AAAGame Privacy Policy

Last Updated: February 20th, 2023

Introduction

AAAGame and its affiliate companies (“we” or “us”) respect the privacy of its online visitors (“you”). We have adopted a Privacy Policy that explains how we collect, use, and use the information you provide us. We refer to all our mobile game products, together with our other services and websites as "Services" in this policy. This policy also explains your choices about how we use information about you. Your choices include how you can object to certain uses of information about you and how you can access and update certain information about you. Using our Services indicates your acceptance of this Privacy Policy. If you do not agree with this policy, do not access, or use our Services or interact with any other aspect of our business. AAAGame is a subsidiary company under Shengzheng Internet Company, or “Shengzheng Wang Luo”, also known as “Shengzheng”.

AAAGame is committed to protecting the privacy of its users and provide them a better social gaming experience ("users" or "you"). This Privacy Policy has been created to inform you about how AAAGame manages, collects, stores, shares, uses and protects the information you provide in connection with any AAAGame game or application whenever you play our games or otherwise access any of our Services, products, or content at www.kc.shengzhengkc.com.

IMPORTANT: YOU HEREBY AGREE THAT IF YOU ARE UNDER THE AGE OF 18 OR ARE CONSIDERED NOT OF LEGAL AGE TO BE AN INDEPENDENT IN THE GEOGRAPHIC AREA YOU ACCESS OUR SERVICES, YOU NOW REPRESENT THAT YOUR LEGAL GUARDIAN HAS READ, UNDERSTOOD, ACKNOWLEDGED, AND AGREED TO THIS PRIVACY POLICY.

This Privacy Policy applies whenever you play our games or otherwise access any of our other products, services, content at www.kc.shengzhengkc.com or the other domains provided by AAAGame, together referred to as "Services". This Privacy Policy describes:

1. What information we collect, how we collect it

2. How we use that information and with whom we share it

3. How you can access and update that information and means of communications

4. How we protect minors’ privacy

5. How we protect the information we store and share about you

6. Miscellaneous

By using the Service, you agree to the collection, disclosure, storage and use of your information as outlined in this Privacy Policy. If you do not want AAAGame to collect, store, use or share your information in the ways described in this Privacy Policy, you should not play AAAGame’s games or use our Services. AAAGame may amend the Privacy Policy from time to time, and AAAGame encourages you to consult the Privacy Policy regularly for changes.

We do not share personal information with third parties for their direct marketing purposes unless you affirmatively agree to such disclosure, typically by "opting in" to receive information from a third party that is participating in a sweepstakes or other promotion on one of our sites. If you do ask us to share your personal information with a third party for its marketing purposes, we will only share information in connection with that specific promotion, as we do not share information with any third party (other than our service providers) on a continual basis.

To prevent disclosure of your personal information for use in direct marketing by a third party, do not opt into such use when you provide personal information on one of our sites.

Users in certain jurisdictions have a right to access personal information held about themselves. Your right of access can be exercised in accordance with applicable law.

1. What Information We Collect and How We Collect It

AAAGame only collects Personal Information to the extent necessary to fulfil one or more of its functions and activities and will do so only by fair and reasonable means. Generally, we will collect Personal Information directly from the individual to whom the Personal Information relates, but in some circumstances (including as outlined below), it may be necessary for us to collect information from a third-party source.

i.  Information You Provide Us

When you successfully register an account for any of AAAGame’s applications, you will be providing the following information:

· Any information used for your profile (In-game usernames and if applicable, email)

· Any information you provide us through surveys

· Any information from transactions made in-game

· Any information from linking your social media account(s) (Please see following sub-section for more details)

The following list comprises possible data we may collect about you:

· Demographic data (age, date of birth, gender)

· Advertising ID

· Gameplay data (in-game progress, in-game inventory)

· Survey information

· Transaction data

· In-game communications (in-game chat and customer service logs)

· IP address (from your latest log-in)

· Device information

· Security related information you provide willingly (telephone number, email address)

ii.  Information About You That We Get from Third-Party Applications, Including Social Networks (like Facebook)

If you play AAAGame’s games or access any of our other Services on connected third-party applications or connect our Services to any third-party applications, including social networks like Facebook, AAAGame may receive certain information about you from the provider of the third-party application. The information we receive depends on the AAAGame game you’re playing, the third-party application, your privacy settings and, if applicable, your friends’ privacy settings on that third-party application. For example, AAAGame may collect and store some or all the following information shared by the provider of the connected third-party application:

· Your first and last name

· your profile picture or its URL

· your user ID number (like your Facebook ID number), which may be linked to publicly available information like your name and profile photo

· the user ID number and other public data of your friends

· the login e-mail you provided to that third-party application when you registered with it

· your physical location and that of the devices you use to access our Services

· your gender

· your birthday and/or age range

· information about your activities on or through the connected third-party application

· any other information that you or the provider of the third-party application share with AAAGame

If you access our Services from a third-party application or connect our Services to a third-party application, you should also read that third-party application’s Terms of Service and Privacy Policy.

