What information do we need to be able to provide the Service?

· If you use the Websites to sign up for the Service, we may collect certain information from you, such as your email address, device information (whether you use an iOS or Android device, and device model), IP address, and your gaming habits. If you use HOK Camp, we may collect information from you, such as game data, in-game friend lists and Open ID, to allow to use various related functions,

· If you register an account for the Service then we will need some information from you to set this up. If you choose to set up your profile using a social media account, we also collect information provided by your social media account service provider to automatically generate your profile, including your name and user ID from that social media account. We will also generate an Open ID, which is an internal ID for your account.

· To maintain the smooth operation of the Service (which includes activities such from addressing bugs or malicious activity through to improving functionality), we will process customary device and network information.

· We will also collect information for analytics purposes, to send you push notifications, to facilitate your participation in activities and events, and to ensure the security of the Service.

· If you need to get in touch with us, we will retain some information so that we can review and respond to your concerns.

More Information.

How will we use your information?

· We will use your information to provide the many functions that comprise the Service. We also use your information for account verification, security purposes, to support and improve the Service, to organize promotional activities and events, to monitor our marketing initiatives, resolve user queries, and to comply with our legal obligations and enforce our legal rights.

More Information.

Who do we share your information with?

· We use third parties and work with our affiliates to help us deliver the best possible experience (such as cloud services to back up your data and support services, payment services, analytics, push notification and ad attribution providers, and providers that carry out surveys).

· All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Service (i.e., to fulfil the purpose(s) described above).

· In some cases we may be required by a court or be under a legal obligation (such as a valid search warrant or subpoena) to disclose certain information.

More Information.

Where do we process your information? 

· Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy.

· We have servers for the Service in Singapore and Brazil. We also have support, engineering and other teams who may support the Service, including from Singapore and the People’s Republic of China. Certain personal information processed for payments, data analytics, push notification and marketing purposes may also be processed by our third-party partners on their servers in Europe, the United States and Singapore.

· For EEA/UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses or taking into account adequacy assessments.

More Information.

How long do we keep your information?

· Unless otherwise required or permissible by applicable laws, we retain your information for the period during which you maintain an account for the Service, or for so long as the information is needed to fulfil the purpose for which it was collected, after which time your data is deleted (as further described in this Privacy Policy). We then delete or anonymise such data, in accordance with applicable laws.

More Information.

How can I exercise my rights over my information?

· Certain jurisdictions offer users specific rights with respect to their information, so you may have a right to access or receive a copy of your data, or to delete your data or restrict or object to our processing of your data. 

More Information.

How will we notify you of changes?

· Changes to this Privacy Policy will be posted here. We will also notify you of changes in accordance with relevant legal requirements.

More Information.

Personal Information

Use

Legal Basis

In relation to the Websites

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

LEVEL INFINITE PASS account log-in information: email address, password, user ID, nickname, user token, open ID, country, date of birth (we do not store your date of birth on our servers)

We use this information to allow you to register, create your account for the Website, and receive notifications of the Game.

Necessary to perform our contract with you to provide you with updates and allow you to register for the Game.

Email (Newsletter)

We use your email to send you our newsletter if you choose to subscribe. You may unsubscribe any time.

We collect this information with your consent.

HOK Camp: browser language, location and device information 

Please note that this data is only stored on your device, and is not retained on our servers.

We use this information to detect your location to provide you with the relevant content specific to your region, and to support your use of certain features on our Websites.

Necessary to perform our contract with you to provide the Service.

HOK Camp reading game data function information: Game data (such as game records, number of games, lineups, MVPs, Open ID), username, nickname and other related game data information

We use this information to allow you to view and share your in-game match data on HOK Camp.

Necessary to perform our contract with you to provide you with information about your matches within the Service.

HOK Camp add friend function information (if applicable in your region): In-game friend list and friend relationships, Open ID

If you take part in our Website-based events (where available in your region), we use this information to allow you to add friends and display friend relationships in the Service.

Necessary to perform our contract with you to provide the Service and connect you with your friends.

HOK Camp performance publication information: Open ID, match-related data

We use this information to allow you to display your match history in the HOK Camp page and to allow other players to view your performance.

Necessary to perform our contract with you to provide the Service.

HOK Camp sharing statistics information: Country / region, gender, online time, online ID

We use this information to allow you to display various statistics on the HOK Camp page.

Necessary to perform our contract with you to provide the Service.

Tlog Data Reporting: IP address, page performance information (page view and user view statistics), selected region and language information

We use IP address and page performance information to analyse global player allocation, and to monitor the effectiveness of our advertisements.  

It is in our legitimate interests to use IP address and page performance information to monitor the success of our advertising and marketing programs.

We use selected region and language information to provide you with the relevant content specific to your region.

Necessary to perform our contract with you to provide the Service.

