Privacy Policy

This Privacy Policy applies to the upcoming mobile game (hereinafter referred to as "the Product") developed and operated by SharpCode Matrix Inc (hereinafter referred to as "the Developer"). As a casual game company, the Developer is committed to providing users with high-quality gaming experiences while strictly protecting the security and privacy of your personal information. This Privacy Policy is intended to clearly inform you of how we will collect, use, store, share, and protect your personal information when you use the Product (after its official launch), as well as your rights and choices regarding your personal information. Please read this Privacy Policy carefully. Your use of the Product after its official launch shall constitute your consent to our collection and use of your information in accordance with the provisions of this Privacy Policy.

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一. Scope of Application

This Privacy Policy applies to your entire process of accessing, downloading, installing, and using this Product through any device (including but not limited to smartphones, tablets, personal computers, etc.), covering all user information we collect and process in the course of providing services.

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二. Collected Information and Permission Acquisition

We collect information in accordance with the principles of legality, legitimacy, and necessity, only collecting data directly related to the services of this Product without excessive collection. The following describes the collection of relevant information in descending order of permission sensitivity:

1 Sensitive Permissions and Corresponding Information Collection

（1）. Location Information Permission

- Collection Method: After you actively enable the location service permission of your device, we will obtain information through the built-in positioning function of the device.

- Collected Content: Only obtain approximate geographic location information (e.g., city-level), not precise latitude and longitude.

- Collection Object: Users who use this Product and actively authorize this permission.

- Collection Purpose: Used to provide region-related game content recommendations (such as regional events, localized scenarios, etc.) and optimize server load distribution.

（2）. Microphone Permission

- Collection Method: Only when you use the built-in voice chat function of this Product, the microphone will be activated for temporary recording after your real-time confirmation and authorization.

- Collected Content: Audio data fragments during voice chat, which are only temporarily cached during the duration of the chat session.

- Collection Object: Users who use the voice chat function and authorize this permission, as well as their chat partners.

- Collection Purpose: To realize real-time voice interaction between users and enhance the game social experience.

（3）. Storage Permission

- Collection Method: When you install this Product or use the data storage function, access the device storage directory after your authorization.

- Collected Content: Game installation package data, cache files, and game saves actively saved by users (including character information, progress data, etc.).

- Collection Object: All users who use this Product and authorize this permission.

- Collection Purpose: To ensure the normal installation and operation of the game, and realize the local storage and reading of save data.

（4）. Account Association Permission (e.g., Third-Party Login)

- Collection Method: When you choose to log in to this Product through a third-party platform (such as Google, Apple, etc.), information is obtained from the third-party platform after your authorization.

- Collected Content: Public information such as the unique identifier, nickname, and avatar corresponding to the third-party platform account; we do not obtain the account password and private data of the third-party platform.

- Collection Object: Users who choose the third-party login method.

- Collection Purpose: To provide you with convenient login services and realize cross-device synchronization of account information.

2.Ordinary Permissions and Corresponding Information Collection

（1）. Device Information Permission

- Collection Method: Automatically collected when you start this Product, no additional authorization is required.

- Collected Content: Technical information such as device model, operating system version, device identifier (e.g., desensitized data of IMEI), processor model, and memory capacity.

- Collection Object: All users who use this Product.

- Collection Purpose: To troubleshoot game operation failures, optimize performance adaptation for different devices, and ensure service stability.

（2）. Network Permission

- Collection Method: Automatically enabled when you use the network function of this Product.

- Collected Content: Network-related data such as IP address, network type (Wi-Fi/mobile data), network connection status, and server response time.

- Collection Object: All users who use the network function of this Product.

- Collection Purpose: To realize network services such as game data synchronization, multi-player online interaction, and update package download.

3.Information Sharing and Sale Statement

（1）. Third-Party Sharing: We will not share your personal information with any irrelevant third parties, except in the following circumstances:

• Obtain your explicit written consent;

• To fulfill obligations stipulated by laws and regulations, and respond to legal requirements from judicial organs or administrative authorities;

• Cooperate with strictly screened service providers (such as server hosting providers, payment service providers, etc.), and such partners can only use relevant information within the scope of providing services for us and must abide by strict confidentiality obligations.

（2）. Data Sale: We will never sell, lease, or use any of your personal information for profit purposes.

4. Data Storage Server Description

All user information we collect is stored in the Amazon Web Services (AWS) server cluster located in the United States. This server has obtained ISO 27001 information security management system certification and has a complete security protection mechanism. Your content is stored in the AWS Region(s) you choose, and we will not move or replicate your content outside of your chosen AWS Region(s) without your agreement.

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3. Data Security Protection Measures

We adopt multiple measures combining technology and management to fully protect your data security:

• Technical Protection: The collected sensitive information is encrypted for storage using the AES-256 encryption algorithm, and the SSL/TLS protocol is used for transmission encryption during data transmission to prevent data from being leaked, tampered with, or illegally used. We offer industry-leading encryption features to protect your content in transit and at rest, and provide you with the option to manage your own encryption keys.

