hrgame

HongKong HRG Information Technology Co.,

  Founded on 2012, Hong Kong HRG Information Technology Co., Limited is a China-based mobile game developer with over a hundred of employees. Equipped with leading technical innovation ability, HRG embarked on oversea publishing business since 2016 with the help of staff from Mainland China, Taiwan, Japan and Korea and an experienced research and development team in wireless internet application development.

  啪啪三国, the first product of the company, make a great success in Mainland China, Taiwan, Hong Kong, Macao, Korea and Japan (it is named 真三國大戰 in Taiwan, Hong Kong and Macao and 三国魂 in Japan) with a best monthly revenue of 50 million globally. Since its establishment, HRG has published a serie of mobile game, such as 龙门镖局, orginated from a TV series,, and 龙战争, set with western sorcery background. It also acts energetically to explore the oversea markets by acquiring GAE, a renowed Japanese company with over 20 years experience in game field and registering 100 million yen monthly turnover through publishing 戦国修羅SOUL in Japanese market.

  Hong Kong HRG brings togater a group of passionate teenagesrs following their dream. Its products illustrate its committment to the game industry that it will stick to innovation, be adventurous in development and believe in the power of quality. HRG is now growing into an international company which insist on its dream of better games, promise distinguished experience to its players and provide favorable welfare to its employees.

  This is everything HRG are looking for.

This privacy policy informs you of your choices and our practices regarding any personal information you provide to us. Your use of the product(s), service(s) and related websites (“Service”) distributed by HONGKONG HRG INFORMATION TECHNOLOGY CO., LIMITED   involves the collection and use of your personal information. It is important for you to understand how this happens and how you may control it.
When you contract to use the Service, you accept our rules and policies regarding your personal information and you expressly consent to us collecting, processing, using and storing your personal information, as described in this policy.
You acknowledge that you have read and understood this privacy policy. If you do not agree with this privacy policy, you must not use the Service. If you change your mind in the future, you may withdraw your consent to use of your personal information in accordance with this policy.
If you have any comments, questions or complaints regarding the processing of your personal information, you can contact us at service@hrgame.com.cn . 

The Types of Personal Information We Use
This section describes the different types of personal information we collect and how we collect it. We will collect and use the following information about you:
• Information you give us.
(i) when you register for the Game or Service (including your nominated nickname, or custom accounts and information we import from your connected social media account (Wechat, Facebook, Google, Twitter or Apple) in order to set up your profile, including your name as it appears on your social media profile and your profile picture);
(ii) when you log-in as a ‘guest’ in order to use the Game or Service (your nickname);
(iii) when you participate in a survey in the Game or Service (in which case we will process the information you provide to us as part of the survey)
(iv) information you provide when seeking help from us such as your name, telephone number and records of the issues you experience;
(v) billing information, such as your name, payment card number and payment account details;
• Information we collect about you.
We automatically collect certain data from you when you use the Game or Service, including your IP address and device information (such as device type, network data, operating system) and information regarding your use of the Game or Service, such as date and time stamps of actions. We also collect and store your data each time you interact with us, for example, when you use in-app support to communicate with us.
• Information you generate and display in the course of using the Service.
You may provide additional information as part of your profile. You may also provide orgenerate information when you communicate with other users in the Service (e.g., chat log). You acknowledge and agree that information generated within our Service should not be considered private and communications within our Services may be viewed/heard by other users. Please avoid revealing any personally identifiable or sensitive information duringsuch commutations.

• Data we collect from our partners.

1. Data we receive if you link a third party tool with the Service (such as Wechat, Facebook, Google, Twitter or Apple);
2. Data from platforms that the games run on (such as to verify payment);
3. Data for advertising and analytics purposes, so we can provide you with a better Service.

Cookies
We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Services. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.
You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies, or instruct the device/web browser to provide notice at the time of installation of cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event of your refusal to install cookies, the Service may be unable to operate as designed.

Children
Our Service is not intended for children and we do not knowingly collect information from children. If you believe that we have unintentionally collected your children’s personal information, you may request the deletion of the information by contacting us atservice@hrgame.com.cn . In some cases we may ask the user to provide us with their birth date. If such information indicates the user is under the age stipulated by the applicable laws and deemed as child under such laws, we will not collect further personal information from the child until a parent/guardian‘s verifiable consent is obtained.

