Privacy Policy

Last modified: May 1, 2025

1. INTRO

We, Happy Buddies, are a technology company that designs, develops and operates mobile games. With this Privacy Policy, we explain how and why we collect, store, use, disclose and otherwise process personal data that we collect via our website, online advertisements and mobile games (collectively, our "Services"). This Privacy Policy does not apply to any other data we collect, such as data we collect offline, from job applicants, or from employees.

If you reside in California, please also see our Supplemental California Consumer Privacy Act Statement. If you reside in the European Economic Area (EEA), United Kingdom or Switzerland (collectively, “EEA+”), please also see our Supplemental EEA+ Privacy Statement.

If you have concerns about providing data to us or it being used as described in this Privacy Policy, please see Section 6 (Control Over Your Information) and Section 7 (Requests to Exercise Privacy Rights) of this Privacy Policy, or contact our Data Protection Officer at happy_buddies@163.com.

2. WHAT TYPES OF PERSONAL DATA WE COLLECT AND HOW WE COLLECT IT

Personal Data Collected Directly from You

We may collect the following types of personal data from you depending on how you use our Services and where you are located:

• Contact Information, including your country or region, name, surname, e-mail address or username.
• User Generated Content, including any files, documents, videos, images, data, or information you choose to upload or transmit through your communications with us or your use of our Services.
• Profile and Gameplay Information, such as your screen name, avatar or profile picture; your in-game progress, scores, achievements and payments (including what you paid for, when and for how much); the competitions you enter; details about how and when you use our Services; and information about your membership and participation in teams on our Services, including messages you send in your team forum.
• Survey Information, including feedback and ratings you provide relating to our Services.
• Inferences, such as information generated from your use of our Services, reflecting predictions about your interests and preferences.
• Parental Information, including your parent’s e-mail address and PIN to be created, only if you activate parental control setting in our Services.

Information We Collect Automatically

Depending on which of our Services you interact with and your location, we may automatically collect and process the following types of personal data:

• Analytics Data, including a user ID that is associated with details about how you use and interact with our games, advertising and other Services; event and conversion data about how and when you use our Services; information about the device you use to access our Services; your Internet Protocol (“IP”) address; browsing history and interactions with our website; operating system and version; internet browser type and version and other details regarding the performance of our Services on your device, including crash logs and diagnostic information (such as battery life, loading time, latency, framerate, or other technical diagnostics);
• Device Data, including your persistent and non-persistent unique device IDs, Identifier For Advertisers (“IDFA”) on iOS, Google Advertising ID on Android, Identifier for Vendor (“IDFV”) on iOS, App Set ID on Android, and game center ID;
• Location Data, including your location based on your Internet Protocol ("IP") address; and

Commercial Information, such as products and services paid for, obtained, or considered, or other consuming histories or tendencies;

Personal Data Collected from Third Parties

Most of the personal data that we collect about you comes directly from you when you play our games or interact with our Services. However, we may also collect personal data from third parties in the following circumstances:

• Social Media: When you interact with our Services through various social media networks, such as when you "Like" our official page on Facebook or follow us, or share our official page’s content on Google, Facebook, X, or other social networks, we may receive some information about you. The data we receive depends on your privacy settings with the social network and may include name, profile picture and friends list. You should always review and, if necessary, adjust your privacy settings on third-party websites, social media networks, and services before making your personal data publicly available and/or linking or connecting your account on one service to other services.
• App Marketplaces: When you download our mobile applications or make in-app payments through the Apple App Store, Google Play or other app marketplaces, we receive personal data about your device, account and payments. We do not receive access to your credit card or bank account data when you make in-app payments through these app marketplaces. The personal data we receive from these third-party companies will depend on your privacy settings with them.
• Information we receive from authentication services you connect to our Service: Some parts of our Services may allow you to log in through a third-party social network or authentication service, such as Facebook, Google and Apple. These services will authenticate your identity and provide you the option to share certain personal data with us, which could include your name, email address and user ID associated with the third party, profile picture, and, in the case of Facebook, the names and avatars of your Facebook friends who are already playing our games. The data we receive is dependent on that third party's policies and your privacy settings on that third-party site. Where available, you will also be able to see which of your friends are playing the same game and their progress through the games (and they will be able to see you and your progress) or access other functionality we make available in our games and other Services, such as inviting friends to play. You can choose not to allow us to access your email address in the Facebook dialog box you see the first time you associate your Facebook account with your profile.

