PRIVACY POLICY

Last revised: June 04, 2024

This Privacy Policy describes how We collect and process personal information to support Our products and services, when You interact with Us and are using Our online and mobile games, vouchers for digital services, other digital content and other services, including the online functions of multimedia products, the websites and mobile sites (collectively “Websites”), servers, software and the framework through which these services are provided (collectively, the “Services”). This Privacy Policy respects the Personal Information Protection and Electronic Documents Act (PIPEDA), and regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, directly applicable from May, 25th, 2018 (hereinafter, "General Data Protection Regulation", or "GDPR"), the privacy laws of the United States, as well as the data privacy laws in all the various jurisdictions in which we operate and have users. When this Privacy Policy refers to “personal information”, it also refers to “personal data” as defined by the GDPR.

The controller of the information processed in connection with this Privacy Policy and within the meaning of data protection regulations, is Changyou.com HK Limited (“We”). You can find our contact details and the contact details of our Data Protection Officers for Your Country/Region in Article 11 of this Privacy Policy.

This Privacy Policy also describes Your rights regarding Your personal information. In this respect, please see Article 9 “WHAT ARE YOUR RIGHTS” and Article 10“FOR U.S. RESIDENTS”.

For information about how we collect, use, share, and otherwise process the personal information of users under the age of sixteen (16) years old (or applicable age in their territory), please refer to Article 8 “CHILDREN’S PRIVACY”.

1. WHAT INFORMATION WE COLLECT

We collect and process Your personal information at different times when You interact with our Websites and Services. Generally, personal information is collected either if:

(i) You provide it to Us；or

(ii) Is automatically collected by Us (i.e. via technology) ；or

(iii) Is obtained from other sources (third parties).

The personal information We collect about You generally depends on how You interact with Us, such as which Websites and Services You use and how You use those Websites and Services.

1.1. Information You provide Us

● Registration Information

We collect information that You provide when You set up an account, such as Your email address and information we import from Your connected social media account (such as Facebook, Apple, Google, Twitter , etc.), including Your name as it appears on Your social media profile, Your user ID and Your profile picture. You can add other information to Your profile.

● Services and Contact Information

When You set up Your profile for Our Websites and Services or participate in our promotional activities, or when You contact Us via our customer service, You may provide Your name, user ID, telephone number, email address, age, country as well as Your feedback. For certain regions, You may also be asked to provide Us with Your date of birth (stored device-side only) for age verification or compliance with applicable laws and regulations.

● Purchase and Transaction Information

When You use Our Websites and Services; especially when You carry out transactions through Our Websites and Services (where applicable) or with Our third-party payment service provider(s), We may collect transaction information, namely on products or services purchased, obtained, considered, or other purchasing or consuming histories or tendencies, bank account and payment information (where applicable), including data in regard to Your activities, orders, use of the Websites and Services and the advertising and other content You engage with.

● Chat Information

Furthermore, We collect personal information of Your chats and other information about the people and accounts You interact with and associated metadata (such as the time the message was send, received and/or read, as well as the participants in the communication).

● Contests, Game, Surveys, Research, Marketing

We collect data provided by You, when You register for a contest, for games or game specific events; or respond to surveys, as well as information related to competition, contests or tournaments You participate in, and/or other information You provide to Us. Also, We collect marketing and communications data, such as Your preferences in receiving marketing materials, Your communication preferences and history of communications with Us and our service providers.

1.2. Information we collect automatically from You

We collect some information automatically when You visit, access, or use Our Services. This includes information about Your gameplay or application usage, purchases, entitlements, and other activity in our Services, typically associated with Your account (if You are logged into Your account or use a third-party account to access our Services) or with an identifier we have assigned to Your device or profile. While the specific types of information that we automatically collect may vary, they generally include:

● Technical Information

We collect certain device and network connection information when You access the Websites and Services. This information includes Your device model, the device system, network type, user agent, browser type and language, device language, mobile carrier, time zone settings, identifiers for advertising purposes, device IDs, country code, series ID, Android ID, IDFV, Your screen resolution and operating system, app and file names and types, battery state, audio settings and connected audio device. Use of Technical Information is necessary to perform our contract with You to provide Our Websites and Services.