How We Use Your Personal Information
We will use the information in the following ways and in accordance with the following legal bases:
• Registration Information (such as: ID on third-party accounts ,nick name, avatar and other information): We use Registration Information to set-up user accounts, allow users to log-in to the Service and provide Services to users. We use this information with your consent to this Privacy Policy.
• Device Information (such as: device ID, device type, operating system, CPU, RAM, IP address, MAC address): We use this information to provide and improve the Service such as: to allow users to download and install the software on their devices; to record and keep track of requests from users of the Service; to detect the user network and device status when the user is using the Service; and to correct bugs or errors that occur when the user is using the Service. Use of Device Information is necessary to perform our contract with you to provide the Service.
• Contact Information (such as: name, email, address, phone number, instant messaging account): We use this information to send notifications to users to inform them of our promotional activities and any rewards they are entitled to. We use this information with your consent to this Privacy Policy.
• User Profile (such as : age, photo and etc.): We use this information to provide customized services to users such as personal information page. We use this information with your consent to this Privacy Policy.
• Game Data (such as: level, heroes, scores, chat logs and etc.): We use this information to provide Services to users as it is the basis of our Service. Use of Game Data is necessary to perform our contract with you to provide the Service.

How We Store and Share Your Personal Information
In order to perform our contract with you, your personal information will be accessible from and will be processed on our servers. Our servers are hosted on cloud servers such as Tencent Cloud Your information may be transferred to and processed in countries outside the country you are located. We will take steps necessary to comply with applicable legal requirements, such as using European Commission approved Standard Contractual Clauses to protect your information. In particular, your information will be transferred to and processed in Singapore where our central database is based.
We share your personal information with selected third parties in and outside your country, including:
• third-party vendors that provide services in support of the Service, such as Tencent Cloud  for the purpose of hosting the Game, Apple and Google for the purpose of providing payment services, Helpshift for the purpose of providing customer support, Facebook and Appsflyer for the purpose of the evaluation of our marketing events. Those third party vendors have limited access to your personal information and are contractually bound not use it for other purposes.
• related group companies, with whom we share your information to operate the Services. The transfers contemplated above are made pursuant to our contract with you; and
• law enforcement agencies, public authorities or other judicial bodies and organizations. We disclose information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to: (i) comply with a legal obligation, process or request; (ii) enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof; (iii) detect, prevent or otherwise address security, fraud or technical issues; or (iv)protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organizations for the purposes of fraud protection).

The Security of Your Personal Information
We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology. We deploy a firewall and other security measures （such as encryption）commensurate to industry standards to prevent unauthorized access to your personal information. Your personal information will remain subject to our technical and organizational controls and our policies and procedures (including this Privacy Policy).Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the information transmitted to our services; any transmission of your information is at your own risk.

Data Retention
We will retain most of your personal information for the lifetime of your use of the Services (i.e. until account deletion in accordance with your request) except that Contact Information obtained from promotional activities will be retained during the lifetime of such activities.
In the event that the processing and retention period have terminated, but personal information is required to be retained continuously for other reasons including for the purposes as prescribed under applicable laws, the relevant personal information will be stored and maintained separately from other types of personal information. If you require us to destroy your personal information before the end of its life cycle, we will destroy your personal information in accordance with local laws.

Your Rights
This section (“Your Rights”) applies to users that are located in the European Economic Area only. For California Residents, please refer to Appendix I. For users located in other territories, please refer to the privacy clauses in our User Agreement.
You have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at service@hrgame.com.cn . Please understand further information may be required to verify your identity when exercising your rights.
Access
You have the right to access personal information we hold about you, how we use it, and who we share it with. If you believe we hold any other personal information about you, please contact us.
Portability
You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent or pursuant to our contract with you, as described in the section “How We Use Your Personal Information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party.
If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. 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).
Correction
You have the right to correct any personal information held about you that is inaccurate. If you believe we hold any other personal information about you and that information is inaccurate, please contact us.
Erasure
You can delete your account, or remove certain personal information. If there is any other personal information you believe we process that you would like us to erase, please contact us.
You may request that we erase the personal information we hold about you in the following circumstances:
• you believe that it is no longer necessary for us to hold such personal information; or
• you believe the personal information we hold about you is being unlawfully processed by us.
You can also exercise your right to restrict our processing of your personal information (as described below) whilst we consider your request.
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 defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Service and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.
Restriction of Processing to Storage Only
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. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (e.g., for the defense of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.
You may request we stop processing and just store the personal information we hold about you where:
• you believe the personal information is not accurate for the period it takes for us to verify whether it is accurate;
• you wish to erase the personal information as the processing we are doing is unlawful but you want us to retain the personal information but just store it instead; or
• you wish to erase the personal information as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defense of legal claims.
Objection
You have the right to object to our processing of personal information about you. We will consider your request in other circumstances as detailed below by contact us.
Announcements
We may from time to time send you announcements when we consider it necessary to do so (such as when we temporarily suspend The Service access for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.

