Privacy Policy of Hero Entertainment

Welcome to use the entertainment services provided by Hero Entertainment. “Hero Entertainment” refers to HK HERO ENTERTAINMENT CO., LIMITED, the Services provider, together with any affiliates or cooperative partners that may exist when you accept, access or use the Services, also referred to as "we" or “us” herein. The registered address of HK HERO ENTERTAINMENT CO., LIMITED. is FLAT/RM 1903 19/F LEE GARDEN ONE 33 HYSAN AVENUE CAUSEWAY BAY, HK.

We highly respect your concerns about privacy. This Privacy Policy (“Policy”) is made to explain the when, how and why when it comes to processing of your personal information in connection with the Services and sets out your choices and rights in relation to that information. Unless otherwise stated herein, all terms used in this Policy shall have the same meaning as defined in the Terms of Service of Hero Entertainment.

If you do not agree to the processing of your personal information in the way stipulated in this Policy, please do not provide your information or stop using the Services. By using this Services you are deemed as accepting this Policy.

If you have any questions or requests in connection with this Policy or processing of your information, do not hesitate to reach out to us at bd_overseas@yingxiong.com

This Policy will help you to understand:

1. What Kind of User Information We May Collect And How To Use It

2. Purpose of Collecting User Information

3. Legal Basis for Processing

4. Storage and Protection of User Information

5. Entrusted Processing, Sharing, Transfer or Disclosure of User Information

6. SDK or Other Similar Applications

7. Your Rights

8. Reminder for Minor Users

9. Scope of This Policy

10. Changes to This Policy

11. Law and Jurisdiction

12. Language

13. Contact Us

1、What Kind of User Information We May Collect And How To Use It

1.1 We may collect the personal information you directly provide to us:

(1) Account Registration Related Information. We may collect: i) your account registration information provided when you register your account, such as email address and password (if applicable); ii) your nickname when you log in as a “guest” in order to use the Services; (iii) your validation information to validate your eligibility for the Service.

Please note that if you log in via your Google Play account/ Apple (iOS game center) account/Facebook account or any other third-party account, you give us your third-party account ID/ username and/or profile picture or any other information as the case may be. In this case, please carefully read the user terms or privacy policy of the services of such third-party platforms. We will comply with both this Policy and the privacy policy of such third-party partners for the purpose of “minimum utilization and maximum protection” of your user information. You may also choose to provide your gender during account registration.

(2) Game Function Related Information. If you choose to use some special functions of the game, you may be required to upload, post, publish or provide personal information, including the information contained in or related to the content you provide (such as metadata, file creation date).

(3) Activity/Survey Related Information. If you choose to participate in an activity/survey organized by Hero Entertainment, whether online or offline, you may be asked to provide some personal information, e.g. email, phone number, geographic (country) location, game habits, preferences, and any other content you choose to provide. We will use this information for activity purposes or improving our Service only and we will process them in line with applicable laws and regulations.

(4) Customer Services Related Information, namely:

i) Contact data (email address, telephone number, etc. )

ii) Account registration information (gender, email, etc.）

Iii) Any other information necessary, such as the answer to a special question we may ask you in order to permit you to unlock or recover a lost or lapsed account.

(5) Other Information You Voluntarily Provided. 

Unless we obtain your consent, we will not collect personal identifiable information or sensitive personal information, such as your legal name, address, telephone number, fax number, etc. You confirm that if you select to submit any personal identifiable information or sensitive personal information, your submission is subject to this Policy and you consent to the terms therein.

We generally do not collect or process any “special categories” of personal data (including information regarding your health, religious or political beliefs, ethnic background, sexual life and sexual orientation). If this would apply, we will generally rely on obtaining additional specific consent from you at the time we collect the information unless there is a legal requirement or other justification for processing that information.

1.2 Information about you generated automatically when you use our Services, including:

(1) Game User Account Or Role ID(s) Information. Our server will generate a specific account and ID for you to facilitate your registration, login and playing experience.

