Privacy Policy

Welcome to Dreamgame, and thank you for playing our games! We have prepared this Privacy Policy to explain, in clear terms, how we handle the information we collect and how you may exercise your privacy rights where those rights apply. This Privacy Policy governs your use of our games; your access to any of our other products, services, content, websites and domains; any other digital properties or online services that link to this Privacy Policy; and our marketing efforts, live events and other activities described herein (collectively, the "Services").

Throughout this document, "Dreamgame" refers to HONGKONG DREAMGAME LIMITED together with its "Affiliates," meaning its subsidiaries, parent companies, joint ventures and other corporate entities under common ownership. Dreamgame may also be referred to as "we," "us" or "our." Should you have questions about this policy or about Dreamgame's data protection practices, please reach out to us as described in Section 10 ("Contact Us").

By using the Services, you consent to the collection, disclosure, storage and use of your information as described in this Privacy Policy. If you do not wish for your information to be collected, stored, used or disclosed in the manner described here, please do not play our games or otherwise use the Services. We may revise this Privacy Policy at any time. Where we make material changes, we will inform you by updating the effective date above and publishing the revised policy through the Services or by other appropriate means.

1.Information We Collect and Process

The personal information we may collect and process about you through the Services generally falls into the following categories:

1.1 Information You Directly and Voluntarily Provide to Us

• Account information: in-game username and password, in-game user ID.
• Contact information: your email address.
• Profile information: such as name, social networking site ("SNS") accounts, age range, gender, image and profile photo.
• Communication information: messages you send to us or through the Services (for example, chat logs and player support tickets).
• Transactional information: your payment and transaction records within the Services.
• Other information: any additional information not specifically listed above, including information you choose to share with our customer service or other teams in-game or by email (for example, details provided to help recover a lost account).

You must ensure that all personal information you provide to us is true, accurate and lawfully provided. You are solely responsible for all liabilities arising from any false or unlawful information you provide, or from your impersonation of another person. If any such conduct causes Dreamgame to incur losses, you must indemnify Dreamgame for those losses.

1.2 Information Automatically Collected Through the Services

When you access the Services, we may automatically collect certain information from you and/or your device, including:

• Device information: mobile device identifiers; IP address, which allows us only to determine your general geographic area and does not reveal your precise location; device details (such as device type, system language, network and carrier data, and operating system); your country; and application performance and debugging data.
• Online activity information: details of the games and platforms you use; information about how you use and interact with the Services (such as in-game events and game version); your current progress within the Services; the date and time of your activity; and user news or notifications within the Services.

As with most online services, we use cookies and similar technologies ("Cookies") to improve your experience and to help prevent fraud when you visit our websites. Cookies are small text files that your browser stores on your device. Most browsers accept cookies automatically, but you may change your browser settings to refuse them. Please note that if you do so, certain features of the Services may not function properly.

1.3 Information You Share on Third Party Websites or through Social Media Services

When you access any Dreamgame Service through a social media account—such as Facebook, WeChat or Google (on which our games may also be described as "applications")—you permit Dreamgame to access certain information from your profile on that platform. What we receive depends on your privacy settings with that platform. You can review and adjust those settings on the social network through which you play our games.

Dreamgame may access and store some or all of the following:

• your user identification number (for example, your Facebook ID), which may be associated with publicly available information such as your name and profile photo;
• information about your activities on or through the connected third-party platform;
• any other information that you or the third-party platform shares with us.

We may also obtain information about you from other third-party sources, such as advertising partners. For instance, if you clicked an advertisement that directed you to one of our Services, we may receive information identifying the advertising network and campaign from which the installation originated.

2.How We Collect Information About You

When you play one of our games, Dreamgame collects and stores certain personal and non-personal information that you supply directly or that is supplied through third-party sources offering our game(s). In addition, your web browser or client software may transmit certain details about your computer (capabilities, game data processing, and so on) to Dreamgame. Certain gameplay information—such as a timestamp of your most recent session and your game progression—is collected from you and/or generated automatically based on your use of our game services.

As is customary for most websites, we automatically gather certain information and store it in log files. This may include unique identifiers such as your browser type, Internet Service Provider (ISP), referring and exit pages, operating system, date/time stamps and clickstream data. We may combine this automatically collected log data with other information we hold about you.

Dreamgame and our partners may deploy tracking technologies such as cookies, beacons, tags and scripts. These technologies help us analyze trends, administer our websites, track how users navigate our websites, and compile demographic information about our user base as a whole. We may receive reports based on the use of these technologies on both an individual and an aggregated basis.

