Privacy Policy of Charge Win

 

Effective Date: October,19,2023

 

Zhihui Li( “we” “us”, “our”)is the provider of Charge Win products and services .In order to protect your personal information and privacy security, we have formulated this Privacy Policy in accordance with laws and regulations and generally applicable industry security standards. Before you use our product, we would like you to pay special attention to the following content:

This Privacy Policy sets out why we collect your personal information when you use our products (including downloading, installing, registering, using our products, etc.), how we collect your personal information, and how we store and manage your personal information.

This privacy policy only applies to the Charge Win and services we provide, and does not include any other third-party products. If our product is connected to products or services provided by other third parties, please have a detailed understanding of the content and relevant privacy policies of the third-party product or service before use, and decide whether to use it.

We have marked in italics and bold the content of this privacy policy that may affect your rights and obligations. Please read this section carefully. We reserve the right to modify and update this policy at any time, so please refer to the latest version of this policy. If you do not agree or accept the terms of this policy, please stop using the products and services we provide. If you continue to use this software after the terms of this agreement have been changed, we will consider you to accept and comply with the updated terms.

We may also explain to you the purpose, scope, and method of collecting corresponding information by updating instructions through instant notifications (including pop-up windows, page prompts, announcements, etc.). These instant notifications and feature update instructions form a part of this privacy policy and have the same effect as this privacy policy.

 

1. How We Collect and Use Your Personal Information

We will collect and use your personal information in accordance with the principles of legality, appropriateness, necessity and good faith. If we wish to use your personal information for other purposes or scenarios not specified in this Policy, or use the collected information for other purposes based on a specific purpose, we will notify you in a reasonable manner and regain your consent.Below we will explain how we collect and use this personal information according to the common types of personal information:

1.1 Marketing information.In order to better provide you with personalized customized services, we may collect your advertising information directly from you and third-party advertising partners (such as Facebook and Google) through third-party SDK (Appsflyer and AppLovin), such as your IP address, IDFA, Android advertising ID (AAID), and users can click/view our activities and creative materials, Your advertising ID and other user engagement data (purchase behavior and in app behavior) (collectively referred to as "advertising identifiers"), Facebook activity ID, user search criteria, and Google advertising campaign information and identifiers, such as advertising photos and videos on the advertising partner platform. We may also share some of your advertising information with third-party advertising partners such as Facebook and Google through third-party SDK (Appsflyer and AppLovin) to monitor the success of our advertising activities, such as your advertising logo, user application activities (including registration, purchase activities, inviting friends, and user retention), And other tracking information (mobile device ID, hash email address, demographic or interest data, browsed content or actions performed on websites/applications).

1.2 Application Data and Log Information(Open ID, IP address, IMEIMac address AndroidIddeviceIDdevice model and information regarding use of the Service).The information we collect is used to provide you with feedback. We will collect this information when you use our product.

1.3 Application analytics information. We will use this information for user area and device information to perform overall application analysis, including error repair, troubleshooting, and debugging; To conduct general analysis to improve our services; Review performance and payments; Make sure the game runs smoothly; Provides troubleshooting, such as resolving and remediating technical issues, bug fixing and debugging.

1.4 Customer Support information (name, open ID, device ID, application version, battery level, Wi-Fi strength, free space on phone, network type, iOS version, platform and network type, carrier, country code and any photos that you may wish to upload to illustrate problems,etc.).We collect the above information to provide you with battery reminders and customer service support in the app or via email, depending on your needs.

1.5 Device and application information(including device model, device name, device manufacturer, running process information, SDK version, and application package name,etc.). We collect this information to send you push notifications about announcements, updates or service-related information, application versions, carrier names and network types.

1.6 Security Information.We use this information to detect and prevent cheating and any domain hijacking on the Service.We may collect different information depending on the operating system of your phone, as follows:

•Android: device root state, list of installed cracker software, list of running cracker software, application file hash (encrypted), host file tampered with, running in Android emulator, Android SDK API level, device boot time, device brand and model, CPU structure and CPU model, resolution, sensor status, device kernel version, country code, language, available memory and available space, Internet type (WiFi/4G/3G).

1.7.You fully understand and acknowledge that in the following exceptional circumstances, our collection and use of personal information does not require your authorization and consent:

l This information is necessary for the conclusion and performance of the contract in which you are involved, or for the implementation of human resource management in accordance with the labor rules and regulations formulated in accordance with the law and the collective contract signed in accordance with the law;

l This information is necessary for fulfilling legal duties or obligations;

l This information is necessary for responding to public health emergencies or protecting the safety of natural persons' lives, health, and property in emergency situations;

l To handle personal information within a reasonable range for public welfare activities such as news reporting and public opinion supervision;

l Handle personal information or other personal information disclosed within a reasonable scope in accordance with the provisions of this Law;

l Other situations stipulated by laws and administrative regulations.

u According to legal regulations, if the sharing or transfer of deidentified personal information is carried out while ensuring that the data recipient cannot recover and re identify the individual, it does not belong to external sharing, transfer, or public disclosure of personal information. The storage and processing of such data do not require separate notice to you and your consent.

