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Effective Date: June 30, 2023
We appreciate your participation in our games! This Privacy Policy explains what personal data Getsu Corporation Ltd. and our subsidiary Getsu Infinithy Ltd. and our affiliate company]]
Getsu Division Ltd. (“Getsu,” “we,” “our,” or “us”) collect, use, share and otherwise process about individuals (“you”) interacting with our games, websites, mobile applications and related services, which we refer to collectively as the Service.

1. Data Controller Information
1.1 Our group of companies comprises various legal entities and business units. In this Privacy Policy, the term "Controller" or "Controllers" refers to the company that determines the purposes and methods of processing your personal data. Please see our Controller list:
- Getsu Corporation Ltd.
Address: Unit B, 11/F, WAH KIT. Commercial centre, 302 DES. Voeux road, central Sheung. Wan, Hong Kong
Email: [email protected]- Getsu Infinity Ltd.
Address: Unit B, 11/F Wan Kit Commercial Centre 302 Des Voeux Road Central Sheung Wan, Hong Kong
Email: [email protected]- Getsu Division Ltd
.Address: Nikou Dimitriou, 45 Rose Court, 3rd floor, Flat/Office 301, 6031, Larnaca, Cyprus
Email: [email protected]1.2 The specific company serving as the Controller for your personal data depends on the Service you are using, typically the one responsible for providing that Service as stated in our terms of service.
1.3 Multiple Controllers may be involved in processing your personal data when it is shared with other companies for a specific purpose.
1.4 If you still have questions about the relevant Controller, please reach out to us using one of the contact methods provided below.

2. Age Limits
2.1 We do not intentionally collect or process personal data from children without parental consent. In the context of this Policy, a child refers to an individual who is under the age of 18 (or the minimum legal age for consent to collect and process personal data, if different under applicable law).
2.2 If you are a parent or guardian and would like to review, change, or delete your child's personal information, you may contact us as described below.

3. Purpose and Legal Basis for Processing
3.1 The lawful bases we rely on for processing personal data are:
3.1.1 When it is necessary to fulfill a contract we have with you, such as our Terms of Service;
3.1.2 When it is in our legitimate interest to process the data;
3.1.3 When we have obtained your consent.
3.2 There may also be cases where we are required by law to collect personal data from you, or where it is necessary to protect your vital interests or the vital interests of another person.

4. What personal data do we collect and when?
4.1 The types of personal data we collect vary depending on the specific Service you use and the legal obligations that apply to us.
4.2 Data you provide directly to us:
4.2.1 Contact information, such as your name and email address;
4.2.2 Player name and password for authentication purposes;
4.2.3 Profile information, including a profile photo if you choose to provide one;
4.2.4 Messages you send to the Service, such as chat logs and player support tickets;
4.2.5 Data you provide when participating in surveys, promotions, sweepstakes, competitions, and other events;
4.2.6 Any other data that you voluntarily provide to us, such as information to help identify a lost account.
4.3 Data we automatically collect when you use our Service:
4.3.1 Data related to your account and game progress;
4.3.2 Your IP address and mobile device identifiers, such as your device or advertising ID;
4.3.3 Data about your device, such as its name, operating system, browser type, and language;
4.3.4 Data collected through the use of cookies and similar technologies;
4.3.5 Approximate location data, which is derived from your IP address;
4.3.6 Data about your use of Service, including gameplay data, purchases made, and your interactions with other players within the Service.
4.4 Data that we collect from our partners and affiliates:
4.4.1 Data we receive when you connect a third-party tool, such as Facebook or Google, to our Service;
4.4.2 Data we receive from third-party providers of analytics and advertising networks;
4.4.3 Demographic data, which helps us determine the general location associated with your IP address;
4.4.4 Data used to combat fraudulent activity, such as identifying refund abuse in games or click fraud in advertising;
4.4.5 Data obtained from the platforms on which our games are hosted, which may be used to verify payments;
4.4.6 Data collected for advertising and analytics purposes to improve the quality of our Service.
4.5 Please note that the specific types of data collected by our partners may vary and are subject to their respective privacy policies.