(2) Game Data. When you are accessing the Services, we may automatically collect relevant information, including your profile picture and any information needed for the game to function, such as gameplay statistics, etc.

(3) Log Information. Log information is classified into device information (about the device you use when you access our Services) and user behavior logs.

(4) Cookies Information. Cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) are small files enabling us to provide certain features and functionality to enhance your experience. You can manage Cookies through browser settings. If you do not want to accept customized services, you can turn off the Cookie function at any time in browser settings.

(5) Your Usage Behavior Information. We collect information on how you use our products, such as the types of content viewed or interacted with, transaction records (ID, product cost, product purchased, IP address, device information (OS version, phone model, device root status) and details of transactions), functions used, operations performed, the users or accounts that you interact with, your text and audio chat data, as well as the time, frequency and duration of your online activities.

(6) Information To Fight Fraud. We collect information from you to fight against fraud, such as refund abuse in games.

(7) Other Information. In order to provide better services to you and improve the service quality of Hero Entertainment, we may need to collect other relevant information from you upon obtaining your consent.

1.3 Your information provided or shared by third parties.

(1) We may receive personal data from a third party if you link it with the Service or make it available to us via your privacy settings.

(2) Other users may provide information relevant to you upon their access to the Services, including relationships, etc.

1.4 How We Use the Information collected.

(1) Registration And Login. For the purpose of successful registration and access to our services, when you register and log in to the account, you need to register in accordance with our guidelines and provide us with your basic registration or login information, e.g. email and password.

(2) Basic Functions Of The Game. When you receive or use the services provided by Hero Entertainment, we may collect, use and store your log information. Log information is classified into device information (about the device you use when you access our Services) and user behavior logs. The above device information includes configuration information, IP address, the version used by the terminal device, device identification code, device ID, device name, device type and version, system version, MAC address, application ID, network type information, UUID, IDFA, and device unique identity information -- International Mobile Equipment Identity (IMEI), which are mainly used to maintain the normal operation of basic functions of the Game and further improve our products and services. User behavior logs include login logs, posting logs, and comment logs, which are mainly used to facilitate you to view the user history records, and for us to conduct operation statistics analysis, customer service complaint handling and other network security analysis.

(3) Customer Service. When providing you with customer service consultation, explanation, complaint, appeal, after-sales service, dispute resolution, and other customer services, we may need you to provide necessary account information and user behavior log information to match and verify your user identity, to track down the problems and disputes involved, and to respond to your requests in a timely manner. At the same time, we may also need to collect and save your contact information, records of calls between you and us and other contact records and the specific contents of them, as well as other necessary information for processing your requests.

(4) Interaction. When you upload or publish texts, pictures, audio, videos and other information in the process of using our services, or interact with other players through texts, pictures, audio, videos and other ways (e.g., chatting, commenting, and sharing), we will collect and store the above information. If the contents contain your personal sensitive information, please consider carefully before publishing them. If the contents involve the personal information of others, please obtain the legal authorization of others before publishing them. If the contents violate the provisions of laws, regulations or other normative documents, violate public order and good customs or public moral standards, infringe upon the rights and interests of others, or involve other illegal or improper circumstances, we will delete or block the contents to maintain a healthy online environment. Depending on the specific interactive service requirements, we may require you to enable the corresponding device access permission. For example, for graphic and video sharing services, you need to enable camera permission and mobile album access permission.

Please particularly note that the service functions involved, the corresponding types of personal information collected, or the scope of permissions may vary according to the actual service content you choose. For details please see the guidlines of the actual product/service in use. Especially, we may remind you in advance by prompts or other means to obtain your permission for personal sensitive information before collecting.

2. Purpose of Collecting User Information

2.1 Hero Entertainment will strictly abide by laws, regulations and relevant government policies, and comply with this Policy and the Agreement to use your information collected for the following purposes:

(1) To provide and manage services for you.

(2) To guarantee the security of services.

(3) To understand the operation and development of services, improve existing services, and develop new high-quality services.

(4) To carry out internal audits, user surveys, and data analysis in order to communicate with you and send out surveys and event invitations.

