Hong Kong Blackbeard Privacy Policy
HONG KONG BLACK BEARD GAMELIMITED (hereinafter referred to as "BBGame", "we", "us") takes your privacy very seriously and will do our best to protect it. As a company registered in Hong Kong, we comply with the Personal Data (Privacy) Ordinance of Hong Kong. In addition, we seek to comply with the relevant laws of the United States of America, namely: CCPA (California Consumer Privacy Act), COPPA (Child Online Privacy Protection Act), CAN-SPAM (Anti-Spam Act). Therefore, we have developed a privacy policy (Privacy Policy) that includes how we collect, use, share, transfer, and store your information.
Although this Privacy Policy applies to all of our services, we also have developed supplemental privacy policies for certain services. You must comply with these additional provisions when using the relevant services. We will seek your consent again when we carry out any data collection and processing activities beyond the remit of the Privacy Policy.
By using or continuing to use our services, you are consenting to our collection, use, storage and sharing of your information in accordance with this Privacy Policy.
I. Information We May Collect
1.1 We may collect certain personal data, including name, profile picture, phone number, email address, age and location. The following are examples of the types of personal data we may collect.
1.2 Information You Submit Directly: personal information you provide to us when you register for an account with us or use our services, such as your chosen nickname, phone number, email and bank card number. We may also pull information from your associated social media accounts (Facebook, iOS Game Center, Google, etc.) including your user IDs, nicknames and avatars to create your profile. You may also provide us with any optional information (including gender) to personalize your game settings when you create your profile.
1.3 Service Usage Information: Information you share with other parties through our services and information stored when you use our services.
1.4 Third Party Shared Information: Information shared about you that is provided by other parties when they use our services.
1.5 Information Required for Transactions: When you conduct any transactions in our services, we collect information such as your account numbers, orders and payment details to facilitate your transactions and maintain a record of the transactions.
1.6 When you use our services, we may collect the following types of information:
1.6.1 Logs, which means technical information that may be automatically collected by the system through cookies, web beacons or other means when you use our services, including:
(a) Device or software information, such as configuration information provided by your mobile devices, web browsers or other programs used to access our services, your IP address, the versions and device identifiers of your mobile devices.
(b) Information searched or viewed while using our services, such as the terms you have searched, the URL addresses of the social media pages you have visited, and other information and content that you have viewed or requested to view while using our services.
(c) Information about mobile applications (APPs) and other software that you have used, and your usage of such mobile applications and software.
(d) Information about your communications through our services, such as the accounts from which you have communicated, and the time, data and length of the communications.
(e) Information contained in the content you share through our services (metadata), such as the dates, times or locations of any shared photos or videos taken or uploaded.
1.6.2 Location information, which means information about your locations collected when you have enabled the positioning features on your devices and used the relevant location-based services we provide, including:
(a) Your geographical location information collected by means such as GPS or WiFi when you use our services through location-enabled mobile devices.
(b) Real-time information provided by you or other users that contains information about your geographic locations, such as your location information contained in the account information you provide, shared information uploaded by you or others that shows your current or former geographic locations, and tagged geographical information contained in photos shared by you or others.
(c) You can stop the collection of your geographical location information by turning off the positioning features.
II. How We Might Use the Information
2.1 We may use the information that we collect when providing the services to you for the following purposes.
(a) Providing services to you.
(b) For identity verification, customer service, security and risk prevention, fraud monitoring, archiving and backup to ensure the security of the products and services we provide to you.
(c) Helping us design new services and improve our existing services.
(d) Enabling us to better understand how you access and use our services so that we can tailor our responses to your individual needs, such as language settings, location settings, personalized help services and instructions, or provide solutions to you and other users of our services in other respects.
(e) Providing you with more relevant advertising in lieu of commonly placed advertising.
(f) Evaluating the effectiveness of advertising and other promotional and marketing activities in our services and improving them.
(g) Software certifications or management software upgrades.
(h) Inviting you to participate in surveys about our products and services.
