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Privacy Policy

Last modified: 18 Jan 2021
Effective Date: 21 Jan 2021

This Privacy Policy explains how XD Entertainment Pte. Ltd. (“XD”, “we”, “us” or “our”) may collect, use, store, process, or otherwise transfer the personal information which you provide to us when using our service, including but not limited to our websites, games and any related mobile applications.

We are committed to protect and respect your privacy by complying with applicable data protection laws including, without limitation, the Singapore Personal Data Protection Act (PDPA) and European Union General Data Protection Regulation (GDPR).

Please read this Privacy Policy carefully and understand it fully before using our service.

By proceeding to access and use our service, you agree and consent to the collection, use, store, process and transfer of your information as well as all terms and conditions specified in this Privacy Policy in the Republic of Singapore and other countries that may have different data protection regulations than your country. If you do not understand or do not accept this Privacy Policy in full, please do not use our service.

We reserve the full rights to update and amend this Privacy Policy to reflect any update or changes in data protection laws or our internal policies. We will endeavour to notify you of such updates and you hereby agree to regularly check new updates for as long as you use our service. By continue to use our service, you signify to us your acceptance to these updates and changes.

INFORMATION THAT WE MAY COLLECT

We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorized by you to disclose your personal data to us (your “authorized representative”) after (i) you (or your authorized representative) have been notified of the purposes for which data is collected, and (ii) you (or your authorized representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorized by law).

You may provide your data to us when using our service. As our services changes from time to time, the data you provide to us or we collect from you may vary depending on the service you are using. By continue to use our service and / or you providing your data to us, it will be construed as your agreement to the terms of our Privacy Policy.

The following are examples of the type of information that we may collect:

  • Mobile device’s unique device ID
  • Mobile device’s type and device name
  • Mobile Operating System and version number
  • Mobile number
  • Username & Password
  • Customer Support related data
  • Game related data such as game level, game progression, virtual currency, transaction related data etc.
  • Forum related data

HOW WE USE YOUR INFORMATION

We may use the collected information for a variety of purposes, primarily for providing, operating and improving our services. Such uses may include but not limited to direct communications with you regarding your account, new features and services, pre-sign up, online & in-game events, attending and resolving customer support related issues (e.g. verifying your identity, responding queries, requests, applications, complaints and feedback from you), trend and user behaviour analysis to improve our services.

In addition, we may send push notifications to your mobile device to provide game updates and other relevant communications. You may manage such notifications under your device's settings.

We may include the use of cookies for certain service such as for our websites. A cookie is a string of information that a website stores on a user’s computer, and that the user’s browser provides to the website each time the user returns. Cookies are widely used to provide better functionality and to increase efficiency.

Publicly Shared Information refers to information that you share publicly while using our services, such as postings in community forums, message boards and social media platforms. You agree that such information is considered as public information and you will not expect privacy or confidentiality under these circumstances. You agree that you shall not held XD liable in any way for display or disclosure of such information.

SHARING OF INFORMATION WITH THIRD PARTIES

We will not share your personal information with unrelated third party advertisers.

We will only share your personal information with third parties under the following circumstances:

Provide Services - we may share your information with our third party partners to provide the necessary services to you.

Required Disclosures - We will disclose information when we believe in good faith that disclosure is required or permitted by law such as court order or subpoena or if such disclosure helps to enforce our terms of use, events, promotions, game rules or to protect the safety and security of our users, employees and third parties, or the integrity of our services.

Mergers and Acquisitions Transactions

In the event that XD undergoes a business transition, such as a merger, acquisition, joint venture, corporate divestiture or dissolution, a sale of assets, or similar transactions, we may share, disclose or transfer your information, including personal information, to the other organizations that are parties to such transactions.

SECURITY OF YOUR INFORMATION

We are committed to safeguarding the personal information you entrust to us. We implement reasonable security measures to protect the security of your personal information and we constantly update our technology with the goal of better protecting your information.

While we take reasonable precautions to prevent possible vulnerabilities and attacks, unfortunately, no website or internet transmission is 100% secure. We cannot guarantee that unauthorized access, misuse, data loss, or other breaches will not occur. If we become aware that your personal information has been compromised, we will notify you within 72 hours and detail any information involved in said breach.

We urge you to take steps to secure your personal information, to use strong passwords, to log out of your account after use, and to use different passwords for different services with different companies. Your assistance is of paramount importance for the protection and security of your account.

Please contact us immediately if you believe your account or personal information is compromised.

AGE REQUIREMENT

Our terms of service forbids minors under the age of 16 to use any of our Services. We respect the privacy of minors, and we do not knowingly collect personal information from minors under 16 years old. We encourage parents and legal guardians to take an active role in managing their children's online activities. If you are between the age of 16 to 18, please ensure that you have parental consent before using any of our Services.

RIGHTS TO PERSONAL DATA

You have the rights to access, rectify and withdraw your personal information we hold about you at any point of time.

If you wish to make a data request with regards to your rights to personal data, please contact us at law@xd.com.

RIGHT TO ACCESS

You have the right to request a copy of the personal information we hold about you. Your information will be sent to you in English and in a computer readable format, unless another reasonable format is requested.

RIGHT TO RECTIFY

You have the right to have any inaccuracies of your personal information we hold about you rectified.

RIGHT TO WITHDRAW

You have the right to have your personal information we hold about you withdrawn. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

If you request for a withdrawal of personal information, where you gave us your consent to use your information for a limited purpose, the withdrawal request will not affect any processing that has already taken place. Your personal information will be deleted if it is no longer intended for its limited purpose, or if it was unlawfully processed.

In an event that there is any delay or dispute as to whether we have the right to continue using your information, we will restrict any further use of all your related information until the request is honoured or the dispute is resolved.

Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.

If you delete your account or withdraw your personal information, you will permanently lose access to our Services, including but not limited to:

  • Your purchases and transactions
  • Your game progress and related game data
  • Forum related data

RIGHT TO OPT OUT

You may opt out of receiving promotional communications from us by contacting us at law@xd.com to have your contact information removed from our promotional email list.

You may continue to receive transactional messages from us regarding our Services regardless of your promotional communications preferences.

DATA RETENTION

We will retain your personal information on our systems until it is no longer necessary to our Services, or as otherwise described in this Privacy Policy.

COOKIES

Small text files, called cookies, are deposited on your device each time you use your browser to visit our websites.

Cookies allow your preferences to be recognized when re-visiting our websites and for the content shown to be optimized. We use cookies to optimize your experiences for the following purposes:

  • For technical purposes, such as ensuring that our website is properly functioning and monitoring its performance.
  • For functional purposes, such as providing preferred settings (e.g. auto-filled username and password), improving user-friendliness.
  • For analytical purposes, to statically assessed the user’s behaviour, which gives us a better understanding as to how users interact with our websites.

Generally, most browsers accept cookies by default. You can enable or disable cookies at any time on the website or your browser. All cookies can be deleted via the browser's setting. However, we will not be able to guarantee the website's complete functionality without cookies.

CONTACT OUR DATA PROTECTION OFFICER

Thank you for taking time to read through our Privacy Policy. We hope you have a better understanding regarding our privacy policy and we have addressed your concerns about how we process your personal information. If you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, you may contact our Data Protection Officer by sending email to law@xd.com.

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