Privacy Policy

Update:11/10/2022

Come into effect since: 11/10/2022

We (Toprank Games (HK) Limited, also “we”, “us”, “our” in this document) are the provider of this application("app"). We attach very importance to your privacy and personal information safety. Please carefully read this privacy policy (“Privacy Policy”) before you use  our app(“Service”, “Services”).

This document will come into effect for all existing users. Your use of the Service from that effective day will be subject to this Privacy Policy. This Privacy Policy explains the when, how and why when it comes to processing of your personal information in connection with the Service, and sets out your choices and rights in relation to that information. It is important for you to understand how we collect and use your information, and how you can control it.

By using the Service you are accepting our rules regarding your personal information as described in this Privacy Policy. If you don't agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Service.

If any dispute or controversy arises between you and us, it shall first be resolved through friendly negotiation; if negotiation fails, you agree to submit the dispute or controversy to the jurisdiction of the people's court in Nansha District, Guangzhou, China, and the laws of the People's Republic of China (excluding conflict of laws) shall apply.

The Privacy Policy includes contents as follows:

1. Personal Information

1.1 Collection

1.2 Usage

1.3 Storage

1.4 Share

1.5 Security

2. Your Rights

3. Services provided by Third Parties

4. Children

5. Notification and Modification

6. California

7.European Economic Area (EEA)

1.      Personal Information

1.1 Collection

When we provide services, we may collect, store and use your certain personal information based on specific product features. If you do not provide relevant information, you may not be able to enjoy the specific services we provide, or you may not be able to achieve desired effect.

The following is a high level summary of the types of personal information we use:

1. Information you provide to us (either directly or through a third party). 

Identification information:When you contact our customer service or use other user response features (such as making an in-sale or after-sales request, complaint or suggestion, etc., we need you to provide necessary personal information to match and verify your user identity in order to protect your account and system security. We may also save your contact details (other contact details you use when you contact us or that you have voluntarily provided to us), your call record and content with us, as well as other information necessary for resolving your problems, in order to contact you conveniently, and to record the handling of related issues and the outcomes.

2. Information we automatically collect from you when you use the Service

· Log and device information: When you use our services, after obtaining your device information permissions, the system may automatically collect log information through cookies, web beacons or other means. We collect such information during your use of the product (including silent state) to determine whether the account is abnormal.If so, we will respond to network abnormalities in a timely manner.

· Scope of collection: Device or software information, such as device model, mac address, signal strength, configuration information, your IP address, and the version used by your mobile device or other programs used to access our Services;

· Information about mobile applications (apps) and other software that you have used, and information about the mobile applications and software you have used in the past;

· Information (metadata) contained in content you share through our Services, such as the date, time, or location of shared photos or videos taken or uploaded.

· Purpose of collection:We collect such information to identify the status of your account, understand product adaptability, ensure the network and operational security of our services, and provide you with page display, browsing, and search services that are more suitable for your needs.

· Application list: After you open the storage and read permissions for reading and writing photos, we can collect such information when you use the functions related to our software.

· Scope of collection: All photos an videos in your photo gallery.

· Purpose of collection:We will access your storage space so that you can download, save, clean up content, or cache features such as accelerated optimization services, and to help you restore your backed up software, so as not to repeatedly distribute existing software locally; Detect software installations to facilitate mobile phone acceleration, software, and file cleanup.

· Billing Information:We use the information to share and bring up third-party payment functions.

· Scope of collection: We may use the IOS system's APIs to collect information about your subscription order, such as purchases, subscription times, order status, payment times. We do not collect specific information about payments, and we are not responsible for the collection and security of such information. Payment information is processed and stored by third-party companies, such as Apple, who can be contacted through their websites: https://www.apple.com. Before you enter your personal payment information, we recommend that you read and familiarize yourself with the privacy policies of these third-party companies.

· Service data and log information: open ID, IP address, device model and information regarding your use of the Service.

