JoyMaker Privacy Policy

1. About the Privacy Policies.

Thank you for using our products and services.

The Privacy Policy describes the privacy practices of JOYMAKER GAMES PTE. LTD. and its Affiliates (including JOYMAKER HONG KONG CO., LIMITED)(collectively, “JoyMaker” or“we”). All capitalized terms used but not defined in the Privacy Policies have the same meaning(s) ascribed to them in the Terms of Service (“Terms”).

The Privacy Policies do NOT apply to information collected by third parties, whether through any application or content (including advertising) that may link to or be accessible from or through our Services.

By accessing, registering with, or using our Services, you agree to the Privacy Policies. If you do not agree with anything described in the Privacy Policies, please do NOT use our Services.

We may amend this Privacy Policy from time to time. (see Section Changes to Our Privacy Policies.) so please check the Policies periodically for updates. We will notify you via pop-up window, in-app notice, or email at least 10 days prior to the effective date of such changes. Your continued use of our Services after the effective date will be subject to the updated Privacy Policy; if you do not agree with the changes, you must stop using our Services. We will not deem your silence or continued use as acceptance of material changes without prior notification and a reasonable opportunity to review.

2. What Information We Collect.

We collect various information from and about users of our Services. The information we collect may include but is not limited to the following categories:(1) information by which you may be personally identified (such as name, email address, and social media information) or any other identifier by which you may be contacted online or offline, (2) information about you but individually does not identify you; and (3) and information about your internet connection, the equipment, program or system used to access our Services, and usage details.

A. Information you provide to us.

We collect your personal information directly from you when you provide it to us. For example, we collect information you provide when you (1) register a JoyMaker account with us, (2) are approved to be a Creator for our Services (3) request rewards for the events, contests or activities in our Services (4) post your content or use social features of our Services (5) participate in a contest, promotion, or event organized by us, or (6) request further Services.

Information we collect may include the following:

Personal Information Collected	Rights to Refuse and Related Adverse Effects
Email address Game ID / Username Login password	Mandatory Refusal will make it impossible to register an account, use the launcher, or access any game services
Device identifier (including JoyMaker ID and advertising ID) IP address OS version	Mandatory Refusal may prevent the launcher from functioning properly or compromise security, potentially making the service unavailable
Game list Game installation status Game launch logs	Mandatory Refusal will make you improperly manage your game library or launch games
Age / Year of birth Gender Interest tags	Optional Refusal will still allow full use of the launcher and games, but personalized recommendations based on your interests will not be provided and ads may be less relevant.
Friend list Contacts synchronization	Optional Refusal will still allow you to play games, but social features within the launcher (e.g., friend online status, party invites) will be unavailable.
Crash reports Detailed performance logs	Optional Refusal will still allow full use of the launcher, but it may affect the efficiency with which developers fix issues specific to your device model.
Approximate Location	Optional Refusal will still allow full use of the launcher and games, but location‑based features or events (e.g., regional leaderboards) will be unavailable. We collect your precise location only when we send you a gift.

Your refusal to provide any of the “Optional” information listed above will NOT cause us to deny you access to the core functions of the launcher (e.g., logging in, managing your game library, and launching games).

You have the right to withdraw your consent to optional information at any time via email. Upon withdrawal, we will immediately stop processing and destroy the relevant information (unless otherwise required by law).

In the course of accessing or using our Services, we may collect channel, video information, etc. based on your use of the YouTube API Services and in accordance with the YouTube API Services Terms of Use (https://developers.google.com/youtube/terms/api-services-terms-of-service), the Google API Services User Information Policies (https://developers.google.com/terms/api-services-user-data-Policies), and the Google Privacy Policies (https://www.google.com/policies/privacy). You can revoke access to these APIs through the Google Security Settings page (https://security.google.com/settings/security/permissions).

B. Information third parties provide to us.

We may receive or search for information about you from third-party partners and businesses when you apply to Creator. These Data Providers may include, for example, advertising partners, platform service providers, or other business partners.