● Communication Logs

You may also provide or generate information when You communicate with other users (chat log data and chat content, both audio and text). We generate a user ID and use this to store Your game data, and we collect and store Your game play statistics (e.g. level, scores) in order to provide You with feedback, information about Your game play and progress.

● Location related information

For example, we may collect Your general location when You use the location-related services, in order to provide relevant service for You, which we typically derive from Your device’s IP address.

1.3. Information third parties give Us (other sources)

We may receive data, including the following, from third parties and combine it with data we have already collected from You directly. All data will be treated in accordance with this Privacy Policy.

● If You sign up to be a user of our Services using Your social media account(such as Facebook, Apple, Google, Twitter , etc.), link Your account with Us to Your social media account or use our social media features, We may access information about You which You have voluntarily provided to Your social media account provider in accordance with the provider's policies, such as Your email address, user ID, nickname, public profile and other contact information;

● Advertisers and other partners share information with Us about You and the actions You have taken outside of the Websites and Services, such as Your activities on other websites and apps or in stores（such as Apple Store, Google Play , etc.）, including the services You purchased, online or in person. These partners also share information with Us, such as mobile identifiers for advertising, hashed email addresses and phone numbers, which we use to help match You and Your actions outside of the Websites and Services with Your account.

● We use a variety of anti-cheat and fraud prevention technologies to help Us identify and prevent malicious activity. These services may collect and analyze data about Your computer and the software on Your computer to detect cheating and may be provided by service providers.

If You do not want Us to collect the aforementioned information/personal information, You may opt out at any time by notifying our Data Protection Officer via the means set forth in Article 9 of this Privacy Policy. Further information on opting out can be found in the section below entitled "WHAT ARE Your RIGHTS" (Article 9). Note, however, that opting out or withdrawing Your consent for Us to collect, use or process Your personal information may affect Your use of the Websites and Services.

2. HOW WE USE YOUR PERSONAL INFORMATION

This section explains how We may use the personal information We collect about You.

We will only use Your personal information for certain specified reasons and only when We have a legal basis to do so. We collect and further process the personal information described above in Article 1 for the following reasons:

2.1. The contractual need to process data

The information You submit to Our Services and the data We collect automatically is collected and processed by Us as set out in this Privacy Policy for the Provision of our Websites and Services, i.e. to register Your account and to allow You to access Your account and our Websites and Services and to provide You with content, products and services through our Website and Services. In addition, We may use the submitted information to answer Your demands, to send You order confirmations and other information regarding Your account, our games and website or the use of Our Services.

We may have to duplicate some of Your personal information within Our databases for technical reasons, or for any other reason indicated in this Privacy Policy. We may use all data collected, also in the chat logs, to enforce our Terms of use, guidelines or policies, to carry out Our legal obligations, and to protect Our rights and the rights and safety of our affiliated companies, users, and employees. The information We receive from other users will be stored by Us and used primarily to help You and Your friends to connect with each other.

2.2. Our legitimate interest

We may also process Your personal information to offer the best possible experience to users, and improve the Websites and Services (e.g. by way of in-game data analytics, etc.). We also use Your personal information for Our internal marketing and demographic studies, so We can constantly improve the Websites and Services we provide You and to better meet Your needs. It is in Our legitimate interest to process Your personal information for these purposes.

2.3. Marketing communication

We may send You advertising or promotional materials, including information about special rebates, promotional offers and other events of interest, based on Your preferences.

We also use Your personal information for our internal marketing and demographic studies, so We can constantly improve the Websites and Services We provide to You to better meet Your needs.

2.4. Your Consent

To provide You with supplementary services (custom content, etc.), We will ask for Your consent before processing Your personal information for this purpose.

2.5. To comply with legal obligations

We might be subject to legal obligations to share personal information with authorities. Your personal information may be disclosed to any relevant judiciary or administrative entity, in accordance with the relevant legal provisions (see Article 5.3, below). This may in particular apply, in regard to Your date of birth, Your age to control access to our games, forums and live chats, in accordance with the relevant laws and regulations.

