Privacy Policy
Last Updated: September 2, 2024
Effective Date: May 6, 2024
Shenzhen DrawSword Studio (hereinafter referred to as "we" or "us") takes user privacy protection seriously. When you use the services provided by DrawSword Studio, we may collect and use relevant information about you. Through this Privacy Policy, we aim to explain to you how DrawSword Studio collects, uses, shares, transfers, stores, manages, and publicly discloses your information when you use our services, as well as the ways in which DrawSword Studio provides you with access to, updates, controls, and protects this information.
This Privacy Policy is closely related to your use of DrawSword Studio's services. We kindly ask you to carefully read and confirm that you fully understand the contents of this Privacy Policy before using our services. For clauses in this Privacy Policy that significantly impact your rights and interests, DrawSword Studio has bolded the font for your special attention. If you have any questions, comments, or suggestions regarding this Privacy Policy or matters related to your personal information, you may contact DrawSword Studio (QQ: 3885733544), and we will provide you with feedback and necessary assistance at the earliest possible time.
If you are under 14 years old, please read the Children's Privacy Policy under the accompaniment of your legal guardian. If you are under 18 years old, please read this Privacy Policy under the accompaniment of your legal guardian. If you are the legal guardian of a minor, please pay special attention to Article 10 of this Privacy Policy and the Children's Privacy Policy.
By installing, using, registering, or accessing DrawSword Studio's services in any other way, you signify your acceptance of this Privacy Policy and your explicit consent, based on knowledge, to DrawSword Studio's collection, use, sharing, transfer, storage, management, and public disclosure of your personal information in accordance with the provisions of this Privacy Policy. Afterward, users may not use their unreading of this policy as any form of defense.
Unless otherwise explicitly stipulated in this Privacy Policy, the terms used herein have the same meanings as those defined in the Game License and Service Agreement.
1. Personal Information That DrawSword Studio May Collect
DrawSword Studio collects only the necessary information required to realize product functions and provide services to you, based on the principles of legitimacy, necessity, and legitimacy. We collect and obtain your personal information through the following channels:
1.1 Information Provided by You
1.1.1 Information filled out when you register an account, including: the nickname (username) you provide when registering as a DrawSword Studio user; TapTap account information and Apple ID information associated with your use of DrawSword Studio's services.
Certain services of ours may require you to provide specific personal sensitive information to realize specific functions. If you choose not to provide such information, you may not be able to normally use certain functions within the services, but it will not affect your use of other functions. If you voluntarily provide your personal sensitive information, it signifies your consent to our processing your personal sensitive information for the purposes and in the manner described in this Policy.
1.2 Information Obtained by DrawSword Studio
When you use DrawSword Studio's services, we may obtain your information through collection, aggregation, recording, and other means:
1.2.1 Log Information
Technical information that may be automatically collected by the system when you use DrawSword Studio's services, including:
When you use DrawSword Studio's services, the following system sensitive permissions related to your personal information may be automatically collected:
1.3 Information Obtained Through Third Parties/Partners
When you purchase DrawSword Studio's services through third parties or use DrawSword Studio's services through third-party accounts, we may obtain your information from such third parties, including:
(1) Information obtained from app stores such as the Apple App Store and TapTap when you purchase DrawSword Studio's services through these platforms.
1.4 Information Collected by DrawSword Studio to Realize Service Functions
(1) Game operation statistical analysis functions and other game security analysis functions collect game behavior log information.
2. Technologies That DrawSword Studio May Use to Collect Your Personal Information
2.1.3 Software Development Kits ("SDKs") are code blocks provided by third-party partners that can be installed in our mobile applications. SDKs help us understand how you interact with our mobile applications and collect certain information about the device and network used to access the application. DrawSword Studio will use the following SDKs in the manner, scope, and for the purposes described below:
(1) Tencent Bugly SDK (Shenzhen Tencent Computer Systems Co., Ltd.)
Usage Scenario within the Game: Provides crash monitoring and reporting services for the game.
