Privacy Policy

Introduction
Your privacy and trust are important to Zenjoy.

This Privacy Policy (“Policy”) provides important information about how Zenjoy and its worldwide affiliated companies and subsidiaries (collectively, “Zenjoy”, “we”, or “us”) collect, store, use, process and /or handle personal information. And this Policy applies to any Zenjoy website, application, software, or service that links to it (collectively, our “Services”). Meanwhile, we may also make different privacy policy with particular privacy practice for some Services parallelly.

Please read this Policy carefully and contact us if you have any questions about our privacy practices or your personal information choices. By ticking the “agree” box after your read this Policy, you expressly consent to the information handling practices described in this Policy.

It is important that you check back regularly for updates to this Policy. If we make changes we consider to be important, we will let you know by placing a notice on the relevant Services and/or contact you using other methods such as email.

Controller
Zenjoy is a multinational company group with different legal entities worldwide. This privacy policy is issued on behalf of the Zenjoy Group so when we mention “Zenjoy”, “we”, or “us” in this Policy, we are referring to the relevant company in the Zenjoy Group responsible for processing your data. Zenjoy Limited, a limited liability company with residence at Room 1403, 14/F., Officeplus @Sheung Wan, No. 93-103 Wing Lok Street, Hong Kong, is the controller and responsible for the Services.


1. The information we collect

User-provided Information: You may provide to Zenjoy what is generally called “Personal Information”, when you register for a Zenjoy Services, or upload, purchase, view or download certain content or products from the Services, enter contests or sweepstakes, or otherwise use the features and functionality of the Services. “Personal information” means any information relating to an identified or identifiable natural person; an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.

Illustratively, we may collect different kinds of Personal Information about you as follows:

• Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
• Contact Data includes billing address, delivery address, email address and telephone numbers.
• Financial Data includes bank account and payment card details.
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Automatically Collected Information: When you access the Services or open one of our HTML emails, we may automatically record certain information from your system by using cookies and other types of tracking technologies. This “automatically collected” information may include Internet Protocol address (" IP Address "), a unique user ID, device type, device identifiers, browser types and language, referring and exit pages, platform type, version of software installed, system type, the content and pages that you access on the Services, the number of clicks, the amount of time spent on pages, the dates and times that you visit the Services, and other similar information. Depending on the law of your country of residence, your IP address may legally be considered as personal information.

Cookies Information: Cookies are pieces of text that may be provided to your computer through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit. We use cookies to enable our servers to recognize your web browser and tell us how and when you visit the site and otherwise use the Services through the Internet.

Our cookies do not, by themselves, contain Personal Information, and we do not combine the general information collected through cookies with other Personal Information to tell us who you are. As noted, however, we do use cookies to identify that your web browser has accessed aspects of the Services and may associate that information with your Account if you have one.

Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. We strongly recommend that you leave cookies active, because they enable you to take advantage the most attractive features of the Services.

This Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer.

Information from Other Sources: We may obtain information, including personal information, from third parties and sources other than the Services, such as advertisers or social media networks for which you have approved our access to information (e.g., information from your Facebook account provided by the Facebook APIs). When you access the Services through social media networks or when you connect a Services to social media networks, you are authorizing to collect, store and use such information and content in accordance with this Policy. We may also obtain information from third parties such as social entertainment platforms regarding your use of such Services, including about your use of the content you choose to broadcast through the Services. If we combine or associate information from other sources with personal information that we collect through the Services, we will treat the combined information as personal information in accordance with this Policy.

We collect, use, disclose, transfer, and store personal information when needed to provide our Services and for our operational and business purposes as described in this Policy. We want to be clear about our privacy practices so that you can make informed choices about the use of your information, and we encourage you to contact us at any time with questions or concerns.

2. How we use your information

We will use your information only for these Service- and business-related purposes.

