User Privacy Policy

Publication Date: September 30, 2021

Last Updated: August 10, 2024

This policy applies to the game products or services (hereinafter referred to as "Xinyou Liangpin Games") provided by Chengdu Xinyou Liangpin Technology Co., Ltd. and/or its affiliated companies (hereinafter referred to as "Xinyou Liangpin" or "we") through third-party channels recognized by Xinyou Liangpin. Users of Xinyou Liangpin Games (hereinafter referred to as "users" or "you") must carefully read this policy before registering and using our game services. Any minors participating in online activities should obtain prior consent from their parents or legal guardians. We will protect minors' relevant information and enforce relevant restrictions in accordance with applicable laws and regulations. If you are a child user under the age of 14, your guardian must read this privacy policy and the "Children's Personal Information Protection Rules," which are part of this privacy policy, and confirm their consent before you can use our services.
If you have any questions, opinions, or suggestions, please contact us through the following:
Email: luotingkeji@163.com

This policy will help you understand the following:

1. How we collect and use your personal information

2. How we use cookies or similar technologies

3. How we share, transfer, and publicly disclose your information

4. How we protect your personal information

5. Your rights

6. How we handle children's personal information

7. Protection of minors

8. Storage of personal information

9. How this policy is updated

10. How to contact us

11. Information collection and usage instructions for third-party SDKs

We fully understand the importance of personal information to you and are committed to maintaining your trust. We adhere to the principles of responsibility consistency, clear purpose, choice and consent, minimum necessity, security assurance, subject participation, and transparency. We also commit to protecting your personal information in accordance with established industry security standards and taking appropriate security measures.
Please carefully read and understand this policy before using our products or services.

 