Real User Monitoring Data Reporting: IP address, device information (iOS version, Android version, PC browser version)

We use this information for the purposes of troubleshooting, to monitor performance of Service, and to monitor the effectiveness of our advertisements.

It is in our legitimate interest to monitor the performance of the Service to ensure the functioning of and improve the Service, and to monitor the success of our advertising and marketing programs.

Google Analytics User Acquisition Data Reporting: IP address, device information (screen dimensions, system OS, system language, user agent)

We use this information for user acquisition purposes and to monitor the effectiveness of our advertisements.

It is in our legitimate interest to allow us to acquire users and to monitor the effectiveness of our advertisements.

In relation to the Game

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

Account Creation (guest log-in): nickname, guest ID

We use this information to create your account for the Service in accordance with your request and to facilitate your use of Service features.

Necessary to perform our contract with you to provide the Service.

Account Creation (if you choose to log in via your social media account):

· Facebook: Name, Facebook ID, profile picture, user token, OpenID, email address associated with the account

· Google Play: User ID, nicknames, profile picture, user token, OpenID, email address associated with the account

· Apple: User ID, nicknames, profile picture, user token, OpenID, email address associated with the account

· X: User ID, nickname, profile picture, user token, OpenID, email address associated with the account

· Discord: User ID, nickname, profile picture, user token, OpenID

· VK: User ID, nickname, profile picture, user token, OpenID

· QQ: OpenID

· Weixin: OpenID, nickname, profile picture

· WeChat: OpenID, nickname, profile picture

If you create and log in via your social media account, your social media profile picture will be set as your Service profile picture by default. You can elect to change your default profile picture to other options in the Service.

We use this information to create your account for the Service in accordance with your request and to facilitate your use of Service features.

We will use your social media account profile picture as your default profile picture in the Service.

If you choose to log in via Facebook, Google Play, Apple or X, we also collect the email address associated with your social media account for account security purposes.

If you choose to log in via Discord, you will have to option to link your Discord ID to the game.

Necessary to perform our contract with you to provide the Service.

It is in our legitimate interest to ensure enhance account security by collecting the email addresses for log-ins via Facebook, Google Play or X.

Account Creation (if you choose to log in via your LEVEL INFINITE PASS account or via email): UID, token, email, password.

In addition, we will disclose information on whether you are under 18, or 18 or older, and your account region information to your LEVEL INFINITE PASS account, if you choose to create a LEVEL INFINITE PASS account and bind your existing game account to it.

We use this information to create your account for the Service in accordance with your request, to facilitate your use of Service features and to ensure consistency across accounts.

Necessary to perform our contract with you to provide the Service.

The sharing of whether you are under 18 or not and your account region information is based on our legitimate interest to ensure compliance and consistent service.

Account Creation (general): Device ID, OpenID, token, selected country/region at sign-up, and installed browsers and social media apps

Regardless of your chosen account creation method, we will process the above data.

We use this information to remember choices (e.g. country/region) you made at sign-up, to improve your experience and to monitor the performance of the Service.

Installed browsers and social media apps will be processed device-side only to display relevant log-in channels and will not be transferred to us.

It is in our legitimate interest to improve user experience and to monitor service performance.

Cloud Gaming Login and IP Data:

· Login transmission via your relevant social media account (user ID, token for business) or guest account (guest ID)

· IP address

We use this information to enable you to use the Service from a cloud server without downloading the Service in accordance with your request.

Necessary to perform our contract with you to provide the Service from a cloud server without downloading the Service.

Account Deletion (in-app): email address, verification codes, region, OpenID, and user token

Available via a customer-service interface or through the settings page

We use this information to send verification codes via email, in order to delete your account for the Service in accordance with your request.

Necessary to perform our contract with you to provide the Service.

Compliance Data: OpenID, token, region, user name

We use this information to verify your eligibility to use the Service.

It is in our legitimate interest to ensure compliance with applicable age-gating rules.

Friend Information (manually added by you or imported from your social media profile)

We use this information so that you can connect with your friends and use Service functions with a social element.

Necessary to perform our contract with you to provide the Service and connect you with your friends.

Facebook Play with Friends information: Open ID, nickname, avatar, rank level, online status

We use this information so that you can use Facebook’s Play with Friends feature and use the Service with a social element.

Necessary to perform our contract with you to provide the Service and connect you with your friends.

Friend Suggestion Information: 

· your phone number (if you to bind your phone number or WhatsApp), IP address, OpenID, and WhatsApp nickname (if you bind your WhatsApp)

· phone numbers and display names of your address book contacts

· suggested friend information: address book display name, game profile data (such as nickname, profile picture, gender, level, ranking, online/offline status and link to profile page)

If you choose to use this feature, this information is used to discover address book contacts that also play the game and use this feature to suggest friends that you may know.