• Account setup and administration: We use personal information such as your name, email address, phone number, and information about your device to set up and administer your account, provide technical and customer support and training, verify your identity, and send important account, subscription, and Service information.
• Personalization: We use personal information to deliver and suggest tailored content such as news, research, reports, and business information and to personalize your experience with our Services. Some of our Services will ask you to share your precise geolocation so we can customize your experience and increase the accuracy of the Service. If you agree to share your precise geolocation with us, you will be able to turn it off at any time by going to the privacy settings on your mobile device or online.
• Marketing and events: We use personal information to deliver marketing and event communications to you across various platforms, such as email, telephone, text messaging, direct mail, and online. If we send you a marketing email, it will include instructions on how to opt out of receiving these emails in the future. We also maintain email preference centers for you to manage your information and marketing preferences. Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts and subscriptions.
• Communication: We use your information to allow you to comment on content, and participate in any events, promotions, activities, focus groups, research studies, contests, promotions, polls, surveys or any productions and to communicate with you regarding your attendance thereto.
• Payments: Sometime, we may use your information to process any refunds, rebates and or charges pursuant to the applicable terms of use.
• Research and development: We use personal information for internal research and development purposes and to improve and test the features and functions of our Services.
• Chat rooms, messaging, and community and event forums: A number of our Services provide features including chat rooms, messaging services, and community and event forums for collaboration, peer connection, games, and information exchange purposes. Depending on the Service, the personal information you choose to post, share, upload, or make available is public and visible to others who use those Services. You should never post or share any information that is confidential or about others unless you have permission to do so. We may use information you provide in community and event profiles and forums to personalize your experience and to make content and peer connection recommendations. These Services may have their own terms of use and, where appropriate, their own privacy policy.
• Legal obligations: We may be required to use and retain personal information for legal and compliance reasons, such as the prevention, detection, or investigation of a crime; loss prevention; or fraud. We may also use personal information to meet our internal and external audit requirements, information security purposes, and as we otherwise believe to be necessary or appropriate: (a) under applicable law, which may include laws outside your country of residence; (b) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include such authorities outside your country of residence; (c) to enforce our terms and conditions; and (d) to protect our rights, privacy, safety, or property, or those of other persons.

We may use Automatically Collected information and Cookies information to maintain and improve our Services, including to do the following things: (a) automatically update the applications on your system; (b) remember your information so that you will not have to re-enter it during your visit or the next time you access our Services; (c) provide customized third-party advertisements, content and information, unless it will include instructions on how to opt out of receiving these advertisements, content and information in the future; (d) monitor the effectiveness of third-party marketing campaigns; (e) monitor aggregate site usage metrics such as total number of visitors and pages accessed; and (f) track your entries, submissions, and status in any promotions or other activities.

3. When we share your information

We do not share your personal information with other organizations for their own marketing or promotional uses without your prior express consent. Please be aware, however, that any personal information that you voluntarily choose to display on any publicly available portion of our Services, such as when you publish content, comments or profile information, becomes publicly available and may be collected and used by others.

If you connect to a third-party services (such as Facebook or Twitter) through an icon or link on our Services or otherwise link your Zenjoy account with a third party services, we may share the contents of your post and associated information (such as your user name, the fact that your connection originated from the Services and other relevant usage and diagnostic information) with such third party. With your consent, which you may withdraw at any time with effect for the future, we may also send information about the content you watch and your activities on the Services to such third parties. Once such information is shared, the use of your information will be subject to that third-party service’s privacy policy and this Policy will not apply. These third-party services may process personal data such as the web pages you visited and IP addresses, and may set cookies to enable features to function properly. We are not responsible for the security or privacy of any personal data collected by these third parties. You should review the privacy policies applicable to the third-party services you connect to, use, or access.

We may disclose Automatically Collected information and other aggregates non-personal information with interested third parties to assist such parties in understanding the usage and demographic patterns for certain programs, content, Services, advertisements, promotions, or other functionality of our Services.

Zenjoy may make both personal and non-personal information available to subsidiaries and affiliated companies that are under common ownership or controlled within the Zenjoy group, but Zenjoy Limited as the controller will guarantee the subsidiaries and affiliates to assume the obligations as same as Zenjoy assumes as information receiver in this Policy.

We may disclose both personal and non-personal information to Services providers working on our behalf to: provide web site hosting, maintenance, and security Services; fulfil orders; conduct data analysis and create reports; offer certain functionality; and assist Zenjoy in improving the Services and creating new Services features. We require that these parties process such information in compliance with this Policy, we authorize them to use the information only for the purposes for which it is provided to them, and we require these parties to use reasonable confidentiality measures.

