Truco Vamos
Privacy Protection Guidelines
Updated on: [2023-7-31]
Became effective on: [2021-6-16]
Summary
Thank you for your choice of Truco Vamos
provided by Spirejoy Limited (hereafter referred to as “we”
or “us”; in the Guidelines; the contact
information regarding personal data protection is: [Name: Joyce; Email: help@inspiresg.net]).
In addition to “Truco Vamos
Privacy Policy” and “Truco Vamos
License and Service Agreement”, through the Truco Vamos Privacy Protection Guidelines
("Guidelines"), we will further elaborate on how we collect, use,
store and share your personal information when you are playing Truco Vamos, as well as the
relevant rights you are entitled to. The Guidelines are part of the “Truco Vamos License and Service
Agreement”. The highlights are as follows:
In
order to provide you with game entertainment and to support the related player
interaction, consumption and other services, we need to collect information
such as your game history, device information, login data and others.
You hereby consent to provide the following specific information for the
purpose:
•
your
age or birthday;
•
your
first and last names;
•
your
e-mail address;
•
a
password;
•
game
username(s);
•
details
about the games you play;
•
approximate
location information;
•
your
game history;
•
your
device’s operating system and version;
•
your
mobile device’s identifiers, like your MAC Address, Identifier for Advertising
(IDFA), and/or International Mobile Equipment Identity (IMEI);
•
your
login data;
•
other
information that helps us make sure it’s you accessing your account,
information necessary for us to provide the support you request, or information
you provide to help us improve our Service (such as answers to an online survey
or a feedback form).
In
order to better protect both the physical and the mental health of minors and
facilitate a healthy access to the internet by minors, we may implement more
stringent anti-addiction measures in addition to the relevant regulations on
anti-addiction policies of online games. At the same time, we have been
constantly developing and testing various new technologies to better protect
the minors.
You
can manage your personal information and the relevant authorizations according
to the provisions of the Guidelines.
We
adopt a wide range of security measures to ensure that your personal
information is protected under a reasonably safe manner.
By reading the full version of “Truco Vamos Privacy Protection
Guidelines”, you may learn more about the processing rules of personal
information such as the correspondence between the types and the uses of
personal information.
1.
Information We Collect
While you are using Truco
Vamos Service, Truco Vamos will collect through the following ways the
information that you voluntarily provide when using the service or the information
generated by your use of the service, in order provide and optimize our
services to you and to ensure your account in safe security:
1.1 When you register or use Truco Vamos Service, we will
collect the information of your network identity and the personal device that
you frequently use, in order to mark you as our users. If you use a Facebook
and (or) other account recognized by us (hereafter referred to as “Third-Party
Account”) as the game account to login to Truco Vamos, we will collect your unique ID, avatar and user name
of Facebook and Third-Party Account to store your login information so that you
can login on different devices.
If you use a Facebook and (or) Third-Party
Account as the game account to login to Truco Vamoss, in order to provide you with better services and
improve your game experiences, we will collect and you hereby consent to provide the following information for the
purpose:
•
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 other
information like your name and profile photo, and your friends’ identifiers;
•
the
user ID number and other information of your friends, like their names and
profile photos;
•
the
login e-mail you provided to the third-party account;
•
nicknames;
•
your
log-in status, battle information/status, achievement information related in Truco Vamos;
•
your
physical location and that of the devices you use to access our Service;
•
your
gender;
•
your
birthday and/or age range;
•
information
about your activities on or through the third-party account;
•
other
information you have shared on the third-party account;
•
If
you access our Service from a third-party account or connect our Service to a
third-party account, you should also read that third-party account’s Terms of
Service and Privacy Notice.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.
and Truco Vamos may present it to you
or other users or your friends. Depending on the specific situations of a game
product, we may provide you with the relevant permissions enabling you to
adjust the settings as to whether or not to display Such Information.