Necessary to perform our contract with you to provide the Service and connect you with your friends.

It is in our and your legitimate interests to connect you with your friends to momentarily check and filter out address book contacts who do not play the game or use this feature.

Customer Support: name, OpenID, device information, email address (if contacted via email), details of ticket, complaint and handling, content of correspondence, game data and details of gameplay under review, IP address

We use this information to improve our services and provide troubleshooting, such as addressing and remediating technical issues and bugs.

Necessary to perform our contract with you to provide and support the Service.

Survey Information: User and contact information (age, gender, email, address, mobile number, select geographic location (country)), device information (phone model, device configuration preference), game information (game habits and preferences (including recently played games, game duration and favourite game categories and experience, language preference), and other content of survey responses user may choose to provide

If you choose to participate in an in-game survey via IMUR, we will only receive an aggregated report of the above data.  

We use the survey information to allow you to participate in surveys about the Service to improve the Service.

We collect this information with your consent.

Email (Newsletter)

We use your email to send you our newsletter if you choose to subscribe. You may unsubscribe any time.

We collect this information with your consent.

Web Feature Information: Account information and preference settings

We use this information to create your account for the Services in accordance with your request and to facilitate your use of the Service.

Necessary to perform our contract with you to provide the Service.

Highlights video sharing information: Video of previous match created by our algorithm, nickname, date of match

We use this information to allow you to share your highlights videos with friends where you turn this feature on.

Necessary to perform our contract with you to provide the Service and share your gameplay with your friends.

YouTube sharing information: Game results, personal homepage, highlights video, team games, social media account (if linked)

We use this information to allow you to share game content to YouTube.

Necessary to perform your contract with you to provide the Service and share your gameplay online.

Version switch information: Open ID, list of heroes and skins owned, registration time and number of games, noble level, account level, ranking stage, hero proficiency

If you switch from the Mainland Chinese version of the Game to the international version of the Game and wish to move your assets, we use this information to:

· verify whether you are the same player in both versions;

· confirm your asset status under the Mainland Chinese version of the Game; and

· issue a corresponding asset in the international version of the Game.

Necessary to perform your contract with you to move your assets where you switch from the Mainland Chinese version of the Game to the international version of the Game.

Circle function information: Circle’s name, avatar through uploaded photo, introduction, bulletin, chatting channel, flag and city, nickname

We use this information to provide you with the function of creating circles and playing with friends.

Necessary to perform our contract with you to provide the Service and connect you with your friends.

In Relation to Other Activities

Information you provide to us (either directly or through a third party) to take part in our activities, events or programs
We will provide you with additional notice if the information collected for a specific activity, event or program exceeds the scope below.

Promotional activities and events information: If you take part in our promotional activities or events, we will collect information from you to facilitate your participation, such as user ID, contact information, address, payment details, purchase information, engagement information, game assets and consumption information, participation records, rewards information and gameplay statistics and information, and other similar personal information.

If you need to register an account to take part, we will collect your account registration or log-in information, including your social media information if you choose to log in via third-party social media. Your game account information may also be used to facilitate your participation.

Where our activities and events have a social element, we may also collect your friend list (either submitted by your manually or from the Service or social media).

We may also take videos and photos of the event.

We use the promotional activities and events information to allow you to participate in our activities and events.

We may publish videos and photos of the promotional activities and events on our social media accounts with your permission.

Necessary to perform our contract with you to allow you to participate in our activities and events. Videos and photos of the event are processed with your consent.

Interaction with Honor of Kings WhatsApp Business Account: WhatsApp number, nickname, role ID, team ID, referral code (if relevant), event history (i.e., user interaction log) and event results

We use this information to facilitate your interaction with the Honor of Kings WhatsApp Business Account, to allow you and your friends to participate in events and receive rewards, to analyze the effectiveness of the events, and to fix bugs.

Necessary to perform our contract with you to provide the Service if you choose to interact with the Honor of Kings WhatsApp Business Account and participate in related events.

It is in our legitimate interest to allow us to acquire users and to monitor the effectiveness of our events.

Content creator program information (HOK Studio): If you register to take part in any of our content creator programs in relation to the Game (including HOK Studio), we will collect information from you for selection purpose and to facilitate your participation if you are selected, such as your name, user ID, your profile picture or avatar, your nickname, UID, email address, social media information, information relating to your gaming experience, contact information, payment details and your submissions.

After registering with HOK Studio, if you wish to register for and/or participate in the "CreatorHub" service in relation to the Game, we may share this information with CreatorHub. Please be aware that it operates independently and has its own distinct Privacy Policy. The CreatorHub privacy policy available here will apply to the processing of data by CreatorHub.

We use content creator program information to select participants to join our content creator program, and to allow you to participate in the same if you are selected.

