PRIVACY POLICY
Last Updated Date: May 28, 2026
PLEASE READ THIS PRIVACY POLICY CAREFULLY. IT DESCRIBES DETAILS ABOUT HOW WE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION YOU SHARED WITH US. IF YOU ARE UNDER THE MINIMUM AGE TO GIVE CONSENT ACCORDING TO APPLICABLE DATA PROTECTION LAWS, DO NOT PROVIDE ANY PERSONAL INFORMATION WITHOUT YOUR PARENT’S OR GUARDIAN’S PERMISSION.
Thank you for reading our Privacy Policy. For the purpose of applicable data protection laws, the data controller of the Service—including Find Journey: Triple Match — is HALCYON STUDIO PTE. LTD. HALCYON STUDIO PTE. LTD.(“We”, “Us”, “Our”, or “Halcyon”).
This Privacy Policy (“Policy ”) applies to personal information collected through our Games, related websites and other online services. This Policy also summarizes when and how your personal information is collected, used, safeguarded and disclosed in connection with your use of the Games. It also describes your rights and available choices regarding your personal information. The Games and the features, functions, software and services offered through the Games, related websites and other online services collectively constitute the “Service(s)”.
It is our policy to comply with applicable data protection laws.
We reserve the right to change the provisions of this Policy from time to time. If we decide to make material changes to this Policy, we will notify you of these changes via an alert on the home page of our website and notify you by email if we have your email address. In any event, we encourage you to periodically review this page for the latest information on our privacy practices.
What personal information do we collect?
For which purposes do we use your personal information?
With whom do we share your personal information?
What steps do we take to protect your personal information?
How long do we retain your personal information?
What choices do you have regarding the use of your personal information?
Special Section for Certain Jurisdictions
The term “personal information” or “personal data” means information that specifically identifies an individual (such as a name, address, telephone number, mobile number, email address, or other account number), and information about that individual’s location or activities, such as information about your use of the Service, IP addresses or mobile device identifiers, when directly linked to personally identifiable information. Personal information also includes demographic information such as date of birth, gender, geographic area and preferences when such information is linked to other personal information that identifies or may identify you.
Personal information does NOT include “anonymized” information, which is data we collect about the use of the Service or about a group or category of products, services or users, or other data from which individual identities or other personal information has been removed so that the individual concerned cannot be identified directly or indirectly. Such data helps us understand trends and our users’ needs so that we can better consider new features or otherwise tailor our Service. This Policy in no way restricts or limits our collection and use of such information.
We may collect information that you voluntarily provide to us, information that we collect automatically through your use of the services, and certain information we obtain from third party sources. For details of the specific personal information we collect, the processing purposes, and legal basis, please refer to For which purposes do we use your personal information?
|
Information You Voluntarily Provide |
Information We Automatically Collect |
Information We Obtain from Third Party Sources |
|
Registration information :When you are
using the game or services within the game
: |
- Internet Protocol (IP) address- broad
geographic location (e.g. country or city-level
location) based on your IP address |
Registration via Third-Party platforms:
If you log in to our Service using
Third-Party accounts, such as Facebook,
Google, Apple Game Center, we may collect
personal information you authorized the
Third-Party platforms to share with us to
pre-populate our sign up form. Exactly what
information we receive from your Third-Party
platforms will depend on your settings, but
it would typically include your basic public
profile information such as |
We also use analytics tools on our Service to retrieve information from your device, including your preferred settings, which in-game adverts you may have viewed, and the means by which you were referred to our Service. We may also deliver advertisements and provide website analytics tools on not our sites and services, and we collect information about page views on these third party sites as well. We treat this information as personal information if we combine it with or link it to any of the identifying information mentioned above. Otherwise, it is used in the anonymized form only.
You can access certain portions of our Service without providing us with certain personal information. However, you will not be able to utilize certain features that require registration or receive materials unless certain information is provided. The processing of this personal information is necessary for the performance of our Service. Where processing is not necessary for the performance of the Service, your consent to such processing will be requested where required under applicable law.
For users in certain jurisdictions, please refer to the Special Section for Certain Jurisdictions for further information about how we collect and process your personal information and your related rights.
