YOUR PRIVACY RIGHTS – SUNBORN PRIVACY POLICY

The purpose of this Privacy Policy is to inform you about our information privacy practices and your privacy rights. Because the success of our Applications is dependent on building and maintaining goodwill with our users, we are committed to implementing measures designed to protect the privacy of those using the Applications (which term includes any SUNBORN websites; please see Definitions section for details). This Privacy Policy describes the types of information we collect; how we collect, use, and share the information; your choices related to our information practices; and how we protect your information.

Some terms used herein are defined in the last paragraph of the Privacy Policy. Please refer below for definitions. This Privacy Policy is governed by and incorporated by reference into the Terms available at Terms of Service, and should be interpreted consistent therewith.

You may be able to access third party services (including through links, advertisements, or other means), including social networks, such as Twitter, Facebook, and Google+, from our Applications. When doing so, please understand that those third parties have their own set of information practices. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third parties.

Table of Contents

1. Information Practices Concerning Children
2. Types Of Information We Collect
3. How We Collect Information About You
4. How We Use The Information We Collect
5. Sharing Of Your Information
6. Your Choices
7. Sunborn Account Deletion Agreement
8. Security Of Your Information
9. Changes To Our Privacy Policy
10. California Privacy Rights
11. Contact Us
12. Definitions

1. Information Practices Concerning Children

Our Applications are not directed to children under the age of 13 and we do not knowingly collect Personal Information from children. If you are under the age of 13, please stop using our Applications. It is our policy not to knowingly solicit or permit children under the age of 13 to provide their Personal Information for any purpose.

We encourage parents and guardians to take an active role in monitoring their children’s use of the Applications. In the event that we learn that we have inadvertently collected Personal Information from children under the age of 13, we will make efforts to promptly delete the information.

2. Types Of Information We Collect

You consent to us collecting the following information, including both Personal Information and non-Personal Information:

• Information We Collect About You. When you use our Applications, we may collect and store information from you directly. For example, when you register with us, we may collect certain information from you, including your name, email address, username, nicknames and passwords, and social networking and open market usernames and information, including profile pictures. Once registered, you may also have the option of completing a user profile.

  When you contact us, we also collect certain Personal Information in order to be able to respond to you.

• Your Contacts. We offer you the ability to locate, invite, and play games with your contacts. To do so, SUNBORN may request access to your address book or social networking accounts. We will ask you for your permission before we access and store your contacts.

• Your Device Information. When you use our Applications on your mobile devices, such as a phone or tablet, we may collect information regarding your devices, including your mobile unique device identifiers and Internet Protocol (IP) address. We may also collect the name you have designated for your device, the device type, the name of your mobile network and mobile provider, and the country from which you connect.

• Your Location. In order to allow you to use the location-based matching feature available in some of our Applications, we may track your location.

• Technical and Usage Information. When you use our Applications, we collect technical and usage information such as your browser type, browser language, referring and exit URLs, platform type, interactions with other users, and usage statistics with the Applications, such as connection times and download records. For more information on how we utilize log files and cookies, please see Section 3, “How We Collect Information about You.”

• Download and payment information: We collect information on what games you download and payments you make to us.

3. How We Collect Information About You

We may collect information about you, your device, and your usage in a number of ways:

• When Provided Directly from You. As mentioned above, we collect information about you directly from you in certain circumstances, including:

  • Account registration;
  • Contest registration and prize acceptance;
  • Customer support and/or technical service requests;
  • Player match up and other head-to-head online competitions;
  • Registration for games and/or special game-specific events;
  • Newsletter subscriptions, referral services, and other marketing surveys and email campaigns;
  • Creation of a personal profile;
  • Product, service and/or subscription orders;
  • Service requests from third party service providers made available to you as part of our Applications;
  • Your accessing our products and/or services on social networks or other third party services; and
  • Otherwise through use of our Applications and other online services where personal information is required for use and/or participation.

• When Communicated or Shared with Other Users. You may also participate in certain activities on our Applications that give you the opportunity to voluntarily communicate or share information with other SUNBORN users, such as Posting messages on a message board, Posting public comments to user profiles or games, sending private messages, sending invitations, and Posting photos. We may monitor, record and store these communications in order to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, or to protect and defend SUNBORN’s rights and property. You consent to the recording, storage and disclosure of such communications you send or receive for these purposes.