Permissions Requested by the SDK: Access to device information.
Types of User Data Collected by the SDK: Includes your device's network status, information on the phone's SD card and external storage card, certain system information about your device, such as IMEI, IMSI, MAC address, serial number, commonly used system version number, phone model, hardware identification code, serial number, whether it is charging, whether it is in a call, and access to the list of running applications.
SDK Privacy Policy Link: https://privacy.qq.com/
3. How DrawSword Studio May Use Your Personal Information
3.1 DrawSword Studio may use the information collected during the provision of services for the following purposes:
3.1.1 To provide you with services, including verifying login information, setting features to manage your account and account information, communicating with you, such as releasing product update information, feature update information, allowing users to find friends who also use DrawSword Studio services, allowing users to log in to third-party services, and providing you with technical support.
3.1.2 For identity verification, customer service, security precautions, fraud detection, archiving, and backup when DrawSword Studio provides services, ensuring the security of the products and services provided to you by DrawSword Studio.
3.1.3 To design new services and improve existing DrawSword Studio services.
3.1.4 To better understand how you access and use DrawSword Studio's services, thereby responding to your personalized needs, such as language settings, personalized help services and instructions, or responding to you and other users in other ways.
3.1.5 To conduct statistics on your use of DrawSword Studio's services to demonstrate the overall usage trends of DrawSword Studio's services, but these statistical information do not include any of your personally identifiable information.
3.1.6 For software certification or software upgrade management.
3.1.7 To invite you to participate in surveys related to DrawSword Studio's products and services.
3.1.8 Other Uses: You understand and agree that after collecting your personal information, we may use technical means to de-identify the data. The de-identified information will not be able to identify your identity. In this case, we have the right to use the de-identified information to analyze the user database and use it commercially without obtaining your additional consent.
Please note that if we intend to use your personal information for purposes not specified in this Policy or collect additional personal information not mentioned, we will obtain your consent separately through page prompts, interaction processes, website announcements, or other means. Once you agree, such additional purposes will be deemed part of this Policy, and such additional information will also be subject to this Policy.
3.2 To ensure service security and help us better understand the operation of our applications, we may record relevant information, such as the frequency of your application use, fault information, overall usage, performance data, and the source of the application. We will not combine the information we store in analytical software with the personally identifiable information you provide in the application.
4. Circumstances Under Which DrawSword Studio May Share, Transfer, or Publicly Disclose Your Personal Information
4.1 Circumstances Under Which DrawSword Studio May Share Your Personal Information
4.1.1 DrawSword Studio may share your information with its affiliated companies, partners, and third-party service providers, contractors, and agents, primarily for the following purposes:
(1) To achieve the purposes described in Section 3 above;
(2) To fulfill DrawSword Studio's obligations and exercise its rights under the Game License and Service Agreement, this Privacy Policy, and other related agreements of DrawSword Studio.
4.1.2 If DrawSword Studio or its affiliated companies share your personal information with any of the aforementioned third parties, we will adopt encryption, anonymization, and other means to ensure your information security. DrawSword Studio will endeavor to ensure that these third parties comply with this Privacy Policy and other appropriate confidentiality and security measures required by DrawSword Studio when using your personal information.
4.2 Circumstances Under Which DrawSword Studio May Transfer Your Personal Information
With the continuous development of DrawSword Studio's business, DrawSword Studio and its affiliated companies may undergo mergers, acquisitions, asset transfers, or similar transactions, and your information may be transferred as part of such transactions. However, DrawSword Studio will require the new company or organization holding your information to continue to be bound by this Privacy Policy. Otherwise, DrawSword Studio will require such company or organization to seek your authorization and consent anew.
4.3 Circumstances Under Which DrawSword Studio May Publicly Disclose Your Personal Information
DrawSword Studio may publicly disclose your information in some prize-winning activities, such as desensitizing and displaying the winner's phone number or login name when announcing the prize-winning list.