Users can manage cookies at the individual browser level. If you decline cookies, you may still use our websites, though your access to certain features or areas may be limited.

3.How We Use the Information We Collect

We may use your personal information for the purposes described below, or for other purposes disclosed to you at the time of collection:

• Service delivery, operations and account management. We may use your personal information to: (i) provide, operate and improve the Services and our business; (ii) personalize the Services, including remembering devices you have previously logged in from and retaining your selections and preferences as you navigate the Services; (iii) create and maintain your user profile; (iv) enable security features, such as recognizing devices you have used before; (v) communicate with you about the Services, including Service-related announcements, updates, security alerts, and support and administrative messages; (vi) understand your needs and interests and tailor your experience and our communications accordingly; and (vii) provide support and respond to your requests, questions and feedback.
• Improvement and development. We may use your personal information to analyze and enhance the Services and our business and to develop new products and services. As part of these activities, we may generate aggregated, de-identified and/or anonymized data from the personal information we collect, by removing the elements that make the data personally identifiable to you. We may use such aggregated, de-identified or anonymized data, and share it with third parties, for our lawful business purposes, including analyzing and improving the Services and promoting our business. We may also use your personal information to analyze your usage of the Services, understand user activity (including which pages are most and least visited and how visitors move through the Services), review user interactions with us, and develop new offerings. All rights, title and interests in and to the aggregated, de-identified and/or anonymized data generated through our processing of users' personal information, and all derivative rights and interests in any developments, analytical models, industry statistics and other results developed based on such data, shall belong exclusively to Dreamgame, to the extent permitted by applicable law.
• Marketing and advertising. We, our service providers and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes. We will send you marketing messages only where we have your consent. You may stop receiving marketing messages at any time by using the unsubscribe option in the message or by contacting us. After you unsubscribe from marketing communications, we may retain information indicating your unsubscribe status solely to ensure that we do not send you further marketing communications. We will not use that information for any other purpose.
• Compliance, protection and anti-fraud security. We may use your personal information to: (i) comply with applicable laws, lawful requests and legal process, such as responding to subpoenas, investigations or requests from government authorities; (ii) protect our rights, privacy, safety or property, or those of you or others (including by bringing and defending legal claims); (iii) audit our internal processes for compliance with legal and contractual requirements and our internal policies; (iv) enforce the terms and conditions governing the Services; and (v) prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
• With your consent. In certain circumstances we may specifically request your consent to collect, use or share your personal information—for example, when conducting surveys or where required by law. Where you provide consent, you may withdraw it at any time, and such withdrawal shall not affect the lawfulness of processing based on consent before its withdrawal.
• To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and that of other individuals. We do so by removing the information that makes the data identifiable to you, and we will not attempt to re-identify any such data. We may use and share such data with third parties for our lawful business purposes, including improving the Services and promoting our business.
• Further uses. In some cases we may wish to use your personal information for additional purposes. Where those purposes are not compatible with the purpose for which the information was originally collected, we will seek your consent.

4.Sharing of Your Information

We may share your personal information with the parties listed below, as well as in the circumstances described elsewhere in this Privacy Policy, in other applicable notices, or at the time of collection. When we share your personal information with third parties, we will limit the disclosure to the minimum information necessary to achieve the relevant purpose of the cooperation. We will require such third parties to process the information strictly within the scope set out in this Privacy Policy, the processing rules communicated by us, and applicable legal requirements, and not to process the information beyond the authorized scope. We will also require such third parties to implement security measures that are no less protective than those required under this Privacy Policy. Except where otherwise required by law, we will not be jointly and severally liable for a third party's non-compliant processing of your personal information.

• Affiliates. Our corporate parent, subsidiaries, sister companies and affiliates, or any other entity under our control or acting in concert with us.
• Service providers. Third parties that perform services on our behalf or assist us in operating the Services or our business.
• Payment processors. Any payment card information used to make purchases through the Services is collected and processed directly by our payment processors, such as PayPal or Adyen.
• Advertising partners. Third-party advertising companies, for interest-based advertising purposes.
• Third parties you designate. We may share your personal information with third parties where you have instructed us to do so or given your consent. For example, we may share information with third parties with whom we collaborate to offer you additional services, limited to what those companies need in order to provide the services you have requested. You acknowledge that such sharing is at your own direction.
• Business and marketing partners. Third parties with whom we jointly offer products or services, or whose products or services may interest you.
• Linked third-party services. If you log into the Services with, or otherwise link your account to, a social media or other third-party service, we may share your personal information with that service. That third party's use of the shared information is governed by its own privacy policy and by the settings associated with your account there.
• Professional advisors. Advisors such as lawyers, auditors, bankers and insurers, where necessary in connection with the professional services they provide to us.
• Authorities and others. Law enforcement, government authorities and private parties, where we believe in good faith that disclosure is necessary or appropriate for compliance and protection purposes.