We may disclose your information if we believe in good faith that such disclosure is necessary to comply with the applicable laws around the world (for example, in the country of your residence); or respond to a court order, judicial or other government subpoena, or warrant in the manner legally required by the requesting entity.

We also reserve the right to disclose your information that we believe, in good faith and after making reasonable enquiries, is appropriate or necessary to take precautions against liability to Zenjoy; protect Zenjoy from fraudulent, abusive, or unlawful uses; to investigate and defend ourselves against third-party claims or allegations to protect the security or integrity of our Services; or to protect the rights, property, or personal safety of us, our users, or others. We will notify you of these disclosures if we reasonably think we can do so legally and without harming the purpose of the disclosure.

You may, of course, decline to share your personal information with us, in which case we will not be able to provide to you some of the features and functionality found on our Services. If you would like to access, review, correct, update, suppress, or otherwise limit our use of your personal information you have previously provided directly to us, you may contact us as outlined in the last section of this Policy titled "How to contact us "; or using the mechanism provided below. In your request, please include your email address, name, address, and telephone number and specify clearly what information you would like to access, change, update, or suppress. We will try to comply with your request as soon as reasonably practicable and any information you give us will be protected by this Policy.

4. Where we store and process personal information

Zenjoy is a multinational corporation, and your personal information may be stored and processed outside of your home country. We take steps to ensure that the information we collect is processed according to this Policy and the requirements of applicable law wherever the data is located.

Zenjoy has networks, databases, servers, systems, support, and help desks located throughout our offices around the world. We collaborate with third parties such as cloud hosting services, suppliers, and technology support located around the world to serve the needs of our business, workforce, and customers. We take appropriate steps to ensure that personal information is processed, secured, and transferred according to applicable law. In some cases, we may need to disclose or transfer your personal information within Zenjoy or to third parties in areas outside of your home country. The areas in which these recipients are located will vary from time to time, but may include the United States, Europe, Canada, Asia, Australia, India, and other countries where Zenjoy has a presence or uses contractors. We ensure a similar degree of protection in this Policy is afforded when disclose or transfer your personal information in areas outside of your home country.

5. Our commitment to data protection

Zenjoy uses commercially reasonable physical, managerial, and technical measures designed to protect the integrity and security of your personal information (for example, making relevant policies and procedures to deal with accident loss and unauthorized access, training our employees and contractors to control risk, limiting access to your personal data to those employees, agents, contractors and other third parties who have a business need to know). However, no security precautions or systems can be completely secure. We cannot therefore ensure or warrant the security of any information you transmit to us, and you do so at your own risk. We cannot guarantee that such information may not be accidentally accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

6. How long we keep personal information

We retain personal information for as long as we reasonably require it for legal or business purposes. In determining data retention periods, Zenjoy takes into consideration local laws, contractual obligations, the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data, the purposes for which we process personal data and the expectations and requirements of our customers. When we no longer need personal information, we securely delete or destroy it.

7. Your right to access and control your personal information

Under certain circumstances, you have the following rights in relation to your personal data:
• Request access to your personal data.
• Request correction of your personal data.
• Request erasure of your personal data.
• Object to processing of your personal data.
• Request restriction of processing your personal data.
• Request transfer of your personal data.
• Right to withdraw consent.

If you wish to exercise any of the rights set out above, you can use the “Contact Us” option within the relevant Service or via email to contact us at policy@zenjoy.net.

We respect your right to access and control your information, and we will respond to requests for information and, where applicable, will correct, amend, or delete your personal information. However, we may require you to provide sufficient proof to verify your identity before your modification request. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. You may also have the right to request deletion of your personal information; however, this is not always possible due to legal requirements and other obligations and factors.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

8. Connecting via social networks

You may choose to use your own social networking logins from, for example, Facebook, Twitter, Wechat or Paypal, to log into some of our Services. If you choose to connect using a social networking or similar service, we may receive and store authentication information from that service to enable you to log in and other information that you may choose to share when you connect with these services. These services may collect information such as the web pages you visited and IP addresses, and may set cookies to enable features to function properly. We are not responsible for the security or privacy of any information collected by these third parties. You should review the privacy policies applicable to the third-party services you connect to, use, or access. If you do not want your personal information shared with your social media account provider or other users of the social media service, please do not connect your social media account with your account for the Services and do not participate in social sharing on the Services.