3. SECURITY

We take Your privacy and the security of Your personal information very seriously. To protect Your personal information, We maintain appropriate safeguards to ensure the security, integrity and privacy of the information You have provided. We use robust security measures to protect personal information from loss, misuse and alteration. We use industry-standard practices such as encrypted communications, physically secured rooms, firewalls and password protection systems to safeguard the confidentiality of Your personal information. In addition, We take reasonable steps to assure that third parties who collect personal information on Our behalf provide sufficient protection of personal information, in addition to requiring their compliance with this Privacy Policy at all times. We will notify users of a data breach pursuant to applicable law.

However, please note that no existing data transmission method on the web, or electronic storage, can guarantee the absolute security of Your personal information. If Your accounts and personal information of Our Websites and Services are protected by a password, You are responsible for ensuring this password’s confidentiality. Please do not disclose this password. If You share a computer or other device with other people, please consider disconnecting from Your accounts before allowing others to use Your computer. Services may contain links leading to third party websites, including but not limited to social media sites. Whenever You click on a link leading to a third party’s website, leave Our Websites and Services as governed by this Privacy Policy. Please note that We do not control such third party’s website and we cannot ensure that third parties’ websites will be governed by the same security and confidentiality obligations. Please consider checking privacy policies of any service provider You transfer Your personal information to.

4. FOR HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION

Unless relevant legal provisions mandate a different data storage and retention period, We will store Your personal information only as long as necessary to process it according to this Privacy Policy. For instance, We may retain certain information after You close Your account for a period of time needed to protect Us from legal claims. In this case, We will archive Your personal information during the relevant statutory period of limitations.

5. WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

We disclose Your personal information to third parties only to the extent described in this Article 5.

5.1. Sharing Your personal information with our affiliated companies

We may share Your personal information among our group of companies. To the extent that Our corporate affiliates and/or technical partners have access to Your information, they will follow practices that are at least as restrictive as the practices described in this Privacy Policy. Such data transfer takes place for the performance of the contract, in particular in order to be able to offer Our Websites and Services.

5.2. Sharing Your personal information with third parties

5.2.1 While browsing on Our Websites, or while using Our Services, external providers may collect Your personal information for and on behalf of Us (such as Facebook, Google, Twitter and Windows, etc.) and We may share some of Your personal information with these partners to allow the functioning of the Websites and Services. For example, these third parties may help provide discounts or offer products, promote the Services, perform electronic payment processing, and any other service that may be required by Us. External providers must comply with this Privacy Policy when collecting Your personal information. These external providers will share Your personal information with no one besides Us, and they may not use Your data for their own independent marketing purposes, unless You consent to their privacy policy and terms of use directly.

5.2.2 In an attempt to provide You with increased value, we may choose various third party websites to link to, and frame within, the Websites or Services. We may also participate in co-branding and other relationships to offer e-commerce and other services and features to Our users. These linked sites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with Us, we have no control over these linked sites, each of which has separate privacy and data collection practices independent of Us. Data collected by our co-brand partners or third party websites (even if offered on or through our Websites or Services) may not be received by Us.

5.3. Sharing Your personal information with government authorities

In accordance with relevant laws, We may have to disclose Your personal information to a judiciary or administrative entity, whenever such disclosure is deemed necessary for protecting or enforcing Our, users’, or third parties’ legal rights. We will notify You before disclosing Your personal information, unless such notice is not required by law.

5.4. Sharing Your personal information in case of mergers

In the unlikely event that our business activities or shares are transferred partly or totally to any third party, such third party may access Your personal information. In this case, We may also allow Your personal information to be transferred to the acquiring third party.

6. DO WE MAKE YOUR PERSONAL INFORMATION PUBLIC? WHO CAN SEE YOUR PERSONAL INFORMATION?

We may offer a public profile feature ("Public Profile") that allows You to publish information, including personal information, to the public Internet. The information You upload or input to Your Public Profile will default to the privacy level You choose. You can choose to change the privacy settings at any time (for the change of in-game elements such as head portrait and character’s name, please refer to the settings interface in the game application. For the change of other settings such as microphone and location access, please consult Your device's manual for more information). By default, certain aspects of the Public Profile are set to "public". Those aspects of the Public Profile that are designated as "public" will be visible to everyone, potentially including people not registered within our environment, and may be indexed and displayed through public search engines when someone searches for You. If You post Your personal information to a Public Profile, including a video, image or photo, You should be aware that these may be viewed, collected, copied and/or used by other users without Your consent.

