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 a mobile game (“Game”) distributed by WhalePb (“WhalePB”, “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.
The minimum age to create a WhalePB User Account is 13（in US）/16（in EU.Japan ）/14（ in Korea）. We will not knowingly collect Personal Data from children under this age. Insofar as certain countries apply a higher age of consent for the collection of Personal Data, We requires parental consent before a User Account can be created and Personal Data associated with it collected. We encourages parents to instruct their children to never give out personal information when online.
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 or your guardian again, your personal data may Transfer to the successor of WhalePb. We may periodically modify, adjust or revise the terms of this privacy policy. The updated terms will be announced to you in the form of a pop-up window, and obtaine your consent again. You agree to check the new terms regularly. If major clause changes are involved, we will make an announcement in advance.
1. What Data We Collect and Process
(1) Data We Collect and Process
(i) Contact data (such as email address or telephone number)
(ii) User Account registration or registration for on-line game participation (such as user name ,password, ID）
(iii) in WhalePB Community Forums, chats, or when you provide feedback or other user generated content. (such as Information that you post, comment or follow in any of our Content and Services;Information sent through chat;Information you provide when you request information or support from us or purchase Content and Services from us, including information necessary to process your orders with the relevant payment merchant or, in case of physical goods, shipping providers;Information you provide to us when participating in competitions, contests and tournaments or responding to surveys, e.g. your contact details.)
(iv) Transaction and Payment Data (such as purchase Subscriptions for Content and Services, If you pay by credit card, you need to provide typical credit card information (name, address, credit card number, expiration date and security code)
(ⅴ) other data you choose to give us (such as data about lost account identification, hacking prevention, consumer services, service maintenance, technical support and surveys, including but not limited to your age, gender, general hobbies and interests, game play interests and habits, browser and device information, data collected through automated electronic interactions and application usage data. and/or other game-related preferences)
(2) Data we collect automatically
(i) Data about your account, game progressions and any use of WhalePB Game(s)
(ii) Internet Protocol (“IP”) address
(iii) Data about your device, such as your device ID, device name, device type, operating system, advertising ID, MAC address, IMEI, CPU, language and the type of browser
(iv) Cookies and similar technologies (see more as below)
(v) General location data
(3) Data we get from our contractors
(i) Data we receive if you link Third-party applications with the WhalePB Services (such as access our services through Facebook, Twitter, Game Center, Google Play or Apple )
(ii) Data to fight cheating (such as refund abuse)
(iii) Data from payment methods that help the WhalePB Game(s) run on (such as to verify and confirm payment)
(iv) Data for advertising and analytics purposes so that we can provide you better services(We ensure that we will not use your data for user profile, and if you are a 13 (or 14 /16) registered user, we will not push ads for you)
Please note that 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 the WhalePB Services.
When you use or interact with SDK that may be available on our services for users, such as third-party social media widgets, share buttons, and/or login mechanisms, these features may include social SDK from Google, Facebook, Twitter or other platforms (if any) and please note it should be subject to their respective privacy policies.
Unless got your Expressly agreement, we will not collect Personally identifiable information(PII) nor sensitive personal information(SPI), such as TURE name, Address, Telephone number, Fax number, and E-mail address. You confirm that if you elect to submit any personal data, your submission is subject to this Privacy Policy and you consent to all the terms therein. Please note that any personal data submitted in Business transaction would not be subject to this Privacy Policy, including but not limited ：job opening, Participate in activities, Business signing.
(4)Cookies
In order to measure the effectiveness of our services, some pages on our websites may use cookies, which are small text files for added functionality or for tracking site usage. We may use cookies and/or authorize third party’s tracking-utility, from time to time, (a) to log your IP address in determining the path that users take on our sites and identifying repeat 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:
(i) remembering you: cookies, web beacons and similar technologies can help us identify you as a registered user or keep the preferences or data that you have previously provided;
(ii) analyzing how you use our services: we can use cookies, web beacons and similar technologies to understand what visitors (including users) are doing on our services, or what pages or sections are most popular;
(iii) serving 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 your provided data; and/or
(iv) other related functions or purposes mentioned in Section 2.
Our authorized contractors or we may use cookies and similar technologies to provide and personalize the services, prevent fraud and for other purpose mentioned above. Please note you can disable cookies in your browser settings, while some parts of the WhalePB Services may then not function properly.
2. Why Do We Collect Your Personal Data
To create a WhalePB ID for user when you use the WhalePB Services and for the purpose to provide great services to you, we collect and process the data to:
(i) Allow you to access or restrict your access to the WhalePB Services;
(ii) Analyze and management WhalePB Services for system administration, user service, security, fraud-detection, check the authenticity of an account owner, archival and/or backup purposes;
(iii) Correct bugs or errors, improve our services and respond to customer desires and preferences, including language and location customization, personalized help and instructions, and other responses;
(iv) Develop new services or products you request and improve the user experience;
(v) Verify and confirm payment;
(vi) Provide you offers on or through the WhalePB Services and deliver advertising that may be relevant to your interests, such as offer you to participate in our surveys or activities;
(vii) Communicate with other users and take action against misbehaving users;
(viii) personalize your experience, keep you up to date on the latest product announcements, provide software verification, upgrades and administration, notify special events and offer other data pertaining to our services; and/or
(ix) protect the integrity, safety, and security of our services or our users, comply with legal obligations, and enforce compliance with the Terms of Service or other restrictions placed on your use of the WhalePB Services.
(ⅹ) 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 terms and conditions hereunder. Affiliate in this Privacy Policy shall mean an entity that directly or indirectly controls, is controlled by or is under common control with WhalePB 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 to users).
3. Advertisements and Your Choices
For the purpose of providing personalized advertisements, you acknowledge and confirm that we may collect and process the data to:
(i) improve advertising and other marketing and promotional activities; and/or
(ii) deliver, target and improve our advertising.
We may also use your data to send you, or have our authorized contractors send you, direct marketing data or contact you for our market research. If you do not wish to receive marketing or advertising materials from us or any of our contractors, please do not provide your contact data via the Internet and you may directly require such contractors to remove your data from the contact list.
(We ensure that we will not use your data for user profile, and if you are a 13 (or 14) registered user, we will not push ads for you)
4. Who May Access Your Personal Data
In addition to WhalePB 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 Users
Other users may, for example in a group challenge, see your in-game activities in group challenge. Other users may also see your display data and read the messages you have posted on or through the WhalePB Services. You confirm that the WhalePB Services may also include message boards, communities, forums, and/or other chat areas, where users may exchange ideas or communicate with other users and you acknowledge that any data you posted to any communication area is publicly viewable. We strongly recommend that all users avoid posting personal or sensitive data at any time.
(2) Competent Authorities
We may provide 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 agreements between us, such as the Terms of Service and this Privacy Policy or otherwise damage us; (b) you are infringing third parties’ rights 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
WhalePB works with a number of (if any) social media contractors, advertising serving contractors, analyzing contractors, payment contractors, fraud-detection contractors and other third-party contractors on or through our services. We do not sell your personal data and only share non-personally identifiable, aggregated, and public data with third parties.
Besides, such contractors may use cookies, web beacons, and/or other tracking technologies to collect or receive data about you and might claim controller rights over your personal data. For example, users purchasing products or services will be required to provide additional data to third party payment contractors, such as a valid credit card number, expiration date. Such third-party payment contractors may collect, process, 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.
Please be aware that we cannot control the activities of such third parties, and we cannot guarantee that they adhere to the same privacy policy as we do. Since those contractors may access your data as data controller and operate under their own privacy policies, we strongly encourage you to check their privacy policies on their official websites and learn more about their data processing practices.
https://www.facebook.com/legal/FB_Work_Privacy
https://www.iubenda.com/blog/privacy-policy-admob/
https://www.mintegral.com/en/privacy/
https://unity3d.com/legal/privacy-policy
https://www.tapjoy.com/legal/players/privacy-policy/
https://www.adcolony.com/privacy-policy/
https://www.criteo.com/privacy/
https://www.inmobi.com/privacy-policy/
https://support.google.com/admob/answer/7665968
https://support.google.com/dfp_premium/answer/9012903
https://www.applovin.com/privacy/
https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
http://en.happyelements.com/site/privacy/
5. Data Retention
We will keep your data for as long as your account is active or as needed to provide you the WhalePB Services unless deletion in accordance with your request.