 

1.8.You fully understand and acknowledge that in the following exceptional circumstances, our collection and use of personal information does not require your authorization and consent:

This information is necessary for the conclusion and performance of the contract in which you are involved, or for the implementation of human resource management in accordance with the labor rules and regulations formulated in accordance with the law and the collective contract signed in accordance with the law;

This information is necessary for fulfilling legal duties or obligations;

This information is necessary for responding to public health emergencies or protecting the safety of natural persons' lives, health, and property in emergency situations;

To handle personal information within a reasonable range for public welfare activities such as news reporting and public opinion supervision;

Handle personal information or other personal information disclosed within a reasonable scope in accordance with the provisions of this Law;

Other situations stipulated by laws and administrative regulations.

According to legal regulations, if the sharing or transfer of deidentified personal information is carried out while ensuring that the data recipient cannot recover and re identify the individual, it does not belong to external sharing, transfer, or public disclosure of personal information. The storage and processing of such data do not require separate notice to you and your consent.

2. How we use cookies and similar technologies

In order to give you a better product experience, improve our product services and detect and prevent security risks in advance. We may need to understand your preferences, consultation and data analysis, and we may use cookies or similar technologies to collect and store information during your use of our products or services, and in doing so send one or more cookies or anonymous identifiers to your device. We do not use cookies for any purpose other than those described in this Policy, and you may retain or delete cookies as you prefer. You can clear all cookies stored in the software, and when you manually clear them, your relevant information will be deleted.

 

3. How We Store, Share and Protect Your Personal Information   

3.1 Store

According to our agreement with you, your personal information will be processed on servers that may not be in your country/region of residence. No matter where our server is located, we will take appropriate measures to protect your rights in accordance with this privacy policy.

Your information can be accessed from your place of residence through our support, engineering, and other teams around the world.

Marketing data collected or shared with third-party advertising partners such as Facebook and Google regarding you may also be stored and processed on our third-party SDK (Appsflyer and AppLovin) servers located in the United States. Customer support information may also be stored on the servers of our third-party partners located in the United States.

 

3.2 Share

We will share your personal information with third parties only in situations occur, as follows

 

The Service needs support provided by Third parties This situation includes:

(a)providers of cloud services that process information identified in this policy on their servers for the purpose of providing the Service, 

(b)to allow you to login through an existing social network account (e.g. Google Play), 

(c)and for the purpose of providing marketing and advertisements on ad partners’ platforms ( Facebook, Google, Apple, Twitter, Snapchat, Appsflyer and AppLovin) and monitor the success of our marketing and advertising programs on such platforms. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.

 

The Service needs support from the other companies within our corporate group In order to operate the Service and conduct surveys for us, the other companies within our corporate group may process your personal information. All related group companies may only use your personal information in accordance with this Privacy Policy.

For legal reasons Your personal information may be legally disclosed to regulators, judicial authorities and law enforcement agencies and other third parties for safety, security, or compliance with the law, when the personal information is needed to: 

(a)comply with a legal obligation or processes

(b)enforce our terms

(c)address issues relating to security or fraud, or protect our users. 

(d)enforce our terms and conditions and other agreements, including:

(i) investigation of any potential violation thereof

(ii)detect, prevent or otherwise address security, fraud or technical issues

(iii)or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction). These disclosures may be made in accordance with the conditions of a valid legal process, such as a subpoena, court order, or search warrant, with or without your permission and with or without notification. The terms of the legal process normally forbid us from notifying you of any such disclosures. If a governmental entity asks for your personal information and fails to offer the required subpoena, court order, or search warrant, we may seek your permission before disclosing the information.

 

To third Parties by virtue of merger & acquisition A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: 

(a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; 

(b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

 

3.3. How We Protect Your Personal Information

We will take security measures in accordance with laws and regulations and industry standards to protect your personal data and ensure that your personal information will not be leaked, damaged, lost, misused, unauthorized access or disclosure at any time; Realize encrypted storage, encrypted transmission and permission control; Conduct security and privacy protection training for employees from time to time to enhance employees' awareness of the importance of protecting personal information.

Please note and understand that the Internet is not an absolutely secure environment and we recommend that you take care of the security of your personal information, such as using complex passwords when using such tools.

