PRIVACY POLICY

This Policy applies to game‑related products and services developed, maintained and operated by Shanghai Lingfeng Network Technology Co., Ltd. and its affiliates (collectively referred to as “Lingfeng”, “we”, “us” or “our”).Last Updated: December 26, 2024

This Policy will help you understand the following:

We understand the importance of your personal information and will make every reasonable effort to keep it safe and secure. We strive to earn and maintain your trust, and abide by the following principles for personal‑information protection: accountability, clear purpose, consent‑based selection, data minimization, security assurance, user participation, and openness & transparency. Meanwhile, we commit to adopting appropriate security safeguards in accordance with industry‑standard security practices to protect your personal information.

By using our products and services, you acknowledge that you have carefully read and fully understood all terms of this Privacy Policy. Before providing any personal or sensitive personal information to us, please carefully consider whether such provision is appropriate, and consent to our processing of such information in accordance with this Policy. We collect and use your sensitive personal information only after obtaining your consent to deliver relevant services. You may decline to grant permission for collection and use of sensitive personal information; however, refusal may affect the availability of corresponding functions and services.

1. How We Collect and Use Your Personal Information

We collect your personal information primarily to deliver safe, enjoyable game services and improve your user experience. Such information helps us achieve these goals.

1.1 Sources of Information We Collect

  1. Information you provide

    1. Information you submit when registering for or using our game services.
    2. Shared information you provide to other parties via our services, and information you store while using our services.

    Please note: If you post or publish information in publicly‑visible areas of our services (including replies to other users’ content), such information may be collected and used by third parties. If you discover improper collection or misuse of your information, please contact us via channels specified in Section 7 “How to Contact Us”.

  2. Information lawfully shared by third parties
    Information about you provided by third parties when they use our game services.
  3. Usage information collected in the course of service delivery
    We collect and record log data, device information and location‑related information generated during your use of our services.

1.2 Types of Personal Information and Purposes of Use

Please note that collected data categories may vary depending on specific products or features you use. Please refer to the Personal Information Collection List within the product for details. As our products iterate and expand, we may launch new features and adjust data‑collection scope or processing purposes. If we intend to use your personal information for new purposes or collect additional personal data not specified herein, we will obtain your separate consent via on‑page prompts, in‑game pop‑ups, website announcements or other reasonable means. You may send inquiries via contact channels listed in Section 7. Below are common scenarios, data categories and processing purposes:

  1. 1.2.1 Account Registration & Login

    To deliver stable continuous services and secure your account, we collect basic registration and login information including your mobile phone number, email address, username and password.

    Subject to applicable laws and our service terms, you may apply for account cancellation by sending an email to raiden@shanghailingfeng.com and following the provided guidance.

  2. 1.2.2 Identity Verification

    In compliance with regulatory requirements, for account security and specific feature access, we may request identity‑verification information such as your real‑name ID data, passport details, biometric information (facial features, fingerprints, etc.). If you decline to provide such information, relevant functions may become unavailable. You authorize us to submit and verify your identity information with competent regulatory authorities and designated verification service providers.

    Identity documents and biometric data qualify as sensitive personal information. Refusal will block relevant functions but will not disable other core game features.

  3. 1.2.3 Core Game Functions, Network & Operational Security

    To detect abnormal account status, ensure software compatibility, maintain basic service availability and operational security, we collect and store log and device‑related data:

    1. (1) Log Information

      When you use our services (including background operation), we automatically record service usage logs: account ID, game‑player ID, search records, IP address, browser type, carrier information, network environment, language setting, access date‑time, page‑visit records, push‑notification interaction, dwell time, refresh actions, publish/follow/subscribe/favorite/share behaviors.

    2. (2) Device Information

      For service stability, operational quality and security protection, we collect hardware model, OS version, device identifiers (Android: IMEI, AndroidID, OAID, IMSI, ICCID, GAID, MEID; iOS: IDFV, IDFA), MAC address, hardware serial number, GUID, SIM‑card identifiers, screen resolution, package name, device settings, process & application list, unique hardware identifiers, software‑hardware fingerprints, IP‑based location data, WLAN / Bluetooth / base‑station metadata, network‑quality metrics and operation logs.

      • Installed‑application list: Used to detect whether third‑party apps (QQ, WeChat etc.) exist on your device; we display reminders for missing apps during sharing or third‑party‑login flows. This data will not be uploaded to our servers.
      • MAC address / Android ID: Used for anti‑cheat capabilities and log analysis.
      • IP address: Used for anti‑cheat capabilities and log analysis.
      • Clipboard access: On app launch we read clipboard content to parse share‑invitation tokens. Clipboard content is processed locally on your device and will not be uploaded to servers.
      • Running‑process information: For malware prevention, operational stability, performance statistics and foreground‑/background‑state detection for share‑token handling.
      • Gyroscope / accelerometer / gravity sensors: Used for device‑status identification.