Data Providers:

●Information from such third-party partners and businesses may include the following:

●Channel name;

●Channel photo;

●Channel contents;

●Subscriber count.

We process this information for the following purposes:

1. To deliver personalized content, including advertisements

2. To enhance your service experience and improve our Services

3. To perform analytics, research, and other purposes disclosed in this Privacy Policy

We may also merge the information received from Data Providers with the personal information we collect directly from you to achieve the above purposes.

3. How We Use Your Information.

We use information we collect about you, including your personal information, to operate our business, improve our Services, and personalize your experience. We may also use the information for such other purposes as allowed by law. For example, we (or a third party on our behalf and under our instructions) may collect, process and use your information for such purposes including the following:

●Provide our Services, including our Services and other services, to you and personalize your service experience.

●Fulfill your orders, including purchase of our goods or service, and any other purpose for which you provide it.

●Set up and administer your account registered with us, and maintain your transaction records.

●Verify your identity.

●Identify the most suitable user to participate in a specific event, contest or activity.

●Provide you with customer and technical support when requested, and communicate with you about your account, purchases (if any), subscriptions or services.

●Send you offers, promotions, newsletters, and communication regarding our Services or related products.

●Display relevant advertisements tailored to your interests and preferences on our Services and elsewhere online across various sites and apps, and measure and analyze effectiveness of advertising, including third parties’ advertisements placed in our Services.

●Undertake research and analysis to develop and improve our Services.

●Monitor our Services, including our Websites, Applications, and networks, and their operation thereof, and track purchases and usage information.

●Identify and fix bugs or program malfunctions.

●Detect and prevent cheating, fraud, malicious or illegal activity.

●Handle user complaints, investigate disputes, monitor and/or moderate chats, regulate players’ online behavior.

●Carry out our obligations and enforce our rights arising from any contracts entered into between you and us.

●Enforce the legal terms governing your use of our Services.

●Other purposes you consent to when we request your information or when you use our Services.

●Any other purpose as we determine, at our sole discretion, to be necessary or required to ensure the safety and/or integrity of our users, employees, third parties, public, and/or our Services, or to comply with requirements of any applicable law.

Data retention.

We destroy personal data whose purpose of collection as consented to by you have been achieved, or whose periods of and use to which you consented to or which were provided in this privacy policy have expired; provided, however, we will continue to store your personal data for the following statutorily-prescribed periods, where applicable including, but not limited to:

Act on Consumer Protection in Electronic Commerce	Records on your cancellation of an order, your payment on a purchased item, and our supply of a good/service: 5 years. Records on the handling of consumer complaints or disputes: 3 years. Records on advertisements and labels: 6 months.
Protection of Communications Secrets Act	Records on your visits to our website: 3 months

If we determine that your personal information is no longer needed, we will destroy it under the supervision of our chief privacy officer and in accordance with applicable law and the Privacy Policy. Personal information in the form of electronic files will be securely deleted using technical methods to prevent recovery and reproduction, and printouts will be destroyed by shredding or incineration.

Where required by applicable laws and regulations, we will retain your information for the statutory retention period; upon the expiry of such period, your personal information shall be deleted or anonymized in line with applicable laws and regulations.

Automated Decision-Making

To optimize our services, enhance security, and provide personalized experiences, we may use automated systems to process your personal information and make decisions in certain aspects of our services (hereinafter referred to as "Automated Decision-Making").If a particular Automated Decision-Making has a significant legal or similar effect on your rights or obligations, you have the right to object to such a decision and request review via the means in Section How to Contact Us.

4. With Whom We May Share Your Information.

We may disclose aggregated information about our users that does not identify any individual or device, without restriction. In addition, we may disclose your personal information to the recipients below.

