CHINESE PARENTS
PRIVACY POLICY
INTRODUCTION
Welcome to Chinese Parents! Thank you for your trust and support in our games.
We LITTORAL GAMES PTE. LTD. (hereinafter referred to as “Littoral games”, “we”, “us”, or “our”), have always been dedicated to provide our users with optimized gaming experiences, while at the same time recognizing and respecting the importance to safeguard the privacy and personal information of our players (hereinafter referred to as “you” or “User(s)”) who access Chinese Parents (hereinafter referred to as the “App”) whether through mobile devices other platforms such as Facebook or Google.
This online Privacy Policy has been adopted to explain:
（1）  how we collect, store, use and transfer or disclose your personal data;
（2）  the ways we collect personal data and why we do so;
（3）  your rights and choices regarding your personal data;
（4）  use of personal data for targeted advertising and marketing purposes.
We may update, adjust or revise this Privacy Policy periodically by posting a modified version, we will notify and if necessary, obtain your consent to ensure your awareness of any changes. In the event of material changes, an announcement will be made in advance. In return you acknowledge to review and check back at the Privacy Policy from time to time, your continued use of the App will signify your acceptance of these changes.
Before you start accessing or using the App, please be sure to carefully read and understand this Privacy Policy. If upon reading this Privacy Policy you voluntarily click or tick "I agree" or complete a similar authorization process, it means that you have read and fully accepted the terms of this Privacy Policy, knowingly and explicitly consent to our collection and h andling of your personal data in accordance with the provisions hereunder in order to optimize the services offered. If you do not accept all or part of this Privacy Policy, or do not fully understand its meaning, you may feel free to contact us immediately in accordance with Article 10, and we will be happy to explain further.
Please be noted that we recognize a special need to protect the privacy of children and will not knowingly collect or store any personal data from any minors. In view of this, the minimum age to create an account in the App is 13, and parental or guardian consent is mandatorily required before an account can be registered and personal data associated with it can be collected from any children above the age of 13 but under the age of 16. We encourage parents or guardians for children under the age of 16 but above 13 to carefully review this Privacy Policy in detail before giving their consent.
This Privacy Policy was last updated on March 9, 2023.
Table of Content
1	Personal data we collect and why we collect it
2	How we use your personal data
3	How is your personal data retained
4	How we use Cookies or similar technologies
5	With whom may your personal data be shared, accesses or transferred
6	Marketing and advertising
7	Your rights and choices
8	How we safeguard your data
9	Children and parental consent
10	What if you have a question or complaint
ARTICLE 1 PERSONAL DATA WE COLLECT AND WHY WE COLLECT IT
1.1  By downloading, using and accessing the App, you consent and acknowledge that the following personal data will be collected by us for the specified, explicit and legitimate purpose as indicated below or fo r the purpose to perform legal liabilities under applicable laws. In cases you refuse to provide any mandatory data collected for the following purposes, you may not be able to normally use or access some functions of the App.
No.	Function	Personal data collected	Purpose for collection
1	Account registration and connection	Mobile number or email address, username, account information, and password	(i) F or creation and registration of account;
			(ii) Allow access and login to services on the App;
			(iii) F or receiving updates of our services and receiving verification codes by email or SMS with your consent, through the email address or mobile number voluntarily provided by you;
2	Registration and connection using Facebook credentials	First a nd last name as well as other information made available to the public based on the User’s privacy settings	(iv) T o protect the safety and security of services and Users;
3	Registration and connection using Apple ID	Apple ID, name or temporary virtual email address	(v) Share in-game photos on the platform;
4	Registration and connection using Google	Information such as name, email address and profile picture depending on your settings in your Google account	(vi) S ee which of your friends are playing the same game and their progress; or
5	Verification of age	Date of birth as voluntarily provided by you, and we will treat your self-reported data as the basis for determining the authenticity of your age	(i) Verify your age for us to decide whether steps shall be taken to limit your access to the App and whether parental consent is legally required
6	For system functions	Device ID, device name, device type and version, version of your device’s  operating system, click history of the App, IP address, device identifier (such as IMEI, IMSI, MAC address), application ID, network access method, type, status, and network quality	(i) A llow your connection to our servers;
			(ii) A llow us to provide you with feedback of your gaming experience, optimize the performance a nd functionality of our services and user experience
7	Verify and confirm payments	Order details/history, payment method, purchase details, amount of purchase order, order completion time and order number	(i) T o verify payments (with other payment providers) and combat fraud and illegal activity;
			(ii) A ssist you to keep track of your purchase histories;
			(iii) M aximize the security of your virtual items purchased
8	Customer service	Your account ID, contact details provided by you and any information you provide to us in communication when you seek for our technical or customer support when you encounter with enquires, recommendations or complaints	(i) F or ease of our feedback and response to your requests;
			(ii) To provide personalized support as per you request and further improve our services;
			(iii) correct bugs or errors within the App
9	Security related information	Device identifier, IP address, login time and date, time zone	(i) R espond to your desires and preferences, including languages and country of location;
			(ii) To protect and enhance the integrity, safety and security of our services;
			(iii) To combat acts that has the potential to disrupt our gaming environment or interfere with or disrupt the normal operation of the App (such as to detect piracy, scan plug-ins, checking authenticity of account owner, prevent fraud etc.)
