This Privacy Policy applies to the unofficially launched game product (hereinafter referred to as "this Product") developed by CloudSail Interactive (hereinafter referred to as "we"). We are well aware of the importance of user privacy, and this Privacy Policy aims to clearly inform you of the methods by which we collect, use, store, share, transfer and protect users' personal information during the operation of the product, as well as the relevant rights you enjoy, so as to help you make appropriate decisions on information provision.

一. Information We Collect and Relevant Permission Instructions

1.1 Sensitive Permissions and Information Collection

Sensitive permissions refer to permissions that involve the user's core personal privacy or may have a significant impact on the user's rights and interests. We will only apply for relevant sensitive permissions and collect corresponding information on the premise of realizing specific product functions and obtaining your explicit authorization and consent. The details are as follows:

• (1) Location information permission (precise positioning/coarse positioning): We will only apply for this permission if this Product includes location-based game functions (such as regional rankings, nearby player matching, etc.). The collection method is to obtain through the positioning module of your device, the collected content is your approximate geographic location (such as city level) or precise geographic location (such as latitude and longitude), and the collection object is users who use this specific function. We will not share this location information with any third party, nor will we use the sale of this information as a profit purpose. The collected location information will be uploaded to our server deployed in the AWS US East Region.

• (2) Camera permission: We will only apply for this permission if this Product includes functions such as avatar customization (taking photos as avatars) and AR game scene interaction. The collection method is to obtain image data through shooting with the camera of your device, the collected content is the photos you took or real-time image frames (only used to realize the above functions, no irrelevant images will be retained), and the collection object is users who use this specific function. This information is only used to realize functions within the product, will not be shared with third parties, and will not be sold. After the functional use is completed, if the relevant image data needs to be temporarily retained (such as cached avatar), it will be uploaded to our aforementioned AWS US server. The retention period is consistent with the use period of your avatar. If you change your avatar, the original image data will be automatically deleted.

• (3) Microphone permission: We will only apply for this permission if this Product includes in-game interaction functions such as voice chat and voice command control. The collection method is to record audio data through the microphone of your device, the collected content is your voice information when using the function, and the collection object is users who use this specific function. Voice information is only used for real-time transmission or command recognition, will not be shared with third parties, and will not be sold. Real-time voice data will not be retained after transmission. If it needs to be retained (such as voice message leave), it will be uploaded to the aforementioned AWS US server, and the retention period is 30 days, which will be automatically deleted after the expiration.

• (4) Device storage permission (such as photo album, file storage): When you need to realize functions such as game screenshot saving, game archive backup, and custom resource import (such as custom wallpaper), we will apply for this permission. The collection method is triggered by your active operation (such as clicking "Save Screenshot" or "Backup Archive"), the collected content is the game screenshots you generated, game archive files or custom resources you actively imported, and the collection object is users who use this specific function. We will not share the above information with third parties, nor will we sell it. Game archive files will be uploaded to the aforementioned AWS US server. Screenshots and custom resources are stored locally on your device by default, and will be synchronized to the server if you choose cloud backup.

1.2 General Permissions and Information Collection

General permissions are necessary for ensuring the basic operation of the product. Some permissions may be granted by the system by default, and the collection of relevant information is used for the realization of the basic functions of the product and operation optimization. The details are as follows:

• (1) Device information permission: We will collect your device model, operating system version, unique device identifier (such as IMEI, Android ID, IDFA, which will be anonymized), processor information, memory information, network type (such as Wi-Fi, 4G/5G) and other basic device information. The collection method is automatically obtained when the product is started, and the collection object is all users who use this Product. This information is only used to ensure the stability of the game operation (such as adapting to different device models), troubleshoot faults and optimize game performance, and will not be shared with third parties or sold. Relevant information will be uploaded to the aforementioned AWS US server.

• (2) Application operation permission: To ensure basic functions such as normal startup of the game, background update, and message push, we will apply for application operation permissions (such as background operation permission, self-startup permission, some permissions require your manual authorization). The collection method is to obtain application operation status information through the system interface, the collected content is application startup time, running duration, background running status, etc., and the collection object is all users who use this Product. This information is only used for the basic operation and maintenance of the product, will not be shared with third parties, and will not be sold. Relevant data is stored in the aforementioned AWS US server.