    We will request corresponding system permissions to gather above device‑related data. Denying these permissions may result in incomplete or degraded game‑service experience.

    Standalone device‑identifier and log data cannot identify a specific natural person. Where such non‑identifiable data is combined with other data to identify you, the combined dataset shall be treated as personal information under this Policy, and we will apply anonymization / de‑identification measures where legally permitted.

  4. 1.2.4 Interaction & Content‑Publishing Features

    When you post comments, replies, likes, shares, favorites or other user‑generated content within our services, we collect and may publicly display your nickname, avatar and published content. Please exercise caution before posting content that contains your own or third‑party personal information. You shall obtain consent from third‑parties before publishing their personal data.

  5. 1.2.5 Order, Payment & Virtual‑Goods Delivery

    1. We collect order‑related data (purchased goods / services, order number, creation timestamp, transaction amount) to display your order history and secure transactions.
    2. To complete payments, deliver virtual goods and process after‑sales disputes, we may receive or share account, order and transaction data with payment providers and other selected service providers selected by you.
  6. 1.2.6 Customer‑Support Services

    When you submit support tickets, privacy‑related complaints or other requests, we may collect necessary personal information to verify your identity for account safety purposes. If you withhold required information, we may not be able to resolve your request. We may store your contact details, communication records and request‑related information for problem resolution, follow‑up and case documentation.

  7. 1.2.7 Information Obtained from Third‑Party Partners

    We may receive account metadata (nickname, avatar, profile name) from affiliated companies or authorized partners when you authorize third‑party‑account binding. We will only use such data if we confirm the source is lawful and after you accept this Privacy Policy.

  8. 1.2.8 Service Notifications

    We may send service‑related push notifications for system maintenance, feature adjustments or service termination. You may opt out of marketing‑oriented push messages via device‑system settings or unsubscribe instructions in messages. Statutorily‑mandated service announcements cannot be disabled.

  9. 1.2.9 Security Protection

    To protect users against fraud, network vulnerabilities, malware and network attacks, and to detect violations of our service rules, we may aggregate account data, transaction records, device‑metadata and partner‑provided authorized information to assess account risk, perform identity verification, detect security incidents and take audit / disposal actions permitted by applicable law.

  10. 1.2.10 System‑Permission‑Dependent Features

    Certain features require corresponding device permissions:

    1. Album / Camera permission: Upload photos and screenshots for posting, commenting or customer‑support evidence submission.
    2. Contacts permission: Query friend status and invite contacts to use our services.
    3. Microphone permission: Voice‑chat interactions and voice‑based customer support.
    4. Location permission: Nearby‑friend interaction features.
    5. Calendar permission: Record events and send reminder notifications.
    6. Storage permission: Cache game resources and save downloaded content.
    7. Telephone‑information permission: Retrieve device identifiers for compatibility analysis and anti‑abuse protection.

    You may revoke permissions at any time via your device’s system settings. Revoking a permission stops further collection for that feature but does not invalidate processing performed with prior consent.

  11. 1.2.11 Exceptions Where Consent Is Not Required

    Under applicable laws, we may collect personal information without your explicit consent in the following scenarios:

    1. National‑security and national‑defense purposes;
    2. Public‑safety and public‑health major‑interest scenarios;
    3. Criminal investigation, prosecution, trial and judgment enforcement;
    4. Safeguarding vital legitimate interests of you or other individuals where obtaining consent is impractical;
    5. Information you voluntarily make publicly available;
    6. Information collected from legally‑public sources such as official news reports and government disclosures;
    7. Necessary for performing a contract at your request;
    8. Legitimate news‑reporting requirements;
    9. Other circumstances stipulated by applicable laws and regulations.
  12. 1.2.12 Sensitive Personal Information Reminder

    Sensitive personal information means data that, if leaked or misused, may endanger personal dignity or personal / property safety. This includes ID numbers, biometric data, communication records, credit data, location traces, accommodation records, health‑related data and transaction records. You agree we may process your sensitive personal information in accordance with purposes and methods laid out in this Policy.

2. How We Use Cookies

A Cookie is a small text file sent by a website to your browser, typically containing identifiers, site names and numeric / character strings. Cookies help browsers record session states, preferred language and other configuration data to improve your revisit experience.

We deploy Cookies to maintain login‑session states, record operating status and store language preferences to enhance service quality. We will not use Cookies for purposes outside those described in this Policy. You may manage or delete Cookies according to your preferences. For further guidance please visit http://www.aboutcookies.org; detailed browser‑setting documentation is available for Google Chrome, Mozilla Firefox, Safari, Opera and other mainstream browsers.