Necessary to perform our contract with you to provide our content creator program.

eSports events and tournaments information: If you take part in our eSports events and tournaments, we will collect information from you to facilitate your participation, such as your name, eSports club, contact information, travel or identification documents, nationality, residence information, age information, your game data such as your username, your device information, gameplay statistics and information, information submitted by you to receive prize such as your payment details, and other similar personal data.

We may also take videos and photos of the event.

We use eSports events and tournaments information to facilitate your participation in the same.

We may need to collect your travel or identification documents for the purposes of verifying your identity to ensure the fairness and security of our eSports events and tournaments. We may also use such information to help arrange accommodation and transportation, if travelling is required for your participation. If your consent is required for the collection of this under application local law, we will seek your consent separately.

We may publish videos and photos of the event on our social media accounts with your permission.

Necessary to perform our contract with you to provide eSports events and tournaments.Where we are required under applicable local law to collect the information on the basis of consent, we will seek your consent. Videos and photos of the event are processed with your consent.

Offline community gathering information:

· Contact information: Discord ID, user ID, email address, phone number, in-game nickname and ID; and

· Videos and photos of the event, which will capture the participants, their interactions, name, team name, game ID, introduction of participants and their clubs (including player profile and club/team profile, player portrait), game data (including game moves & game results), tournament points and ranking, interviews and surveys.

If you take part in our offline community gatherings (where available in your region), we will use this information to contact you regarding the gathering, to allow you to participate in the gathering, to maintain records of and report on the gathering, and to publish this on our social media accounts with your permission.

Necessary to perform our contract with you to provide offline activities relating to the Service.

It is in our legitimate interests to promote and report on such offline community gatherings.

Where we are required under applicable local law to collect the information on the basis of consent, we will seek your consent. Videos and photos of the event are processed with your consent.

CBT Account Information: Your account information from Honor of Kings’ Closed Beta Test, namely the related OpenID, CBT & Service account registration information and ID.

In order to deliver reward to you for activities that you signed up for during the test.

Necessary to perform our contract with you to deliver rewards.

In-game event information: User ID, contact information, address, and payment details

We use this information to allow you to participate in lucky draws and to deliver prizes to you if you win such lucky draws.

Necessary to perform our contract with you to deliver rewards.

Information generated as part of the Services and Websites

Account Creation & Authentication: IP address, OpenID, system time

We use this information to create your account for the Service and Websites in accordance with your request, and authenticate your log in.

Necessary to perform our contract with you to provide the Service.

Game Data: OpenID, IP address (only kept in aggregated format for server improvement), device model, game play statistics (e.g. level, heroes, scores)

We use this information to allow you to use the Service and its features.

Necessary to perform our contract with you to provide the Service.

Profile Information: Basic profile information (profile picture, nickname, labels, honours, past gameplay statistics, number of skins and heroes) and details on gameplay statistics, heroes, skins, honours, and social interactions

We use this information to create your profile page which you and other players can visit.

Necessary to perform our contract with you to provide your profile page.

Geographic Matchmaking (optional): GPS information (approximate distance, but no exact location shown)

If you choose to use this feature, we use this information to allow you to connect with users near your location. Your and users’ exact location GPS information is not shared with other users.

Necessary to perform our contract with you to allow you to connect with users nearby.

Game room (optional): OpenID, IP address, system time, geographic matchmaking information (if enabled and as described above)

If you choose to use this feature, we use this information to allow you to play with nearby users.

Necessary to perform our contract with you to allow you to connect with users nearby.

Friend Recommendation (optional): IP address, OpenID, common friends, suggested friend information (whether you are friends on social media accounts bound to your account, game profile data such as nickname, profile picture, gender, level, ranking, online/offline status and link to profile page)

If you choose to use this feature, we use this information to recommend to you, and recommend you to, other players that you may know.

Necessary to perform our contract with you to allow you to connect with other players that you may know.

Analytics, Crash Reporting & Performance, game speed acceleration and network diagnostics:  

· User Region: country, province, city, carrier id, region, IP address

· Device Information: application version, application ID, battery information, WiFi strength, available space, network type, OS information, carrier, country code, device language, device resolution, brand, manufacturer, device type, device model, device identifiers, RAM, ROM and CPU information, GPU information, advertising ID, game frame information, mobile signal strength, network round trip time, network bytes received/sent, login/pay step event information, XWID

· OpenID, aggregated IP address, device model, system version information, and base station ID, User Agent

We use this information to perform general and game data analytics, including for the purposes of tracking which advertisements have been successful for future campaigns and for payment to advertising partners (such analytics also includes reviewing game performance and payments) and for the purposes of error-fixing, troubleshooting, debugging, services and website stability assurance, game speed acceleration and network diagnostics.