1.2  For the purposes as stipulated above, our affiliated company may be allowed to process, analyze you information on the condition that they will act in compliance with the terms and conditions of this Privacy Policy. For the purpose of this article, affiliated company refers to an entity that directly or indirectly controls, is controlled by or is under the common control of LITTORAL GAMES PTE. LTD .
1.3  B y agreeing to our Privacy Policy, you agree and acknowledge that we may analyze, profile, segment, merge and/or all personal data collected for the specified, explicit and legitimate purposes stipulated under this Privacy Policy.
1.4  Under any circumstances where our collection of your personal data is based on your express consent, you may elect to withdraw or refuse to such consent at any time by changing your in-App privacy settings or by contacting us in the ways described in this Privacy Policy.
1.5  During your use of the App, we may need your consent and permission before access to your device’s specific functionality for the purposes as set out below. Please be aware that we will not automatically turn on those functions on your device without having obtained your specific consent in advance.
Function	Purpose	Whether and when your consent is needed	Whether you can withdraw such consent
Internet connection	Allow connection to t he internet	Yes, your consent is needed before first opening the App	Yes, any time in your in-App settings
Storage	Read contents of the memory card;	Yes, your consent is needed before first opening the App	Yes, any time in your in-App settings
	Modify or delete SD Card contents
You may turn off permissions or withdraw your consent to our access to the above functions of your device and deny us from collecting any such personal data any time in your in-App settings. While please be noted that you may not be able to utilize certain services in the App if the associated permission or consent has been withdrawn.
ARTICLE 2 HOW WE USE YOUR PERSONAL DATA
2.1  W e will use your personal data collected by us in accordance with this Privacy Policy for the specified, explicit and legitimate purposes as described hereunder.
2.2  In cases where we will require additional personal data for purposes not otherwise stated under this Privacy Policy, or when such personal data will be used for purposes other than the ones as described hereunder (expect where we are to perform the legal liabilities under applicable laws) , we will seek for your additional consent in advance.
ARTICLE 3 HOW IS YOUR PERSONAL DATA RETAINED
3.1  Y ou acknowledge and agree that your personal data collected by us may not be located in your country of residence and can be accessed or processed by our support team, and/or affiliated companies around the world. Regardless of where our servers are located, we will be dedicated to safeguard and secure your personal data and rights in accordance with this Privacy policy and any applicable laws including the California Consumer Privacy Act of 2018 (“ CCPA ”) and the Children’s Online Privacy Protection Act (“ COPPA ”) governing in the United States or the General Data Protection Regulation (“ GDPR ”) governing in the European Union.
3.2  You acknowledge and agree that your personal data collected by us will be retained and used for so long as your account is active and only as needed to provide you with the services in the App unless your account or data is requested to be deleted by you or as otherwise required by law .
3.3  I n cases we received your request to deactivate or delete your account or your personal data, we will immediately remove and delete such data in a permanent and non-reversable way to which all gaming history will be permanently deleted, unless there is a mandatory requirement for us to retain some or all of the data in order to enforce our legal obligations, to maintain financial records and for technical needs. While we promise to only store your information as long as necessary to fulfil the purposes for which the information is collected or where the applicable law provides for longer storage and retention period. Upon the expiration of such period, your personal data will be deleted, blocked or be rendered anonymous as provided by applicable law.