Public: We may disclose the username and ID of certain users on our Websites, for example, the winners of a contest. But we will redact certain parts of the username and ID information. In addition, you agree that your information posted on or transmitted through our Services (collectively, “User Content”) is posted and transmitted to others at your own risk. We cannot control the actions of other users or third parties with whom you choose to share your User Content. Therefore, we cannot and do not guarantee that your User Content will not be viewed by unauthorized persons.

Our Subsidiaries and Affiliates: We may share your information with our Affiliates for the purposes described in the Privacy Policies.

Our Contractors and Service Providers: We do provide some of our Services through contractual arrangements with contractors, service providers, and other third parties we use to support our business. We will share your personal information with our service providers for all purposes described in the Privacy Policies (see Section How We Use Your Information) and as reasonably necessary in order to provide the Services to you or to carry out your instruction. When our contractors and service providers collect or receive personal information, we require them to keep personal information confidential and use it only on our behalf and for the purposes consistent with the Privacy Policies.

Other Business Partners: We may share your information with third-party app stores, game platforms and other business partners with whom we offer Services to you.

Third-party plugin: Third-party social media features and tools integrated into our Services (such as Facebook “Like” button or “Share” button) are hosted by a third party, who may also collect information when you use our Services. These third-party features and tools are subject to the privacy Policies of the third party that provides them.

Social features: When you use the social features of our Services, your information, such as your username, profile, picture, Game progress and score, or any other information that you transmit or post using such social features, will be shared with your recipient or the public in general. For example, any information that you include in your public profile will be visible to others. In addition, you can post or display your content on public areas of our Services, such as player forums or bulletin boards, or a third-party social media network that you signed up for.

Business Transfer: A business transaction includes but is not limited to a merger, acquisition, dissolution (including bankruptcy), change of control, or a sale of all or a portion of our assets, or businesses. If we undergo such transactions, including preparation of any of such transactions, we may share, disclose, or transfer all of your information, including personal information, to the successor or assignee. Any third party to which we transfer or sell our assets will have the right to continue to use the personal and other information that you provide to us in the manner set out in the Privacy Policies.

With consent: With your express consent, we may share your information with other third parties for additional purposes. You agree to share your information with such third-party recipients, who may use your information subject to their respective privacy policies.

Compliance with Law: We may also share your personal information when we determine that it is reasonably necessary (i) to comply with any legal obligation (for example, a court order or subpoena), (ii) to enforce our Terms and policies and/or any other agreements; or (iii) to protect the legitimate rights, property, or safety of us, our users, or others; or (iv) for other purposes as we reasonably believe are permitted by law or regulation.  We fully cooperate with law enforcement agencies in identifying those who use our Services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.

we provide your personal information to third parties in the circumstances set forth below. We will obtain your separate consent before any such provision. You have the right to refuse consent. Refusal will not affect your ability to use the core functions of the launcher (e.g., login, game launch), but may make certain additional features unavailable.

Scope of Entrusted Work	Third Parties' Identity

5. Third-Party Sites and Services Collecting Information.

Our Services may contain links to third-party sites or third-party services. These third-parties may have privacy policies and data practices different from ours. We do not control and are not responsible for the privacy policies or practices of such third-party sites or services. You should consult the privacy policies of each third-party site or service before using them.

In addition, when you use our Services, certain third parties, such as advertisers, ad networks, and ad servers, analytic companies, may use automatic information collection technologies to collect information about you or your device. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different apps, and other online services. websites. They may use the information to provide you with interest-based (behavioral) advertising or other targeted content. 

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

6. Your Choices About Our Collection, Use, and Disclosure of Your Information.

We strive to provide you with choices regarding our collection and use of your personal information. The specific choices available may vary depending on the Services you use.

Promotional messages from us. If you do not want us to use your contact information for marketing purposes, you can opt-out by contacting us via the means in Section How to Contact Us. You can also unsubscribe from our marketing communication by clicking the unsubscribe link provided in our email.