· Other Information: Other individual services require you to enable specific information involved in those permissions. In addition none of the following permissions will be enabled by default unless expressly authorized by you, and if you do not enable the following authorizations, it will not affect your normal experience of our basic functions, such as:

· After you turn on our permission to read/write your calendar, we may obtain your schedule time in order to provide you with recording, reminders and other functions;

· After you turn on the permission to use our notification bar, we  may obtain the content of your notification bar in order to provide you with the cleaning notification and the red packet reminder service,and provide you with information prompts, so that you can enter our products more quickly.

3. Information we collect through a third party

We obtain information that you authorize to share from our affiliates, third-party partners. For example, we may obtain your account information (including user name, avatar, nickname, subject to your authorized content) from a third party and bind your third-party account to your service account registered with our products after you agree to this policy, so that you can directly log in and use our services through the third-party account. We will collect and use your information in accordance with relevant laws, regulations, and the agreement with affiliates or third-party partners, and under the premise that the source of the information provided by them is legitimate.

4. Exemption

According to applicable laws and regulations, under the circumstance below, we may collect your information without your prior consent.

· To protect national security or national defense security;.

· To protect public safety, public health, or major public interests.

· To comply with the requirements of the relevant governmental authority or other legally authorized organization.

· To protect your or any individuals’ major legitimate rights or interests such as life and property of the information subject or other individuals,while it is difficult to obtain your consent.

· Collecting information from lawfully and publicly disclosed information, such as lawful news reports, open government information, and other such channels;

· Necessary for signing a contract according to your requirements;

· Necessary for maintaining the safe and stable operation of our services, such as discovering and disposing of the failure of products or services;

· It is necessary for lawful news reporting;

· When it is necessary for an academic research institution to carry out statistical or academic research based on the public interest, and when providing the results of academic research or description to the outside world, the information contained in the results is de-identified;

· For purposes that are reasonable and necessary to enforce the relevant Terms of Service or privacy policy, to protect the public interest, and to protect the personal property safety or other legitimate rights and interests of our customers, or our affiliates', other users, or employees.

1.2. Usage

1. To display and recommend goods or services for you

We may use the information you provide to us, the information we collect about you directly or indirectly (such as your browsing and search history, device information, location information, etc.) to model recommendation algorithms, model programmatic advertising recommendation algorithms, analyze user behavior, and user portraits by combining one or more of the above information, to extract your browsing history, search preferences, behavior habits, location information and related characteristics. In order to provide you with page display and recommend personalized content that is more tailored to your needs.

2. To send you marketing messages which is based on your characteristics via email, SMS or other means, to provide or promote the our or third parties’ goods and services

Our goods and services, including but not limited to: instant messaging services, online media services, interactive entertainment services, social networking services, payment services, Internet search services, location and mapping services, application software and services, data management software and services, online advertising services, Internet finance and other social media, entertainment, online games, e-commerce, information and communication-related software and services; and

Third-party goods and services, including but not limited to: Internet services, food and catering, sports, music, movies, television, live performances and other arts and entertainment, books, magazines and other publications, clothing and accessories, jewelry, cosmetics, personal health and hygiene, electronics, collectibles, household utensils, appliances, home decoration and furnishings, pets, cars, hotels, transportation and travel, banking, insurance and financial services, points and rewards programs, and other goods and services that we believe may be relevant to you.

3. To give you notice

We give you notices in connection with a service when necessary (e.g., when we suspend a single service, change, or terminate the provision of a single service due to system maintenance).

If you do not wish to continue to receive messages from us, you may ask us to stop pushing, for example, to ask us to stop sending promotional text messages in accordance with the SMS unsubscribe guidelines, or to set up a mobile device to no longer receive messages from us; However, we do not apply the circumstances where we send messages in accordance with the provisions of the law or the service agreement of the individual service.