3. How We Share, Transfer, Publicly Disclose and Store Your Personal Information

3.1 Sharing

Within our corporate group, your data may be shared among Shanghai Lingfeng Network Technology Co., Ltd. and its affiliates on a minimum‑necessary basis to deliver services. All affiliated entities shall comply with this Privacy Policy. Affiliates will seek fresh consent if they intend to process personal information for new purposes.

We will not share your personal information with external third‑party companies, organizations or individuals except under the following conditions:

  1. We obtain your explicit consent for sharing.
  2. Sharing is required by applicable laws or mandatory orders issued by competent governmental authorities.
  3. Third‑party SDKs embedded in our products may collect personal information to deliver their respective functions. Their processing is governed by their own privacy policies. Please refer to our Third‑Party‑SDK Personal‑Information‑Sharing List for full details.
  4. Sharing with authorized partners strictly limited to purposes stated in this Policy, following data‑minimization principles. Partners may not reuse shared data for unrelated purposes. Partner categories include:

We execute strict confidentiality agreements with all external recipients of personal information, requiring them to follow our instructions, this Privacy Policy and appropriate security safeguards.

3.2 Transfer

We will not transfer your personal information to external third‑parties except:

  1. Transfer happens with your explicit consent.
  2. In cases of merger, acquisition, asset sale or bankruptcy liquidation involving personal‑information hand‑over. The acquiring entity shall remain bound by this Privacy Policy. If new processing purposes are introduced, the new controller shall obtain your fresh consent.

3.3 Public Disclosure

We publicly disclose personal information only in the following circumstances:

  1. You provide explicit consent for disclosure.
  2. Disclosure is required by law, legal proceedings, litigation or mandatory regulatory requirements.

3.4 Data Storage

  1. Storage Location: Personal information collected and generated within Mainland China will be stored within Mainland China. We will not transfer personal information out of Mainland China without your explicit consent or mandatory legal / regulatory requirements. Data is stored via local device caching, databases and server logs secured by technical safeguards.

    Note for overseas users: When you access our services from outside China, your personal data will be transmitted to and processed on servers located in Mainland China. By using our services you consent to this cross‑border data transfer.

  2. Storage Period: We retain personal information only for periods necessary to fulfill stated service purposes or as required by law. Upon expiry of retention periods, data will be deleted or anonymized, subject to account‑cancellation requests and statutory exceptions.

4. How We Protect Your Personal Information

  1. We adopt industry‑standard security safeguards to prevent unauthorized access, disclosure, alteration, damage or loss of personal information. Security measures include HTTPS encrypted communications, bastion‑host‑based operation‑access auditing, firewalls, WAF web‑application firewalls, anti‑DDoS traffic‑cleaning infrastructure, asymmetric encryption for sensitive database data, layered network‑and‑terminal‑defense systems, strict access authorization & audit logging for internal staff, full‑lifecycle monitoring for sensitive‑data access, and internal privacy‑protection training programs.

  2. Our security capabilities include application‑layer encryption, network‑layer encryption, database encryption, abnormal‑access monitoring for networks and databases.
  3. We strive to avoid collecting irrelevant personal data and retain data only for the shortest practicable period permitted by law.
  4. Internet transmission cannot be guaranteed to be 100 % secure. Please avoid transmitting sensitive personal information over unencrypted channels and use complex passwords to protect your account.
  5. We periodically publish security‑risk and personal‑information‑impact‑assessment related materials as appropriate.
  6. In the event of a personal‑information‑security incident, we will notify you of incident facts, potential impacts, mitigation measures, user‑protection advice and remedial steps via letter, SMS, in‑game push or public announcements in accordance with legal requirements. We will also report such incidents to relevant regulatory authorities as required.

5. How We Process Children’s Personal Information

  1. We implement anti‑addiction systems in compliance with PRC regulatory requirements to safeguard minors’ legitimate interests. Real‑name verification is used to identify minor accounts and apply anti‑addiction restrictions.
  2. Collection, storage, sharing, transfer and disclosure of children’s personal information requires verifiable explicit consent from their legal guardians. We will adjust our practices accordingly if new laws governing children’s data‑protection take effect.
  3. If you are a legal guardian and object to our processing of your ward’s personal information, please contact us. We will promptly delete the relevant minor‑user data and discontinue service provision for that account.
  4. A dedicated contact is assigned for children‑privacy‑related inquiries. Please send emails to raiden@shanghailingfeng.com. We will respond within fifteen (15) working days.

6. How This Privacy Policy Is Updated

  1. This Privacy Policy may be revised from time to time.
  2. When material revisions occur, we will notify you via in‑game pop‑ups, page prompts or website announcements upon version updates. Your continued use of our game services constitutes acceptance of the revised Privacy Policy.

7. How to Contact Us

If you have any questions, comments or suggestions regarding this Privacy Policy, please email us at raiden@shanghailingfeng.com. Normally we will reply within fifteen (15) working days after verifying your user identity.