(i) In situations where we are required by law to disclose information, including to comply with legal obligations or legal processes, to enforce the terms of our agreements, to deal with matters relating to security or fraud, or to protect our users; and
(j) If we sell or acquire any business, merge, enter into a partnership or sell some or all of our assets, we may disclose your information to the buyer of the relevant business. In such cases, we will always require the relevant purchaser to comply with this Privacy Policy.
2.2 In order to provide our users with a better experience, improve our services or for other purposes to which you have consented, we may use the personal information collected through one of our services to aggregate information or personalize it for our other services, in accordance with relevant laws and regulations. For example, your personal information collected when you use one of our services may be used in another service to provide you with specific content that is relevant to you, rather than generally pushed content. You may also request that we use the personal information you provide and store in one service for our other services if we provide the option to do so in the relevant service.
III. Access and Control Your Personal Information
3.1 We will use our best efforts to implement appropriate technical means to ensure that you can access, update and correct your registration information or other personal information provided when using our services. When accessing, updating, correcting and deleting the aforementioned information, we may require you to verify your identity to safeguard your account.
3.2 According to the applicable laws of your place of residence, you have the right to request that BBGame process your personal data in accordance with your request, including:
(a) Viewing your personal data.
(b) Accessing your personal data.
(c) Correcting (or amending) personal data that you believe to be incorrect.
(d) Erasing (or deleting) personal data.
(e) Requesting electronic copies (or portable versions) of personal data.
(f) Stopping certain data processing practices, including disabling targeted advertising.
BBGame allows all players to submit relevant requests to exercise their rights. Players can submit requests by sending emails to [support_en@bb.game], or through the in-game customer service.
IV. Information We May Share
4.1 We will not share your personal information with any third party, except in the following circumstances.
(a) Sharing with your consent. After obtaining your consent, we may share your personal information with other parties.
(b) Sharing to our affiliates: Your personal data may be shared with our affiliates. As a matter of policy, we will only share as much information as is necessary.
(c) Sharing to our authorized partners: Some of our services are provided by our authorized partners. We may share your certain personal information with our authorized partners to provide better customer service and user experience. We will only process your personal information for specific, explicit and lawful purposes and will only share information that is necessary to provide the services. Our authorized partners are not authorized to use the personal information shared for any other purposes.
4.2 We do not sell or rent your personally identifiable information to any third party, but may use non-personally identifiable information to help advertisers carry out demographic targeting.
4.3 In order to complete payment for orders, deliver goods or services, confirm the status of transactions and provide you with after-sales and dispute resolution services, we may share your accounts, orders, transactions and payment information related to transactions with the above service providers.
4.4 Sharing on the basis of law or reasonable grounds: We may share your personal information where required to do so by law, legal processes, litigation or public and governmental authorities. We will also share your information where there is a reasonable need to do so.
V. Information Security
5.1 We will only retain your personal information for as long as is necessary for the purposes described in this Privacy Policy and for as long as is required by law or regulation.
5.2 We use a variety of security technologies and procedures to protect against the loss, misuse, unauthorized access or disclosure of information. For example, in some services, we will use encryption technology (such as SSL) to protect the personal information you provide. However, due to technical limitations and potential malicious practices, it is not always possible to guarantee 100% security of information, even with all the available efforts in enhancing security measures. You should be aware that the systems and communication networks you use to access our services may experience problems due to factors outside of our control.
VI. The Information You Share
6.1 Several of our services allow you to publicly share information about yourself not only with your social network, but also with all users of the services, such as information you upload or post on our services (including your publicly available personal information, lists you create), your responses to information uploaded or posted by others, and including location data and log information related to such information. Other users of our services may also share information about you (including location data and log information). In particular, our social media services are designed to enable you to share information with users around the world, so that shared information can be delivered widely in real time. As long as you do not delete the shared information, it will remain in the public domain. Even if you delete the shared information, it may be independently cached, copied or stored by other users or third parties not under our control, or kept in the public domain by other users or such third parties. Therefore, please think carefully before you upload, post and communicate information through our services. In some cases, you can filter the users who are able to view your shared information through the privacy settings of some of our services.
6.2 We reserve the right to remove the content you share that is related to drugs, violence, gambling, sexually themed or suggestive, otherwise verbally vulgar, offensive to the public and other users, and unsuitable for general audiences or infringes the intellectual property rights of any third party.