If you are unclear about what information a third-party application is sharing with us, please go to the third-party application to find out more about their privacy practices.

iii.  Cookies and Automated Information Collection

Like many websites, AAAGame and service providers acting on our behalf, like Google Analytics, store log files and use tracking technologies such as "cookies" to collect information. A cookie is a small data file that is transferred to your computer’s hard disk or your mobile device for record-keeping purposes. The Service may send cookies to a computer or a mobile device when a user accesses or views a Service. Information contained in a cookie may be linked to personal information for purposes such as improving the quality of AAAGame’s Services, tailoring recommendations to interests, and making the Service easier to use.

Third party advertisers on the Services may also use, place, or read cookies or other technologies as described below on your browser, and those practices are subject to their own policies. Cookies can be disabled at any time by changing your web browser’s options to stop accepting cookies, to prompt you before accepting a cookie from the websites you visit or limit the type of cookies you allow. Flash cookies operate differently than browser cookies and cookie management tools available in a web browser may not remove flash cookies. If you do not accept cookies, however, you may not be able to use all features, portions, or functionalities of the Service.

We and our service providers may also employ other technologies including (i) web beacons, which allow us to know if a certain page was visited or whether an e-mail was opened; (ii) tracking pixels, which allow us or our advertising partners to advertise more efficiently and effectively by excluding our current users from certain promotional messages, identifying the source of a new installation or delivering ads to you on other websites; and (iii) local shared objects also known as flash cookies, which help us to reduce fraud, remember your in-game preferences and speed up load times.

We and our service providers use these log files, tags, and tracking technologies to collect and analyze certain kinds of technical information, including:

· the type of device you are using

· your operating system version

· your mobile device’s identifiers, like your MAC Address, Identifier for Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI)

· your browser types

· your browser language

· referring and exit pages, and URLs

· platform type

· the number of clicks on a page or feature

· domain names

· landing pages

· pages viewed and the order of those pages

· the amount of time spent on pages

· game state and the date and time of activity on our websites or games

In some cases, we will connect this information with your social network ID or AAAGame user ID.

For more information on how to limit the types of cookies you allow, please see sections iii (“Choices Regarding the Sale of Your Personal Information) and Opting out of Cookie Tracking section.

iv.Choices Regarding the Sale of Your Personal Information

The State of California requires us to abide by the California Consumer Protection Act (“CCPA”). CCPA mandates us to how personal data may be sold to third parties and how you may opt-out of these sales. “Sale” or “Sales” of personal information to third parties is defined by CCPA to include instances where data is made available to third parties for no charge. This encompasses sharing user information to Apple, Facebook, Google, or advertising/analytics firms without the transfer of any monetary amount(s) between parties. Beyond this example, we do not engage in any “selling” of personal information for profit. Personal information is defined by the CCPA as information and/or data which includes but are not limited to IP addresses, mobile device IDs, and cookie IDs.

How to Limit and/or Restrict Our Use of Tracking Technologies?

Users may opt-out of having your personal information disclosed and/or “sold” by writing an email to kingdomclash@aaagame.com with the subject line “opt-out personal information/data”. Your case will be considered “open” now your message is sent, and we reserve the right to keep your case open for 30 days maximum before issuing a response.

Limiting and/or Restricting regarding Mobile Advertising

Android & iOS operating systems feature options which limit the tracking of personal information by resetting your advertising ID. Please contact either organization directly to find more details on how to do this.

Do Not Track

Some operating systems such as iOS feature system settings which allow for users to turn

on their device’s “Do Not Track” configuration. This will limit the amount of information sent to advertisers and other third parties when you engage in activities across websites.