ARTICLE 4 HOW WE USE COOKIES OR SIMILAR TECHNOLOGIES
4.1  We and our third-party partners may use tracking technologies such as Cookies to tailor and optimize your personalized user experiences. We and our third-party partners store cookies, flash cookies, or other local storage provided by your browser (or associated application) on your computer or mobile device that typically contain identifiers, site names, and some numbers and characters (collectively, " Cookies "). We and our third-party partners may collect information about you through user login Cookies and use the information for the following purposes:
(i)  User login Cookies: Cookies can notify us when you access the App, so that we can verify your identity information to ensure the security of your account;
(ii)  Analytical Cookies: Cookies allow us to understand your in-game activities and enable us to improve our products and services.
4.2  The collection and use of your information by third-party partners through Cookies is not subject to this Privacy Policy, but is governed by their own information protection statements, and we are not responsible for Cookies or similar technologies of third parties.
4.3 You may wish to manage or disable our use of Cookies on the condition that your browser permits, for more information please refer to https://www.aboutcookies.org/ , but your ability to use some features or function of our services may be limited.
ARTICLE 5 WITH WHOM MAY YOUR PERSONAL DATA BE SHARED, ACCESSES OR TRANSFERRED
5.1  Share
We may share your personal data with third parties only in the ways that are described in this Privacy Policy and you acknowledge the occurrence of such sharing of your personal data:
5.1.1  W here your explicit consent or authorization was granted in advance, or you request us to share your personal data with third parties by email or other means;
5.1.2  Provision in accordance with applicable laws and regulations, or in accordance with the mandatory requirements of the competent government departments;
5.1.3  Sharing with the parents or guardian of the minors under the age of 16: for example, if you are a minor, we will share your purchase history with your guardian so that they can confirm and process the transactions performed by the minor;
5.1.4  Sharing with our affiliated companies: We may share your personal data with our affiliates; however, we will only share such data to the necessary extent and be bound by the terms and conditions stated under this Privacy Policy; affiliates will also take the same security measures to ensure the safety of your personal data in accordance with this Privacy Policy;
5.1.5  Share with our business partners: We may share your personal data with our business partners, but we will only share data that is non-personally identifiable on its own, aggregated or public with third parties for specified, explicit, legitimate and necessary purposes as stated under this Privacy Policy. Our partners are not authorized to use or process the personal data shared for any purposes other than the ones stipulated hereunder. The types of our business partners include:
(i)  Suppliers of goods or professional technical services : We may share your personal data with third parties who support our functionality. This support includes providing us with infrastructure technology services, payment services, data processing, social networking portals etc. The purpose for us to share this information is as necessary to fulfill the functions of our services;
a)  Please be noted that your payment details are fully handled by payment service providers, and we do not collect or process your actual payment details including card number or security code. The only information we collect will be those concerning transaction date, amount and items purchased.
(ii)  Advertising and marketing services contractors: for how we share data to such third parties please refer to Article 6 below.
5.2  T ransfer
We will not transfer or sell your personal data to any company, organization or individual, but when it comes to mergers, acquisitions, re-organization, bankruptcy liquidations or other similar events, if it involves the transfer of personal information, we will inform you of the relevant situation and require new companies and organizations holding your personal data to continue to be bound by this Privacy Policy, otherwise we will require such company and organization to re-obtain your authorization and consent.
5.3  D isclosure
5.3.1  E xcept as otherwise stated under this Privacy Policy or as mandatorily required by law, we will not disclose any of your personal data in public.
5.3.2  W e reserve the right to disclose your personal data if we, in our good faith, believe that disclosing such data is necessary to identify, contact, or bring legal action against you, if (a) you are violating any other agreement(s) between you and us or otherwise damages us; (b) you are infringing third-parties’ rights and interests (including but not limited to intellectual property rights); and/or (c) we believe that it is necessary to prevent fraud or other illegal activities.
