**Fenshun Network Game Privacy Terms** **Update Date: April 25, 2024** These "Fenshun Network Game Privacy Terms" ("Privacy Terms") are an inseparable part of the "Fenshun Network Game License and Service Agreement" ("User Agreement"), agreed upon by the user (hereinafter also referred to as "you") and Fenshun Network Technology (Shanghai) Company Limited (hereinafter referred to as "Fenshun Network" or "we"). Unless the user has read and accepted all contents of these Privacy Terms, they have no right to use Fenshun Network games and services. Using Fenshun Network games and services constitutes the user's acknowledgment and agreement to sign these Privacy Terms. These Privacy Terms clarify your understanding of the following: 1. How we collect and use personal information 2. How we share, transfer, and publicly disclose your personal information 3. How we store and protect your personal information 4. Your rights to manage personal information 5. Service suspension and termination 6. Updates to these Privacy Terms and access 7. Contact us 8. Other **1. How We Collect and Use Personal Information** Fenshun Network collects and uses your personal information based on legal and regulatory compliance and following principles of legitimacy, legality, and necessity. This is necessary for using our services or as needed by our products and/or services. If we wish to use your personal information for purposes not specified in these Privacy Terms, or for other purposes based on specific reasons, we will inform you in a timely and reasonable manner and seek your consent again before using it. The types of personal information we collect and use include: - **Essential Information**: Necessary for the core functions of our products and/or services; your authorization is required. If you refuse to provide this, you will not be able to use our products and/or services normally. - **Additional Information**: Needed for non-core business functions; you can choose whether to authorize us to collect this. If you refuse, it may prevent the realization of additional business functions or achieving our intended effects but will not affect the normal use of core business functions. We would like to remind you that as our game products and services vary, so do the core business functions and the types of personal information collected, which differ based on the content of the specific game product/service provided. Additionally, as we strive to offer you perfected game products and services, we continuously improve our offerings, including technology, which means we may frequently introduce new business functions that might require the collection of new personal information or changes in the purpose or manner of use of personal information. If a function or game product/service that collects your personal information is not specified in these Privacy Terms, we will provide further explanations through updates to this policy, page prompts, pop-ups, etc., about the purpose, content, manner, and scope of such information collection, offering you the option to consent independently, and will collect it only after obtaining your explicit consent. If you have any doubts about these matters, you can contact us using the method provided in Section 7 of these Privacy Terms, and we will respond promptly. In the process of using Fenshun Network games and services, we typically collect and use your personal information in the following scenarios: **Account Registration and Identity Verification:** - **When registering and logging into a Fenshun Network user account or using our game products and services**, you need to follow our instructions to complete a series of registration procedures, during which you will need to provide us with information including account nickname, user avatar, mobile phone number, and email address. Collecting this information is necessary to label and identify you as a Fenshun Network user and to save your login information. This information is essential for registering and logging into a Fenshun Network user account or for using Fenshun Network game products and services. If you choose not to provide it, you may not be able to use Fenshun Network game products and services. - **For some game products and services**, we support logging in with third-party platform accounts. If you log in using a third-party platform account, we will collect related information under that account based on your authorization (including third-party account, username, nickname, avatar, and other authorized information, as specifically displayed on the third-party account authorization page). Collecting this information helps provide you with account login services and ensures the security of your account, guarding against security risks. If you refuse to authorize this information, you will not be able to use third-party platform accounts to log into our platform, but it will not affect the normal use of our other products and services. - **To satisfy real identity verification requirements**, we may need you to provide real identity information and biometric information (static or dynamic facial features) to complete identity authentication . If you do not provide the aforementioned information, we will not be able to offer you related functions and services. For identity verification purposes, you agree and authorize us to provide, inquire about, and verify your aforementioned identity information with relevant identity authentication institutions (such as personal credit agencies, government departments, etc.), either on our own or through entrusted third parties. Please note, your identity information, biometric information, and similar sensitive personal information should be provided with caution. If you refuse to provide this information, you may not be able to receive related services, but this will not affect the normal use of other functions and services. **Using Fenshun Network Games and Services:** - **Reading/Writing External Device Storage**: We need to obtain permission to read/write external device storage (if you use an Android device, the involved permissions might include "Read External Storage Permission," "Read/Write SD Card Content Permission," and "Modify/Delete SD Card Content Permission"). Acquiring these permissions and information is necessary for installing game products on the device, storing and retrieving game saves and files (including necessary game processes and caches, as well as reading, writing/downloading/saving/modifying images or albums, files, crash logs, etc.), ensuring