It is in our legitimate interest to carry out data analytics to track which advertisements have been successful for future campaigns and for payment to advertising partners, and for the purposes of solving game crashes, debugging, services and websites stability assurance, game speed acceleration and network diagnostics.

Cloud Gaming Resource Allocation Data: IP address, and for game activities, token

We use this information to allocate cloud resources if you would like to use the Service from a cloud server without downloading the Service.   

Necessary to perform our contract with you to provide the Service from a cloud server without downloading the Service.

Cloud Gaming Performance Data: IP address, device model, device System-on-a-Chip model  

We use this information to carry out analytics on the performance and functioning of the Service on the cloud server in your city or region and of the Service’s video decoding capabilities, and to improve the functionality of the Service.   

It is in our legitimate interest to ensure the functioning of, and improve, the Service.

Cloud Gaming Network Data: WiFi strength, WiFi connection speed, whether device supports 5G, WiFi frequency, network round trip time (mobile network and WiFi), possible number of devices using same WiFi

We use this information to provide better user experience and to improve the Service.

It is in our legitimate interest to improve user experience and the Service.

Cloud Gaming Duration Data: (via app) stay time on web browser session, token, token key

We use this information to determine your gaming duration (i.e., the amount of time you have spent on playing the game from a cloud server without downloading the game), and to calculate the remaining time you have (per day) to play the game from a cloud server without downloading the game (if applicable).

It is in our legitimate interest ensure the integrity of the Service by ensuring time limits are not circumvented.

Cloud Gaming Duration Data: OpenID

We use this information to ensure time limits or time extensions for playing the game are implemented and time limits are not circumvented.

It is in our legitimate interest ensure the integrity of the Service by ensuring time limits are not circumvented.

Necessary to perform our contract with you to provide time extensions for use of the Service from a cloud server without downloading the Service.

Cloud Gaming Status Data: OpenID, last login time

We use this information to check if your account is active.

Necessary to perform our contract with you to provide the Service from a cloud server without downloading the Service.

Cloud Gaming Log Data: User ID, OpenID, IP address, device model, device System-on-a-Chip model, WiFi strength, WiFi connection speed, WiFi frequency, whether device supports 5G, possible number of devices using same WiFi, token, token key

We use this information for troubleshooting to improve the Service and user experience.   

It is in our legitimate interest to improve the Service and user experience.

Xiaomi Cloud payment information:

· Identity: Open ID, role ID, country, Midas order ID, Xiaomi order ID

· Device information: CPU model, device model

· Other: Currency, SDK version, application version, network type, amount

We use this information to allow you to make in-app purchases on Xiaomi.

Necessary to perform our contract with you to facilitate your payments without downloading the Service.

Push Notifications (Firebase):

· Device information: Device model, device name, device manufacturer, running process information

· Other: SDK version, application package name, application version, operator name, network type

We use this information to send you push notifications during the Services.

Necessary to perform our contract with you to provide the Services.

Transaction Information (Midas in-app purchases – via Google Play, App Store, Xiaomi GetApps or Huawei AppGallery): OpenID, role ID, country, order IDs, device information (CPU model, device model), currency, SDK version, application version, network type, amount, IDFV

We use this information to facilitate your transactions as part of the Service and maintain transaction records.

Necessary to perform our contract with you to facilitate your transactions as part of the Service and maintain transaction records.

Service Information & Connection Management Data: OpenID, device name, device model, login channel ID

We use this information to allow game servers to communicate.

Necessary to perform our contract with you to provide the Service.

Game Update & SDK Data: OpenID, device information (device name and model, login channel ID)

We use this information to detect and download version updates and manage integrated SDKs.

Necessary to perform our contract with you to allow you to play the latest version of the Service and use all functions of the Service.

Text Chat Data

We use this information to facilitate the posting of your communications with other users.

We also process text chat data to identify, for example, unsolicited commercial communications, including plug-in sales and advertising, spam, harmful communication, exploits, bullying, harassment, threats of violence or conduct which is hateful, harassing, abusive, racially or ethnically offensive, defamatory, humiliating, threatening, profane or similarly objectionable.

Necessary to perform our contract with you to facilitate the posting of your communications with other users.

It is in our legitimate interest to ensure the security and integrity of our service and the safety of our users.

Voice Chat Data (real-time voice): OpenID, device information (device name, device model, client exports IP, device brand, UUID, system time), SDK version, IP address, network type, model

Please note voice files are only stored on your device, and is not processed by our servers

We use this information to facilitate your communications with other users.

Necessary to perform our contract with you to facilitate your communications with other users.

Voice Chat Data (voice messages): OpenID, device information (device name, device model, client exports IP, device brand, UUID, system time), SDK version, IP address, network type, model, voice file, report data

We use this information to facilitate your communications with other users.

Necessary to perform our contract with you to facilitate your communications with other users.