Cookie Analytics

Many web browsers and mobile devices have cookies accepted as a default. You may turn off this feature or delete your cookies by accessing the settings configuration of your browser and/or mobile device. NOTE: Once you delete or reject cookies this may affect certain features or services of our website, your gaming experience, and beyond. You may find more information on how to opt out of cookie analytics from your devices by visiting the following websites:

· If you are based in Europe (European Digital Advertising Alliance)

o   http://www.youronlinechoices.com/

· If yIf you are based in Canada (Digital Advertising Alliance of Canada)

o   https://youradchoices.ca/

·  If you are based in the United States (Network Advertising Initiative)

o   http://optout.networkadvertising.org/

· If you are based in the United States (Digital Advertising Alliance)

o   http://optout.aboutads.info/

v.Information About You That You Share with Us Directly

When you use our Services (whether through a social network or through AAAGame directly), you may give us information directly (like when you’re setting up your account) and we will store that on our systems and use it for the purposes described in this Privacy Policy.

Some games or parts of our Services may use a more traditional registration or account set-up process where you may be asked to give us some or all the following information:

· your age or birthday

· your first and last names

· your e-mail addresses

· a password

Other information that helps us make sure it’s you accessing your account or helps us improve our services (such as answers to an online survey or a feedback form).

We may also let you create a player profile, separate from your social networking site profile (for example, your Facebook profile), that other AAAGame players can see. Your player profile may include information like:

· profile photo

· game username(s)

· your gender

· biographic details (like your age or age range).

· approximate location information that you provide

· links to your profiles on various social network; and

· details about the games you play

vi.Information You Generate Using Our Communications Features

Except for games designed for children under 13, you may be able to take part in certain activities on our Service that let you communicate or share information not just with AAAGame, but also with other AAAGame players. These include:

· participating in player forums and message boards

· posting public comments to other players’ profiles or gameboards

· sending private messages or invitations to other players, either directly on our websites or to their e-mail accounts

· chatting with other players

· posting photos or drawings

You acknowledge and expressly agree that we may access in real-time, record and/or store archives of these communications, comments, photos and drawings on AAAGame’s servers to make use of them to protect the safety and well-being of our players and AAAGame’s rights and property in connection with our Services; to conduct research; to operate, improve, personalize and optimize our Services and our players’ experiences, including through the use of analytics; and to manage and deliver contextual advertising.

vii.Payment Information

AAAGame may obtain the billing and payment information that you provide when your purchase is processed by someone else (like Facebook, Apple or Google) such as when you purchase something in a game you play on a social network or that you downloaded on your mobile device. Our Terms of Service explain our policies and terms relevant to our charges, billing practices, third-party credits, and virtual currencies.

If you purchase virtual currency or virtual items in a AAAGame game, our third-party payment processor will collect the billing and financial information it needs to process your charges. This may include your postal address, e-mail address and financial information.

AAAGame does not collect or store your financial information, like credit card numbers. However, AAAGame’s payment processors may share non-financial information with us related to your purchases, like your name, billing address and the items purchased to fulfill your order.

viii. Message Boards and Chat Rooms

You may be able to take part in certain activities on our websites or games that give you the opportunity to communicate or share information not just with AAAGame, but also with other users of our Service. Note that certain information you post and communicate through a Service, or a third-party site or service is public information for which you have no expectation of privacy.

You may choose to disclose information about yourself in the course of contributing user generated content to AAAGame sites or Services or in its chat rooms, blogs, message boards, user “profiles” for public view or in similar forums on its sites through mobile services and/or through third party sites or services, posting public comments to other users' profiles or gameboards, sending private messages or invitations to other users, either directly on our websites or to their e-mail accounts and posting photos. Information that you disclose in any of these forums is public information, and there is no expectation of privacy or confidentiality.

You should be aware that any personally identifiable information you submit during these public activities can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. AAAGame is not responsible for the personally identifiable information you choose to make public in any of these forums. We may also record and store archives of these communications on AAAGame’s servers to protect the safety and wellbeing of our users and AAAGame’s rights and property in connection with the Service. You acknowledge and consent to the recording and storage of such communications for these purposes.

If you post a video, image, or photo through a Service for public view, you should be aware that these may be viewed, collected, copied and/or used by other users without your consent. AAAGame is not responsible for the videos, images, or photos that you choose to post through a Service. Please see AAAGame’s Terms of Service on this point and for other guidelines about posting content through any Service.

ix. Customer Support Correspondence

Except as provided herein, when you ask for help from our Customer Support team, we will collect and store the contact information you give them (generally, your name and e-mail address), information about your game play or activity on our Services, and your AAAGame player and/or social network ID number. We will also store the communications you have with the Customer Service team and any information in those communications to provide support and improve the Services. For users of our games designed for children under 13, we will use your contact information for the sole purpose of providing a one-time response to your question. We will then delete your information from our servers.

x.Other Sources

We may collect or receive information about you from other sources like third-party information providers. We use this information along with information you provide us directly, for example, to help you and your friends connect or to serve you advertising more tailored to your interests.

