Chengdu 91Act Technology Co., Ltd., along with its affiliates (hereinafter referred to as "91Act," "we," or "us"), respects and values the privacy of users (hereinafter referred to as "users" or "you"), and is committed to protecting the security and lawful use of the personal information you provide in the course of using our services.
This Privacy Policy (hereinafter referred to as "this Policy") explains how we collect, use, store, disclose, and protect your information when you access and use the online gaming platform, related products, and services provided by 91Act. These services include our website (https://91act.com, hereinafter referred to as the "Website") as well as our game products published on various mobile platforms (such as iOS and Android) (collectively referred to as the "Services").
This Policy does not apply to any third-party websites or services, even if such websites or services are displayed within our platform via links. Please note that we do not control how these third parties handle your personal information. We strongly recommend that you carefully review the privacy policies of any third-party websites or services before accessing them or providing any personal data.
Before you register, download, install, log in to, or otherwise use the 91Act online gaming platform, products, or services, please read this Policy in its entirety, especially any provisions highlighted in bold, different colors, or otherwise marked for your attention. If you disagree with any part of this Policy, you should immediately cease using the relevant 91Act products and services. For certain specific functions, we may separately request your explicit consent to ensure compliance with applicable laws and regulations.
We will collect and use your personal data in compliance with applicable laws and regulations, based on the specific products and service scenarios, to provide you with a stable, secure, and personalized gaming experience, fulfill our contractual obligations with you, and continuously improve our services.
1. Creating and Managing Accounts
To facilitate your use of our services, you may register and log in to the game via your Apple Game Center or Google Play account. If you choose to register and log in using your Apple or Google account, this process will trigger identity verification and will be carried out in accordance with the respective platform's terms of service and privacy policy to complete account creation, linking, or management. When you link your account, we will collect the following information: (1)your username, (2)user ID, (3)email address, (4)account nickname, (5)account avatar, in order to create, link, and manage your account.
In addition, to identify abnormal registration activities, prevent unauthorized use of accounts, and enhance your personalized experience, we may record the time of your registration and login, the device you use, your login IP address, and location information. This information helps us verify your identity, protect account security, and support the provision of account management and preference settings.
If you refuse to provide the above basic registration information, we may be unable to create a game account for you, and you will not be able to use our services normally.
2. Ensuring Game Service, Troubleshooting, and Optimizing Experience
When you use the 91Act game services, in order to ensure the proper operation of various game functions, optimize product performance, troubleshoot technical issues, improve service stability, and continuously enhance your interactive experience, we will collect game operation data such as registration time, login time, game version, stack traces, crash reports, abnormal process data, game progress, statistical data, and feedback information you provide.
At the same time, we will collect device and operation information related to your use of the game, including platform type (iOS or Android), device name, device model, device ID, hardware type, Media Access Control (MAC) address, International Mobile Equipment Identity (IMEI), operating system (OS), IP address, accelerometer data, gyroscope data, CPU information, language, time zone, screen DPI, resolution, memory data, and graphics card model.
3. Age Verification
To comply with applicable laws governing the protection of children's data in your jurisdiction and to ensure that you meet the minimum age requirements for using this game service, we will collect and use your date of birth and country or region information when you create an account or log in for the first time. This information will be used solely to verify your age and determine whether you meet the minimum age required in your region. If you have not reached the statutory age, we will deny registration. Except as required by law, we will not use this information for any purpose unrelated to age verification.
4. Payment Services
When you top up your account, purchase virtual goods, or subscribe to services within the game, we will collect transaction-related data, including the transaction date, transaction order number, payment channel used, currency, payment amount, and details of the purchased products. This information is used to process your payment requests, verify the status of transactions, issue invoices or purchase receipts, resolve transaction disputes, provide after-sales support, and fulfill our obligations related to finance and taxation.
We undertake to use the above information only to the extent necessary to provide, maintain, and improve the services and to fulfill our legal responsibilities for protecting user data security. If you refuse to provide such information, certain game functions may not be available to you.
5. Social Features
Our game currently allows players to add friends using in-game functionality. You may search for or identify other players in the game and send friend requests to establish interactive connections. This feature is solely intended for in-game communication and interaction and does not involve the use of external social media platforms or contact lists. We do not access or process your social media accounts or contacts stored on your device; however, we will collect in-game friend information, including your friends' avatars and account details.
