CURRENT POSITION:INDEX>NEWS

Mattel163 Limited Online Privacy Statement

2018-10-15

INTRODUCTION

This Privacy Statement applies to the web Sites, Mobile Apps or Apps, and other online services, including connected products (collectively the “Services”) provided by Mattel163 Limited ("Mattel163", "we", "our", or "us"). This Privacy Statement governs your use of our Services, regardless of how you access or use them. By “Sites”, we mean any website or URL of ours that we have linked to this Privacy Statement and all features, applications, content, and downloads that are operated by us and that are available through the Sites. By “Mobile Apps” and “Apps”, we mean our products and services that we make available via mobile telecommunications platforms and/or through social networking platforms or app stores that contain or link to this Privacy Statement. Each time you access and/or use the Services, you agree to be bound by and comply with all of the terms of this Privacy Statement. Do not use the Services if you do not agree to all of the terms of this Privacy Statement. Use of Apps and other Services, like connected products, may be subject to an End-User License Agreement (EULA). Specific Services may provide more detailed explanations of how data is collected, used, stored, or disposed of, and may provide additional specific options for you to choose how and what type of information to provide.

This Privacy Policy does not apply to any information collected by Mattel163 offline. Nor does it apply to websites, apps, or other online services maintained by our affiliates, or other companies or organizations to which we link and is not subject to Mattel163’s control. Mattel163 is not responsible for the content or activities provided on those websites, apps, and online services.

Mattel163 is a member in good standing of ESRB’s Privacy Certified Program. To protect your privacy, we have voluntarily undertaken this privacy initiative, and all of our Services where this Privacy Policy is posted and an ESRB Privacy Certification seal is displayed have been reviewed and certified by ESRB Privacy Certified to meet established online information collection, use, and disclosure practices. As a licensee of this privacy program, we are subject to audits of our Services and other enforcement and accountability mechanisms administered independently by the ESRB.

We want you and your family to have fun using our Services, and urge you and your family to follow common sense whenever disclosing personal information - in our Services or anywhere else.

OVERVIEW

We encourage you to review our complete Privacy Statement in detail, as it includes important information.

What information do we collect about adults and teens?

What are cookies and tracking technologies and how are they used?

How will we use the information about you?

How do we share your information?

What are the links and other important information?

How to exercise your rights over your information?

What about our policy concerning children?

What about California Privacy Rights for California residents?

How to contact us with your question?

WHAT INFORMATION WE COLLECT ABOUT ADULTS AND TEENS?

We collect information from adults and teens in such conditions: (1) make anin-app purchase, (2) product or account registration, or registration for on-line game participation, (3) player match-up services, (4) message boards or forums, (5) contest registrations, (6) a consumer complaint, (7) surveys, (8) customer service or technical support, (9) interact withusvia social media such as Facebook and Google Play, and/or (10) newsletters.

The following information will be collected:

Registration Information. In order to use our Services, sometimes you may be requested to create an account. Then we will receive and store information you provide, including your country of residence, gender, age, email address, username, character name, password and other information that help us confirm your access to your account.

Financial Information. Users purchasing products or services will be required to provide additional information such as a valid credit card number, expiration date, and shipping and billing addresses.

Device Information. We collect information about the device you use to access ourServices, including your Device ID, Device Type, Operating System, CPU, RAM, IP address, AD ID, and voice data collected by microphone with your consent.

Game Data Information. We collect information about how you use our Services, such as your game level, progress, scores, achievements, game log and interactions with other users. We have a record feature that you have the option of saving your in-game performance and interactions through a video. You may completely choose whether or not to use this feature. You also have a access to the replay recordings in your profile setting page.

Location Information. We collect information about your general location, including country level.In addition, we will collect information about your precise location, but only when you provide affirmative, opt-in consent within the Service (for example, if you choose to search for nearby friends to play a game).

User-generated Content.You may be able to share or upload content, like comments, reviews, profile photos, game-play video or screenshot etc. If you share or upload content (may including your and other users’ personal information, like username and profile photo) in an online bulletin board, chat room, or other online social media platforms, it will be publicly accessible. For the protection of your information, we recommend you do not use your real name and personal photo in our game. We are not responsible how you choose to share personal data with the public or third parties,or how third parties use the feature to share information.

Contact Information. We will collect personal contact information, like name, e-mail address, phone number or instant messaging account from adults and teens when voluntarily submitted, including when needed to inform you about our promotional activities and any rewards you are entitled to get. We collect this information with your consent.

Information we collect from third parties. When you sign-in to our Services with a social media account, such asFacebook, Google Play, or iOS Game Center, we will collect information from your third party account, including your nickname, profile picture and/or friend list with your consent.

WHAT ARE COOKIES AND TRACKING TECHNOLOGIES AND HOW ARE THEY USED?

Our Services use technology, like cookies and web beacons, to manage registrations or access to certain features, store your settings and preferences, conduct age-screening, offer you personalized content, shop, help us understand the features that appeal to visitors, and manage advertising, among other things.

