隐私政策

This Privacy Policy describes how and why we, SP Interactive L.L.C.-FZ (“Company”, also “we,” “us”), collect personal data related to you, use your personal data, and explains your rights related to this data processing.

The Privacy Policy applies to data processing when you: install and play video games owned and published by the Company and available at our website and through game platforms (the “Games”); create and use your game account (the “Account”); use our websites, forums or other communication and collaboration tools, any other digital product or service we provide (collectively, the "Services").

1. WHERE WE COLLECT DATA FROM

The sources where we might collect your personal data.

Directly from You

We may obtain personal data directly from you. For instance, you directly provide us with personal information when you set up, use and manage your Account, make purchases, or contact Support Service; sign up for our game tests, creator partnership programs and other events.

Data Collected Automatically

Some information is collected automatically when you use our Services. For instance, when you visit our websites, your browser sends technical details such as the address of the page you viewed, your IP address, and your browser type and version. When you play the Game, we automatically record your user ID and other game-related identifiers together with information about how you play, including your in-game actions, matches and results.

Game Platforms

We receive information from the platforms and app stores where our Games are published, such as AppStore, Google Play, Steam. For example, we receive information about your sign up and in-app purchases through such platforms.

Social Media

If you access or log in through a social media service, the information we collect may include your user ID and/or username associated with that social media, as well as any information or content you have permitted the social media service to share with us, such as your profile picture, email address, or friends lists.

Advertising Partners

We receive information from our advertising partners to help us deliver ads and measure their performance, as well as to recognize you across browsers and devices. This may include pseudonymous advertiser identifiers that some advertisers or other third-party ad platforms choose to share with us.

Payment Providers

Our payment providers collect your credit card details, e-wallet information, or other payment details depending on the payment method you use. Payment providers also process technical data in connection with your transactions. We only receive payment verification data and do not have access to the full payment details.

2. PURPOSES FOR WHICH WE COLLECT YOUR DATA

We collect and process your personal data for various purposes set out below.

Personal data that we process to enter into a contract are necessary to provide you with our Services. If you choose not to provide or decide to restrict processing of your personal data, in full or in part, we might not be able to provide you with the Services. Where we process your personal data to comply with a legal obligation, providing such personal data is a statutory requirement. If you do not provide the required personal data, we may be unable to comply with our legal obligations and, as a result, may be unable to provide you with access to the Services.

Providing the Services. To perform the contract with you and provide you with our Services, we process your data to register and manage your Account (including sign-in through third-party providers), to deliver the Services and enable their functionality, to operate matchmaking, save your progress, settings, and preferences, and support other game features. We also process your data to respond to technical support requests, to diagnose and resolve technical problems you report.

Processing In-Game Purchases. We process your data to facilitate in-game purchases, whether made through authorized platforms (such as AppStore, Google Play, Steam) or through our own web-shop. Apart from performing the contact to provide you with the Services, this is also necessary to fulfil our legal obligations related to online payments and reporting.

Improving the Services and User Experience. We process your data to identify and fix technical issues, optimize the Services for different devices, and analyze gameplay and usage patterns so that we can improve existing features and develop new ones. This processing is based on our legitimate interest in improving the Services and tailoring them to players' interests.

Conducting Closed Testing. When we receive an application from you to take part in testing, we process your application data to organize and run testing of a Game and new features, including closed (invite-only) testing, so that we can gather feedback, reproduce and fix issues, measure stability and performance, and evaluate new content before release,- all these to perform the contract and in the legitimate interest to make a good game that our players will enjoy and continuously improve it.

Preventing Cheating, Fraud, and Other Deceptive Practices. We process data in the legitimate interest to protect players, ensure fair play, and the integrity of the Game by detecting and responding to cheating, fraud, and abuse.

Marketing Communications and Analytics. We process your data to send you news, offers, and updates about our Games and other Services. We also may conduct advertising campaigns run on external channels (such as social media, other websites and apps), which may be shown to users based on their interests. Depending on the content and channels, this data processing is based on the legitimate interest in promoting our Services or your consent.

Service Communication. To provide you the Services, deliver related information and send compulsory notices, we process your data to send service communications, such as security alerts and technical notices, to tell you about critical changes or to our Services or legal documents.

Operating Community Features. To maintain and enhance players interaction and the Company’s relationship with players, we process personal data to run community services, including our official Discord server and forums.

Website Analytics. We analyze the performance of our websites (loading speed, browser and device compatibility, technical errors), how visitors move through them (pages visited, interactions, session flows), and assess how our marketing and promotion efforts perform, where feasible in pseudonymized or anonymized form, to improve the user experience. Part of data is collected based on the legitimate interest to enable and optimize website functionality, other – on consent to enable optional features.