No special categories of information
We do not request or intend to collect any “special categories of information” or “special category data” as defined in applicable data protection laws and regulations,such as any information on health, race, religion, political opinions or philosophical beliefs, sexual preferences or orientation. We also want to kindly remind you to be cautious when sharing this information about yourself (or others) in our forums.
No credit card information
Our Games enable in-app purchases and we collect information about your purchase or transaction records in the Services. However, we do not process payments for in-app purchases nor have access to your credit card information.
Payment transactions for in-app purchases are mostly completed through the app store via your App Store account or Google Play account, or through platforms such as Sony, or through the payment method you choose such as VISA, PayPal, WeChat Pay or Alipay, etc. Any post-purchase processes are controlled by the Apple and Google stores, Sony and other payment providers and are subject to those payment providers’ specific terms of service. Please review the privacy policies and terms of service of your Apple and Google stores, Sony and the payment providers you choose.
Cookies and other tracking technologies
Many browsers enable you to control the use of cookies at the individual browser level. Cookies are small data files that are stored on a user’s hard drive at the request of a Website or the Service to enable the Website or the Service to recognize users who have previously visited them and retain certain information such as customer preferences and history. If we combine cookies with or link them to any personally identifying information, we would treat this information as personal information.
You can also refer to your browser or mobile device’s instructions or help screen to learn about these functions. You may not be able to delete or disable cookies on certain mobile devices and/or certain browsers.
Remember, if a browser or mobile device is set not to accept cookies or if a user rejects a cookie, some portions of the Website or Service may not function properly. For example, you may not be able to sign in and may not be able to access certain Website or Service features or services.
The following cookies are used on the Services:
1. Strictly necessary cookies. These are cookies that are essential to the functioning of our Services. For example, we used cookies to ensure load balancing of the equipment we use to provide you with the Services. This category of cookies cannot be deactivated.
If you set your browser to refuse these cookies, some of the services on the Service will not be provided in an optimal manner, or will not be provided at all.
2. Analytics cookies. These cookies allow us to continue to improve the features of our Website through traffic analysis. They allow us to recognize, count and track the number of visitors to our Services. This helps us improve the functionalities of our Services, for example, by ensuring that users can easily find what they are looking for.
If you do not allow these cookies, we will not be able to continue to analyze the functionality of our Services.
When cookies and other tracking technologies process your personal information, we retain such personal information in accordance with the “How long do we retain your personal information?” section of this Policy, and in any event for no longer than 1 year.
You can find more information about the cookies we used in the table below:
|
Applicable Service |
Name of the cookie |
Host of the cookie |
Type of cookie |
Category |
Description/purpose |
Validity duration |
Link to the third party privacy policy for third party cookies |
|
Websites of the game |
google analytics |
third party |
third party |
analytics |
To record page view and unique visitor (UV, PV) |
1 year |
|
|
Baidu analytics |
third party |
third party |
analytics |
To record page view and unique visitor(UV, PV) |
1 year |
Data collected to prevent cheating and unauthorized software
When you run our Game software or receive our Services, this may involve software functions designed to detect cheating or unauthorized and malicious programs. In this context, we may access, collect, monitor and/or remotely store screenshots of game play, information relating to hardware capacity, modifications related to our Game software, signatures, profiles or names of known or suspected unauthorized or malicious third party programs, files or processes that enable or facilitate cheating, unfair advantage or hacking of the Games or Services. If circumstances suggesting unauthorized or malicious programs are detected, the Game software may also communicates to us the user’s account and User ID, as well as information about the unauthorized or malicious program or its use.
We see this processing as necessary for the purposes of the legitimate interests in ensuring that fraudulent activity is not carried out in or using our Services. Pursued by us, where legitimate interest is not sufficient for the collection, your consent to such processing will be requested where required under applicable laws or on the Furthermore, in jurisdictions where consent is required, we will ensure that such consent is obtained prior to engaging in the aforementioned monitoring and data collection activities.