1.3 Information Sharing and Sale Statement

We strictly abide by the requirements of relevant laws and regulations such as the California Consumer Privacy Act (CCPA) of the United States, and will not transfer your personal information to any third party for the purpose of sale. Except for the following circumstances, we will not share your personal information with third parties: 1) Obtain your explicit written or oral consent; 2) For the purpose stated in this Privacy Policy, and the third party is our service provider (such as AWS providing server storage services, third-party payment institutions providing payment services), such third parties can only use your information within the scope of providing services for us and must abide by strict confidentiality obligations; 3) It is necessary to disclose to third parties in accordance with applicable laws and regulations, legal procedures, mandatory requirements of government departments or judicial rulings; 4) To protect the legitimate rights and interests of us, you or other users, disclose to third parties within a reasonable and necessary scope.

二. How We Protect Information Security

We adopt technical measures and management measures that meet industry standards to comprehensively protect the security of your personal information, including:

• 1. Technical guarantee: We use AES-256 encryption algorithm to encrypt and store the personal information uploaded to the server, and use SSL/TLS encryption technology for the data transmission process to prevent information from being unauthorized accessed, tampered with or leaked during transmission and storage; we have deployed security devices such as firewalls and intrusion detection systems (IDS) to effectively resist network attacks; we regularly conduct security vulnerability scans and penetration tests on servers to repair potential risks in a timely manner.

• 2. Management guarantee: We have established a strict information security management system, clarified the information security responsibilities of personnel in various positions, and conducted strict background checks and regular information security training for employees who have access to users' personal information; implemented hierarchical management of information access rights, and only authorized necessary personnel to access specific information; established an information security incident emergency response plan. In the event of an information security incident, the emergency response plan will be activated in a timely manner, remedial measures will be taken, and reports will be made to relevant departments in accordance with legal and regulatory requirements.

• 3. Third-party service guarantee: For third-party service providers that provide services for us, we will sign strict service agreements and confidentiality agreements with them, clarify their information security obligations and liability for breach of contract, and regularly evaluate their information security guarantee capabilities to ensure that they can effectively protect user information security.

三. Data Retention and Deletion Mechanism

We retain your personal information in accordance with the principles of "minimum necessity" and "reasonable period". The specific retention and deletion rules are as follows:

• 1. Data retention period: For information that ensures the basic operation of the product (such as device information, game archives), we will retain it for 90 days from the date you cancel your account; for information generated by you using specific functions (such as location information, voice messages, screenshots), we will retain it for 30 days from the date the function is used and there is no subsequent use demand, or process it immediately in accordance with your active deletion operation; for anonymized data used for operation analysis and optimization (information that can identify personal identity has been removed), we can retain it continuously during the product operation period, but the data can no longer be associated with specific individuals.

• 2. Active deletion mechanism: You can actively delete personal information through the following methods in the product: (1) Delete avatar, nickname, custom resources and other information in "Settings - Personal Information Management"; (2) Delete location information, voice messages and other information related to specific functions in "Settings - Privacy Settings"; (3) Delete game archive files in "My Archives". After you initiate the deletion operation, the relevant information will be removed from the front-end display within 24 hours, and the complete deletion on the server side will be completed within 7 working days. The deleted data cannot be recovered.

• 3. Passive deletion mechanism: If your account has not logged in to use this Product for 180 consecutive days, we will regard you as giving up the right to use the account. After notifying you (if you can be contacted), we will delete all personal information under your account (except information that must be retained in accordance with laws and regulations) within 30 days; when this Product ceases to operate, we will issue an announcement on channels such as the product official website and app store. Within 90 days after the announcement is issued, all users' personal information will be deleted.

四. Your Rights

In accordance with the requirements of relevant U.S. laws and regulations and Google Developer Policies, you enjoy the following rights regarding personal information, and we will provide you with convenient channels for exercising your rights:

• 1. Right to know: You have the right to learn about the specific circumstances of our collection, use, storage and sharing of your personal information through channels such as this Privacy Policy and "Settings - Privacy Statement" in the product.

• 2. Right of access: You have the right to access the personal information under your account, including your basic account information (such as nickname, avatar), usage records (such as game login records, function usage records), collected permissions and corresponding information (such as location information records), etc. You can query by yourself through the function "Settings - Personal Information Management - My Information Query" in the product. If you need to obtain more detailed information, you can contact our customer service team.