Voice Chat Data (for in-game safety): Voice files (as described above) are processed and only stored on your device, and is not processed by our servers, except for on receipt of a report or complaint.

We store the voice messages and the last 30 or 60 seconds of the real-time voice chat files on your device. In case of a report or a complaint we process such voice chat data on our servers to identify, and to improve tools we use to identify, for example, unsolicited commercial communications, including plug-in sales and advertising, spam, harmful communication, exploits, bullying, harassment, threats of violence or conduct which is hateful, harassing, abusive, racially or ethnically offensive, defamatory, humiliating, threatening, profane or similarly objectionable.

It is in our legitimate interest to ensure the security and integrity of our service and the safety of our users.

Anti-Cheat Data: Android: Device information such as device identifiers, OS version, manufacturer, CPU, country code and language, root/simulator status, APK data, process data, SD card cache, APK name and version, start time, SD card target file, host file, screenshots of gameplay (if you are suspected of cheating behaviour), sensor data, critical system library data, Open ID

We use this information to ensure the security of the Service.

It is in our legitimate interest to ensure the security of the Service.

Account Security Information: game log Information and any information you submit for account recovery, such as account information, contact information, game service information, device identifiers, device information, location information (e.g., IP address, country), gameplay data, details of incident, in-app purchase records and any identity verification information submitted.

We use this information to ensure the security of the Service, such as for:

· account recovery, binding, or rebinding,

· user account system operation,

· account security risk review and improvement,

· account security reinforcement,

· real-time account security risk monitoring and protection, and

· account fraud prevention.

Necessary to perform our contract with you to support account system operation and account recovery, binding, or rebinding.

It is in our legitimate interest to ensure the security of the Service.

Gift Data: IP address, device model platform data (including device ID, username, token, phone and email), game play statistics, task completion status, game account credits, user gift pack collection record, gift pack distribution status, activity points, identity information (Open ID, role ID), eligibility for gift package distribution, package contents

We use this information to facilitate gift delivery.

Necessary to perform our contract with you to facilitate the distribution of gifts.

Cloud Gaming Prize Delivery Data: Open ID

If you win an in-Service prize, we use this information to deliver your prize.

Necessary to perform our contract with you to deliver your prize.

Advertising Information (AppsFlyer and Moloco):

· Technical information: technical information related to your device

· Technical identifiers: unique identifiers that generally only identify your device, browser or application such as IP address, advertising ID, Open ID and user agent

· Engagement information: your interactions with our advertisement campaigns

We use this information for ad attribution purposes.

It is in our legitimate interest to carry out data analytics for ad attribution purposes to understand how our users interact with advertisements.

Advertising Information (Firebase): device data (OS, model, app store, app version), device identifiers, event data (session duration, geography, open/launch/update, purchase, country, interests, language, new/established, ad clicks and impressions), analytics data (usage, clearance, crashes, removal, payment)

We use this information for user acquisition purposes and to monitor the effectiveness of our advertisements.

It is in our legitimate interest to allow us to acquire users and to monitor the effectiveness of our advertisements.

Advertising Information (Meta):

· Contact Information: email address

· Event Data: information shared by the user about people and the actions that they take on the relevant website, app or shop

· Device identifiers

We use this information for user acquisition purposes and to monitor the effectiveness of our advertisements.

We also use the aggregated and anonymised data for analytics purposes.

It is in our legitimate interest to allow us to acquire users and to monitor the effectiveness of our campaigns.

Mini-forum: Open ID, profile picture, nickname and likes

We use this information to provide you with the mini-forum for dissemination of official news and information.

Necessary to perform our contract with you to provide the mini-forum.

NetTool: Network information and OS version

We use this information to operate NetTool used to test host reachability.

It is in our legitimate interest to monitor, analyse and fix bugs.

Gameplay-related FAQ system (Vlink):

FAQ and Q&A function: OpenID, RoleID, device information, social platform nickname, and system information, including SDK version, application version, IP address, network type and client language.

We use this information to operate and provide you with our gameplay-related FAQ system.

Necessary to perform our contract with you to provide the gameplay-related FAQ system.

Data analysis: OpenID, Role ID, device information, social platform nickname, and system information, including SDK version, application version, IP address, network type and client language.

We use this information to operate and provide you with our gameplay-related FAQ system.

It is in our legitimate interest to improve the services we offer.

Push-notifications: OpenID, RoleID, device information, login channel ID, SDK version, application version, and IP address.

We use this information to operate and provide you with our gameplay-related FAQ system.

Necessary to perform our contract with you to provide the gameplay-related FAQ system.

System management: OpenID, RoleID, device information, social platform information, and system information, including SDK version, application version, IP address, network type and client language.

We use this information to operate and provide you with our gameplay-related FAQ system.

Necessary to perform our contract with you to provide the gameplay-related FAQ system.