Ⅰ. How We Collect and Use Your Personal Information
When you use our products and/or services, we collect and use your personal information in the following two ways:
1. To provide you with the essential functions of online gaming services, you must authorize us to collect and use necessary information. If you refuse to provide the required information, you will not be able to use our products and/or services normally.
2. To provide you with extended features of our products and/or services, you can choose to authorize us to collect and use additional information. If you refuse to provide this information, you may not be able to use certain extended features or achieve the intended functionality, but this will not affect your ability to use the basic functions of our products and/or services.
(a) We collect and obtain your personal information through the following channels:
1. Information you voluntarily provide. For example:
(1) The information you provide when registering a Xinyou Liangpin game account or using Xinyou Liangpin game services.
(2) Information you share with others through Xinyou Liangpin games and the information you store while using Xinyou Liangpin games.
2. Information about you legally shared by third parties, meaning information provided by others when using Xinyou Liangpin services.
3. Personal information generated when you use Xinyou Liangpin games.
(b) We collect and use the following types of personal information for basic business functions:
1. Game Registration and Login
(1) When you use the account registration feature, we collect personal identification information you voluntarily provide, including: mobile number or email address, verification code results, and password creation. Your password is automatically stored, transmitted, and verified in an encrypted format; we do not store, transmit, or verify your password in plaintext. You should carefully assess your physical and electronic environment to prevent password leaks. We collect this information to complete the registration process, provide you with a stable service, and protect your account security. Please be aware that your mobile number and verification code results are considered sensitive personal information. We collect this data to comply with legal requirements. If you refuse to provide this information, you may not be able to use this feature, so please consider carefully before providing it.
Some of our products/channels allow you to log in using third-party platform accounts (e.g., QQ/WeChat/Weibo/Baidu). If you log in using a third-party platform account, we will obtain related information (including nickname, avatar, and authentication information) based on your authorization. We collect this information to provide login services and ensure account security. If you refuse to authorize this information, you will not be able to log in using third-party accounts, but this will not affect your access to other products and services.
(2) Depending on different distribution channels, you may use different user registration and login systems. The personal information you provide to the distribution channel and the collection, usage, and protection principles of your data are subject to the privacy policy of that distribution channel. Please read their policy carefully.
2. Real-Name Authentication
According to Chinese laws and regulations, online game users must undergo real-name authentication. When you complete real-name authentication, we will collect your real name and ID number and determine whether you need to enter the anti-addiction system based on your age. If you refuse to provide this information, you will be treated as a guest user. Guest users have limited playtime, cannot make in-game purchases, and cannot access services requiring real-name authentication. Per anti-addiction system regulations, guest mode allows one hour of gameplay. After that, the user will be forced offline and unable to re-enter the game on the same device for 15 days.
When using Xinyou Liangpin games, we may collect personal device information, including phone status, network status, hardware model, MAC address, wireless network name (SSID), SIM card information, device serial number, running processes, OS type and version, software installation list, device sensors, and unique identifiers (IMSI/IMEI/android ID/IDFA/OPENUDID/GUID/IDFV/OAID/CAID/MEID/Device ID/ICCID). To collect this basic device information, we will request device access permissions. We use this data to verify your identity and provide basic services. If you refuse access, you may not be able to use certain services.
(3) We collect and use the following types of personal information to provide you with additional business functions:
1. Consumption and Transactions
When you use the consumption and transaction services of Xinyou Liangpin games, we collect and aggregate your top-up records, in-game virtual currency, game balance, game type, and game record information.
Regarding your consumption and transactions related to virtual assets in the game, we retain your consumption and transaction records and do our best to protect the security of your virtual assets.
2. Providing Prizes or Other Mailing Services
For certain service items, in order to provide you with physical prizes or other mailing services, you need to provide recipient information, including name, shipping address, postal code, recipient, and contact phone number. If you refuse to provide this information, we will not be able to complete the prize distribution or mailing service.
3. Customer Service
(1) We need to collect your mobile phone number or email address to send you service-related notifications when necessary (such as suspensions or maintenance) to help you stay informed about our service status. Additionally, we may occasionally send you marketing information regarding our self-operated or agency game products via SMS or email. If you do not wish to receive such messages, you can unsubscribe via the method provided in the marketing message.
(2) When you contact us, we will retain your communication/call records, any files you provide containing your other personal information (such as bank statements, game screenshots), and the contact details you leave so that we can reach you or assist in resolving your issues.
4. User Surveys
We may invite you to participate in surveys regarding Xinyou Liangpin game products to help us improve existing games and services or design new ones. You can choose to participate voluntarily and provide personal information as requested, including but not limited to age, gender, contact address, occupation, and educational background.
5. Providing Security Protection
To ensure the normal use of our services, maintain the proper functioning of basic game features, optimize game performance, enhance your gaming experience, and protect your account security, as well as combat behaviors that disrupt the fairness of the game or interfere with normal game services, we will collect your device information or personal behavior information when using our services, including:
(1) Software and hardware information of your device, as well as information you allow us to receive through enabled device settings, such as device model, operating system version, device identifiers (such as IDFA or IDFV), software version number, and browser type.
(2) Device connection and network status information, such as the language used or IP address.
(3) Service log information. We record the time you use our product, your last usage time, the content you view and stay on within our product, game progress, and game crash logs to optimize our products and services.
(3) We collect and use the following types of personal information to provide you with additional business functions:
1. Consumption and Transactions
When you use the consumption and transaction services of Xinyou Liangpin games, we collect and aggregate your top-up records, in-game virtual currency, game balance, game type, and game record information.
Regarding your consumption and transactions related to virtual assets in the game, we retain your consumption and transaction records and do our best to protect the security of your virtual assets.
2. Providing Prizes or Other Mailing Services
For certain service items, in order to provide you with physical prizes or other mailing services, you need to provide recipient information, including name, shipping address, postal code, recipient, and contact phone number. If you refuse to provide this information, we will not be able to complete the prize distribution or mailing service.
3. Customer Service
(1) We need to collect your mobile phone number or email address to send you service-related notifications when necessary (such as suspensions or maintenance) to help you stay informed about our service status. Additionally, we may occasionally send you marketing information regarding our self-operated or agency game products via SMS or email. If you do not wish to receive such messages, you can unsubscribe via the method provided in the marketing message.
(2) When you contact us, we will retain your communication/call records, any files you provide containing your other personal information (such as bank statements, game screenshots), and the contact details you leave so that we can reach you or assist in resolving your issues.
4. User Surveys
We may invite you to participate in surveys regarding Xinyou Liangpin game products to help us improve existing games and services or design new ones. You can choose to participate voluntarily and provide personal information as requested, including but not limited to age, gender, contact address, occupation, and educational background.
5. Providing Security Protection
To ensure the normal use of our services, maintain the proper functioning of basic game features, optimize game performance, enhance your gaming experience, and protect your account security, as well as combat behaviors that disrupt the fairness of the game or interfere with normal game services, we will collect your device information or personal behavior information when using our services, including:
(1) Software and hardware information of your device, as well as information you allow us to receive through enabled device settings, such as device model, operating system version, device identifiers (such as IDFA or IDFV), software version number, and browser type.
(2) Device connection and network status information, such as the language used or IP address.
(3) Service log information. We record the time you use our product, your last usage time, the content you view and stay on within our product, game progress, and game crash logs to optimize our products and services.