you can log in and use our services normally, and maintaining the basic functions of the game in a stable manner. If you refuse to provide the aforementioned permissions, you may not be able to use our related products and services. - **Game Log Information**: Includes login logs, item logs, shop purchase logs, event logs, guild logs, upgrade logs, chat logs, in-game friendship records, game match information, and other game log information generated during the use of Fenshun Network game products and services. We collect this information for game operation statistical analysis, customer service complaint handling, game anti-cheating analysis, and other game experience optimization analyses, also facilitating your access to your game history records within the game client. If you refuse to provide the aforementioned permissions, you may not be able to use our related products and services. - **Interaction Information**: When you interact with other players in the game through text, images, voice, and other means, we may collect and save the aforementioned information content to filter inappropriate content such as pornography, violence, politics, insults, malicious advertising, etc., thereby purifying the gaming environment and maintaining a healthy online environment. If you refuse to provide the aforementioned permissions, you may not be able to use our related products and services. If you wish to interact with other users through voice or capture, upload, save pictures, after your authorized consent, Fenshun Network games will access your microphone, camera (camera), album, read/write external device storage permissions. If you refuse to provide the aforementioned permissions, you may not be able to use our related products and services, but it will not affect the normal use of other functions of Fenshun Network games and services (except as otherwise provided in these Privacy Terms), and you can also close the aforementioned permissions at any time in the system settings. - **Game Application Information, Device Information (Unique Device Identifier, Device Serial Number, Device Manufacturer, Device Name, Device Type and Version, Device Model, Device Style, Device MAC Address), Network Identity Information (IP Address), Operating System and Process Information, Network Environment Information, and Game Crash Records**: We collect the aforementioned information for verifying account information, ensuring the security of your game account, and for advertisement data monitoring and verification, as well as to create a fair, healthy, and secure gaming environment, combating behaviors that disrupt the fair gaming environment or interfere with, disrupt the normal operation of game services (such as detecting piracy, scanning plugins, preventing cheating, etc.); we may use your IP address to identify the location of your device when connected to the Internet, to facilitate specific activity content and display your IP location according to relevant regulations. Please pay special attention that in some older versions of Android systems, mobile manufacturers may bundle permission requests. In such cases, our pop-up window for obtaining device information may display as asking permission to make calls and manage calls. If you refuse to provide the aforementioned permissions or information, you may not be able to use our related products and services. - **Transaction Information**: Includes recharge records, consumption records, and other necessary information related to transactions. When you use certain in-game consumption features, we collect the aforementioned information to enable you to check your transaction records and ensure the security of your virtual items to the greatest extent possible. In case of disputes during transactions, we provide information to customer service personnel to support the handling of dispute claims. Recharge records and consumption records are considered sensitive personal information. Collecting the aforementioned information is necessary to realize the consumption functions of Fenshun Network services; otherwise, transactions cannot be completed. If you refuse to provide the aforementioned permissions or information, you may not be able to use our related products and services. - **Sensor Information**: We use an accelerometer sensor to determine the orientation changes of the device itself by obtaining sensor data, thereby adjusting the display layout of the chat interface in landscape/portrait mode differently. **Customer Service**: When you initiate a complaint, appeal, or consultation with Fenshun Network, for your account and system security, we may require you to provide account information first and match it with your previously provided personal information to verify your user identity. Additionally, to facilitate contact with you or to help solve your problems or send gifts, we may also need you to provide your name, mobile phone number, email, address, and other contact information and personal information. Furthermore, we will collect information about your communication with us (including text/images/audio/video/call record forms) and other necessary information related to your needs. The aforementioned information is considered sensitive personal information, and we collect it to investigate facts and help solve your problems. If you refuse to provide the aforementioned information, we may not be able to provide you with timely feedback on complaints, appeals, or consultations. **Cookies and Similar Technologies**: To improve related services, Fenshun Network may use cookies and similar technologies to store and track user-related data at certain times. The use of these technologies is limited to estimating traffic numbers, statistically analyzing user preferences, and other commercial, market analysis, or academic purposes. Cookies and similar technologies may be used by third parties, such as advertising services requiring recognizable data, as evaluation metrics and data, which are only used for analysis to evaluate the effectiveness of promotional and marketing activities and to improve them. **According to relevant laws and regulations, in the following situations, we may collect and use your related personal information without seeking your consent**: 1. Related to our fulfillment of obligations prescribed by laws and regulations; 2. Directly related to public safety, public health, public information, and other significant public interests; 3. Directly related to criminal investigation, prosecution, trial, and judgment enforcement; 