VII. Sensitive Personal Information You Share
7.1 Certain personal information may be considered sensitive personal information because of its specific nature, such as that regarding your race, religion, personal health, medical information, education, professional status, political views, philosophical views, and trade or union affiliation. Sensitive personal information is more strictly protected than other personal information.
7.2 Please note that the content and information you provide, upload or post when using our services (e.g. such as photos about your social activities) may reveal sensitive personal information about you. You need to consider carefully whether to disclose relevant sensitive personal information when using our services.
7.3 Sensitive information that you disclose to "everyone" on the game forums or through game-related social networking sites may be collected and stored by us in accordance with this Privacy Policy, and you agree to the processing of your sensitive personal information for the purposes and in the manner described in this Privacy Policy.
VIII. How We May Collect Information
8.1 In order to make your visit easier, we may identify you through small data files when you use the services we provide, to save you from having to repeatedly enter your registration information, or to help determine the security level of your account. These data files may be cookies, Flash cookies, or other local storage provided by your browser or associated applications (collectively, "Cookies").
8.2 You understand that some of our services are only available through the use of Cookies. You may modify your acceptance of Cookies or refuse Cookies if your browser or browser add-on services allow you to do so, but this may in some cases affect your safe use of the services we provide.
8.3 Web pages often contain electronic images ("web beacons") that help websites count users who visit the pages or access certain cookies. We use web beacons to collect information about your web browsing activity, such as the addresses of the pages you visited, the address of the referring pages you previously visited, how long you stayed on the pages, your browsing environment, and your display settings.
8.4 You can refuse or manage Cookies or web beacons through your browser settings, but please note that if Cookies or web beacons are deactivated, you may not enjoy the best experience with the services and some services may not work properly. Also, you will receive the same number of advertisements, but these will be less relevant to you.
IX. Advertising Services
9.1 We may use your relevant information to provide you with advertisements that are more relevant to you.
9.2 We may also use your information to send you marketing messages via our services, emails or otherwise, to offer or promote our or third parties' goods and services as follows:
(a) Our goods or services, the goods or services of our affiliates and partners, including instant messaging services, online media services, interactive entertainment services, social networking services, payment services, Internet search services, location and mapping services, applications and services, data management software and services, online advertising services, Internet finance, and other social media, entertainment, e-commerce, information and communication software or services (collectively, "Internet Services").
(b) Third party Internet Services providers, and third party goods or services related to: food and dining, 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, housewares, appliances, home decor and furnishings, pets, automobiles, hotels, transportation and travel, banking, insurance and other financial services, membership points and rewards programs, and other goods or services that we think may be relevant to you.
9.3 If you do not want us to use your personal information for the aforementioned advertising purposes, you can ask us to stop using your personal information for those purposes by using the relevant prompts we provide in our advertisements, or the guidelines provided in specific services.
X. Emails and Messages We May Send to You
10.1 Email and message push. When you use our services, we may send emails to you with the information you provide, news or push notifications to your devices. If you do not wish to receive these messages, you can follow our relevant prompts and choose to unsubscribe on your devices.
10.2 Service-related announcements. We may make service-related announcements to you when necessary (for example, when a service is suspended for system maintenance). You may not be able to cancel those service-related announcements that are not promotional in nature.
XI. Exceptions to the Application of the Privacy Policy
11.1 Our services may include or link to social media or other services (including websites) provided by third parties. For example:
You use the "Share" button to share certain content to our services, or you use third-party connection services to log into our services. These features may collect information about you (including your log information) and may place Cookies on your computer in order to function properly as described above.
11.2 We provide you with links to third party services or websites through advertisements or other means of our services. Such third party social media or other services may be operated by the relevant third parties or by us. Your use of such third party social media services or other services (including any personal information you provide to such third parties) is subject to the terms of services and privacy policies of such third parties (not this Privacy Policy), which you need to read carefully. This Privacy Policy applies only to the information we collect and does not apply to the services provided by any third parties or the rules governing the use of information by third parties, and we are not responsible for any third parties’ use of information provided by you.
