Privacy Policy

1. Introduction

Beijing Dongba Culture Media Co., Ltd. ("we," "us," or "our") is committed to protecting your privacy and ensuring the security of your personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use our mobile applications, games, websites, and related services (collectively, the "Services").

By using our Services, you consent to the practices described in this Privacy Policy. If you do not agree with these terms, please do not use our Services.

2. Information We Collect

We collect various types of information to provide and improve our Services:

2.1 Personal Information

• Account Information: When you create an account, we may collect your email address, username, and password.
• Payment Information: For in-app purchases, payment details are processed by third-party payment processors (Apple App Store, Google Play Store) and we do not store your credit card information.
• Contact Information: When you contact us for support, we collect your email address and any other information you provide.

2.2 Non-Personal Information

• Device Information: Model, operating system version, unique device identifiers (IDFA, GAID), IP address, and mobile network information.
• Usage Data: How you interact with our apps, including features used, time spent, game progress, and crash reports.
• Location Data: Approximate location derived from IP address for regional compliance and localization purposes (we do not collect precise GPS location without explicit consent).
• Advertising IDs: Google Advertising ID (GAID) or Apple Identifier for Advertisers (IDFA) for monetization, attribution, and analytics purposes.

3. How We Use Your Information

We use the collected information for the following purposes:

• To provide, maintain, and improve our Services
• To personalize user experience and content recommendations
• To process transactions and send related notifications
• To respond to customer service requests and support needs
• To analyze usage patterns and optimize performance
• To comply with legal obligations and regulatory requirements
• To prevent fraud, security breaches, and illegal activities
• To serve targeted advertisements through third-party advertising partners

4. Information Sharing and Disclosure

We do not sell your personal information to third parties. However, we may share information in the following circumstances:

4.1 Service Providers

We work with trusted third-party service providers who help us operate our business, including:

• Analytics Partners: Google Analytics, Firebase, Mixpanel for usage analysis
• Monetization Platforms: AdMob, AppLovin, Unity Ads, ironSource for advertising
• Cloud Services: AWS, Google Cloud for data storage and processing
• Customer Support: Zendesk, Intercom for support ticket management

4.2 Legal Requirements

We may disclose information if required by law, regulation, legal process, or governmental request, or to protect our rights, property, or safety.

4.3 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the transaction.

5. International Data Transfers

As a global company serving users in over 150 countries, we may transfer your information across international borders. We implement appropriate safeguards to ensure adequate protection of your data, including:

• Standard Contractual Clauses (SCCs) for EU data transfers
• Compliance with local data protection laws in each jurisdiction
• Encryption of data in transit and at rest
• Regular security audits and assessments

6. Compliance with App Store Policies

Our data collection and usage practices comply with the Google Play Developer Program Policy and the Apple App Store Review Guidelines. We only request permissions that are necessary for app functionality and clearly explain their purpose.

We participate in Apple's App Tracking Transparency (ATT) framework and Google's Privacy Sandbox initiatives to respect user privacy choices.

7. Global Privacy Regulations

We respect and comply with international privacy standards:

7.1 GDPR (General Data Protection Regulation - Europe)

• We act as a data controller for personal data processed in the EU
• We provide data access, rectification, erasure, and portability rights
• We maintain records of processing activities
• We conduct Data Protection Impact Assessments (DPIAs) when required
• Our EU representative can be contacted at: support@dongba-bj.com

7.2 CCPA/CPRA (California Consumer Privacy Act/Rights Act)

• We provide notice of data collection practices
• We honor "Do Not Sell or Share My Personal Information" requests
• We do not discriminate against users who exercise their privacy rights
• Our California privacy contact: support@dongba-bj.com

7.3 Other Jurisdictions

We also comply with privacy laws in other jurisdictions where we operate, including Brazil's LGPD, Canada's PIPEDA, and China's Personal Information Protection Law (PIPL).

8. Children's Privacy & Age Management

We take children's privacy seriously and comply with relevant regulations:

• COPPA (Children's Online Privacy Protection Act): We do not knowingly collect personal information from children under 13 without verifiable parental consent.
• GDPR-K (UK Age Appropriate Design Code): We implement age verification mechanisms and default privacy settings for child users.
• Age Gates: We implement age gates in our applications to restrict access to age-inappropriate content.
• Parental Controls: We provide tools for parents to monitor and control their children's app usage.

If we become aware that we have collected personal information from a child without proper consent, we will promptly delete such information.

9. Data Security

We implement industry-standard security measures to protect your information:

• SSL/TLS encryption for data transmission
• Encryption at rest for sensitive data
• Regular security testing and vulnerability assessments
• Access controls and authentication mechanisms
• Employee training on data protection practices
• Incident response procedures for data breaches

However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

10. Your Rights and Choices

Depending on your location, you may have the following rights regarding your personal information:

• Access: Request a copy of the personal information we hold about you
• Correction: Request correction of inaccurate or incomplete information
• Deletion: Request deletion of your personal information
• Restriction: Request restriction of processing in certain circumstances
• Portability: Request transfer of your data to another service provider
• Objection: Object to processing based on legitimate interests
• Withdraw Consent: Withdraw consent where processing is based on consent

To exercise these rights, please contact us at: support@dongba-bj.com

11. Cookies and Tracking Technologies

Our websites and some of our applications use cookies and similar technologies to:

• Remember your preferences and settings
• Analyze website traffic and user behavior
• Deliver personalized advertising
• Improve website functionality and performance

You can manage cookie preferences through your browser settings or device controls.

12. Changes to This Privacy Policy

We may update this Privacy Policy periodically to reflect changes in our practices or legal requirements. We will notify you of material changes by posting the updated policy on our website with a new "Last Updated" date. Your continued use of our Services after such changes constitutes acceptance of the revised policy.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

Email: support@dongba-bj.com

Address: Room 110-4852, Building 1, Xiwengzhuang Town Government, No. 66 Huanhu Road, Miyun District, Beijing, China

Data Protection Officer: dpo@dongba-bj.com