If you would like to learn more about how we secure your information, please see Security of Your Information section below.

2. How We Use the Information We Collect and With Whom We Share It

i.How We Use Your Information

The main use of the information we collect, and store is to provide a better gaming experience, but there are other uses as well. The uses for which we collect and store your information include:

· to create your game accounts and allow you to play our games

· to operate, improve and optimize our Services and our players’ experiences

· to identify and suggest connections with other AAAGame players and personalize our Services to you

· to enable players to communicate with each other

· to provide technical support and respond to player inquiries

· to protect the safety and well-being of our players

· to protect AAAGame’s rights and property in connection with our Services

· to prevent fraud or potentially illegal activities, and to enforce our Terms of Service

· to manage and deliver contextual and behavioral advertising

· to notify players of in-game updates, new products, or promotional offers

· to administer rewards, surveys, sweepstakes, contests, or other promotional activities or events sponsored or managed by us or our business partners

· to comply with our legal obligations, resolve any disputes we may have with you or other players, and to enforce our agreements with third parties; and

· to conduct research.

One important use of your information is communication. If you have provided your e-mail address to AAAGame, we will use it to respond to customer support inquiries, and keep you informed of your in-game activity, including comments from friends, let you know about in-game status and promotions as well as tell you about gift and neighbor requests. Some messages, like invites for friends to join you in a game, may include your name and profile photo. We may also send promotional e-mail messages and promotional SMS messages (e.g., text messages) ("Promotional Communications") directly or in partnership with other parties, in accordance with your marketing preferences. Each Promotional Communication will offer you choices about receiving additional messages. Receipt of such communications depends on AAAGame having certain contact information from you. If you play one of our games designed for children under 13, you will not be able to provide us with certain contact information. Please see the section on Our Policies Concerning Children for more information.

ii.How We Share Your Information

We may disclose or publish aggregated information (information about you and other players collectively that is not intended to specifically identify you, for example, players between the ages of 25 and 30 who live in Chicago) and other non-personal information about our players for industry analysis, demographic profiling, marketing, analytics, advertising, and other business purposes. In addition, with your prior consent we may also share your information (which may include personal information) with third parties (in other words, parties other than AAAGame) or allow third parties to collect this information from our Services in the following circumstances:

· To third-party service providers, contractors, or agents who perform tasks/functions on our behalf, including but not limited to service hosts, customer service providers, marketing/advertising companies, and payment providers

· To comply with a legal proceeding, court order, or other legal processes outlined by court order or subpoena

· To protect us or our other users in cases where we are at risk of suspected fraud or other illegal activities. These also may include violations of our Terms & Agreements/Terms of Service or Privacy Policy. We also reserve the right to use any information collected with your consent as evidence or support should we and you reach arbitration or litigation

· To another corporate entity/business in the case of bankruptcy, dissolution; transfer, sale, or divestiture of portion or all our business or assets; as part of a corporate merger or acquisition

· More information regarding these types of circumstances may be found below in the following sub-sections.

iii.How We Share Your Information - Your Consent

With your consent, we may share your information with third parties or allow them to collect your information from our Services in some ways not specifically described in this Privacy Policy.

iv.Aggregated and Analytical Information

We use anonymous, statistical, or aggregated information and may share it with our partners for legitimate business purposes. It has no effect on your privacy, because there is no reasonable way to extract data from the aggregated information that can be associated with you. We will share your identifiable information only subject to the terms of this policy, or subject to your prior consent.

v.Friends and Other AAAGame Players

The Service supports and often encourages you to interact with other players. In most AAAGame games, if you play through a social network or register through a social network (for example, Facebook Connect), your social network friends will see your name, profile photo and descriptions of your game activity. Similarly, in many AAAGame games, other players, regardless of whether they are your social network friends or not, will be able to see descriptions of your game activity (including the identification of any AAAGame games you have played), communicate with you within our Services, and view your game profile, which may include your name or a “game name” and your profile photo.

vi.Third-Party Advertising Including Tailored Advertising and Analytics

We have advertising on our Services so we can continue to offer many of our Services for free.

We do not actively share personal information with third-party advertisers for their direct marketing purposes unless you give us your consent.

When advertisers or ad networks place ads in our Services, they may collect, or we may share the following types of information from within our Services:

· Performance data (like the number of clicks on an advertisement).

