Last revised: May 12, 2023
This Privacy Policy sets forth the agreement between Changyou.com HK Limited and any one of its parent, subsidiary or affiliated companies（"We"）and our players and users of our Services (hereinafter “You” or "Users"). This Privacy Policy is incorporated as part of our Terms of Use, accessible in our Games, Applications and/or Services.
We collect personal data to support our products and services, while respecting all applicable laws, including but not limited to the Personal Information Protection and Electronic Documents Act (PIPEDA), and regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, directly applicable from May, 25th, 2018 (hereinafter, "General Data Protection Regulation", or "GDPR"). As defined in the GDPR, "personal data" means any information relating to an identified or identifiable natural person, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. In the context of this Privacy Policy, “personal data” and “personal information” shall be deemed to have the same meaning.
By using our services, you authorize us and our affiliated companies (collectively, "we"), to process your personal data according to this Privacy Policy. If you do not accept the terms of this Privacy Policy, please refrain from using our online games or our games’ online functionalities, our websites, our mobile apps and any other online products and services (hereinafter "Services").
We collect and process your personal information at different times when you interact with our Services. Generally, personal information is collected when:
• when you register and/or use our Services, Games or Site, or open an account with us;
• when you submit any form, including, but not limited to, application forms or other forms relating to any of our products and services, whether online or by way of a physical form;
• when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our products and services;
• when you interact with us, such as via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails; including when you interact with our customer service agents;
• when you use our electronic services, or interact with us via our Games or Site or use our Services. This includes, without limitation, through cookies which we may deploy when you interact with our Games or Site;
• when you grant permissions on your device to share information with our mobile application or Site;
• when you link your account of our Games or Site or use our Services with your Social Media Account (defined below) or other external account or use other social media features, in accordance with the provider’s policies;
• when you carry out transactions through our Games or Site (where applicable) or with our authorized third-party payment service providers;
• when you provide us with feedback or complaints;
• when you register for a contest, for games or game specific events;
• during your gameplay; and
• when you submit your personal data to us for any reason.
The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.
2.1 The personal data that We may collect after obtaining user’s consent includes:
• name, username and user ID;
• contact information (including email address, telephone number, and/or address;);
• transaction information, including bank account and payment information where applicable and subject to applicable law;
• chat and other information about the people and accounts you interact with;
• gender, age, and/or date of birth;
• information sent by or associated with the device(s) used to access our Services;
• photographs or audio or video content that you submit via the Services;
• location related information, including IP address;
• government issued identification or other identification you share with us, where applicable;
• marketing and communications data, such as your preferences in receiving marketing materials, your communication preferences and history of communications with us and our service providers;
• survey responses, competition, contest or tournament related information, and/or other information you provide to us;
• any other information you provided when you sign up or use the Services, including information shared via any linked Social Media Account (“Social Media Account”);
• usage and transaction data, including data on your activities, orders, use of the Services and the advertising and other content you engage with; and
• Other personal information that we need to collect according to provisions of this Privacy Policy or applicable laws and regulations.
2.2 You agree not to submit any information to us which is inaccurate or misleading, and you agree to inform us of any inaccuracies or changes to such information. Subject to applicable law, we reserve the right at our sole discretion to require further documentation to verify the information provided by you.
2.3 If you sign up to be a user of our Services using your Social Media Account, link your account to your Social Media Account or use our social media features, we may access information about you which you have voluntarily provided to your Social Media Account provider in accordance with such provider's policies, and we will manage and use such personal data in accordance with this Privacy Policy at all times.
2.4 If you do not want us to collect the aforementioned information/personal data, you may opt out at any time by notifying our Data Protection Officer via the means set forth in Article 10 of this Privacy Policy. Further information on opting out can be found in the section below entitled "WHAT ARE MY RIGHTS?". Note, however, that opting out or withdrawing your consent for us to collect, use or process your personal data may affect your use of the Services.
The information you submit to our Services is collected and used by us as set out in this Privacy Policy. In addition, We may use the submitted information to answer your demands, to send your order confirmations and other information regarding your Account of our Games or Site or use our Services, to send you advertising or promotional materials, including information about special rebates, promotional offers and other events of interest, based on your preferences.
We also use your personal information for our internal marketing and demographic studies, so we can constantly improve the Services we provide you and to better meet your needs.
We may have to duplicate some of your personal data within our databases for technical reasons, or for any other reason indicated in this Privacy Policy. We may use your IP address to enforce our Terms of Use. In case of misuse of the Services by any User, We reserve the right to block such User’s Account of our Games or Site or limit the use of our Services, as provided by licensed manufacturers cooperated with us. We may use your date of birth or your age to control access to its forums and live chats, in accordance with the relevant laws and regulations. We do not monitor the content of chat communications on our Services. However, We reserve the right, at our sole discretion and without notice, to modify or delete any communications in violation of legal provisions on our Services. We may use all data collected in the forums and chat logs to enforce our Terms of Use, to carry out our legal obligations, and to protect our rights and the rights and safety of our affiliated companies, users, and employees. Your information may be disclosed to any relevant judiciary or administrative entity, in accordance with the relevant legal provisions.
