Document

Saint Seiya Awakening (IOS) and Saint Seiya Awakening: Knights of the Zodiac (Android)

Privacy Policy

Last Updated: [0910] 2019

Please note that if you are ordinarily resident in Hong Kong Special Administrative Region (Hong Kong), Taiwan, or Macao Special Administrative Region (Macau), please refer instead to “https://member.gamamobi.com/member/privacy.html” privacy policy. If you are ordinarily resident in Thailand, Philippines, Indonesia or Malaysia, please refer instead to “https://www.gtarcade.com/en/privacy.html” privacy policy. If you are ordinarily resident in the People’s Republic of China (for the purpose of this privacy policy, this term excludes Hong Kong, Taiwan and Macau), please refer instead to “https://game.qq.com/privacy_guide.shtml” privacy policy.

Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Here is a summary of the information contained in this privacy policy. This summary is to help you navigate the privacy policy and it is not a substitute for reading everything! You can use the hyperlinks below to jump directly to particular sections.

What information do we need to provide the Game?

If you register an account to use the Game then we will need some information from you to set this up. We will also process some information when you use the Game (e.g., to make sure your progress is saved) and when you buy items (e.g., to ensure you get the purchased content). If you choose to set up your Game profile using a social media account, we also collect information from that social media account. If you need to get in touch with us then we will also retain some information so that we can get back in touch with you and address any concerns. More Information.

How will we use your information?

We use your information to provide the many functions and services that comprise the Game. We also use your information for account verification, security purposes and to support and improve the Game. We do not share your information with any third parties, except where we need to in order to provide the Game (e.g., using our affiliates around the world to help us to deliver the Game) or we are instructed to by a court, authority or compelled by law. More Information

Who do we share your information with?

We have affiliates around the world who help us deliver the Game and we may be required by a court or legal obligation to disclose certain information in some circumstances More Information

Where do we process your information?

Our servers are located in the United States, Singapore, Germany, France, Hong Kong Special Administrative Region (Hong Kong) and the People’s Republic of China (for the purpose of this privacy policy, this term excludes Hong Kong, Taiwan and Macau). Our support, engineering and other teams are located in our offices around the world (including the United States and Hong Kong). More Information

How long do we keep hold of your information?

We generally retain your information for the period for which the Game is available after which time your data is deleted (as further described in this privacy policy), unless otherwise required by applicable laws. More Information

How can I exercise my rights over my information?

Depending on where you live, you may have certain rights with respect to your information, such as rights of access, to receive a copy of your data, or to delete your data or restrict or object to our processing of your data. More Information

How to get in touch with us

If you have any questions about anything in this policy, or want to exercise any rights you may have, please contact us here.

How will we notify you of changes?

If there are any significant changes to this privacy policy, we will update the policy here. More Information

Contact Information

Data Controllers:

Youzu (Singapore) PTE. LTD. Email: dataprotectofficer@yoozoo.com

Proxima Beta Pte. Limited. Email: dpo@proximabeta.com

EU Representative:

For Proxima Beta Pte. Limited: Tencent International Service Europe B.V. Email: eudataprotection@tencent.com

Welcome to Saint Seiya Awakening(IOS) and Saint Seiya Awakening: Knights of the Zodiac(Android) !

This privacy policy explains the when, how and why when it comes to processing of your personal information in connection with the mobile game Saint Seiya Awakening(IOS) and Saint Seiya Awakening: Knights of the Zodiac(Android) (the “Game”), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

If you do not agree to the processing of your personal information in the way this privacy policy describes, please do not provide your information when requested and stop using the Game. By using the Game you are accepting our rules regarding your personal information as described in this privacy policy.

This Game is published by Youzu (Singapore) Pte. Ltd. (“Youzu”) and has been developed by Proxima Beta Pte Limited. (“Proxima Beta”) (collectively, “we”, “us”, “our”).

