PRIVACY POLICY

PLEASE READ THIS PRIVACY POLICY CAREFULLY. IT DESCRIBES DETAILS ABOUT HOW WE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION YOU SHARED WITH US. IF YOU ARE UNDER THE MINIMUM AGE TO GIVE CONSENT ACCORDING TO APPLICABLE DATA PROTECTION LAWS, DO NOT PROVIDE ANY PERSONAL INFORMATION WITHOUT YOUR PARENT’S OR GUARDIAN’S PERMISSION.

Thank you for reading our Privacy Policy. For the purpose of applicable data protection laws, the data controller is “Perfect World Games”, a group of global developers and publishers of PC games, console games and mobile game applications (“Games”). This means that Perfect World Games is responsible for determining how and why your personal data is processed. You can find the specific entities of Perfect World Games that are covered by this Privacy Policy here.

This Privacy Policy (“Policy ”) applies to personal information collected through our Games, related websites and other online services. This Policy also summarizes when and how your personal information is collected, used, safeguarded and disclosed in connection with your use of the Games. It also describes your rights and available choices regarding your personal information. The Games and the features, functions, software and services offered through the Games, related websites and other online services collectively constitute the “Service”.

It is our policy to comply with applicable data protection laws.

We reserve the right to change the provisions of this Policy from time to time. If we decide to make material changes to this Policy, we will notify you of these changes via an alert on the home page of our website and notify you by email if we have your email address. In any event, we encourage you to periodically review this page for the latest information on our privacy practices.

What is personal information?

What personal information do we collect?

For which purposes do we use your personal information?

Do we share personal information? If so, how we share your information?

What steps do we take to protect your personal information?

How long do we retain your personal information?

What choices do you have regarding the use of your personal information?

How do we protect children?

How can you contact us?

Changes to this Policy

Special Section for Certain Jurisdictions

What is personal information?

The term “personal information” or “personal data ” means information that specifically identifies an individual (such as a name, address, telephone number, mobile number, email address, or other account number), and information about that individual’s location or activities, such as information about your use of the Service, IP addresses or mobile device identifiers, when directly linked to personally identifiable information. Personal information also includes demographic information such as date of birth, gender, geographic area and preferences when such information is linked to other personal information that identifies or may identify you.

Personal information does NOT include “anonymized” information, which is data we collect about the use of the Service or about a group or category of products, services or users, or other data from which individual identities or other personal information has been removed so that the individual concerned cannot be identified directly or indirectly. Such data helps us understand trends and our users’ needs so that we can better consider new features or otherwise tailor our Service. This Policy in no way restricts or limits our collection and use of such information.

What personal information do we collect?

We may collect information that you voluntarily provide to us, information that we collect automatically through your use of the services, and certain information we obtain from third party sources.

	Information You Voluntarily Provide	Information We Automatically Collect	Information We Obtain from Third Party Sources
PC Games		- Internet Protocol (IP) address - broad geographic location (e.g. country or city-level location) based on your IP address - log data (time and period) - in-game items and behaviors - achievements you have completed in the game - other users you referred	Your publicly available information on Steam (if applicable), such as - the public personal name you have chosen to represent you on Steam - your Avatar picture - whether you have received a ban for cheating in a multiplayer game Your ownership of the game
Console Games – Sony		Progress in the game : - Internet Protocol (IP) address - log data (time and period) - in-game items and behaviors - achievements you have completed in the game - other users you referred	If you play our game on a network connected console of Sony, Sony may share with us your - PSN Online ID The sharing of such information by Sony to us will be subject to the privacy policy of Sony ( https://www.playstation.com/en-us/legal/privacy-policy/ ).
Mobile Games	When you are using the game or services within the game : - If applicable, your phone number may be used to create an account or for pre-registration. - the chat log and message you communicated or posted in our Service - microphone when you give us the permission to your device - precise location data when you give us the permission to access the location of your device (not applicable for Korean users) - your purchase or transaction records in the Service - IDFA only after your permission Any information you submit to our support team by email or other means for any reason, for example, asking for customer support. Other personal information you provide in connection with your voluntary participation in surveys, sweepstakes, contests, promotional offers, and other activities.	- Internet Protocol (IP) address - broad geographic location (e.g. country or city-level location) based on your IP address - device information, including the device type, device model, device maker, device operating system and its language or other technical data like processor, or combination of this data available from a device for a developer for checking the device compatibility with a particular application - device identifiers, such as a universally unique identifier (“UUID”), referring to the small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may convey information to us about how you browse and use the Service and may remain persistently on your device, to help you log in faster and enhance your navigation through the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled. - Advertising ID, i.e. Identifier for Advertisers on Apple (if authorized) and Google Advertising Identity. These are unique identifiers for mobile device that advertisers use for personalized advertising. They are consistent across all mobile applications and thus allow cross-app tracking. You can opt in or out of it in your privacy settings. Advertising IDs are non-permanent, non-personal identifiers, which are uniquely associated with your device. Progress in the game : - log data (time and period) - in-game items and behaviors - achievements you have completed in the game - other users you referred Some of the automatically collected information may be collected through cookies as explained further under the heading “ Cookies and other tracking Technologies ” below	Third-Party platforms : If you log in to our Service using Third-Party accounts, such as Facebook, Google, Apple Game Center Naver, we may collect personal information you authorized the Third-Party platforms to share with us to pre-populate our sign up form. Exactly what information we receive from your Third-Party platforms will depend on your settings, but it would typically include your basic public profile information such as - your username - profile picture - gender (with your option) - your friends playing the same Game - other information from Third-Party platforms that you have permitted the Third-Party platforms to share with us - any information you have made public on the Third-Party platforms. You should always review, and if necessary, adjust your privacy settings on the Third-Party platforms before linking or connecting them to our Service. Advertising partners : From time to time, we may also receive personal information about you from other third-party sources. For example, if you click on an advertisement to direct you to one of our services or Games (such as an advert of one of our Games in another publisher’s game), we may receive the information from third parties that allows us to know which ad network and advertising campaign your installation was originated from.
Websites		- Internet Protocol (IP) address - device information, including the device type, operating system and version

