Kunpo Interactive Privacy Policy

Update Date: December 27, 2024

Preface

Qingdao Kunpo Interactive Technology Co., Ltd. and its affiliates (“we” or “Kunpo Interactive”) strictly protect the personal information and privacy of users (“users” or “you”) of Kunpo Interactive products and game services (collectively, the “services”). We understand the importance of your personal information and will protect it in accordance with laws and regulations. We have formulated this Privacy Policy and remind you to read and understand it carefully before using our products or services so that you can make informed choices.

Special Notes

• Users under the age of 14 are also subject to the Children’s Privacy Protection Statement. Where a specific clause conflicts with this policy, the specific clause prevails within its scope.
• We collect and use your information in accordance with this policy, and will not bundle irrelevant data collection simply because you agreed to this policy.
• When you enable certain features or services, we collect only what is necessary to provide those features or services.
• If you are not logged in, we may use device identifiers to provide basic information push; if you are logged in, we will push based on your account information.
• Sensitive permissions are not enabled by default and are only used with your explicit authorization, which you may withdraw. Even with authorization, we will not collect information when it is unnecessary for a given feature or service. Product-specific, just-in-time notices (e.g., pop-ups or page prompts) about the purpose, scope, and use of information form part of this Privacy Policy and have the same effect as this policy.
• Please read this policy carefully—especially bolded or emphasized terms—and use our services only after fully understanding and agreeing to them. By using our services, you indicate your full understanding and consent to this policy.

Contents Covered in This Privacy Policy

1. How we collect and use personal information
2. Use of cookies and similar technologies
3. Sharing, transfer, and public disclosure of personal information
4. Third-party services we access
5. Storage of personal information
6. How we protect personal information
7. How you can manage your personal information
8. Terms for minors
9. Revisions and notifications of this Privacy Policy
10. Dispute resolution
11. Contact us

I. How We Collect and Use Personal Information

(1) How we collect and obtain your personal information

1. Information you provide

For example: information you provide when registering an account or using Kunpo Interactive services; information you share with third parties through our services; and information you store when using our services. Please note that if you upload or post information in public areas visible to other users or respond to others’ posts, that information may be collected and used by others. If you discover misuse, please contact us via the channels in Contact Us.

2. Information shared by third parties

Information about you shared by third parties that use Kunpo Interactive services.

3. Information we obtain

When you use Kunpo Interactive services, we may collect, aggregate, and record information such as log information, location information, and device information.

(2) Purposes for which we collect and use personal information

1. Registration and login. To provide stable services and ensure account security, we require basic registration or login information (e.g., phone number) to create your account and password. You may also log in via a third-party account, authorizing us to obtain your avatar, nickname, and other public information, and—after you agree to this policy—bind that account to your game account.

2. Real-name verification. As required by laws, regulations, and supervision, or to verify user identity and ensure system and service security, you may need to provide real identity information (e.g., name, ID number, household register, photos) or biometric information (static or dynamic facial features). You consent and authorize us to provide, query, and verify such information with relevant identity authentication institutions (e.g., government agencies or credit institutions). Identity and biometric data are sensitive; without them, you may be unable to log in or may face restrictions.

3. Payments and purchases. When you use in-game purchasing, we collect your top-up and purchase records (e.g., purchased services, order numbers, timestamps, amounts, virtual transactions, redemption codes) to help you manage orders, protect your virtual items, and assist administrative/judicial verification.

4. Maintaining basic functionality. To provide browsing/search and ensure network/operational security, we may collect and associate information about your usage, including:
(1) Log information: login account, search queries, IP address, browser type, carrier, network environment, language, match data, pages visited in player communities, duration, refresh and posting records (including when the app is in the background).
(2) Device information: device model, OS/version, client version, resolution, package name, settings, process and software lists, identifiers (e.g., MAC/IMEI/Android ID/IDFA/OpenUDID/GUID/HarmonyOS OAID/AAID/ODID/IMSI), hardware/software characteristics, sensor data (gyroscope, accelerometer, orientation, gravity), and location (IP, GPS, WLAN access points, Bluetooth, base station data). We may request permission to access device info to provide basic services; refusal may affect service use.

Standalone device or log information cannot directly identify a natural person. If combined with other data to identify a person, we will treat it as personal information and apply anonymization or de-identification where applicable.