• Through log files, cookies, and similar technological means. When you use our Applications, SUNBORN may collect information about your use and interaction with those Applications. The bulk of this information is collected and stored through the use of technological means like cookies, log files, and analytical measurements and tools.

  • Cookies are small pieces of instruction stored on your hard drive or device, not on our Applications. Cookies may help you navigate the Applications as easily as possible, may allow you to customize your user experience in our Applications, or provide other means of enhancing the services we can deliver through our Applications. We may use cookies to deliver content specific to your interests and to prevent you from reentering your username and password each time you access the Applications. We collect information using cookies in order to analyze the usage of our Applications, for authentication purposes, and to improve and personalize the services we provide to you. Cookies may be delivered to your mobile device as part of your access to and use of our Applications. You may have the option to reject cookies, depending on the Application, your mobile device, and other factors, though rejecting cookies may impair certain functionalities offered from within the Application.

  • Log files are small files that typically contain IP addresses. An IP address is a numeric address that may be assigned to your computer by your Internet Service Provider. In general, we use log files to monitor traffic on our websites and through our Applications, to troubleshoot technical problems and authenticate users' entitlements to our products. In the event of user abuse of our websites or Applications, however, we use IP addresses or game system IDs provided by our licensed hardware manufacturers to exercise our right to block access to our websites or Applications. If available, IP addresses and game system IDs may be used in order to enforce our Terms

  • We may also make use of analytic metrics tools, whether created by us or by third parties, to collect information when you use our games, services, and Applications

    • These tools and technologies use server log files, web beacons, cookies, tracking pixels and other technologies to collect and analyze certain types of information, including cookies, IP addresses (including for purposes of determining your approximate geographic location), mobile or other hardware device ID or other device identifiers, the name of your mobile network and mobile provider, browser types, browser language, information passed from your browser (if any), referring and exit pages, and URLs, platform type, click information, information about your device, peripheral hardware, software and/or applications installed on your machine and/or device, domain names and types, landing pages, pages viewed and the order of those pages, advertising conversion rates, the date and amount of time spent on particular pages, other Internet and website usage information, game state and the date and time of activity on our websites or games, information about how your game is used, including game metrics and statistics, feature usage and purchase history, as well as unique hardware identifiers such as MAC Address, mobile unique device ID (if applicable) and other similar information.

    • Use of certain analytic tools may require the transmission and/or storage of information about you and your activities on services and devices not controlled by SUNBORN. For example, use of Google Analytics, a web analytic service offered by Google Inc. ("Google"), requires that certain information about your activities be transmitted to and stored on Google server based in the US. On behalf of SUNBORN, Google will use this information in order to evaluate your usage of this websites and/or Applications (as may be applicable), to make reports on website activities and/or to provide the website operator with other services related to this websites. Your IP-address collected by Google Analytics will not be matched up with other data of Google.

    • Similarly, certain third party analytic tools may allow the companies offering those tools to collect information on our websites or through our Applications for their own purposes. In such cases, information collected about you may be combined with information collected independently from other websites and/or other online or mobile products and services relating to your activities across their network of websites as well as online and/or mobile products and services. Such information is not subject to this privacy statement, nor is under the control of SUNBORN.

4. How We Use The Information We Collect

We may use the information we collect in the following ways:

• To create your account, which allows you to play our games and communicate with other SUNBORN users;

• To provide you with a customized or personalized experience;

• To provide you with technical support or to respond to your questions or comments;

• To identify and suggest connections with other SUNBORN users or to send invitations on your behalf to your social networking friends or contacts in your address book;

• For legal purposes, for example to enforce our Terms or to prevent fraud or other illegal activities;

• To provide you with relevant and targeted or direct advertising from SUNBORN or third parties;

• To send you e-mails with useful updates or promotions about our Applications and other products and services;

• To send you notifications (SMS, push, remote, or local) on your mobile device to provide you with useful information about our Applications and other products and services (to learn how you can manage the types of notifications you receive, follow the instructions under Section 6, “Your Choices”).