(4) Device Permissions
During the provision of game services, we may require you to enable certain device access permissions, including:
1. Storage Permission
To store necessary application configuration files and downloaded content or to read content you need to upload and sync, we require access to your storage. On iOS devices, this permission is referred to as "Photo Access."
2. Location Permission
Certain services require access to your location information to display your current region or provide relevant local services. You may choose to disable this permission. Additionally, if you need to use the "Find Device" service, this permission is necessary.
3. Phone (Device Information) Permission
To obtain your device identifier for account login, synchronization, and backup, we require access to your phone (device information). Disabling this permission may affect your account security.
4. Phone (Call) Permission
To facilitate device location services, this permission allows you to call the phone number displayed on the "Find Device" interface. You may disable this permission at any time without affecting other functions.
5. SMS Permission
For registration and login services, SMS verification codes are required to verify your identity. Granting this permission allows automatic code filling, though you may also enter the code manually.
6. Contacts Permission
For quick login functionality, we may access contact information on your device to autofill phone numbers. You may also enter the number manually.
7. Camera Permission
Certain services require camera access for scanning QR codes, taking photos, etc. You may enable or disable this permission. If you need to back up camera settings, this permission is also required.
8. Calendar Permission
If you need to back up or sync calendar data, this permission is required.
9. Call Log Permission
When contacting us, we may store information such as your account, phone number, address, email, IP address, communication/call logs, and other contact details to assist with inquiries or record issue resolutions.
10. Software List Permission
To ensure proper game operation and detect anti-cheat mechanisms, we require access to your installed software list.
11. Microphone Permission
If you wish to interact with other players via images, voice, or video, upon your authorization, the game may access your photos, storage files, microphone, and camera to provide screenshot saving, image uploads, and voice chat features.
12. Sensor Permission
To adapt to your device status, we may access gravity and acceleration sensors to determine screen orientation.
As our features and services continuously evolve, if any function or service not mentioned above requires collecting your information, we will provide explanations via prompts or interactions and seek your consent.
Due to differences in services provided across devices and platforms, we may not utilize all permissions on your device. For example, on iOS devices, we do not access phone permissions, calendar permissions, call logs, etc. The actual permissions required will depend on the specific game product.
Enabling these permissions authorizes us to collect and use the corresponding information to provide related functionalities. You may revoke permissions via device settings, in which case we will be unable to provide the corresponding features.
(3) We collect and use the following types of personal information to provide you with additional business functions:
1. Consumption and Transactions
When you use the consumption and transaction services of Xinyou Liangpin games, we collect and aggregate your top-up records, in-game virtual currency, game balance, game type, and game record information.
Regarding your consumption and transactions related to virtual assets in the game, we retain your consumption and transaction records and do our best to protect the security of your virtual assets.
2. Providing Prizes or Other Mailing Services
For certain service items, in order to provide you with physical prizes or other mailing services, you need to provide recipient information, including name, shipping address, postal code, recipient, and contact phone number. If you refuse to provide this information, we will not be able to complete the prize distribution or mailing service.
3. Customer Service
(1) We need to collect your mobile phone number or email address to send you service-related notifications when necessary (such as suspensions or maintenance) to help you stay informed about our service status. Additionally, we may occasionally send you marketing information regarding our self-operated or agency game products via SMS or email. If you do not wish to receive such messages, you can unsubscribe via the method provided in the marketing message.
(2) When you contact us, we will retain your communication/call records, any files you provide containing your other personal information (such as bank statements, game screenshots), and the contact details you leave so that we can reach you or assist in resolving your issues.
4. User Surveys
We may invite you to participate in surveys regarding Xinyou Liangpin game products to help us improve existing games and services or design new ones. You can choose to participate voluntarily and provide personal information as requested, including but not limited to age, gender, contact address, occupation, and educational background.
5. Providing Security Protection
To ensure the normal use of our services, maintain the proper functioning of basic game features, optimize game performance, enhance your gaming experience, and protect your account security, as well as combat behaviors that disrupt the fairness of the game or interfere with normal game services, we will collect your device information or personal behavior information when using our services, including:
(1) Software and hardware information of your device, as well as information you allow us to receive through enabled device settings, such as device model, operating system version, device identifiers (such as IDFA or IDFV), software version number, and browser type.
(2) Device connection and network status information, such as the language used or IP address.
(3) Service log information. We record the time you use our product, your last usage time, the content you view and stay on within our product, game progress, and game crash logs to optimize our products and services.

(4) Device Permissions
During the provision of game services, we may require you to enable certain device access permissions, including:
1. Storage Permission
To store necessary application configuration files and downloaded content or to read content you need to upload and sync, we require access to your storage. On iOS devices, this permission is referred to as "Photo Access."
2. Location Permission
Certain services require access to your location information to display your current region or provide relevant local services. You may choose to disable this permission. Additionally, if you need to use the "Find Device" service, this permission is necessary.
3. Phone (Device Information) Permission
To obtain your device identifier for account login, synchronization, and backup, we require access to your phone (device information). Disabling this permission may affect your account security.
4. Phone (Call) Permission
To facilitate device location services, this permission allows you to call the phone number displayed on the "Find Device" interface. You may disable this permission at any time without affecting other functions.
5. SMS Permission
For registration and login services, SMS verification codes are required to verify your identity. Granting this permission allows automatic code filling, though you may also enter the code manually.
6. Contacts Permission
For quick login functionality, we may access contact information on your device to autofill phone numbers. You may also enter the number manually.
7. Camera Permission
Certain services require camera access for scanning QR codes, taking photos, etc. You may enable or disable this permission. If you need to back up camera settings, this permission is also required.
8. Calendar Permission
If you need to back up or sync calendar data, this permission is required.
9. Call Log Permission
When contacting us, we may store information such as your account, phone number, address, email, IP address, communication/call logs, and other contact details to assist with inquiries or record issue resolutions.
10. Software List Permission
To ensure proper game operation and detect anti-cheat mechanisms, we require access to your installed software list.
11. Microphone Permission
If you wish to interact with other players via images, voice, or video, upon your authorization, the game may access your photos, storage files, microphone, and camera to provide screenshot saving, image uploads, and voice chat features.
12. Sensor Permission

