This Privacy Policy shall apply to the applications published in the Apple App Store by Hong kong Apex network company and that is accessible from mobile devices (the "Game","App").

1. GENERAL

Regarding the Services: Hongkong Apex network technology company. ("Apex", "we", "us" or "our") is the Data Controller within the meaning of the General Data Protection Regulation ("GDPR"). This privacy policy shall inform you on how we collect, process and use ("Use") personal data in connection with the Services.

2. DATA WE COLLECT, PROCESS, USE AND DELETE

2.1 In general, you can use the Services without providing any personal information such as e.g. your name, email address, postal address, telephone number, financial information (all such information concerning the personal or material circumstances of an identified or identifiable individual data subject together "Personal Data"). Therefore, if you do not provide us directly with Personal Data in another way or actively consent to the Use by us of certain Personal Data, we, in general, do not Use your data with the exception of the following:

  2.1.1 Regarding the Website: When you open the APP, we will show you the game accouncement, your browser transfers certain data so that it can access the Website, namely:

  2.1.2 Regarding the App: certain data is transmitted by your mobile device:

as well as events within the application recorded with Amplitude analytics in order to give us the possibility to continuously improve the App.

2.1.3 Regarding the App: in certain cases, such as ending a free trial of our App, you can choose to use a valid email address as your account name ,we will send a verify code to your email address to confirm you can use that email address, so when you forget your password, you can find back your password by this email address.

2.1.4 Regarding the App: We record your phone brand and model, your mobile phone OS version ,OS language, mac address and IMEI. We use IMEI and mac as account when you use quickly login mode, brand and model ,OS version can help us to continuously improve the App. OS language help us to find the same language to you in APP.

Regarding the App: we save a record of IDFA(IDentifier For Advertising) that is a virtual code by Apple Inc. for protect user’s real UDID from a advertising. We use IDFA to find which ad channel is our players from. If you don’t want to send IDFA to us, you can stop this function from iOS settings. The legal basis for the processing of the data described above in section 2.1.1 through 2.1.5 (to the extent such data is to be considered Personal Data) is Art. 6 (1) sentence 1 lit. f GDPR (legitimate interests; regarding section 2.1.1 the legitimate interests to Use such data arises from the fact that without such data the Website cannot be accessed by our customers and/or other users; regarding section 2.1.2 the legitimate interests to Use such data is that we have an interest to continuously improve the App; regarding section 2.1.3 the legitimate reason is that we need to help you use a real email address, so when you forget your password , you can get back your password by email; regarding section 2.1.4 the legitimate reason is that we need the information to locate your account when you login anonymous account; regarding section 2.1.5 the legitimate reason is that we need the information to find which ads channel you are from).

2.2 Only in cases in which you have given us prior consent we also use your Personal Data for other purposes but only to the extent needed in each specific case. The legal basis for the processing of the data described in this section 2.2 is Art. 6 (1) sentence 1 lit. a GDPR (consent).

We may disclose Personal Data to third parties where such disclosure is required by law (for example, upon request of a court or of law enforcement authorities). The legal basis for the processing of the data described in this section 2.3 is Art. 6 (1) sentence 1 lit. c GDPR (legal obligation).

We may also Use certain data as set forth in section 3 below.

2.3 We allow users to self delete the user data we keep. Fill in the ID in the game through the website (click here), and click Delete to self delete the user's personal privacy data (but not the game role data). Please note that the user's personal privacy data deleted by this operation cannot be retrieved. Please operate with caution.

3. APEX'S THIRD PARTY SDK POLICY

3.1 Our Apps use Facebook SDK of Facebook (https://developers.facebook.com/docs/ios/, https://developers.facebook.com/policy)to analyze sources of app installations and how you use the app. Facebook SDK and Analytics is a service which helps us to improve ours Service by better understanding general app usage patterns.

3.2 Our Apps use TalkingData SDK of tendcloud.com(http://www.talkingdata.com/privacy.jsp?languagetype=en)to analyze how you use the app

3.3 Our Apps use AppsFlyer SDK of appsflyer.com(https://www.appsflyer.com/product/data-privacy/,https://www.appsflyer.com/product/gdpr)to analyze sources of app installations.

3.4 Our Apps use Firebase SDK of google firebase(https://www.google.com/policies/privacy/)to analyze how you use our apps and monitor our apps’ crash and report the crash point to help us improve our apps.

3.5 If you decide to deactivate (some of) the cookies and tools described above, please note that certain features and functionalities of the Services might not work or might not be accessible to you.

3.6 The legal basis for the processing of the data described in this section 3 (to the extent such data is to be considered Personal Data) is Art. 6 (1) sentence 1 lit. f GDPR (legitimate interests; the legitimate interests to Use such data is that we use and analyze the respective data to improve our Services, such as by gaining a better understanding of your interests and requirements regarding our Services and to help personalize your user experience).

4.TECHNICAL IMPLEMENTATION OF THE SERVICES BY SUBCONTRACTORS

We partly use service providers who process Personal Data on behalf of us to operate the technical platform for the Services (for example, some custom service order will send to third party for processing, because some languages we can’t understand). These service providers process the data exclusively according to our instructions (order processing). The legal basis for the data processing described in this section 4 is Art. 6 (1) sentence 1 lit. b GDPR (performance of contract and pre-contractual measures) and Art. 28 GDPR (order processing).

5.DURATION OF STORAGE OF PERSONAL DATA

Unless no shorter storage period is indicated in this privacy policy, we, in general, store Personal Data as long as required for the provision of the Services to you, and/or as it is necessary with regard to the contractual relationship with you, thereafter only if and to the extent that we are obliged to do so by mandatory statutory retention obligations. If we no longer require the respective Personal Data for the purposes described above, such Personal Data will only be stored during the respective legal retention period and not processed for other purposes.

6.YOUR RIGHTS

You have the right to request information from us at any time about your Personal Data stored by us. If the legal requirements are met, you also have rights vis-à-vis us to request from us access to and rectification or erasure or restriction of processing concerning your Personal Data or to object the processing of your Personal Data as well as the right to receive your Personal Data provided to us in a structured, established and machine-readable format from us (you can transfer this data to other parties or have it transferred; data portability). If you have given your consent to the use of personal data, you can revoke such consent at any time (for the future). If you believe that the processing of your Personal Data by us is in breach of the applicable data protection laws, you can issue a complaint with the competent supervisory authority for data protection.

7.CONTACT

You can contact us (e.g. if you have any questions about data protection regarding Apex (including regarding the assertion of your rights further explained in section 6 above)), for example, via the address indicated above in section 1 or via the following emails: dataprotect@ksn-teck.com (Apex Data Protection Officer)

8.KEEPING YOUR PERSONAL DATA SECURE

We have taken extensive technical and operational precautions to protect the Personal Data retained by us against unauthorized access and misuse. Our security procedures are revised regularly and adapted to reflect technological progress.