6. Third-Party Services and Data Sharing
To enhance the continuity, interactivity, and analytical capabilities of our services, we may embed or integrate service components provided by third parties into the platform, including but not limited to third-party login authentication (such as Google, Apple ID), third-party payment services, and troubleshooting tools. If you wish to stop sharing information with a particular third party or to withdraw your authorization, you may submit a request through the "Contact Us" section of this policy, and we will assist you in completing the process within a reasonable period.
The main integrated third-party SDKs include:
Backtrace SDK
Third-Party Company: Backtrace
Personal Information Involved: crash logs, device model, operating system version
Use Scenario: used during game operation
Purpose of Use: analysis of game anomalies and crashes
Method of Collection: SDK local collection
Third-Party Link: https://backtrace.io/
Apple SDK
Third-Party Company: Apple Inc.
Personal Information Involved: account nickname, avatar, username, account ID, email address, device name, device model, device ID, IP address, network type
Use Scenario: used when Apple provides account login and payment services
Purpose of Use: provision of Apple account login and payment services
Method of Collection: SDK local collection
Third-Party Link: https://www.apple.com/legal/privacy
Google Play SDK
Third-Party Company: Google LLC
Personal Information Involved: account nickname, avatar, username, account ID, email address, device name, device model, device ID, IP address, network type
Use Scenario: used when Google Play provides account login and payment services
Purpose of Use: provision of Google Play account login and payment services
Method of Collection: SDK local collection
Third-Party Link: https://policies.google.com/privacy
1. How We Share Your Personal Information
We respect your privacy and will not sell your personal information or disclose it to third parties for unauthorized purposes. We will only share your personal information under the following circumstances, where there is a lawful basis and within the necessary scope:
a) With Your Explicit Consent
i. When you agree that we may disclose your personal information to specific third parties (for example, through an authorization window or your account settings), we will share the relevant data within the scope of your authorization. These third parties will process your information in accordance with their respective privacy policies.
ii. If you wish to withdraw your authorization for such sharing, please send an email to: service_bbee@91act.com.
iii. If you wish to stop receiving marketing information from a third party, please contact the relevant third party directly to exercise your rights.
b) Third-Party Vendors and Processors Necessary to Perform Services
We may entrust third-party service providers to carry out operational tasks on our behalf, including but not limited to:
i. Data hosting and cloud computing (e.g., server providers);
ii. Payment processing;
iii. In-game behavior analytics.
These service providers are permitted to access your personal information only to the extent necessary to provide the above services and are required to comply with contractual obligations regarding confidentiality, data security, and lawful processing. They must not use your information for any other purpose. Because these third-party services are independently operated, their data processing activities are governed by their own privacy policies rather than this Privacy Policy. We recommend that you carefully review the privacy terms of the relevant providers to understand their purposes of data collection, how they use your information, and the channels available to exercise your rights.
2. How We Transfer Your Personal Information
Without your authorization, we will not transfer your personal information to any third party. However, if any of the following transactions or events occur, we will inform you of the relevant circumstances and will continue to protect your personal information in accordance with applicable laws and to a standard no less stringent than that required by this Privacy Policy, or we will require the new data controller to do so:
a) Mergers, divisions, reorganizations, bankruptcies, asset sales, or financing;
b) Acquisition by or transfer of control to another company;
c) Transfer of all or part of our business to a third party.
In the event of such changes, we will notify you of the change of control over your information via in-game notifications, email, or announcements on our official website. The transferee will continue to process your personal information in accordance with this Privacy Policy or will separately notify you of any new policy that will apply.
3. How We Publicly Disclose Your Personal Information
We may disclose your personal information to competent authorities within the scope permitted or required by law under the following circumstances. Please understand that, in such cases, we may not be able to notify you of the disclosure in advance:
d) As required by mandatory legal processes, such as court orders, subpoenas, or search warrants;
e) In response to lawful requests from law enforcement agencies or regulatory authorities;
f) To fulfill our obligations under applicable laws, regulations, tax compliance, or anti-money laundering requirements;
g) To identify, prevent, or address fraud, security, or technical issues;
h) To protect the rights, property, and safety of our users, employees, or the public.
We attach great importance to the security of your personal information and are committed to adopting reasonable technical and organizational measures in line with industry standards to prevent your information from being accessed, disclosed, used, modified, or destroyed without authorization.