Logging in with Facebook will not allow us to post anything to your page without your permission, and we will not receive any information about your Facebook friends who do not play our games. If you do not wish your Facebook friends to be able to see your progress in our games, you can prevent this by disconnecting your Facebook account from our games and updating your app permissions from within your Facebook settings. If you choose not to connect your profile to your Facebook, Google or Apple account, the personal data that we collect when you play our games will be linked to a randomly generated user ID rather than information that could identify you directly, but we will collect device-level identifiers and other information associated with those identifiers described above. We recommend that you read Facebook's Privacy Policy and review your privacy settings from time to time to ensure that you understand fully how your Facebook data is shared.

• Other Sources: We may also collect personal data from publicly available sources, third parties who obtain your prior consent to send us your personal data, or through transactions such as mergers and acquisitions.

3. PURPOSES FOR PROCESSING YOUR PERSONAL DATA

We may use your personal data for the following purposes, depending on how you interact with our Services and your location:

• To enable us to personalize your in-game profile, provide our games (including the social elements of our games, such as team play and competitions), to ensure that the services you have paid for are activated in the games, and to provide you with player support if you need it;
• To enable us to optimize our games for you and for the device that you are using, as well as to deliver customized in-game events, offers and promotions;
• To manage our organization and its day-to-day operations;
• To verify your identity and entitlement to products or Services when you contact us or access our Services;
• To request your participation in our surveys about our organization, organizations we partner with, and our Services;
• To help maintain the safety, security and integrity of our property and Services, technology assets and business;
• To operate, improve and optimize our games and other Services;
• To personalize our Services, understand our users and their preferences to enhance user experience and enjoyment using our Services and improve our users' experience;
• To provide access to certain areas, functionalities and features of our Services, including social features and multiplayer competitions;
• To communicate with you regarding Services-related information, including confirmations, technical notices, updates, security alerts and support and administrative messages;
• To enable players to communicate with each other in games or on our social media accounts;
• To respond to your comments and inquiries and provide customer support services;
• To prevent potentially prohibited or illegal activities, including cheating or fraud and to protect our players;
• To measure interest in our Services;
• To ensure internal quality control;
• To enable us to comply with laws that apply to us, to prevent fraud, to ensure compliance with our Terms of Use or, where necessary, to defend, exercise or establish our legal rights, including our rights under our Terms of Use;
• To activate, verify and give effect to parental control settings;
• To comply with contractual and legal obligations and requirements;
• To provide support through our customer service channels when requested;
• To conduct internal research and analytics;
• To evaluate and enter into a reorganization, restructuring, merger, acquisition, or whole or partial sale or transfer of our business or assets ("Business Transaction"), and
• To engage in the marketing activities described in this Privacy Policy.

4. DISCLOSURE OF YOUR PERSONAL DATA

We may disclose personal data to the following types of third parties and in the below-mentioned circumstances.

• Other Users in Your Online Community: If you participate in any of our online communities or send a virtual gift of virtual items to other users on our Services, we may disclose your public profile information to other online community members, including your screen name, profile picture or avatar, your in-game scores and achievements, the gifted items, and any other information you choose to provide or make public.
• Contests, Sweepstakes, and Survey Providers: We may disclose personal data to third parties who assist us in delivering our contests, sweepstakes, or survey offerings and processing the responses.
• Service Providers: We may disclose your personal data to our service providers. The types of service providers (data processors) to whom we entrust personal data include companies that (i) provide us with IT and related services; (ii) assist us with customer service activities; (iii) provide analytics and search engine services that assist us in the improvement and optimization of our Services; and (iv) provide any supporting activities in connection with our Services. We have executed appropriate contracts with the service providers that prohibit them from using or sharing personal data except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements.
• Disclosures to Protect Our Rights, Your Rights or the Rights of Others (e.g., as Required by Law and Similar Disclosures): We may access, preserve, and disclose your personal data to third parties, such as legal advisors and law enforcement authorities, if we believe doing so is required or appropriate: (i) to comply with law enforcement or national security requests and legal processes, such as a court order or subpoena; (ii) to respond to your requests; (iii) to protect your, our or others' rights, property or safety; (iv) to enforce our policies or contracts; (v) to collect amounts owed to us; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; (vii) in connection with the establishment, exercise, or defense of legal claims; or (viii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
• Ad Networks and Advertising Partners: We work with third-party ad networks and advertising partners to deliver advertising and personalized content on websites and services that we do not operate, and across other devices. These parties may collect information directly from a browser or device when an individual visits our Services through cookies or other data collection technologies. This information is used to provide and inform our targeted advertising, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. Please see Section 5 (Targeted Advertising) below for more information. Where permitted by applicable laws, we may also disclose personal data to our advertising partners to help them send you information that we believe will be of interest to you.
• With Your Consent: We may disclose personal data about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual's consent or direction, we may post their testimonial on our websites or other Services.
• Sale of Assets and Change of Control: We may disclose personal data to potential acquirers of our business assets and their representatives for the purposes of evaluating and entering into Business Transactions.