5. Sharing Of Your Information

It is our policy not to share your Personal Information with third parties for their own use except with the following parties or in the following circumstances. With respect to your non-Personal Information (such as anonymous, aggregated statistical data), we may share such information with third parties for various purposes, including for the purpose of explaining our user demographics or improving the quality or delivery of our services and the marketing materials available through the Applications. Although we will not share your Personal Information with third parties for the purpose of enabling third parties to send marketing materials to you about their products or the products of others, we may use third party advertisers (including Chartboost, AdMob, and Cauly) to deliver advertising within the SUNBORN mobile environment. We may share your non-Personal Information, including your operating system, country location, and Applications usage information with these third party advertisers for the purposes of delivering these advertisements. If you do not want us to share your Personal Information with the third parties set forth below for particular purposes as described, please see Section 6 below, Your Choices, or do not provide us any Personal Information or use the Applications. Usage constitutes consent to the practices described herein.

• Third Party Service Providers. We may use third party service providers, such as payment gateway companies, platform service companies, and analytics companies, to help us provide or improve the Applications we offer you. We may share your Personal Information with these third party service providers so that they may provide their services to us.

• Social Networking Users. Your profile, which will have your username and profile picture, may be visible to other third party social network users. In addition, your social networking friends may be able to see information about your uses and interactions with our Applications, for example your game results, scores, and profile information may be Posted on your Facebook Wall or on Twitter.

• Other SUNBORN Users. Some of your Personal Information (included in your profile and nicknames) may also be visible to other SUNBORN users, through the Applications or through related websites. Other SUNBORN users (both those who are your social networking friends and those who are not your social networking friends) may be able to view information about your uses and interactions, such as your game results, scores, and profile information.

• Legal Purposes. We may provide your Personal Information to third parties where we have a good faith belief that doing so is required by law or to cooperate with regulators or law enforcement authorities. We may also provide your Personal Information to third parties in order to protect the rights or property of a third party or SUNBORN, including enforcing our Terms.

• Health or Safety. We may share your Personal Information when we have a good faith belief that there is an emergency that poses a threat to the health or safety of you, another person, or the public generally.

• Sale or Merger. If SUNBORN is involved in a major business transition, such as a merger, acquisition by another company, or sale of its assets, we may transfer your Personal Information to the successor organization in such transition. If material changes to SUNBORN’s privacy practices will occur as a result of the business transition, we will amend the Privacy Policy and the Personal Information you previously submitted will continue to be treated pursuant to the last version of the Privacy Policy you agreed to unless you continue to use the Applications, which usage shall constitute consent to the new practices.

• Game Events. For some game related events, we may share information, including your profile and nicknames, with third parties.

6. Your Choices

SUNBORN provides you with a variety of choices to control the use and sharing of your information, including your Personal Information.

• Notifications (SMS, Push, Remote, and Local). You can usually opt out of receiving notifications by following these steps: (1) Go to Menu; (2) Settings; (3) Push “off” under “Push Notifications”. When we receive an opt-out request from you, we may send you a message confirming our receipt of your opt-out request.

• Accessing Your Contacts. We offer you the ability to locate, invite, and play games with your contacts. To do so, SUNBORN may need to access your address book or social networking friends lists. We will ask you for your opt in permission before we access and store your contacts.

• Cookies. You may be able to manually delete HTML cookies and set your browser to refuse HTML cookies by going into your browser’s settings. Note though that doing so may affect your experience with our Applications.

• User Profiles. You can change and update information in your user profile at any time. The information your previously provided may continue to be stored, however.

• Ads. Advertising associations offer methods (http://www.aboutads.info/choices/ and http://www.networkadvertising.org/choices/) by which you may be able to opt out of receiving behavioral advertising.

• Personal Information. You may at any time indicate that you wish us to stop processing your Personal Information (if such Personal Information is necessary for you to have an account, you will no longer be able to use the Game and may no longer be able to use other aspects of the Service).

7. Sunborn Account Deletion Agreement

The "Sunborn Account Deletion Agreement" (henceforth known as "This Agreement") is established between you ("the User" or "you") and Shanghai Sunborn Network Technology Co., Ltd. and its affiliates ("Sunborn", "Sunborn Network", "we", "our", or "us"). This Agreement is legally binding.