(5) To answer or satisfy legal or regulatory requirements.

(6) To send you notifications, answer your inquiries or deal with your complaints.

(7) To facilitate account verification and clearance.

(8) Marketing lets you know about products and services that may be of particular interest to you.

(9) To detect cheating and activities that ruin the experience of users, security risks, fraud and other unlawful activity.

(10) To customize your personal experience.

Hero Entertainment promises not to match the information stored in the analysis software with the personal identity information provided by you in the application when analyzing user data. If we plan to use your user information for other purposes not specified in this Policy or use the collected personal information for a specific purpose for other purposes, we will ask for your permission.

2.2 We use Cookies to collect usage data of websites and to operate our services, which may include:

1) Remembering You: Cookies can help us identify you as a registered user or keep the preferences or data that you have previously provided.

2) Help To Provide And Personalize Our Services And Analyze Gaming Usage: we can use Cookies to understand the activities that visitors (including users) carry out in our services, or to identify the most popular pages or sections.

3) Targeted Push Notifications: Cookies 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.

4) Preventing Fraud.

You can disable Cookies in your browser settings, but some parts of our services may not function properly afterwards.

3. Legal Basis for Processing

In most cases, the legal basis we adopted for processing your data is one of the following:

3.1 Already obtained your consent to use your information for agreed purposes.

3.2 In our legitimate interest as a commercial organization.

3.3 Necessary to perform our contract with you to provide the Service.

3.4 To comply with a relevant legal or regulatory obligation.

3.5 Other legal basis set forth in applicable laws and regulations.

4. Storage and Protection of User Information

4.1 Storage Of User Information.

(1) Storage Period. Except otherwise stipulated in applicable laws and regulations, Hero Entertainment stores information about you for the shortest possible period of time only for the purpose set forth in this Policy. After you cancel the authorization or the storage period expires, we will delete or anonymize your user information.  

You acknowledge and agree that to improve the quality of our Services, we may need your user data for research or statistical purposes, in which case we will make sure your personal information has been anonymized first and we may use this information without further notice to you.

(2) Storage Area. For the purposes described in this policy, your information may be transferred to countries/regions outside your residence or may be stored or processed in these countries/regions. Regardless of where our servers are located, we will take reasonable steps to protect your rights in accordance with the provisions of this Privacy Policy.

4.2 Protection of User Information. We are well aware that personal information is important to you and will do our best to protect your personal information safely and reliably. In order to protect users’ information security, Hero Entertainment will take various reasonable security measures at physical, technical, organizational and management levels to protect your data and information and prevent information leakage, loss and damage. These security measures include technical measures such as SSL, information encryption storage, access control of data centers, dedicated network channels, and agents, as well as personnel or institutional management measures such as access control and management of employees or outsourcers, signing of confidentiality agreements, and formulation of the company’s confidentiality system. If unfortunately, the user information security incident occurs, we will – according to relevant laws and regulations -- timely inform you of the basic information of the related incident, possible adverse effects and measures we have taken or will take via any possible means, such as public announcement, SMS, phone call, email notification, etc., in order to remedy the situation as soon as possible. At the same time, we will also proactively report the handling of the relevant incident in accordance with the requirements of the regulatory authorities.

5. Entrusted Processing, Sharing, Transfer or Disclosure of User Information

At present, in order to provide better services for you and improve your user experience, Hero Entertainment may entrust a third party to process, share, transfer or disclose your information in the following circumstances.

5.1 Certain specific modules or functions in our products and services may be provided by external suppliers. We will conduct security assessments on the companies, organizations and individuals entrusted to process personal information and the entrusted behavior, sign strict confidentiality terms or agreements with them and specify the entrusted matters, processing period and purpose, and the responsibilities of the trustee. And we will require the trustee to process and protect your information in accordance with the privacy policy, information usage description and other relevant confidentiality measures and security measures of Hero Entertainment.