· Aggregated and/or de-identified information about you and other players collectively that is not intended to specifically identify you (like players between the ages of 21 and 25 who live San Francisco)

· Certain technical information (for example, IP addresses, non-persistent device identifiers such as IDFAs, and de-identified persistent device identifiers such as a hashed Android ID)

· Your social network ID

· Other contextual data about your game play (for example, your level and session length)

The information collected may be used to:

· Measure how effective ads are, to offer you targeted advertising to personalize your experience by showing you advertisements for products and services that are more likely to appeal to you (a practice known as behavioral advertising), and/or undertake web analytics (like Google Analytics which is used to analyze traffic and other player activity to improve your experience).

· Measure how effective ads are, to offer you targeted advertising to personalize your experience by showing you advertisements for products and services that are more likely to appeal to you (a practice known as behavioral advertising), and/or undertake web analytics (like Google Analytics which is used to analyze traffic and other player activity to improve your experience).

Please note, after clicking on a third-party advertisement, you may no longer be on a site hosted by AAAGame or the social network through which you are playing AAAGame’s games.

If you do not want to receive tailored in-application advertisements from third parties, please see How to Access, Update and Manage Your Information. Please note that no tailored advertisements will be delivered for AAAGame games designed for children under 13, though AAAGame may allow contextual advertisements to be displayed.

vii.Third-Party Service Providers

We will share your information with third-party companies to perform services on our behalf, like processing payments, analyzing data, optimizing game play, e-mail delivery, hosting services, customer service and to help us in our marketing efforts, including managing and delivering contextual and tailored advertisements. We contractually require these third-party service providers to maintain the confidentiality of the information we share with them, and we contractually require them not use your information for anything other than to provide services on our behalf.

viii.Sale or Merger

If AAAGame undergoes a business transition (including proposed transactions), like a merger, acquisition by another company, or sale of all or part its assets (like selling a game), we may disclose or transfer all of your information, including personal information, to the successor organization in the transition. We will make reasonable efforts to let you and other players know (in the way described in Changes to Our Privacy Policy) of the business transition before transferring your personal information.

3. How to Access, Update and Manage Your Information and Means of Communication

i. How to Access, Update and Manage Your Information and Means of Communication

If you want to review, delete, or change the information AAAGame has about you or have additional questions, contact us to kingdomclash@aaagame.com

ii. Stopping Use of Your Information

If you no longer want AAAGame to make active use of your information, you may send an e-mail to kingdomclash@aaagame.com

Place "Delete My Account" in the subject line and include your first name, last name, UID and your social network ID for the social network from which you access our Services (if applicable) in the body of the e-mail (for example, your Facebook user ID). We will respond to your request within thirty days. Please note that certain records, for example those relating to payments or customer service matters, will be held for legal and accounting purposes. If you have sent content through or posted content on the Service, we may not be able to delete it.

iii. Manage Information We get from a Third-Party Application

To manage the information AAAGame receives about you from a third-party application where you play our games, like Facebook, you will need to follow the instructions for the third-party application for updating your information and changing your privacy settings. To review and update information associated with your AAAGame game profile in certain games, visit the “settings” page in that game. You also can manage some aspects of information collection and use by visiting the “settings” page of your mobile device and reviewing the permissions of each application or “app.”

Once AAAGame receives your information from a third-party application or your mobile device, that information is stored and used by AAAGame in accordance with this Privacy Policy. You may access and update that information as described below.

iv. Opting Out of Geolocation

If you have previously allowed us to access your geolocation data, you can stop making geolocation available to us by visiting your mobile device's settings for the relevant application or the “settings” page for the relevant game.

v.Opting Out of Promotional Emails from AAAGame

If you want to stop receiving promotional e-mails from AAAGame, click on the "unsubscribe" link in any promotional email from AAAGame or visit the e-mail preference. Please note that once we receive your request, it may take an additional period of time for you opt-out to become effective. You unsubscribe or e-mail preference change will be processed promptly, and in no event longer than ten business days.

vi.Opting from FB messages

If you want to stop receiving messages through our game pages, you may click on the "settings" icon on the top of such message, and by clicking” manage messages” you may turn off all messages from such game.

vii.Opting Out of Other Communications

When you install our apps on your mobile device you can choose to receive push notifications, which are messages an app sends you on your mobile device even when the app is not on. You can turn off notifications by visiting your mobile device’s “settings” page.

In most of our games, you may find under “your account” or Settings” section an option to stop e-mail or other notifications.