We process your personal data, wherever necessary:
- To provide you with the Services (creation of your account of our Games or Site or use our Services, bug detection, fighting fraud, online payment, etc.)
- To offer the best possible experience to users, and improve the Services (in-game data analytics, etc). It is in our legitimate interest to process your data for these purposes.
- To provide you with supplementary services (custom content, etc.). In such case, We will ask for your consent before processing your personal data for this purpose.
We take your privacy and the security of your personal information very seriously. To protect your personal information, We maintain appropriate safeguards to ensure the security, integrity and privacy of the information you have provided. We use robust security measures to protect personal information from loss, misuse and alteration. We use industry-standard practices such as encrypted communications, physically secured rooms, firewalls and password protection systems to safeguard the confidentiality of your personal information. In addition, we take reasonable steps to assure that third parties who collect personal information on our behalf provide sufficient protection of personal information, in addition to requiring their compliance with this Privacy Policy at all times. Please note, we will notify Users of a data breach pursuant to applicable law.
However, please note that no existing data transmission method on the web, or electronic storage, can guarantee the absolute security of your personal data. If your accounts and personal data of our Games or Site or use our Services are protected by a password, you are responsible for ensuring this password’s confidentiality. Please do not disclose this password. If you share a computer with other people, please consider disconnecting from your accounts before allowing others to use your computer. Services may contain links leading to third party websites, including but not limited to social media sites. Whenever you click on a link leading to a third party’s website, you agree to leave our Services as governed by this Privacy Policy, and you understand and agree that We do not control such third party’s website. We cannot guarantee that third parties’ websites will be governed by the same security and confidentiality obligations. We are not liable for the use of your personal data by these third parties. Please consider checking privacy policies of any service provider you transfer your personal data to.
DESPITE OUR REASONABLE EFFORTS TO KEEP YOUR PERSONAL INFORMATION SECURE, NO COMPANY CAN GUARANTEE THE SECURITY AND PRIVACY OF ITS SERVICES, INFORMATION AND OTHER DATA.
Unless relevant legal provisions mandate a different data retention period, We will store your personal data only as long as necessary to process it according to this Privacy Policy. For instance, we may retain certain information after you close your account for a period of time needed to protect us from legal claims. In this case, we will archive your personal data during the relevant statutory period of limitations.
We do not disclose your personal data to any third party without your prior consent.
We may share your personal information among our group of companies. To the extent that our corporate affiliates and/or technical partners have access to your information, they will follow practices that are at least as restrictive as the practices described in this Privacy Policy.
5.2.1 While browsing on our websites, or while using our Services, external providers may collect your personal data for and on behalf of us and We may share some of your personal data with these partners to allow the functioning of the Services (such as Facebook, Google, Twitter, Yahoo and Windows). For example, these third parties may help deliver your purchases, provide discounts or offer products, promote the Services, perform electronic payment processing, and any other service that may be required by us. External providers must comply with this Privacy Policy when collecting your personal data. These external providers will share your personal data with no one besides us, and they may not use your data for their own independent marketing purposes, unless you consent to their privacy policy and terms of use directly.
5.2.2 In an attempt to provide you with increased value, we may choose various third party websites to link to, and frame within, the Site or Games. We may also participate in co-branding and other relationships to offer e-commerce and other services and features to our visitors. These linked sites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with us, we have no control over these linked sites, each of which has separate privacy and data collection practices independent of us. Data collected by our co-brand partners or third party websites (even if offered on or through our Site or Games) may not be received by us.
In accordance with relevant laws, We may have to disclose your personal data to a judiciary or administrative entity, whenever such disclosure is deemed necessary for protecting or enforcing our legal rights, Users, or third parties. Unless required by law, We will not be required to notify you of any such disclosure.
In the unlikely event that our business activities or shares are transferred partly or totally to any third party, such third party may access your personal data. In this case, We may also allow your personal data to be transferred to the acquiring third party.
Please be aware that your personal information may be transferred to, stored in, and processed by affiliated companies, developers, servers, subcontractors and/or our partners, located in third countries outside your region. Some personal data recipients are located in countries that are not considered as ensuring an adequate protection level according to the GDPR and other statutes in force enacted by EU Commission. In such case, We use the strict framework of the GDPR as well as EU Commission’s approved standard contractual clauses, which are available on the EU Commission website (https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_fr/).Because different jurisdictions may have different data protection requirements, we take steps to implement adequate safeguards to protect your data.
We may offer a public profile feature ("Public Profile") that allows you to publish information, including personal information, to the public Internet. Other than as stated on the applicable Public Profile site, the information you upload or input to your Public Profile will default to the privacy level you choose, and you can choose to change the privacy settings at any time (For the change of in-game elements such as head portrait and character’s name, please refer to the Settings interface in the game application. For the change of other settings such as microphone and location access , please consult your device's manual for more information). By default, certain aspects of the Public Profile are set to "public". Those aspects of the Public Profile that are designated as "public" will be visible to everyone, potentially including people not registered within our environment, and may be indexed and displayed through public search engines when someone searches for you. If you post your personal information to a Public Profile, including a video, image or photo, you should be aware that these may be viewed, collected, copied and/or used by other users without your consent.