 

II. How We Use Cookies or Similar Technologies
1. Cookies and Logs
We may obtain and use your information through cookies and store this information as log data.
Using cookies allows us to provide users with a better online experience. We use cookies to benefit users. For example, cookies can make the login process faster when using Xinyou Liangpin games, help us identify the pages and content you are connected to, enable us to serve you better and faster, and enrich your experience during gameplay.
You can control whether your device accepts cookies. Please refer to the documentation provided with your device for more information on this.
2. We Use Cookies for the Following Purposes
(1) Remembering your identity. Cookies help us recognize you as a registered user or save other information you provide to us.
(2) Analyzing your use of our services. We may use cookies to understand which activities or services you prefer when using Xinyou Liangpin game products.
(3) The non-personally identifiable information collected through cookies for the above purposes may be provided to other partners to analyze how you and other users use Xinyou Liangpin game services.
Our products or services may place cookies, which may collect non-personally identifiable information related to you for analyzing how users use our products and services. You can control cookies through user selection mechanisms or user management. If you disable cookies, we may not be able to provide you with the best service, and some services may not function properly.

 

III. How We Share, Transfer, and Publicly Disclose Your Information
1. Sharing
Except for the following circumstances, we will not share your personal information with any company, organization, or individual outside of Xinyou Liangpin without your consent. However, the following exceptions apply:
(1) To provide you with services, we may share your information with partners or third parties, such as institutions providing login services, payment services, advertising services, statistical analysis services, third-party logistics services, and platform services. For personal information collected through SDKs, including the purpose, required device permissions, and the data security protection capabilities of the receiving party, please refer to the "SDK Provider Personal Information List."
(2) Necessary sharing with affiliates. To facilitate our provision of consistent services based on a unified account system and to enable you to manage your account uniformly and ensure system and account security, your personal information may be shared between us and our affiliates as necessary.
(3) To achieve the purposes described in Section I of this policy, "How We Collect and Use Your Personal Information."
(4) To fulfill our obligations and exercise our rights under this policy or other agreements we have with you.
(5) To share with third parties, such as partners who entrust us with promotion, but we will only provide them with information on the reach and effectiveness of the promotion, not information that can identify you, such as your name, phone number, or email address; or we will aggregate the information so that it does not identify you personally.
(6) Within the scope permitted by laws and regulations, to comply with the law, protect the interests, property, or safety of us, our affiliates, partners, you, or other Xinyou Liangpin game users or the public from harm, such as to prevent illegal activities like fraud and reduce credit risks, we may exchange information with other companies or organizations. However, this does not include selling, renting, sharing, or otherwise disclosing information for profit in violation of the commitments made in this policy.
(7) In response to your legitimate needs or with your authorized consent.
(8) In response to the legitimate requests of your guardian (if applicable).
(9) As provided in individual service agreements signed with you (including electronically signed agreements and corresponding platform rules) or other legal documents.
(10) For academic research purposes.
(11) For social public interests in compliance with laws and regulations.
We will only share your information for lawful, legitimate, necessary, specific, and explicit purposes. For companies, organizations, and individuals with whom we share information, we will sign strict confidentiality agreements requiring them to process the information in accordance with our instructions, this policy, and any other relevant confidentiality and security measures.
2. Transfer
We will not transfer your personal information to any company, organization, or individual, except in the following cases:
(1) Transfer with explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties.
(2) In the event of a merger, acquisition, or bankruptcy liquidation, if personal information is involved in the transfer, we will require the new holder of your personal information to continue to be bound by this policy; otherwise, we will require the company or organization to re-obtain your authorization and consent.
3. Public Disclosure
We will only publicly disclose your personal information under the following circumstances and with industry-standard security measures in place:
(1) With your explicit consent, we will disclose the information you specify based on your request.
(2) When required by laws, regulations, mandatory administrative enforcement, or judicial requirements, we may disclose your information in accordance with the type of information and the method of disclosure requested. In compliance with laws and regulations, when we receive such requests for disclosure, we will require the receiving party to provide corresponding legal documents, such as a subpoena or investigation letter.
4. Exceptions to Prior Authorization for Sharing, Transfer, and Public Disclosure
In the following circumstances, sharing, transferring, or disclosing your information does not require prior authorization or consent:
(1) Related to the fulfillment of legal obligations by the personal information controller.
(2) Directly related to national security or defense security.
(3) Directly related to public safety, public health, or significant public interests.
(4) Directly related to criminal investigation, prosecution, trial, and execution of judgments.
(5) To protect the life, property, or other significant legitimate rights and interests of you or others, where it is difficult to obtain the individual's consent.
(6) Information you have voluntarily disclosed to the public.
(7) Information collected from legally publicly disclosed sources, such as legitimate news reports or government information disclosure channels.
According to legal provisions, sharing, transferring, or disclosing de-identified personal information, ensuring that the data recipient cannot restore and re-identify the information subject, does not constitute external sharing, transfer, or public disclosure of personal information. The storage and processing of such data will not require separate notification or consent from you.