4.4 Other Circumstances Under Which DrawSword Studio May Share, Transfer, or Publicly Disclose Your Personal Information
DrawSword Studio or its affiliated companies may also share, transfer, or publicly disclose your personal information for the following needs:
4.4.1 With your prior explicit consent or authorization;
4.4.2 To comply with court orders or other legal procedures;
4.4.3 To comply with the requirements of relevant government agencies;
4.4.4 As reasonably necessary to comply with applicable laws and regulations, maintain public interests, or protect the personal and property safety or legal rights and interests of DrawSword Studio's customers, DrawSword Studio, or its group companies, other users, or employees;
4.4.5 As necessary for legitimate news reporting;
4.4.6 Necessary for statistical or academic research conducted by academic research institutions based on public interests, provided that when providing the results of academic research or descriptions externally, the personal information contained in the results is de-identified;
4.5 Except for the above circumstances, DrawSword Studio and its affiliated companies will not share, transfer, or publicly disclose your personal information without your consent.
5. Your Rights
5.1 Accessing and Correcting Your Personal Information
DrawSword Studio will make every effort to adopt appropriate technical means to ensure that you can access, update, and correct your registration information or other personal information provided when using DrawSword Studio's services. The scope and manner in which you can access, modify, and delete your personal information will depend on the specific services you use. When accessing, updating, and correcting the aforementioned information, DrawSword Studio may require you to verify your identity to ensure account security. If you encounter any difficulties when accessing, updating, and correcting the aforementioned information, you can contact us through the contact information listed in this Agreement.
5.2 Deleting Your Personal Information
You may request us to delete your personal information under the following circumstances:
5.2.1 If our processing of personal information violates laws and regulations;
5.2.2 If we collect and use your personal information without your consent;
5.2.3 If our processing of personal information violates our agreement with you;
5.2.4 If you no longer use our products or services or if you deactivate your account;
5.2.5 If we no longer provide you with products or services.
If we decide to respond to your deletion request, we will also notify the entities that obtained your personal information from us and require them to promptly delete it, unless otherwise stipulated by laws and regulations or these entities obtain your independent authorization. When you delete information from our services, we may not immediately delete the corresponding information in the backup system, but will delete it when the backup is updated.
5.3 Despite the above agreements, in accordance with legal and regulatory requirements, DrawSword Studio may not be able to respond to your requests under the following circumstances:
5.3.1 Related to national security and national defense security;
5.3.2 Related to public safety, public health, and significant public interests;
5.3.3 Related to criminal investigation, prosecution, and trial;
5.3.4 With sufficient evidence indicating your subjective malice or abuse of rights;
5.3.5 Responding to your request will seriously harm the legitimate rights and interests of other individuals or organizations.
5.4 Deactivation of Personal Information Subject's Account
You may deactivate your previously registered account at any time. You can deactivate your registered account by contacting DrawSword Studio's Information Department.
5.5 Channels for Complaints or Reports Related to Personal Information Security
You may file complaints or reports related to personal information security with DrawSword Studio at any time through QQ: 3885733544. DrawSword Studio will accept and handle your complaints or reports within 15 working days after receiving them.
5.6 Withdrawal of Consent for Collection of Personal Information
After you deactivate your DrawSword Studio account, you may withdraw all authorizations for consent to the collection of personal information, and DrawSword Studio will no longer collect the corresponding personal information. However, your decision to withdraw consent will not affect the previously conducted collection of personal information based on your authorization.
You may contact DrawSword Studio's customer service and request withdrawal of the Privacy Policy while deactivating your account.
5.7 Obtaining a Copy of Your Personal Information
You have the right to obtain a copy of your personal information. You can contact QQ: 3885733544, and the customer service representative will verify your personal information. After completing the verification, the personal information copy will be provided to you via email. Subject to compliance with relevant laws and regulations and technical feasibility, we will provide you with a copy of your personal information upon your request.
