Privacy
Policy
Starshine
Hong Kong Games Co., Limited
(“Starshine
Hong Kong Games”or “we,” “us,” “our”) take your
privacy very seriously. This Privacy Policy ("Policy")
explains how we, as the data controller, collect, use, and protect
your personal data (also known as personal information in certain
jurisdictions) when you access, use, and play our games, features,
content, and services related to our games, related websites, and
other online services ("Services"). Before
using our services, please read and understand this policy carefully
so that you can better understand our services and make appropriate
choices.
You
can view this policy and adjust your privacy settings at any time
through the in-game settings interface. In-game
settings interface .
If you have any questions, please follow the instructions below. 9
Please refer to the instructions in the "Contact Us"
section to get in touch with us.
This
policy will help you understand the following:
Personal
data we collect
When
you use our services, we may collect your personal data. Personal
data generally refers to any information relating to an identified
or identifiable natural person. An identifiable natural person is
one who can be identified, directly or indirectly, in particular by
reference to an identifier such as a name, an identification number,
a location address, an online identifier or to one of the factors
specific or particular to the physical, physiological, genetic,
mental, economic, cultural or social identity of that natural
person.
Please
note that the data listed in this policy may not constitute personal
data as defined by applicable data protection laws. Personal data
should be interpreted in accordance with applicable data protection
laws and shall not be interpreted in a manner that conflicts with
the rights and obligations set forth in such laws.
Personal
data does not include "anonymized" data, which is
information we collect about the use of our services, a group or
category of products, services, or users, or information from which
personal identifiers or other personal data have been removed so
that it cannot be used to directly or indirectly identify an
individual. This data helps us understand trends and user needs so
that we can better consider new features or otherwise customize our
services. This policy does not in any way limit or restrict our
collection or use of such data. However, if we combine or associate
aggregated data with your personal data in a way that enables us to
directly or indirectly identify you, we will treat the combined data
as personal data and process it in accordance with this policy.
We
may collect data that you actively provide to us, data that we
automatically collect when you use our services, and certain data
that we obtain from third-party sources.
Personal
data you provide to us
When
you use our services, you may provide us with the following types of
data:
Advertising
preference settings data .
If
you authorize us to collect your advertising identifiers (such as
IDFA), we may use it to provide you with a more relevant advertising
experience.
Customer
Service Data .
When
you contact us for support or feedback, participate in events or
surveys we organize, or subscribe to our information push
notifications, we may collect your information, including your name,
email address, shipping address, and any other details you provide
to us. The specific personal data collected will depend on the
relevant interface displayed or the content of your communication
with us.
Personal
data we collect automatically
When
you use our services, we automatically collect certain information.
This includes:
Identifier
data .
This
includes your device identifier (e.g., device IP Address, IDFV、
Android
ID、
Google
AID、
IMEI）and
your device IP Address. The approximate location will be based on IP
Address inference.
Equipment
and technical data This includes your device model,CPU Information,
storage capacity, Screen size, network type, country where the
device is located/Region, device language, operating system version,
device time zone, and other technical information.
Use
data . Information about your interactions with our services,
including game events, scores, session duration, interactions, and
other gameplay information.
Advertising
data . Information related to ads and interactions with ads,
including the ads displayed, the time period during which the ads
were visible, ad sizes, the number of times ads were displayed, the
number of clicks, and the number of conversions. This data helps us
measure the effectiveness of ads.
Personal
data we receive from third parties
We
may also obtain information about you from third parties, including:
social
media platforms
When
you choose to use Google When you log in to your account, we will
use the account verification service provided by them,
andreceivenecessary
information (such as encrypted login codes, login status, etc.) to
enable account functionality. Please note that your use of any
third-party solutions for registration, as well as any personal data
you provide to such third parties or that is collected by them, will
be governed by their terms of use, privacy policy, and other
policies, and access to their registration services is subject to
their terms of use, privacy policy, and other policies. You may view
their privacy policies in detail via the following
links:https://policies.google.com/privacy。
When
youparticipate
in activities hosted on third-party platforms, we may, with your
authorization, receive information related to your participation in
such activities, subject to the specific terms of the relevant
activity notice.
app
store
When
you Apple App Store Google Play When you subscribe to the app, we
will receive your device ID、
Payment time, payment sequence
(encrypted), and payment status .