7. OUR GLOBAL OPERATIONS AND DATA TRANSFERS

7.1. To support our global operations

Our corporate group operates around the world. Pursuant to our contract with You to provide You with the Game Services, Your personal information will be processed on servers that may not be located where You live. Your information can be accessed from outside of where You live by our support, engineering and other teams around the world. No matter where our servers are located, we take appropriate measures to safeguard Your rights in accordance with this Privacy Policy. Our servers for the Game Services are located in Singapore.

Certain entities in our Corporate Group, located outside Your country of residence, are given limited remote access to this information so they can provide certain functions, as described in the Our Corporate Group section in Article 5 “WITH WHOM DO WE SHARE Your PERSONAL INFORMATION?”. This access is limited, secure and only granted where necessary under strict security controls and authorisation approval protocols.

7.2. Transfers of personal information to third countries

Please be aware that Your personal information may be transferred to, stored in, and processed by affiliated companies, developers, servers, subcontractors and/or Our partners, located in third countries outside Your region. Some personal information recipients are located in countries that are not considered as ensuring an adequate protection level according to the GDPR and other statutes in force enacted by EU Commission. In such case, We use the strict framework of the GDPR as well as EU Commission’s approved standard contractual clauses under Article 46 (1), (2) lit. c) GDPR, which are available on the EU Commission website (https://commission.europa.eu/publications/standard-contractual-clauses-international-transfers_en) . Because different jurisdictions may have different data protection requirements, We take steps to implement adequate safeguards to protect Your data. To receive a copy of the standard contractual clauses, please contact Us via the contact details provided in Article 11 of this Privacy Policy.

8. CHILDREN’S PRIVACY

With parental consent, We may collect personal information from children. In some cases, we may ask the user to provide Us with their date of birth for age verification. If such information indicates the user is under the age stipulated by the applicable laws and deemed as child under such laws, we will not collect further personal information from the child until a parent/guardian’s verifiable consent is obtained.

By children, we mean users under the age of sixteen (16) years old; or in the case of a region where the minimum age for processing personal information differs.

9. WHAT ARE YOUR RIGHTS

You have certain rights in relation to the personal information we hold about You, depending on where You are located. Some of these only apply in certain circumstances (as set out in more detail below).

You can access and update the contact information You gave Us during registration (that is, Your e-mail address or any other information that would directly enable Us to contact You), by logging in and clicking the in-game settings interface. Additionally, You have a right to access, rectify, erase, object, or restrict processing for all Your personal information processed by Us, as well as the right of data portability. You can exercise these rights by contacting Us via the means set forth in Article 11 of this Privacy Policy. We will answer Your request within a month following the receipt of Your demand. We reserve the right to extend this delay up to two months if it being necessary regarding the complexity of Your demand, or based on the number of demands We receive. In such case, We will inform You of this extension within a month following the receipt of Your demand. For any data processing activity requiring Your consent (e.g. behavioral advertising), You may withdraw Your consent at any time. This withdrawal does not affect the lawfulness of any previous processing.

● Access

You have the right to access personal information We hold about You. In particular, You can request information about the processing purposes, the category of data, the categories of recipients to whom Your data has been or will be disclosed, the planned storage period, the existence of a right to rectification, erasure, restriction of processing or objection, the existence of a right of complaint, the origin of Your data if it has not been collected by Us, as well as the existence of automated decision-making including profiling and, if applicable, meaningful information about its details. You can access the personal information You have made available as part of Your account by logging into Your account. If You believe We hold any other personal information about You, please contact Us via the means set forth in Article 11 of this Privacy Policy.

● Portability

You have the right to receive a copy of certain personal information We process about You. This comprises any personal information We process on the basis of Your consent or pursuant to our contract with You. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that We transfer that personal information to another party, with certain exceptions according to relevant laws and regulations. We will provide further information to You about this if You make such a request.

If You wish Us to transfer such personal information to a third party, please ensure You have listed that party in Your request. Note that We can only do so where it is technically feasible. Please note that We may not be able to provide You with personal information if providing it would interfere with another person’s rights (for example, where providing the personal information We hold about You would reveal information about another person or Our trade secrets or intellectual property).

● Correction/Rectification

You have the right to correct any of Your personal information We hold that is inaccurate. You can access the personal information We hold about You by logging into Your account. If You believe We hold any other personal information about You and that information is inaccurate, please contact Us via the means set forth in Article 11 of this Privacy Policy.