Bug fixing and analysis: Device and user account identifiers and IP address

We use this information to determine which devices commonly encounter bugs and crashes.

It is in our legitimate interest to monitor, analyse and fix bugs.

Cloud Gaming Activity Data Analytics Information (reported to Adjust): Device ID data, user attribution data, web activity data, IP address, user agent

We use this information to carry out data analytics (including operation and maintenance analysis and traffic analysis), to improve the Service on the cloud server.

It is in our legitimate interest to use this information to improve the Service on the cloud server. 

Discord Game Activity Information:

· From Discord: user ID, nickname, profile picture

· Gameplay statistics

We use this information to allow you to participate in game activities via Discord and to provide leaderboard information in-game and via Discord. 

Leaderboard information displayed on Discord will be processed according to Discord's privacy policy.

To the extent applicable and permissible in your region, it is necessary to process this information to perform our contract with you to provide the Service.

Otherwise, it is in our legitimate interest to provide game activities.  

 Competition information (if applicable in your region):

· User ID;

· Winning information: History of gaming activity (such as first day of registration, total days playing, total matched, total hours, total stars, medals, most used heroes, server name, winning rate, favourite route, time online, esports activity, most used fixed text chat phrases, most frequent teammate, likes, skin, pre-fixed labels, in-game social interaction status;

· Custom Content: Selected personalized label for event; annual business card

· Lucky draw result: User ID and prize

We may also take videos and photos of the competition.

If you take part in our competitions (where available in your region), we use such data to allow you to participate in and obtain rewards from the competition.

Necessary to perform our contract with you to provide competitions.

Where we are required under applicable local law to collect the information on the basis of consent, we will seek your consent. Videos and photos of the competition are processed with your consent.

Ranking information: Nickname, avatar, avatar frame, number of points consumed (for top 30 players only), number of points obtained through activity (for top 100 players only)

We use this information to provide rankings related to the points consumed and obtained by users in events, and to provide rewards.

It is in our legitimate interest to ensure the integrity of high-scoring players is supported by appropriate evidence in-Game.

Personal Information

Retention Policy

In relation to the Website and Other Activities

LEVEL INFINITE PASS account log-in information

Stored for the lifetime of user's use of the LEVEL INFINITE PASS Account, until account deletion in accordance with user's request, upon which it will be deleted within 30 days.

Where you do not request for account deletion, such data will be retained for 30 days after the Game is shut down, before it is deleted.

HOK Camp

This data is only stored on your device, and is not retained on our servers.

Email (Newsletter)

Stored until you unsubscribe to our newsletters.

Tlog Data Reporting

Stored for the lifetime of the Website (i.e., until account deletion in accordance with your request) and then for 30 days.

Real User Monitoring Data Reporting

Stored for the lifetime of the Website (i.e., until account deletion in accordance with your request) and then for 30 days.

Google Analytics User Acquisition Data Reporting

Stored for 3 months (on Google’s servers).

Promotional activities and events information, content creator program information, eSports event and tournament information

For the duration of the activity, event, tournament or program, after which personal information will be deleted within 6 months.

For content creator program, if you are not selected after submitting an application to us, we will not store your personal information and will delete it within three months after the selection process has come to an end. If you are selected, stored for the lifetime of your use of it (i.e., until account deletion in accordance with your request) and then for 30 days.

Interaction with Honor of Kings WhatsApp Business Account

Stored for up to 6 months by us.

This information will also be processed by Meta in accordance with its privacy policy. Below you can find the relevant links:

WhatsApp Business Terms of Service

WhatsApp Privacy Policy

CBT Account Information

For the duration of the activity, after which it will be deleted within 6 months.

In-game event information

Stored for up to the lifetime of your use of the Service (i.e., until account deletion in accordance with your request) and then for 30 days.

Competition information

Ranking information

Stored for the duration of the event, after which it will be deleted within 1 month.

Offline community gathering information

Contact details will be deleted immediately after the event.

Videos and photographs will be stored until the termination of the Service, or deleted within 30 days upon your deletion request.

HOK Camp reading game data function information

HOK Camp add friend function information

Xiaomi Cloud payment information

Stored until the termination of the Service, or deleted within 30 days upon your deletion request.

HOK Camp performance publication information

HOK Camp sharing statistics information

We do not store this information.

In relation to the Game

Account Creation, Cloud Gaming Login and IP Data, Account recovery (guests only), Account Deletion (in-app), Friend Information, Game Data, Profile Information, Analytics Crash Reporting & Performance, Push Notifications (Firebase), Advertising Information (AppsFlyer, Firebase), Geographic Matchmaking, Service Information & Connection Management Data, Game Update & SDK Data, Text Chat Data, Bug Fixing and Analysis Data, Mini-forum, NetTool, Game room, game speed acceleration and network diagnostics, Email (Newsletter)

Stored for up to the lifetime of your use of the Service (i.e., until account deletion in accordance with your request) and then for 30 days.