XII. Use of Our Services by Minors
12.1 We encourage parents or guardians to guide minors under the age of eighteen in using our services, and recommend that minors read this Privacy Policy with their parents or guardians and seek the consent and guidance of their parents or guardians before submitting personal information.
12.2 We recognize the need to provide further privacy protections for personal information collected from children who may use our services. Certain features on our websites and games are age-restricted and therefore not available to children, and we do not knowingly collect personal information from children in connection with those features. When we intend to collect personal information from children, we take additional steps to protect the privacy of children, including:
(a) Notifying parents of our information practices regarding children, including the types of personal information we may collect from children, what we may use that information for, and whether and with whom we may share that information.
(b) Obtaining parental consent to collect personal information from their children or send information about our products and services directly to their children, in accordance with applicable laws.
(c) Limiting the personal information we collect about children to a reasonable and necessary range to participate in online activities.
(d) If you would like to view or change the information we have about your child, please email [support_en@bb.game] (company email).
XIII. California Residents: Your Privacy Rights
13.1 Under California (USA) law, California residents with whom we have established a business relationship may choose not to have personal information about them disclosed to third parties for direct marketing purposes. Therefore, it is our policy not to disclose personal information collected online to third parties for direct marketing purposes without your consent. If you want to opt out at any time after giving your approval, please email [support_en@bb.game] (company email).
13.2 In September 2013, California enacted the California Online Privacy Amendment Protection Act, which requires website operators to disclose how they respond to browsers or other mechanisms used by consumers to provide consumers with choices regarding the collection of personally identifiable information about consumers' online activities over time and across different websites or online services. While some latest browsers have incorporated a "Do Not Track" feature that, when turned on, sends a signal or preference to the websites you visit to indicate that you do not want your online activity tracked, the DNT protocol, which can be implemented across multiple devices and websites, has not been widely adopted. Currently, our computer systems do not support, and cannot operate, the DNT headers that we may receive. Therefore, the choices we offer you regarding the collection and use of personally identifiable information will continue to operate as described in this policy.
13.3 In addition to the details provided in "II. How we might use the information" of this Privacy Policy, California residents may also refer to the following table:
| Categories | Data collected | Reasons for collection | Has the information been "sold" to a third party in the last twelve (12) months? |
| Identifier | [ ] ID(online identifier) | Operate the user account of the corresponding game on the server of [ ] | No |
| Internet Protocol address (truncated) | Analysis (by rough location), fraud detection, personalized advertising, marketing campaigns, performance measurement | Yes (personalized advertising) | |
| Advertising identifier | Personalized advertising, marketing campaigns, performance evaluation | Yes (personalized advertising) | |
| MAC address | Personalized advertising, marketing campaigns, performance evaluation | Yes (personalized advertising) | |
| Email Address | Customer support, opt-in user surveys | No | |
| Categories of personal information listed in the California Customer Records Statute (California Citizenship Code §1798.80(e)) | Not collected | No | |
| Classification characteristics protected by California or federal law | Not collected | No | |
| Business Information | Game installation details, in-app purchase history | Analysis, personalized advertising, marketing campaigns, performance measurement, customer support and fraud detection | Yes (personalized advertising) |
| Biometric information | No | ||
| Internet or other similar networking activities | Game installation details, in-app purchase history, session events | Analysis | No |
| Advertising campaigns (clicks, advertisement engagement) | Personalized advertising | be | |
| Geographical location data | Rough location (inferred from Internet truncated protocol addresses) | Analysis, fraud detection. | No |
| Sensory data | Not collected | No | |
| Professional or employment-related information | Not collected | No | |
| Non-public educational information (accoding to the Family Educational Rights and Privacy Act, 20 U.S.C. § 1232g, 34 C.F.R. Part 99) | Not collected | No | |
| Deduction drawn from other personal information. | Not collected | No |
13.4 Personal information does not include: publicly available information from government records, de-identified or aggregated consumer information, information outside the scope of the CCPA, such as health or medical information or clinical trial data covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), personal information covered by certain industry-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or the California Financial Information Privacy Act (FIPA), and the Driver Privacy Protection Act of 1994.