For the purpose of EU data protection laws, we are the joint data controllers, except where otherwise states in this privacy policy. This means we jointly determine the means and purposes of processing personal data collected in connection with the operation of the Game.

Youzu is a company registered in Singapore with its office located at 9 Raffles Place #26-01 Republic Plaza Singapore (048619) . Youzu can be contacted at dataprotectofficer@yoozoo.com.

Proxima Beta is a company registered in Singapore with its office located at 10 Anson Road #21-07 International Plaza. The representative of Proxima Beta in the EU for the purpose of EU data protection laws is Tencent International Service Europe B.V , which is a Dutch company within the Tencent group. The registered address of Tencent International Service Europe B.V is 26.04 on the 26th floor of Amstelplein 54, 1096 BC Amsterdam, the Netherlands. Our data protection officer can be contacted at eudataprotection@tencent.com.

Please reach out to us if you have any questions or concerns regarding the processing of your personal information: you should at first instance contact Youzu at dataprotectofficer@yoozoo.com. You can also contact Proxima Beta at any time at dpo@proximabeta.com.

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled “How we use your personal information” below.

The following is a high level summary of the types of personal information we use:

You give us information about you when you register and log in for the Game such as your social media ID if you register or log in using your social media account or your Youzu ID and email address if you register or log in using Youzu GT Arcade. We import this information in order to set up your Game profile. If you log in to Youzu’s website “https://www.gtarcade.com/ ” (the “Website”), then Youzu also collects the information listed immediately above in this paragraph from your social media account.

We automatically collect certain data from you so that we can provide you with the many functions and services that comprise the Game. This includes Game log-in information, certain activity, network and device information, IP address, game and log data, chat data, transaction information (if you conduct any transactions), your advertising ID, your friends list (if you choose to log in using Facebook), security and debugging related information, data for the purpose of Game analytics, data for the purpose of updating your security related information, quality monitoring information, support data (if you contact customer support), and information pertaining to notifications and in-Game settings to process Game updates.

We collect and store your Game data, which includes your Open ID, IP address, server data, device information and device and game settings, as well as your Game play statistics, in order to provide you with feedback and information about your Game play and progress.

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Website, to which you may be directed if you use the Game’s customer support features. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.

You have the option to permit installation of such Cookies or subsequently disable them. You may accept all cookies, or instruct the device to provide notice at the time of installation of cookies, or refuse to accept all cookies by adjusting the relevant cookie retention function in your device. However, in the event of your refusal to install cookies, the Website (or part of the Website) may be unable to operate as designed.

The Game is not intended for children. Children must not use the Game for any purpose. By children, we mean users under the age of 16 years old; or in the case of users located in in the countries specified below, the specified age.

If you are over the age of 16 years old but under the age stipulated below, you need the consent of your parent or guardian before using the Game.

Country/region	Minimum age
Australia	18
Brazil	18
European Economic Area (all EU countries, Iceland, Liechtenstein and Norway)	16


Switzerland	16
Turkey	18

Russia	14

We do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under this age, please contact Youzu in the first instance at dataprotectofficer@yoozoo.com. You may also contact Proxima Beta at dpo@proximabeta.com and we will delete such information.

This section provides more detail on the types of personal information we collect from you, and why. For users who live in the European Economic Area (“EEA”), it also identifies the legal basis under which we process your data.

We may collect other personal information from you from time to time for specific reasons (such as a promotion in your country/region). When this happens, we will provide more information on any specific changes to the way we process that personal information that might differ to this privacy policy prior to collecting or processing any additional information. In some cases, that information may be shared with us with your consent – and if that is the case, we will provide you with further information on how we process that information and your rights.

We operate around the world. Pursuant to our contract with you to provide you with this Game, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this privacy policy. Our servers for this Game are located in:

Only where necessary will we share your personal information with third parties. Situations where this occur are:

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the information transmitted to our services; therefore we do not assume any responsibility for any transmission of your information which you do at your own risk.