These opt-out tools are provided by third parties, not AAAGame. AAAGame does not control or operate these tools or the choices that advertisers and others provide through these tools.

viii.Opting Out of Third-Party Tailored Advertising

In addition, if you do not want to receive tailored in-application advertisements from third parties that relate to your interests in apps on your mobile device, you may opt- out by adjusting the ad tracking settings on your device. You can also reset the “Advertising Identifier” (like an IDFA) from your mobile device’s settings page, which will prevent continued use of existing behavioral data tied to the previous “Advertising Identifier.” Further, depending on the platform provider (such as Apple or Google), you may be able to download apps, such as the Digital Advertising Alliance’s “AppChoices” app, that offer to provide you with control regarding the collection and use of cross-app data for tailored advertising. Like the opt-out tools mentioned above for web, these mobile opt-out tools are provided by third parties, not AAAGame. AAAGame does not control or operate these tools or the choices that advertisers and others provide through these tools.

Please note that you may still receive advertisements from third parties within AAAGame’s games even if you opt out of tailored advertising, but they will not be based on your activity across unrelated web sites or apps.

ix. Opting Out of Cookie Tracking

You can set your web browser to warn you about attempts to place cookies on your computer or limit the type of cookies you allow. Flash cookies operate differently than browser cookies and cookie management tools available in a web browser may not remove flash cookies. To learn more about and manage flash cookies you can visit the http://www.adobe.com/ and make changes at the Global Privacy Settings Panel.

If you disable cookies, you may lose some of the features and functionality of our Services because AAAGame’s cookies are necessary to track and enhance your game activities.

xi. General Data Protection Act (European Data Protection Rights)

 You are entitled to certain rights regarding your personal information and/or data if said information/data is subject to the European Union’s data protection law. If the above applies to you then (1) you are entitled to the right to request access to, the amendment, or deletion of personal information/data; (2) if there were or will be any occurrence of your personal data being processed that was based on your prior consent or through formal contractual agreement, you have the right to request and receive a copy of the personal data that was processed; (3) under certain circumstances you may obtain a restriction of the processing of your personal data; (4) if applicable, you may withdraw consent at any time from having your personal information/data processed; and lastly (5) residents of France may send specific instructions regarding how your personal information/data is to be used after your death.

Any of these requests should be sent via email to us at kingdomclash@aaagame.com. You have the right to contact and submit a complaint to a supervisory authority, however we will honor most requests, so it is advisable for you to contact us first. None of your information is collected without attaining your consent (acceptance of Terms & Agreements; acceptance of Privacy Policy).

Please refer to the following list for a comprehensive review of the rights for users of AAAGame applications if they are in the European Economic Area:

· Access: You have the right to access the personal information we have available on you, how we use said information, and who we share it with. Contact us directly if you wish to review, view, or access any of said information.

· Portability: You have the right to receive a copy of certain personal information we have or processed about you. Furthermore, you have the right to receive this information in an organized and computer-readable format. Lastly, you have the right to request said personal information to another party.

·  Amendment/Correction: You have the right to amend any personal information we may have about you that is incorrect. Please contact us at kingdomclash@aaagame.com to review your information first.

· Erasure: You have the right to remove certain types of personal information we may have about you, or to have all the information along with your AAAGame account deleted. To do so, please contact us at kingdomclash@aaagame.com. Furthermore, any requests for such deletion requires that one of the following must be true:

o You believe the information about you is no longer up-to-date

o You believe the information may have been unlawfully processed

o Your rights to erasure also include the right to restrict our processing of your personal information. We will honor such requests unless there are valid grounds under data protection laws.

· Restriction of Processing to Storage Only: You have the right to require us to stop processing your personal information we may hold for purposes other than storage in some cases. Please note that if we are instructed by a legal authority or have valid grounds under data protections laws, then the data processing on such information may be resumed.

You may request for us to stop processing any personal information we may have regarding you in the following circumstances:

o   If the personal information we may have about you is not accurate during the time it takes us to verify its accuracy

o   If the processing of personal information we may have about you in unlawful, but you still wish for us to retain in instead of store it

o   If your personal information is no longer necessary for us to provide our service, however you require it to be stored for reasons including legal claims

· Objection: You have the right to object to the processing of any personal information we have about you. Please note that we must evaluate the request internally for validity. Contact us at kingdomclash@aaagame.com to learn more.

· Notifications/Announcements: We will occasionally send out service notifications regarding our application(s), such as game closure periods for maintenance, security and privacy implementations, or other related communications. Contact us at kingdomclash@aaagame.com should you wish to opt-out of these types of notifications.

xii. California Online Privacy Protection Act Notice

If you are a resident in the state of California and the processing of personal information about your person is subject to the state of California’s California Consumer Privacy Act (“CCPA”), then you have specific rights regarding that information and how it is processed.