If a personal information security issue unfortunately occurs, we will immediately set up a special emergency team, start the emergency plan, prevent the expansion of the security issue incident, and in accordance with the requirements of laws and regulations, timely inform you of the basic situation and possible impact of the security incident, as well as the disposal measures we have or will take, and provide you with suggestions for self-prevention and risk reduction. Remedial measures taken for you, etc. We will promptly inform you of the relevant situation of the event through SMS, telephone, push notification, etc. When it is difficult to inform the personal data subject one by one, we will make an announcement in a reasonable and effective manner. At the same time, we will also proactively report the handling of personal information security incidents in accordance with the requirements of the regulatory authorities.

4.  Minors

Our Service is not intended for minors. Minors must not use the Service for any purpose.We do not collect personal information from minors under these ages for any purpose. If you believe that we have personal information of a minors under these ages without parental/guardian consent, or if you are the parent or guardian of the user and wish to detele this information, please contact us at [ seaweeddepvel@gmail.com ] and we will delete such information.

 

5. Changes and updates to the Privacy Policy

We may revise this Privacy Policy from time to time. If this Privacy Policy is revised, we will display the changed Privacy Policy to you in a push notification, pop-up window, announcement, or other manner that complies with legal requirements when you log in and update the version.

 

6. Contact & Complaints

You can contact us in the following ways and we will respond to your request within 15-20 working days:

·If you have any questions or complaints about the way we handle personal information or this Privacy Policy, or ask to query, correct, delete your personal information, change the scope of your authorization and consent, the personal information subject may cancel the account, respond to your above requests, or refuse our use of your personal information. You can contact us at the following email address [ seaweeddepvel@gmail.com  ].

·If you are not satisfied with our response, especially if you believe that our processing of personal information has harmed your legitimate rights and interests, you may also seek resolution through the following external channels: File a lawsuit with the competent court in Tianhe District, Guangzhou, Guangdong Province, where this Policy is signed.

 

California

This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).

 

Collection and Disclosure of Personal Information

Over the past 12 months, the following personal information from or about you or your device has been collected and disclosed:

 

Category Detail Source

Identifiers such as your name as it appears on your social media profile, open ID / user ID, IP address, phone number, mailing address, email address, and nickname directly from you and your device and from social media platforms (if sign up via a social media account)

Internet or other electronic network activity information such as your information regarding your use of the Service, including level, score, date and other device information as described in the main policy directly from you and your device

Commercial information about any transactions within the Service such as what products were purchased and how much they cost directly from you and your device and the Google Play or Apple iOS store

Other information described in subdivision (e) of Section 1798.80. directly from you in the context of being our consumer

 

Purposes of Collecting Your Personal Information:

•To provide you the Service, including offering the Service, maintaining your account, and delivering audio and text messages;

•To process surveys;

•To improve our services, including the functionality of the Service;

•For security and verification purposes, including to prevent and detect fraudulent activity;

•To address and remediate technical issues and bugs.

 We disclose personal information to the following types of entities:

•Other companies within our corporate group who process your personal information in order to operate the Service

•Other companies that provide services on our behalf who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing the services to us

•Regulators and judicial authorities and law enforcement agencies

•Entities that acquire all or substantially all of our business

 

In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” in the CCPA. 

 

Rights under the CCPA 

If you are a California resident, you have the right to:

•Request we disclose to you free of charge the following information covering the 12 months preceding your request:

the categories of personal information about you that we collected;

the categories of sources from which the personal information was collected;

the purpose for collecting personal information about you;

the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and other specific pieces of personal information we collected about you;

•Request we delete personal information we collected from you, unless CCPA recognizes an exception; and

•Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.   

 

We aim to fulfil all verified requests within 45 days pursuant to the CCPA.  If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay. 

 

How to Exercise Your Rights

You may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may exercise your rights, if any, regarding other data by contacting us at [ seaweeddepvel@gmail.com  ].

 

European Economic Area (EEA)

When you are located in the EEA, you will have following additional rights: 

•To ask for a copy of your personal data to be provided to them, or a third party;

•To lodge a complaint about the processing of your personal data with your local data protection authority in the EEA.

 

When you are located in the EEA, your personal data will be transferred to recipients in countries located outside the EEA, which do not provide a similar or adequate level of protection to that provided by countries in the EEA.

 

You hereby expressly consent to the transfer of your personal data to recipients, as described in this Privacy Policy, which are located outside the EEA. You may withdraw your consent at any time.

 

You can use your accounts of the App to update and correct your personal data. You can also contact us and ask us to update or correct your data.

 

We do not knowingly collect personal data about children under the age of 13 (in EEA is under the age of 16). If a parent or guardian becomes aware that his or her child has provided us with data without their consent, he or she should promptly contact us and we take reasonable steps to ensure that such data is deleted from our files.

 

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to [seaweeddepvel@gmail.com].