Partnership Communications. We may communicate with you on potential collaborations and partnerships, as well as other inquiries and questions sent to us via email, social media or other means of communication. Data processing occurs based on the legitimate interest to facilitate a potential or current partnership, as well as out of necessity to take steps to enter into a contract regarding a potential partnership and further perform a contract.

Enforcement of Terms of Service. Our Terms of Service contain provide certain rules and limitations for the use of the Games and other services, including prohibition of abusive, unlawful, or otherwise harmful content and behavior. To enforce the provisions of the Terms of Services and to pursue the legitimate interest to protect our users and the quality of Services, we may process personal data to ensure compliance, investigate alleged violations and apply respective penalties, handle users’ complaints and appeals.

Claims Management. If the Company is involved in a dispute or controversy, we may process the personal data as necessary to support and defend the Company’s position.

Regulatory Compliance. We may process data to comply with applicable laws, including responding to lawful requests from courts, regulators, or other authorities.

3. HOW WE SHARE DATA

In limited circumstances, we may share your personal data with our partners and service providers.

Gaming and Other Digital Platforms. Where you access our services through third-party gaming platforms, app stores, or account authentication providers (for example, Google Play, App Store, Steam, Meta), we exchange login data with the relevant platform operator. In some cases, gameplay data may be shared with the platforms for user support or other features related to our Services.

Payment Providers. We use authorized payment service providers to process payments for our Services. When you make a payment, your payment information is collected and processed directly by the payment provider or payment platform you choose. We do not receive or store your complete payment card or other payment credentials. For example, we use Xsolla to facilitate payment processing.

Infrastructure and Hosting Providers. We use third-party cloud infrastructure and hosting providers, such as Amazon Web Services (AWS), to host our Games, websites, databases, and other technical systems necessary to provide our Services.

Analytics and Product Improvement Providers. We use analytics and product improvement providers to understand how our games and services are used, measure performance, diagnose technical issues, improve stability and user experience, and evaluate the effectiveness of features.

Advertising and Marketing Partners. We use advertising partners to promote our Games, measure the effectiveness of advertising campaigns, acquire new users, and attribute application installs and conversions.

Business Service Providers. We may share personal data with third-party service providers, such as software developers or administrative service providers, who help us operate and manage our Services.

Governmental Bodies. We may share data with government authorities if required by applicable law.

As a global organization, we may transfer your data to third parties in various countries. We make every effort to ensure an adequate level of personal data protection when sharing data. In particular, to safeguard data transfer, we rely on technical security measures and contractual terms.

4. FOR HOW LONG WE PROCESS YOUR DATA

We retain your personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy. Once those purposes have been fulfilled, we will delete or anonymize your personal data, unless a longer retention period is required or permitted by applicable law.

As a general rule, we retain personal data associated with your account for as long as your account remains active so that we can provide the Services. When determining how long to retain personal data, we consider a range of factors, including the nature and sensitivity of the personal data, the purpose for which the data was collected and whether that purpose has been fulfilled, applicable legal requirements and limitation periods for legal claims.

Even if you request the deletion of your account or personal data, we may retain certain information where necessary to:

- comply with our legal obligations (for example, retaining transaction records to satisfy tax or accounting requirements);

- establish, exercise, or defend legal claims;

- detect, investigate, or prevent fraud, cheating, security incidents, or other violations of our Terms and Conditions, including preventing users from circumventing account restrictions or bans;

- exercise our overriding legitimate interests, where permitted by applicable law.

5. COOKIES AND OTHER TRACKING TECHNOLOGIES

As most digital services, we use cookies and other similar tracking technologies to provide our Services and track their performance, personalize user’s experience, target advertising campaigns and assess their performance, prevent abuse and fraud. Trackers also allow to save your progress, remember your choices, and ensure use Services across devices.

Cookies are small text files placed on your device when you visit the website that identify your browser or device. They serve a range of functions, like helping you move between pages smoothly or storing your preferences. They can also make the ads you see online more relevant to your interests.

Cookies are not the only means of recognizing or tracking visitors. We may use other similar technologies, such as web beacons (also called “tracking pixels”), tiny image files carrying a unique identifier that let us tell when someone access our website or app. These trackers

When you use our Services, we may set the following categories of cookies and other trackers:

Strictly necessary cookies. These are essential for us to provide access to the Services or their particular features. Because the Services cannot be delivered to you without them, they cannot be switched off, though you can block or delete them through your browser or app settings.

Performance and functionality cookies. These improve how the Services performs and functions but are not essential to using it. Without them, certain features may not work.

Analytics cookies. These gather information, often in aggregate form, that helps us understand how the Services are used and how well our marketing campaigns perform.

Advertising cookies. These help make advertising more relevant to you, for example by stopping the same ad from appearing over and over, making sure ads display correctly for advertisers, and, in some cases, choosing ads based on your interests.