5. Interactive and publishing services. When you upload/post or interact (chat, post, reply, like, share), we collect and display your nickname, avatar, and content. We may collect and retain text, images, voice, and video exchanged in-game to filter inappropriate content (e.g., political, pornographic, violent, abusive, malicious ads) and report to authorities when required.

6. Customer service and other user response functions. When contacting support or using response functions (complaints/suggestions), we may need necessary personal information to verify identity and protect your account/virtual items. We may retain communications, your contact details, and information related to your request.

7. Indirect collection. With your authorization, we may obtain information from affiliates or partners (e.g., username, nickname, avatar from third-party login), and bind it to your Kunpo product account.

8. Security protection. To ensure account security and a fair, healthy gaming environment, we may collect game identifiers, hardware/OS information, process and crash logs to detect piracy, plug-ins, and cheating.

9. Device permissions. Certain services require enabling device permissions:
(1) Storage: download/save content or caching;
(2) Photos/Camera: upload/capture media for posts/comments or support;
(3) Microphone/Voice: voice features and support;
(4) Location: nearby interactions;
(5) Device info: unique identification for compatibility, anomaly detection, and security.
You may disable these permissions at any time via device settings; disabling stops related collection but does not affect prior lawful processing.

10. Exceptions to consent. We may collect/use necessary personal information without consent when related to national defense/security, public safety/health/interest, criminal investigations, vital interests where consent is hard to obtain, public disclosures, lawful public sources, contract performance, product/service security and stability, legitimate news reporting, academic research in the public interest, or other circumstances provided by law.

11. Sensitive personal information notice. Sensitive data includes ID numbers, biometric data (static/dynamic), communications and content, location and trajectory, and transaction information. You agree we may process such data as described.

II. Use of Cookies and Similar Technologies

We store small data files (Cookies, Flash Cookies, or other local storage) on your device. Cookies typically contain an identifier, site name, and numbers/characters. You can disable cookies in your browser, which may affect access or service quality. We do not use cookies beyond the purposes in this policy.

1) Security and efficiency. Authentication and security cookies/identifiers help confirm safe login and detect fraud or misuse, improving efficiency and response speed.

2) Easier access. These technologies retain login states and reduce repetitive input.

3) Clearing cookies. Most browsers let you clear cached data. Clearing may affect cookie-dependent features.

III. Sharing, Transfer, and Public Disclosure of Personal Information

(1) Sharing

We value your privacy and, without separate consent, will not share personal information with third parties outside Kunpo Interactive, except in these cases:

1. Necessary sharing to realize services/features, e.g., payment institutions (orders/amounts), real-name authentication providers, and other suppliers/partners.
2. Necessary sharing with certain partners: data services (ad monitoring/statistics/analysis), product analytics (crash/network/DNS), marketing (including device info/phone number), etc.
3. Necessary sharing with affiliates and/or their service providers. If sensitive personal information or purposes change, we will seek your consent again.
4. To achieve the other purposes described in Section I of this policy.
5. To perform obligations or exercise rights under this policy or other agreements with you.
6. To comply with laws and protect the interests, property, or safety of us, affiliates, partners, users, or the public (e.g., fraud prevention and risk reduction).
7. At your lawful request or with your authorization; or at your guardian’s lawful request.
8. As agreed in service-specific agreements or other legal documents with you.
9. For academic research.
10. For public interest as permitted by law.

We will only share information for legitimate, necessary, specific, and explicit purposes, and require recipients to sign confidentiality agreements and follow this policy.

(2) Transfer

We do not transfer your personal information except with your explicit consent, or in mergers, acquisitions, or bankruptcy (where the new entity remains bound by this policy or re-requests your consent).

(3) Public disclosure

We will disclose personal information only with your explicit consent, or per laws/regulations/legal procedures/governmental or judicial requirements, or to protect users/the public from harm, and will require appropriate legal documents when applicable.

(4) Exceptions to prior consent

No prior consent is required in situations involving national security/defense, public safety/health/interest, judicial or administrative enforcement, vital interests where consent is hard to obtain, your self-disclosed information, lawful public sources, academic research in the public interest, or other circumstances provided by law. If data is technically processed so recipients cannot re-identify individuals or restore data, further notice/consent is not required.

IV. Third-Party Services We Access

Kunpo Interactive may access or link to third-party platforms or services (see “Third-Party SDK Catalog”). Examples include content sharing, links to third-party services/websites, and integrating third-party SDKs (e.g., ads, push, payments, location, third-party login/sharing, analytics, voice recognition, intelligent customer service, storage, web/video viewing, performance optimization, account security, hardening, anti-spam/anti-cheat, encryption, etc.). These third parties operate their own services and are governed by their own terms and privacy statements. Please read their terms carefully.

V. Storage of Personal Information

We store personal information only for the minimum period necessary for the purposes described, unless otherwise required by laws/regulations. If we terminate services/operations, we will stop collection, notify you in advance, and delete or anonymize personal information unless otherwise required.

Personal information collected and generated within the PRC during operations is stored in China, except as required by law, with your consent, or where cross-border services need it. In such cases, we will comply with applicable laws/regulations and provide adequate protection.

VI. How We Protect Personal Information

1) Security measures. We apply industry-standard physical, electronic, and managerial measures (e.g., SSL encryption, access control, trusted protection mechanisms). We strictly manage employees who may access your information and bind them by confidentiality obligations.

2) Incident handling. In the event of a security incident (e.g., data leak), we will initiate emergency plans, and notify you per legal requirements regarding the situation, impacts, measures taken, self-protection advice, and remedies, via email, letter, phone, push notifications, or announcements when individual notice is infeasible. We will also report to regulators as required.

VII. How You Can Manage Your Personal Information

1) Information management. You may access, modify, and delete registration and other personal information, and manage device permissions (album/camera/contacts/location, etc.) through device settings.

2) Changing your consent scope. Contact us via in-app Customer Service, hotline +86-4000039581, or email support@kunpo.cc to withdraw consent. Withdrawal stops further processing for the related permissions but does not affect prior lawful processing.

3) Obtaining a copy of your personal information. Request via in-app Customer Service/Contact Us, hotline, or email. We will provide a copy within 15 working days.

4) Account deletion. You may submit a deletion request via in-app Customer Service/Contact Us, hotline, or email. After deletion, we will cease providing services and promptly delete or anonymize your information.

5) Complaints and reports. Contact us via in-app Customer Service, hotline, or email. We will respond within 15 days after verification.

6) Accessing the Privacy Policy. View the full policy in your account: Settings → Privacy Policy.

7) Notice of cessation of operations. If we cease operations, we will stop collecting personal information, notify you individually or by public announcement, and delete or anonymize your information.

8) Situations where we may not respond. Requests involving national security/defense, public safety/health/interest, criminal procedures, malicious abuse of rights, serious harm to others’ rights/interests, or trade secrets.

VIII. Terms for Minors

1) General terms. Users under 14 should read this policy with guardians and obtain consent. We protect minors’ personal information per laws, and collect/use/share/disclose it only when permitted by law, with guardian consent, or when necessary to protect minors. If we learn minors’ information was collected without verifiable guardian consent, we will delete it as soon as possible. Guardians may contact us with questions.

2) Special protection. We follow anti-addiction requirements, using real-name checks to determine whether an account belongs to a minor and, if so, apply restrictions such as gameplay time limits and forced logouts. We may contact guardians to confirm and handle suspicious spending. Users under 14 are also subject to the Children’s Privacy Protection Statement and may only use our services after guardian consent to that statement.

IX. Revisions and Notifications

We may update this policy to improve our services. Such updates form part of this policy and have the same effect. We will not reduce your rights under the current policy without your explicit consent. After updates, we will notify you via website announcements, push notifications, pop-ups, or other means before the updated terms take effect.

X. Dispute Resolution

This policy is signed in Shinan District, Qingdao, Shandong Province, PRC. The establishment, effectiveness, performance, interpretation, and dispute resolution are governed by the laws of mainland China. Disputes shall be resolved amicably first; failing that, they shall be submitted to the People’s Court of Shinan District, Qingdao.

XI. Contact Us

If you have any questions, comments, or suggestions regarding this policy, please contact us via in-app Customer Service/Contact Us, the customer hotline +86-4000039581, or email support@kunpo.cc. We will review and reply within fifteen (15) working days after verifying your identity.

We have a dedicated personal information protection department. Email: support@kunpo.cc

Address: Tianfu Avenue, High-tech Zone, Chengdu, China  |  Postal Code: 610041

Note: This is an English translation of the main body text of the original Chinese Privacy Policy for convenience only. In case of any inconsistency, the Chinese version shall prevail.