We are not responsible for disclosure by other users of your Personal Information, including without limitation, videos, images or photos that you choose to make public on our Services. Also, please remember that the Personal Information you provide to us as part of your Public Profile may reveal or allow others to identify aspects of your life that you may not choose to state on your Public Profile directly (for example, your picture may reveal your gender). Certain Services may feature a friend finder tool. By using our friend finder tools, you acknowledge that these tools will help you find your contacts, and will also allow your contacts to associate your Account and the other accounts (if any) of our Games or Site or use our Services, and related gaming entitlements, including games played on PC, mobile and console platforms with your social networking profile and/or email address. Your resulting friends' list, which may be accessible across our sites, will be subject to this Privacy Policy. Note that the friends that you choose to include on your friend list may be able to find and/or identify you in the context of different our products and Services, and may see the profiles and information you have made visible to them or to everyone. Similarly, We may also collect or receive information about you from other users of our Games or Site or use our Services who choose to upload their emails and other contacts. This information will be stored by us and used primarily to help you and your friends to connect with each other.
We do not knowingly collect or maintain any personal data or non-personally-identifiable information from minors nor is any part of our Site, Games or other Services directed to them. As a parent or legal guardian, please do not allow minors under your care to submit personal data to us and please also consult our Terms of Use for more information. In the event that personal data of minors in your care is disclosed to us, you hereby consent to the processing of the minor’s personal data and your acceptance and agreement to be bound by the terms of this Privacy Policy on behalf of minors. In the event you do not in fact consent to the processing of the personal data of minors in your care, please contact our Data Protection Officer. We will close any accounts used exclusively by minors and remove and/or delete any personal data that was submitted without parental consent by minors or as otherwise required by applicable law. The definition of minors shall be subject to applicable laws and regulations.
You can access and update the contact information you gave us during registration (that is, your e-mail address or any other information that would directly enable us to contact you), by logging in and clicking the in-game settings interface. Additionally, you have a right to access, rectify, erase, object, or restrict processing for all your personal data processed by us, as well as the right of data portability. You can exercise these rights or terminate your account of our Games or Site or terminate the use our Services by contacting us via the means set forth in Article 10 of this Privacy Policy. We will answer your request within a month following the receipt of your demand. We reserve the right to extend this delay up to two months if it necessary regarding the complexity of your demand, or based on the number of demands we receive. In such case, we will inform you of this extension within a month following the receipt of your demand. For any data processing activity requiring your consent (e.g.cookies, behavioral advertising), you may withdraw your consent at any time. This withdrawal does not affect the lawfulness of any previous processing.
To be specific, you have certain rights in relation to the personal information we hold about you, depending on where you are located. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at most within one month (though this may be extended by a further two months in certain circumstances).
The sub-sections entitled “Access”, “Correction”, and “Erasure” also apply to users that are located in Canada, Argentina and Russia.
Access
You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us via the means set forth in Article 10 of this Privacy Policy.
Portability
You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent (e.g., survey information) or pursuant to our contract with you (e.g., game play statistics), as described above in the section “How Do We Use the User’s Personal Data”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party, with certain exceptions according to relevant laws and regulations. We will provide further information to you about this if you make such a request.
If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (for example, where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).
Correction
You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us via the means set forth in Article 10 of this Privacy Policy.
Erasure
You can delete your account, or remove certain personal information, by logging into your account. If there is any other personal information you believe we process that you would like us to erase, please contact us via the means set forth in Article 10 of this Privacy Policy.
We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defense of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Service and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.
Restriction of Processing to Storage Only
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. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defense of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.
Retention of personal information
We may retain your personal information as long as needed to provide services or products to you, or as required or permitted by applicable laws, such as tax and accounting laws, or for the exercise or defense of legal claims. If you make a request for erasure of your personal information and we determine that there is a valid basis for your request, we will endeavor to erase the personal information within 30 days of your request, or inform you if it will take longer.
Objection against Profiling and Targeted Marketing
At any time you have the right to object to our processing of personal information about you in order to send you promotions, special offers and marketing messages, including where we build profiles for such purposes and we will stop processing the personal information for that purpose. Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for objection. However, we may retain the personal information if there are valid grounds under law for us to do so.
To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us via the means set forth in Article 10 of this Privacy Policy. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.
Announcements
We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend the Service’s access for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.
We reserve the right to modify this Privacy Policy at any time. As a result, please consider checking this Privacy Policy from time to time.
Your use of the Services after We changed this Privacy Policy shall signify that you agree with these changes. If you do not accept changes made to this Privacy Policy, please refrain from using the Services.
For any question related to your personal data processing and this Privacy Policy, please contact our data protection officer at the following address:cyougpd@gmail.com.
You can also write us at the address below:
Attn: Room 1901, 19/F, Lee Garden One, 33 Hysan Avenue, Causeway Bay, Hong Kong
Please be assured that any Personal Information that you provide in communications to the above email and postal mail addresses will not be used to send you promotional materials, unless you request it.