Disabling cookies or deleting those that are already stored in your web browser is available in your browser. Here are the links with instructions on how to manage cookies in some popular browsers:

Google Chrome

Mozilla Firefox

Apple Safari

Microsoft Edge

6. YOUR RIGHTS

6.1. The Rights Related to Your Personal Data

As a data subject, you can exercise the following rights:

Right to Be Informed. You have the right to receive clear and transparent information about how we collect, use, disclose, and otherwise process your personal data.

Right of Access. You have the right to request confirmation of whether we process your personal data and, if so, to obtain access to that data, as well as a copy of it. Your access request should not adversely affect the rights and freedoms of others, and we can limit the scope of the personal data provided.

Right to Rectification. You have the right to request that we correct inaccurate or incomplete personal.

Right to Erasure ("Right to Be Forgotten"). In certain circumstances, you have the right to request that we delete your personal data. This right is not absolute and may not apply where we are required or permitted by law to continue processing your personal data.

Right to Data Portability. Where processing is based on your consent or the performance of a contract and is carried out by automated means, you have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another controller where technically feasible.

Right to Restrict Processing. In certain circumstances, you have the right to request that we temporarily restrict the processing of your personal data, for example while we verify the accuracy of the data or assess an objection you have raised.

Right to Withdraw Consent. Where we rely on your consent to process your personal data, you may withdraw your consent at any time.

Right to Object. You have the right to object to our processing of your personal data where such processing is based on our legitimate interests.

Right Not to Be Subject to Automated Decision-Making. Where a decision producing legal effects concerning you, or similarly significantly affecting you, is based solely on automated processing, including profiling, you have the right not to be subject to such a decision.

Right to Lodge a Complaint. If you are located in the United Kingdom, you may complain to us directly where you consider that your data has been mishandled or processed in breach of applicable data protection law.

6.2. For the Residents of the United States

This section applies only to individuals who reside in U.S. and are subject to state consumer privacy laws.

Right to Access (Right to Know). You have the right to request confirmation of whether we process your personal information and to request access to the personal information we have collected about you. Certain information may be exempt from disclosure under applicable law.

Right to Data Portability. You have the right to request that we provide your personal information in a readable format, making it easy for you to transfer your data to another entity.

Right to Correct. If you believe the information we hold about you is inaccurate or outdated, you can request that we correct it.

Right to Delete. You have the right to request that we delete personal information we have collected from or about you, subject to exceptions permitted by applicable law. Please note that deleting your personal information may require us to permanently delete your account.

Right to Opt-Out of Certain Processing. You may limit how we process your personal information unless we have legitimate grounds to keep doing so.

Right to Opt-Out of Sales or Targeted Advertising. We do not engage in the traditional "selling" of your personal information, meaning we do not trade personal details for any monetary compensation. However, like many online services, we may use cookies, pixels, SDKs, and similar technologies that disclose certain information to advertising and analytics partners. Under the laws of certain U.S. states, such disclosures may constitute a "sale" of personal data. Where required by applicable law, you may exercise your right to opt out by adjusting your cookie preferences or other privacy settings available through our Services.

Right to be Free from Discrimination. State privacy laws typically prevent discrimination based on your decision to exercise your privacy rights. This includes practices like offering different quality goods or services, charging different prices, or imposing penalties. We will not discriminate against you in any way if you choose to exercise your privacy rights.

Right to Appeal. If we deny a request to exercise any of these rights, you may, depending on your state, be able to appeal that decision.

Private Right of Action. In some states you may be able to claim civil damages for breaches of privacy law, within certain limits.

Limit Use of Your Sensitive Personal Information. We do not use or disclose sensitive personal information in terms of US state privacy laws for purposes other than those permitted by applicable law.

6.3. How to Exercise Your Rights

To exercise any of your other rights over how we process your personal data, please send your request to: support@spistudios.com.

For cookies, pixels, beacons, tags, scripts, and similar technologies, you will need to clear them in your browser. For more information, see section 5. COOKIES AND OTHER TRACKING TECHNOLOGIES above.

7. UPDATES

We may update this Privacy Policy from time to time by posting a modified version on our website. We encourage you to review this Policy periodically so that you are aware of any changes.

In case of material changes, we will provide a relevant notice in accordance with legal requirements. We reserve the right to suspend services that require the processing of your data if you refuse to acknowledge the new version of the Privacy Policy.

Any updates to this Privacy Policy will take effect the day after the revised version is published.

8. CONTACT US

If you have any questions about how the Company processes personal data or if you disagree with how we handle data processing and protection, please feel free to reach out to us.

Postal address:

SP Interactive L.L.C.-FZ

Meydan Grandstand, 6th floor, Meydan Road,

Nad Al Sheba, Dubai, U.A.E.

Email: support@spistudios.com

You also have the right to submit a complaint to a data protection authority in the country where you are located.