We use your personal information to provide products and services you ask for, to communicate with you, to improve our services, and for other purposes including those set out in the chart below.
|
Personal Information |
Purpose |
Legal basis relied on according to GDPR （ only users located in the European Economic Area ("EEA") and UK） |
|
Mobile Games |
||
|
Registration information: |
To create your account for the Mobile Games per your request and phone number may be also used for pre-registration |
Necessary for the performance of the contract
for the provision of the mobile game App between
us, in line with art. 6.1(b) of the GDPR |
|
The chat log and message you communicated or posted in our Service, regardless whether it is in the form of text, voice, image or video |
To deliver the Mobile Games and/or the in-game service to you |
Necessary for the performance of our Service,
specifically, the chat function within the game,
in line with art. 6.1(b) of the GDPR |
|
Your purchase or transaction record in the
Service through Apple Store, Google Play,
PayPal, WeChat Payment, Alipay and other payment
method (subject to in-Game availability): |
To keep the record of your transaction history and to deliver the product you purchased to you |
Necessary for the performance of our Service, specifically, the in-game purchase, in line with art. 6.1(b) of the GDPR |
|
Any information you submit to our support team by email or other means for any reason, for example, asking for customer support |
To provide technical support, customer service and ensure the continued smooth operation of our Service |
Necessary for the performance of our customer service, in line with art. 6.1(b) of the GDPR |
|
Progress in the game:- log data (time and period)- in-game items and behaviors- achievements you have completed in the game |
To keep the record of your account, to collect and anonymize usage data and to improve the functionality of our Games and Service (including anti-cheat measures) |
Our legitimate interests in reviewing the performance of, and preventing the misuse of, our Service and improving its functionality, in line with art. 6.1(f) of the GDPR |
|
- Internet Protocol (IP) address |
To improve our games and services and to make our application compatible with your device |
Our legitimate interests in performing and improving our Service, in line with art. 6.1(f) of the GDPR |
|
Screenshots of game play, information relating to hardware capacity, modifications related to our Game software, signatures, profiles or names of known unauthorized or malicious third party programs, files or processes that enable or facilitate cheating, unfair advantage or hacking of the Games or Service |
To prevent or investigate actual or suspected fraud, hacking, infringement, or other misconduct in any of our products and services |
Our legitimate interests in detecting and preventing fraud, other crimes and the misuse of our Service, in line with art. 6.1(f) of the GDPR |
|
Information from advertising attribution
partners. E.g. if you click on an advertisement
to direct you to one of our services or games
(such as an advert of one of our Games in other
publisher’s game), we may receive the
information. |
To know which ad network and advertising campaign your installation was originated from and to pay that advertiser |
Our legitimate interests in promoting our Service, in line with art. 6.1(f) of the GDPR |
|
Information from analytics partners. We may
integrate analytics providers in some of our
Games. We then receive reports that help us
optimise our in-game features and events to each
user of our Games. |
optimise our in-game features and events to each user of our Games. |
Our legitimate interests in promoting our Service, in line with art. 6.1(f) of the GDPR |
|
Information from mobile measurement
partners, if you click on a link or interact
with content that advertises the Game, we
store this information and that
advertisement and certain marketing
analytics data with your profile. |
To know which ad network and advertising campaign your installation was originated from and to pay that advertiser |
Our legitimate interests in promoting our Service, in line with art. 6.1(f) of the GDPR |
|
Information from analytics partners. We may
integrate analytics providers in some of our
Games. We then receive reports that help us
optimise our in-game features and events to each
user of our Games. |
optimise our in-game features and events to each user of our Games. |
Our legitimate interests in promoting our Service, in line with art. 6.1(f) of the GDPR |
|
Other personal information you provide in connection with your voluntary participation in surveys, sweepstakes, contests, promotional offers, and other activities. |
To request feedback, perform research and analysis and to enable us to operate, develop, customize and improve the Service and our publications, products and services |
Our legitimate interests in performing research and improving our Service, in line with art. 6.1(f) of the GDPR |
|
Websites |
||
|
- Internet Protocol (IP) address- device information, including the device type, operating system and version |
To improve our games and services and to make our application compatible with your device |
Our legitimate interests in performing and improving our Service pursued by us, in line with art. 6.1(f) of the GDPR |
To contact you about our or a third party’s services, products, activities, promotions, special events or offers and for other marketing, informational, product development and promotional purposes, we may collect and (provided we have obtained your consent where required by law in the case of electronic marketing to you, such as email) use the information you provided (such as your name, phone number, email address) in our Services or which are lawfully shared by third parties (if applicable), and your physical address for sending promotional materials. You can ask us to stop sending you marketing messages at any time by following the opt-out links in marketing messages we send to you or contacting us at: support@halcyonhappy.com.