5.8 Constraints on Automated Decision-Making by Information Systems
In certain business functions, we may make decisions based solely on non-manual automatic decision-making mechanisms, including information systems and algorithms. If these decisions significantly affect your legal rights and interests, you have the right to ask us for an explanation, and we will provide appropriate relief.
6. Information Security
6.1 DrawSword Studio will retain your personal information only for the period necessary to achieve the purposes stated in this Privacy Policy and as required by laws and regulations. After the retention period expires, we will anonymize or delete your information.
6.2 DrawSword Studio only permits employees and partners of DrawSword Studio and its affiliates who need to know this information to access your personal information. Strict access control and monitoring mechanisms have been established for this purpose. DrawSword Studio also requires all personnel who may come into contact with your personal information to fulfill corresponding confidentiality obligations. Failure to fulfill these obligations may result in legal liability or termination of the cooperative relationship with DrawSword Studio.
6.3 The internet is not an absolutely secure environment. Communication methods such as email, instant messaging, social software, etc., with other users cannot be guaranteed to be fully encrypted. DrawSword Studio advises you to use strong passwords or change your account password regularly when using such tools and to protect the security of your personal information.
6.4 DrawSword Studio uses various security technologies and procedures to protect the personal information you provide, preventing unauthorized access, disclosure, use, modification, damage, or loss of data.
7. Guidance Regarding Sharing Your Personal Information
7.1 Currently, DrawSword Studio's services do not provide channels for you to share personal information; this excludes situations where you share using screenshots via other tools.
8. Guidance Regarding Sensitive Personal Information
8.1 Sensitive Personal Information refers to personal information that，once leaked, illegally provided, or abused, may endanger personal and property safety, easily lead to damage to personal reputation, physical and mental health, or discriminatory treatment, etc. This includes your financial information (including transaction records, etc.), identity information, race, religion, personal biometric information, personal education and employment information, personal communication information, and personal health and medical information. Compared to other personal information, sensitive personal information will be subject to stricter protection by DrawSword Studio.
8.2 You agree to the processing of your sensitive personal information for the purposes and in the manner described in this Privacy Policy.
9. Information DrawSword Studio May Send You
9.1 Service-Related Announcements
DrawSword Studio may send you service-related announcements when necessary (e.g., when suspending a service for system maintenance). You may not be able to cancel or restrict DrawSword Studio from sending you these service-related announcements, which are non-promotional in nature.
10. Protection of Minors
10.1 DrawSword Studio places great importance on protecting the personal information of minors. Minors under the age of 18 may not use DrawSword Studio's services without the consent of their parents or legal guardians. We advise minors to seek the consent and guidance of parents or guardians before submitting personal information. If you are the parent or legal guardian of a minor under 18, you should supervise and manage the minor's use of DrawSword Studio's services.
10.2 DrawSword Studio will only use or publicly disclose minors' personal information when permitted by law or when necessary to protect the minor.
10.3 If a minor uses DrawSword Studio's services without the consent of their parent or legal guardian, the minor's parent or guardian has the right to contact DrawSword Studio and request the deletion of the minor's personal information. DrawSword Studio will promptly delete such information upon verification.
10.4 If DrawSword Studio discovers that it has collected a minor's personal information without obtaining prior verifiable parental or guardian consent, it will strive to delete the relevant data as soon as possible.
10.5 If you are a child under 14 years old, before using relevant products or services, you should, according to the registration and usage process, obtain prior consent from your parent or legal guardian. Your parent or legal guardian should assist you in completing the product or service registration process so that you can use the products or services we provide.
10.6 If you are the guardian of a child, before helping the child complete the registration or use of a product or service, you should carefully read this Privacy Policy and the "Children's Privacy Policy," decide whether to agree to them, and assist the child in registering and using the service so that the child can use the products or services we provide.
11. How Your Personal Information is Transferred Globally
11.1 In principle, the personal information generated and collected within the territory of the People's Republic of China will be stored within the territory of China.