Targeted advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by taking one of the following actions:

●Applications: You can enable the “Opt out of interest-based ads” (Android) or “Limit Ad Tracking” (iOS) settings on your mobile device and reset your advertising identifier.
* Android Chrome
*iOS Safari

Residents in certain states and countries may have additional personal information rights and choices. Please see Section Your Privacy Rights. and other state or country specific notices provided in the Privacy Policies for more information.

7. How We Keep Your Information Secure.

The security of your personal information is important to us. We maintain appropriate technical and physical safeguards to protect your personal information against unauthorized access, loss and misuse. We take commercially reasonable security measures to protect your personal information, including encryption of sensitive information, firewalls, and IDS (intrusion detection system).

Although we take appropriate measures to safeguard against unauthorized disclosure or access of your information, no security measure is perfect. Thus, we cannot guarantee the security of your information. You hereby agree to use our Services at your own risk. We do not assume any responsibility for the unauthorized use or access of your information beyond our reasonable control.

8. Children’s Privacy.

By children, we mean users under the age of 14 years old. We will confirm your age by implementing appropriate age verification measures, in order to comply with applicable legal requirements. You should refer to the laws in your jurisdiction to ensure you are above the relevant legal minimum age.

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 these ages, please contact us.

Special Note to Parents.

If you become aware that your child has provided us with personal information at our Service, we invite you to notify us so that we may delete the information from our records and discontinue any related features or services. We also urge parents to instruct their children never to give out their real names, addresses or phone numbers without parental permission when using the Internet. We appreciate your cooperation in assisting us to provide a safe and enjoyable online experience for your children.

9. Your Privacy Rights.

Consumer privacy laws may provide their residents with additional rights regarding their personal information. You may have the following rights depending on where you live.

●The right to access your personal information.Upon receipt of your access request, we will allow you to review the personal information that we collected about you, including the categories of information and sources from which we collected it, the business purpose of using or sharing your information, and with whom we may share it.

●The right to delete certain personal information. You may request that we delete your personal information subject to certain exceptions under the applicable laws. For example, we may deny your deletion request if retaining the information is necessary for us or our service providers to provide Services that you requested, protect against fraudulent or illegal activities, comply with a legal obligation or make other internal and lawful uses permitted under the law. We will delete personal information not subject to one of such exceptions from our records and will direct our service providers to take similar action. 

●The right to correct inaccuracies. You may request to correct any inaccurate or incomplete information that we have about you.

●The right to object. You may have the right to object to our processing of your personal data for direct marketing purposes or research or statistical purposes, or processing based on certain legal grounds such as processing necessary for our or a third party’s legitimate interest or performing a task in the public interest.

●The right to opt-out of automated individual decision-making, including profiling. Certain state residents have the right to opt-out of automated decision-making or profiling in furtherance of decisions that produce legal or similarly significant effects. We currently do NOT engage in “profiling” with such purpose or effect.

●The right to opt-out of targeted advertising. You may have the right to opt out of personal data processing for targeted advertising and sales under the laws of some states.  As explained in the Privacy Policies, certain information about you may be collected by or shared with our advertising partners for the purposes of delivering advertisements that may be more relevant or interest to you. You may opt out of such sharing and disable targeted advertising at any time by following the steps described in Section Your Choices About Our Collection, Use, and Disclosure of Your Information. or by submitting a request as directed below.

●The right to nondiscrimination.We will not discriminate against you for exercising any of your privacy rights. Unless permitted by the law, we will not deny, or provide a different level or quality of goods or services for choosing to exercise such rights; however, provided that we may select the most suitable users to participate in a specific event, contest or activity based on your information.

●The right to consent withdrawal. To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us. 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. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.

●The right to suspend processing of personal data.You may request that we suspend the processing of your personal data. Upon receiving your request, we will temporarily halt certain or all processing activities related to your personal data, except in cases where processing is required by law, necessary to protect the rights of others, or necessary to fulfill contractual obligations when you have not clearly requested contract termination.

●The right to Complain.You may have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority where applicable.

