MOBILE APP PRIVACY POLICY
This Privacy Policy governs your use of
the software application: GameStore (the "Mobile Application")
for mobile devices that was created by Snakebyte Digital Limited.
Snakebyte Digital Limited and/or its
subsidiary(ies) and/or affiliates (hereinafter collectively referred to as the "Company")
pledges to meet fully with the requirements of Cap 486 of the Personal Data
(Privacy) Ordinance of the Laws of the Hong Kong Special Administrative Region.
In doing so, the Company will ensure compliance by its staff to the strictest
standards of security and confidentiality in respect of all personal
information and data submitted by users via its website, its sub-domains, and
any other websites, media platforms, or applications including the Mobile Application
operated by the Company (hereinafter collectively referred to as the "Channels")
and the Company will not release such information to anyone without the prior
consent of the relevant user(s) of the Channels (whether registered or not)
(the "User" or the "Users"), except to the
authorised persons listed in Paragraph 3 below.
Users are strongly recommended to read
this Privacy Policy carefully in order to understand the Company's policy and
practices with regard to the treatment of personal information and data
provided by Users on the Channels. This Privacy Policy is applicable to both
registered and non-registered Users, and the provisions herein may be updated,
revised, varied, or amended from time to time as the Company deems necessary.
If Users have questions or concerns
regarding this Privacy Policy, they should first contact the Customer Service
of the Company via email to support@gamestoreapp.com.
1
Purpose
of Collection of Personal Data
1.1
In the
course of using the Channels, Users may disclose or be asked to provide
personal information and/or data. In order to benefit from and enjoy the
various services offered by the Channels, it may be necessary for Users to
provide the Company with their personal information and/or data. Although Users
are not obliged to provide the information and/or data as requested on the
Channels, the Company will not be able to render certain services on the
Channels in the event that Users fail to do so.
1.2
The
Company's purposes for collection of information and data on the Channels
include but are not limited to the following:
(a) to perform the daily
operation of the services provided to Users;
(b) to identify Users who have
posted advertisements, materials, messages, photos, views, or comments or such
other information (collectively "Information") on the
Channels;
(c)
to
identify Users who have viewed the Information posted on the Channels;
(d) to provide Users with
marketing and promotional materials for their enjoyment of benefits as members
of the Channels (for further details, please refer to Paragraph 4 entitled
"Subscription of Newsletter/Promotional Materials/Marketing
Materials" below);
(e) to identify Users who have
enjoyed their benefits as members of the Channels by receiving and using
marketing and promotional materials;
(f)
to allow
members of the Channels to enjoy their benefits as members by enrolling for
special events hosted by the Company;
(g) to enable the Company to
select and present information that matches the needs of Users or to create
personalised contents;
(h) to design and provide
products and services to Users in relation to the above purposes;
(i)
to
compile and analyse aggregate statistics about Users' use of the Channels and
service usage by Users for the Company's internal use; and
(j)
to
facilitate the Company use of Users' personal data for purposes relating to the
provision of services offered by the Company and marketing services, special
events, and/or promotions of the Company and/or its clients.
1.3
The
Company strives to collect only personal data which is necessary and adequate
but not excessive in relation to the purposes set out above.
1.4
If the
User is under the age of eighteen (18), the Company strongly recommends that he
or she seeks prior consent from a parent or guardian, who may contact the
responsible personnel of the Company via email to support@gamestoreapp.com to
register the User as member of the Channels.
1.5
If the
Company requires the User's personal data for a purpose other than those set
out hereinabove, the Company may request the User's prescribed consent to the
same. If the User is a minor, the prescribed consent should be given by his or
her parent or guardian.
2
Collection
of Personal Data
2.1
The
Company may collect personal information and/or data about the User, such as
his or her name, login ID and password, address, email address, phone number,
age, sex, date of birth, country of residence, nationality, education level,
and work experience that is not otherwise publicly available. Occasionally, the
Company may also collect additional personal information and/or data from the
User in connection with contests, surveys, or special offers.
2.2
Only
duly authorised staff of the Company will be permitted to access the User's
personal information and data, and the Company shall not release such personal
information and data to any third parties save and except for the circumstances
listed out under the Paragraph 3 entitled "Disclosure or Transfer of
Data".
3
Disclosure
or Transfer of Data
3.1
The
Company agrees to take all practicable steps to keep all personal information
and data of Users confidential and/or undisclosed, subject to the following
conditions.