Please note that payment transactions for in-app subscriptions are
processed through the app store platform using your app store
account. We do not process payments for in-app subscriptions or
access your credit card information.
Personal
data not involving special categories
Certain
categories of personal data, such as information about your race or
ethnicity, religious or philosophical beliefs, etc., are considered
more sensitive than other categories of personal data in certain
jurisdictions and therefore require a higher level of protection.
For clarity, our services do not collect any such special categories
of personal data.
How
we use your personal data
We
process your personal data only for specific purposes and only to
the extent necessary to achieve those purposes. Specifically, we use
the personal data we collect for the following purposes, in
accordance with the purposes described in the above processing
activities:
Provide,
maintain, and perform our services
In
particular:
We
use your personal data to provide our games, ensure that they run
properly on your device, provide updates, and fix any malfunctions
or crashes.
We
use the necessary personal data you provide to verify your in-game
subscription so that you can complete the subscription process.
We
use the personal data you provide for account login, verification,
and management to fulfill the account functions you request; and
We
use your personal data in accordance with the rules of the activity
you have chosen to participate in, in order to fulfill the terms of
the agreement we have reached with you, such as the distribution of
rewards.
Improve
game performance and user experience
In
particular:
We
analyze your personal data to improve the stability, security, and
overall performance of the game. This helps us understand how you
interact with the game, identify areas for improvement, and optimize
the overall user experience.
We
analyze your personal data to understand user trends, preferences,
and interactions with our games. This helps us make data-driven
decisions to improve the quality of our services, develop new
features, and customize your gaming experience based on your
preferences.
Send
service information by group
We
use your personal data to send you information related to our
services, such as test invitations, basic update information, and
new features that may be of interest to you.
Provide
customer support and respond to your inquiries.
We
use your personal data to provide you with timely and accurate
customer support, respond to your inquiries, and handle complaints
or feedback. This ensures that we can resolve any issues you may
encounter and improve our services based on your feedback.
Ensure
safety and compliance with legal obligations
We
use your personal data to improve the safety and security of our
games, detect and prevent fraud, and comply with laws and
regulations. This includes verifying your identity, protecting your
account, managing your consent, and ensuring that our services
comply with applicable laws and regulations.
Provide
advertising and marketing communication services
In
particular:
We
use your personal data to place advertisements in our games and
measure their effectiveness. This includes general advertisements
and personalized advertisements; as well as
We
may also use your data to promote our games through other
applications or online services.
Conduct
investigations and other activities
Participation
in these activities is voluntary, and we will obtain your consent if
required by applicable law.
We
process your personal data only on the legal basis permitted by
applicable law. The legal basis will depend on the specific context
and purpose for which we collect and use your data.
If
you reside in the European Economic Area (EEA), we will process
personal data related to your use of our products and services in
the following circumstances:
Contract
Necessity: We need to collect and process certain data in order to
enter into a contract with you and fulfill our contractual
obligations. This applies to section 2.1 Section "Providing,
Maintaining, and Performing Our Services".
Legitimate
interests: We may process your personal data based on our legitimate
interests. However, this is subject to the condition that these
interests are not overridden by your interests or fundamental rights
and freedoms. So that we can operate and improve our business. This
applies to:
---Section2.2Section
Improve game performance and user experience;
---Section2.3Section
Send service information by group;
---No.
2.4Section Provide customer support and respond to your inquiries;
---No.
2.5Section Ensure safety and comply with legal obligations;
---The
2.6 Section Placing advertisements and marketing information. If the
relevant processing is for the placement and display of
non-personalized general advertisements or for our basic advertising
effectiveness measurement, such processing is necessary. Specific
details will be provided when you open our application through our
CMP(Consent Management Platform) for display.