We may provide links to and from the websites and/or applications of our partners and affiliates. If you follow a link to any of these websites, please note that these websites and/or applications have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any information to these websites and/or applications. Your acceptance or consent to this Privacy Policy does not cover your acceptance or consent to any other privacy policies.

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.

Some countries’ laws grant specific rights to users of this Game, which are set out in this section.

This section entitled “Your Rights” applies to users that are located in the European Economic Area.

The sub-sections entitled “Access”, “Correction”, and “Erasure” also apply to users that are located in Brazil, Canada and Russia.

You have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at dataprotectofficer@yoozoo.com.

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your Game account. If you believe we hold any other personal information about you, please contact us at dataprotectofficer@yoozoo.com.

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent or pursuant to our contract with you, as described above in the section “How We Use Your Personal Information”. You have the right to receive this personal information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer it to another party, with certain exceptions. We will provide further information to you about this if you make such a request.

You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your Game account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at dataprotectofficer@yoozoo.com.

If there is any personal information you believe we process that you would like us to erase, please contact us at dataprotectofficer@yoozoo.com.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on this Game and there are grounds for erasure, we will use reasonable steps to try to tell others who are displaying the personal information or providing links to the personal information to erase it too.

You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

You have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below by contacting us at dataprotectofficer@yoozoo.com.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at dataprotectofficer@yoozoo.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend Game access for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.

We welcome questions, comments and requests regarding this privacy policy. Please address them to Youzu at dataprotectofficer@yoozoo.com. You can also contact Proxima Beta at any time at dpo@proximabeta.com.

In the event that you wish to make a complaint about how we process your personal information, please contact Youzu in the first instance at dataprotectofficer@yoozoo.com and Youzu will endeavour to deal with your request as soon as possible. You can also contact Proxima Beta at any time at dpo@proximabeta.com. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you consider we have infringed data protection laws.

If we make any material changes to this privacy policy, we will post the updated privacy policy here and notify our users within the Game. Please check this page frequently to see any updates or changes to this privacy policy.

SUPPLEMENTAL TERMS FOR USERS IN CERTAIN JURISDICTIONS

Some countries’ laws contain additional terms for users of this Game, which are set out in this section.

If you are a user located in one of the countries listed below, then the terms set out below under the name of your country apply to you.

If you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Game.

Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the Game. You acknowledge that if you do not provide us with your personal information, we may be unable to provide you with access to certain features or sections of the Game, including social media integration and in-Game purchases.

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the Australian Information Commissioner (Telephone +61 1300 363 992 or email enquiries@oaic.gov.au).

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORIZE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL DATA, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

If a user located in Canada wishes to obtain written information about our policies and practices with respect to our service providers located outside Canada, they may contact Youzu at the first instance at dataprotectofficer@yoozoo.com. You may also contact Proxima Beta at any time at dpo@proximabeta.com. Our privacy experts who monitor these email addresses are also able to answer any questions users may have about the collection, use, disclosure or storage of personal information by our service providers.

Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.

If you are using this App in Russia, you consent (for the purposes of the Russian Federal Law No. 152-FZ dated 27 July 2006 “On Personal Data” (as amended) or any replacement regulations) to the processing in accordance with this privacy policy of your information. You also consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to United States, Singapore, Germany, France, Hong Kong Special Administrative Region (Hong Kong) and the People’s Republic of China (for the purpose of this privacy policy, this term excludes Hong Kong, Taiwan and Macau).

The data controller representative in Turkey for the purpose of compliance with Turkish law on Personal Data Protection Law and its secondary regulations can be contacted at dataprotectofficer@yoozoo.com for Youzu and at dpo@proximabeta.com for Proxima Beta. Please include the word “Turkey” in the subject line of your email.

