Effective Date of Current Policy: March 1, 2025

1.Introduction


This Privacy Policy is incorporated by reference into the Hong Kong Happy Time Games Terms of Service. (The “Terms”). The terms “Hong Kong Happy Time Games,” “we,” and “us” include Hong Kong Happy Time Mutual Entertainment CO., Limited. This Privacy Policy explains our online and offline information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can opt out of a use or correct or change such information.

2.Information Use


This Privacy Policy applies to Personal Information that is Processed by Hong Kong Happy Time Games in the course of our business, including on websites (each a “Site” or “Sites”), mobile applications, forums. All individuals whose responsibilities include the Processing of Personal Information on behalf of Hong Kong Happy Time Games are expected to protect that data by adherence to this Privacy Policy.


3.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. You give us information about you:
nowhen you register for the Game (including your nominated nickname, and information we import from your connected social media account (e.g. Facebook, Twitter or Apple sign-in account) in order to set up your profile, including your name as it appears on your social media profile and your profile picture;Develop new products and Services;
nowhen you set up your profile for the Game (including information you voluntarily elect to provide in order to customise gameplay, such as gender);
owhen you submit your contact details to us (including your name, email address and physical address) as part of promotional activities for the Game;
owhen you make purchases in the Game (in which case we will process the information you provide to us to facilitate the payment).
.Information we collect about you. We automatically collect certain data from you when you use the Game and/or the Community Website, including your IP address, physical location and device information (such as device type, network data, OS) and information regarding your use of the Game and/or the Community Website, 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 Game Services. You may provide additional information as part of your profile (such as gender). You may also provide or generate information when you communicate with other users in the Game (e.g., chat log data, chat content) behalf of Hong Kong Happy Time Games are expected to protect that data by adherence to this Privacy Policy.


4.How Hong Kong Happy Time Games use your information


4.1.To Provide Products, Services, or Information Requested. Hong Kong Happy Time Games may use information about you to fulfill requests for products, Services, or information; including information about potential or future Services, including to:
1.Generally manage Individual information and accounts;
2.Respond to questions, comments, and other requests;
3.Provide access to certain areas, functionalities, and features of Hong Kong Happy Time Games’ Services;
4.Contact you to answer requests for customer support or technical support;
5.Allow you to register for events.
4.2.Administrative Purposes. Hong Kong Happy Time Games may use Personal Information about you for its administrative purposes, including to:
1.Measure interest in Hong Kong Happy Time Games’ Services;
2.Develop new products and Services;
3.Ensure internal quality control;
4.Verify Individual identity;
5.Communicate about Individual accounts and activities on Hong Kong Happy Time Games’ Services and systems, and, in Hong Kong Happy Time Games’ discretion, changes to any Hong Kong Happy Time Games Policy;
6.Send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance;
7.Process payment for products or services purchased;
8.Process applications and transactions;
9.Prevent potentially prohibited or illegal activities;
10.Enforce our Terms.
4.3.Marketing Hong Kong Happy Time Games Products and Services. Hong Kong Happy Time Games may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content, product, or Services. Hong Kong Happy Time Games may provide you with these materials by message, phone, postal mail, facsimile, email or other communication means, as permitted by applicable law. Such uses include:
1.To tailor content, advertisements, and offers;
2.To notify you about offers, products, and services that may be of interest to you;
3.To provide Services to you and/or a Third-Party;
4.For other purposes disclosed at the time that Individuals provide Personal Information; or
5.Otherwise with your consent.
You may contact us at any time to opt-out of the use of your Personal Information for marketing purposes, as further described in Section 6 below.
4.4.Research and Development. B Hong Kong Happy Time Games may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, Hong Kong Happy Time Games may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
4.5.Services via Mobile Devices. From time to time, Hong Kong Happy Time Games may provide Services that are specifically designed to be compatible and used on mobile devices. Hong Kong Happy Time Games will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings, location information, mobile carrier, and the operating system of your device. Mobile versions of Hong Kong Happy Time Games’ Services may require that users log in with an account. In such cases, information about use of mobile versions of the Services may be associated with accounts. In addition, Hong Kong Happy Time Games may enable Individuals to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to Hong Kong Happy Time Games to enable Individuals to access accounts and to enable Hong Kong Happy Time Games to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. Hong Kong Happy Time Games may use personal or non-identifiable information transmitted to Hong Kong Happy Time Games to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Privacy Policy or in other notices Hong Kong Happy Time Games provides.
4.6.Anonymous and Aggregated Information Use. Hong Kong Happy Time Games may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Hong Kong Happy Time Games’ Services or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Hong Kong Happy Time Games may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Hong Kong Happy Time Games and with Third-Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
4.7.Sharing Content with Friends or Colleagues. Hong Kong Happy Time Games’ Services may offer various tools and functionalities. For example, Hong Kong Happy Time Games allows you to provide information about your friends through our referral services, such as “Tell a Friend.” Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Email addresses that you may provide for a friend or colleague will be used to send your friend or colleague the content or link you request, but will not be collected or otherwise used by Hong Kong Happy Time Games or any other Third-Parties for any other purpose.
4.8.Other Uses. Hong Kong Happy Time Games may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.


5.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. Our group companies have information security and access policies that limit access to our systems and technology. We also protect data through the use of technological protection measures such as encryption. Your personal information will remain subject to our technical and organisational controls and our policies and procedures (including this Privacy Policy).
Unfortunately, the 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.