Where processing is not necessary for the performance of the Service or we cannot rely on legitimate interests in a particular case (because for example your privacy rights and freedoms in that case outweigh the legitimate interests), your consent to such processing will be requested as appropriate under applicable law.
Compliance with our legal obligations
We may use your information when we are required to do so by law, or pursuant to valid law enforcement requests.
For purposes for which you give us consent
We may also collect and use personal information for specified purposes when you give us your consent to do so.
We will share your personal information with third parties only in the ways that are described in this privacy statement or as otherwise required by law. We do not sell or trade any personal information about our visitors and users to any third parties.
Please note that nothing herein restricts the sharing of anonymized information, which may be shared with third parties without your consent.
Our service providers
We may share personal information with vendors, consultants and other service providers (“Service Providers”) such as:
We provide such Service Providers with access to the information they may need to perform our services under reasonable confidentiality terms. In some cases, the Service Provider may be directly collecting the information from you on our behalf. Our Service Providers are under an obligation to use personal information they obtain from us exclusively to provide the services for us. However, we are not responsible for any additional information you provide directly to these Service Providers and we encourage you to become familiar with their practices before disclosing any personal information directly to such Service Providers.
Our subsidiaries
We may share information with companies in the same group of companies, which includes our subsidiaries (i.e., any organization we own or control) and/ or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Policy.
We share such information in our legitimate interests, where applicable to organize our business as appropriate. Where we cannot rely on legitimate interests for the sharing in a particular case (e.g., because for example your privacy rights and freedoms in that case outweigh the legitimate interests), your consent to such processing will be requested as appropriate under the applicable law.
Sharing when you give us consent
From time to time, we may also share personal information with third parties when you give us your consent to do so.
Sharing in response to legal obligations
We reserve the right to disclose your information (including personally identifiable information) in response to the law, legal processes, litigation, and/or requests from public and governmental authorities within or outside your country of residence. We access, disclose or preserve personal information, including the content of your communications, in good faith that we are lawfully authorized by public authorities or required to do so, including to meet national security or law enforcement requirements, or where reasonably necessary or appropriate to comply with the law or with legal processes or authorities, respond to any claims, or to protect the rights, property or safety of us, our users, our employees or the public, including but not limited to protect us or our users from fraudulent, abusive, inappropriate or unlawful use of our Services.
Sharing due to merger, acquisition and similar situations of the transfer of company assets
Information we collect, including personal information, may also be disclosed or transferred as part of, or during negotiations concerning, any merger, sale, divestiture, or transfer of all or a portion of the company assets, financing or acquisition or in any other situation where personal information may be transferred as one of the business assets of the Company, in our legitimate interests to ensure continuity of our business. You will be notified via email and/or a notice of any change in ownership, uses of your personal information, and choices you may have regarding your personal information.
International transfer
Your personal information will be transferred and shared globally, among HALCYON STUDIO PTE. LTD. and its affiliated companies as necessary. Your information will be accessible from and processed in servers located globally. In particular, your account information and in-game data will be stored in servers located in the United States of America to ensure the proper operation of our services and your experience. We also have support, technical and other teams who may support the service, including from China.
As we are a global company, your personal information may be transferred to and processed in countries other than the country in which you reside. Although these countries may have data protection laws that are different to the laws of the country in which you reside, we ensure appropriate safeguards in place so that your personal information will remain protected in accordance with this Policy. The information relating to your account and use of our Games may be transferred internationally, among our Group.
You acknowledge and understand that the laws regarding personal information in the country or region to which the data is transferred may be less stringent than the laws of your country and may not offer the same protections or rights as the laws of your country. If you object to your personal information being transferred or used as described in this Policy, please do not use the Services.
Links to third party
Our Website or Services may contain links to other websites or be accessible from third-party platforms. We do not control such sites, platforms or their activities. Any personal information you provide on linked pages is provided directly to that third party and is subject to that third party’s privacy policy. We are not responsible for the content or privacy and security practices and policies of websites to which we link or platforms from which the Services are accessible. Links from our Website or Service to third parties or to other sites are provided for your convenience only. We encourage you to learn about their privacy and security practices and policies before providing them with personal information.