We also work with third parties who offer analytics or deliver targeted ads online through websites or Apps. To do so, they use technology and collect device identifiers, such as your IP address or mobile Device ID, and information on your activities. You may be able to opt out of receiving targeted ads on our Services by emailing us at privacy@mattel163.com. You will still see ads, although they may be less relevant to you.

Tools are available to help you control some of these technologies.

Some web browsers may transmit “do not track” signals. Web browsers may incorporate or activate these features differently, making it unclear if users have consciously activated them. As a result, at this time, we do not take steps to respond to such signals. You can manage your cookie preferences using your own browser settings (for example, Chrome, Edge, Internet Explorer, Firefox, Safari, or Opera) to accept or block some or all cookies or receive notice so you can consent to cookies. Check your browser’s Help menu or your built-in mobile device settings to find out how. Some mobile devices store cookies not only in areas connected to the browser, but also in areas that are app-specific, so these cookies cannot be controlled by the browser settings. Check your app-setting options on your mobile device to find out how to manage or delete cookies that may be stored in these other areas. If you block all cookies, some features of our Services may be unavailable to you.

If you want to know more about the cookies and third parties (e.g SDK or advertisement providers) we use to collect your personal information for marketing and analyzing, including additional information on the third parties’ privacy policies and opt-out options, please click here for more details.

HOW WILL WE USE THE INFORMATION ABOUT YOU?

We use all information we collect to provide and improve our products and services, understand our consumers, operate efficiently, and manage content and advertising. For example, we may use the information we collect in the following ways:

We use Registration Information to set-up user accounts, allow users to log-in to the Services and provide Services to users. We use this information pursuant to our contract with you to provide the Services.

We use Device Information to provide and improve the Services such as: to allow users to download and install the Services on their devices; to enable user voice chat with each other; to record and keep track of requests from users of the Services; to detect the user network and device status when the user is using the Services; and to correct bugs or errors that occur when the user is using the Services. Use of Device Information is necessary to perform our contract with you to provide the Services.

We use Contact Information to send notifications to users to inform you of new version of our Services, features, updates, promotions or enhancements and other information about ourServicesthat might be relevant to you.We use this information with your consent.

We use general location data (i.e., country level) to know what language players use in order for us to provide Services that are applicable to your geography. In addition, we use precise location data when players choose to search for nearby friends to play a game; however, we will not collect your precise location data without you providing affirmative, opt-in consent within the Service.

We use Social ID to enable users to share their game achievement on social media or invite their friends to the Services. We use this information with your consent.

We use User Profile to provide customized services to users such as a personal information page. We use this information with your consent to this Privacy Policy.

We will use your personal information to handle your customer service or technical support questions or issues.

We use your personal information for marketing and advertising, including by providing your personal information to other companies or organizations that offer products or services that may be of interest to you. We share this information with your consent andprovide you with an opportunity to opt-out.

HOW DO WE SHARE YOUR INFORMATION?

We share information, including personal information in the following ways:

We share all information we obtain within our family of companies, and with our agents and third-party service providers to the extent necessary for them to fulfill their tasks on our behalf.

We share personal contact information (e.g.email address) for adults and teens with third parties for marketing purposes with your consent.

We share information about usage and interests that we obtain through cookies and technology with advertising agents and third-party service providers, and obtain consent if required by applicable law.

We share any information we obtain as necessary to satisfy a legal request, protect property or personal safety, when a business is bought or sold, or as otherwise allowed or required by law.

WHAT ARE THE LINKS AND OTHER IMPORTANT INFORMATION?

LINKS

Our Services may link to or use other content from the Internet, including content offered by third parties that we do not control and whose privacy and data collection practices may differ from ours. For example, we may link to social media sites or sites that sell our products. We encourage you to carefully review the privacy policy and terms of use of such third parties, as they are not covered by this Privacy Statement, and Mattel163 is not responsible for them.

You may be able to alter settings on your browser, device, or other software to block or partially block those third parties. Sometimes those settings may not be effective.

OTHER IMPORTANT INFORMATION

SECURITY

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. Our group companies have information security and access policies that limit access to our systems and technology. We also protect data through the use of technological protection measures such as encryption. Your personal information will remain subject to our technical and organizational controls and our policies and procedures (including this Privacy Policy).

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the information transmitted to our Services.

If we learn that your unencrypted personal information has been compromised by a data breach, we will notify you consistent with applicable laws.

OUR LOCATION; DATA TRANSFERS

Mattel163’s Services and the servers that make our Services available are governed by Hong Kong law and may be located in Hong Kong or other countries that may have different privacy laws than where you live. The use of our Services is subject to the collection, transfer, processing, and use of data in accordance with this Privacy Statement. Do not use the Services if you do not agree to this Privacy Statement.