5. How will we use your data?
Getsu collects your data so that we can:
5.1 To ensure the functionality of the Service:
5.1.1 Enable users to create accounts and enjoy our games and Service;
5.1.2 Efficiently administer and operate the Service;
5.1.3 Verify and process your payments;
5.1.4 Fulfill your specific product and service requests;
5.1.5 Send you essential service-related communications necessary for the Service's operation.
5.2 To enhance the player experience and improve the Service:
5.2.1 Update and enhance player profiles for accurate and relevant information;
5.2.2 Continually develop and improve the Service to provide an enhanced player experience;
5.2.3 Manage our interactions and maintain a positive relationship with you;
5.2.4 Provide social features within the Service to encourage player engagement and interaction;
5.2.5 Personalize your Service experience based on your preferences and requirements;
5.2.6 Respond to your inquiries, questions, and provide player support when needed;
5.2.7 Present Getsu offers within the Service and through other platforms, including email, to keep you informed;
5.2.8 Send important information such as updates, security alerts, and support messages related to the Service;
5.2.9 Facilitate communication among players to foster social interaction and collaboration.
5.3 To display personalized advertisements:
5.3.1 Track the content you access and your online behavior associated with the Service;
5.3.2 Deliver, target, and enhance our advertising and the overall Service.
5.4 To maintain a safe, secure, and fair Service:
5.4.1 Analyze and monitor Service usage and its social features to gain insights and improve performance;
5.4.2 Moderate chats, utilizing automated systems or manual review, to ensure a respectful and safe environment for all players;
5.4.3 Take necessary actions against fraudulent activities or inappropriate behavior to uphold the Service's integrity.
5.5 We may process your data for additional purposes if you grant us consent.

6. Marketing
6.1 We provide you with an opportunity to express your preferences with respect to receiving certain marketing communications from us. If you would like to update these preferences, you can submit a request at [email protected] You can also follow the ’unsubscribe’ instructions provided in any marketing email you receive.
6.2 Even if you opt out of receiving promotional communications, you may still receive non-promotional communications from us, such as important service updates or changes to our Getsu Terms of Service or Privacy Policy.

7. How do we store your data?
7.1 Your personal information will be retained for as long as is necessary to carry out the purposes set out in this Privacy Policy (unless a longer retention period is required by applicable law).
7.2 As part of our regular procedures, we may de-identify unused game accounts and review and de-identify unnecessary data. If you specifically ask for the removal of your personal data, we will retain it for the duration required to fulfill our legitimate business interests, which may include complying with legal obligations, resolving disputes, and enforcing agreements.
7.3 We use a variety of technical and organizational security measures, including encryption and authentication tools, to maintain the safety of your personal data.

8. Your data protection rights
8.1 As a user, you are entitled to the following:
- The right to access
You have the right to request for copies of your personal data.- The right to rectification
You have the right to request that we correct or complete any information you believe is inaccurate or incomplete.- The right to erasure
You have the right to request that we erase your personal data, under certain conditions.- The right to restrict processing
You have the right to request that we restrict the processing of your personal data, under certain conditions.- The right to object to processing
You have the right to object to Getsu’s processing of your personal data, under certain conditions.- The right to data portability
You have the right to request that Getsu transfer the data that we have collected to another organization, or directly to you, under certain conditions.- The right to withdraw consent
You have the right to withdraw your consent, where the processing of your data is based on your consent. If you withdraw your consent, we may not be able to provide you with access to all or parts of our websites and service.- The right to complain
The right to complain with the supervisory authority responsible for data protection matters (e.g., in the UK, the Information Commissioner’s Office). You can find a good overview of EU data protection authorities via the website of the European Data Protection Board.8.2 We have a one-month timeframe to respond to your request. If you would like to exercise any of these rights, please contact us at [email protected]

9. California Residents
9.1 This section applies to California-based consumers.
9.2 Data Collection
In the past 12 months, we have collected the following categories of personal information enumerated in the CCPA:
- Identifiers, including name, email address, and online identifiers (such as IP address).
- Commercial or transaction information, including records of products or services purchased, obtained, or considered.
- Internet activity, including browsing history, and interactions with a website, email, application, or advertisement.
- Geolocation data.
- Inferences drawn from the above information about your predicted characteristics and preferences.
9.3 Data Use
The reasons or objectives for collecting your personal data for business or commercial purposes are explained in section 5 of Privacy Policy.
9.4 Data Disclosure or Sale
We do not engage in the traditional sense of "selling" your personal data to third parties. However, we may share your cookie information and advertising identifiers with third-party advertising platforms to provide personalized advertisements, track app installations, and enhance the effectiveness of advertising campaigns. If this sharing falls within the definition of a "sale" under the CCPA (California Consumer Privacy Act), you may have the option to opt out of this sharing by following the instructions outlined in the Privacy Policy.
9.5 Minors
If you are a California resident under 18 years old and registered to use the Service, you can ask us to remove any content or information you have posted on the Service. To make a request, email us at [email protected] with “California Under 18 Content Removal Request” in the subject line, and tell us what you want removed.
9.6 Your rights:
9.6.1 You have the right to request the categories of personal information and specific pieces of personal information we have collected, stored, and shared about you, as well as how we obtained that information.
9.6.2 You have the right to request the deletion of personal information held by us or our service providers.
9.6.3 We will not discriminate or retaliate against you for exercising your rights under this section of our Privacy Policy.
9.6.4 You may request that we do not sell your personal information.
9.6.5 You have the right to authorize an agent to request on your behalf.
9.7 Right to Opt-out
To the extent Getsu sells your personal information as the term “sell” is defined under the CCPA, you have the right to opt-out of the sale of your personal information by us to third parties at any time. You may submit a request to opt-out by clicking Do Not Sell My Personal Information.
9.8 Right to Non-discrimination
You have the right not to receive discriminatory treatment by us for the exercise of any of your rights.