Account Creation (General)

Installed browsers and social media apps will be processed device-side only and will not be transferred to us.

Other information: 6 months.

Cloud Gaming Resource Allocation Data 

Cloud Gaming Performance Data

Cloud Gaming Duration Data

Cloud Gaming Prize Delivery Data

Stored until the earlier of the termination of the Service, completion of the relevant game activity (if applicable), or until account is inactive.

Cloud Gaming Network Data Cloud Gaming Status Data

Cloud Gaming Log Data

Stored until the earlier of the termination of the Service or after 6 months.

Transaction Information 

Stored until the termination of the Service (or if earlier, deleted within 30 days upon your request), and where required to comply with legal obligations, until the expiration of any retention periods for which such data must be retained.

Friend Recommendation Data

YouTube sharing information

Version switch information

Not stored.

Advertising Information (Moloco)

Stored for 180 days and deleted within 30 days upon receipt of a deletion request.

Advertising Information (Meta)

This information will be collected and stored by Meta in accordance with its privacy policy. You can find Meta’s privacy policy here.

In relation to your use of our cloud gaming website services, this information will be processed by Meta only and not by us.

In relation to your use of our other services, in addition to processing by Meta, we will store this information, if available to us, for the lifetime of your use of the Service (i.e., until account deletion in accordance with your request) and then for 30 days.

Compliance Data

1 year after the Service is shut down.

Voice Chat Data (real-time voice)

Voice Chat Data (voice messages)

Voice files will not be stored.

All other information: 1 month.

Voice Chat Data (in-game safety)

Voice files will only be stored on your device and not be stored on our servers, unless a report or complaint is made, in which case the relevant voice messages or the last 30 or 60 seconds of the relevant real-time voice chat file and OpenID are stored on our servers to enable us to review the complaint or report. This data will be deleted as soon as the review is complete and in any event within 7 days. If objectionable content is found, this data will be retained for 30 days as evidence.

Anti-Cheat Data, Gameplay-related FAQ system (Vlink), Account Security Information

90 days or until account deletion in accordance with your request and then for 30 days.

Friend Suggestion Information

Phone numbers and display names of address book contacts (other than names of contacts suggested as friends): Not stored but processed momentarily to suggest players that you may know.

Your phone number, WhatsApp nickname (if relevant) and suggested friend information: Stored until you disable the friend suggestion feature.

Gift Data

Within 6 months after end of an activity.

Survey information (IMUR)

Any aggregated survey responses collected via IMUR will be retained for one year.

Survey Information (non-IMUR)

If you choose to participate in a survey via a channel other than IMUR, we will retain your survey response for 30 days.  

Customer Support information

Customer support log data (OpenID, date of ticket and type of customer service request): Stored for the lifetime of your use of the Service (i.e., until account deletion in accordance with your request) and deleted within 30 days.

Game data: Momentarily reviewed to provide customer support and not stored.

Other data: Stored for 2 years or deleted earlier upon user request.

Cloud Gaming Activity Data Analytics Information

Stored for the duration of the cloud gaming activity by us.

Stored for 28 days by Adjust.

Discord Game Activity Information

Stored for the duration of the game activity.

Leaderboard information displayed on Discord will be deleted according to Discord's privacy policy

Web Feature Information

Preference settings: Stored device-side only.

Other data: Stored for the lifetime of your use of the Service (i.e., until account deletion in accordance with your request) and then for 30 days.

Highlights video sharing information

If the highlights video is:

· Not viewed: Stored for one month;

· Viewed but not shared: 6 months; and

· Viewed and shared: Stored until the termination of the Service.

If you request for deletion, we will delete this within 30 days.

Circle function information

Stored until the circle has been disbanded, or until you delete such data.

Facebook Play with Friends information

As determined by Facebook

Jurisdiction

Representative

Address

Contact details

EU

Proxima Beta Europe B.V.

Buitenveldertselaan1-5,1082 VA, Amsterdam, the Netherlands

dpo_hok@proximabeta.com.

Türkiye

Özdağıstanli Ekici Avukatlık Ortaklığı.

Nidakule Ataşehir Kuzey Begonya Sok. No:3 Kat. 17 D: 162 34746 Ataşehir / İstanbul, Türkiye

Özdağıstanli Ekici Avukatlık Ortaklığı is our data controller representative and its authority is limited to the authorities stipulated under the Law on Protection of Personal Data w. no 6698. Özdağıstanli Ekici Avukatlık Ortaklığı is not authorised for any other matters such as in-Service conduct, suspensions, investigations, civil or criminal complaints.

turkeydatarep_proximabeta@iptech-legal.com