You have legal rights in relation to the personal information data we hold about you. As a Turkish data subject, you may have right to (and to the extent permitted under applicable laws and regulations):

b) request information about processing if your personal data has been processed;

d) know the third parties in the country or abroad to whom personal data has been transferred;

e) request rectification in the event personal data is incomplete or inaccurate;

f) request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the Personal Data Protection Law (Turkey);

g) object to certain processing of data, and seek certain remedies in accordance with the Personal Data Protection Law (Turkey).

Users located in Turkey and under the age of 18 are required to obtain parental/guardian consent prior to using the App. Also above mentioned rights must be used by their parents/guardian on behalf of them.

We may voluntarily report a cyber-security incident where it constitutes a crime under UAE law (e.g. under the UAE Cybercrime Law). The incident can be reported to the relevant authorities for the purpose of investigations. Please note also that voluntary reporting of a cyber-security incident can also be made to the UAE Computer Emergency Response Team (“CERT”). CERT is a security awareness organisation that provides a process for logging incidents and advising on known cyber security threats in the UAE.

Personal Information	Use	Legal Basis (only relevant if you are located in the EEA)
Game
Information you provide to us (either directly or through a third party).
Account creation and log-in using: Facebook: Facebook ID, access token, name, profile picture; Twitter: Twitter ID, access token, name, profile picture; Google: Google ID, access token, name, profile picture; Game Center: Player ID, name, profile picture; and Youzu GT Arcade: Youzu ID, email address	We use this information to set up your account and facilitate your log-in in accordance with your instructions.	Necessary to perform our contract with you to provide this Game.
Website: If you log-in to Youzu’s Website, Youzu collects the following information from you: Facebook: Facebook ID, access token, name, profile picture; Twitter: Twitter ID, access token, name, profile picture; Google: Google ID, access token, name, profile picture; Game Center: Player ID, name, profile picture; and Youzu GT Arcade: Youzu ID, email address	Youzu uses this information to facilitate your log-in to the Youzu’s website.	Necessary to perform our contract with you to provide you access to the website for this Game.
Friends list: If you log-in using Facebook, we collect your friends’ Facebook ID, name, nickname and profile picture.	We use this information so that you can connect with your friends.	Necessary to perform our contract with you to provide the Game and connect you with your friends.
Information generated as part of the Game (and its in-Game services)
Game log-in: IDFV (for iOS users) or UUID (for Android users), SDK version, network information, device information including brand, model, language and screen settings and hardware information.	We use this information to process your account registration and log-ins into the Game.	Necessary to perform our contract with you to register an account, log-in and play the Game.
Game data: Open ID, IP address, server data, game settings, device information including system version, IDFV, network type, hardware information, settings and status (including charging and battery status, and brightness), gameplay information including rankings, battle-related data, comments, level data, package data, game progress, resources, scores; in-game profile and character information including nickname, picture, equipment, image cache, legion guild data, friends list, mailbox and announcements, in-Game virtual gold data; purchase data.	We use this information to: provide you with feedback and information about your gameplay and progress; and to facilitate your use of the Game, and to improve the Game, including the functionality of the Game.	IP Address: Necessary to perform our contract with you in order to facilitate a connection to the game server. All other Game Data: Necessary to perform our contract with you in order to allow you to play the game and for details of game activity to be documented and saved for future game play.
Advertising: If you log-in using Facebook, Twitter, Google, Game Center or Youzu GT Aracade, Youzu collects: IP address, IDFA/IMEI, device model, country code, advertising ID, platform, device brand.	If you click on a link that advertises the Game, Youzu processes the advertising ID for that advertisement.	It is in Youzu’s legitimate interests to use this information to monitor the success of Youzu’s advertising and marketing programs.
Payments: If you make purchases through the Apple App-Store or Google Play: Youzu processes information about your transaction, player ID, device ID, device information, device cookies, IDFV, device status, network type, network operator, phone number, MAC address, version, OS, currency; and Proxima Beta processes Open ID, item ID, device settings and information including IMEI, MAC address, IDFV, network type, hardware information, device status.	We use this information to facilitate your purchases and to allow you to make a payment.	Necessary to perform our contract with you to facilitate your payment and provide you with details of your transactions.