 

IV. How We Protect Your Personal Information
1. We have adopted industry-standard security measures to protect the personal information you provide, preventing unauthorized access, disclosure, use, modification, damage, or loss. We will take all reasonably feasible measures to protect your personal information. For example:
(1) Establishing reasonable institutional norms and security technologies to prevent unauthorized access, use, or modification of your information and to avoid data damage or loss.
(2) Using various encryption technologies, such as SSL and TLS, to protect your information.
(3) Implementing isolation techniques.
(4) When using information, such as displaying or associating information, we employ multiple data anonymization techniques to enhance security. We use strict data access controls and multi-factor authentication to protect information and prevent misuse.
2. Our Data Security Capabilities:
(1) Managing and regulating the storage and use of information through data classification and grading systems, data security management standards, and data security development standards.
(2) Implementing comprehensive security controls through confidentiality agreements for information handlers, monitoring, and audit mechanisms.
(3) Enhancing security awareness. We also conduct security and privacy protection training courses to strengthen employees' understanding of the importance of information protection. Only necessary personnel are allowed to access your personal information, and they are prohibited from recording or saving it. We have established strict access controls and monitoring mechanisms. We also require all personnel who may come into contact with your information to fulfill corresponding confidentiality obligations. Failure to fulfill these obligations will result in legal liability.
3. We will take all reasonably feasible measures to ensure that no irrelevant personal information is collected. We will only retain your personal information for the period necessary to achieve the purposes stated in this policy, unless an extension is required or permitted by law.
4. The internet environment is not 100% secure. We will do our best to ensure the security of any information you send to us. If our physical, technical, or administrative safeguards are breached, resulting in unauthorized access, disclosure, alteration, or destruction of your information, and causing harm to your legitimate rights and interests, we will bear corresponding legal liability.
5. In the unfortunate event of a personal information security incident, we will promptly notify you in accordance with legal requirements: the basic situation of the incident and its potential impact, the measures we have taken or will take, suggestions for self-protection and risk reduction, and remedies for you. We will inform you of the incident via email, letter, phone, push notification, etc. If it is difficult to notify each individual, we will issue a public notice in a reasonable and effective manner.
At the same time, we will proactively report the handling of personal information security incidents to regulatory authorities as required.

 

V. Your Rights
In accordance with relevant Chinese laws, regulations, and standards, and referencing common practices in other countries and regions, we will strive to ensure that you can exercise the following rights regarding your personal information:
1. Access Your Personal Information.
You can query some of your personal information at any time through the user center in the game application and the in-game character interface. For information not displayed in the page design, you can contact us using the contact information provided in Part X, and we will respond to your access request within fifteen working days.
2. Correct Your Personal Information.
You can correct and modify some of your personal information through the information query interface. If you find errors in the personal information we process about you, you can contact us at any time using the contact information provided in Part X, and we will respond to your correction request within fifteen working days.
3. Delete Your Personal Information.
In the following circumstances, you can contact us at any time using the contact information provided in Part X to request the deletion of your personal information:
(1) If our processing of personal information violates laws and regulations.
(2) If we collect or use your personal information without your consent.
(3) If our processing of personal information violates our agreement with you.
(4) If you no longer use our products or services, or if you deactivate your account.
(5) If we no longer provide you with products or services.
If we decide to respond to your deletion request, we will also notify the entities that obtained your personal information from us to delete it promptly, unless otherwise required by law or if these entities have obtained your independent authorization.
When you delete information from our services, we may not immediately delete the corresponding information from our backup systems, but we will delete it when the backup is updated.
4. Change the Scope of Your Authorization.
For the collection and use of additional personal information, you can grant or withdraw your authorization at any time. You can change the scope of authorization by adjusting access permissions for the camera, microphone, contacts, etc., in your mobile device settings, changing browser settings, adjusting product settings, or notifying us using the contact information provided in Part X. When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw consent will not affect the processing of personal information previously conducted based on your authorization.
5. Account Deactivation by the Information Subject
You can request to deactivate your account at any time using the contact information provided in Part X. After deactivation, we will stop providing you with products or services and, upon your request, delete your personal information or anonymize it, unless otherwise required by law.
Please note that if you have obligations to fulfill at the time of deactivation, and within the scope permitted by law, your deactivation request may not be immediately supported. Once your deactivation is confirmed, account information, personal identification information, transaction records, etc., will be irrecoverable or unavailable; however, you will still be responsible for your actions prior to deactivation while using our platform services.
6. Obtain a Copy of Your Personal Information
You have the right to obtain a copy of the personal information we have collected about you, within the scope supported by mainland China's laws and regulations. You can contact us using the contact information provided in Part X to request a copy of the above information.
If technically feasible, such as through matching data interfaces, we can also transmit a copy of your personal information directly to a third party specified by you.
7. Responding to Your Requests
To ensure security, you may need to provide a written request or otherwise prove your identity. We may first require you to verify your identity before processing your request. If you are dissatisfied, you can also file a complaint using the contact information provided in Part X.
For reasonable requests, we generally do not charge a fee. However, for repeated or excessive requests, we may charge a reasonable cost fee. For requests that are unfounded, require excessive technical means (e.g., developing new systems or fundamentally changing current practices), pose risks to the legitimate rights and interests of others, or are impractical (e.g., involving information stored on backup tapes), we may refuse.
Please note that our response to your requests only applies to personal information collected and generated by us in accordance with this privacy policy. If the information is collected and used by a channel provider, please refer to the channel provider's publicly available privacy policy to assert your rights.
In the following circumstances, as required by law, we will not be able to respond to your requests:
(1) Related to the fulfillment of legal obligations by the personal information controller.
(2) Directly related to national security or defense security.
(3) Directly related to public safety, public health, or significant public interests.
(4) Directly related to criminal investigation, prosecution, trial, and execution of judgments.
(5) There is sufficient evidence that you have acted in bad faith or abused your rights.
(6) To protect the life, property, or other significant legitimate rights and interests of you or others, where it is difficult to obtain the individual's consent.
(7) Responding to your request would severely harm the legitimate rights and interests of you or others.
(8) Involving trade secrets.