● Erasure/Deletion

You can delete Your account, or remove certain personal information, by logging into Your account. If there is any other personal information You believe we process that You would like Us to erase, please contact Us via the means set forth in Article 11 of this Privacy Policy. If You make a request for erasure of Your personal information we will endeavor to erase the personal information within 30 days of Your request, or inform You if it will take longer.

We may need to retain personal information if there are valid grounds under data protection laws for Us to do so (for example, for the defense of legal claims or freedom of expression) but we will let You know if that is the case. Where You have requested that we erase personal information that has been made available publicly on the Service and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.

After the deletion of Your account, we reserve the right to store Your profile and any content on our servers for a reasonable period of time, but not longer than 2 years from Your notice of deletion. This helps Us to restore Your account quickly if You want to return to our Services. If You want to delete Your information permanently please select an option to “delete my account permanently”.

● Restriction of Processing to Storage Only

You have a right to require Us to stop processing the personal information We hold about You other than for storage purposes in certain circumstances. Please note, however, that if We stop processing the personal information, We may use it again if there are valid grounds under data protection laws for Us to do so (for example, for the defense of legal claims or for another’s protection). As above, where We agree to stop processing the personal information, We will use reasonable steps to inform any third party to whom We have disclosed the relevant personal information so that they can stop processing it too.

● Retention of personal information

We may retain Your personal information as long as needed to provide Our Websites and Services or products to You, or as required or permitted by applicable laws, such as tax and accounting laws, or for the exercise or defense of legal claims. If You make a request for erasure of Your personal information and We determine that there is a valid basis for Your request, We will endeavor to erase the personal information within 30 days of Your request, or inform You if it will take longer.

● Right to Object

You also have the right to object to the processing of Your personal information. We will stop the processing in question if We do not have compelling legitimate grounds to continue such processing or if processing is not necessary for legal claims.

● Withdraw of Consent

You may withdraw any consent You previously provided to Us for certain processing activities by contacting Us via the means set forth in Article 11 of this Privacy Policy. Where consent is required to process Your personal information, if You do not consent to the processing or if You withdraw Your consent We may not be able to deliver the expected service.

● Complaint with the supervisory authority

You also have the right to lodge a complaint with the supervisory authority responsible for Us or for You. You may lodge the complaint with the supervisory authorities in the member state of Your place of residence.

● Objection against Profiling and Targeted Marketing

At any time You have the right to object to our processing of personal information about You in order to send You promotions, special offers and marketing messages, including where we build profiles for such purposes and we will stop processing the personal information for that purpose. Please provide as much detail as possible on Your reasons for the request to assist Us in determining whether You have a valid basis for objection. However, we may retain the personal information if there are valid grounds under law for Us to do so.

To the extent provided by applicable laws and regulations, You may withdraw any consent You previously provided to Us for certain processing activities by contacting Us via the means set forth in Article 11 of this Privacy Policy. Where consent is required to process Your personal information, if You do not consent to the processing or if You withdraw Your consent we may not be able to deliver the expected service.

● Announcements

We may from time to time send You announcements when we consider it necessary to do so (for example, when we temporarily suspend the Service’s access for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.

10.PRIVACY POLICY UPDATES

We may update or amend this Privacy Policy from time to time in particular to take account of technological or organizational changes and / or changes in data protection law. As a result, please consider checking this Privacy Policy from time to time.

If You do not accept changes made to this Privacy Policy, please refrain from using the Services.

11.CONTACT US

You can contact Us under:

Changyou.com HK Limited

Room 1901, 19/F, Lee Garden One, 33 Hysan Avenue, Causeway Bay, Hong Kong

Bill

CS-JRFF@cyou-inc.com

For any question related to Your personal information processing and this Privacy Policy, please contact our Data Protection Officer.

If You are located in European Economic Area, our Data Protection Officer is

Jasmine

CS-JRFF@cyou-inc.com

If You are located in Countries and regions outside the European Economic Area, our Data Protection Officer is

Lily

CS-JRFF@cyou-inc.com

Please be assured that any Personal information that You provide in communications to the above email and postal mail addresses will not be used to send You promotional materials, unless You request it.