4. For the protection of the life, property, reputation, and other significant lawful rights and interests of you or other individuals, but it is difficult to obtain consent; 5. The personal information collected is disclosed by you to the public; 6. Collecting personal information from legally publicly disclosed information, such as lawful news reports, government information disclosure, etc.; 7. Necessary for the signing and performance of contracts at your request; 8. Necessary for maintaining the safe and stable operation of the products or services provided by Fenshun Network, such as discovering and handling faults in products or services; 9. Necessary for conducting lawful news reporting; 10. Necessary for conducting statistical or academic research for public interest, and when providing academic research or descriptive results to the outside, the personal information contained in the results undergoes de-identification processing; 11. Other circumstances stipulated by laws and regulations. Please understand that the functions and services we provide you are continuously updated and developed. If a function or service not mentioned above collects your information, we will explain the content, scope, and purpose of the information collection through page prompts, interactive processes, website announcements, etc., to obtain your consent. **II. How We Share, Transfer, and Publicly Disclose Your Personal Information** 1. **Sharing** We value the protection of your personal information. Your personal information is an important basis and component for us to provide you with products and/or services. We only collect and use your personal information within the scope and purposes described in these Privacy Terms or as required by law, and maintain strict confidentiality. Under normal circumstances, we do not share your personal information with any companies, organizations, and individuals, except in the following cases: 1) Prior explicit authorization or consent obtained from you; 2) Required to share your personal information according to applicable laws, legal procedures, government mandatory orders, or judicial decisions; 3) Within the scope permitted or required by law, it is necessary to provide your personal information to third parties to protect the interests, property, or safety of Fenshun Network and its users or the public from harm; 4) Your personal information may be shared among our affiliated companies. We only share necessary personal information, and such sharing is also subject to the purposes stated in these Privacy Terms. Affiliated companies will seek your authorization again if they wish to change the purpose of processing the personal information; 5) To provide you with better, higher quality products and services, some of our services are provided by authorized partners. We may share some of your personal information with partners to provide better customer service and user experience. We only share your personal information for legal, legitimate, necessary, specific, and explicit purposes, and only the personal information necessary to provide the service is shared. Also, we require partners to process your personal information according to our instructions, these Privacy Terms, and other relevant confidentiality and security measures. Our partners do not have the right to use the shared personal information for any other purposes. If you refuse our partners to collect the personal information necessary to provide the service, you may not be able to use the third-party service on our platform. 6) Some of our games can also be downloaded and enjoy game services through the game co-operation channel platform. If you obtain software products through game co-operation channels (such as brand mobile phones or third-party app stores) other than the Fenshun Network platform, some channels will integrate the co-operation channel SDK into the software products to log into our game products and implement payments through that channel. To ensure you can smoothly log into the game products and use the related services, you need to authorize the co-operation channel SDK to provide the corresponding services; after your authorization, the channel party will collect your relevant personal information. The software products that integrate the co-operation channel SDK are provided by the co-operation channel with account, payment, and customer service-related services, including but not limited to account registration, account login, and account information changes. Please read the relevant co-operation channel privacy policy terms based on the specific co-operation channel from which you obtained the software products to understand the types of information collected, purposes, and personal information protection rules by the channel party. The information collection and processing activities of our partners are governed by their own privacy terms or declarations, which do not apply to these Privacy Terms. To ensure the maximum protection of your information, we recommend that you review the privacy terms of any third-party services before use. To protect your legal rights, if you discover any risks associated with related third-party services, we suggest you immediately terminate the related operations and promptly contact us. 2. **Transfer** We will not transfer your personal information to any company, organization, or individual, except in the following cases: 1) Transfer upon obtaining explicit consent: After obtaining your explicit consent, we will transfer your personal information to other parties; 2) Required to provide in cases mandated by applicable laws, legal procedures, mandatory administrative or judicial requirements; 3) In cases involving mergers, acquisitions, asset transfers, bankruptcy liquidation, or similar transactions, if personal information transfer is involved, we will require the new entity that holds your personal information to continue to be bound by these "Privacy Terms," otherwise, we will require that entity or organization to seek your authorization again. 3. **Public Disclosure** We will only publicly disclose your personal information in the following cases: 1) After obtaining your explicit consent; 2) Based on legal disclosure: In cases where disclosure is mandated by law, legal procedures, litigation, or by governmental authorities, we may publicly disclose your personal information. 