Chat data: Text and audio: Content of your message, Open ID, IP address, nickname, union information including player ID, levels, scores), user profile, in-game profile picture , battle log data, image cache and voice data (if you use audio chat).	If you enable chat services (audio and/or text) then we will process such data in order to deliver your messages to other users.	Necessary to perform our contract with you to provide the chat services in-Game.
Customer Support: If you use our customer support function, we collect: IP address, device model, country code, platform, device brand, email address (if you choose to contact us via email or provide your email otherwise to us), Open ID, network information.	We use this information to improve our services and to provide troubleshooting, such as addressing and remediating technical issues and bugs.	Necessary to perform our contract with you to provide and support the Game.
Debugging: SDK information and game account information; device settings and information including system version, IDFV, network type, hardware information, device status; user information including application package, application version, process name; Game-app information including Game bundle ID and Game version.	Proxima Beta uses this information to improve the Game by addressing and remediating technical issues and bugs.	It is in our legitimate interest to debug the Game and to provide you with a stable game system.
Game analytics: SDK information and game account information; device settings and information including system version, IDFV, network type, hardware information, device status; user information including application package, application version, process name; Game-app information including Game bundle ID and Game version.	Proxima Beta uses this information for the purpose of Game-analytics to assess the functionality of the Game and to improve the Game.	It is in our legitimate interest to analyse the functionality of the Game and to improve it.
Quality monitoring: Open ID, device settings and information, MAC address, Android ID, hardware information including performance and usage, IMEI, Game performance data, network traffic, Game system related files names and opened URLs, role ID, IP address, user-connected WiFi SSID and client exit; device’s ID number, UUID.	Proxima Beta uses this information to monitor the quality of the Game functions and the services provided in connection with this Game.	It is in our legitimate interest to monitor the quality of the Game and the services provided in connection with this Game.
Image quality setting: device information and hardware information	Proxima Beta uses this information to set the image quality of the Game to an adequate setting for your device’s performance.	Necessary to perform our contract with you to provide the Game.
SDK update: Open ID, login channel ID, device information	Proxima Beta uses this information to download and configure SDK updates for the Game in accordance with your device’s information.	Necessary to perform our contract with you to provide the Game.
Notifications and Game settings for updates: IDFV (iOS), UUID (Android), device settings and information, SDK version, resolution, screen orientation, network type, hardware information, language and region settings.	Proxima Beta uses this information to notify you about updates and any important information before you start the Game and to retain your original Game settings after Game updates.	Necessary to perform our contract with you to provide the Game.

Personal Information	Retention Policy
Account creation and Game log-in information; Advertisement data; Customer support; Website Game data; Friends list; and Chat data.	Stored for the lifetime of the Game and is then deleted within 30 days. If you request the deletion of this data, we will delete it within 30 days from receipt of your deletion-request.
Payments	Stored for one year, unless you request the deletion of your account or you request to delete this data. In both cases, your data will be deleted within 30 days from your request. Please note that these time periods are subject at all times to our legal obligations to retain certain information (for example, pursuant to anti-money laundering requirements or tax laws). The period of time for which such data will be retained will in those cases be in accordance with our legal obligations.
Debugging	Stored for 30 days and then automatically deleted. If you request to delete your account or the Game reaches the end of its lifetime, we delete your data within 30 days.
Game analytics	Stored for three months and then automatically deleted. If you request to delete your account or the Game reaches the end of its lifetime, we delete your data within three months.
Quality monitoring	Stored for up to one year. If you request your account deletion or the deletion of this data, we will delete the data in either case within 30 days from your deletion request.
Image quality setting	Stored for 30 days and then deleted automatically.
SDK update; and Notifications and Game settings for updates.	We do not store this information.