You understand and acknowledge that you are currently using the Sunborn Account ("Pass Account" or "This Account") deletion service provided by us. By agreeing to This Agreement and continuing, you acknowledge that you understand the consequences of deleting your Pass Account and voluntarily agree to be bound by all the terms in This Agreement. We would like to remind you again that the Pass Account deletion is irreversible; once deleted, you will no longer be able to log in or access any services provided by Sunborn Network with This Account, which include your past interactions with Sunborn Network and/or the goods or services provided by Sunborn Network ("Sunborn services" or "services") that you have registered and used. You will also not be able to recover any settings or information by logging in with your Pass Account (even if you register a new Pass Account and use Sunborn services with the same personal details).

Section 1 – How to delete your Pass Account

1. Before the deletion, you must make sure your Pass Account meets the following conditions:

• (1) This Account is registered through Sunborn's official channel by you for your own personal use in accordance with Sunborn's User Terms and Conditions and/or all relevant rules listed in other Sunborn services that are subjected to periodic modifications.
• (2) At the time of applying for a deletion, This Account is functional and the security of This Account is not at risk (including but not limited to this Pass Account being banned or frozen, showing unusual login activities, and showing other unusual activities).
• (3) This Account is free of any rights and/or encumbrance that are generated or maintained due to the existence of This Account; does not involve the illegal use of someone else's account; is not shared with a third party; and can under no circumstances cause dispute over the use of This Account or infringe on a third party's legal rights.

2. You should follow the steps listed herein to complete your Pass Account deletion:

• (1) You must delete your Pass Account through Sunborn Network's official channel and follow the instructions provided by the corresponding page to complete the account deletion procedure.
• (2) You have carefully read and accept all terms listed in This Agreement, understand clearly the consequences of deleting your Pass Account, and voluntarily agree to be bound by these terms.
• (3) If the Pass Account you intend to delete meets all the conditions listed in Clause 1, Sunborn Network will verify the security status of your Pass Account to ensure it is free of any irregularities that could affect the security of the account. You understand and agree that if This Account fails to meet any one condition listed in Clause 1, Sunborn Network is entitled to reject your deletion application and refuse to provide its Pass Account deletion service to you.
• (4) After the Pass Account you intend to delete clears the aforementioned security verification, you must verify the personal information provided at the time of registration, including the mobile number, email address, real name, password, and other personal details used to register This Account. You understand and agree that if the personal information you provide does not match that which was used to register this Account, Sunborn Network is entitled to reject your deletion application and refuse to provide its Pass Account deletion service to you.
• (5) After agreeing to this agreement and clearing both the security and personal information verification stages, This Account will officially enter an account deletion freeze period ("freeze period"). If you wish to log in or use any Sunborn services with This Account during the freeze period, you may click the "Activate" button on the login page to reactivate This Account. Upon clicking the "Activate" button, the account deletion process will terminate immediately, and you may resume normal use of This Account. If you do not log in or use any Sunborn services with This Account during the freeze period, once the freeze period expires, deletion of this Account will be complete, and all data stored within This Account will be lost permanently.

Section 2 – Consequences of deleting your Pass Account

1. Once your Pass Account is deleted, you will no longer be able to log in or use any Sunborn services with This Account. You will also not be able to recover any settings or information by logging in with your Pass Account, even if you register a new Pass Account and use Sunborn services with the same personal details.

2. You understand and agree that once your Pass Account is deleted, all content, information, data, and records you generated through logging in and using Sunburn services with This Account will be removed or processed anonymously (unless other legal regulations apply). You will no longer be able to access, transfer, acquire, continue to use, or retrieve all aforementioned content, messages, data, and records which have been removed or processed anonymously. You also forgo the right to request Sunborn Network to recover them for you. These content, information, data, and records include but are not limited to:

• (1) the personal data you provided when registering This Account, including your mobile number, email address, real name, password, and other personal information;
• (2) content and corresponding saved records generated by using all Sunborn services through This Account, including but not limited to game characters, game levels, corresponding achievements, virtual items, event participation records, friends, corresponding privileges, etc.;
• (3) all other content, information, data, records, etc. contained within This Account.

3. You understand and agree that once your Pass Account is deleted, Sunborn Network will remove all privileges or expected privileges (if any) generated by your use of This Account. Such privileges or expected privileges include but are not limited to:

• (1) your top-up balance accumulated throughout your use of This Account and all relevant virtual items acquired from topping up, including but not limited to virtual currencies, accumulated top-up privileges, items, characters, etc. purchased in-game;
• (2) online services already purchased through This Account that have not expired, including but not limited to monthly cards, dashboard packages, appearance packages, battle vouchers, costume packages, background packages, passes, etc. of all Sunborn Network games;
• (3) other generated but unconsumed privileges and/or expected possible privileges in This Account.