 

VI. How We Handle Children's Personal Information
Our services are primarily aimed at adults. Without the consent of a guardian, children should not create their own game accounts. If you are a child under the age of fourteen, only your guardian can read this privacy policy and the "Children's Personal Information Protection Rules," which are part of this policy, and provide consent before you can use our services. For the collection of children's personal information with the guardian's consent, we will only use this information in accordance with the "Children's Personal Information Protection Rules" when permitted by law, with the guardian's explicit consent, or when necessary to protect the child.
If we discover that we have collected a child's personal information without prior verifiable guardian consent, we will take steps to delete the data as soon as possible.

 

VII. Protection of Minors
We attach great importance to the protection of minors' personal information and continuously explore new methods for safeguarding their personal information.
We actively comply with national anti-addiction policies by enabling an anti-addiction system to protect the legitimate rights and interests of minors. We verify whether the real-name information of an account belongs to a minor through real-name identity checks and decide whether to include the account in the anti-addiction system. Additionally, in accordance with national anti-addiction policies, we collect necessary personal information from you and your guardian, particularly login times and game duration, to automatically intervene and restrict minors' gaming time at the system level, enable forced logout functions, and guide minors to play games reasonably. We also attempt to contact guardians for reminders, confirmation, and handling after suspected minor consumption, helping minors use the internet healthily.
At the same time, to better protect the physical and mental health of minors and encourage healthy internet use, we may implement stricter anti-addiction measures beyond the national regulations on online game addiction prevention. We are also continuously researching new technologies to protect minors.
If you are the legal guardian of a minor, please ensure that the minor uses Xinyou Liangpin game services or provides their personal information only after obtaining your authorization. If you have any questions about the personal information of the minor under your guardianship, please contact us using the information provided in Part X.

VIII. Storage of Personal Information
1. Methods and Duration of Information Storage
We store your information securely. Generally, we only retain your personal information for the period necessary to achieve the service purposes or as required by laws and regulations.
2. Geographic Location of Information Storage
In accordance with laws and regulations, we store user personal information collected within China within the country.
3. Notification in the Event of Service Termination
If our products or services cease operations, we will notify you through announcements as required by relevant laws and regulations and safeguard your legitimate rights and interests in accordance with the law.

 

IX. How This Policy Is Updated
1. Please understand that as our game services continue to evolve, we strive to implement the concept of "privacy by design," improve our product design, and promptly inform you of the content, scope, and purpose of personal information collection through page prompts, announcements, or interactive processes as necessary supplements to this privacy policy.
2. We will not reduce your rights under this privacy policy without your explicit consent. We will publish updated versions of the privacy policy. For significant changes, we will provide more prominent notice (including, for certain services, sending emails to explain the specific changes to the privacy policy).
3. Significant changes to the privacy policy include but are not limited to:
(1) Major changes in our service model, such as the purpose of processing personal information, the types of personal information processed, and how personal information is used.
(2) Major changes in our ownership structure or organizational framework, such as changes in ownership due to business adjustments, bankruptcy, mergers, etc.
(3) Changes in the main parties with whom personal information is shared, transferred, or publicly disclosed.
(4) Significant changes in your rights and how you exercise them regarding personal information processing.
(5) Changes in the department responsible for personal information security, contact information, or complaint channels.
(6) When a personal information security impact assessment report indicates high risks.