1.2 In order to comply with the relevant
laws, regulations and policies and the requirements of competent authorities, Truco Vamos users may need to
complete the real-name verification before using and enjoying Truco Vamos. For the purpose, you hereby consent that we may collect your
real-name ID and other information, including:
•
your
first and last names;
•
your
age or birthday;
•
ID
number;
•
photos.
Your refusal to provide your real-name ID information may result in
a failure to log into Truco Vamos
or the corresponding restrictions to your use of Truco
Vamos.
1.3 In order to ensure your use of our
service under normal conditions, to maintain the normal operation of basic
functions of the game, to optimize the performance of the game product, to improve
your gaming experience and protect the security of your game account, we will
collect the information including:
•
your
device ID as well as the name;
•
type
and version of your device;
•
the
version of the system;
•
IP
address;
•
MAC
address;
•
application
ID;
•
network
type.
1.4 When you use Truco
Vamos Service, we will collect your game log
information, including:
•
log-in
data;
•
item
logs;
•
game
battle information;
•
friends relation records.
so that you can view the records of your game
history on your terminal and we can use the above information for analyzing
game operation statistics, handling customer service complaints and other game
security analyses. Also, to improve the game experience for you, we may
synchronize the afore-mentioned information with the later versions of the game
or with other products you are using that are provided by us.
1.5 When you use the consumption function of Truco Vamos, we will collect your
recharge history, purchase records
and other information, so that you can check your transaction records, and at
the same time to protect your virtual items to the greatest extent possible. Recharge history and purchase records
are sensitive information. It is necessary to collect the above information in
order to enable the consumption function of Truco Vamos, otherwise the transaction could not be completed.
1.6 To protect the security of your game
account and to create a fair, healthy and safe gaming environment, we will
collect information such as your game identity information, hardware and
operating system information, processes and breakdown records and other
information, for the purposes of fighting against the behaviors that destroy
the fair gaming environment or that interfere and disrupt normal game services
(such as detecting counterfeits, scanning plug-ins, preventing cheating, etc.).
1.7 According to reports and targeting of
keywords involving pornography, violence, political and abusive content,
terrorism, malicious advertising, and other legally prohibited content, we may
store temporarily and filter the information when you interact with other
players through text, images, voice, video and other means in the game, for the
purpose of purifying the game environment and maintain a healthy Internet
environment.
1.8 If you wish to interact with other game
players through voice and video, and to participate in live broadcasting, upon
your authorization, Truco Vamos
will access your microphone and camera to accommodate you with voice chatting,
interaction during live broadcasting and other functions. But we will never
violate the privacy of your voice and video. You can also revoke the
authorization of the microphone and camera at any time.
1.9 If you wish to interact with nearby game
players, upon your authorization we will collect the information of your geographic location to search for nearby
game players, so that you can match with them or team up with them, etc. Geographic location information is a
type of sensitive information. Your refusal to provide this information will
only result in your incapability to interact with nearby game players, and will
not affect your normal use of other functions provided by Truco
Vamoss. You can also withdraw your authorization for
the geographic location information at any time.
1.10 We
have enabled a reminder function for moderate time length of playing games. If
you use a wearable device, we will, with your consent, collect information such
as your heartbeat when you are playing the game, so as to issue a system
reminder when you have spent excessive time on the game.
1.11 We may analyze your game data to
understand your preference, and we may share your such preference and relevant
necessary information to other products and services within the Truco Vamos Group, in order to
better show you what you may be of interest within Truco
Vamoss and other products and services within Truco Vamos Group.