Contact & Complaints
For the purposes of European Data Protection Law, the Data Controller is HONGKONG HRG INFORMATION TECHNOLOGY CO., LIMITED. In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance.
--Contact Information--
Name: HONGKONG HRG INFORMATION TECHNOLOGY CO., LIMITED
Mail: service@hrgame.com.cn
This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws.

Changes
If we make any material changes to this policy, we will post the updated policy here and notify our users. Please check this page frequently to see any updates or changes to this policy.

International Transfer
We may transfer information that we collect about you to affiliated entities, or to other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, and we take steps to ensure adequate safeguards are in place to enable transfer of information and the use and disclosure of information about you, including personal information, as described in this Privacy Policy.

Jurisdiction
This Privacy Policy and any action related thereto will be governed by the laws of People’s Republic of China without regard to its conflict of laws provisions. Any dispute arising from or in connection with this Policy shall be submitted to Shanghai International Economic and Trade Arbitration Commission/Shanghai International Arbitration Center ("SHIAC") for arbitration, which shall be conducted in accordance with SHIAC's arbitration rules in effect at the time of applying for arbitration. The seat of arbitration shall be Shanghai, China. The language to be used in the arbitral proceedings shall be Chinese. The arbitral award is final and binding upon both parties.

 

Appendix I Privacy Policy for California Residents
Effective date：May 31th, 2021

Introduction
This Privacy Policy and Notice for California Residents (“Notice”) applies to all visitors and users of HRG's games, online applications, and mobile applications who reside in the State of California (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this Notice.
This Notice does not apply to employment-related Personal Information collected from California-based employees, job applicants, contractors, or similar individuals.

PERSONAL INFORMATION WE COLLECT
Personal Information means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Information does not include:
(i) Publicly available information from government records.
(ii) Deidentified or aggregated consumer information.
(iii) Information excluded from the CCPA's scope, such as:
(iv) Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
(v) Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
In particular, we may have collected the following categories of Personal Information from consumers within the last twelve months:

Category	Examples
Identifiers	A name, account name, device ID, email address, IP address
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	A name, address, telephone number, signature, government-issued ID, bank account number, or other financial information. Some Personal Information included in this category may overlap with other categories
Protected classification characteristics under California or federal law	Age, race, gender, national origin
Commercial information	Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
Internet or other similar network activity	Browsing history, search history, or any information on a consumer's interaction with a website, application, or advertisement
Geolocation data	Physical location, IP address, device shared location, and Wi-Fi connection location
Inferences drawn from other Personal Information	Profile reflecting a person's preferences

We will not collect information associated with your physical location, telephone number, or government-issued ID without first obtaining your consent.

SOURCES OF PERSONAL INFORMATION
HRG may collect the categories of Personal Information listed above from the following categories of sources:
(i) Directly from you.
(ii) Indirectly from you - for example, from your actions on our websites, games, and applications.
(iii) From service providers and/or third parties, including telecommunication service providers, location services, payment and auditing processors, and social media services.
(iv) From government agencies and public authorities.
(v) From other affiliate entities of HRG.

USE OF PERSONAL INFORMATION
HRG may use or disclose the Personal Information we collect for one or more of the following business purposes:
(i) To set up user accounts and provide services to the users.
(ii) To promote our products and services.
(iii) To create, maintain, customize, and secure your account with us.
(iv) To personalize your experience with our products and services, and to deliver contents or offerings relevant to your interests.
(v) To help maintain the safety, security, and integrity of our website, products and services, databases and other technology assets, and business.
(vi) For testing, research, analysis, and product development, including to develop and improve our website, products, and services.
(vii) To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
(viii) To enforce our terms of service and other agreements, policies, and standards.
(ix) To work with third parties and service providers to evaluate their marketing services.
(x) To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our users is among the assets transferred.
We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

DISCLOSURE OF PERSONAL INFORMATION
In the preceding twelve months, we may have disclosed the following categories of Personal Information to the following categories of persons or entities:

Category of Information	Categories of Persons or Entities to Whom the Information Was Disclosed
Identifiers	•dentifiusersCustomer service vendors • Data analysis vendors • Payment and auditing processors • Social media services
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	• Other users • Customer service vendors • Data analysis vendors • Payment and auditing processors • Social media services • Location services
Protected classification characteristics under California or federal law	• Other users • Data analysis vendors • Social media services
Geolocation data	• Other users • Telecommunication service providers • Customer service vendors • Location services

We do not sell any of your Personal Information.