5.2 We will not share your personal information with any other company, organization or individual unless we obtain your express consent. Hero Entertainment may share necessary user information of you with necessary third-party partners. Regarding such third-party partners, we will sign strict confidentiality terms or agreements with them and require them to process and protect your information in accordance with the privacy policy, information usage description and other relevant confidentiality measures and security measures of Hero Entertainment.

(1) Generally, our third-party partners are of the following types:

① Third-party service providers and contractors.

② Agents or intermediaries.

③ Legal, accounting, business and other professional consultants.

④ Advertising partners.

⑤ Third-party SDK service providers.

(2) Use of your information by such a third-party partner is mainly for the following purposes:

① To provide services for you.

② To achieve the purpose of Article 5.1.

③ To perform our obligations under the Agreement between Hero Entertainment and you.

④ To exercise our rights in the Agreement between Hero Entertainment and you.

⑤ To maintain and improve services and optimize the user experience. If this third-party partner changes the purpose of your user information usage, you will be asked for permission.

5.3 When it comes to mergers, acquisitions, asset transfers or similar transactions, Hero Entertainment may transfer your personal information to third parties associated with such transactions and your personal information is likely to be part of such transactions. In this circumstance, Hero Entertainment will require new managers to continue to do a good job in protecting users’ personal information in accordance with the provisions of laws, regulations and policies and provisions of this Policy. If the new manager changes the purpose of your user information usage, you will be asked for permission then.

6. SDK or Other Similar Applications

We may access SDKs or other similar applications provided by third-party service providers for the purpose of implementing relevant services.

The aforesaid third-party services are operated by relevant third parties. Your use of such services shall be bound by the third-party service providers’ service terms and privacy policy, and not subject to this Policy. To better protect your legitimate rights and interests, you are advised to read the service terms and privacy policy of such third-party service providers carefully before using any third-party SDK service. If you find that these SDKs or other similar applications are at risk, you are advised to terminate relevant operations immediately and contact us in time.

7. Your Rights

When you receive or use the services provided by Hero Entertainment, we will do our best to ensure that you can exercise the following rights with respect to your personal information:

7.1 Query, access, modify and delete your personal information. You can log in to your account and follow the instructions in the game to query, access, modify and delete your personal information. Unless otherwise provided by law, we will delete or anonymize your information once it is deleted. We will also simultaneously notify entities who have obtained your personal information from us and request them to promptly delete such information, unless otherwise provided by law or unless that entity has obtained your independent authorization. If you modify or delete information from our products or services, we may not immediately modify or delete the corresponding information in the backup system, but we will modify or delete the information when the backup is updated.

7.2 Change or withdraw the scope of your authorization. You have the right to change or withdraw the scope of your authorization. Part of our service functions requires some basic personal information or relevant permissions of the devices you use (refer to Article 1 of this Policy and see the information or function that the specific product or service actually intends to obtain for details). You have the right to give or change or withdraw authorization at any time. You can change or withdraw the scope of your authorization as guided in the game or you can even cancel your account to permanently withdraw all the authorization for us to continue to collect your personal information. Please note that when you withdraw your authorization, we will no longer process the corresponding personal information and will not be able to continue to provide specific service functions or services based on such authorization. However, your decision to withdraw authorization will not affect the personal information processing carried out based on your previous authorization.

7.3 Cancel your account. You have the right to cancel your account. You can request to cancel your account by sending an email to us. Please know, understand and agree that the account cancellation is irrevocable and irreversible upon completion. After the account is canceled, your account and all its contents cannot be recovered. And we will stop providing you with products or services and delete your personal information unless otherwise stipulated in laws and regulations.

7.4 Your above requests shall be responded. Generally, the above requests can be completed by yourself on the corresponding interface of our products and services according to the notification or guidelines published online. If there is a request that may not be able to be met through online processing services at present, or if you encounter any problems or obstacles or have any opinions or suggestions in the process of exercising your rights, you can also send an email to the official mailbox to contact us, and we will handle it. Please know, understand and agree that in response to your above requests, in order to protect the security of your account and information, we may need to verify your identity first, then process your request after you complete your identity verification in accordance with relevant instructions. For your reasonable requests, the verification and processing time will be 15 working days after you contact us and after the identity verification is successfully completed (if necessary). Such a response period may be extended for your own reasons or for other reasons beyond our control. We may refuse requests that are repeated many times for no reason, exceed reasonable limits, require excessive technical means (such as developing a new system or fundamentally changing the current practice), bring risks to the legitimate rights and interests of others, or are highly impractical. However, we will explain to you the reasons and grounds for the refusal.