1.12 In accordance with relevant laws,
regulations and standards, we may collect and use your personal information in
the following situations without obtaining your authorization:
1.
where
it is directly related to national interests such as national security and
national defense security; and directly related to major public interests such
as public security, public health, and public knowledge;
2.
where
it is directly related to criminal investigations, prosecutions, trials and
enforcement of judgments, etc.;
3.
where
it is for protecting the fundamental legal rights of you or other individuals,
such as life, property and reputation, but it is also difficult to obtain
consent from you or the related individual;
4.
where
the personal information we collected is disclosed to the public by yourself;
5.
where
the personal information is collected through legitimate and public channels,
such as legitimate news reports, government information disclosure, etc.;
6.
where
it is necessary to sign and perform the contract according to your requests;
7.
where it is necessary to maintain a safe and
stable operation of the products or services provided by us, such as the
discovering and treating of the malfunctions of such product or service. But we
will continue to protect the security of your personal information and ensure
that it will not be used for other purposes;
8.
where it is necessary to conduct statistical
or academic research for public interests; and when externally providing the
results of academic research or description, applying de-identification method
to the personal information contained in the results. In addition, it will not
be used for any other purposes and activities; or
9.
other
circumstances as stipulated by the laws and regulations.
1.13 Please understand that the functions and
services we provide to you are constantly updated and developed. If a certain
function or service is not included in the above descriptions herein but your
information is collected there, we will separately explain to you the content,
scope and purpose of such collection through prompts, interaction process,
website announcement and other ways in order to obtain your consent.
At present, aside from collecting game
research information from third-party research organizations to help us upgrade
our game products and provide personalized services, and aside from your use of
Third-Party Account to login in Truco Vamoss prescribed in Section 1.1 herein, we do not take the
initiative to obtain your personal information from any third party outside of Truco Vamos Group. In the future,
if Truco Vamos needs to
obtain your personal information indirectly from a third party outside of Truco Vamos Group and process
such personal information, we will strictly comply with the relevant laws and
regulations, and we will require the said third party to obtain your consent
and to guarantee the legality of the information it provides.
2.Storage
of Information
2.1
Manner and Term of Storing Information
We will store your information in a secure
manner, including storing it locally (such as data caching via APP), using
database and server logs.
In general, we will only store your
information for a necessary period for achieving the purpose of providing our
services or as required by laws and regulations.
2.2
Territory of Storing Information
Personal information collected would be stored
within [Amazon servers located in Singapore] pursuant to the laws and
regulations.
2.3
Termination Notice of the Product or Service
In the event the operation of a product or
service is terminated, we will make an announcement in accordance with the
relevant laws and regulations, and will protect your legitimate rights and
interests.
3.Information
Security
3.1
Security Measurements
We strive to protect information security of
the users to avoid any information leakage, loss, improper usage, unauthorized
access and disclosure, etc. We employ multiple security measures, including
technical protection solutions, management system controlling, security system
guarantee and others to make sure the user’s personal information is protected
in a reasonably secured manner.
To avoid any kind of doubt, it is neccessary to specify to you that all the game products of
us have nothing to do with money, all golds and props in our game products are
only for purpose of entertainment in the game.
We adopt leading technical protection
measures in the industry. The measures we take include but not limited to
firewall, encryption (such as SSL), de-identification or anonymization, access
controlling, etc. Further, we will constantly strengthen the security capacity of
the software installed in your devices. For example, we will implement part of
the encryption work in your devices locally to consolidate a secured
transmission; we will collect the information of the applications installed in
your devices and its processing information during operation to avoid malicious
programs such as virus and Trojan.
We have established special management
regulations, procedures and organizations to safeguard the security of the
personal information we collected. For example, we will apply strict limitation
on the scope of people authorized to access the information, requiring them to
obey confidential obligations and conducting audits. Those who violates such
obligations will be punished in accordance with the regulations. We will also
review the management regulations, procedures and organizations to prevent
unauthorized access, use or disclosure of the users’ information by those
people that are without authorization.
We suggest you give full attention to the
protection of personal information when using the products and services, and we
will also provide multiple security methods to assist you to protect the
security of your personal information.
3.2
Dealing with Security Incident
If any security incident such as the leak of
personal information occurs, we will initiate the emergency plan to prevent it
from expanding, and ensure to inform your of what we
know within 72 hours upon knowledge, or when there is reasonable belief, that a
personal data breach has occurred. Upon the occurrence of such incident, we
will inform you the basic situation of the security incident, the treatment
measures and remedies we will take or have taken as well as our advices for
you, via announcements, push notifications or emails, etc. If it is difficult to inform every user, we will issue the warning
through public announcements or other reasonable
means.