• 3. Right to correction: If you find that your personal information is incorrect or incomplete (such as wrong nickname, abnormal avatar information), you have the right to request us to correct it. You can correct basic information by yourself through the function "Settings - Personal Information Management" in the product. For information that cannot be corrected by yourself, you can contact customer service to provide relevant supporting materials, and we will review and process it within 5 working days.

• 4. Right to deletion: You have the right to actively delete your personal information in accordance with the instructions in the "Data Retention and Deletion Mechanism" of this Privacy Policy. For the specific operation path, please refer to that part.

• 5. Right to withdraw consent: You have the right to withdraw your authorization and consent to relevant permissions (such as withdrawing location information permission, camera permission, etc.). You can withdraw the authorization through the path "App Management - This Product - Permissions" in the device system settings. After withdrawing the authorization, we will no longer collect information under the corresponding permission, but it may affect the normal use of related functions.

• 6. Right to cancel account: You have the right to cancel your product account. After the account is canceled, we will delete all personal information under your account in accordance with the requirements of the "Data Retention and Deletion Mechanism". You can apply for cancellation through the function "Settings - Account Security - Cancel Account" in the product. We will complete the account cancellation within 7 working days after reviewing and confirming that it is your own operation.

五. Terms for Minors' Use

We attach great importance to the protection of minors' personal information. In accordance with the requirements of the Children's Online Privacy Protection Act (COPPA) and relevant laws and regulations of the United States, the following special terms are formulated for minors to use this Product:

• 1. Scope of Application: Minors referred to in this clause are children under the age of 13. Children under the age of 13 must use this Product with the consent and guidance of their parents or legal guardians (hereinafter referred to as "guardians"), and the guardians shall exercise relevant rights and perform obligations on their behalf.

• 2. Restrictions on Information Collection: We will only collect minors' personal information on the premise of realizing specific purposes permitted by COPPA (such as providing basic game functions and ensuring account security) and obtaining explicit written consent from guardians. The scope of collection is strictly limited to the necessary minimum, including minors' account nicknames (which shall not include real names), guardians' contact information (for verifying guardians' identities), basic in-game operation data, etc. We will not collect sensitive information such as minors' location information and biometric information, nor will we apply for sensitive permissions such as camera and microphone.

• 3. Information Use and Sharing: The collected minors' personal information is only used to provide customized game services for minors (such as adapting the game difficulty for minors and filtering inappropriate content) and communicating with guardians on relevant matters. It will not be used for other purposes, nor will it be shared or sold to any third party, unless explicit consent is obtained from guardians or otherwise stipulated by law.

• 4. Guardians' Rights: Guardians have the right to view, correct and delete minors' personal information, withdraw consent to minors' use of this Product and information collection, and request the cancellation of minors' product accounts. When exercising the above rights, guardians can contact us through the email provided in the "Contact Information" section of this Privacy Policy and provide materials that can prove the guardianship relationship (such as birth certificate, household registration book scan, etc.), and we will review and process it within 5 working days.

• 5. Content Protection: This Product will strictly review the game content for minors, filter content containing inappropriate information such as violence, pornography and horror, and set a reasonable game duration reminder function to guide minors to use the game healthily.

六. Use of Cookies

To enhance your game experience and optimize product services, we may use Cookies technology when you use this Product. Cookies are small text files stored locally on your device, mainly used to record your game preference settings (such as picture quality settings, sound effect volume), login status (avoid repeated login), game progress (temporarily cache unsaved game data) and other information.

You have the right to choose whether to accept Cookies. You can disable or delete Cookies by adjusting browser or device settings, but after disabling Cookies, you may need to re-enter your account password every time you log in, and some game preference settings cannot be saved, which may affect your use experience. We will not collect your sensitive personal information through Cookies, nor will we share or sell the information in Cookies with third parties.

七. Policy Updates

This Privacy Policy may be adjusted with the iteration of product functions, updates of laws and regulations or changes in operational needs. After this policy is updated, we will inform you of the updated content through pop-ups in the product, official website announcements, email notifications and other methods. If the updated content involves your core rights and interests (such as changes in the scope of collected information and sharing rules), we will ask you to confirm and agree to the updated Privacy Policy when you log in to the product next time. If you disagree, you will not be able to continue using this Product.

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八. Contact Information

If you have any questions, suggestions about this Privacy Policy, or need to exercise your rights related to personal information, please contact us through the following methods:

• Company Address: 

• Contact Email: info@cloudsailinteractive.com

We will reply and handle it within 10 working days after receiving your contact information.

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