We also use analytics tools on our Service to retrieve information from your device, including your preferred settings, which in-game adverts you may have viewed, and the means by which you were referred to our Service. We may also deliver advertisements and provide website analytics tools on non-Perfect World sites and services, and we collect information about page views on these third party sites as well. We treat this information as personal information if we combine it with or link it to any of the identifying information mentioned above. Otherwise, it is used in the anonymized form only.

You can access certain portions of our Service without providing us with certain personal information. However, you will not be able to utilize certain features that require registration or receive materials unless certain information is provided. The processing of this personal information is necessary for the performance of our Service. Where processing is not necessary for the performance of the Service, your consent to such processing will be requested where required under applicable law.

For users in certain jurisdictions, please refer to the Special Section for Certain Jurisdictions for further information about how we collect and process your personal information and your related rights.

No special categories of information

We do not request or intend to collect any “special categories of information” as defined in Art.9 of the General Data Protection Regulation (“GDPR”), such as any information on health, race, religion, political opinions or philosophical beliefs, sexual preferences or orientation. We also want to kindly remind you to be cautious when sharing this information about yourself (or others) in our forums.

No credit card information

Our Games enable in-app purchases and we collect your purchase or transaction record in the Service. However, we do not process payments for in-app purchases nor have access to your credit card information.

Payment transactions for in-app purchases are mostly completed through the app store via your App Store account or Google Play account, or through platforms such as Sony, or through the payment method you choose such as VISA, PayPal, WeChat Payment or Alipay, etc. Any post-purchase processes are controlled by the Apple and Google stores, Sony and other payment providers and are subject to those payment providers’ specific terms of service. Please review the privacy policies and terms of service of your Apple and Google stores, Sony and the payment providers you choose.

Cookies and other tracking technologies

Many browsers enable you to control the use of cookies at the individual browser level. Cookies are small data files that are stored on a user’s hard drive at the request of a Website or the Service to enable the Website or the Service to recognize users who have previously visited them and retain certain information such as customer preferences and history. If we combine cookies with or link them to any personally identifying information, we would treat this information as personal information.

You can also refer to your browser or mobile device’s instructions or help screen to learn about these functions. You may not be able to delete or disable cookies on certain mobile devices and/or certain browsers.

Remember, if a browser or mobile device is set not to accept cookies or if a user rejects a cookie, some portions of the Website or Service may not function properly. For example, you may not be able to sign in and may not be able to access certain Website or Service features or services.

Data collected to prevent cheating and unauthorized software

When you run our Game software or receive our Service, this may involve software functions designed to detect cheating or unauthorized and malicious programs. In this context, we may access, collect, monitor and/or remotely store screenshots of game play, information relating to hardware capacity, modifications related to our Game software, signatures, profiles or names of known or suspected unauthorized or malicious third party programs, files or processes that enable or facilitate cheating, unfair advantage or hacking of the Games or Service. If circumstances suggesting unauthorized or malicious programs are detected, the Game software may also communicate to us the users account and User ID and information about the unauthorized or malicious program or its use.

We see this processing as necessary for the purposes of the legitimate interests in ensuring that fraudulent activity is not carried out in or using our Services. Pursued by us, where legitimate interest is not sufficient for the collection, your consent to such processing will be requested where required under applicable laws or on the basis of providing our services.

For which purposes do we use your personal information?

We use your personal information to provide products and services you ask for, to communicate with you, to improve our services, and for other purposes including those set out in the chart below.