4.
How We Use the Information
We will strictly obey the laws, regulations
and the agreement with our users, and we will make use of the collected
information in accordance with the Guidelines, "Truco
Vamos License and Service Agreement" and "Truco Vamos Privacy Policy"
so as to provide you with better service.
4.1
Rules for Using Information
We will use the collected information in
accordance with the following rules:
1.
based
on the information we collected, we will provide you with multiple functions
and services, including the general gaming functions, interactive functions
between players, live broadcasting functions as well as consumption functions;
2.
we
will analyze the operation of our products based on the frequency and
situations of your use of Truco Vamos,
malfunction information and performance information, etc., so as to ensure a
safe provision of our services, and to optimize our products and improve the
quality of our services. We will not combine your personal information with the
information we stored in the analysis software.
4.2
The Way to Seek Consent after Informing the Purpose of Changing
We will use the collected information within
the scope included in the Guidelines. If we use your personal information
beyond the scope and a direct or reasonably relevant scope, of purpose we
claimed when collecting the information we will again
inform you and seek your express consent before using your personal
information.
5.Provide
to Other Entities
Currently, except for the conditions provided
in the Guidelines and “Truco Vamos
License and Service Agreement”, we will not actively share, provide or transfer
your personal information to any other third party outside of Truco Vamos Group. In the event
we share, provide or transfer your personal information or you need us to
share, provide or transfer your personal information to a third party outside
of Truco Vamos Group, we
will directly ask for your prior express
approval or confirm that the third party has obtained your express approval.
Notwithstanding the above paragraph, we might
provide your log-in information and relevant information (such as log-in data,
item logs, etc.) generated in the game to the overseas developer entities or
relevant third parties for the purpose of conducting security analysis, and
helping to improve game services and further optimize users’ experience in
game.
Truco
Vamos integrates Bugly SDK
products and/or services into our applications. In order to keep abreast of our
product operation dynamics and quickly discover and resolve your abnormal
feedback, we may need to collect relevant personal and sensitive user data from
you, including: Installed Application, crashes information, Android ID/IDFV,
and provided to the Bugly SDK operator in a
de-identified or anonymous manner.
The following privacy policy linked provide
you information about Bugly’s
processing of your personal information.（https://privacy.qq.com/policy/tencent-privacypolicy）
Truco
Vamos Group's product integrates with Umeng+SDK. Umeng+SDK needs to
collect your device's Mac address, unique device identification code
(IMEI/android ID/IDFA/OPENUDID/GUID, SIM card IMSI information) to provide
statistical analysis services, and through Geographically calibrate the
accuracy of report data and provide basic anti-fraud capabilities.
The following privacy policy linked provide
you information about Umeng’s
processing of your personal information.（https://www.umeng.com/page/policy）
Truco
Vamos cooperates with reputational ad exchange
platforms including Mintegral. When you install and
use our product after you view and click an ad served by Mintegral
Service, they may collect information about your downloading, installation,
activation of an app or other activities about you within the app. Where Mintegral acts as Demand Side Platform (“DSP”) serving ads,
in order to analyze and display advertising including personalized or
behavioral advertising on your device, we may collect and share your personal
information with them including the following: screen size & orientation,
device make, model, operating system, operating system version, device type,
version and characteristic of the app used by you when you interact with the Mintegral Services, carrier information, network connection
type, IP address, user-agent; country, time zone and locale settings (country
and preferred language) and mobile advertising identifier (e.g. Apple IDFA or
Google advertising ID).
The following privacy policy linked provide
you information about Mintegral’s
processing of your personal information.（https://www.mintegral.com/en/privacy/）
In addition, we will try to contact the parent or legal guardian after a person that is
suspected to be a minor has made consumption, and inform the parent or legal
guardian of the consumption records and other information to remind the parent
or legal guardian to confirm and handle this issue.
