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PRIVACY POLICY

Effective Date: November 28th, 2019 

 

miHoYo Limited (“miHoYo”, “we”, “our”, or “us”) greatly recognize and value the privacy of people (“you” or “User”), who visit our websites, use or access our games, whether played on mobile devices, PCs, our websites or other approved platforms (“miHoYo Game(s)”), and/or otherwise use or access any of our provided services, including but not limited to customer supporting, marketing and advertising, and community services (collectively the “miHoYo Services”). 

 

This Privacy Policy describes how we may collect and use your personal data and the choices you have about your personal data which you provide or we collect in connection with the miHoYo Services. By accessing our websites or otherwise using the miHoYo Services, you acknowledge that you have read, understood and accepted the following terms. In the case you do not agree to any of the terms, you may immediately stop using our services.

 

In the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, your personal data may be transferred to miHoYo's successor.

 

miHoYo reserves the right to amend, modify or revise this Privacy Policy at any time and you agree to check periodically for new terms. Your continued access to the miHoYo Services will constitute your acceptance to the newly updated Privacy Policy. 

 

1. Personal Data We Collect

Personal data means any data that may be used to identify an individual, such as full name, email address, contact address, postal code, position data, title, occupation, personal interests, and other data that you choose to submit. 

 

(1) Data you provide to us

(i)    contact data (such as email address and telephone number)
(ii)    account registration or registration for on-line game participation (such as user name and password)
(iii)    your messages or other communication data provided to us (such as through message boards, communities or forums)
(iv)    other data you choose to give us (such as data about lost account identification, hacking prevention, consumer services, service maintenance, technical support and surveys, including but not limited to your age, date of birth, gender, general hobbies and interests, your likes and dislikes, lifestyle data or preferences, game play interests and habits, and/or other game-related preferences)

(2) Data we collect automatically

(i)    data about your account, game progressions and any use of the miHoYo Game(s), such as gameplay data and your interactions with other users on or through the miHoYo Services
(ii)    your Internet Protocol (“IP”) address
(iii)    data about your device, such as your device ID, device name, device type, operating system, advertising ID, MAC address, IMEI, CPU, language and the type of browser
(iv)    data we collect with cookies and similar technologies (see more as below)
(v)    general location data

(3) Data we collect from our contractors

(i)    data we receive if you link a third party tool with the miHoYo Services (such as access our services through Facebook, Twitter, Game Center, Google Play or Apple)
(ii)    data to fight fraud (such as refund abuse)
(iii)    data from payment methods that help the miHoYo Game(s) run on (such as to verify and confirm payment)
(iv)    data for advertising and analytics purposes so that we can provide you better services

 

Please note that we may merge and update our collected personal data with data from third party contractors in order to update your data, perform market analysis, and/or otherwise improve the miHoYo Services.  

 

When you use or interact with third-party plug-ins that may be available on our services for users, such as third-party social media widgets, share buttons, and/or login mechanisms, these features may include social plugins from Google, Facebook, Twitter or other platforms (if any) and please note it may be subject to their respective privacy policies. 

 

Unless you choose to voluntarily provide the data to us, we do not collect personally identifiable data about you, such as your name, address, telephone number, fax number, and e-mail address. You confirm that if you elect to submit any personal data, your submission is subject to this Privacy Policy and you consent to all the terms therein. Please pay attention that any personal data submitted in a business capacity, including but not limited to a job opening, attending our activity, would not be subject to this Privacy Policy. 

 

2. Why Do We Collect Your Personal Data

 

We usually create a miHoYo ID for you when you use the miHoYo Services and for the purpose to provide great services to you, you acknowledge and confirm that we may collect and process the data to:

(i)    allow you to access or restrict your access to the miHoYo Services;
(ii)    analyze and monitor the use of the miHoYo Services for system administration, customer service, security, fraud-detection, check the authenticity of an account owner, archival and/or backup purposes;
(iii)    correct bugs or errors, improve our services and respond to customer desires and preferences, including language and location customization, personalized help and instructions, and other responses;
(iv)    develop new services or products you request and improve the user experience;
(v)    verify and confirm payment;
(vi)    provide you offers on or through the miHoYo Services and deliver advertising that may be relevant to your interests, such as offer you to participate in our surveys or activities; 
(vii)    enable you to communicate with other users and take action against misbehaving users; 
(viii)    personalize your experience, keep you up to date on the latest product announcements, provide software verification, upgrades and administration, notify special events and offer other data pertaining to our services; and/or
(ix)    protect the integrity, safety, and security of our services or our users, comply with legal obligations, and enforce compliance with the Terms of Service or other restrictions placed on your use of the miHoYo Services.