4. Help us design new services and improve our existing services;

5. Evaluate and improve the effect of advertising and other promotion activities;

6. Software certification or management software upgrades;

7. To involve you in surveys about our products and services;

8. Other Uses

You understand and agree that after collecting your personal information, we will de-identify or anonymize the data through technical means. The anonymized information will not be able to identify you, and in this case we may use the  anonymized information  for user database analysis or commercialize it without your consent.

Please note that if we want to use your personal information for other purposes not specified in this policy or collect additional personal information that is not mentioned, we will obtain your consent separately through page prompts, interactive processes, website announcements or by other means. Once you give us consent, such additional use will be deemed to be part of this Policy and such additional information will apply to this Policy.

9. Tips about sensitive personal information

Sensitive personal information refers to personal information that, once leaked, illegally provided or abused, may endanger the safety of persons and property, and easily lead to damage to personal reputation, physical and mental health or discriminatory treatment. Some personal information may be considered sensitive due to its specificity, such as your race, religion, personal health and medical information. Sensitive personal information is more strictly protected than other personal information. The above information provided by you or collected by us may contain your sensitive personal information, such as id card number, personal biometric information (including facial recognition features, voiceprints, etc.), bank account numbers, communication records and contents, property information, credit information, whereabouts, accommodation information, health and physiological information, and transaction information. Please be cautious and be aware of your sensitive personal information, and you agree that we may process your sensitive personal information for the purposes and manner described in this Policy.

1.3. Storage   

Pursuant to our contract with you to provide you with the Service, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this Privacy Policy.

Marketing data about you that is collected or shared with third party ad partners (e.g., Facebook and Google) may also be stored and processed on our third party SDK’s (Appsflyer and AppLovin) servers in the United States. Customer support information may also be stored in our third party partner’s servers in the United States.

1.4. Share

Your information can be accessed from outside of where you live by our support, engineering and other teams around the world.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

· Third parties that provide services in support of the Service, including providers of cloud services that process information identified in this policy on their servers for the purpose of providing the Service, to allow you to login through an existing social network account (e.g. Apple), and for the purpose of providing marketing and advertisements on ad partners’ platforms ( Facebook, Google, Apple, Twitter, Snapchat, Appsflyer and AppLovin) and monitor the success of our marketing and advertising programs on such platforms. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.

· Companies within our corporate group who process your personal information in order to operate the Service and conduct surveys for us. All related group companies may only use your personal information in accordance with this Privacy Policy.

· Regulators, judicial authorities and law enforcement agencies and other third parties for safety, security, or compliance with the law. There are circumstances in which we are legally required to disclose information about you to authorities such as to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant. We may also disclose your information to:

o enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;

o detect, prevent or otherwise address security, fraud or technical issues; or

o protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction).

· A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

1.5. Security

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Service or otherwise via the Internet; any transmission of your information which you do at your own risk.

Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.

2. Your Rights

Some jurisdictions’ laws grant specific rights to users of the Service, which are set out in this section.

This section entitled “Your Rights” applies to users that are located in a Relevant Jurisdiction. If you are located in a territory outside a Relevant Jurisdiction, please refer to the Supplemental Jurisdiction-Specific Terms for an overview of your rights and how these can be exercised.

The sub-sections entitled “Access”, “Correction”, and “Erasure” also apply to users that are located in Canada, Argentina and Russia.

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 least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at  [toprank@toprankmob.com] .

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 at  [ toprank@toprankmob.com ] .

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 at [ toprank@toprankmob.com ]. 

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 at [ toprank@toprankmob.com ].

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 defence 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.

Restrict automated decision-making and targeted push

You have the right to restrict automated decision-making and targeted push at any time, and we will provide you with options that are not specific to your personal characteristics.

For example, if we use your data and algorithms to push marketing information, commercial advertisements, etc. (hereinafter referred to as "targeted push"), we will clearly mark “targeted push” and provide you with the option to stop receiving it; When you choose to stop receiving targeted push messages, we will stop. If you do not want to receive commercial advertisements from us, you can cancel at any time by selecting [Settings - Privacy Management - Personalized Advertising], after which we will block personalized push content for you. However, you shall be aware that the push information you receive will no longer be accurate, and it will affect our ability to provide you with more optimized product experience.