Personal Information	Purpose	Legal basis relied on according to GDPR （ only users located in the EU）
PC Games
- Internet Protocol (IP) address - broad geographic location (e.g. country or city-level location) based on your IP address	To safeguard your account security in case of unusual sign-in activities	Our legitimate interests in detecting and preventing fraud, other crimes and the misuse of our Service, in line with art. 6.1( d ) of the GDPR
Your email address	To send you our service information from time to time	Necessary for the performance of our Service in line with art. 6.1( b ) of the GDPR
Your publicly available information on Steam, such as - the public personal name you have chosen to represent you on Steam - your Avatar picture - whether you have received a ban for cheating in a multiplayer game Your ownership of the game	To deliver the Steam Games and service to you	Necessary for the performance of our Service in line with art. 6.1(b) of the GDPR
Progress in the game: - log data (time and period) - in-game items and behaviors - achievements you have completed in the game - other users you referred	To keep the record of your account and to ensure the functionality of our Games and Services	Necessary for the performance of our Service in line with art. 6.1(b) of the GDPR
Console Games – Sony Games
Your information shared by Sony Platform: - PSN Online ID	To deliver the Console Games and service to you	Necessary for the performance of our Service in line with art. 6.1(b) of the GDPR
Progress in the game: - log data (time and period) - in-game items and behaviors - achievements you have completed in the game - other users you referred	To keep the record of your account and to ensure the functionality of our Games and Services	Necessary for the performance of our Service in line with art. 6.1(b) of the GDPR Legitimate interests pursued by us, in line with art. 6.1(f) of the GDPR
Mobile Games
Registration information : - user name; - email address ( if applicable ); - phone number ( if applicable ) Facebook (with your authorization) : - Facebook ID - profile pic, - gender (with your option), - your friends playing the same Game - information you have made public on Facebook - other information you give permission to Facebook to share with us Google Play (with your authorization) : - Gmail address, - nickname, - profile pic - information you have made public on Google - other information you give permission to Google to share with us Apple Game Center (with your authorization) : - user ID in Apple Game Center - information you have made public on Apple Game Center - other information you give permission to share with us	To create your account for the Mobile Games per your request and phone number may be also used for pre-registration	Necessary for the performance of the contract for the provision of the mobile game App between us, in line with art. 6.1(b) of the GDPR
The chat log and message you communicated or posted in our Service, regardless whether it is in the form of text, voice, image or video	To deliver the Mobile Games and/or the in-game service to you	Necessary for the performance of our Service, specifically, the chat function within the game, in line with art. 6.1(b) of the GDPR
Your purchase or transaction record in the Service through Apple Store, Google Play, PayPal, WeChat Payment, Alipay and other payment method: - User ID - Cost - Purchased product	To keep the record of your transaction history and to deliver the product you purchased to you	Necessary for the performance of our Service, specifically, the in-game purchase, in line with art. 6.1(b) of the GDPR
Any information you submit to our support team by email or other means for any reason, for example, asking for customer support	To provide technical support, customer service and ensure the continued smooth operation of our Service	Necessary for the performance of our customer service, in line with art. 6.1(b) of the GDPR
Progress in the game: - log data (time and period) - in-game items and behaviors - achievements you have completed in the game	To keep the record of your account and to improve the functionality of our Games and Services	Our legitimate interests in reviewing the performance of our Service and improve its functionality, in line with art. 6.1(f) of the GDPR
- Internet Protocol (IP) address - broad geographic location (e.g. country or city-level location) based on your IP address - device information - device identifiers, e.g. UUID - Advertising ID	To improve our games and services and to make our application compatible with your device	Our legitimate interests in performing and improving our Service, in line with art. 6.1(f) of the GDPR
Screenshots of game play, information relating to hardware capacity, modifications related to our Game software, signatures, profiles or names of known unauthorized or malicious third party programs, files or processes that enable or facilitate cheating, unfair advantage or hacking of the Games or Service	To prevent or investigate actual or suspected fraud, hacking, infringement, or other misconduct in any of our products and services	Our legitimate interests in detecting and preventing fraud, other crimes and the misuse of our Service, in line with art. 6.1(f) of the GDPR
Information from advertising partners. E.g. if you click on an advertisement to direct you to one of our services or games (such as an advert of one of our Games in other publisher’s game), we may receive the information	To know which ad network and advertising campaign your installation was originated from and to pay that advertiser	Our legitimate interests in promoting our Service, in line with art. 6.1(f) of the GDPR
Other personal information you provide in connection with your voluntary participation in surveys, sweepstakes, contests, promotional offers, and other activities.	To request feedback, perform research and analysis and to enable us to operate, develop, customize and improve the Service and our publications, products and services	Our legitimate interests in performing research and improving our Service, in line with art. 6.1(f) of the GDPR
Websites
- Internet Protocol (IP) address - device information, including the device type, operating system and version	To improve our games and services and to make our application compatible with your device	Our legitimate interests in performing and improving our Service pursued by us, in line with art. 6.1(f) of the GDPR

To contact you about our or a third party’s services, products, activities, promotions, special events or offers and for other marketing, informational, product development and promotional purposes, we may collect and (provided we have obtained your consent where required by law in the case of electronic marketing to you, such as email) use the information you provided (such as your name, phone number, email address) in our Services or which are lawfully shared by third parties (if applicable), and your physical address for sending promotional materials. You can ask us to stop sending you marketing messages at any time by following the opt-out links in marketing messages we send to you or contacting us at: privacy@pwrd.com .

Where processing is not necessary for the performance of the Service or we cannot rely on legitimate interests in a particular case (because for example your privacy rights and freedoms in that case outweigh the legitimate interests), your consent to such processing will be requested as appropriate under applicable law.

Compliance with our legal obligations

We may use your information when we are required to do so by law, or pursuant to valid law enforcement requests.

For purposes for which you give us consent

We may also collect and use personal information for specified purposes when you give us your consent to do so.

Do we share personal information? If so, how we share your information?

We will share your personal information with third parties only in the ways that are described in this privacy statement or as otherwise required by law. We do not sell or trade any personal information about our visitors and users to any third parties.

Please note that nothing herein restricts the sharing of anonymized information, which may be shared with third parties without your consent.

Our service providers

We may share personal information with vendors, consultants and other service providers (“Service Providers”) such as our analytics providers, our cloud service providers and our vendors who are engaged by or working with us in connection with the operation of the Service and who need access to such information to carry out their work for us. We may also share personal information with auditors, accountants, lawyers, financial or professional advisers. We provide access to the information they may need to perform our services under reasonable confidentiality terms. In some cases, the Service Provider may be directly collecting the information from you on our behalf. Our Service Providers are under an obligation to use personal information they obtain from us exclusively to provide the services for us. However, we are not responsible for any additional information you provide directly to these Service Providers and we encourage you to become familiar with their practices before disclosing any personal information directly to such Service Providers.