9. Friends and Other Players

Our Services allow you to interact with your friends, and if you use a social network account to register a game account with us, your friends may be able to see your name, profile picture and game activity. Other players may be able to view certain public information associated with your social network profile.

10. Payment Information

When you purchase virtual currency or items, or get cash prize in our Services, we and our business partner responsible for processing payments will collect the billing information needed to process your charges or drawing. This may include financial information like your Paypal accounts, credit card accounts, or billing address.

11. Our policy towards children

Our Services usually have minimum age requirement of users and are not directed to children, and we do not knowingly collect data relating to children. If you become aware that your child has provided us with personal information without your consent, please email to policy@zenjoy.net.

12. In the Event of Merger or Sale

In the event that Zenjoy or some or all assets related to the Services are acquired by or merged with a third-party entity, we reserve the right, in any of these circumstances, to transfer or assign the information that we have collected from you as part of that merger, acquisition, sale, or other change of control.

13. Further Privacy Notice for EU Residents

Lawful Basis for Processing Personal Information

The lawful basis for processing your information includes: i) performance of a contract with you; ii) necessary to comply with a legal obligation; and iii) necessary for our legitimate interests (including but not limited to recover debts due to us; keep our records updated and to study how customers use our products/services; study how customers use our products/services, to develop them and grow our business; run our business, provide administration and IT services, network security, prevent fraud; define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

Legal basis for each processing purpose provided in Section 2 of this Policy are:
• Account setup and administration: the legal basis for this processing is Art. 6(1)(b) GDPR.
• Personalization: the legal basis for this processing is your consent according to Art. 6(1)(a) GDPR.
• Marketing and events: the legal basis for this processing is Art. 6(1)(f) GDPR.
• Communication: the legal basis for this processing is Art. 6(1)(b) or (f) GDPR.
• Payments: the legal basis for this processing is Art. 6(1)(b) GDPR.
• Research and development: the legal basis for this processing is Art. 6(1)(f) GDPR.
• Chat rooms, messaging, and community and event forums: the legal basis for this processing is Art. 6(1)(f) GDPR.
• Legal obligations: the legal basis for this processing is Art. 6(1)(c) GDPR or Art. 6(1)(f) GDPR.

Cookie Policy

Cookies are small data files of information that a website or mobile application transfers to your hard drive or mobile device to store and sometimes track information about you. Although cookies do identify a user’s device, cookies do not personally identify users.

Our Services use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you use our Services and also allows us to improve our Services.

Types of cookies we may use:
• Strictly necessary cookies: these are cookies that are required for the operation of a website and App, such as to enable you to log into secure areas.
• Performance cookies: these types of cookies recognize and count the number of visitors to a website and users of an App and to see how users move around in each. This information is used to improve the way the website and App work.
• Functionality cookies: these cookies recognize when you return to a website or App, enable personalized content and recognize and remember your preferences.
• Targeting cookies: these cookies record your visit to a website or App, including the individual pages visited and the links followed.

Generally, the strictly necessary cookies and some performance and functionality cookies only last for the duration of your visit to a website or expire when you close an App; the functionality cookies and some targeting and performance cookies may last for a longer period of time.

Some of the cookies used by our website and App may be set by us, and some are set by third parties who are delivering services on our behalf. For example, we use Google Analytics to track what users do on the App so we can improve the design and functionality.

Most websites, mobile devices and apps automatically accept cookies but, if you prefer, you can change your browser, device or app settings to prevent that or to notify you each time a cookie is set. Please note however, that (as with other websites and apps) by blocking or deleting cookies used on our website or App you may not be able to take full advantage of our Services.