Generally speaking, the
Company will only disclose and/or transfer the User's personal information
and/or data to the Company's personnel and staff for the purpose of providing
services to the User. However, the Company may disclose and/or transfer such
information and/or data to third parties under the following circumstances:
(a) where the information and/or
data is disclosed and/or transferred to any third-party suppliers or external
service providers who have been duly authorised by the Company to use such
information and/or data and who will facilitate the services on the Channels,
under a duty of confidentiality;
(b) where the information and/or
data is disclosed and/or transferred to any agents or associates of the Company
who have been duly authorised by the Company to use such information and/or
data;
(c)
where
the Company needs to protect, and defend its rights and property;
(d) where the Company considers
necessary to do so in order to comply with the applicable laws and regulations,
including without limitation compliance with a judicial proceeding, court
order, or legal process served on the Channels; and
(e) where the Company deems
necessary in order to maintain and improve the services on the Channels.
3.2
Personal
data collected via the Channels may be transferred, stored, and processed in
any country in which the Company operates. By using the Channels, the User is
deemed to have agreed to, consented to, and authorised the Company to disclose
and/or transfer his or her personal information and data under the
circumstances stated above, as well as to any transfer of information
(including the Information) outside of the User's country.
4
Subscription
to Newsletter, Promotional Materials, or Marketing Materials
4.1
The
Company may from time to time send to members and Users of the Channels
newsletters, promotional materials, and marketing materials based on the
personal information and data that they have provided to the Company. The
Company may use the User's data in direct marketing and the Company requires
the User's consent (which includes an indication of no objection) for that
purpose. In this connection, please note that:
(a) the name, login ID and password,
contact details, age, sex, date of birth, country of residence, nationality,
education level, and work experience of the User held by the Company from time
to time may be used by the Company and/or its authorised personnel or staff in
direct marketing;
(b) the following classes of
services, products, and subjects may be marketed:
(i)
products
and services offered by the Company and its advertisers (the names of such
entities can be found in the relevant advertisements and/or promotional or
marketing materials for the relevant products and services, as the case may
be); or
(ii)
donations
and contributions for charitable and/or non-profit making purposes;
(c)
the
above products, services, and subjects may be provided or (in the case of
donations and contributions) solicited by the Company and/or:
(i)
third
party service providers providing the products, services, and subjects listed
in Paragraph 4.1(b) above; and
(ii)
charitable
or non-profit marking organisations;
(d) in addition to marketing the
above services, products, and subjects itself, the Company also intends to
provide the data described in Paragraph 4.1(a) above to all or any of the
persons described in Paragraph 4.1(b)(ii) above for use by them in
marketing those services, products, and subjects, and the Company requires the
User's written consent (which includes an indication of no objection) for that
purpose; and
(e) the Company may receive
money or other property in return for providing the data to the other persons
in Paragraph 4.1(b)(ii) above and, when requesting the User's written consent
as described in Paragraph 4.1 above, the Company will inform the User if the
Company receives any money or other property in return for providing the data
to the other persons.
1.2
Suitable
measures are implemented to make available to such members the options to opt
out of receiving such materials. In this regard, Users may choose to sign up or
unsubscribe for such materials by logging into the registration or user account
maintenance webpage, or by clicking on the automatic link appearing in each
newsletter/message, or by contacting the Customer Service of the Company via
email to support@gamestoreapp.com.
2
Access
2.1
Any User
is entitled to request access to or make amendments to his or her own personal
information and data kept with the Company by contacting the Customer Service of the
Company via email to support@gamestoreapp.com.
2.2
In the
event that a User wishes to access or amend his or her personal information and
data, the Company may request him or her to provide personal details in order
to verify and confirm his or her identity. A HKID card number or passport
number or business registration certificate number cannot be amended unless
such data is proved to be inaccurate. The Company is required to respond to a User's
request within twenty-one (21) days of his or her request and will endeavour to
do so wherever possible.
3
Cookies
and Log Files
3.1
The
Company does not collect any personally identifiable information from any User
whilst they visit and browse the Channels, save and except where such
information of the User is expressly requested. When Users access the Channels,
the Company records their visits only and does not collect their personal
information or data. The Channels' server software will also record the domain
name server address and track the pages the Users visit and store such
information in cookies, and gather and store information like Internet protocol
(IP) addresses, browser type, referring/exit pages, operating system, date/time
stamp, and clickstream data in log files. All these are done without the Users
being aware that they are occurring.
3.2
The
Company and third-party vendors engaged by the Company use the Company's
cookies and third-party cookies, such as the Google Analytics cookies, together
to inform, optimise, and serve marketing materials based on the Users' past
visits to the Channels.
3.3
The
Company does not link the information and data automatically collected in the
above manner to any personally identifiable information. The Company generally
uses such automatically collected information and data to estimate the audience
size of the Channels, gauge the popularity of various parts of the Channels,
track Users' movements and number of entries in the Company's promotional
activities and special events, measure Users' traffic patterns, and administer
the Channels. Such automatically collected information and data will not be
disclosed save and except in accordance with the Paragraph 3 entitled "Disclosure
or Transfer of Data"
4
Google
Analytics
4.1
Google
Analytics Advertising Features ("Features") are implemented on
the Channels. The Features which the Company has implemented are based on
Google Analytics Demographics and Interest Reporting.