Fulfilling
legal obligations: We may collect and use your personal data as
required by applicable law to fulfill our legal obligations. This
clause applies to the following: 2.5 Section "Ensuring Safety
and Compliance with Legal Obligations".
Agree:
In limited circumstances, and where the legal basis for the above
processing does not apply, We will collect certain data with your
explicit consent. This applies to Section 2.6
Section "Providing Advertising and Marketing Communications"
and Section 2.7 Section "Management of Surveys and Other
Activities." You may withdraw your consent at any time, but
this will not affect the validity of processing activities conducted
prior to withdrawal. For more details, please refer to Section
"Management of Surveys and Other Activities." 6
Section 'Your Legal Rights' .
Other:
We may also collect and use your personal data based on other legal
grounds as permitted by applicable law.
How
we share your personal data
In
order to provide you with more convenient and efficient services, we
may share your personal data with our partners or entrust data
processing parties (and/or sub-processors) to process your personal
data for the purposes described in this policy. In such cases, we
will require the data recipients to keep your personal data strictly
confidential and to process only the necessary data within the scope
of their contract or legal obligations and under our control. We
will not disclose your personal data to third parties unless we have
obtained your consent or there is another legal basis for doing so.
We may share your personal data with the following categories of
third parties:
Our
affiliated companies. Your personal data may be shared with our
affiliates to the extent necessary to fulfill the purposes of
processing specified in this policy, to provide you with the
services you have requested, or to conduct necessary IT Maintenance
and operation. In doing so, we will comply with applicable data
protection laws and ensure that your personal data is adequately
protected.
Technical
service providers. In order to provide you with basic services, we
may introduce some service providers in our products and services,
including:
Data
Storage Service Provider: We use Amazon Web Services, Inc. ( Web
Services, Inc.）.
You
may review their privacy policy for more
details:https://aws.amazon.com/privacy/.
Crash
analysis service provider: We use SmartBear
(Ireland)
Limited provides "bugsnag SDK”. You may review their privacy
policy for more details: https://smartbear.com/privacy/
.
Information
Push Service Provider: We use Google LLC Through "Google
Firebase SDK” provided
"Firebase Cloud Messaging”Services. You may review their
privacy policy for more details:https://policies.google.com/privacy
.
Privacy
Management Service Provider: We use Google LLC Provided by "Google
UMP SDK”Manage privacy. You can view their privacy policy details
via the following link:https://policies.google.com/privacy
.
Advertising
partners. We may share your data with advertising partners to
identify you or your device, deliver ads to you or your device, and
measure the effectiveness of those ads. The data we share may
include device identifiers (GAID or IDFA）、IP
Address and other information related to ad delivery and your
interaction with ads, such as device, screen, application, version,
user agent, network, SIM Data related to cards, time zones, and
cellular network locations.
These
service providers may use API、
SDK、Cookie
or other similar tracking technologies to collect information about
your device and your use of the Services. We use a CMP Manage
consent and permissions related to our advertising activities and
request our advertising partners to process personal data in
accordance with the permissions we transmit. .
These partners may process your data in accordance with their own
privacy policies. For further information, please refer to Appendix
-Advertising
Partner List ’.
If you wish to withdraw your consent or opt out of
advertising-related matters, please refer to The
6 Section ‘Your legal rights’ b
Below.
Certain
third-party services also allow you to post information about your
gaming activities on their websites for sharing with others. If you
use these features, the privacy policies and terms of those
third-party services will apply to your conduct on those websites
and to the information they collect.
In
addition, we may disclose your personal data in the following
circumstances:
When
we choose to sell, transfer, or merge any part of our business or
our assets, the new owner will assume all of our rights and
obligations under this policy.
In
cases involving national security, law enforcement, or public
interest.
International
transfer of personal data
In
order to facilitate our business operations in global markets, we
may store your personal data on local servers or servers located in
other countries based on the technical configuration of our
services, and may transfer your personal data to service providers
located in different countries for processing. Such arrangements are
subject to change at any time.
When
your personal data is transferred to a recipient located in a
foreign country and such transfer meets the definition of
international transfer or cross-border transfer of personal data
under applicable laws, we will determine the legal basis for the
transfer and take appropriate security measures to ensure that the
level of protection required by applicable laws is met.