 

For the purposes set forth above, our affiliates may be commissioned to process your data, provided that such affiliates comply with terms and conditions hereunder. Affiliate in this Privacy Policy shall mean an entity that directly or indirectly controls, is controlled by or is under common control with miHoYo Limited hereto. 

 

In all of the above cases and purposes, you acknowledge and confirm that we may analyze, profile, segment, merge and/or update all collected data (regardless of an aggregated or individualized manner for the purposes of improving service quality and providing a better experience to users).

 

3. Advertisements and Your Choices

For the purpose of providing personalized advertisements, you acknowledge and confirm that we may collect and process the data to:

(i)    improve advertising and other marketing and promotional activities; and/or
(ii)    deliver, target and improve our advertising.

 

We may also use your data to send you, or have our authorized contractors send you, direct marketing data or contact you for our market research. If you do not wish to receive marketing or advertising materials from us or any of our contractors, please do not provide your contact data via the Internet and you may directly require such contractors to remove your data from the contact list.

 

4. Cookies or Similar Technologies 

In order to measure the effectiveness of our services, some pages on our websites may use cookies, which are small text files for added functionality or for tracking site usage. We may use cookies and/or authorize third party’s tracking-utility, from time to time, (a) to log your IP address in determining the path that users take on our sites and identifying repeat users of our sites, (b) to collect the websites or sources that linked or referred you to our services, and/or (c) to collect technical data about the devices and software you use to access our services, the operating system of your devices, and other similar technical data. Notwithstanding the foregoing, we do not link your IP address to your personal data. If you do not wish to accept cookies or want to be notified of when they are placed, you may set your web browser to do so, if your browser permits.

 

We use the cookies, web beacons and similar technologies to personalize your experiences on our services and for various other purposes, including:

(i)    remembering you: cookies, web beacons and similar technologies can help us identify you as a registered user or keep the preferences or data that you have previously provided;
(ii)    analyzing how you use our services: we can use cookies, web beacons and similar technologies to understand what visitors (including users) are doing on our services, or what pages or sections are most popular;
(iii)    serving advertising: cookies, web beacons and similar technologies help us provide you with advertising that we believe is relevant to you or of interest to you, on the basis of your provided data; and/or
(iv)    other related functions or purposes mentioned in Section 2.

 

Our authorized contractors or we may use cookies and similar technologies to provide and personalize the services, prevent fraud and for other purpose mentioned above. Please note you can disable cookies in your browser settings, while some parts of the miHoYo Services may then not function properly.

 

5. Who May Access Your Personal Data 

In addition to miHoYo and/or its affiliates, other parties may also access your personal data in the following situations. You acknowledge that you have foreseen and agreed to the occurrence of such disclosure when you provide your personal data. 

 

(1) Other Users

Other users may, for example in a group challenge, see your in-game activities in group challenge. Other users may also see your display data and read the messages you have posted on or through the miHoYo Services. You confirm that the miHoYo Services may also include message boards, communities, forums, and/or other chat areas, where users may exchange ideas or communicate with other users and you acknowledge that any data you posted to any communication area is publicly viewable. We strongly recommend that all users avoid posting personal or sensitive data at any time.

 

(2) Competent Authorities

We may provide certain portion of your personal data to judicial or administrative authorities as so requested. Besides, we may disclose certain portion of your personal data within a strictly limited scope of recipients when we reasonably think it is necessary to protect us, our users or a portion of the public. 

 

In addition to be required by applicable laws, we reserve the right to disclose your personal data in the cases if we, in our good faith, believe that disclosing such data is necessary to identify, contact, or bring legal action against you, if (a) you are violating any agreements between us, such as the Terms of Service and this Privacy Policy or otherwise damage us; (b) you are infringing third parties’ rights and interests (including but not limited to intellectual property rights); and/or (c) we believe that it is necessary to prevent fraud or other illegal activities. 