5.How to Exercise Your Rights

Users located in Europe can find further information about their rights in the "Notice to European Users" section below. Users located in U.S. states with privacy laws applicable to us can find further information in the "U.S. State Privacy Rights Notice" section below.

You may opt out of receiving promotional communications, such as our marketing emails, at any time. To do so, follow the unsubscribe instructions at the bottom of our emails or contact us at https://dreamgame.hk/. Push notifications can be disabled through the "options" or "settings" page within the relevant game.

You can opt out of interest-based advertising in mobile applications through your device's privacy settings by selecting "Limit Ad Tracking" (Apple iOS) or "Opt out of interest-based ads" (Android). To opt out of personalized in-game offers, please contact us at https://dreamgame.hk/.

6.Data Deletion

We will delete or anonymize your personal information when you take actions such as deleting information, disabling device functions or closing your account, subject to applicable laws. You may also exercise your right to request the deletion or removal of your personal information by submitting a request through the in-game "Support" button or contacting us at https://dreamgame.hk/. After verifying your identity, we will review and process your request within the period required by applicable law or, where no period is specified, within a reasonable period. We may retain information necessary to comply with legal obligations, process outstanding transactions, protect our legitimate rights and interests, or satisfy other lawful retention requirements. We will delete or anonymize retained information promptly after the relevant purpose has been fulfilled.

We generally retain the personal information we collect for as long as necessary to fulfill the purposes for which it was collected, including satisfying any legal, accounting or reporting obligations, establishing or defending legal claims, or for compliance and protection purposes. In determining an appropriate retention period, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it and whether those purposes can be achieved by other means, and applicable legal requirements.

Once we no longer need the personal information we hold about you, we may delete it, anonymize it, or isolate it from further processing.

7.Age Limit

A Child User of the Services who is below the minimum legal age in their jurisdiction may use the Services only after obtaining prior consent from a parent or legal guardian ("Parent"). For users in certain regions, the applicable minimum age as of the date of this policy is set out in the table below. We undertake never to collect a Child User's personal information before obtaining a Parent's consent. If we learn that we have collected personal data from a Child User without such consent, we will take reasonable steps to delete that data as promptly as possible. If you are the Parent of a Child User and wish to withdraw your consent or request deletion of your child's personal data, please contact us at https://dreamgame.hk/.

Accessing a Child User's personal data. A Parent may review, access and change their Child User's personal data. If you wish to withdraw your consent, please contact us at https://dreamgame.hk/. Following withdrawal, your child will lose access to the relevant features and the associated personal information will be deleted.

8.Privacy Policies of Linked Sites and Advertisers

The Services may contain advertisements and links to websites, mobile applications and other online services operated by companies other than Dreamgame. We are not responsible for the privacy practices or content of those third parties. If you have questions about how they use your information, please review their policies and contact them directly.

9.Security of Your Information

We have adopted reasonable technical and organizational measures consistent with generally accepted industry standards to protect the security of your personal information. To the extent permitted by applicable law, except where an information security incident is caused by our willful misconduct or gross negligence, we shall not be liable for unauthorized access, disclosure or other security risks arising from force majeure, unforeseeable malicious attacks by third parties, or your own acts or omissions, or other factors beyond our reasonable control.

10.Contact Us

If you have any questions, comments or concerns about this Privacy Policy, please contact us at https://dreamgame.hk/.

11.U.S. State Privacy Rights Notice

Unless stated otherwise, this section applies to residents of U.S. states to the extent those states have privacy laws applicable to us granting their residents the rights described below (collectively, the "State Privacy Laws").

This section explains how we collect, use and share the Personal Information of residents of these states and the rights those users may have regarding their Personal Information. Please note that not every right listed below is provided under each State Privacy Law, so not all rights will be available to all users. In addition, we may be unable to process your request if you do not give us sufficient detail to confirm your identity or to understand and respond to your request.