Our subsidiaries

We may share information with companies in the same group of companies as Perfect World Games, which includes our subsidiaries (i.e., any organization we own or control) and/ or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Policy.

We see this processing as necessary for the purposes of organizing our business as appropriate. Where we cannot rely on legitimate interests for the sharing in a particular case (because for example your privacy rights and freedoms in that case outweigh the legitimate interests), your consent to such processing will be requested as appropriate under applicable law.

Sharing when you give us consent

From time to time, we may also share personal information with third parties when you give us your consent to do so.

Sharing in response to legal obligations

We reserve the right to disclose your information (including personally identifiable information) in response to law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We may access, disclose or preserve personal information, including the content of your communications, in the good faith belief that we are lawfully authorized by public authorities or required to do so, including to meet national security or law enforcement requirements or that doing so is reasonably necessary or appropriate to comply with the law or with legal process or authorities, respond to any claims, or to protect the rights, property or safety of Perfect World Games, our users, our employees or the public, including without limitation to protect Perfect World Games or our users from fraudulent, abusive, inappropriate or unlawful use of our Service.

Sharing due to merger, acquisition and similar situations of the transfer of company assets

Information we collect, including personal information, may also be disclosed or transferred as part of, or during negotiations of, any merger, sale, divestiture, or transfer of all or a portion of the company assets, financing or acquisition or in any other situation where personal information may be transferred as one of the business assets of Perfect World Games. You will be notified via email and/or a notice of any change in ownership, uses of your personal information, and choices you may have regarding your personal information.

International transfer

In order to be able to perform our contract with you, your personal information will be transferred and shared globally, among Perfect World Games Co. Ltd and its affiliated companies. Your information will be accessible from and processed in servers located globally. In particular, your account information will be stored in servers located in the United States of America.

As Perfect World Games is a global company, your personal information may be transferred to and processed in countries other than the country in which you reside. Although these countries may have data protection laws that are different to the laws of the country you reside in, we ensure appropriate safeguards in place so that your personal information will remain protected in accordance with this Policy. The information relating to your account and use of our games may be transferred internationally, among Perfect World Group.

You acknowledge and understand that the laws regarding personal information in the country or region to which the data is transferred may be less stringent than the laws of your country and may not offer the same protections or rights as those laws. If you object to your personal information being transferred or used as described in this Policy, please do not use the Service.

Links to third party

Our Website or Service may contain links to other websites or be accessible from third-party platforms. We do not control such sites, platforms or their activities. Any personal information you provide on linked pages is provided directly to that third party and is subject to that third party’s privacy policy. We are not responsible for the content or privacy and security practices and policies of websites to which we link or platforms from which the Services are accessible. Links from our Website or Service to third parties or to other sites are provided for your convenience only. We encourage you to learn about their privacy and security practices and policies before providing them with personal information.

If you are a consumer that downloads and uses our application implemented with any advertising SDK (software development kits) or otherwise interacts with the Services, the Advertising Company may be an independent controller of the personal data processed in order to provide the Services that it will individually determine the purposes and means of processing such data. Such data refers to any information or data that advertising company collects through the SDK implemented in our application, in connection with any advertisement or otherwise in connection with the Service, eg. user device information, user identifiers, information about advertisements served, viewed or clicked or other user interactions with advertisements or the Service, information about user applications, network information and header information. Please be aware that in no event will the advertising party and us process personal data as joint controllers.

Game updates

When we update or “patch” any of our game applications or other software, we may utilize a patch routine to verify whether the most recent version is installed on your computer. If not, the most recent version may automatically be uploaded to your device.

Push notifications and local notifications

We may send push notifications to your mobile device to provide game updates and other service relevant messages. You can manage push notifications from your mobile device’s settings page for the relevant game and/or from the settings page within the relevant mobile game. We may also send local notifications to your mobile device to provide game updates and other relevant information. To manage local notifications, you should consult your mobile device’s settings page for the relevant game and/or from the settings page within the relevant mobile game.

Performance monitoring

When you communicate with other players within a game or utilize any interactive features available on the Service, such as instant text, voice or image messaging, forums or chat rooms, such communications and postings are transmitted through our servers, and we may, but are not obligated to, monitor all such communications and postings for purposes such as protecting the rights and safety of Perfect World Games and our users, including those that are designated as “private,” to the degree that laws and regulations enable us to do this. Therefore, as the abovementioned performance monitoring might involve access to these communications and postings, please do not use these communication channels for private or confidential messages.

What steps do we take to protect your personal information?

We use physical, technical, and administrative measures to safeguard information in our possession against loss, theft and unauthorized use, disclosure, or modification. Please note, however, that no data transmission or storage can be guaranteed to be 100% secure. As a result, although we strive to protect the information we maintain, we cannot ensure or warrant the security of any information that you transmit to us.

You should note that our Service Providers may be responsible for processing, handling or storing some of the personal information that we receive. They are not authorized to market to you independently. These Service Providers are contractually required to safeguard and secure the personal information they received from us. Although we strive to protect your personal information, you should be aware, however, that information sent over the Internet is not necessarily secure and may be intercepted or accessed by third parties. Therefore, we cannot guarantee the security of such information, and we are not responsible or liable for any such interception or unauthorized access.

How long do we retain your personal information?

We will only retain your personal information for as long as it is reasonably necessary for the purpose for which that information was collected and to the extent permitted by applicable laws (including for the purpose of satisfying any legal, regulatory, tax, accounting or reporting requirements).

