Latest update on 09/10/2024
This privacy policy (“Policy”) informs you of your choices and our
practices in relation to your Information (as defined below).In this
Policy,"we”or "us" refers to CYBER SPHERE SARL.We choose why we need
to use your Information and how it is used, which means we are
considered the data controller in certain countries. For the purpose
of this Policy, “Information” means any information relating to an
identified or identifiable individual. When you use the Website and
Services, you accept our rules and policies which set out how we
handle your Information, and you understand we collect, process, use
and store your Information as described in this Policy. If you do
not agree with this Policy, you must not play any of the Games. If
you change your mind in the future, you must stop playing the Games
and you may exercise your rights in relation to your Information as
set out in this Policy.
The games EraShadows: Redemption (developed by HOANG NGOC
EDUCATION CONSULTANT ONE MEMBER COMPANY LIMITED) and Turret Wars
Offensive (developed by Web Development Labs, Ltd) have each been
exclusively authorized to CYBER SPHERE SARL for operation.CYBER
SPHERE SARL is solely responsible for handling all payment-related
matters through the respective game applications (including but not
limited to in-app purchases, refunds, and related transactions). All
such matters are subject to the terms and policies of CYBER SPHERE
SARL.These authorizations shall remain in full force and effect
unless and until they are formally revoked in writing by the
respective licensors — HOANG NGOC EDUCATION CONSULTANT ONE MEMBER
COMPANY LIMITED and Web Development Labs, Ltd.
1.Personal Information We Collect
We collect and process various personal data to enhance your gaming
experience. This includes information you provide, such as contact
and payment details, as well as automatically gathered data like
your IP address, device information, and in-game actions. Cookies
are used to improve functionality, and we also receive information
from third parties, including payment processors and advertisers.
Information You Provide:
· Contact details: name, username, phone
number, and email address.
· Payment details: payment methods (e.g.,
credit or debit card numbers).
· Profile photos and transaction history:
cash top-ups and frequency.
Information Automatically Collected During
Gameplay:
· Identifiers: IP address, advertising ID,
Adjust ID, HTTP header, MAC address, device ID, third-party app IDs,
location data, and device information (model, brand, language, OS).
· Cookies: We use cookies and similar
technologies (web beacons, log files, scripts, eTags) to enhance
your experience. You can control cookie installation, though refusal
may limit game functionality.
· Usage data: Game ID, timestamps of
events, gameplay time, scores, interactions with teams, advertising
engagement, transaction records, and evidence of cheating or
modified versions of the game.
Information from Third Parties:
· Payment Providers: We receive transaction
details (ID, country, payment provider, purchased items, currency,
value, payment timestamp).
· Advertising Partners: We receive data on
your interactions with ads.
· Mobile Measurement Partners: Information
on marketing campaign performance and fraud detection (advertising
ID, IP address, location, transaction data).
· Communication Providers: In-game chat,
audio, or video functionalities may involve sharing your third-party
IDs, usernames, and, in some cases, content.
2.How We Use Your Personal Information?
Provide You with the Games. We use your information
to fulfill our contractual obligations, such as enabling you to
create an account, play the games (including as a guest), save your
progress, and interact with friends through in-game chat, audio, or
video calls (if available). This includes processing your
registration details, gameplay data, identifiers, and other relevant
information regarding your use of the games.
Improve and Monitor Game Use. To enhance
our games and user experience, we collect and generate data about
you and your device (e.g., battery level, Wi-Fi strength, device
manufacturer, model, and operating system) during gameplay. This
helps us improve our games and ensure they function correctly.
Provide Support and Respond to Requests.
When you seek support, we use your information to create a support
account, address your queries and complaints, and provide
assistance. This involves processing your registration details,
identifiers, device information (e.g., Wi-Fi strength, free space),
and other information collected through our support channels.
Conduct Analytics. We analyze data to
understand and improve our games, newsletters, and advertising
campaigns. This includes processing automatically collected or
generated data to create anonymized insights, segment users by
characteristics or interests, and perform predictive analytics about
user preferences.
Send Updates About In-Game Offers. We
tailor promotional offers and information about virtual items
available for purchase in-game based on your gameplay, location,
device data, and in-game interactions. This is done based on our
legitimate interest in providing relevant updates.
Prevent Fraud and Legal Compliance. To
protect users and our interests, we monitor game use to detect and
address fraud, manage legal claims or disputes, and enforce our
terms and policies. This involves processing relevant information
from you, automatically collected data, and information provided by
third parties.
Conduct Surveys. Occasionally, we may
invite you to participate in surveys to gain insights into our user
base and improve our games. If you choose to participate, we process
your registration details and responses to survey questions.
3.Who We Share Your Personal Information With?