1. To protect data security, we have implemented, including but not limited to, the following measures:
a) Using encryption protocols during data transmission;
b) Restricting access permissions and authorizing only designated employees and partners to access personal data under the principle of "minimum necessary access";
c) Employing technical safeguards such as firewalls, intrusion detection systems, and access log audits on servers and databases;
d) Conducting regular security vulnerability assessments and applying timely patches and updates;
e) Contractually requiring third-party data processors to fulfill equivalent data protection obligations.
2. Despite our reasonable efforts to provide security protections, please understand:
a) Due to the openness of the internet and the inherent uncertainties of technology, no system can be completely immune to intrusion or data breaches;
b) Unforeseeable risks such as hacker attacks, system vulnerabilities, or malicious software may result in the disclosure of information;
c) We are not responsible for any personal information that you choose to disclose or transmit in public network environments.
Therefore, although we will do our utmost to protect the personal information you submit through our services, we cannot guarantee its absolute security. You acknowledge and accept that, in extreme circumstances, there may still be a risk of information disclosure caused by factors beyond our control.
If we discover or reasonably suspect that a personal data breach has occurred which may affect your rights and freedoms, we will report it to the relevant supervisory authorities within the timeframe required by law, and, as appropriate, promptly notify you via in-game notifications, email, or other means, providing relevant information and any recommended protective measures.
We will retain your personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy or for such periods as required to comply with legal obligations, resolve disputes, and enforce our agreements, always adhering to the principles of "data minimization" and "necessity" to avoid unreasonable or excessive data retention.
While your account remains active or you continue to use our services, we will maintain the relevant information. If you request to delete your account, we will delete or anonymize your personal information after completing identity verification. If you withdraw your consent for us to process your personal information, we will cease the corresponding processing activities and retain only the data necessary to continue providing basic services.
If we terminate our services or discontinue the operation of our game products, we will issue an announcement in accordance with applicable laws and regulations and proceed to delete or anonymize your personal information.
In accordance with applicable data protection laws, we provide you with appropriate mechanisms and settings that allow you to access, copy, correct, supplement, delete, or withdraw your personal information. Additionally, we have established channels for complaints and reports, and your feedback will be handled in a timely manner. You may submit a request to exercise your rights through the contact methods specified in the "Contact Us" section of this Policy. To protect the security of your account and prevent misuse of your personal data, we may require you to provide additional information to verify your identity before processing your request. Within the limits permitted by law, we may also decline requests that are manifestly unfounded, repetitive, or excessive, or we may charge a reasonable fee as allowed by applicable law.
Specifically, you may have the following rights:
1.Right of Access
You have the right to know whether we are processing your personal information and to understand the specific circumstances of such processing. You can also view and access certain personal information within the game. If you have other inquiries regarding your personal information, you may contact us using the details provided in this Privacy Policy. We will make every effort to support reasonable requests. However, we may not be able to fulfill your request if it falls beyond the scope of our data storage, exceeds reasonable limits, or if fulfilling the request would seriously infringe upon the lawful rights and interests of you or other parties.
2. Right to Rectification
If you believe that any personal information we hold about you is inaccurate or incomplete, you have the right to request its correction. Where supported by our services, you may also update your information directly in your account settings.
3. Right to Withdraw Consent
If we process your personal data based on your consent, you have the right to withdraw your consent at any time without providing a reason. Once we receive your withdrawal request, we will immediately cease processing activities related to that consent. You can withdraw your consent at any time by deleting information within the game, enabling or disabling specific features, adjusting device permissions for our products, modifying your settings, or contacting us as described in the "Contact Us" section.
Withdrawal of consent does not affect the legality of processing based on consent before its withdrawal. Please note that certain services may no longer be available if you withdraw your consent.
4. Right to Data Portability
Depending on the applicable laws of your country or region, you may have the right to obtain certain personal information you provided to us in a structured, commonly used, and machine-readable format, or to request the transfer of such data to another data controller. Please note that the practical implementation of this right depends on whether our service architecture supports cross-platform data operations. Restrictions from third-party platforms may prevent us from completing data migration or automated transfers. If you wish to exercise this right, please contact us, and we will assist you within the framework of applicable law.
5. Right to Obtain a Copy
You have the right to request a copy of your personal data that we hold.