5. TARGETED ADVERTISING

We rely on third-party advertising networks and other advertising technology providers (“AdTech Providers”) to serve targeted online ads at users of other companies’ websites, games and online services. These ads are targeted at users that we or our AdTech Providers believe would be interested in our Services. To enable these targeted ads, we may disclose the following types of personal data about players of our mobile games and viewers of our ads to our AdTech Providers:

• Identifier For Advertisers (IDFA) and Google Advertising ID
• IP address
• What Services of ours they have used
• Date and time of when they used our Services
• Inferred interests

Our AdTech Providers use this information to make the online ads users see more relevant to their interests and provide advertising-related services such as reporting, attribution, analytics and market research. Our AdTech Providers combine the personal data that we disclose to them with data they may have collected about the same individuals elsewhere, such as when those individuals use other websites and online services that rely on the same AdTech Providers. This Privacy Policy does not apply to the collection and use of your personal data by our AdTech Providers. We recommend that you review our AdTech Providers’ privacy policies for more information. A list of our AdTech Providers and their privacy policies can be found here.

6. CONTROL OVER YOUR INFORMATION

There are a variety of ways in which you can control how our Services process your personal data.

Delete or Reset our Services: If you delete our games from your mobile device, we will no longer collect personal data via our games on your mobile device and any data associated with our Services that is stored on your device (which may include your game progress) may be deleted. However, we may still process any personal data we collected from you before you deleted our games from your mobile device. You can also reset your mobile advertising identifier using your phone, in which case you will appear to us and our advertising partners as a new user that is not associated with any prior activity or data.

Deactivate Your Account: Should you wish to deactivate your account completely, you can disassociate your Facebook account from our mobile games and delete our games from your mobile devices. Please note that if you completely deactivate your account, all your progress in our games and any unspent virtual items will be lost, and we may not be able to restore them in the future. We may still process personal data we collected from you before you deactivated your account.

Change our Services’ Access to Your Device Information: You may control our Services' access to your device information through your "Settings" app on your device. For instance, you can withdraw permission for our Services to access your network devices and location data and to integrate with your other applications.

Deactivate Push Notifications: If you activate our push notifications at the level of your device, we may occasionally send you push notifications through our mobile applications with game updates, high scores and other notices that may be of interest to you. You may at any time opt-out from receiving these types of communications by changing the relevant settings on your mobile device.

Targeted Advertising:

• If you reside in the EEA, UK, Switzerland, Türkiye or South Korea, we request your consent to engage in the targeted advertising activities described in Section 5 (Targeted Advertising) when you first launch our games. If you consent, you may subsequently withdraw your consent at any time by going to Settings.
• If you reside in the U.S., you can opt out of the targeted advertising activities described in Section 5 (Targeted Advertising) by going to Settings. If you opt out of targeted advertising, you may still see ads for our products and Services, but that advertising will not be targeted using your personal data.
• You can also choose to prevent your device's ad identifier from being used for interest-based advertising, or you can reset your device's ad identifier by changing your device's settings. Settings vary from device to device, but you will usually find the ad identifier settings under "privacy" or "ads" in your device's settings.
• To update your advertising preferences with Facebook, you will need to log in to your account on Facebook and update your settings there.

Submit a Request to Exercise Privacy Rights: You may have privacy rights under the laws that apply to you or us. Please see the following section for more information about how to submit a request to exercise privacy rights you may have.