 

(3) Third-Party Contractors

miHoYo works with a number of (if any) social media contractors, advertising serving contractors, analyzing contractors, payment contractors, fraud-detection contractors and other third-party contractors on or through our services. We do not sell your personal data and only share non-personally identifiable, aggregated, and public data with third parties.

 

Besides, such contractors may use cookies, web beacons, and/or other tracking technologies to collect or receive data about you and might claim controller rights over your personal data. For example, users purchasing products or services will be required to provide additional data to third party payment contractors, such as a valid credit card number, expiration date. Such third-party payment contractors may collect, process, retain your data to process payments and resolve subsequent payment disputes and inquiries. We may also receive, process and store the provided information from you and/or such third-party payment contractors to confirm payment, record purchase history and/or protect our legitimate interest when resolving subsequent payment disputes and inquiries. 

 

Please be aware that we cannot control the activities of such third parties, and we cannot guarantee that they adhere to the same privacy policy as we do. Since those contractors may access your data as data controller and operate under their own privacy policies, we strongly encourage you to check their privacy policies on their official websites and learn more about their data processing practices.

 

6. Data Retention

We will keep your data for as long as your account is active or as needed to provide you the miHoYo Services unless deletion in accordance with your request. In the case you request to remove or delete your personal data, we will retain your data as long as necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and/or enforce the agreements between us. Please note that the remove or deletion any of your data may result in the termination of some of our applicable services.

 

7. Your Rights

If you request in writing, we will provide you a copy of your personal data in an electronic format after passing our review process. You also have the right to correct or modify your data, have your data deleted, object how we use or share your data, and restrict how we use or share your data. Also, you may always withdraw your consent, for example by turning off GPS location sharing in your mobile device settings.

 

Pertaining to the marketing or promotional communications, you may opt-out of receiving such communications in accordance with the instructions therein, such as SMS, email or other contact methods provided to us. You may also opt-out of advertisements on mobile applications by checking the privacy settings and respectively selecting "limit ad tracking" (iOS) or "opt-out of app notification" (Android). Besides, you may use game settings to personalize your in-game preferences.

 

8. Securing Your Data

Pertaining to your use of our services, we have endeavored to take reasonable measures to prevent unauthorized access to or improper use of your personal data, such as organizational controls, technical protection and other protection measures. Unfortunately, the transmission of information via the internet is not completely secure. While we strive to protect your personal data, we cannot ensure the security of the data transmitted to our services and any transmission of your information is at your own risk. Therefore, we urge you to take every possible precaution to protect your personal data when using our services, including but not limited to changing your passwords often, not reflecting your real name or other personal data in registration, using a combination of letters and numbers when creating passwords, using a secure browser and/or taking other possible security measures. Please note for security reasons, we store passwords in encrypted form.

 

Please be aware that advertisers or websites with links to and/or from our websites may collect personal data about you and this Privacy Policy does not apply to, and cannot control the activities of, those other advertisers or websites. We highly recommend that you read the privacy policy of such third party websites which you may be directed to before providing any personal data.

 

9. Age Limits

You represent that you are an adult or older in your country of residence (or at other age in your jurisdiction where you are classified as a majority) when using the miHoYo Services. If you are a minor child or under the legal age of majority (“Child”), please do not send any data about yourself to us, including your name, address, telephone number, or email address.  

 

We strongly urge parents to instruct their Child never to disclose personal data without the prior permission of parents. If we learn that we have collected personal data about a Child, we will delete that data as quickly as possible. Also, if you believe that we might have any data from or about a Child, please contact us. 

 

10. Contact and Complaints

For the purposes of European Data Protection Law, the Data Controller is miHoYo Limited. If you have any questions about this Privacy Policy or have any requests for resolving issues with your personal data, please contact us in the first instance, either send a letter addressed to miHoYo Limited with its contact address: 6F, BLK C4, Shanghai Putian Information Industrial Park, 700 Yishan Rd, Shanghai, China, Attention: Customer Service Department; or email us through the contact information at the bottom of our website. .

 

 

miHoYo Limited
November 28th, 2019 

mihoyo