• Access Control: Establish a strict permission management system, only authorizing personnel in necessary positions to access user data, and all access behaviors are fully traceable. We provide an advanced set of access, encryption, and logging features to help configure access control permissions effectively.

• Security Monitoring: Deploy a real-time security monitoring system to continuously monitor data access and operation behaviors. Once abnormal access or potential risks are detected, the emergency response mechanism will be activated immediately.

• Security Audit: Conduct regular data security audits and risk assessments, promptly fix potential security vulnerabilities, and update security protection strategies.

• Employee Training: Regularly provide employees with training on data privacy protection laws and regulations as well as safe operation standards to strengthen employees' awareness of privacy protection.

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4. Data Retention and Deletion Mechanism

(1) Data Retention Period

• For your account information and core game data (such as character information, payment records, etc.), we will retain it continuously during the existence of your account to ensure your normal use of the services of this Product.

• For temporarily generated data (such as voice chat cache, temporary login credentials, etc.), it will be automatically deleted after the service is completed or when the preset period (maximum 7 days) is reached.

• For non-identity identification data such as device information and network logs, it will be retained for a reasonable period necessary to achieve the collection purpose (maximum 12 months), and will be automatically anonymized or deleted after the period expires.

(2) Data Deletion Mechanism

• Active Deletion: You can independently apply to delete some operable data (such as game saves, nickname and avatar, etc.) through the "Settings - Account and Privacy - Data Management" function in this Product; if you need to cancel your account and delete all personal information, you can submit an application to us through the "Contact Information" below.

• Passive Deletion: If your account has not been logged in for 18 consecutive months and there are no unfinished transactions or unexpired rights and interests, we will notify you 30 days in advance via the registered email. If you do not respond within the notification period, we will automatically cancel the account and delete the relevant personal information (except as otherwise stipulated by laws and regulations).

• Statutory Deletion: When required by laws and regulations, or when the data processing purpose has been achieved, cannot be achieved, and there is no need to save it, we will immediately delete or anonymize the relevant data.

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5. Your Rights

In accordance with relevant U.S. privacy laws and regulations (such as the California Consumer Privacy Act (CCPA), etc.), you enjoy the following rights related to personal information:

• Right to Know: Have the right to review this Policy and consult us about the specific circumstances of the collection, use, storage, etc. of your personal information.

• Right of Access: Have the right to apply to us for a copy of your personal information, and we will respond within 15 working days.

• Right to Rectification: If you find that your personal information stored by us is incorrect or incomplete, you have the right to apply for correction, and we will complete the processing within 5 working days after verification.

• Right to Erasure: Have the right to apply for the deletion of your personal information when statutory or agreed conditions are met (see the "Data Retention and Deletion Mechanism" section of this Policy for details).

• Right to Withdraw Consent: Have the right to withdraw the authorization for various permissions at any time (operable through device system settings or in-product settings), but withdrawing consent may cause some functions to not work normally.

• Right to Complaint: If you believe that our information processing behavior has infringed your privacy rights and interests, you have the right to complain to us through the "Contact Information" below, and we will feedback the processing result within 10 working days.

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6. Use of Cookies

1. Definition and Types of Cookies: Cookies are small text files stored on your device. The Cookies we use mainly include two types: necessary Cookies and functional Cookies.

2. Purpose of Use:

• Necessary Cookies: Ensure the basic function operation of this Product, such as remembering your login status and maintaining session stability. Such Cookies cannot be disabled.

• Functional Cookies: Optimize your user experience, such as remembering your game preference settings and loading historical game progress.

3. Management Method: You can choose to disable functional Cookies through browser or device settings, but this may cause some personalized functions to not work normally; disabling necessary Cookies may affect the basic operation of this Product.

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7. Policy Updates

• We will revise this Privacy Policy from time to time in accordance with the update of laws and regulations, the iteration of product functions, and the optimization of privacy protection practices.

• When significant changes are made to this Policy (such as substantial changes in the scope of information collection and purpose of use), we will send you a clear notice through pop-ups in this Product, registered email push, etc., and remind you to review the updated policy content.

• Your continued use of this Product indicates that you accept the updated Privacy Policy; if you do not agree to the changed content, you should stop using this Product immediately.

• After this Policy is updated, we will retain the historical version on the official website and in the Product for your review.

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8. Contact Information

If you have any questions, suggestions, or complaints about this Privacy Policy, or need to exercise relevant data rights, you can contact us through the following methods:

• Contact Email: info@sharpcodematrix.com

• Contact Address: 1021 N Market Plz Pueblo West, CO 81007

We will provide you with professional answers and processing services as soon as possible after receiving your feedback.

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SharpCode Matrix Inc