Juvenile residents of California, or those under the age of 18 who have registered accounts or are registered users of any online sites, services, or applications possess the right to request, remove, and obtain the removal of information and/or content they have publicly posted under the California Business and Professions Code Section 22581. If you choose to exercise this right regarding any content or information on our sites, applications, or service you have publicly posted, then write a message to kingdomclash@aaagame.com with the subject line “request to remove my public information”. Please be aware that this right is not guaranteed as certain legal requirements as pertained by the law may not allow, permit, or require the removal of information and/or content under some circumstances.

California law specifies that “California Customers”, or residents of California who disclosed and/or provided personal information to any business that the resident has prior or current relationship(s) including but not limited to business, personal, familial, or household purposes may request information regarding whether the business has provided, disclosed, or sold any of their information to a third party for the third party’s marketing purposes. If such a disclosure or sale was made by the business, California law provides you the right to request a list of all third parties to whom your personal information have been disclosed to. If you are a resident of California, you may request this information or learn more about this by sending a written message to kingdomclash@aaagame.com with the subject headline “Shine the Light” or “California Customers”. Please note that these right(s) are as stipulated and/or required under California law, specifically California Civil Code section 1798.83, or “Shine the Light” law.

The Right to Know: You have the right to have us disclose and/or notify you of the personal information that has been collected about you. Furthermore, you also have the right to request more information regarding how your personal information is collected, used, or the disclosed. These rights can be invoked through a written request made by you via email to kingdomclash@aaagame.com with the subject line “request for information”. For us to provide you the information, we are legally required to verify your identity. The degree of verification will be determined by what is legally required by the law. This entails us requiring you to provide your name and the email address registered to your account. If this is not possible, you will be asked to provide your name and the user id, or “Friend Code” associated with your account.

The Right Request Deletion: You have the right to request we delete all or some of your personal information that we hold or are in possession of in both physical and digital form. These requests are not guaranteed under extraordinary exceptions, such as if we are requested to provide your personal information by law enforcement or similar government agencies. For us to delete all or some of your personal information, we are legally required to verify your identity. The degree of verification will be determined by what is legally required by the law. This entails us requiring you to provide your name and the email address registered to your account. If this is not possible, you will be asked to provide your name and the user id, or “Friend Code” associated with your account.

Right to Opt-Out: You have the right to opt-out of the sale of your personal information by sending a written message with your request that includes the subject line “request to opt out of sales” to kingdomclash@aaagame.com. Under California’s legal definition of “sell” or “sold” (which includes the not-for-profit disclosure, dissemination, or release of information to any third-party site such as Facebook, Google, or Apple) our company has engaged in the “selling” of our users’ personal information such as cookie IDs, device IDs, and IP addresses for the purposes of advertisement.

4. Children Policy

i. Policy Regarding Persons Under 21

Unless written otherwise, our games are intended for use by those 21 or older for amusement purposes only. Without derogating from the foregoing, AAAGame does not knowingly collect personal information from children under the age of 18. Children under the age of 18 should not use our websites or games at any time. If AAAGame learns that a person under the age of 18 has provided it with personal information, AAAGame will take reasonable steps to delete such information as soon as possible.

5. How we protect the information we store and share about you.

i. Security of Your Information

AAAGame has made reasonable technical and organizational measures designed to secure your information both online and offline from accidental loss and from unauthorized access, use, alteration, or disclosure, and we are committed to the protection of customer information. We will take reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy.

When you sign into your AAAGame account or enter payment information, we or our third-party payment processor use secure socket layer technology ("SSL") to encrypt the transmission of that information. While we take reasonable precautions against possible security breaches of our Services and our customer databases and records, no website or Internet transmission is completely secure, and AAAGame cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur and that third parties will never be able to overcome those measures or use your personal information for improper purposes.

Also please note that email and messaging systems are not considered secure, so AAAGame discourages you from sending AAAGame personal information through these media. We urge you to take steps to keep your personal information safe (including your account password), and to log out of your account after use. If you access our Services through a social network and your social network account is hacked, this may lead to unauthorized play of your AAAGame games without your permission. So, be careful to keep your Account Information secure.