If you are a consumer that downloads and uses our application implemented with any advertising SDK (software development kits) or otherwise interacts with the Services, the Advertising Company may be an independent controller of the personal data processed in order to provide the Services that it will individually determine the purposes and means of processing such data. Such data refers to any information or data that advertising company collects through the SDK implemented in our application, in connection with any advertisement or otherwise in connection with the Services, e.g. user device information, user identifiers, information about advertisements served, viewed or clicked or other user interactions with advertisements or the Service, information about user applications, network information and header information. Please be aware that in no event will the advertising party and us process personal data as joint controllers.
Push notifications and local notifications
We send push notifications to your mobile device to provide game updates and other service relevant messages. You can manage push notifications from your mobile device’s settings page for the relevant game and/or from the settings page within the relevant mobile game. We also send local notifications to your mobile device to provide game updates and other relevant information. To manage local notifications, you should consult your mobile device’s settings page for the relevant game and/or from the settings page within the relevant mobile game.
Communication monitoring
When you communicate with other players within a game or utilize any interactive features available on the Services, such as instant text, voice or image messaging, forums or chat rooms, such communications and postings are transmitted through our servers, and we monitor all such communications and postings (e.g. via profanity filters), including those that are designated as “private,” to the degree that laws and regulations enable us to do this, for purposes of protecting the rights and safety of us and our users, including identifying and removing content that violates our policies. Therefore, as the abovementioned performance monitoring might involve access to these communications and postings, you should not use these communication channels for private or confidential messages.
We use physical, technical, and administrative measures to safeguard information in our possession against loss, theft and unauthorized use, disclosure, or modification. Please note, however, that no data transmission or storage can be guaranteed to be 100% secure. As a result, although we strive to protect the information we maintain, we cannot ensure or warrant the security of any information that you transmit to us.
You should note that our Service Providers may be responsible for processing, handling or storing some of the personal information that we receive. They are not authorized to market to you independently. These Service Providers are contractually required to safeguard and secure the personal information they received from us. Although we strive to protect your personal information, you should be aware, however, that information sent over the Internet is not necessarily secure and may be intercepted or accessed by third parties. Therefore, we cannot guarantee the security of such information, and we are not responsible or liable for any such interception or unauthorized access.
We will only retain your personal information for as long as it is reasonably necessary for the purpose for which that information was collected and to the extent permitted by applicable laws (including for the purpose of satisfying any legal, regulatory, tax, accounting or reporting requirements).
For example:
l your registration information and any game data generated from your account's activity will be held for as long as your account remains active, or until the Game or platform expires.
l your text chat data (e.g., public text messages) is stored for 30 days; and
l your voice message data, voice chat data and profanity filtering information is stored for 90 days (unless you request to delete your account or data, in which case such data will be deleted within 30 days).
We retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you. When we no longer need to use your information, we will remove it from our systems and records and/or take steps to anonymise it promptly so that you can no longer be identified from it.
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.
If you would like to delete your data, please refer to the heading of “What choices do you have regarding the use of your personal information?” below.
As the subject of the personal information, you are entitled to have the rights provided by the privacy laws in your jurisdiction. Your rights may include part or all of those described underneath. You can exercise your rights entitled by the privacy laws in your jurisdiction at any time by sending us relevant requests to support@halcyonhappy.com. Your rights may include:
Right to access your data
You have the right to access personal information we hold about you, how we use it, and who we share it with.
Right to correct your data
You have the right to correct any personal information held about you that is inaccurate. For example, you can contact us if your email address has been changed so we may replace your old email address.
Right to have your data deleted
You can delete your account (i.e. the account on our Service, excluding any account on the third party platforms, such as Facebook), or remove certain personal information that we have stored about you. However, please note that we may need to retain personal information if there are valid grounds under data protection laws for us to do so (e.g., for the defense of legal claims or freedom of expression). If that is the case, we will inform you of such valid grounds.