4.2
Google
Analytics is a web analysis service provided by Google which utilises the data
collected to track and examine the use of the Channels to prepare reports on
the Users' activities and share them with other Google services. Google may use
the data collected to contextualise and personalise the marketing materials of
its own advertising network.
4.3
Users
can opt out of Google Analytics by contacting the Customer Service of the Company via
email to support@gamestoreapp.com.
5
Links
to Other Websites, Media Platforms, or Applications
5.1
The
Channels may provide links to other websites, media platforms, or applications
which are not owned or controlled by the Company. Personal information and data
from Users may be collected on these other websites, media platforms, or
applications when Users visit such websites, media platforms, or applications
and make use of the services provided therein. Where and when Users decide to
click on any advertisement or hyperlink on the Channels which grants Users
access to another website, media platform, or application, the protection of
Users' personal information and data which are deemed to be private and
confidential may be exposed in these other websites, media platforms, or
applications.
5.2
Non-registered
Users who gain access to the Channels via their accounts in online social
networking tools (including but not limited to Facebook) are deemed to have
consented to the terms of this Privacy Policy, and such Users' personal data
which they have provided to those networking tools may be obtained by the Company
and be used by the Company and its authorised persons in and outside of the
User's country for the purpose of providing services and marketing materials to
the Users. These Users are deemed to have consented to the Company and its
authorised personnel's access and use of their personal data so obtained,
subject to the other provisions of the Privacy Policy.
5.3
This
Privacy Policy is only applicable to the Channels. Users are reminded that this
Privacy Policy grants no protection to Users' personal information and data
that may be exposed on websites, media platforms, or applications other than
the Channels, and the Company is not responsible for the privacy practices of
such other websites, media platforms, or applications. Users are strongly
recommended to refer to the privacy policies of such other websites, media
platforms, or applications.
6
Security
6.1
The
security of Users' personal information and data is important to the Company.
The Company will always strive to ensure that Users' personal information and
data is protected against unauthorised access. The Company has implemented
appropriate electronic and managerial measures in order to safeguard, protect,
and secure Users' personal information and data.
6.2
All
personal data and information provided by Users is only accessible by the
authorised personnel of the Company or its authorised third parties, and such
personnel shall be instructed to observe the terms of this Privacy Policy when
accessing such personal information and data. Users may rest assured that their
personal information and data will only be kept for as long as is necessary to fulfil
the purpose for which it is collected. Registered Users should safeguard their
unique usernames and passwords by keeping them secret and confidential and by
never sharing these details with anyone.
6.3
The
Company uses third-party payment gateway service providers to facilitate
electronic transactions on the Channels. Regarding sensitive information
provided by Users, such as credit card numbers for completing any electronic
transactions, the web browser and third-party payment gateway communicate such
information using secure socket layer technology (SSL).
6.4
The
Company follows generally accepted industry standards to protect the personal
information and data submitted by Users to the Channels, both during
transmission and once the Company receives it. However, no method of
transmission over the Internet, or method of electronic storage, is completely
secure. Therefore, while the Company strives to protect Users' personal
information and data against unauthorised access, the Company cannot guarantee
its absolute security.
7
Retention
of Personal Data
Once the Company has
obtained a User's personal information and/or data, it will be maintained
securely in the Company's system. Subject to legal requirements, the personal
information and/or data of Users will be retained by the Company after
deactivation of the relevant service until the User requests the Company in
writing to erase his or her own personal information and/or data from the
Company's database or to terminate his or her membership of the Channels.
8
Changes
in this Privacy Policy
The Company reserves the
right to update, revise, modify, or amend this Privacy Policy in the following
manner at any time as the Company deems necessary and Users are strongly
recommended to review this Privacy Policy frequently. If the Company decides to
update, revise, modify, or amend this Privacy Policy, the Company will post
those changes to this webpage and/or other places the Company deems appropriate
so that Users are aware of what information the Company collects, how the
Company uses it, and under what circumstances, if any, the Company discloses
it.
9
Governing
Law and Jurisdiction
Nothing in this Privacy
Policy shall limit the rights of the User under the Personal Data (Privacy)
Ordinance. This Privacy Policy shall be governed by the laws of the Hong Kong
Special Administrative Region. You agree to submit to the exclusive
jurisdiction of the Hong Kong courts.
For any query, please contact Customer
Service of the Company via email to support@gamestoreapp.com.