Other Players and Users. Your profile information
and in-game activities, along with any other information you choose
to share (such as chat data), may be visible to other players and
users.
Third-Party Developers. When you play
third-party games published by us, we share your information with
the developers of those games to facilitate your access and
experience.
Group Companies. We may share your
information with entities that are part of our group of companies
for internal purposes.
· Law Enforcement and Judicial Bodies. We
disclose information if required by law or in good faith belief that
it is necessary to:
· Comply with legal obligations or
requests,
· Enforce terms of service and other
agreements,
· Investigate potential violations,
· Address security, fraud, or technical
issues,
· Protect rights, property, or safety of
us, our users, or the public.
Change of Corporate Ownership. In the event of a merger,
acquisition, bankruptcy, reorganization, partnership, asset sale, or
similar transaction, we may disclose your information as part of
that process.
4.Third Party Privacy Practices
If you access any Games through a third-party platform(“Third-Party Services”), you must understand that those Third-Party Services may collect other Information about you (including Information you share with them directly or about your use of the Games) in accordance with their own terms and privacy policies. The privacy practices described in this Policy do not apply to Third Party Services. Any links in the Games to Third Party Services do not imply that we endorse or have reviewed the Third-Party Services.
5.Security
Although we have in place security measures to maintain the privacy and integrity of your Information, unfortunately, the transmission of Information via the internet is not completely secure. We may also take extra steps to protect your Information and minimize the Information we process. For example, when you provide us with your password as part of the registration process, we apply a one-way hash.
6.Children's Protection
We are committed to ensuring the safety and privacy of children
using our games. We do not knowingly collect personal information
from individuals under the age of 18 without parental consent. If we
become aware that a child under this age has provided personal
information, we will take immediate steps to delete such information
and close the child's account.
Parents and guardians are encouraged to monitor their
children's online activities and ensure that their children do not
share personal information without their consent. If you have
concerns about your child's data or believe we may have collected
information from a child under the age of 18, please contact us at
service@cyberspheresarl.com, and we will address the issue promptly.
Our privacy practices are designed to comply with applicable
laws and regulations concerning children's online privacy.
7.How Long Do We Store Your Information?
Your information is kept for as long as you are registered or actively using our games, and then for up to five years from the date you stop interacting with the games. When deleting information, we take measures to make it irrecoverable or irreproducible, and electronic files containing your information will be permanently deleted.
8.Country-Specific Privacy Rights
8.1 European Economic Area (EEA) and United Kingdom
If you are located in the EEA or the United Kingdom, you
have the following rights under the General Data Protection
Regulation (GDPR) and UK GDPR:
• The right to access your personal data;
• The right to correct inaccurate or
incomplete personal data;
• The right to erase your personal data in
certain circumstances;
• The right to restrict or object to
processing;
• The right to data portability;
• The right to withdraw your consent at any
time, where processing is based on consent;
• The right to lodge a complaint with a
data protection authority.
Our legal bases for processing your data may include
contract performance, legal obligation, legitimate interests, and
consent. If your personal data is transferred outside the EEA or UK,
we implement appropriate safeguards such as Standard Contractual
Clauses (SCCs).
8.2 United States (California Residents – CCPA/CPRA)
If you are a California resident, under the California
Consumer Privacy Act (CCPA) and the California Privacy Rights Act
(CPRA), you may have the right to:
• Know what categories and specific pieces
of personal information we collect and disclose;
• Request deletion of your personal
information;
• Opt out of the sale or sharing of
personal information;
• Correct inaccurate personal information;
• Limit the use of sensitive personal
information;
• Not be discriminated against for
exercising any of your rights.
• To exercise your rights, please contact
us at service@cyberspheresarl.com. We will verify your identity
before processing any requests.
We do not sell your personal data, but we may share certain
data with advertising partners in a way that could be considered a
"sale" under California law. You may opt out of such sharing by
emailing us or adjusting your in-game privacy settings.
8.3 Japan (Act on the Protection of Personal Information -
APPI)
If you reside in Japan, we process your personal information
in accordance with the Act on the Protection of Personal Information
(APPI). Under APPI, you have the right to:
• Know the purpose of use of your personal
data;
• Request disclosure, correction, addition,
or deletion of your personal data;
• Request suspension of use or erasure of
your personal data;
• Lodge complaints regarding the handling
of your personal information.
We do not use your data for purposes other than those stated
in this Policy without your consent. If we transfer your data
outside of Japan, we ensure the recipient provides a comparable
level of data protection or obtain your prior consent.
9.Changes
Any updates or changes to this Policy will be published here. If there are any significant changes, we will notify you through the website and in-Game.
10.Contact Us
To contact us with your questions or comments regarding this Privacy Policy or data collection, please email us at service@cyberspheresarl.com.We will endeavor to deal with your complaint as soon as possible.