FINANCIAL INCENTIVES
We may offer nominal in-game currency and rewards to users when they choose to provide their email addresses and/or phone numbers. HRG may use the information collected to serve the user with more relevant promotional materials, and the value of a user's email address and phone number to HRG is reasonably related to the value of the corresponding in-game currency and rewards. Users can withdraw from this incentive at any time by requesting deletion of the collected information, as provided below.

CALIFORNIA CONSUMER RIGHTS REGARDING PERSONAL INFORMATION
The CCPA provides you with certain rights regarding your Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

The Right To Know
You have the right to request that we disclose to you certain information about our collection and use of your Personal Information over the preceding twelve months. Once we receive and confirm a verifiable consumer request, we will disclose to you the following information responsive to your request:
(i) The categories of Personal Information we collected about you.
(ii) The categories of sources from which the Personal Information was collected.
(iii) The categories of third parties with which we share Personal Information.
(iv) The specific pieces of Personal Information we have collected about you.
(vi) Our business or commercial purposes for collecting that Personal Information.
(vii) If we disclosed your Personal Information for a business purpose, we will list such disclosures, identifying the Personal Information categories that each category of recipient obtained.

The Right To Request Deletion
You have the right to request that we delete any of your Personal Information that we collected from you and retained. Once we receive and confirm a verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
We may deny a deletion request if retaining the information is necessary for us or our service providers to:
(i) Complete the transaction for which the Personal Information was collected; provide a good or service requested by the California Consumer or reasonably anticipated within the context of a business's ongoing business relationship with the California Consumer or otherwise perform a contract between the business and the California Consumer.
(ii) Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
(iii) Debug to identify and repair errors that impair existing intended functionality.
(iv) Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
(v) Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
(vi) Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses' deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
(vii) To enable solely-internal uses that are reasonably aligned with the expectations of the consumer based on the consumer's relationship with the business.
(viii) Comply with a legal obligation.
(ix) Otherwise use the California Consumer's Personal Information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information.

Exercising the Right To Know and the Right To Request Deletion
To exercise the right to know and the right to request deletion, please submit a verifiable consumer request to us by either emailing us at service@hrgame.com.cn or contacting the in-game customer service.
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
HRG is required to respond to your verifiable consumer request no more than twice in a 12-month period. The verifiable consumer request must:

1. Provide sufficient information—for example, your name, address, or other information depending on the type of request and the sensitivity of the information requested—that allows HRG to reasonably verify that you are the person about whom HRG collected Personal Information or an authorized representative; and

(iii) Contain sufficient detail such that HRG is able to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and cannot confirm that the Personal Information belongs to you.
Making a verifiable consumer request does not require you to create an account with HRG. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format
HRG will respond to a verifiable consumer request within 45 days of its receipt when possible. If we require more time (up to 45 additional days), we will inform you in writing, within 45 days of receipt of the original request, of the extension period and the reason for the extension.
Any disclosures will cover only the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. HRG will deliver information by mail or electronically, at your election, and if provided electronically, the information shall be in a portable and, to the extent technically feasible, readily-useable format that allows you to transmit the information to another entity without hindrance.
We do not charge a fee to respond or process your verifiable consumer request unless it is manifestly unfounded, excessive, or repetitive. In such a case, we may charge a reasonable fee or refuse to act on the request, but we will inform you of the reasons for that decision and provide you with a cost estimate before completing the request.

Non-Discrimination
We will not discriminate against you because you have exercised any of your rights under the CCPA, including, but not limited to, by:
(i) Denying products or services to you;
(ii) Charging different prices or rates for products or services, including through the use of discounts or other benefits or imposing penalties;
(iii) Providing a different level or quality of products or services to you; or
(iv) Suggesting that you will receive a different price or rate for products or services or a different level or quality of products or services.

Contact Information
If you have any questions or comments about this Notice, the ways in which HRG collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us by either emailing us at service@hrgame.com.cn  or contacting the in-game customer service.

 

Email：service@hrgame.com.cn