Specifically:
If
you reside in the European Economic Area (EEA), and
If
your personal data is transferred to a country that has made an
adequacy decision/region (such as Israel, the United Kingdom, and
the United States (participating in the EU)-Commercial organizations
in the United States under the U.S. Data Privacy Framework) will be
subject to the adequacy determination mechanism;
If
your personal data is transferred to other countries/region, we will
assess the effectiveness of personal data protection and
cybersecurity safeguards and take measures as required by applicable
law. For countries located outside the European Economic Area (EEA),
we will assess the effectiveness of personal data protection and
cybersecurity safeguards and take measures as required by applicable
laws. "14">)/regions, we generally agree to apply the
EU Standard Contract Clauses (SCC), to ensure compliance with the
legally required level of data protection. You may review them here.
SCC More information (including text copy):
https://commission.europa.eu/
publications/standard-contractual-clauses-international-transfers_en.
Data
security and data retention
We
are committed to protecting the security of your personal data. We
take reasonable and appropriate administrative, technical,
organizational, and physical security and risk management measures
in accordance with applicable laws to ensure that your personal data
is adequately protected while in our possession, preventing its
accidental or unlawful destruction, damage, loss, or alteration,
unauthorized or unlawful access, disclosure, or misuse, as well as
any other unlawful processing of your personal data.
We
will only retain your personal data for as long as is reasonably
necessary to fulfill the purposes outlined in this policy. When your
personal data is no longer required for the purposes outlined in
this policy, we will delete or anonymize your personal data, unless
otherwise required by applicable law.
Your
legal rights
You
may have certain legal rights regarding the processing of your
personal data, which vary depending on your jurisdiction, including:
Access
rights. You may request access to your personal data held by us.
Right
to rectification. If you believe that your personal data is
inaccurate, you may request that we correct it.
Delete
rights. You may request that we delete your personal data. If you
are located in a country where you have the right to request the
deletion of your personal data, you may exercise this right by
contacting us at the email address provided in the "Contact Us"
section of this Privacy Policy. >/region is part of the European
Economic Area (EEA), you have the right to request that we delete
your personal data in the following circumstances:
a)
The
corresponding processing purposes have been achieved;
b)
We
have processed your personal data unlawfully;
c)
You
have withdrawn your consent to the processing of data, and there is
no other legal basis for continuing to process the data;
d)
You
have successfully objected to the processing of your data.
e)
Where
there is an obligation to delete personal data under EU law or the
law of an EU member state applicable to us; or
f)
Personal
data is processed in accordance with the General Data Protection
Regulation (GDPR) >GDPR) Article 8 Article 1 The information
collected is used to provide the information society services
described in the relevant section of this policy.
Restrict
processing rights. You have the right to request that we restrict
the processing of your personal data. If you are located in a
country where you have the right to restrict processing, you can
exercise this right by contacting us at the email address provided
in the "Contact Us" section of this Privacy Policy.
>/region is part of the European Economic Area (EEA), you have
the right to request that we process your personal data only within
a limited scope under the following conditions:
a)
The
accuracy of your personal data is in question;
b)
You
have requested that personal data be restricted rather than deleted
in accordance with the conditions for legitimate deletion.
c)
The
data is no longer relevant to the purposes for which we collected
it, but you require the data to assert, exercise, or defend legal
rights; or
d)
The
success of the objection remains controversial.
Data
portability. You have the right to request that we assist you in
transferring your personal data to another entity. If you are
located in a country/region is part of the European Economic Area
(EEA), you have the right to obtain from us the personal data
concerning you that you have provided to us in a structured,
commonly used and machine-readable format, and to request that we
transmit this personal data to another data controller under the
following conditions:
a)
Data
processing is based on consent or contract; or
b)
Processing
is done through automated means.