7. REQUESTS TO EXERCISE PRIVACY RIGHTS

Depending on the privacy laws that apply to our use of your personal data, you may have some or all of the following privacy rights:

• Access to personal data: You may have the right to access your personal data that we use.
• Correction or deletion of personal data: You may have the right to ask us to correct or complete your personal data if it is wrong or incomplete. You may also have the right to ask us to delete your personal data when certain conditions apply.
• Restriction on processing personal data: You may have the right to ask us to restrict the use of your personal data when certain conditions apply.
• Object to processing of personal data: You may have the right to object to certain uses of your personal data by us when certain conditions apply.
• Portability of personal data: You may have the right to receive your personal data in a structured and commonly used format so you can use this data with another company when certain conditions apply.

Right to opt out of:

• Targeted advertising: If you play our games, we may use your personal data for targeted advertising purposes as described in Section 5 above. If you reside in certain states in the United States (including California, Colorado, Connecticut, Delaware, Indiana, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia), you have or will soon have the right to opt out of our use of your personal data for these targeted advertising purposes. You may opt out in-game by going to Settings.
• Selling: Some of the laws that apply to our processing of personal data qualify some of our disclosures of personal data to our AdTech Providers as “selling” personal data. You may have the right to direct us not to sell your personal data to third parties.
• Right to non-discrimination: You may have the right not to receive discriminatory treatment for exercising these rights. However, please note that if the exercise of these rights limits our ability to process personal data (such as in the case of a deletion request), we may no longer be able to provide you with our products and services or engage with you in the same manner.
• Right to appeal: If we decline to take action on a request exercising one of your rights set forth above, you may have the right to appeal our decision. In these cases, we will notify you providing our reasons for denying the request and instructions for how you can appeal the decision.
• Right to Withdraw Consent: There are certain circumstances where we request your consent to process your personal data. In these instances, if you have provided consent, you may have the right to withdraw your consent at any time. If you withdraw your consent, this will not affect the lawfulness of our use of your personal data before your withdrawal.

To submit a request to exercise your privacy rights, you can contact us by any method described in the Contact Us section below. In your request, please describe what rights you are exercising and how you would like us to assist. We may need to request specific information from you to help us verify your identity and that you have the right to request what your are requesting. These are security measures to ensure that we do not disclose personal data to any person who has no right to receive it, or otherwise process the data in unauthorized ways. We may also contact you to ask for further information about your request to clarify the scope of your request and speed up our response. We will respond to requests to exercise privacy rights according to applicable laws.

8. CHILDREN

We do not intend to or knowingly collect personal data from children aged 12 and under. If a child aged 12 or under has provided personal data to us, we encourage the child's parent or guardian to contact us to request that we remove the personal data from our systems. If you believe that we might have any information from or about children, please contact us.

9. SECURITY

We maintain physical, technical, electronic and procedural measures intended to protect personal data from unauthorized processing, including firewalls, data encryption technologies, internal data security protocols and data protection and processing agreements with organizations that receive your personal data from us. However, no server, computer or communications network or system, or data transmission over the internet can be guaranteed to be 100% secure. As a result, while we strive to protect your personal data, we cannot ensure or warrant the security of any personal data you transmit to us or through our Services.

10. THIRD-PARTY WEBSITES

Our Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Policy, this Privacy Policy does not apply to, and we are not responsible for, any personal data practices of third-party websites and online services or the practices of other third parties. To learn about the personal data practices of third parties, please visit their respective privacy policies.

11. RETENTION

We retain your personal data only as necessary for the purposes for which the personal data is processed or for legal requirements. The length of time for which we retain personal data depends on the purposes for which we collect and use it and how long we need to retain it to comply with applicable laws (including for the purpose of satisfying any legal, regulatory, tax, accounting or reporting requirements), to establish, exercise or defend our legal rights, or to make the data available to judges and courts or the competent public authorities. Once the personal data is no longer necessary for the purposes for which we collected it, we will delete it.

12. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time, and we will post the updated Privacy Policy on this page. When we make changes to this Privacy Policy, we will change the date at the beginning of this Privacy Policy. If we make material changes to this Privacy Policy, we will notify individuals by email to their registered email address, by prominent posting on our Services, or through other appropriate communication channels. Any new policy will be effective from the date it is published by us.

13. CONTACT US

If you have any questions about our privacy practices, personal data processing activities, or would like to exercise your rights under privacy laws, you may contact us at happy_buddies@163.com.