When you contract to use the Game or use the Community Website (the “Game Services” or “Services”), 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.
If you have any comments, questions or complaints regarding the processing of your personal information, you can contact us at Privacy@service.netease.com.
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:
o when 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;
o when you set up your profile for the Game (including information you voluntarily elect to provide in order to customise gameplay, such as gender);
o when you submit your contact details to us (including your name, email address and physical address) as part of promotional activities for the Game; and
o when 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).
You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies, or instruct the device (in the case of the Game) or web browser (in the case of the Community Website) 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 Game may be unable to operate as designed.
Our Service is not intended for children. If you are located in the European Economic Area and under the age of 16, you must not use the Service for any purpose.
How We Use Your Personal Information
We will use the information in the following ways and in accordance with the following legal bases:
Device Information (Device ID, Device Type, Operating System, CPU, RAM, IP address, MAC address): We use this information to provide and improve the Game Services such as: to allow users to download and install the Game on their devices; to record and keep track of requests from users of the Game; to detect the user network and device status when the user is playing the Game; and to correct bugs or errors that occur when the user is playing the Game. Use of Device Information is necessary to perform our contract with you to provide the Game.
Game Data (Level, Heroes, Score, chat log and etc): We use this information to provide Services to users as it is the basis of our Game. Use of Game Data is necessary to perform our contract with you to provide the Game.
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 (depending upon your location and the game server you select). Our servers are located in:
• the United States; and
• the People’s Republic of China (“PRC”); and
• the European Union
We share your personal information with selected third parties in and outside your country, including:
• third parties that provide services in support of the Game and the Community Website, including:
o Amazon Web Services (“AWS”), located in the United States, that processes download and instalment information, account set-up and log-in information, user log information, purchase information, notification push information, social sharing information, on the basis of Privacy-Shield certified, for the purpose of hosting the Game;
o Facebook, located in the United States, that processes Device ID and some of in-app activities, on the basis of Privacy-Shield certified, for the purpose of the evaluation of its marketing services;
o Amap, located in the United States, that processes physical locations, on the basis of the performance of our contract with you, for the purpose of providing in-app Location-Based Service;
o Apple, located in the United States, that processes of purchase information, on the basis of the performance of our contract with you, for the purpose of sign-in function and providing in-app purchase;
o Google, located in the United States, that processes of purchase information, on the basis of Privacy-Shield certified, for the purpose of providing in-app purchase;
o Helpshift, located in the United States, that processes of Registration Information and Device Information, on the basis of Privacy-Shield certified, for the purpose of providing in-app customer support;
• related group companies, with whom we share all of your personal information to operate the Game Services. The transfers contemplated above are made pursuant to our contract with you.
• law enforcement agencies, public authorities or other judicial bodies and organisations. 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:
o comply with a legal obligation, process or request;
o enforce our terms of service and other agreements, policies, and standards, including investigation of any potential violation thereof;
o detect, prevent or otherwise address security, fraud or technical issues; or
o 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 organisations for the purposes of fraud protection); and
• a third party that acquires all or substantially all of us or our business. We will disclose information to a third party in the event that we sell or buy any business or undergo a merger, in which case we will disclose your data to the prospective buyer of such business. We will also disclose information to a third party if we sell, buy, merge or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user information may be among the transferred assets.
The Security of Your Personal Information
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.
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 and Contact Information obtained from customer services will be retained within two years of the date you provide.
When destroying personal information, measures will be taken to make the personal information irrecoverable or irreproducible, and electronic files which contain personal information will be deleted permanently using a technical method which makes the files irreproducible.
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 (as set out in the retention policy above), we will destroy your personal information in accordance with local laws).
This section (“Your Rights”) applies to users that are located in the European Economic Area only. 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 firstname.lastname@example.org.
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 and complete the corresponding request form.
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 (e.g., gender information) or pursuant to our contract with you (e.g., game play statistics), 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).
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 and complete the request form.
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 and complete the request form.
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 Game Services 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 defence 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 defence of legal claims.
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 and completing the request form.
We may from time to time send you announcements when we consider it necessary to do so (such as when we temporarily suspend Game 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 Hong Kong NetEase Interactive Entertainment 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.
Name: Hong Kong NetEase Interactive Entertainment Limited
Designated EU representative and contact information:
Maetzler Rechtsanwalts GmbH & Co KG
Attorneys at Law
c/o Hong Kong NetEase Interactive Entertainment Limited
Schellinggasse 3/10, 1010 Vienna, Austria
Please add the following subject to all correspondence:
GDPR-REP ID: 100001
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.
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.