6.Cookies, Mobile Advertising Indentifiers, Pixel Tags/Web Beacons, Analytics Information, And Interest-Based Advertising


We, as well as Third-Parties that provide content, advertising, or other functionality on our Services, may use mobile advertising identifiers, cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone, or other devices (referred to collectively as a "device") that allow us to record certain pieces of information whenever you visit or interact with our Services, and to recognize you across devices.
6.1.Mobile Advertising Identifiers. Mobile advertising IDs are identifiers used by mobile operating systems (Apple and/or Android) and made available to advertising providers to gather metrics on mobile apps (Apple’s IDFA or Google’s AAID) to help advertisers provide ads that may be more relevant to your interests. Third-Party advertisers and advertising networks may use advertising identifiers collected from the Services to deliver advertisements they believe are relevant to you in other Third-Party apps.
6.2.Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Site may not work properly.
6.3.Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.
6.4.Social Media Widgets: Our Services include social media features, such as links to Facebook and LinkedIn (that might include widgets, such as the share this button or other interactive mini-programs). These features may collect your IP address or which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. These social media features are either hosted by a Third-Party or hosted directly on our Services. Your interactions with these features are governed by the privacy policy of the company providing them.
Analytics. We may also use Google Analytics, Google Analytics Demographics and Interest Reporting, and Google Analytics for Firebase including Crashlytics and Fabric Data Processing, such as “Fabric Answers,” “Fabric Crashlytics,” or “Fabric Beta” provided by Google to collect information regarding visitor behavior and visitor demographics on some of our Services, to collect information regarding all or some of our Services, and to develop website content. This analytics data is not tied to any Personal Information. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. For more information about Google Analytics for Firebase, please visit https://firebase.google.com/docs/analytics/. You can opt out of Google’s collection and Processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout. Our uses of such Technologies fall into the following general categories:
6.5.Operationally Necessary. We may use cookies, web beacons, or other similar technologies that are necessary to the operation of our Services. This includes technologies that allow you access to our Services; that are required to identify irregular Services behavior, to prevent fraudulent activity and improve security; or that allow you to make use of our functions, such as shopping-carts, saved search, or similar functions;
6.6.Performance Related. We may use cookies, web beacons, or other similar technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use our Services, to determine if you have interacted with our Services, to determine whether you have viewed an item or link, or to improve our Services;
6.7.Functionality Related. We may use cookies, web beacons, or other similar technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content in our Services;
6.8.Advertising or Targeting Related. We may use Hong Kong Happy Time Games or Third-Party cookies and web beacons to deliver content, including advertisements relevant to your interests, in our Services or on Third-Party sites. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
If you would like to opt out of the Technologies we employ in our Services, you may do so by blocking, deleting, or disabling them as your browser or device permits.


7.Third-Party Payment Processing


We may sell virtual items or merchandise through our Services. When you make purchases through the Services, we process your payments through a Third-Party application, including the App store and SNS. The Third-Party application may collect certain financial information from you to process a payment on behalf of Hong Kong Happy Time Games, including your name, email address, address, and/or other information.


8.Children


The Services are not directed to children under 13, and Hong Kong Happy Time Games does not knowingly collect Personally Identifiable Information from children under 13. In addition, you are not permitted to use our Services if you do not meet the minimum age requirement applicable to our Services in your jurisdiction. If you learn that your child has provided us with Personal Information without your consent, you may alert us at cs@hongkongtanwan.com. If we learn that we have collected any Personal Information from children under 13 (and in jurisdictions under the age of 16 in the European Union), we will promptly take steps to delete such information and terminate the child’s account.


9.Data Deletion Requests


We are committed to protecting your privacy and ensuring transparency in how we handle your personal data. In accordance with applicable laws and platform requirements, this section explains how you can request the deletion of your personal data.

1. Your Right to Request Data Deletion

You have the right to request the deletion of your personal data held by us. This right applies in the following circumstances:

2. How to Submit a Data Deletion Request

To request the deletion of your personal data, please follow these steps:

  1. Contact Us: Send your request to our designated contact point using one of the following methods:

  1. Provide Necessary Information: To help us process your request efficiently, please include the following details in your request:

3. Our Process for Handling Data Deletion Requests

Once we receive your data deletion request, we will:

  1. Verify Your Identity: To protect your privacy, we will take steps to verify your identity before processing your request.
  2. Process Your Request: We will review your request and delete the relevant data within 30 days of receipt, unless the request is complex or requires additional time. If additional time is needed, we will notify you and explain the reason for the delay.
  3. Confirm Deletion: Once your data has been deleted, we will notify you via email or other preferred communication method.

4. Exceptions to Data Deletion

Please note that we may not be able to delete your data in certain circumstances, including but not limited to:

If you have any questions about this process or need assistance, please contact us at cs@hkhappytime.com.

10.Redress/Compliance and Accountability


If you have any questions about our privacy practices or this Privacy Policy, please contact Hong Kong Happy Time Games by email at cs@hkhappytime.com. We will address your concerns and attempt to resolve any privacy issues in a timely manner.
11.Changes To Our Privacy Policy
This Privacy Policy may change from time to time. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you use the Services after the updated Privacy Policy is posted on the Services. If at any point you do not agree to any portion of the Privacy Policy then in effect, you must immediately stop using the Services. We may revise this Privacy Policy in our sole discretion, so review it periodically. If you continue to use the Services made available to you after such changes have been made, you hereby provide your consent to the changes.