5.4  Please note that the information you voluntarily share or even publicly share when using our services may involve personal information of yourself and others. We strongly recommend you to not publicly share your and others’ personal data, if the information involved contains the personal information of others, please obtain the consent of others before sharing or disclosing.
5.5  In accordance with relevant legal requirements, if we take necessary technical measures in an irreversible way where the data no longer relate to an identified or identifiable natural person, we may share, transfer or disclose such processed data without having obtained your express consent in advance.
ARTICLE 6 MARKETING AND ADVERTISING
6.1  I n order to show personalized advertisements in the App, you acknowledge and agree that on the condition that we have your consent in advance we may use your personal data that have undergone pseudonymization, meaning data which could be attributed to a natural person by the use of additional information to:
(i)  Deliver, target and improve our advertising;
(ii)  Improve advertising and other marketing and promotional activities.
6.2  We may also use your data to send you, or have our third-party partner to deliver newsletters, advertisements, market research or surveys. If you do not wish to receive any such information from us or from any third parties, you may opt out of such notifications via in-App settings or contact us.
6.3  Without your consent, we ensure that we will not use your data for marketing purposes, and after granting permission, you may also withdraw such consent at any time. For the avoidance of doubt, if we know that you are a registered user under the age of 16, we will not target you with advertising.
6.4  Third Party Partners
For a better gaming experience and to provide you with complete functions of the App, such as payment, third-party log-ins, mobile number verification and targeted advertisement, we may use third-party software development kits (SDKs) as applicable. These SDK service providers and our other third party partners may access and collect data regarding your activities and your device, including mobile identifiers, device information, system operation information, network status information, application list information, base station information, SIM card identification number (ICCID), SIM card serial number (simserial), log-on times etc.
A list of these partners are as below and they have their own privacy policies and security measures that you should be aware of and participate when they collect and process your data. We would encourage and recommend you to directly read and review their privacy policies and your privacy settings on applicable platforms frequently to ensure that you fully understand how much of your personal data is available on the platforms and how are they shared and used.
SDK or Third Party Partners	Link to their Privacy Policy
Meta Platforms, Inc.	https://www.facebook.com/policy.php
(Facebook Log-ins and shares)
Apple Inc.	https://www.apple.com/legal/privacy/data/en/sign-in-with-apple/
(IOS Log-ins)
Alphabet Inc.	https://policies.google.com/privacy
(Google Log-ins)
Unity	https://unity3d.com/legal/privacy-policy
Thinkingdata	https://docs.thinkingdata.cn/ta-manual/latest/en/installation/installation_menu/privacy.html#links-to-other-sites
Firebase	https://firebase.google.com/support/privacy
A RTICLE 7 YOUR RIGHTS AND CHOICES
7.1  During your use of the App, you can access, correct/modify, delete, object to how we use or share your personal data by contacting us, as well as exercising your right to change in-App privacy settings and to de-activate your account. You may feel free to contact us immediately in accordance with Article 10 of this Privacy Policy, and your comments will be processed in a timely manner, but you acknowledge that upon receiving such request, we may require you to provide relevant information to confirm that you are the user from who we collected the personal data.
7.2  Right of access : You have the right to request for the following free of charge, except where according to our reasonable judgment, your request affects or will affect the rights or freedom of other users or is manifestly unfounded or excessive:
(i)  t he purpose of collection and processing, whether your personal data has been collected, used or disclosed;
(ii)  t he categories of your personal data collected;
(iii)  t he categories of sources from which your personal data is collected;
(iv)  t he recipients or categories of recipient to whom the personal data have been or will be disclosed.
7.3  R ight to rectification
In cases where your personal data is inaccurate, not up-to-date or incomplete for the purposes it was collected for, you have the right to request us to rectify such personal data without undue delay.
7.4  Right to erasure
You have the right to request for deletion of your personal data if:
(i)  such data is no longer necessary in relation to the purposes for which they were collected or processed as stipulated under this Privacy Policy;
(ii)  the deletion was based on a legal ground.
Y ou acknowledge that as a result of the deletion, you will lose access to related services in the App, which may include your account, subscriptions and App-related information linked to such account and you may lose the possibility to access other services through the Accoun t.