Right to restrict processing and withdraw your consent
You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances (such as where you believe such data to be inaccurate, our processing is unlawful or that we no longer need to process such data for a particular purpose). In cases where we have requested your consent to process personal information, you may withdraw your consent at any time by sending a communication to us specifying which consent you are withdrawing or by using the consent withdrawal functionalities available in our Services. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds other than your consent, for example, when the processing is necessary to fulfil the obligations of a contract, processing is necessary to protect the vital interest of you or another natural person, or other legitimate reasons under data protection laws.
Right to take your data with you (“right to portability”)
You have the right to receive a copy of certain personal information we process about you in a structured, electronic format. For example, you can contact us to receive your data if you want to upload it to another service, where this constitutes (a) personal information which you have provided to us, and (b) that we are processing that information on the basis of your consent or to perform a contract with you and (c) that is processed by automated means. Additionally, you have the right to require us to transmit such personal data directly to another controller, where this is technically feasible. However, please note that we may not be able to provide you with personal information if this would interfere with another individual’s rights (e.g. where this would reveal information about another person or our trade secrets or intellectual property) or there are other limitations recognized under data protection laws.
Right to object to the way your data is handled
You have the right to object to our processing of personal information about you. In particular, you have the right to object to being profiled for the purposes of direct marketing (for example, where we collect information about you to decide what marketing information to send to you, based on your preferences or personal characteristics).
You also have the right to object to marketing at any time by opting-out using the unsubscribe function displayed in any such communications from us.
Right to lodge complaints to the supervisory authority
To help us verify that you are the subject of the personal information and to exercise your rights outlined above, we may require you to provide sufficient proof of identification. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We will respond to all access requests within the time period stipulated by the applicable data protection laws. This period may be extended where necessary as permitted by laws, taking into account the complexity and number of the requests we are handling at the time.
You have the right to lodge complaints about the data processing activities carried out by us before the competent data protection authorities.
If you are in the EEA or UK and think we have infringed data protection laws, you can complain to or file a claim with the data protection supervisory authority in the EEA country in which you live or work or with the UK Information Commissioner’s Office, as applicable to you.
If you are under the minimum age to give consent according to applicable data protection laws, we must receive valid parental consent, otherwise you are not permitted to access the Service.
The Service is not directed to children under such minimum age. If we discover that we have inadvertently collected information from children under such minimum age, without first obtaining valid parent/guardian consent, we will delete such children’s information from our systems in accordance with applicable law (though we will retain the email address to ensure that the user does not re-sign up to the Service). If you become aware that personal information about a person under such minimum age has been provided to us without valid parent/guardian consent, please immediately contact us at: support@halcyonhappy.com.
Where the settings or notices in our Service provided in your jurisdiction does not specify a minimum age, children under the age of 18 are not eligible to use our Service.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily or any questions, comments on this Policy or wish to exercise your rights described in this Policy, please contact us at: support@halcyonhappy.com.
We reserve the right to change the provisions of this Policy from time to time to reflect changes to the scope of the Services or for other reasons. Therefore, it is important to check the effective date of this Policy posted here each time you use the Services. If we decide to make material changes to this Policy, we will notify you of these changes via an alert on the home page of our website and notify you by email if we have your email address.
If you are located in the EEA or UK, the European Union
General Data Protection Regulation (“EU GDPR”) or UK Data Protection Regulation (the “UK GDPR” and, together with the EU GDPR, the
“GDPR”) apply to the collection and
processing of your personal data by us.
For the purpose of the GDPR, the data controller is HALCYON STUDIO PTE. LTD.
This means that HALCYON STUDIO PTE. LTD.
is responsible for determining how and why your personal
data is processed.
As outlined in the “Data collected to prevent cheating and
unauthorized software” section of the Policy, we may also
process your personal information to detect cheating or
unauthorized and malicious programs. We see this processing
as necessary for the performance of our Services, pursuant
to art. 6.1(b) of the GDPR and for our legitimate interests
to ensure the functionality of, and prevent the misuse of,
our Service, in line with art. 6.1(f) of the GDPR.
Where processing is not necessary for the performance of the
Service or where we cannot rely on legitimate interests in a
particular case (e.g. because your privacy rights and
freedoms in that case outweigh the legitimate interests),
your consent to such processing will be requested as
appropriate under the applicable law.
For complementary information regarding the purposes for
which we use your personal information, please see the “For
which purposes do we use your personal information?” section
of this Policy.