4. **Cases Where Prior Consent Is Not Required** In the following situations, we may share, transfer, and publicly disclose personal information without obtaining your prior consent: 1) Related to our fulfillment of obligations; 2) Directly related to public safety, public health, and significant public interests; 3) Directly related to criminal investigation, prosecution, trial, and judgment enforcement; 4) For protecting the significant lawful rights and interests of the personal information subject or other individuals, where it is difficult to obtain consent; 5) The personal information subject voluntarily disclosed the personal information to the public; 6) Collecting personal information from legally publicly disclosed sources, such as lawful news reports and government information disclosure. According to legal stipulations, sharing, transferring, and publicly disclosing personal information that has been de-identified, ensuring that the recipient cannot restore and re-identify the personal information subject, does not constitute an act of sharing, transferring, or publicly disclosing personal information, and such data's storage and processing do not require further notification and consent from you. **III. How We Store and Protect Your Personal Information** 1. **Information Storage** 1) Storage Duration: We retain your personal information for the shortest duration necessary to fulfill the purposes of providing products and services. 2) After exceeding the storage duration, we will delete or anonymize (de-identify) your personal information. 2. **Information Protection** 1) Your personal information security is critically important to us. We strictly comply with relevant laws and regulations and take industry-recognized reasonable and feasible measures to protect your personal information, preventing unauthorized access, disclosure, use, alteration, and loss of information. 2) When Fenshun Network requires users to provide information related to their personal identity, it must disclose its privacy terms to users in a clear and noticeable manner beforehand and take necessary measures to protect user information. 3) Except as explicitly stipulated in these Privacy Terms, without user permission, Fenshun Network may not provide, disclose, or share personal identity information included in user registration data, such as name, contact information, home address, etc., except in the following cases: authorized by the user or the user's guardian for Fenshun Network to disclose; required by relevant laws and regulations or mandatory provisions for Fenshun Network to disclose; required by judicial or administrative bodies based on legal procedures for Fenshun Network to provide; when Fenshun Network is maintaining its legal rights and initiates litigation or arbitration against a user; provided at the legal request of a user's guardian to provide user personal identity information. 3. **User Account Use and Custody** 1) To ensure user account security, Fenshun Network has the right to review whether the identity information provided by users during registration is true and valid and should actively take technical and managerial measures to ensure the security and effectiveness of user accounts. Users have the obligation to properly keep their account and password and use their account and password correctly and securely. Failure by either party to fulfill the aforementioned obligations resulting in lost account passwords, stolen accounts, or other situations causing damage to the civil rights of users and others shall bear legal responsibility. 2) Users have legal rights and bear responsibilities for activities conducted using their accounts after login. 3) If a user discovers that their account or password is being used illegally by others or if there are abnormal usage circumstances, the user should promptly notify Fenshun Network according to the processing methods announced by Fenshun Network and has the right to instruct Fenshun Network to take measures to suspend the login and use of that account. 4) When Fenshun Network takes measures to suspend the login and use of a user's account based on the user's notification, Fenshun Network should require the user to provide and verify personal valid identity information consistent with their registered identity information. 5) If Fenshun Network verifies that the user's provided personal valid identity information is consistent with the registered identity information, it should promptly take measures to suspend the login and use of the user's account. **IV. Your Rights to Manage Personal Information** We understand your concern for personal information and strive to ensure you have the right to inquire, correct, delete, and revoke authorization for your personal information, enabling you to fully protect your privacy and security. Your rights include: 1. **You have the right to inquire about your personal information** You can inquire about the personal information you have provided to us according to the instructions (or settings) provided by our products and services. This includes: 1) Account Information: You can access your personal information page within the relevant game product at any time to access your personal data, including avatar, nickname, etc. 2. **You have the right to correct your personal information** If you find that the personal information you have provided to us is registered incorrectly, incomplete, or needs to be updated, you can contact us through the methods provided in these Privacy Terms and submit a correction request. 1) For some of your personal information, such as your avatar and nickname, we provide operational settings on the relevant game function pages, allowing you to directly make corrections/modifications. 2) If you encounter difficulties in exercising the above rights, or for other situations where we may currently not provide online self-correction/modification services, you can contact us through the methods provided in these Privacy Terms and request us to correct or modify your information. After verifying your identity and ensuring that the correction/modification does not affect the objectivity and accuracy of the information, we can correct or modify incorrect or incomplete information, unless otherwise stipulated by laws and regulations. 3. **You have the right to delete your personal information** 1) For some of your personal information, you can contact us through the methods provided in these Privacy Terms to submit a deletion request. After the deletion request is approved, we will delete or anonymize the information, unless otherwise stipulated by laws and regulations. 