13.5 We obtain the personal information of the above categories from the following sources:
(a) Directly from our end-users: for example, from customers who contact us for customer support or to provide customer feedback.
(b) Indirectly from our end-users: for example, through the information we collect from end users in the course of providing customer support to them.
(c) Directly or indirectly from activities on our websites or in our games: for example, from APIs and Cookies embedded in our websites or games (as described above) to measure game metrics and progress, time spent playing at each level, and other information relevant to improving our products.
(d) From third parties who interact with us in connection with the services we provide: for example, from third-party analysis or anti-cheat providers, or advertising intermediaries for the purpose of marketing and providing you with personalized advertisements.
13.6 Sharing of personal information. We may disclose your personal information to third parties for commercial purposes, in which case,,we will enter into contracts describing the purposes and requiring the recipients to keep your personal information confidential and not use it for any purposes other than to perform the contracts.
13.7 In the past twelve (12) months, we have disclosed the personal information of the following categories for commercial purposes: identifiers, business information, Internet or other similar network activities, and geographical location data.
13.8 In the past twelve (12) months, we have disclosed your personal information to the third parties of the following categories for commercial purposes: our affiliates, service providers, third parties to whom you or your agents have authorized us to disclose your personal information in connection with the products or services we provide to you, and our suppliers.
13.8 Apart from certain exceptions, you have the right to request that we delete any of your personal information collected from you. Once we receive and acknowledge a verifiable consumer request from you, we will delete (and instruct our service providers to delete) your personal information from our records, unless an exception applies.
13.9 We may refuse your request for deletion if it is necessary for us or our service providers to retain the information in order to:
(a) Complete the transactions where we collect personal information, to provide the goods or services you request, to take reasonably expected actions in our ongoing business relationship with you, or to perform our contract with you in other ways.
(b) Detect security incidents and prevent malicious, deceptive, fraudulent or illegal activities or prosecute those responsible for such activities.
(c) Debug our products to identify and fix errors that impair existing intended functions.
(d) Exercise freedom of expression and ensure that other consumers exercise their right to freedom of expression, or exercise other rights provided by law.
(e) Comply with the California Electronic Communications Privacy Act (California Penal Code § 1546 et seq).
(f) Participate in public or peer-reviewed scientific, historical or statistical research in the public interest, in accordance with all other applicable ethics and privacy laws, where the deletion of the information may render the results of the research impossible or seriously damaged, provided that you have offered informed consent in advance.
(g) Enable internal use that is consistent with consumer expectations based on your relationship with us.
(h) Comply with legal obligations.
(i) Make other internal lawful uses of that information that are compatible with the context in which you provide that information.
13.10 We will not discriminate against you for exercising your CCPA rights. Unless permitted by the CCPA, we will not:
(a) Charge different prices or rates for goods or services sold to you, including by giving discounts or other concessions, or by imposing penalties.
(b) Provide you with a different level or quality of goods or services.
XIV. Scope of the Privacy Policy
14.1 This Privacy Policy applies to all of our services, except for certain specific services which will be subject to separate privacy policies. The separate privacy policies for certain specific services will describe in detail how we use your information in connection with those services and form part of this Privacy Policy. If there is an inconsistency between the privacy policies of the specific services and this Privacy Policy, the former will apply.
14.2 Please note that this Privacy Policy does not apply to: information collected by third party services accessed through our services (including any third party websites); and information collected by other companies or organizations that serve advertisements on our services.
XV. Changes
15.1 We may amend the terms of this Privacy Policy from time to time and such amendments form part of this Privacy Policy. If such modifications result in actual diminishment of your rights under this Privacy Policy, you may choose to discontinue using the services we provide to you. In such cases, if you continue to use our services, you will be deemed as agreeing to be bound by this Privacy Policy, as amended.
XVI. Contact us
16.1 If you have any questions about this Privacy Policy, please contact us through the following ways:
E-mail: support_en@bb.game
Address:16/F,KOWLOON BUILDING, 555 NATHAN ROAD, MONGKOK,KOWLOON,HONGKONG