 

X. How to Contact Us
1. If you have any questions, comments, or suggestions regarding the privacy policy, you can contact us through the following methods. Generally, we will respond within fifteen working days.
Chengdu Xinyou Liangpin Technology Co., Ltd.
Address: Room 3, 32nd Floor, Building 2, No. 530, Middle Section of Tianfu Avenue, Hi-Tech Zone, Chengdu, Sichuan, China
Email: luotingkeji@163.com
2. If you are dissatisfied with our response, especially if our personal information processing activities have harmed your legitimate rights and interests, and no agreement can be reached through negotiation, either party may submit the dispute to the local People's Court for resolution.

 

XI. Personal Information Controlled by Third-Party Channels
If you download the game installation package provided by a third-party channel and log in to the game using a channel account, you acknowledge and understand that the third-party channel is the controller of your personal identity information. To provide you with complete online game services, you should authorize the third-party channel to share your personal identity information with Xinyou Liangpin games. Xinyou Liangpin games will provide personal information protection in accordance with the commitments in this privacy policy. If the third-party channel refuses to share your personal registration information with Xinyou Liangpin games, the scope of protection under this privacy policy will be limited to the personal information generated during your use of the online game services, and the realization of your personal information rights will be restricted. Please contact the third-party channel responsible for your account registration to assert relevant personal information protection.
At the same time, you also authorize Xinyou Liangpin games to share some of the personal information generated during your use of online game services with the channel for the purpose of login and game cooperation. For specific details, please refer to the channel SDK section in the "SDK Provider Personal Information List."

Chengdu Xinyou Liangpin Technology Co., Ltd.

 

Children's Personal Information Protection Rules
Chengdu Xinyou Liangpin Technology Co., Ltd. (hereinafter referred to as "Xinyou Liangpin" or "we") deeply understands the importance of protecting the personal information and privacy of children (referring to minors under the age of fourteen, the same below). The "Children's Personal Information Protection Rules" (hereinafter referred to as "these Rules") are an inseparable part of Xinyou Liangpin's "User Agreement" and "Privacy Policy." Unless otherwise specified in these Rules, the definitions in these Rules are consistent with those in the "User Agreement" and "Privacy Policy."
[Scope of Application]
These Rules aim to explain the personal information protection policies we have specifically formulated and implemented for child registered users (hereinafter referred to as "children" or "your child"). As the guardian of the child (hereinafter referred to as "you"), you can clearly understand through these Rules how we collect, use, store, and share your child's personal information, as well as the relevant rights of children and their guardians. We will take special measures to protect children's personal information in accordance with these Rules.
These Rules do not apply to the personal information protection of minors over the age of fourteen and adults.
[Special Notes]
Child users are obligated to notify their guardians, who should carefully read, fully understand, and agree to these Rules before guiding the child to use the relevant game services. We use the national online game real-name authentication and anti-addiction system to implement relevant protection measures for minors (including children). We will also refer to industry best practices to confirm the authorization and consent of guardians. Unless otherwise required by laws and regulations, we will assume in good faith that the operations and authorizations of child users in our services have been guided and agreed upon by their guardians.
These Rules will explain the special rules for the protection of children's personal information from the following aspects:
1. How We Collect Children's Personal Information
2. How We Use Children's Personal Information
3. How We Transfer and Entrust the Processing of Children's Personal Information
4. How We Disclose Children's Personal Information to Third Parties
5. How We Store Children's Personal Information
6. How We Ensure the Security of Children's Personal Information
7. How You Can Manage Children's Personal Information
8. Changes to These Rules
9. Children's Personal Information Protection Officer
10. Application of Xinyou Liangpin's "Privacy Policy"

I. How We Collect Children's Personal Information
Xinyou Liangpin does not differentiate between providing different online game service functions for children and non-children. Therefore, during the provision of online game services to children, the scope of children's personal information collected is consistent with the necessary and non-necessary personal information required for the basic and extended business functions described in the "Privacy Policy." The purpose is to provide appropriate game services to children and ensure the security of their game accounts.
Additionally, to verify the authenticity of the guardian relationship and ensure the authenticity of the guardian's identity, we may also need to collect your contact information (phone number and/or email address) as the guardian, as well as other necessary and reasonable information that helps us determine the authenticity of the guardian relationship.
Please note that your child can also use Xinyou Liangpin's products and/or services by logging in through a registered account with our cooperative channels (such as app stores, channels, WeChat, etc.). In this case, we will share relevant information about your child's account with the channel, including the account name and nickname (but excluding real-name authentication information). For the personal information collected by the channel, the channel's children's personal information protection policy or related statement applies.
To protect the security of your child's personal information, we remind you again that the entire registration process should be completed under your guidance.

II. How We Use Children's Personal Information
We strictly comply with national laws, regulations, and policies, and adhere to the scope of authorization and consent in the "Privacy Policy" to use the collected information to provide game services to children. If our use of children's personal information exceeds the scope of the "Privacy Policy" or the purpose for which we collected the information, we will notify you again and obtain your consent before using the children's personal information.