Right
to object. You have the right to object to the processing of your
personal data. If you are located in a country/region is part of the
European Economic Area (EEA), we will no longer process your
personal data unless we can demonstrate compelling legitimate
grounds for the processing that override your interests, rights, and
freedoms, or the processing is necessary for the establishment,
exercise, or defense of our legal rights. If personal data is used
for direct marketing purposes, including marketing-related
profiling, you have the right to object at any time, and we will no
longer process your personal data.
Withdraw
consent. You may withdraw your consent at any time. Once you
withdraw your consent, we will no longer have the right to continue
processing the relevant data based on that consent. This does not
affect the lawfulness of processing based on consent before its
withdrawal. Where applicable, we will notify you of any changes to
the processing activities that are subject to your consent.
CMP(Consent Management Platform) Collects and shares consent and
permissions related to advertising activities. You may change your
preferences at any time in the game's privacy settings. You can
manage your consent related to advertising through the in-game
settings interface. Please note that even if you withdraw your
consent for personalized advertising, you may still receive ads from
us or third parties in our services; however, these ads will no
longer be personalized for you.
Right
to complain and report. You have the right
to lodge a complaint with the relevant supervisory authority. If you
are located in a country /
region
is part of the European Economic Area (EEA), please refer to the
following directory
(https://edpb.europa.eu/about-edpb/board/members_en)
for detailed information about local data protection authorities.
If
you live in California,
you may have the following rights:
Request
us to provide you with the following information free of charge,
covering the period prior to your request12months:
---
The
categories of personal data we collect about you;
---
Categories
of sources from which personal data is collected;
---
The
purpose of collecting your personal data;
---
We
have disclosed to you the categories of third parties to whom we
have disclosed your personal data, as well as the categories of
personal data disclosed (if applicable) and the purposes for which
your personal data was disclosed; and
---
The
specific personal data we collect about you;
Request
that we delete the personal data we have collected from you, unless
the California Consumer Privacy Act (CCPA) >CCPA>;
You
also have the right to refuse the sale or sharing of your personal
data. In certain circumstances, you may have the right to request
that the processing of your personal data be restricted. You can
always choose one of the following options to refuse future
collection of your personal data by us and other companies:
---
You
may exercise your rights at any time by sending us a request
regarding your personal data via the following
methods:manager@hkstarshinegames.com.
When
you exercise your rights under the California Consumer Privacy Act
(CCPA), you shall not suffer any unlawful discrimination as a result
of exercising such rights. >), you shall not be subject to any
unlawful discrimination, including providing different levels or
quality of services, or refusing to provide goods or services to
you.
The
above rights apply only in specific circumstances as provided by
applicable law. Before processing your request, we may require you
to verify your identity and provide supporting documentation. If we
decide not to respond to your request regarding the above rights, we
will explain the specific reasons.
Children's
privacy
Our
services are designed and provided for users of all ages. We do not
intentionally collect personal data from children, nor do we display
targeted ads to children, unless required by law. If you believe we
have displayed targeted ads to children, collected any personal data
from children, or that our services may be designed for, targeted
at, or used by children, or that personal data has been transmitted
from children with knowledge of this, thereby violating our policy,
please contact us via email:manager@hkstarshinegames.com.
Changes
to this policy
This
policy may be updated from time to time. If we make material changes
to this policy (such as the types of personal data we collect), we
will provide a prominent notice within the service and update the
policy so that you can review the policy. By
continuing to use the service, you confirm that you have read and
understood the updated policy.
Contact
us
|
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https://advertising.amazon.com/legal/privacy-notice?ref_=a20m_us_fnav_l_prvcy |
|
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https://www.applovin.com/privacy |
|
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https://www.adjust.com/terms/privacy-policy/ |
|
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https://www.pangleglobal.com/privacy |
|
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https://www.facebook.com/about/privacy/ |
|
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https://unity3d.com/legal/privacy-policy |
|
|
https://vungle.com/privacy/ |
|
|
https://policies.google.com/privacy?hl=en#infocollect |
If
you have any questions, complaints, feedback, or other related
matters regarding personal data protection while using our services,
including requests to exercise your legal rights, please contact us
via the following methods:
Please
contact our data protection department at
manager@hkstarshinegames.com。
Last
updated: July
12,2025