6. Right to Erasure
You have the right to request that we delete your personal information under the following circumstances:
b) You have withdrawn your consent to the processing of the data;
c) The data processing violates applicable laws.
d) Laws require us to delete the data.
a) The data is no longer necessary for the purposes for which it was collected;
Please note that if you choose to delete your account or request the deletion of personal data associated with your account, we will verify your identity, the security status of your account, and the conditions for deletion. Once the deletion is completed, you will no longer be able to access any game content, virtual assets, records, or other service features associated with the account. Deleted data cannot be recovered, so please exercise caution before proceeding.
Additionally, to facilitate the exercise of your right to deletion, we provide an easy-to-use account deletion feature within the game. You can submit a deletion request through the in-game menu under "Settings - Game - Permanently Delete Account." Please note that once you confirm the submission of your deletion request, your account and all related personal information will be permanently deleted and cannot be restored. You will not be able to re-register or recover any previous game data or services using the same third-party account. Ensure that you fully understand and confirm this operation before submitting your request.
We take the protection of children's personal data very seriously and are committed to complying with applicable laws and regulations regarding children's data protection worldwide, including but not limited to the U.S. Children's Online Privacy Protection Act (COPPA), Article 8 of the EU General Data Protection Regulation (GDPR), and other relevant legislation in various countries or regions.
We do not knowingly provide services to or collect personal information from children under the age of 13, or from users who have not reached the minimum age required by applicable laws in their country or region (whichever is higher). Nor do we knowingly offer services to or engage in data processing activities targeting such users.
Accordingly, we have implemented an age verification process when users access our services and determine, based on the age information provided by users, whether they meet the minimum age requirements stipulated by applicable law. Within reasonable bounds, we will employ technical and organizational measures to identify and prevent underage users from accessing our services or submitting personal information.
Please provide truthful and accurate age information. If you intentionally provide false age information and, as a result, we unknowingly collect your data, you and your guardian shall bear any consequences arising therefrom, and we will not assume any related legal liability.
If you are under the aforementioned minimum age, please do not register for or use our services, and do not submit any personal information to us (including but not limited to your date of birth, country of residence, or address).
If you are a parent or guardian and believe that we have collected your child's information without your consent, please contact us immediately at service_bbee@91act.com. Upon verifying your identity, we will promptly take steps to delete, cease processing, or otherwise appropriately handle such information in accordance with the law.
We provide our services through the certified cloud service provider Google Cloud and currently store users' personal information primarily in data centers located in the United States to support our global service delivery and technical operations. To enable service functionality, improve performance, or maintain disaster recovery capabilities, your personal information may be transferred to other countries or regions outside your place of residence.We acknowledge that certain jurisdictions impose strict restrictions on the cross-border transfer of personal information. When transferring user data across borders involving such jurisdictions, we will comply with the applicable legal requirements to ensure appropriate safeguards are in place.We understand and respect the expectations and requirements of different countries regarding data protection and are committed to implementing measures such as encrypted transmission, access controls, data minimization principles, and strict limitations on employee access during cross-border data transfers, to ensure that your data receives a level of protection comparable to that of your country of residence.
1. We may revise this Privacy Policy from time to time to reflect changes in laws, regulatory requirements, or updates to our services and technical solutions.
2. If this Policy undergoes material changes (for example, changes to the purposes of data processing, data sharing practices, or your rights), we will provide you with an update notice by means of an announcement or pop-up notification on our website or within the application, and where required by law, we will seek your renewed consent.
3. We encourage you to review this Privacy Policy periodically to stay informed about our latest privacy practices.
4. Unless otherwise specified, all revisions will take effect immediately upon publication of the updated version. By continuing to use our services after any updates to this Policy, you are deemed to have read, understood, and accepted the revised Privacy Policy and to agree that we may collect, process, and use your personal information in accordance with the updated version.
If you have any questions, comments, suggestions, or requests regarding this Privacy Policy or our processing of your personal information, please contact us by email at service_bbee@91act.com.
We will respond to your request in a timely manner in accordance with applicable laws and are committed to addressing any reasonable concerns you may have regarding privacy protection. We will respond after receiving your verifiable request and will reply within the time limits prescribed by applicable laws and regulations.
1. This Privacy Policy constitutes an integral part of the 91Act User Agreement. In the event of any inconsistency or conflict between this Privacy Policy and the User Agreement, this Privacy Policy shall prevail.
2. This Privacy Policy is provided in English only, and the English version constitutes the sole legally binding text. If we provide translations in other languages for convenience in the future, such translations shall be for reference only and shall not be considered legally binding or used as a basis for interpreting this Policy.