III. How We Entrust and Transfer Children's Personal Information
If we need to entrust a third party to process children's personal information, we will conduct a security assessment of the entrusted party and the entrusted activities, sign an entrustment agreement, clarify the responsibilities, processing matters, processing period, nature, and purpose of both parties. The entrusted processing will not exceed the scope of your authorization for us to process children's information. We will take responsibility for the protection of children's personal information in entrusted processing scenarios and supervise and require the entrusted party to fulfill the following obligations:
1. Process children's personal information in accordance with laws, regulations, and our requirements.
2. Assist Xinyou Liangpin in responding to requests from children's guardians.
3. Take measures to ensure information security and promptly provide feedback to us in the event of a children's personal information security breach.
4. Require the timely deletion of children's personal information upon termination of the entrustment relationship.
5. No sub-entrustment is allowed.
6. Other obligations related to the protection of children's personal information as required by law.
The scenarios and necessity of transferring children's personal information are detailed in the "Privacy Policy." We will only provide children's personal information to third parties for legitimate, necessary, and specific purposes.
We will conduct a security assessment ourselves or through a third-party agency when entrusting or transferring children's personal information and adopt encryption and other technical measures to ensure the security of children's information.

IV. How We Disclose Children's Personal Information to Third Parties
We will only disclose your child's personal information based on legal or regulatory requirements or agreements with you. For more details, please refer to the "Privacy Policy."

V. How We Store Children's Personal Information
We strictly comply with laws, regulations, and regulatory policies to store the collected children's personal information within the territory of the People's Republic of China. Children's personal information is stored using encryption measures that meet industry standards to ensure its security.
Generally, we will only store your child's personal information for the period necessary to achieve the required service purposes or as required by laws and regulations. After exceeding the period stipulated by laws or regulations, we will delete your child's personal information or anonymize it using de-identification techniques as required by law.

VI. How We Ensure the Security of Children's Personal Information
The personal information security measures disclosed in the "Privacy Policy" apply to children's personal information. At the same time, we have classified children's personal information as sensitive personal information and strictly comply with national laws and regulations to ensure its security.
1. Encrypt or take other necessary technical measures when storing, transmitting, or transferring children's personal information.
2. Conduct a security impact assessment when entrusting or transferring to a third party.
3. To ensure the security of children's personal information, we have established specialized management systems, processes, and organizations. We strictly limit the range of personnel who can access children's personal information, require them to comply with confidentiality obligations, and prohibit unauthorized access or use of children's personal information. In addition to maintaining access records, we take technical measures to prevent illegal copying or downloading of children's personal information.

VII. How You Can Manage Children's Personal Information
You can exercise the rights of the personal information subject through the methods described in the "Privacy Policy." By exercising rights such as modification and deletion on your child's account, you can protect your child's information security and mental and physical health.
Based on the design of the parent supervision function in the anti-addiction system, you can also apply for supervision services through our parent certification supervision. We will correct your child's account settings and personal information according to your requests and relevant procedures.

VIII. Changes to These Rules
We may revise or adjust these Rules in accordance with changes in national laws, regulations, regulatory policies, and the technological environment. When the content of these Rules changes, we will notify you of the updated Rules in an appropriate manner during version updates. Please read the updated Children's Personal Information Protection Rules carefully. Your child's continued use of Xinyou Liangpin's products and services indicates your consent to our collection, processing, and use of your child's personal information in accordance with the updated Rules.

IX. Children's Personal Information Protection Officer
Xinyou Liangpin has a dedicated personal information protection organization that strictly complies with these Rules to fulfill its obligations to protect children's personal information and has designated a responsible person. If you have any complaints or reports regarding the security of children's personal information, or if you have any questions, comments, or suggestions regarding these Rules, please contact our personal information protection contact:
Contact: Children's Personal Information Protection Officer
Address: Room 3, 32nd Floor, Building 2, No. 530, Middle Section of Tianfu Avenue, Hi-Tech Zone, Chengdu, Sichuan, China
Email: luotingkeji@163.com

X. Application of the "Privacy Policy"
Xinyou Liangpin's "User Agreement" and "Privacy Policy" are the unified user service agreement and general privacy terms applicable to all Xinyou Liangpin users. The content stipulated therein, including but not limited to user rights and information security measures, applies to all Xinyou Liangpin users. These Children's Personal Information Protection Rules are specifically designed for the privacy protection of children and include special protections for children's personal information. If there are any inconsistencies or conflicts between Xinyou Liangpin's "User Agreement" and "Privacy Policy" and these Rules, these Rules shall prevail.

XI. Third-Party SDK Information Collection and Usage Description
When you use the software's functions or services, in certain specific usage scenarios, we may use software development kits (SDKs) provided by third-party service providers with the corresponding business qualifications and capabilities to provide services to you. These SDKs may collect and use your personal information, which we will obtain after your authorization and consent. The software conducts strict security checks on SDKs or similar applications and requires third-party service providers to adopt strict data protection measures to effectively safeguard your legal rights. The specific information about these SDKs is as follows: