Privacy Policy

To better protect your rights, please contact us in the manner described in Article 10 of this Privacy Policy if you have any questions or suggestions.

Overview

Welcome to use the game products and related services provided by Shanghai Neverland Tech Co., Ltd. (hereinafter referred to as "the Company," "we," "us," or "our").

When you use our products or services, we may collect, use, store, share, and manage your relevant information. This Privacy Policy is closely related to the services you use and the rights you enjoy. We hope you will read it carefully and understand the corresponding relationship between personal information types and uses, as well as more detailed rules on personal information processing. In particular, the terms marked in bold/underlined should be read carefully, and you should start using the services only after confirming that you fully understand and agree with them. Please note that we will periodically review and update our policies, so related measures will change accordingly.

After reading this Privacy Policy, if you have any questions about this Privacy Policy or related matters, please contact us. By using or continuing to use our products and services, you agree that we may collect, use, store, share, and manage your relevant information in accordance with this Privacy Policy.

Our Commitment

We promise to protect the security of your data and not sell your data to third parties. We promise to give you the right to access and delete your own data, and provide you with various ways to manage and review your own marketing choices and any other information (such as information) obtained from us.

What is Personal Information?

Personal information can be any relevant information of identified or identifiable natural persons. In other words, personal information is any information that can allow us to directly or indirectly identify you (such as your user account information, name, email address, IP address, or country, etc.).

Information We Collect

When you use our products or services, we may collect, store, and use the following information related to you. If you do not provide certain relevant information, you may not become our user, or you may not enjoy certain services or functions we provide, or you may not achieve the intended effects of relevant services.

1.  Information you provide voluntarily
   1.  The relevant personal information you need to provide us when using our products or services, such as phone number, email, device name, and identity information, including but not limited to:
      1. Relevant information you fill in when registering an account, such as nickname, avatar, mobile phone number, ID card number, or real-name identity information required by laws and regulations; if you refuse to provide real-name identity information, you may not be able to enter the game, we cannot provide you with corresponding services, or you may be subject to corresponding restrictions during use;
      2. Information you upload when using our services;
      3. Information submitted when you participate in our events.
   2. The shared information you provide to other parties through our services, and the information you store when using our services.
   3. Information contained in the content you share through our services (metadata), dates, times, or locations contained in shared photos or videos you uploaded.
   4. Information we obtain when you use the service.
2. Log information, which refers to technical information that the system may automatically collect through cookies or other means when you use our services, including:
   1. Detailed usage information of our services, your login time, and accessed content;
   2. Information about communications you made through our services, including account information,
   3. IP addresses;
   4. Device or software information: your mobile device model, software version information, operating system and version, web browser type, MAC address, mobile network information, your device ID, device model, carrier, hardware serial number, sensors, application installation list, android_id/IMEI/IDFA/OPENUDID/GUID, SIM card IMSI information. We may associate your unique device identifier or phone number with your account.
   5. Phone permissions: To better serve you, we need to identify your local identification code and obtain your device identification code as your unique identity authentication. You may authorize us to read your phone permissions when using our services. If you do not provide this personal information, you may not be able to use the services mentioned above.
3.  Recharge and consumption information: When you use our product or service consumption function, we will collect and store your recharge and consumption record information, so as to query your account's recharge and consumption records for you.
4. Ad tracking: To better serve you with our advertising services, you may authorize us to access your activity records on other related apps and websites when using our services. If you refuse to authorize, you will not be able to use the corresponding functions, but it will not affect your normal use of other game functions. You may also cancel related permissions at any time.

How we use your information

We only use your personal information for the following purposes and uses as stated in this policy:

1. To provide you with various game services and functions
   1. Basic game functions and customer service.
2.  Product issue fixes and product optimization:
   1. In order to improve the gaming user service experience and solve bugs that may occur during the use of the game, we will use the log information generated during the use of the game service, including device information, regional information (without precise positioning), game behavior information, and transaction information. Before analyzing the log, we will anonymize the above information and analyze the type of user and corresponding game behavior as a whole.
3.  Internal and external audits:
   1. In order to fulfill the obligations stipulated by laws and regulations and regulatory agencies, we may provide anonymized personal information, device information, and transaction information to regulatory or audit agencies in support of various internal and external audit processes, under the premise of signing a confidentiality agreement.
   2. When we use information for purposes not stated in this policy or for collecting information for specific purposes for other purposes, we will seek your consent in advance.
   3. If it is non-essential personal information, you can delete the personal information you have provided at any time or revoke the authorization you have provided to us. Deleting information or revoking authorization may cause you to be unable to realize some functions corresponding to the game, but it will not affect your use of the basic functions of the game.

How we share and publicly disclose your personal information

1. Without your consent, we will not share any personally identifiable or identity-recognizable information with any third party, except for the following:
   1. With your consent：After obtaining your consent, we will only share your personal information with other companies, organizations and individuals for legal, legitimate, necessary, specific, and clear purposes. We must obtain your consent before sharing any of your personal information.
   2. For legal reasons：We may also retain, preserve or disclose your personal information for the following reasons:
      1. To comply with applicable laws and regulations;
      2. To comply with court orders or other legal procedures;
      3. To comply with relevant government agency requirements;
      4. For reasonable and necessary purposes of complying with applicable laws and regulations, maintaining social public interests, or protecting the personal and property safety or legitimate rights and interests.
2. You agree that in order to provide better services, 
   1. we may share your personal information that does not contain personal identification or identification with our affiliated companies, partners, and third-party service providers, contractors, and agents (such as communication service providers who send emails or notifications on our behalf, map service providers who provide us with location data) for the following purposes:
      1. To provide you with our services;
      2. To achieve the purposes described in the "How We May Use Information" section;
      3. To fulfill our obligations and exercise our rights under this Privacy Policy;
      4. To understand, maintain, and improve our services.
   2.  If we share your personal information with any of the above-mentioned third parties, we will use encryption, anonymization, and de-identification measures to protect your information security and personal privacy. At the same time, we will make efforts to ensure that such third parties comply with this Privacy Policy and other appropriate confidentiality and security measures that we require them to comply with to ensure the security of your personal information.
   3. Our partners include the following types:
      1. Third-party service providers. We may share your personal information with third parties that support our functions. These include providing us with infrastructure technology services, payment services, and data processing. We share this information to enable us to provide basic functions of our gaming services.
      2. Dispute resolution. In the event that you have a dispute, complaint or have been complained against when using the app and related services, in order to protect your and other parties' legitimate rights and interests, maintain a good trading order and social environment, we will provide your name, valid ID number, contact information, and dispute content to consumer protection departments and regulatory authorities based on their requirements, for timely dispute resolution, except where prohibited by law and regulations.
3. Public disclosure: We will only disclose your personal information in the following circumstances and subject to the premise of adopting security protection measures that meet industry standards:
   1. Disclose the personal information you specify in the disclosure method that you explicitly agree with according to your needs;
   2. We may disclose your personal information in accordance with legal and regulatory requirements or mandatory requirements of administrative or judicial authorities. When we receive such disclosure requests, we will require the requesting party to provide relevant legal documents, such as subpoenas or investigation letters. We will carefully review each disclosure request to ensure that it complies with relevant legal regulations. Provided that permitted by law and regulations, we will encrypt files containing disclosure information.

How do we protect your information

We will use industry-standard security measures to protect the personal information you provide us, and prevent unauthorized access, disclosure, use, modification, damage, or loss of data.

We will take all reasonable and feasible measures to ensure that we do not collect unnecessary personal information. We will only retain your personal information for the shortest period necessary to achieve the purposes described in this policy, unless we need to extend the retention period or are permitted by law.

The internet is not an entirely secure environment, and we strongly recommend that you avoid sending personal information through unencrypted means. Please use complex passwords (including numbers, uppercase and lowercase letters, special characters, and avoid using your name or birthdate), to help us ensure the security of your account.

Although the internet environment is not 100% secure, we will do our best to ensure or guarantee the security of any information you send us. If our physical, technical, or managerial security measures are breached, resulting in unauthorized access, disclosure, alteration, or destruction of information and harm to your legitimate interests, we will assume corresponding legal responsibility.

In the event of a personal information security incident, we will promptly inform you of the basic situation and possible impact of the incident, the disposal measures we have taken or will take, suggestions for you to independently prevent and reduce risks, and remedial measures for you. We will inform you of the relevant situation of the incident through letters, SMS, phone calls, push notifications, and if it is difficult to inform each data subject individually, we will issue public notices in reasonable and effective ways. At the same time, we will proactively report the disposal situation of personal information security incidents to regulatory authorities in accordance with their requirements.

Can minors use our services

We attach great importance to the security and protection of minors' information, and strictly abide by the national regulations and requirements for preventing addiction. Our services and games are not intended for minors, and we do not knowingly collect information from minors.

We strongly advise parents or guardians to guide minors to avoid disclosing any personal information when surfing the internet. If parents or guardians have any doubts about data transmission, they can contact us at support@nlentmt.com to inquire, modify, delete or cancel the personal information of minors. If we confirm that we have collected information from minors, we will immediately delete it, unless we are legally responsible for retaining such data.

Changes to the Privacy Policy

This policy may change from time to time. Any changes to this policy will be posted on our official website, and in the event of significant changes, we will notify you more clearly, such as through email, in-game pop-ups, or account pop-ups. If you receive a notice of changes to this policy but refuse to accept it, you may not be able to continue to enjoy the full functionality of our services. If you continue to use our services, you accept our changes and agree to collect and process your data in accordance with our updated policy.

Contact Information and Complaint Procedures

If you are dissatisfied with how we handle your data, please contact us by email at support@nlentmt.com. If you have any questions or feedback about this policy or any part of it, please feel free to let us know.