You can constrain automated decision-making made by information systems at any time, and in some business functions, we may only make decisions based on non-manual automatic decision-making mechanisms including information systems, algorithms, etc. If these decisions significantly affect your legitimate interests, you have the right to ask us for an explanation and we will provide appropriate remedies.

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 at [ toprank@toprankmob.com ]. 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.

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., service statistics). 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. 

Complaints and Reports

We have set up a complaint channel, and you can feedback through the contact information listed in this policy. Your comments will be dealt timely.

 Protection of personal information of deceased users

After the death of a user (natural person only), his/her close relatives may, for their own legitimate interests, exercise the right to access, copy, correct, delete, etc. personal information of the deceased user through the contact information published in this policy, unless otherwise arranged before the deceased user's death.

Please understand and confirm that in order to fully protect the personal information rights and interests of deceased users, the close relatives of deceased users who apply to exercise this right need to submit the identity documents, death certificate documents, and identity certificates of the deceased users in accordance with the procedures or customer service prompts specified by us

We may from time to time send you announcements when we consider it is 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.

Response

For security purposes, you may be required to provide a written request or prove your identity by other methods. We may ask you to verify your identity before processing your request. We will respond you within 15 working days. If you are not satisfied with our response, you may also contact our customer service staff to make a complaint.

In principle, we will not charge you a fee for reasonable request, but for same or similar repetitive requests that exceed reasonable limits, we will charge you certain fee as appropriate. We may reject requests that are unreasonably repetitive, requiring excessive efforts (e.g., need to develop new systems or fundamentally change existing rules), posing a risk to the legitimate rights and interests of others, or impractical (e.g., involving information stored on backup tapes).

In the following cases, we may not respond to your request in accordance with laws and regulations:

1. Related to Personal Data Controllers' performance of obligations required by laws and regulations;

2. Related to national security or national defense security;

3. Related to public safety, public health, or major public interests;

4. Related to criminal investigation, prosecution, trial, etc.;

5. It is proved that you have subjective malice or abuse of rights;

6. For the purpose of safeguarding the major lawful rights and interests of other individuals, such as their life and property, and it is difficult to obtain the consent of the person;

7. Responding to your request will cause serious damage to the legitimate rights and interests of you or other individuals or organizations;

8. Involving trade secrets.

We will try our best to take any appropriate technical measures to ensure that you can access, update and correct your registration information or other personal information provided when using our services. At the same time, we will require you to authenticate your identity to protect your account security.

3. Services Provided by Third Parties

A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any new owner or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any new owner or other third party involved in such sale or transfer.

4. Children

4.1 By children, we mean users under the age of 13 years old; or in the case of a country where the minimum age for processing personal information differs, such different age. For users located in certain countries, we have listed the relevant minimum age in the table below.

4.2 If you are children, you shall read this Agreement and use the Service under the supervision and guidance of a guardian, and we will collect your personal information from children only after obtaining your parental/guardian consent.

4.3 We do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without parental/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at [ toprank@toprankmob.com ] and we will delete such information.

4.4 If you are the parent or guardian of the user, you may contact us at toprank@toprankmob.com to provide us with your consent of dealing with  your child’s personal Information.

4.5. Before we collect, use, transfer, or disclose children's personal information, we will notify the child's guardian in advance through the contact information of the guardian provided when the child's guardian registers an account for the child, and only after obtaining their consent will the child's information be collected, used, transferred, and disclosed.

4.6  The child's guardian may refuse us to collect, use, transfer and disclose the child's personal information in accordance with this Privacy Policy after receiving above notice, and we may not collect, use, transfer and disclose any of the child's information. However, If we are not authenticated (as well as withdrawal of consent) with child’s necessary personal information, the child  may not be able to use some of our services or may be subject to restrictions in the process of using our services. If the child's personal information is necessary to operate our products, the child will not be able to use our products at all.