Except as otherwise provided in the
Guidelines, “Truco Vamos
License and Service Agreement” and “Truco Vamos Privacy Policy”, we will not publicly disclose the
information we collect. If a disclosure is necessary, we will inform you about
the purpose of the disclosure, the type of the disclosed information and the
sensitive information that may be involved, and we will also obtain your
express approval.
As our business continuously develops, we are
likely to conduct transactions such as mergers, acquisitions and asset
transfers, etc. We will inform you of the information and continue or require
the new controllers to continue to protect your personal information in
accordance with the laws and regulations and the standards no lower than the
requirements of the Guidelines.
In addition, in accordance with relevant
laws, regulations and standards, we may share, transfer, or publicly disclose
personal information without your prior authorization and approval in the
following situations:
1.
where
it is directly related to the national security and national defense security;
2.
where
it is directly related to public security, public health or major public
interests;
3.
where
it is directly related to criminal investigation, prosecution, trial and
enforcement of judgments;
4.
where
it is for protecting the material legal rights and interests such as life,
property and others of the personal information holder or other individuals but
it is also difficult to obtain consent from the involved person;
5.
where
the personal information holder publicly discloses personal information by
himself/herself; or
6.
where
the personal information is collected through legitimate and publicly channels,
such as legitimate news reports, government information disclosure, etc.
6.
Data Retention and Deletion
6.1
Data Retention
How long we retain your personal information
depends on why we collected it and how we use it, but we will not retain your
personal information for longer than is necessary for our business purposes or
for legal requirements.
As a general rule, we retain your personal
information only as long as required to perform the Services or other purpose
that was the reason for the collection of the information. We will retain most
of your personal information as long as you use the Services (i.e., until
account deletion in accordance with your request) with the following
exceptions: Contact Information that is obtained as a result of you
participating in our promotional activities will be retained during such
activities as expressly designated in the corresponding activities.
We will retain personal information about you
and connected with your account and/or the Services you use from us for as long
as you have an active account with us. We will take reasonable measures to
delete this personal information if you delete your account. However, you
acknowledge that we will keep certain records (e.g., personal information
relating to payments or customer service matters) where we need (and have
rights) to, such as for legal or accounting purposes. We’ll also keep
information in order to exercise, defend, or establish our rights.
In the event that the processing and
retention period have terminated, but personal information is required to be
retained continuously for other reasons including for archiving purposes as
prescribed under applicable laws, the relevant personal information will be
stored and maintained separately from other types of personal information. If
you require us to destroy your personal information before the end of its life
cycle (as set out in the retention policy above), we will destroy your personal
information in accordance with local laws).
6.2
Data Deletion
You can delete your account, or remove
certain personal information.If
there is any other personal information you believe we process that you would
like us to erase, please contact us at help@inspiresg.net.
You may ask us to delete or remove your Personal Date.Please
state your account ID and deletion request in your email clearly. We will
usually process your request within 48 hours of receiving your email.
When you remove our app and request to delete
your data, the system will call the data deletion callback. You can do this
simply by going to your Facebook profile and navigating to the Settings &
Privacy > Settings > Apps & Websites page and clicking the Send
Request button.
You may request that we erase the personal
information we hold about you in the following circumstances:
you believe that it is no longer necessary
for us to hold such personal information; or
you believe the personal information we hold
about you is being unlawfully processed by us.
You can also exercise your right to restrict
our processing of your personal information (as described below) while we
consider your request.
We may need to retain personal information if
there are valid grounds under data protection laws for us to do so (e.g., for
the defense 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 the Services and there are
grounds for erasure, we will use reasonable steps to try to tell others that
are displaying the personal information or providing links to the personal
information to erase it too.
When destroying personal information,
measures will be taken to make the personal information irrecoverable or
irreproducible, and electronic files which contain personal information will be
deleted permanently using a technical method which makes the files
irreproducible.