Third-party services/plugins

Access our Services through Facebook Connect
You may have the opportunity to connect to our Services through Facebook Connect when you register for Services or after you have registered for Services. If you connect to Services through Facebook Connect, we will collect, store, and use in accordance with this Policy any and all information you agreed that Facebook could provide to us through its API. This process links our Services to your Facebook profile and we may access, collect and store the following information, among other information, as allowed by you, Facebook’s API, and your Facebook privacy settings:

- your Facebook name;
- your profile picture;
- your email address;
- your gender;
- your birthday;
- your location;
- the names and pictures of your Facebook friends;
- your interests and affinity networks;
- other information you make publicly available via Facebook

You may find Facebook’s Privacy Policy here:
https://www.facebook.com/policy

Google Firebase Authentication
We may use Google Firebase Authentication to make your authentication easier and more convenient. This service provider has access to personal information required to perform its tasks. Google Firebase may not use them for other purposes. In addition, Google Firebase is required to treat the information in accordance with the applicable data protection laws.

You may find Google’s Privacy Policy here:
https://policies.google.com/privacy

Payment Method PayPal
If you choose to pay our Services via PayPal, the information you provide will be sent to PayPal for payment at sign-up. PayPal may not use them for other purposes. In addition, PayPal is required to treat the information in accordance with the applicable data protection laws.

You may find PayPal’s Privacy Policy here:
https://www.paypal.com/gp/webapps/mpp/ua/privacy-full

Google Analytics
We may use this technology to make our website more interesting for you and to optimize its functionality. The purpose of the processing is our legitimate interest in improving our Services. If you only wish to accept our own cookies, but not those of our service providers and partners, you can select the setting in your browser "Block third party cookies", or contact us via email at policy@zenjoy.net

You may find Google’s Privacy Policy here:
https://policies.google.com/privacy

Amazon Web Services
Your personal information may be stored on our behalf on third-party infrastructure provider Amazon Web Services. Amazon may not use the data for other purposes. In addition, Amazon is obliged to treat the information in accordance with the relevant data protection laws.

You may find AWS’s Privacy Policy here:
https://aws.amazon.com/privacy/

Loggly
We may use Loggly to analyze data provided by you. We may use this technology to make our Services more interesting for you and to optimize its functionality. Loggly may not use the data for other purposes. In addition, Loggly is obliged to treat the information in accordance with the relevant data protection laws.

You may find Loggly’s Privacy Policy here:
https://www.loggly.com/about/privacy-policy/

Adjust
We may use Adjust to analyze data provided by you. We may use this technology to make our Services more interesting for you and to provide better customized Services. Adjust may not use the data for other purposes. In addition, Adjust is obliged to treat the information in accordance with the relevant data protection laws.

You may find Adjust’s Privacy Policy here:
https://www.adjust.com/terms/privacy-policy/

The Facebook “Like” Button
We may integrate the Facebook "Like" button on our Services. Regardless of whether you are logged in to your Facebook account or not, the plugin establishes a direct connection between your browser and the Facebook server and sends Facebook the information that you have visited our website using your IP address. If you are logged into your Facebook account while visiting our website, you can link our content to your Facebook account by clicking the "Like" button.

You may find Facebook’s Privacy Policy here:
https://www.facebook.com/policy

Twitter Plugin
We may include a Twitter plugin in our Services that allows you to link the content of our Services to your Twitter account. If you are logged into your Twitter account while using our Services, a link will be established. The exact content of the data transmitted to Twitter and how Twitter uses it is beyond our knowledge.

You may find Twitter’s Privacy Policy here:
https://twitter.com/en/privacy

Instagram Plugin
We may include an Instagram plugin in our Services that allows you to link the content of our Services to your Instagram account. The exact content of the data transmitted to Instagram in this way and how it is used by Instagram is beyond our knowledge.

You may find Instagram’s Privacy Policy here:
https://help.instagram.com/402411646841720


Transfer Personal Information out of European Union

When we transfer personal information from the European Union to other countries in which applicable laws do not offer the same level of data privacy protection as in your home country, we take measures to provide an appropriate level of data privacy protection. In other words, your rights and protections remain with your data. For example, we use approved contractual clauses, multiparty data transfer agreements, intragroup agreements, and other measures designed to ensure that the recipients of your personal information protect it. If you would like to know more about our data transfer practices, please contact us at any time.

14. How to contact us

If you have any concerns, questions or complaints regarding our Policy or privacy practice, please feel free to contact us at
Attn: Zenjoy Compliance Team
Address: Room 1403, 14/F., Officeplus @Sheung Wan, No. 93-103 Wing Lok Street, Hong Kong
Email: policy@zenjoy.net
Tel: +86 10 65206723