For example, your registration information and any game data generated from your account's activity will be held for as long as your account remains active, or until the Game or platform expires. We may store certain data only for several minutes or several days, such as your log data, chat data, in-game activity data.

We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. When we no longer need to use your information, we will remove it from our systems and records and / or take steps to anonymise it promptly so that you can no longer be identified from it.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.

If you would like to delete your data, please refer to the heading of “What choices do you have regarding the use of your personal information?” below.

What choices do you have regarding the use of your personal information?

As the subject of the personal information, you are entitled to have the rights provided by the privacy laws in your jurisdiction. Your rights may include part or all of those described underneath. You can exercise your rights entitled by the privacy laws in your jurisdiction at any time by sending us relevant requests to privacy@pwrd.com. Your rights may include:

Right to access your data

You have the right to access personal information we hold about you, how we use it, and who we share it with.

Right to correct your data

You have the right to correct any personal information held about you that is inaccurate. For example, you can contact us if your email address has been changed and we should replace your old email address.

Right to have your data deleted

You can delete your account (i.e. the account on our Service, excluding any account on the third party platforms, such as Sony), or remove certain personal information that we have stored about you. However, please note that we may need to retain personal information if there are valid grounds under data protection laws for us to do so (e.g., for the defense of legal claims or freedom of expression). If that is the case, we will inform you of such valid grounds.

Right to restrict processing and withdraw your consent

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances (such as where you believe such data to be inaccurate, our processing is unlawful or that we no longer need to process such data for a particular purpose). In cases where we have requested your consent to process personal information, you may withdraw your consent at any time by sending a communication to us specifying which consent you are withdrawing or by using the consent withdrawal functionalities available in our Service. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.

Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds other than your consent, for example, when the processing is necessary to fulfil the obligations of a contract, processing is necessary to protect the vital interest of you or another natural person, or other legitimate reasons under data protection laws.

Right to take your data with you (“right to portability”, applicable to EU users only)

You have the right to receive a copy of certain personal information we process about you in a structured, electronic format. For example, you can contact us to receive your data if you want to upload it to another service, where this is (a) personal information which you have provided to us, and (b) if we are processing that information on the basis of your consent or to perform a contract with you and (c) the information is processed by automated means. Additionally, you have the right to require us to transmit such personal data directly to another controller, where technically feasible. However, please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (e.g. where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property) or there are other limitations recognized under data protection laws.

Right to object to the way your data is handled

You have the right to object to our processing of personal information about you. In particular you have the right to object to being profiled for the purposes of direct marketing (for example where we collect information about you in order to decide what marketing to send you, based on your preferences or personal characteristics).

Right to lodge complaints to the supervisory authority

To help us verify that you are the subject of the personal information and exercise your rights outlined above, we may require you to provide sufficient proof of identification. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We will respond to all access requests within thirty days. This period may be extended by two further months where necessary, taking into account the complexity and number of the requests we are handling at the time.

You have the right to lodge complaints about the data processing activities carried out by us before the competent data protection authorities, where existing. For more information on your right to lodge complaints to supervisory authorities, please refer to the Special Section for your jurisdiction.

How do we protect children?

For the purpose of this privacy policy, if you are under the minimum age to give consent according to applicable data protection laws, please ensure that you have obtained your parents’/guardians’ consent for us to process your personal information according to this policy. The Service is not directed to children under such minimum age. If we discover that we have inadvertently collected information from children under such minimum age, we will delete the children’s information from our systems in accordance with applicable law. If you become aware that personal information about a person under such minimum age has been provided to us, please immediately contact us at: privacy@pwrd.com.

If you are under such minimum age please not use the Service.

Where the settings or notices in our Service provided in your jurisdiction does not specify a minimum age, children under the age of 16 are not eligible to use our Service.

How can you contact us?

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily or any questions, comments on this Policy or wish to exercise your rights described in this Policy, please contact us at: privacy@pwrd.com.

Changes to this Policy

From time to time, we may revise this Policy to reflect changes to the scope of the Services or for other reasons. Therefore, it is important to check the effective date of this Policy posted here each time you use the Services. If we decide to make material changes to this Policy, we will notify you of these changes via an alert on the home page of our website and notify you by email if we have your email address. You can also find the old version of this Policy here.

Special Section for Certain Jurisdictions

European Union

When you are in the European Union, the European Regulation (EU) 2016/679, also referred to as the GDPR, applies to the collection and processing of your personal data by Perfect World.

For the purpose of the GDPR, the data controller is Perfect World Games. This means that Perfect World Games is responsible for determining how and why your personal data is processed. You can find the specific developer on the games or websites and find the list of Perfect World entities that are covered by this Privacy Policy here.

Perfect World’s representative for GDPR purposes in the European Union is Perfect World Europe B.V., with registered address in NL- 1096 CJ Amsterdam, Joan Muyskenweg 22-4, The Netherlands, with corporate identification number 24484242.

You can contact our representative at the following address: Rhijnspoorplein 10-38, 1018 TX Amsterdam, Netherlands.

As outlined in the “Data collected to prevent cheating and unauthorized software” section of the Policy, we may also process your personal information to detect cheating or unauthorized and malicious programs. We see this processing as necessary for the performance of our Service, pursuant to art. 6.1(b) of the GDPR.

For complementary information regarding the purposes for which we use your personal information, please see the “For which purposes do we use your personal information?” section of this Policy.