If there are other special provisions provided by applicable laws and regulations in the country where you live or work, we will process your requests in accordance with applicable laws.

7.5 Depending on your place of residence, you may be able to exercise your right to data portability and right of refusal, etc. on your information in accordance with applicable legal requirements.

7.6 In the case of push notifications related to marketing or advertising communications, you can object to our right to process your data for direct marketing purposes by using the "Unsubscribe" link in such marketing communications. With regard to the sending of personalized communications of a marketing or promotional nature, you may choose to accept or object to our processing of your data for personalized push notifications by enabling or disabling this feature in the relevant settings. When you choose to turn off personalized recommendations, you will not be able to enjoy the personalized recommendation services provided by us.

8. Reminder for Minor Users

You confirm 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 services. If you are a minor, you should obtain prior consent from your parent or any other guardian (hereinafter referred to as “guardian”) before receiving or using the services provided by Hero Entertainment. Please know, understand and agree that minors should not register and create their own accounts, receive or use our products and services without the consent of their guardians. If you are the guardian of a minor, please contact us through the contact information specified in this Policy if you have any doubts about the personal information of the minor under your guardianship or require us to query, access, modify, correct, or delete the information. We strongly urge parents to supervise minors to protect their personal information. If we learn that we have collected personal information about a minor, we will delete such data immediately. Also, if you believe that we might have collected data from or about a Minor, please contact us immediately.

9. Scope of This Policy

This Policy applies to the Services provided by Hero Entertainment except for certain specific services. However, when a specific service has its own privacy policy, the special provisions of such privacy policy shall prevail.

This policy does not apply to services provided to you by other companies or individuals. Your use of such third-party service is subject to ch third-party’s own privacy policy.

10. Changes to This Policy

We may amend the contents or terms of this Policy in due course. Such amendments or changes may result in a material derogation of your rights under this Policy, and we will notify you of the changes or amendments via prompts in prominent positions on the page, email to you, etc. before the changes or amendments become effective. In this case, if you do not agree to such amendments or changes, you have the right to and shall immediately stop using our products or services.

11.  Law and Jurisdiction  

The conclusion, interpretation and performance of this Policy shall be governed by the laws of the People's Republic of China, without giving effect to any conflict of law provisions.

Any dispute arising from or in connection with this Policy shall be submitted to China International Economic and Trade Arbitration Commission (CIETAC) for arbitration which shall be conducted in accordance with the CIETAC 's arbitration rules in effect at the time of applying for arbitration. The arbitration place shall be Beijing, China. The arbitral award is final and binding upon both parties.

Any such arbitration shall be conducted solely by the parties in their individual capacities, and by entering into this Policy, you and Hero Entertainment expressly waive the right to participate in a class action.

If any court or arbitrator determines that the class action waiver set forth in the preceding sentence is invalid or unenforceable for any reason, or that the arbitration can proceed on the premise of a class action, the arbitration provisions set forth in this section shall be deemed invalid and void in their entirety. Both parties shall be deemed not to have agreed to arbitrate the claim.

12. Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and the local language version of this privacy policy, the English version shall prevail.

13. Contact Us

If you have any doubts, opinions or suggestions regarding the protection of your personal information under this Policy and in the process of receiving or using our products and services, please contact us via email as listed on the first page. Normally, after receiving your email and verifying your user identity (our verification and the processing time are 15 working days), we will get back to you as soon as possible. However, please know, understand and agree that we will not be able to respond to your requests in the circumstances listed in Article 7.4 of this Policy.

Last updated on  , 2023.3.30