Although we strive to protect your personal data, we cannot guarantee the security of your data while it is being transmitted to our site; any transmission is at your own risk. Once we have received your information, we have procedures and security features in place to try to prevent unauthorized access. If you have questions about the security of our websites, please submit a ticket via the applicable support channel of the game.

ii. Safety, Security and Compliance with Law

Your information, and the contents of all your online communications in our Services and between You and AAAGame may be accessed and monitored as needed to provide our Service and may be disclosed:

· When we have a good faith belief that we must disclose the information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or legal process (for example, a court order, search warrant or subpoena)

· To satisfy any laws or regulations that apply

· Where we believe in our sole discretion that the Service is being used in committing a crime, including to report such criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions

· When we have a good faith belief that there is an emergency that poses a threat to the health and/or safety of you, another person, or the public generally

· To protect the rights or property of AAAGame and other applicable third parties, including to enforce our Terms of Service

iii.  International Operations and Transfers Out of the EEA

When you use Our Services, your data may be sent to the United States and possibly other countries.

As part of our international operations, we may transfer data to our Affiliates (which means subsidiaries, parent companies, joint ventures, and other corporate entities under AAAGame group from time to time for our legitimate business purposes.

We store information about players and visitors to our sites on servers located in the United States, and we may also store this information on servers and equipment in other countries. Personal data collected within the European Economic Area (“EEA”) may be transferred to, and stored at, a destination outside of the EEA.

The data we hold may also be processed by employees operating outside of the EEA who work for us or one of our Affiliates or for one of our vendors. This staff may be engaged in, among other things, (i) the processing of transactions and your payment details and (ii) the provision of support services. When we transfer your personal information internationally, we will take reasonable steps to ensure that your personal information is treated securely, lawfully and in the manner we describe here. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored, used, or processed in, may be different from the privacy laws applicable to the place where you are resident.

The data we hold may also be processed by employees operating outside of the EEA who work for us or one of our Affiliates or for one of our vendors. This staff may be engaged in, among other things, (i) the processing of transactions and your payment details and (ii) the provision of support services. When we transfer your personal information internationally, we will take reasonable steps to ensure that your personal information is treated securely, lawfully and in the manner we describe here. Please note that laws vary from jurisdiction to jurisdiction, and so the privacy laws applicable to the places where your information is transferred to or stored, used, or processed in, may be different from the privacy laws applicable to the place where you are resident.

iv.How Long We Keep Your Information

How long we retain your information depends on why we collected it and how we use it. We will not retain your personal information for longer than is necessary for our business purposes or for legal requirements. For instance, we may retain some information for a few years after you have closed your account with us if this is necessary to meet our legal obligations or to exercise, defend or establish legal rights.

For more details regarding what information is kept and for how long, please refer to the table below:

v.Changes to Our Privacy Policy

If we decide to make material changes to our Privacy Policy, we will tell you and other players by placing a notice on www.kc.shengzhengkc.com or its equivalent in-game, or by sending you a notice to the e-mail address we have on file for you prior to the change becoming effective. We may supplement this process by placing notices on game blogs, social network pages, and/or forums and on other AAAGame websites. You should periodically check www.kc.shengzhengkc.com and this Privacy Policy for updates.

vi.Contact Us

For any questions, comments or concerns about our Privacy Policy or any other issue please contact AAAGame at: kingdomclash@aaagame.com or via our in-game customer service for any of our product(s).

6. Miscellaneous

i. Arbitration and Judicial Jurisdiction

This Privacy Policy and any related actions to it shall be governed under the laws of the People’s Republic of China without regard to its conflict of the provision of its laws. Any conflict or legal disputes arising from or related to this Privacy Policy shall be submitted to the Shanghai International Economic and Trade Arbitration Commission/Shanghai International Arbitration Center (“SHIAC”) for arbitration. Any such arbitrations will be conducted under the SHIAC’s procedures and rules that are in effect at the time of the arbitration’s submission to SHIAC. The seat of arbitration shall be in Shanghai, China, and the language to be used in the arbitral proceedings shall be in Chinese. Finally, the arbitral award is final and binding upon both parties.

ii. Information Security

AAAGame implements both physical and technical security measures to prevent any instance of cyber crime, theft, misuse, disclosure, alteration, destruction, or other illegal activities pertaining to your data and information. These measures include administrative policies aimed at preventing which every employee, contracted employee, and affiliate must adhere by to ensure your data and information’s safety.

iii. Links to Third Parties or Sites and Services which are non-AAAGame

IMPORTANT: THIS PRIVACY POLICY ONLY DESCRIBES AAAGAME’s PRACTICES.

AAAGame may provide Services may contain links to other sites, services, or applications not our own. We do not have any jurisdiction or influence over how those sites, services, or applications handle their own privacy policies or measures; thus, we take no responsibility for them. We highly recommend you frequently check their privacy policies to understand their practices.