Software Development Kits. Please note that we have implemented software development kits (“SDK”) in our Services. Such SDK may be implemented to enable certain functionalities if you play the Game “Fantasy New Jade Dynasty”:

- To collect users' voice chat information (using the Game Multimedia Engine SDK and after obtaining microphone permission);

- To read photos of albums (using the NativeGallery SDK, and after applying permission);

- To read video data (using the NativeCamera SDK, and after applying permission); and

- To apply for storage permission and provide uploading and downloading services of game face-pinching data and data related to operation activities (using the Tencent cloud storage).

Cookies and other tracking technologies.

The following cookies are used on the Services:

1. Strictly necessary cookies. These are cookies that are essential to the functioning of our Services. For example, we used cookies to ensure load balancing of the equipment we use to provide you with the Services. This category of cookies cannot be deactivated.

If you set your browser to refuse these cookies, some of the services on the Service will not be provided in an optimal manner, or will not be provided at all.

2. Analytics cookies. These cookies allow us to continue to improve the features of our Website through traffic analysis. They allow us to recognize, count and track the number of visitors to our Services. This helps us improve the functionalities of our Services, for example, by ensuring that users can easily find what they are looking for.

If you do not allow these cookies, we will not be able to continue to analyze the functionality of our Services.

When cookies and other tracking technologies process your personal information, we retain such personal information in accordance with the “How long do we retain your personal information?” section of this Policy, and in any event for no longer than 1 year.

You can find more information about the cookies we used in the table below:

Applicable Service	Name of the cookie	Host of the cookie	Type of cookie	Category	Description/purpose	Validity duration	Link to the third party privacy policy for third party cookies
Websites of the game	google analytics	third party	third party	analytics	To record page view and unique visitor (UV, PV)	1 year	https://policies.google.com/privacy
Websites of the game	Baidu analytics	third party	third party	analytics	To record page view and unique visitor(UV, PV)	1 year	https://tongji.baidu.com/web/help/article?id=330&type=0

International transfers. Perfect World is a multinational group with companies registered outside the EU. Our servers and main business operations are located globally and some of our businesses are primarily in China or the United States of America, as described in the “International transfer” section of this Policy. By using our Service and providing us with information, you acknowledge and understand the transferring, storing and processing of your information on computers located in China and the United States of America in the manner described in this Policy. If you object to your personal information being transferred or used as described in this Policy, please do not use this Service.

Data retention. We will retain your personal information in accordance to the “How long do we retain your personal information?” section of this Policy.

In addition, we may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. When we no longer need to use your information, we will remove it from our systems and records and / or take steps to anonymise it promptly so that you can no longer be identified from it.

Your data protection rights. If you are located in the European Union, the following conditions apply to your exercising of your data protection rights:

- Regarding the right to access your data: Where you exercise your right access personal information we hold about you, you also have the right to obtain a copy of this personal information.

- Regarding the right to have your data deleted: Where you exercise your right to have your data deleted, we will inform you of any valid grounds we may have to retain your personal information.

- Regarding the right to restrict processing and withdraw your consent. The circumstances under which you have a right to require us to stop processing the personal information we hold about you other than for storage purposes include cases where you believe such data to be inaccurate, that our processing is unlawful or that we no longer need to process such data for a particular purpose. In cases where we have requested your consent to process personal information, you may withdraw your consent at any time by sending a communication to us specifying which consent you are withdrawing or by using the consent withdrawal functionalities available in our Service. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.

- Regarding the right to object to the way your data is handled.

In addition to your other data protection rights, you may also object to the processing of your personal information for certain purposes:

● To stop receiving marketing communications from us: you may demand that we stop any direct marketing to you, at any time. You will find a link or instructions to unsubscribe in any such communications from us.

● For other purposes: you may object to the processing of your personal information where such processing is based on a legitimate interest as described above. Please describe the reasons relating to your particular situation to justify your request. If applicable, we will stop the processing unless we have compelling legitimate grounds.

You also have an additional data protection right in certain conditions: the Right to take your data with you (“right to portability”).

Pursuant to the GDPR, you have the right to receive a copy of certain personal information we process about you in a structured, electronic format. For example, you can contact us to receive your data if you want to upload it to another service, where this is (a) personal information which you have provided to us, and (b) if we are processing that information on the basis of your consent or to perform a contract with you and (c) the information is processed by automated means. Additionally, you have the right to require us to transmit such personal data directly to another controller, where technically feasible.

However, please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (e.g. where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property) or there are other limitations recognized under data protection laws.

Contacting us. If you have any thoughts or questions about this Policy, or if you wish to exercise any of your data subject rights, you may contact us at: privacy@pwrd.com. You may also contact our representative at Rhijnspoorplein 10-38, 1018 TX Amsterdam, Netherlands.

Processing your request and Right to lodge complaints to the supervisory authority. As outlined in the “Processing your requests and Right to lodge complaints to the supervisory authority” section of this Privacy Policy, we will respond to all access requests within thirty days. If you are located in the European Union, we will respond to all data protection rights requests within thirty days. This period may be extended by two further months where necessary, taking into account the complexity and number of the requests we are handling at the time.

If you are based or the issue you would like to complain about took place in the European Economic Area (EEA), please click here for a list of local data protection authorities in the countries within the EEA in which we operate.

Changes to the Privacy Policy. We reserve the right to change the provisions of this Policy from time to time. If we decide to make material changes to this Policy, we will notify you of these changes via an alert on the home page of our website and notify you by email if we have your email address. In any event, we encourage you to periodically review this page for the latest information on our privacy practices.