2) When the following situations occur, you can directly request us to delete your personal information, except for information that has been anonymized or otherwise stipulated by laws and regulations: a) When our handling of personal information violates laws and regulations; b) When we collect and use your personal information without obtaining your consent; c) When our handling of personal information violates our agreement with you; d) When we terminate service and operations. 4. **You have the right to withdraw your authorization for personal information and permissions** As mentioned earlier, some functions of the game products and services we provide require obtaining related permissions from your device (including the album, camera, microphone, etc., specific to the functions actually obtained by the product). You can withdraw (or stop) the continued authorization for these permissions at any time after granting them. For example, you can turn off your authorization for the photo album on your iOS device by going to "Settings - Privacy - Photos." Understand that once you withdraw authorization, we will not be able to continue providing you with specific functions and/or services corresponding to the withdrawn authorization. However, your decision to withdraw authorization will not affect the processing of personal information previously carried out based on your authorization. **V. Service Suspension and Termination** 1. Users who post illegal information, seriously violate social morals, or engage in other behaviors prohibited by law, Fenshun Network has the right to immediately terminate the provision of services to the user. 2. If a user engages in improper behavior while receiving services from Fenshun Network, Fenshun Network has the right to terminate the provision of services to the user. 3. If a user provides false registration identity information or engages in behavior that violates this agreement, Fenshun Network has the right to suspend the provision of all or part of the services to the user; Fenshun Network taking suspension measures should notify the user and inform the suspension period, which should be reasonable. After the suspension period expires, Fenshun Network should promptly restore services to the user. **VI. Updates to These Privacy Terms and Access** 1. To provide you with better services, we will update the terms of these Privacy Terms based on the update status of the product and the relevant requirements of laws and regulations, and such updates constitute part of these Privacy Terms. Without your explicit consent, we will not reduce the rights you are entitled to under these Privacy Terms. If such updates result in a substantial reduction or significant change to your rights under these Privacy Terms, we will notify you by highlighting the notification or sending you a push message or by other means. If you continue to use our services, it indicates that you have fully read, understood, and agreed to be bound by the revised Privacy Terms. 2. Significant changes include but are not limited to: 1) Major changes in our service model, such as changes in the purpose of processing personal information, the types of personal information processed, and the use of personal information; 2) Significant changes in ownership structure, organizational structure, etc., such as business adjustments, bankruptcy mergers, and acquisitions causing changes in ownership; 3) Changes in the main recipients of personal information sharing, transferring, or public disclosure; 4) Significant changes in your rights to participate in personal information processing and how they are exercised; 5) Changes in the contact information and complaint channels of personnel responsible for handling personal information security; 6) When a personal information security impact assessment report indicates high risk. **VII. Contact Us** 1. If you have any questions or need consultation or complaints related to personal information protection when using our "Fenshun Network Game Privacy Terms" or our services, you can contact us through any of the following methods: 1) You can contact customer service or submit feedback online on the relevant function pages in the Fenshun Network game product; 2) You can send an email to our dedicated customer service email support@moment.fun to contact us; 2. We will respond to your opinions and suggestions as soon as possible within 15 working days after receiving them and verifying your user identity. If special or complex situations occur, our response time may be accordingly extended. Additionally, you understand and acknowledge that in the following situations related to personal information, we may not be able to respond to your requests: 1) Related to public safety, public health, and significant public interests; 2) Related to criminal investigation, prosecution, and trial; 3) There is sufficient evidence indicating your subjective malice or abuse of rights; 4) Responding to your request will cause serious harm to the lawful rights and interests of you or other individuals, organizations; 5) Involving trade secrets; 6) Other circumstances stipulated by laws and regulations. **VIII. Other** Unless otherwise agreed, the terms used in these Privacy Terms generally have the following definitions, and if not specifically explained in these Privacy Terms, the relevant term meanings are consistent with the User Agreement: 1. Device: Refers to a device that can be used to access or use Fenshun Network games and services, such as a tablet or smartphone. 2. Unique Device Identifier: Refers to a series of characters embedded in the device by the device manufacturer, which can be used to uniquely identify the corresponding device (such as IMEI/android ID/IDFA/OpenUDID/GUID/SIM card/IMSI information, etc.). 3. IP Address: Each device connected to the internet is assigned a number, called the Internet Protocol (IP) address. These numbers are usually assigned based on geographic region. 4. Cookie: A cookie is a small file containing a string that is sent and stored on your computer, mobile device, or other devices (usually encrypted) when you log in and use websites or other online content. Similar technologies to cookies are other technologies that can be used for purposes similar to cookies, such as Web Beacons, Proxies, Embedded Scripts, etc. 5. Fenshun Network Account: Also known as "account," "user account," refers to the account registered by a user to use Fenshun Network games and services in accordance with the User Agreement and related legal and policy requirements. Fenshun Network Technology (Shanghai) Company Limited