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 us. Please note that the remove or deletion 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 — for the storage and retention period required by law. After that your Personal Data will be deleted, blocked or anonymized, as provided by applicable law.
6.Security of Your Personal Information
We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. Our group companies have information security and access policies that limit access to our systems and technology. We also protect data through the use of technological protection measures such as encryption. Your personal information will remain subject to our technical and organisational controls and our policies and procedures (including this Privacy Policy).
Unfortunately, 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 such transmission of your information is at your own risk. We rely on you to select secure passwords, to protect those passwords, and to use appropriate security software on you devices.
7.Your Rights
If you request in writing, we will provide you a copy of your personal data in an electronic format after passing our review process. You also have the right to correct or modify your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data.
Pertaining to the marketing or promotional communications, you may opt-out of receiving such communications in accordance with the instructions therein, such as email provided to us. You can make a request for the rights below, but only once within 12 months (California resident).
7.1 Right of Access.
You have the right to access your Personal Data that we hold about you, i.e. the right to require free of charge (i) information whether your Personal Data is retained, (ii) access to and/or (iii) duplicates of the Personal Data retained. You can use the right to access to your Personal Data through the Privacy Dashboard. If the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request.
7.2 Right to Rectification.
If we process your Personal Data, we shall endeavor to ensure by implementing suitable measures that your Personal Data is accurate and up-to-date for the purposes for which it was collected. If your Personal Data is inaccurate or incomplete, you can change the information you provided via the Privacy Dashboard.
7.3. Right to Erasure.
You have the right to obtain deletion of Personal Data concerning you if the reason why we could collect it (see section 2. above) does not exist anymore or if there is another legal ground for its deletion.
As a result of deleting your WhalePB User Account, you will lose access to WhalePB services, including the WhalePB User Account, Subscriptions and game-related information linked to the WhalePB User Account and the possibility to access other services you are using the WhalePB User Account for.
7.4 Right to Object
When our processing of your Personal Data is based on legitimate interests according this Privacy Policy, you have the right to object to this processing. If you object we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing as described in Article 21 of the GDPR; in particular if the data is necessary for the establishment, exercise or defense of legal claims. You also have the right to lodge a complaint at a supervisory authority.
7.5 Right to restriction of processing of your Personal Data
You have the right to obtain restriction of processing of your Personal Data under the conditions set out in article 18 of the GDPR.
7.6 Right to Personal Data portability
You have the right to receive your Personal Data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller under the conditions set out in article 20 of the GDPR. WhalePB makes your Personal Data available in structured HTML format through the Privacy Dashboard as described above.
To exercise any of these rights, please contact us at [email protected]. We will respond to such requests without undue delay and generally within one month (this may be extended by two further months in certain circumstances). We may ask that you provide further information or complete a form in connection with a request. We will work with third parties to which we have transferred your personal information as appropriate to fulfill your request. We may not be able to fulfill requests that would interfere with rights of others (e.g., where providing personal information would reveal information about another person) or our rights (e.g. where we have an independent basis for processing, or the information includes our trade secrets or intellectual property).
8.Contact and Complaints
WhalePb Limited is the data controller under this Privacy Policy, and its address is UNIT 417,4/F LIPPO CTR TOWER TWO NO 89 QUEENSWAY ADMIRALTY HONG KONG . If you have questions or wish to make a complaint about how we process your personal information, please contact our Data Protection Officer at [email protected] and we will endeavor to deal with your request as soon as possible. You may also have the right to complain to data protection authorities in the country in which you live or work.
Changes
If we make any material changes to this policy, we will post the updated policy here and notify our users.
Effective Date：2020/06/25