4. Once your Pass Account is deleted, the agreement you signed with Sunborn Network when you registered and used This Account as well as relevant Sunborn services will be terminated, with the exception of the parts within the agreement which will remain in effect, or where other legal regulations or This Agreement apply.

5. Other consequences caused by the deletion of your Sunborn Pass Account (if any).

Section 3 – Disclaimer

1. Despite the above terms, once your Pass Account is successfully deleted:

• (1) you will remain legally responsible for your behavior while using Sunborn Network services before the deletion of your Pass Account, Sunborn Network also retains the right to pursue legal action against such behavior according to corresponding terms and conditions in Sunborn Network's agreement;
• (2) you or other persons can still browse or access all public content you created on the internet through search engines and/or other third-party platforms.

Section 4 – Others

1. This Agreement is made in Xuhui District, Shanghai. Any dispute between the parties regarding the content of This Agreement or its execution (including but not limited to disputes over the contract or any other right or interest in property) is to be settled through friendly negotiation. If no settlement can be reached, both parties agree to submit the case to the People's Court of Xuhui District of Shanghai.

2. Sunborn Network reserves the rights to amend, alter, and revise This Agreement

.

8. Security of Your Information

Although we do not represent that we follow any particular, independent code of best practices, we maintain reasonable physical, electronic, and procedural safeguards to protect your information. For example, we protect some of your information by using a firewall and Secure Socket Layer (SSL) encryption.

While we take reasonable precautions against possible security threats, there is no such thing as “perfect security” on the Internet, so we cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. We strongly recommend that you take steps to maximize the security of your information, such as not sharing your login information and logging out of your account after you are done using our Applications.

We store your information in the United States as well as other territories. You consent to such storage and to the transfer of information from one territory to another.

We will take reasonable steps to require any third parties who you authorize us to share your Personal Information with to comply with the terms of this Privacy Policy.

9. Changes to Our Privacy Policy

From time to time, we may make changes to this Privacy Policy. If we amend this Privacy Policy, we will notify you and other users by Posting a revised version of the Privacy Policy. Any changes to this Privacy Policy will take effect upon Posting on the effective date which is Posted at the bottom of this Privacy Policy. Your continued use of the Applications after any such changes signifies your acceptance thereof.

10. California Privacy Rights

In some circumstances, California residents would have the right to request information from us regarding the manner in which we share your Personal Information with third parties for their direct marketing purposes. However, we do not share your Personal Information with third parties for the purpose of direct marketing. If you have any questions regarding our practices, please email us at hello@sunborngame.com.

11. Contact Us

If you have any questions or concerns regarding our Privacy Policy or our information practices generally, you can e-mail us at hello@sunborngame.com. We allow you to access and change or modify your information as previously provided. You may do so by accessing and modifying your information through the Applications. To protect your privacy and security, we will take reasonable steps to verify your identity before granting access or making changes or modifications. Unfortunately, we cannot always ensure that such changes or modifications will be reflected in all iterations of your information as previously stored.

12. Definitions.

“Applications” → Our communications tools, which may heretofore or hereafter be accessed by users through any medium or device now known or hereafter devised, including but not limited to communication tools such as websites, software, mobile games and applications. Unless explicitly stated otherwise, any new tools that alter or improve the current Applications shall be included in the definition of “Applications.”

“Including” → “Include,” “Includes,” “Including,” “include,” “includes,” and “including” herein mean including without limitation.

“Personal Information” → Any information concerning the personal and material circumstances of an identified or identifiable individual. This includes information like name, postal address, e-mail address or telephone number, but also usage date in some cases. Usage data are data required to use our website, for instance information about start, end and extent of website use as well as login data.

“Post” → To upload, post, create, make available, send, share, communicate or transmit.

“Privacy Policy” → This policy available at Privacy Policy.

“Terms” → The terms and conditions, available at Terms of Service, and the Privacy Policy, available at Privacy Policy.

Effective Date: 2023.05.01