11.2 As we provide products or services through resources and servers located worldwide, this means that, subject to your authorization and consent and after we conduct a Personal Information Impact Assessment as required by laws and regulations, your personal information may be transferred to jurisdictions outside the country/region where you use the product or service, or accessed from such jurisdictions. Such jurisdictions may have different data protection laws or may not have relevant laws at all. In such cases, we will ensure that your personal information receives a level of protection equivalent to that within China. For example, we will request your consent for the cross-border transfer of personal information or implement security measures such as data de-identification before the transfer.
12. Scope of Application of the Privacy Policy
12.1 Unless explicitly stated otherwise by DrawSword Studio for certain specific services, this Privacy Policy applies to all services provided by DrawSword Studio.Specific services will be governed by specific privacy policies. For privacy policies pertaining to certain specific services, DrawSword Studio will explain in more detail how we use your information in those services. The privacy policy for that specific service forms part of this Privacy Policy. If there is any inconsistency between the privacy policy for a specific service and this Privacy Policy, the privacy policy for that specific service shall prevail.
13. Exceptions to the Application of the Privacy Policy
13.1 DrawSword Studio's services may include or link to social media or other services (including websites) provided by third parties. For example: DrawSword Studio may provide you with links through advertisements or other means within our services, allowing you to access third-party services or websites.
13.2 These third-party social media or other services are operated by the relevant third parties and have their own privacy policies and methods and measures for obtaining your personal information. These third-party privacy policies, methods, and measures for obtaining your personal information are not controlled by DrawSword Studio. Your use of such third-party social media services or other services (including any personal information you provide to such third parties) is subject to the terms of service and privacy policy of that third party (not DrawSword Studio's relevant agreements or this Privacy Policy). You need to read their terms carefully.This Privacy Policy applies only to the information collected by DrawSword Studio and does not apply to any services provided by third parties or the use of information by third parties. DrawSword Studio bears no responsibility for any third party's use of your personal information.
14. Changes
Our privacy policy may change.
14.1 We will post any changes to this privacy policy on this page. For significant changes, we will display the updated privacy policy in a pop-up window when you log in for the first time after the change. Please note that we will only collect, use, share, and store your personal information in accordance with the updated privacy policy after you have read the changes and clicked the "Agree" button in the pop-up window. Significant changes include, but are not limited to:
14.1.1 Significant changes in the scope, mode, etc., of the services we provide, such as changes in the purpose of collecting/using personal information, the types of personal information processed, the manner of using personal information, the identity of third parties receiving data, etc.;
14.1.2 Significant changes in our operating entity, organizational structure, or ownership structure, such as changes in ownership due to business adjustments, mergers, acquisitions, or reorganizations;
14.1.3 Major changes to your rights regarding the processing of your personal information and how you can exercise them;
14.1.4 Changes in the methods or primary recipients involved in sharing, transferring, or publicly disclosing personal information;
14.1.5 When a personal information risk assessment report indicates a high risk;
14.1.6 Changes to the department responsible for personal information security, its contact information, or complaint channels;
14.1.7 Other changes that may significantly impact your personal information rights and interests.
14.2 To ensure you receive notifications promptly, we recommend you update your contact information with us when it changes. If you continue to use the App services after the updated policy takes effect, it signifies that you have fully read, understood, and accepted the updated policy and agree to be bound by it.
15. Contact DrawSword Studio
Personal Information Protection Agency: Customer Service Department
Game Contact Email: 3885733544@qq.com
Business Cooperation QQ: 3885733544
Mailing Address: Nanshan District, Shenzhen, Postal Code: 518000.
16. Dispute Resolution
16.1 The formation, effectiveness, performance, interpretation, and dispute resolution of this Privacy Policy shall be governed by the laws of the mainland territory of the People's Republic of China (excluding conflict of laws rules).
16.2 If any dispute arises between you and DrawSword Studio regarding the implementation of this Privacy Policy, the parties shall first attempt to resolve it through friendly negotiation. If negotiation fails, both parties agree to submit the dispute to the People's Court of Nanshan District, Shenzhen for litigation.