For purposes of this section, "Personal Information" carries the meaning given to "personal data," "personal information" or similar terms, and "Sensitive Personal Information" carries the meaning given to "sensitive personal information," "sensitive data" or similar terms, in each case as defined in the State Privacy Laws—except that neither term includes information exempted from the scope of those laws. In some cases we may provide a separate privacy notice to particular categories of residents, such as job applicants, in which case that notice applies instead of this section.

Your privacy rights

The State Privacy Laws may grant residents some or all of the rights listed below. These rights are not absolute, and some State Privacy Laws do not provide them. We may therefore decline your request in certain cases as permitted by law.

• Information. You may request the following details about how we have collected and used your Personal Information:
  • the categories of Personal Information we have collected;
  • the categories of sources from which it was collected;
  • the business or commercial purpose for collecting and/or selling it;
  • the categories of third parties with which we share it;
  • the categories of Personal Information we sold or disclosed for a business purpose;
  • the categories of third parties to whom it was sold or disclosed for a business purpose.
• Access. You may request a copy of the Personal Information we have collected about you.
• Appeal. You may appeal our denial of any validly submitted request.
• Correction. You may ask us to correct inaccurate Personal Information we hold about you.
• Deletion. You may ask us to delete the Personal Information we have collected from you.
• Opt-out.
  • Opt out of processing for targeted advertising. We may process Personal Information for targeted advertising purposes, and you may opt out of certain such processing.
  • Opt out of profiling / automated decision-making. We do not use your Personal Information for profiling or automated decision-making that produces significant financial effects or significant effects concerning housing, education, employment, health care, criminal justice, or similarly significant matters.
  • Opt out of other sales of personal data. We do not sell your Personal Information within the meaning of the State Privacy Laws.
• Consumers under 16. We have no actual knowledge that we sell or share the Personal Information of consumers under 16 years of age. We do not intentionally collect Personal Information from children under 13.
• Sensitive Personal Information. We do not intentionally collect or process Sensitive Personal Information other than as may appear in certain user-to-user messages, and in that case we do not process it for the purpose of inferring characteristics about consumers under California's privacy law.
• Non-discrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the State Privacy Laws.

Exercising your right to information / know, access, appeal, correction and deletion

You may submit such requests by contacting our support team via the "Support" button in the game, or at https://dreamgame.hk/.

Exercising your right to opt out of the "sale" or "sharing" of your Personal Information

While we do not sell personal information for money, we—like many companies—use services that help deliver interest-based ads to you as described above. The State Privacy Laws may treat our use of some of these services as "selling" or "sharing" your Personal Information with the advertising partners providing them.

Website: You may submit requests to opt out of tracking for targeted advertising purposes or other sales of Personal Information via the "Support" button in the game or at https://dreamgame.hk/. An opt-out request submitted through a browser will apply only to the browser and device from which it was submitted.

Game / Mobile Application: To opt out of the "sale" or "sharing" of personal information arising from your use of our games or mobile applications, please contact our support team through the "Support" button in the game, or contact us at https://dreamgame.hk/, providing your request, the mobile game name, your username and your email address so that we can match your request to the relevant account.

Verification of identity; authorized agents

We may need to verify your identity before processing your information / know, access, appeal, correction or deletion request, and we reserve the right to confirm your state of residence. To verify your identity, we may ask you to log into an online account (if you have one), provide identifiers that we can match against information previously collected from you, confirm your request using the email address or telephone number stated in the request, provide government-issued identification, submit a declaration under penalty of perjury, or provide other information where permitted by law.

Under some State Privacy Laws you may authorize an agent to submit a request on your behalf. We may need to verify your agent's identity and authority to act for you, and may require a copy of a valid power of attorney granted to your agent under applicable law. If you have not provided your agent with a power of attorney, we may ask you to take additional steps permitted by law to verify that the request is authorized—for example, by providing your agent with written and signed permission to exercise your rights on your behalf, supplying the information we request to verify your identity, and confirming that you have authorized the agent to submit the request.

Personal information we collect, use and disclose

The table below summarizes the Personal Information we collect, the purposes for which we collect it, and the third parties to whom we may disclose it, cross-referencing both the categories defined in the "Information We Collect and Process" section of this Privacy Policy and the categories of Personal Information specified in the CCPA (Cal. Civ. Code §1798.140). The table reflects our current practices and those during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us—for example, in free-form web forms—may contain other categories of personal information not described below.