Software Development Kits. Please note
that we have implemented software development kits
(“SDK”) in our Service.
International transfers. We are a
multinational group with companies registered outside the
EEA and UK. Our servers and main business operations are
located globally and some of our businesses are primarily in
China or the United States of America, as described in the
“International transfer” section of this Policy. By using
our Service and providing us with information, you
acknowledge and understand the transferring, storing and
processing of your information on computers located in China
and the United States of America in the manner described in
this Policy. If you object to your personal information
being transferred or used as described in this Policy,
please do not use this Service.
For any transfers of data outside the EEA or the UK, the
data transfer will be under the European Commission’s
standard contractual clauses for the transfer of personal
data to third countries (specifically, module one
(controller to controller transfer) and module two
(controller to processor transfer), as relevant), or the UK
Information Commissioner’s international data transfer
addendum to the EU standard contractual clauses, as
relevant, unless the data transfer is to a country that has
been determined by the European Commission or the relevant
UK authorities, as applicable, to provide an adequate level
of protection for individuals’ rights and freedoms for their
personal data. Please contact us at support@halcyonhappy.com should you wish to examine a copy of the EU standard
contractual clauses or UK international data transfer
addendum.
This section provides additional detail for residents of
California and certain other U.S. states on how we collect,
use and disclose Personal Information, and the rights such
residents may have with respect to that Personal
Information. For the purposes of this section, “Personal
Information” has the meaning given in the California
Consumer Privacy Act of 2018 (the “CCPA”),
as well the meaning given to “personal data” under other
U.S. state privacy laws. Unless otherwise specified,
Personal Information includes “sensitive personal
information” as defined by the CCPA and “sensitive data” as
defined by other U.S. state privacy laws.
While we have tried to fully describe our data practices
elsewhere in this Privacy Policy, this section supplements
the description of our information collection and sharing
practices elsewhere in this Policy, as required under
applicable U.S. state laws.
We collect, use and disclose, and have during the past 12 months collected, used and disclosed, the following categories of Personal Information. In the past 12 months, we have disclosed such categories to our Service Providers and Subsidiaries, as described further in the “With whom do we use your personal information?” section above.
The purposes for which we use these categories of Personal Information, listed in the below table, are described further in the “For which purposes do we use your personal information ” section of our Privacy Policy. Our relevant data retention practices are addressed in the “How long do we retain your personal information ?” section of our Privacy Policy.
Note that the CCPA defines “sell,” “share,” and “personal
information” very broadly, and some of our data disclosures
described in this Privacy Policy may be considered a “sale”
or “sharing” under those definitions. In particular, we let
mobile measurement providers collect identifiers (such as IP
addresses), activity data (browsing, clicks, app usage), and
device data through our sites and apps when you use our
online services.
In the preceding twelve months, we may have disclosed the
following categories of personal information to the
following categories of persons or entities:
|
|
Categories of Persons or Entities to Whom the Personal Information Was Disclosed |
|
Identifiers |
• Third-party sign-in services
• Advertising service providers |
|
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) |
• Other affiliate entities of the Company |
|
Protected classification characteristics under California or federal law |
• Other affiliate entities of the Company |
|
IP address |
• Mobile measurement providers |
|
Advertising identifiers |
• Mobile measurement providers |
|
Date of birth and Country |
• Age verification and parental consent service
providers |
|
Payment related data |
• Payment service providers |
|
The chat log and message |
• Content moderation service providers |
|
In-game informations to be displayed in Discord:
|
• Discord |
|
Any information you submit to our support team |
• Customer service providers |
We do not use or disclose Sensitive Personal Information (as defined by the CCPA) for purposes other than those expressly permitted under the CCPA. If you find that your sensitive personal information is being used for any purposes other than to provide the services or goods you have requested or as is otherwise permitted by law, you have the right to limit such use by send us an email at support@halcyonhappy.com. Additionally, we will not attempt to re-identify de-identified information that we derive from Personal Information, except for the purpose of determining whether our de-identification process satisfies legal requirements.