UPDATES

We will update this Privacy Statement from time to time by posting the updated Privacy Statement online. We will not change how we handle previously collected information without providing notice, and, as applicable, obtaining your consent.

RETENTION

We will retain most of your personal information for the lifetime of your use of the Services (i.e. until account deletion in accordance with your request) with the following exceptions: Contact Information that is obtained as a result of you participating in our promotional activities will be retained during the lifetime of such activities as expressly designated in the corresponding activities. Gameplay video recordings in our game system will be deleted from servers within one month since the date of your use. In addition, audio voice files will be stored for up to 48 hours after you use it in the game, and then deleted from our servers.

When destroying personal information, measures will be taken to make the personal information irrecoverable or irreproducible, and electronic files which contain personal information will be deleted permanently using a technical method which makes the files irreproducible.

In the event that the processing and retention period have terminated, but personal information is required to be retained continuously for other reasons including for the purposes as prescribed under applicable laws, the relevant personal information will be stored and maintained separately from other types of personal information. If you require us to destroy your personal information before the end of its life cycle (as set out in the retention policy above), we will destroy your personal information in accordance with local laws.

HOW TO EXERCISE YOUR RIGHTS OVER YOUR INFORMATION?

THE RIGHT TO ACCESS, UPDATE AND MAKE OPT-OUT CHOICE

If you want to stop receiving promotional updates or information about our Services, you can email us at privacy@mattel163.com. Any promotional emails we send you will also include information on how to opt out.

If you want to access, update, or delete your personal information, or withdraw your consent to our collection or use of your personal information, you can email us at privacy@mattel163.com. However, if your personal information is being maintained pursuant to a contractual or other legal obligation, we may not be required to honor your request.

Parents can access their children’s data and make choices about how Mattel163 uses that data, including updating or deleting the data or refusing to permit further collection and use, by emailing us at privacy@mattel163.com.

APP CONTROLS

Your device may allow you to block or manage push notifications; location information; in-app purchases; camera, microphone, and photo reel, album, or gallery permissions; or ability to access the web.

WHAT ABOUT OUR POLICY CONCERNING CHILDREN?

We take many special precautions to protect the privacy of children. In general, we define “children” as users under 13 years old, but adhere to local definitions of “children” where a different age applies. In our Services intended for children, we do not collect personal information, which includes but is not limited to: first and last name, e-mail address, phone number, home or physical address or geolocation, online contact information (instant messenger identifier, video chat identifier, VOIP identifier, and screen name that permits direct contact with children online), phone number, social security number, persistent identifier (e.g., a customer number held in a cookie, IP address, device serial number, or unique device identifier), photographs, videos, and audio recordings containing the child’s image or voice (or any other personal information about the child); account numbers (credit card, bank account, etc.); and medical information, from children without providing direct notice to a parent and obtaining verifiable consent from a parent or legal guardian, except in limited circumstances authorized by law.

We collect some information (like IP address, mobile device unique identifier or device ID, operating system, etc.) automatically and use technology like cookies to provide functionality and support the internal operations of our Services.

We do not ask for more personal information than is necessary for a child to participate in an activity.

We take steps to prevent children from posting or publicly disclosing personal information. If we were to discover that a child’s personal information has been posted in a public forum on one of our Services, we would remove it immediately.

If we collect an email address from a child in connection with a customer support inquiry, we delete the child’s email address immediately upon responding to the child’s request.If you are a parent that has provided consent to the collection of your child’s personal information, you have the option to consent to the collection and use of your child’s personal information without consenting to our disclosure of that information to third parties. If you have previously provided consent for the collection and sharing with third parties, and you would like to withdraw your consent, please contact us at privacy@mattel163.com.

WHAT ABOUT CALIFORNIA PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS?

California Civil Code § 1798.83 permits our users who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not share our users' personal information with unaffiliated third parties for direct marketing purposes without our users’ consent. However, if you are a California resident and you have any questions about our disclosure of your personal information to third parties, please contact us at:

 

Mattel163 Limited

Office of Privacy & Info Security

1/F Xiu Ping Commerical Building, 104 Jervois Street, Sheung Wan, Hong Kong

privacy@mattel163.com

 

HOW TO CONTACT US WITH YOUR QUESTION?

We strive always to be transparent and clear about our policies. If you have questions or wish to send us comments about this Privacy Policy or one of our Services, please contact us at:

 

Mattel163 Limited

Office of Privacy & Info Security

1/F Xiu Ping Commerical Building, 104 Jervois Street, Sheung Wan, Hong Kong

+86(0)571-89852929

privacy@mattel163.com

 

As previously stated, Mattel163 is a licensee of the ESRB’s Privacy Certified Program. If you believe we have not responded to your inquiry or your inquiry has not been satisfactorily addressed, please contact the ESRB at:

 

ESRB

Attn.: Privacy Certified Program

420 Lexington Avenue, Suite 2240

New York, NY 10170

www.esrb.org/privacy/contact.aspx