7.5  R ight to restriction of processing
You have the right to restrict the processing of your personal data under the conditions set out in Article 18 of the GDPR or any other applicable laws in your country of residence.
You acknowledge that the App require processing of necessary personal data in order to enable its functioning. When you withdraw or restrict your consent for us to process your personal data, we will not be able to continue to provide you with the services corresponding to the withdrawal of consent .
7.6  R ight to data portability
You have the right to receive your personal data in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller under the conditions set out in Article 20 of the GDPR or any other applicable laws in your country of residence.
7.7  R ight to object
You have the right to object our processing of your personal data, including the use of automated processing or profiling by changing your in-App privacy settings or contact us in accordance with Article 10 of this Privacy Policy.
If you object, we will no longer process your personal data unless there are compelling and prevailing legitimate grounds of processing as described in Article 21 of the GDPR or any other applicable laws in your country of residence; in particular, if the data is necessary for the establishment, exercise or defense of legal claims.
A RTICLE 8 HOW WE SAFEGUARD YOUR DATA
8.1  W e value and recognize the importance to your privacy and the need to providing a secure environment for them. In order to protect your personal data from unauthorized access, disclosure, alteration, loss or destruction, we have adopted network security and data protection technology and management measures, such as:
(i)  formulating and implementing internal security management systems and operating manuals;
(ii)  setting up internal network security and responsible persons;
(iii)  taking technical measures to prevent computer viruses and network attacks, network intrusions and other harmful network security behaviors;
(iv)  monitoring and recording network operation status and network security incidents;
(v)  taking data backup, data encryption, employee access control measures, employee training and other data safety measures.
8.2  Please be aware that although we will do our best to ensure or guarantee the security of any data you provide to us, the internet environment and transmission of information via the internet is not 100% secure, and we are not responsible for any hacking, cyber-attacks, risks and losses arising therefrom or related to it. Therefore, we strongly urge you to take every possible precaution to protect your personal data when using our services, including but not limited to changing your passwords from time to time, not reflecting your real name or other personal data in registration, using a combination of letters and numbers when creating passwords, using a secure browser and/or taking other possible security measures. Please note that for security reasons, we store passwords in encrypted form.
8.3  After the unfortunate occurrence of a personal information security incident, we will promptly inform you with the following items in accordance with the requirements of laws and regulations:
(i)  the basic situation and possible impact of the security incident;
(ii)  the measures we have taken or will take;
(iii)  suggestions on measures that you can take independently on yourself;
(iv)  any remedial measures for you.
We will promptly inform you of the relevant circumstances of the incident by means of application push, email, text message, telephone, etc., and when it is difficult to inform each user one by one, we will take a reasonable and effective way to issue an announcement. At the same time, we will also take the initiative to report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.
ARTICLE 9 CHILDREN AND PARENTAL CONSENT
9.1  There is a special need to protect children and minor’s privacy online, in view of this our App are not directed to children under 13. By using our App with a registered account, you present that you are of the age above 13, if you are under the age of 16 please do not independently send any personal data about yourself to us, including your name, address, telephone number, or email address.
9.2  We do not and will now knowingly collect personal data from children under the age of 16, without the consent from their parents or guardians. We strongly urge parents and guardians to instruct their children never to disclose or give out their personal data when using our services without the prior permission of their parent/guardian. If we learn that we have collected personal data about a child with no consent, we will delete that data as quickly as possible.
9.3  In addition to the above, we may take additional steps to limit access or certain features of our services in the App when a user indicates that they are under the age of 16.
9.4  I f you believe that we might have unintentionally collected information from or about a child under the age of 13, please contact us in accordance with Article 10, and we will delete such information as quickly as possible.
A RTICLE 10 WHAT IF YOU HAVE A QUESTION OR COMPLAINT
10.1  I f you’ve got any questions about this Privacy Policy or personal data protection, or wish to file a complaint or exercise your right as stated hereunder. You may contact us at any time via the following:
Name of our contact person: Bin Wang
Attn: Privacy
E mail: contact@littoralgames.com
10.2  In general, we will respond within fifteen (15) working days upon receiving your written request. If you are not satisfied with our response, especially if our personal data processing harms your legitimate rights and interests, you may also elect to complain or report to the regulatory authorities.