This Privacy Policy outlines how WAH FUNG LIMITED (“we,” “us,” or “our”) collects, processes, retains, discloses, and safeguards your personal data when you interact with our digital products and services. These services include mobile applications, web-based platforms, interactive game environments, promotional programs, loyalty initiatives, customer feedback mechanisms, and marketing outreach. We are committed to transparency, compliance with the applicable data protection regulations of the Hong Kong Special Administrative Region, and enabling users to exercise control over their personal information.

By accessing or continuing to engage with our platforms, you acknowledge that you have read and accepted the practices described in this Policy.

1. Scope of Application

This Privacy Policy is applicable to all digital systems, applications, and channels managed by WAH FUNG LIMITED. This includes but is not limited to mobile games, official websites, communication tools, account management systems, and support infrastructures. Whether you are a registered user, guest, beta tester, or promotional participant, this Policy governs how your data is handled.

Should you have any questions or concerns, you may contact us at:

Email: [email protected]

2. Types of Data We Collect

We collect different types of data depending on how you engage with our services. This allows us to maintain and improve our operations, deliver a more personalized experience, and fulfill our legal obligations.

2.1 Data You Submit Voluntarily

Registration Information: When creating an account, we may collect your username, email address, password, avatar, location (region or country), language setting, and confirmation of age eligibility.

User-Generated Content: This includes any custom profile details, uploaded media, in-game messages, or forum comments you submit.

Promotions and Surveys: Information provided when entering contests, participating in beta programs, completing surveys, or submitting feedback.

Support Requests: Any communications with our support teams, including logs, screenshots, or crash reports you voluntarily provide.

2.2 Data Collected Automatically

Technical Identifiers: Device-specific information such as IP address, device type, operating system, browser configuration, unique identifiers (e.g., IMEI), and system language.

Usage Statistics: Engagement metrics like time spent in-app, feature navigation paths, gameplay interactions, latency data, and menu selections.

Security Monitoring: Logs related to unauthorized login attempts, exploit detection, and integrity assessments.

Location Information: If granted permission, we may collect geolocation data to tailor region-specific experiences or to comply with legal disclosure requirements.

2.3 Information from Third Parties

Social Media and Login Services: If you access our services through external platforms, we may receive profile identifiers such as your name, email address, and display image.

Advertising & Analytics Partners: Data from ad impressions, user segmentation, re-engagement metrics, and behavior modeling tools.

Payment Providers: Transaction statuses, anonymized billing data, and associated payment tokens used for validation or processing.

Our approach is to collect only the information necessary for clear and legitimate purposes.

3. How We Use Your Data

The data we collect serves a range of functional and operational needs:

Account Management: Enabling registration, login verification, account recovery, and user credential management.

Personalization: Tailoring your in-game experience, preferences, matchmaking, and interface language.

Product Enhancement: Informing development of new features, content updates, and gameplay refinements based on usage trends.

Support Efficiency: Logging service requests, identifying common issues, and enhancing troubleshooting resources.

Promotions and Engagement: Sending notifications about campaigns, rewards, new content, and personalized recommendations.

Security and Fair Play: Identifying automated activity, fraud, unauthorized access, or unfair gameplay behavior.

Compliance Requirements: Keeping transaction logs, managing age-restriction protocols, and preparing for audits.

Analytics and Insights: Conducting user behavior analysis, A/B testing, and market research to inform business strategies.

All data usage is supported by legal grounds such as contractual necessity, user consent, or legitimate business interests.

4. Cookies and Similar Technologies

We use cookies, SDKs, tags, and similar technologies to gather analytics, deliver features, and improve the performance of our services.

Session Persistence: Keeping users logged in and restoring app states.

Performance Metrics: Tracking system load times, frame rates, and feature responsiveness.

Feature Experimentation: Activating test features for selected user cohorts.

User Flow Analysis: Recording clicks, navigation sequences, and engagement levels.

Advertising Attribution: Monitoring campaign effectiveness and referral sources.

You may manage or disable cookie preferences in your browser or device settings. Disabling certain tracking features may impact user experience or functionality.

5. Data Disclosure Practices

We do not sell your personal data. However, we may disclose it under the following circumstances:

Authorized Service Providers: Including vendors who assist with hosting, data analysis, payment processing, marketing support, or fraud prevention.

Corporate Affiliates: Within our group of companies to maintain consistent service and share backend infrastructure.

Legal Compliance: In response to lawful subpoenas, government inquiries, or other regulatory obligations in the Hong Kong Special Administrative Region.

Business Transfers: In the event of a merger, acquisition, or sale of company assets, we may share data under confidentiality safeguards.

User-Directed Sharing: When you request integration with third-party services or choose to link external accounts.

We require all third parties to maintain strict confidentiality and uphold appropriate data protection measures.

6. Data Storage and Protection

To safeguard your data, we employ a multilayered security approach:

Global Redundancy: Storing data across multiple geographic regions to reduce downtime risk and ensure reliability.

Encryption Standards: Using TLS for data in transit and AES-256 for storage-level encryption.

Access Controls: Limiting staff access to sensitive information based on operational role and necessity.

Vulnerability Testing: Conducting internal audits and engaging third-party firms to assess security posture.

Monitoring Systems: Implementing real-time anomaly detection and automated alerts for suspicious behavior.

Backup and Recovery: Maintaining secure backup procedures and disaster recovery plans.

We regularly evaluate our retention schedules to avoid storing data beyond its intended purpose.

7. Your Rights and Choices

Depending on your jurisdiction, including Hong Kong, you may have certain legal rights regarding your personal data:

Access: Request a copy of your personal data that we hold.

Rectification: Ask us to correct inaccurate or incomplete data.

Erasure: Request deletion of your data under applicable conditions.

Portability: Obtain your data in a machine-readable format.

Restriction: Limit how your data is used in specific contexts.

Objection: Object to processing based on legitimate interest.

Withdrawal of Consent: Revoke any consent you previously granted.

8. Protection of Children’s Data

We do not intentionally collect personal information from individuals under 13 years of age, or the minimum age allowed by local laws. If we discover that such data has been collected inadvertently, we will take prompt action, including:

Deleting the data permanently.

Deactivating any associated accounts.

Notifying the responsible parent or guardian, where feasible.

9. Cross-Border Data Transfers

Due to the global nature of our services, some data may be transferred to and processed in jurisdictions outside the Hong Kong Special Administrative Region. We ensure such transfers comply with international data protection principles through:

Contractual Safeguards: Adopting standard clauses approved by data protection authorities.

Compliance Programs: Aligning practices with frameworks such as those modeled after the GDPR.

Vendor Risk Assessments: Evaluating all third-party processors for legal compliance and security performance.

Records of all such transfers are maintained and reviewed regularly.

10. Policy Updates

This Policy may be updated periodically to reflect regulatory developments, technology changes, or modifications to our data processing activities. We will notify users of substantial changes via:

App or website banners.

Direct emails.

In-product pop-up messages.

You are encouraged to revisit this Policy regularly. Continued use after any update indicates acceptance of the revised terms.

11. Contacting Us

For questions, concerns, or data-related requests, please contact us:

Email: [email protected]

Address: ROOM 63, 7/F, WOON LEE COMM BLDG, 7-9 AUSTIN AVE, TST HK

We are committed to responding promptly and transparently.