United States

Minimum Age. In the United States, the minimum age for users is 13. We therefore do not knowingly collect any personal information online from children under the age of 13 in the United States without parental consent, unless permitted by law. If we learn that a child under the age of 13 has provided us with personal information, we will delete it in accordance with applicable law.

Do-Not-Track Signals. Some web browsers may transmit “do not track” signals to the websites and other online services with which the browser communicates. There is currently no widely accepted standard that governs what, if anything, websites and online services should do when they receive these signals. We currently do not take action in response to these signals. If and when a standard for responding is established, we may revisit this Policy on responding to these signals.

Collection across Sites. Other parties may collect personally identifiable information about an individual consumer’s online activities over time and across different Web sites when you use our Services.

While we have tried to fully describe our data practices elsewhere in this Privacy Policy, this section supplements the description of our information collection and sharing practices elsewhere in this Policy, as required under applicable U.S. state laws.

As noted above, we may also disclose your personal information as part of, or during negotiations of, any merger, sale, divestiture, or transfer of all or a portion of the company assets, financing or acquisition or in any other situation where personal information may be transferred as one of the business assets of Perfect World Games.

We provide you with a number of rights described in the section “What choices do you have regarding the use of your personal information?” above in accordance with applicable law, including the right to request to access, correct, delete, and take your data with you. In addition, if you are a California resident, you may request that we disclose to you the following information covering the 12 months preceding your request: (i) the categories of personal information we collected about you and the categories of sources from which we collected such personal information; (ii) the business or commercial purpose for collecting, sharing, or selling personal information about you; (iii) the categories of personal information about you that we sold or shared (as defined by California law) and the categories of third parties to whom we sold or shared such personal information; and (iv) the categories of personal information about you that we otherwise disclosed and the categories of third parties to whom we disclosed such personal information.

We will not unlawfully discriminate against you for exercising your rights. Please submit your request by sending an email to privacy@pwrd.com. Once we receive your request, we may verify it by requesting information sufficient to confirm your identity, including by asking you to verify information about your use of the Service. If you would like to use an authorized agent to exercise your rights, we may request evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. Not all kinds of requests can be made by authorized agents in all states.

[If you are a Colorado, Connecticut or Virginia consumer and] If we refuse to take action on your request, you may appeal this refusal within a reasonable period after you have received notice of the refusal. You may file an appeal by contacting us at privacy@pwrd.com.

De-identified information. Where we maintain or use de-identified data, we will continue to maintain and use the de-identified data only in a de-identified fashion and will not attempt to re-identify the data.

Korea

For the purpose of providing services to Korean users, “Perfect world” means Fedeen Games Limited or Perfect World Korea Co., Ltd, depending on the specific developer on the games or websites.

A. In the case of sharing with third parties (“Recipients”) for their benefit (Provision)

Generally we won’t share your personal data with third parties, once we do so, we will inform you of the purposes, recipients and other related information and obtain your consent therewith, or in some other cases that we are required by applicable laws or to fulfill our legal obligations. In certain circumstances we may share some data to third parties to provide our services, the detailed information are listed as below.

Recipient	Items of the personal information to be transferred	Countries/regions where the personal data is to be transferred and time	Purposes of use of the personal data by the recipient	Periods of retention by the recipient
third party payment platforms: Paypal, Payletter, Xsolla, Applestore and other payment channels	payment amounts, role ID or other payment related data pursuant to payment platforms’ privacy policies	where the third party service providers are located, from time to time.	To finish the purchase orders under users’ instruction	retained for such period as is described in the retention period clauses of payment platforms’ privacy policies thereof

B. In the case of sharing with outsourced service providers (“Processors”) for the benefit of Perfect World Games (Outsourcing)

Recipient	Items of the personal information to be transferred	Countries where the personal data is to be transferred and time	Purposes of use of the personal data by the recipient	Periods of retention by the recipient	Privacy policy of the recipient
NICE평가정보주식회사 대표이사 귀중	Name, phone number, date of birth, telecommunications service provider	Korea, when verifying the age as requested by law	To verify the age of the users	Retained for such period as is described in the retention period clauses hereafter	/
IVE Korea Co., Ltd.	phone numbers that users provide	Korea, once when sending messages	to send service messages to users who provide their phone numbers	retained for such period as is described in the retention period clauses hereafter	/
AppsFlyer privacy@appsflyer.com	Technical information such as browser type, device type and model, system language, memory; and technical identifiers such as IP address Google Advertiser ID, Customer issued user ID and other similar unique identifiers	Germany, from time to time	To analyse the effectiveness of their marketing campaigns	retained for such period as is described in the retention period clauses hereafter	https://www.appsflyer.com/legal/services-privacy-policy/
Alibaba Cloud intlcompliance@service.aliyun.com	data generated in your game processing and account data in games	The USA, instantly or from time to time	Data storage in the server	retained for such period as is described in the retention period clauses hereafter	https://www.alibabacloud.com/help/en/legal/latest/alibaba-cloud-international-website-privacy-policy
Amazon cloud aws-korea-privacy@amazon.com	Account data in games	The USA, instantly	For safety back up	retained for such period as is described in the retention period clauses hereafter	https://aws.amazon.com/privacy/?nc1=f_pr
Perfect World BJ Software Tech Development Co., Ltd privacy@pwrd.com	data generated in your game processing	Mainland China, instantly	Maintaining, operation supports and analysis	retained for such period as is described in the retention period clauses hereafter	https://www.wanmei.com/safestatic/privacy.html

Cookies and other tracking technologies

We use cookies to maintain the reliability, security, and personalization of our website. When you accept cookies, it will help us improve our website by identifying users, remembering your preferences, or providing personalized user experience.