Depending on where you live, you may have the rights listed below in relation to Personal Information that we collect about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
We will not unlawfully discriminate against you for
exercising your rights. Please submit your request by
sending an email to our Data Protection Officer via
support@halcyonhappy.com. Once we receive your request, we may verify it by
requesting information sufficient to confirm your identity,
including by asking you to verify information about your use
of the Service. If you would like to use an authorized agent
to exercise your rights, we may request evidence that you
have provided such agent with the power of attorney or that
the agent otherwise has valid written authority to submit
requests to exercise rights on your behalf. Not all kinds of
requests can be made by authorized agents in all states.
Global Privacy Control. We recognize
the Global Privacy Control opt-out preference as a valid
request for residents of certain states to opt-out of the
sale and sharing of the personal information processed
through the browser you are using. This controls whether
your browser sets third-party cookies on our websites that
are used for targeted advertising. This is only based on
browser settings and not your device settings. Please see
the list of browsers that support GPC and instructions
on how to enable it.
Appeal. If we refuse to take action on your
request, you may be entitled to appeal this refusal within a
reasonable period after you have received notice of the
refusal. You may file an appeal by contacting us
at support@halcyonhappy.com.
Minimum Age. In the United States, the
minimum age for users is 13. With the exception of specific
states, such as Texas, where the minimum age shall be 18. We
therefore do not knowingly collect any personal information
online from children under the minimum age in the United
States without parental consent, unless permitted by law. If
we learn that a child under the minimum age has provided us
with personal information without parental consent, we will
delete it in accordance with applicable law.
Do-Not-Track Signals. Some web browsers may
transmit “do not track” signals to the websites and other
online services with which the browser communicates. Unless
otherwise specified, we currently do not take action in
response to these signals and we do not process your
Personal Information in a manner that would require us to
respond to similar opt-out preference signals.
"Shine the Light" Right.
In accordance with the provisions of California Civil Code
section 1798.83, also known as the "Shine the
Light" law, California residents who have provided
personal information to us may request information regarding
the disclosure of such information to third parties for the
third parties' direct marketing purposes. To make such a
request, please contact us via email at support@halcyonhappy.com. We are required to respond to one request per California
resident each year and may not be required to respond to
requests made by means other than through the designated
email address. Please note that under the law, we do not
disclose personal information to third parties for their
direct marketing purposes.
Right to Delete Publicly Posted Content. In
accordance with California Business and Professions Code
section 22581, California residents under the age of 18 who
are registered users of our Games and Service have the right
to request the removal of any content or information that
you have publicly posted. To proceed, please send us an
email at support@halcyonhappy.com, providing us with a detailed description of the specific
content or information you wish to have removed. Please note
that your request does not guarantee the complete or
comprehensive removal of content or information posted
online, and that the law may not permit or require removal
in certain circumstances. Should you wish to appoint an
authorised agent to submit an access or deletion request on
your behalf, you will need to provide written authorisation
signed by you. We may still require you to verify your
identity and confirm that you have granted the authorised
agent permission to submit the request.
Should you be residing in Canada and have the intention of acquiring written details concerning our policies and procedures regarding service providers operating outside of Canada, you are welcome to get in touch with us through support@halcyonhappy.com. In cases where we engage service providers who may potentially gain access to your personal data, we mandate that they uphold privacy and security benchmarks equivalent to our own. By means of contracts and additional safeguards with these service providers, we ensure the confidentiality and security of your personal information remains intact and that it is not exploited for any purpose beyond what is stipulated in this Privacy Policy.
Minimum Age. In Malaysia, the minimum age for users is 18. We therefore do not knowingly offer our services or collect any personal information from children under the age of 18 in Malaysia without parental consent, unless permitted by law. If we discover that we have inadvertently collected information from children under such minimum age, we will delete the children’s information from our systems in accordance with applicable law. If you become aware that personal information about a person under such minimum age has been provided to us, please immediately contact us at the contact details below.
Your Rights. You have the right to request access to and correction of information about you held by us. We will try our best to respond within 21 days as soon as we receive your request. However, the process may take longer if we face difficulties due to incomplete information provided by you.
Please note that you must submit your request to access or correct your personal information in writing, and your rights are subject to any statutory exemptions and/or exceptions applicable under the Malaysian Personal Data Protection Act 2010 (“MY PDPA”) that allow us to collect, use or disclose your personal information.
Contact Details. If you have any queries, our Customer Service can be contacted at: support@halcyonhappy.com.