●Right to request transmission of personal data to specified processors. Subject to the statutory conditions, you are entitled to request us to transmit your specific personal information in a structured, machine-readable format to the specialized personal information management agencies specified by law or other third parties complying with the security standards.

●Announcements. We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to Our Services for maintenance, security, privacy or administrative-related communications). There are essential system and service-related announcements and you may not opt out of these notifications, which are not promotional in nature.

●How to exercise your rights.You may also contact us with your personal information inquiries or for assistance in modifying or updating your personal information and exercising your rights. Our contact details are provided in the Section How to Contact Us.

Your request to access or delete your personal information must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information. You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to personal information associated with that specific account. For non-accountholders, we may verify by asking and confirming unique details we have about you or your device.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Authorized Agents.Only you, or someone legally authorized to act on your behalf, may exercise your rights.  If your agent submits a request to know or a request to delete, we may ask you to confirm directly with us your identity and your designated agent’s authority to submit the request for you unless you have provided your agent with a valid power of attorney duly executed under the law of your residence.

 

12. Where We Hold Your Information.

We will keep your data only for as long as your account is active or only for as needed to provide you with Our Services unless deleted in accordance with your request or where we are required to do so under applicable law.

The locations of servers for Our Services include one or a combination of the following locations:

• Singapore

You acknowledge and agree that your data will be collected and processed on our servers, which may not be located in your country/region of residence and can be accessed by our support, engineering and/or our Affiliates around the world. No matter where our servers are located, we will make great efforts to take the appropriate safeguards to guarantee your rights in conformity with this Privacy Policy and any applicable laws and regulations.

With your explicit consent, we may transfer your personal information to overseas partners or service providers in order to provide relevant services. You may refuse to consent, but refusal may limit or prevent the use of certain services. Details of the transfer are as follows:

Item	Details
Recipient	JOYMAKER GAMES PTE. LTD.
Country of Transfer	Singapore
Purpose of Use	To improve service quality
Retention and Usage Period	Retained for the duration of the agreement and as required by law.
Rights to Refuse and Related Adverse Effects	Refusal will make it impossible to use the relevant services

We ensure that the recipients will use and store your personal information in compliance with domestic and international regulations and will take all available physical and technical measures to protect your information.

To refuse the cross-border transfer of your personal information, please contact us using the information provided in Section How to Contact Us of this Privacy Policy.

Where necessary for the purposes mentioned in Section How We Use Your Information and of this policy, we may transfer your personal information to other parties, including those in Section With Whom We May Share Your Information under this policy, which may involve the cross-border transfer of data to other countries and regions. In doing so, we will ensure that your personal information receives the appropriate level of protection in compliance with the applicable laws and regulations.

If you request to remove or delete your personal information, please note that we will continue to retain your data for the longest time permitted by applicable laws and regulations, to perform our legal obligations, resolve disputes, or enforce the agreements between you and us. Please note that the removal or deletion of any of your data may result in the termination or suspension of some of our Services.

Where required by law, we will only store your information as long as necessary to fulfil the purposes for which the information is collected and processed or where the applicable laws and regulations provide for longer storage and retention periods. Upon the expiration of such period, your personal information will be deleted or anonymized, in accordance with applicable laws and regulations.

11.Changes to Our Privacy Policies.

From time to time, we may update the Privacy Policies to clarify our practices or to reflect new or different privacy practices, such as when we add new features. We reserve the right to modify and/or make changes to the Privacy Policies at any time.

If we make any material changes, we will notify you by appropriate means ,such as pop-up windows, website announcements, or other methods required by applicable law.You will have 30 calendar days from the date of notification to review the updated Policies. If you do not raise any objections within this period, your continued access to or use of our Services will be deemed acceptance of the updated Privacy Policies.

12.How to Contact Us.

If you have a question about the Privacy Policies or any of our privacy practices, you can contact us by one of the following methods.

A.Personal Information Protection Officer

• Name：Allenzhao

• E-mail: allenzhao@huanle.com

2. General Inquiries

• E-mail:service@joymaker.com