The following cookies are used on the Services:

Essential Cookies. These cookies are essential for enabling your movement and providing basic website service. Essential Cookies should be always active so that we can save your preferences for cookie settings. You cannot disable these cookies. By continuing to use our site you give consent to essential cookies.

Functional Cookies. These cookies are used to remember information that way the Service behaves or looks, such as by remembering your log-in details, or providing us information about how our site is used.

Analytics Cookies. These cookies help us measure the website’s performance and improve your experience. They allow us to identify popular search terms and help surface our content more effectively.

For more information about our use of cookies, please refer to our Cookie Policy.

Destruction of Personal Information

We will destroy your personal data without delay upon the expiration of the retention period you consented to, the achievement of the purpose of processing, or other reasons for which the personal data information is no longer necessary.

Notwithstanding the expiration of the retention period or the achievement of the purpose, in the event we are required to retain your personal data for a longer period pursuant to an applicable law, such data will be transferred to a separate database or retained at a different location.

Our procedure and method of destroying personal information are as follows.

- Destruction Procedure: We will select personal information which has a cause for discard and discard such personal information with the approval of its personal information protection manager. We will select the personal data to be destroyed (i.e., personal data whose purpose of processing is achieved or whose retention period has expired) and destroy it with the approval of our privacy officer.

- Destruction Method: If printed on paper, we will destroy the personal data by shredding, incinerating, or some other similar method and, if saved in electronic file format, by using technical methods (e.g., Low-Level Format) which ensure that the data cannot be restored or recovered.

The Period of Retention of Personal Information

- Act on the Consumer Protection in Electronic Commerce, etc.: Records regarding cancellation of contracts or orders and/or records regarding payments or provision of goods (5 years); Records regarding customer complaints or dispute resolution (3 years); and Records on labeling or advertising (6 months).

- Protection of Communications Secrets Act: Log record data, communications confirmation data such as trace record of access location, etc. (3 months); Telecommunications confirmation data such as telecommunications date and time, commencement and end time of telecommunications, number of uses, etc. (1 year).

Age Verification

Under our policy, game service is available only to persons who are 12 years of age or older, and that children under the age of 14 should ensure to get your parental consent. Perfect World will comply with the relevant laws and regulations should there be a need to verify game players’ ages. When providing Services that require age verification and identity verification, we may collect the following information:

- Name

- Date of Birth

- Mobile phone number

- telecommunications service provider

Data Security and Integrity

Perfect World Games takes the following technical, administrative, and physical security measures to safeguard your personal data against unauthorized access, use, alteration, and disclosure:

- Technical measures: Establishment and implementation of Internal Management Plan, operation of a data protection department; and periodic data security training for employees

- Administrative measures: Access control to personal information processing systems; implementation of an access control system, encryption of personal information; and installation of security programs and regular updates thereof.

- Physical security measures: access control to physical storage places (e.g., computer rooms and storage rooms) where personal information is kept.

Remedy for Infringement of Rights and Interests

A. Department in charge of personal information protection: Legal Department

Contact detail: privacy@pwrd.com

B. If a user’s otherwise needs to report or consult in relation to infringement of personal information, the member may inquire at the following institutions and seek remedy.

- Personal Information Dispute Mediation Committee ( www.kopico.go.kr / 1833-6972 without area code)

- Personal Information Protection Center (privacy.kisa.or.kr / 118 without area code)

- Cyber Division, the Ministry of Scientific Investigation at the Supreme Prosecutors’ Office (www.spo.go.kr/1301 without area code)

Cyber Bureau at the National Police Agency (https://ecrm.cyber.go.kr/ / 182 without area code)

Japan

When you are in Japan, the Act on Protection of Personal Information of Japan applies to the collection and processing of your personal data by Perfect World.

Perfect World Games is a multination group with companies registered out of Japan and our servers and main business operations are located globally and some of our business are primarily in China. By using our Service and providing us with information, you acknowledge and understand the transferring, storing and processing of your information on computers located in China in the manner described in this Policy. If you object to your personal information being transferred or used as described in this Policy, please do not use this Service.

If you have any thoughts or questions about this Policy, you may contact us: privacy@pwrd.com .

Malaysia

Minimum Age. In Malaysia, the minimum age for users is 18. We therefore do not knowingly offer our services or collect any personal information from children under the age of 18 in Malaysia without parental consent, unless permitted by law. If we discover that we have inadvertently collected information from children under such minimum age, we will delete the children’s information from our systems in accordance with applicable law. If you become aware that personal information about a person under such minimum age has been provided to us, please immediately contact us at the contact details below.

Your Rights. You have the right to request access to and correction of information about you held by us. We will try our best to respond within 21 days as soon as we receive your request. However, the process may take longer if we face difficulties due to incomplete information provided by you.

Please note that you must submit your request to access or correct your personal information in writing, and your rights are subject to any statutory exemptions and/or exceptions applicable under the Malaysian Personal Data Protection Act 2010 (“MY PDPA”) that allow us to collect, use or disclose your personal information.

Contact Details. If you have any queries, our Customer Service can be contacted at : privacy@pwrd.com

This Policy is provided in English and Bahasa Malaysia. The English version prevails in the event there are any inconsistencies between the two versions.

Updated on 27, July, 2022