary in scope and applicability depending on the region. For example, they may extend to your household or legal entity, or may be exercised by a legal representative on your behalf. We will comply with applicable privacy laws, including any required response times. Subject to certain exemptions, you have the right to:

    • Request a copy of your personal information (known as "accessing your data").
    • Delete your information. When you request us to delete your personal information, please remember that this right may have legal limitations. For instance, we will retain certain payment records or customer service records that we need to keep, including for legal or accounting purposes. We will also retain information to exercise, protect, defend, or establish our own or third parties' rights.
    • Withdraw your consent at any time directly in the services or by contacting us, where applicable. Withdrawing your consent will not affect the processing that has already taken place before your withdrawal. Similarly, it will not affect the processing of your personal information based on other legitimate grounds.
    • Object to the processing of your personal information, request us to restrict the processing of your personal information, or request the portability of your personal information.
    • Not be subject to decisions based solely on automated processing that have legal effects or similarly significantly affect you.
    • Lodge a complaint with a data protection authority.

    25. For California residents, please also refer to Section 8 for more rights.

    26. Managing Personal Information Received from Third-Party Applications/Platforms and Your Mobile Devices You can manage the personal information we receive from third-party applications or platforms and your mobile devices as follows:

    • To manage the personal information we receive from third-party applications or platforms, such as Facebook, Apple, Google, or Amazon, you can update your privacy settings through the "Settings" menu of the third-party application or platform.
    • For your mobile device, please visit the "Settings" page or web browser on your phone to review the access permissions for each of our services.

    27. Once we receive your information from third-party applications or platforms or your mobile device, we will process it according to this Privacy Policy.

    28. Opting Out of Huoli's Promotional Communications You can opt-out of receiving promotional communications from us at any time by following the unsubscribe instructions provided in the communication or by contacting us directly at info@huoligames.com. Please note that you may continue to receive non-promotional messages from us, such as service-related notifications and account management messages.

    29. Opting Out of Third-Party Behavioral Advertising You can opt-out of third-party behavioral advertising by adjusting your device settings to limit ad tracking, or by visiting the Digital Advertising Alliance's consumer choice page at http://www.aboutads.info/choices or the Network Advertising Initiative's opt-out page at http://www.networkadvertising.org/choices.

    30. California Consumer Specific Provisions These additional provisions for California consumers apply only to individuals residing in California. The California Consumer Privacy Act of 2018 ("CCPA") and the California Privacy Rights Act of 2020 ("CPRA") provide additional rights to know, access, correct, delete, and opt-out, and require "businesses" to provide notice and means to exercise these rights when collecting or disclosing personal information.

    31. Your California Privacy Rights: California residents have the rights listed under the CCPA. However, these rights are not absolute, and in some cases, we may refuse your request by law.

    • Information: You can request information on how we have collected and used your personal information in the past 12 months:

      • The categories of personal information we have collected.

      The categories of sources from which we collected personal information.

      The business or commercial purposes for collecting and/or selling personal information.

      The categories of third parties to whom we have disclosed personal information.

      The categories of personal information we have sold or disclosed for business purposes.

      The categories of third parties to whom we have sold or disclosed personal information for business purposes.

    • Access: You can request a copy of the personal information we have collected about you in the past 12 months.
    • Correction: You can request us to correct any inaccurate, incomplete, or outdated information on your account by providing us with the necessary information to make the correction.
    • Deletion: You can request us to delete the personal information we have collected from you, subject to applicable legal restrictions.
    • Right to Opt-Out of the Sale of Information: You can opt-out of the sale of your personal information, to the extent legally applicable.
    • Non-Discrimination: You have the right to exercise the above rights without discrimination as prohibited by the CCPA.

    32. Right to Opt-Out of the Sale of Information We do not "sell" most of our users' information as it is commonly understood. However, consistent with common practices of online operating companies, we do "share" information, allowing certain third-party advertising networks and other third-party businesses to collect your personal information directly from your browser or device through cookies or tracking technologies when you visit or interact with our website, use our applications, or otherwise interact with us, in compliance with applicable laws and regulations.

    33. How to Exercise Your Rights To exercise your rights to know, access, correct, delete, opt-out of the sale of information, or any other rights you may have under applicable law, please email us at info@huoligames.com. with the subject line "Rights Request," specifying the rights you wish to exercise (e.g., your right to deletion). Before we process your request, we need to verify your identity. To verify your identity, we typically require information from you that matches the information we maintain in our systems, in accordance with applicable law. In some cases, we may refuse to fulfill your request, especially if we cannot verify your identity or find your information in our systems. If we cannot meet all or part of your request, we will explain the reasons for the refusal.

    34. In some cases, you may submit requests through an authorized agent who (i) provides sufficient evidence that the requester is your authorized agent with written permission and (ii) you have successfully verified your identity in accordance with applicable law.

    35. Our goal is to respond to consumer requests within 45 days of receiving them. If we need more time, we will notify you in writing of the reasons and the extended period, in accordance with applicable law.

    36. International Data Transfers Our services have a global nature, and therefore your data can be transferred anywhere in the world. Since different countries may have different data protection laws from your own country, we take measures to ensure that the appropriate safeguards explained in this Privacy Policy are in place. The appropriate safeguards we may use include the Standard Contractual Clauses approved by the European Commission and other legal mechanisms, in compliance with applicable law. Some of the partners and processors mentioned in this Policy are located outside the European Union. In such cases, we ensure that:

    32. Right to Opt-Out of the Sale of Information We do not "sell" most of our users' information as it is commonly understood. However, consistent with common practices of online operating companies, we do "share" information, allowing certain third-party advertising networks and other third-party businesses to collect your personal information directly from your browser or device through cookies or tracking technologies when you visit or interact with our website, use our applications, or otherwise interact with us, in compliance with applicable laws and regulations.

    • Personal data is transferred to countries considered to provide an adequate level of protection, or
    • For the transfer of personal data to countries deemed by the European Commission to have adequate levels of protection, any mechanism providing appropriate safeguards is used, as stipulated by applicable regulations, especially the adoption of the European Commission's Standard Contractual Clauses, in compliance with applicable law.

    37. Changes to This Policy We may update this Policy to reflect changes in our data and information privacy practices. We will notify you of significant changes by posting the new policy on our website and updating the effective date. Your continued use of the services after the effective date will be subject to the updated Privacy Policy, provided that such changes are in compliance with applicable laws and regulations.

    38. Contact Us If you have any questions or concerns about our Privacy Policy, including exercising any rights under applicable law, please contact us at info@huoligames.com.