4.7 Our staff's access to children's personal information shall be subject to the approval of head in charge of children's personal information protection or his authorized management personnel, and the access shall be recorded, technical measures shall be taken to avoid illegally copy or download of children's personal information.

4.8 The parent or guardian of child may withdraw consent of collect, use, transfer and disclose their child's personal information by contacting us, and we will delete such information.

4.9 If we transfer children's personal information to a third party, we shall conduct a security assessment by ourselves or by entrusting a third-party agency.

4.10 If we stop operating products or services, we will immediately stop collecting children's personal information, delete the children's personal information we hold, and promptly notify the child's guardian of the suspension or termination of products and services.

5. Notification and Modification

In order to provider you with better service, we reserve the right to modify the terms of this Agreement as necessary, and such modifications will become part of the Privacy Policy. You may review the most recent version of these Terms and Conditions on the relevant Services page. If you do not accept the modified Agreement, you should stop using the Services provided by us. Otherwise if you continue to use the Software or Services provided by us after the terms of this Agreement have been changed, you will be deemed to have accepted the modified Agreement. Please check the Services page frequently to see if there are any updates or changes to the Privacy Policy.

6. California

This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:

· Identifiers, such as your name as it appears on your social media profile, open ID / user ID, IP address, phone number, mailing address, email address, and nickname. This information is collected directly from you and your device and from social media platforms if you choose to sign up using a social media account.

· Internet or other electronic network activity information, such as your information regarding your use of the Service, including level, score, date and other device information as described in the main policy. This information is collected directly from you and your device.

· Commercial information about any transactions within the Service such as what products were purchased and how much they cost. This information is collected directly from you and your device and the Google Play or Apple iOS store.

· Other information described in subdivision (e) of Section 1798.80. This information is collected directly from you in the context of being our consumer.

 We collect your personal information for the following purposes:

· To provide you the Service, including offering the Service, maintaining your account, and delivering audio and text messages;

· To process surveys;

· To improve our services, including the functionality of the Service;

· For security and verification purposes, including to prevent and detect fraudulent activity;

· To address and remediate technical issues and bugs.

 We disclose personal information to the following types of entities:

· Other companies within our corporate group who process your personal information in order to operate the Service

· Other companies that provide services on our behalf who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing the services to us

· Regulators and judicial authorities and law enforcement agencies

· Entities that acquire all or substantially all of our business

In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” in the CCPA. 

Rights under the CCPA 

If you are a California resident, you have the right to:

· Request we disclose to you free of charge the following information covering the 12 months preceding your request:

o the categories of personal information about you that we collected;

o the categories of sources from which the personal information was collected;

o the purpose for collecting personal information about you;

o the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and

o the specific pieces of personal information we collected about you;

· Request we delete personal information we collected from you, unless CCPA recognizes an exception; and

· Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the CCPA.   

We aim to fulfill all verified requests within 45 days pursuant to the CCPA.  If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay. 

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may exercise your rights, if any, regarding other data by contacting us at  [toprank@toprankmob.com].

7. European Economic Area (EEA)

When you are located in the EEA, you will have following additional rights:

· To ask for a copy of your personal data to be provided to them, or a third party;

· To lodge a complaint about the processing of your personal data with your local data protection authority in the EEA.

When you are located in the EEA, your personal data will be transferred to recipients in countries located outside the EEA, which do not provide a similar or adequate level of protection to that provided by countries in the EEA.

You hereby expressly consent to the transfer of your personal data to recipients, as described in this Privacy Policy, which are located outside the EEA. You may withdraw your consent at any time.

You can use your accounts of the App to update and correct your personal data. You can also contact us and ask us to update or correct your data.

We do not knowingly collect personal data about children under the age of 13 (in EEA is under the age of 16). If a parent or guardian becomes aware that his or her child has provided us with data without their consent, he or she should promptly contact us and we take reasonable steps to ensure that such data is deleted from our files.