7.If
you believe you have discovered a security vulnerability affecting Truco Vamos products and
services, please report it to us immediately. We welcome anyone reporting to us
and will investigate all reports and do our best to fix reasonable
vulnerabilities as soon as possible.
We
encourage you to send an encrypted email to help@inspiresg.net by using your
PGP key with the following information:
1.
The specific products and software versions
you believe to be affected;
2.
A description of the behavior you observed
and the behavior you expected;
3.
A numbered list of steps to reproduce the
problem or a video demonstration (if the steps may be difficult to complete).
You
will receive an automatic response from Truco Vamos confirming that we have received your report. If we
need more information, we will contact you.
8.Your
Rights
During the time you use Truco
Vamos Service, we may provide you with the
corresponding operation settings based on the specific situation of the game
products, so that you can search, delete, change or withdraw your relevant personal
information. You can refer to the specific instructions of the corresponding
game products to guide your operation. In addition, we have set up the channel
to receive complaints and reports, and your opinion will be dealt with in a
timely manner. To exercise any of your rights regarding personal information,
please contact us at help@inspiresg.net.
9.Amendments
We may amend the Guidelines as appropriate.
When the provisions of the Guidelines have been amended, we will inform you of
the amended Guidelines in a proper way at the time of version update. Please
read the amended Guidelines or the content carefully. Your continuous use of Truco Vamos would be deemed as
your approval for us to collect, deal with or use your personal information in
accordance with the updated Guidelines.
10.Protection
of Minors
We
attach great importance to the protection of minors’ personal information, and
we will keep exploring new ways to protect minors’ personal information.
We
will protect the legitimate rights and interests of minors by initiating
anti-addiction system in accordance with relevant regulations on online game
anti-addiction policies. We will make a judgment on whether the real name
information of an account belongs to a minor via the identification result of
information such as real-name identity, based on which we decide whether the
account shall be included in the anti-addiction system. In addition, we will
collect information such as your login time, length of playing games, etc., and
guide the minors to play games rationally through ways such as automatically
intervening and limiting the game duration of the minors in our system,
enabling the function of mandatorily exiting the game, etc. When the
consumption is conducted by a person suspected to be a minor, we will then try
to contact his or her parent or legal guardian for reminders, confirmations and
deposition, so as to help the minors have a healthy access to the Internet.
At
the same time, in order to better protect both the physical and mental health
of minors and facilitate a healthy access to the Internet for them, we may
employ stricter anti-addiction measures on the basis of relevant anti-addiction
policies related to online games. Further, we will keep conducting researches
and testing various technologies to protect the minors. For example, in order
to further improve the accuracy of real-name verification on identities and to
try best to prevent minors from impersonating the identity of others, we may
enable face-recognition verifications in some games or for some users (subject
to specific game strategies) under specific situations (for example, when you
log into a game, or when you top up, purchase or make transactions during the
game).
Besides,
we may also collect your game behavior data generated during the game (for
example, the data such as the click pressure and radius, the relative position
of the click, the acceleration direction, and the direction of gravity formed
when you operate the game on the terminal device, and the voice data generated
when you interact with other players through online voice in the game) to
preliminarily determine whether the user is a minor (regarding the voice data,
the system will only randomly use some of your online voice to judge whether it
is from a child or an adult). If the preliminary determination shows you are a
minor, we may enable the face-recognition verification in accordance with the
foregoing prescriptions.
If
you are the parent or legal guardian of a minor, please pay attention to
whether the minor uses Truco Vamos
Service or provides his or her personal information after obtaining your
authorization and approval. If you have questions about the personal
information of the minor under your guardian, please contact us through the
contact details provided in Section 9 herein.
11.
Contact Us
When you have other complaints, suggestions,
or questions regarding personal information of minors, please send your
questions to [Name: Joyce; Email: help@inspiresg.net] .
We will review the relevant questions as soon
as possible, and will respond within 15 days upon verifying your user identity.