Additional information for California residents

Shine the Light law. Under California's Shine the Light law (California Civil Code Section 1798.83), California residents may ask companies with whom they have formed a business relationship primarily for personal, family or household purposes to disclose the names of third parties to which certain personal information (as defined under that law) was disclosed during the preceding calendar year for those third parties' own direct marketing purposes, along with the categories of personal information disclosed. You may submit such requests via https://dreamgame.hk/. Your request must include the statement "Shine the Light Request," provide your first and last name and mailing address, and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency. Please note that we do not accept requests by telephone, mail or facsimile, and we are not responsible for notices that are improperly labeled or sent, or that are incomplete.

Additional information for Oregon and Minnesota residents

Third parties. You may request a list of the specific third parties to which Dreamgame has disclosed personal information by contacting us at https://dreamgame.hk/.

12.Notice to European Users

12.1 General

• Personal information. References to "personal information" in this Privacy Policy should be read to include "personal data" as defined in the GDPR. Under the GDPR, "personal data" means information about individuals who are directly identified or identifiable from it. The personal information we collect from and about you is described in more detail in the "Information We Collect and Process" section.
• Controller. HONGKONG DREAMGAME LIMITED is the controller of the processing of your personal information covered by this Privacy Policy for the purposes of European data protection legislation (including the EU GDPR and the so-called "UK GDPR," as applicable, together the "GDPR"). Please see the "Contact Us" section above for our contact details.
• Our GDPR representative. We have appointed a representative in Europe as required by the GDPR. You may contact our representative through Dreamgame at https://dreamgame.hk/.
• Our Data Protection Officer. We have appointed a Data Protection Officer, who is responsible for independently overseeing and advising us on our compliance with the GDPR (including compliance with the practices described in this Privacy Policy). To contact our Data Protection Officer directly, please email: service@dreamgame.hk.

12.2 Our legal basis for processing

For each purpose for which we use your personal information, the GDPR requires us to have a "legal basis." The legal bases we rely on are:

• where we need to perform a contract we are about to enter into, or have entered into, with you ("Contractual Necessity");
• where processing is necessary for our legitimate interests and your interests and fundamental rights do not override those interests ("Legitimate Interests")—further detail on the specific legitimate interests pursued for each purpose is set out in the table below;
• where we need to comply with a legal or regulatory obligation ("Compliance with Law");
• where you have given us specific consent to carry out the processing for the relevant purpose ("Consent").

The legal bases we rely on for each relevant purpose are set out below. For more information on these purposes and the data types involved, see "How We Use the Information We Collect."

12.3 No automated decision-making

As part of the Services, we do not engage in automated decision-making and/or profiling that produces legal or similarly significant effects.

12.4 Your rights

European data protection laws grant you certain rights over your personal information. If you are located in Europe, you may ask us to take the following actions in relation to the personal information we hold about you:

• Access. Provide information about our processing of your personal information and give you access to it.
• Correct. Update or correct inaccuracies in your personal information.
• Delete. Delete your personal information where there is no valid reason for us to continue processing it; you may also request deletion where you have exercised your right to object (see below).
• Portability. Transfer a machine-readable copy of your personal information to you or to a third party of your choosing.
• Restrict. Restrict the processing of your personal information—for example, if you want us to verify its accuracy or the grounds for processing it.
• Object. Object to our processing where we rely on Legitimate Interests; you may also object where we process your personal information for direct marketing purposes.
• Withdraw consent. Where we rely on your consent, you may withdraw it at any time.

Exercising these rights. You may submit requests via https://dreamgame.hk/. We may ask you for specific information to help confirm your identity and process your request. Whether we are required to fulfill a request depends on a number of factors (for example, why and how we are processing your personal information). If we reject a request in whole or in part, we will explain our grounds at the time, subject to any legal restrictions.

Your right to lodge a complaint with your supervisory authority. In addition to the rights above, if you are dissatisfied with our response to a request, or with how we process your personal information, you may lodge a complaint with the data protection regulator in your habitual place of residence.

For users in the European Economic Area, you may contact us at https://dreamgame.hk/ to obtain contact details for the data protection regulator in your country.

12.5 Data processing outside Europe

For EEA and UK users, transfers of personal information outside the EEA and UK, including transfers between our affiliates and to third parties, shall rely on applicable legal safeguards, including standard contractual clauses, adequacy decisions issued by relevant competent authorities, or other lawful transfer mechanisms recognized by applicable law. You may contact us at https://dreamgame.hk/ for further information about the specific mechanism used for the transfer and to request a copy of the applicable safeguards.