10. Data Sharing and Transfers
10.1 We disclose and share personal data with the following parties for the purposes outlined below:
Within our group of companies
As part of our affiliation with a group of companies, we collaborate and support each other in conducting our businesses. Consequently, we may receive your personal data for processing, based on a legal basis and in line with any permissions you have granted, as outlined in this Privacy Policy.
Outside our group of companies
- Other players and users
The Service allows players and users to interact with one another. This means that other players may have access to certain aspects of your profile, such as your profile data, in-game activities, and posted messages.
- Third-Party Service Providers
These providers assist us with various services, including hosting game servers, providing player support, managing advertising campaigns, analyzing user data, and preventing fraud. Getsu ensures that these providers adhere to the necessary privacy and security measures to protect your data and only process it for the specific purposes outlined by Getsu.
- Other third parties
In the event of a potential change in control of our business, such as a sale, merger, acquisition, or any other transaction or reorganization, we may share your information with interested parties. This includes sharing information as part of the due diligence process with new or prospective business owners and their respective professional advisors.
- Law enforcement bodies, authorities, and courts
We disclose information when necessary to prevent, investigate, or prosecute criminal activities. We may also disclose information in response to legal processes, such as court orders, subpoenas, or requests from regulators, government authorities, or law enforcement bodies.
- Advertising and Social Media partners
The Service incorporates features from our partners, including social media tools, APIs, SDKs, and in-game advertising. We may share your personal information with analytics systems to evaluate the performance of our Services and with third parties such as ad networks. By using our Service, you consent to the transfer of your information to these third parties and agree to their processing of your data in accordance with their privacy policies.
10.2 Our Service operates on a global basis, which means that your data may be transferred to any location in the world. Because privacy laws may vary from country to country, we take steps to ensure that appropriate safeguards are in place to protect your data, as described in this Privacy Policy. Our partners also use appropriate safeguards, such as standard contractual clauses approved by the European Commission and Privacy Shield certification for transfers to the United States, to ensure the protection of your data during international transfers.

11. Cookies and Tracking Data
11.1 We and our partners use cookies, which are small text files placed on your computer, to analyze how users interact with our Service. We also employ similar technologies such as web beacons, pixels, tags, and device identifiers. These technologies help us improve the Service, enhance marketing efforts, analyze data, and optimize website functionality.
11.2 To learn more about the specific cookies used on our website, including their names, providers, purposes (essential for website functioning, performance, or marketing), and lifespan, you can click on the Cookie Settings link located in the footer of each website. This link allows you to customize your cookie preferences and manage your settings at any time.
11.3 Please note that you have the option to decline the use of cookies by adjusting the settings in your browser. However, be aware that disabling cookies may limit your access to certain features and functionalities of our website.
11.4 Getsu works with various analytics and ad serving partners on our mobile apps, websites, and other online platforms. These partners may use cookies, web beacons, and similar tracking technologies to collect or receive data about you. Please refer to the links provided for more information about their privacy practices and opt-out options.- Facebook
Privacy Policy: https://www.facebook.com/about/privacy- Google
Privacy Policy: https://policies.google.com/privacy- TikTok
Privacy Policy: https://www.tiktok.com/legal/privacy-policy?lang=en- Twitter
Privacy Policy: https://twitter.com/en/privacy- Unity Technologies
Privacy Policy: https://unity3d.com/legal/privacy-policy11.5 How to delete cookies and opt out of targeted advertising and analytics:
11.5.1 If you want to limit behavioral advertising, you can do so by restricting ad tracking in your device settings. Please note that opt-outs are browser and device specific and it may take some time for your opt-out to take effect.
11.5.2 You can opt-out of interest-based advertising in mobile applications by going to the privacy settings on your Android or iOS device and turning off “Allow Apps to Request to Track” or selecting "Limit Ad Tracking" (Apple iOS) or "Opt-out of Interest Based Ads" (Android).
11.5.3 For display advertising on the website, you can also adjust your browser settings to limit certain tracking by means of cookies by visiting the following sites: http://www.aboutads.info/choices and http://www.youronlinechoices.eu.
11.6 Do Not Track
Currently, our website does not accommodate "Do Not Track" preferences that may be accessible in your browser. To learn more about Do Not Track, please visit donottrack.us.

12. Changes to the Privacy Policy
12.1 We may make updates to this Privacy Policy. We will inform you of any significant changes by posting a notice on our websites. We recommend checking this policy periodically to stay informed and ensure you are aware of any updates.

13. Contact
13.1 If you have any issues with our compliance you may contact at [email protected]. You also have the right to lodge a complaint with the data protection regulator in your jurisdiction.