Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.
This privacy policy (“Policy”) explains the when, how and why when it comes to the processing of your personal information and sets out your choices and rights in connection with the mobile game HEROIC FATES (“Game”, “Game Services”), which has been operated by FRASER GAMES INC. (“we”, “us”, and “our”). Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it. If you do not agree to the processing of your personal information in the way this Policy describes, please do not provide your information when requested and stop using the Game. By using the Game, you are accepting our rules regarding your personal information as described in this Policy.
Unless otherwise specified in the Policy, the Policy does not apply to products and/or services independently provided to you by any third party accessed through our products and/or services, for example, content of external links featured in our products and/or services. Please note that if you provide your personal data to a third party while using a third party’s products and/or services, your data is subject to the third party’s privacy policy or similar policies. We are not liable for any third party’s improper use or disclosure of the data you provide to any third party.
This Policy will help you understand the following:
I. How We Collect and Use Your Personal Data
II. Sharing Your Personal Data with Third Parties
III. How We Protect Your Personal Data
IV. How We Retain Your Personal Data
V. Push Notifications
VI. Policies Regarding Children
VII. Other Related Matters Needing Attention
VIII. Your Rights to Your Personal Data
IX. International Transfers of Your Personal Data
X. Revisions To the Policy
XI. Disputes And Jurisdiction
XII. Contact Us
Please carefully read the following content regarding the protection of privacy.
I. How We Collect and Use Your Personal Data
1. Information You Provide Us With (either directly or through a third party).
Once you have registered and/or use the Game, we will collect data on your actions in the game, including but not limited to all personal data and data related to identifying you that you provide upon registering your account (hereinafter referred to as “personal data”).
a) Account registration information (direct via email): when you set up an account to register for the Game via email, we will collect your email address, password for the purposes of account login, email verification code for password recovery and promotion of related events; We only receive this information if you voluntarily provide it.
b) Account registration information (via social media accounts): when you choose to log into the Game with your social media account (Apple, Google, Facebook), We will collect Google/Apple/Facebook authorization data (such as nickname of the account) to provide our third-party account login services in accordance with your request.
c) We will collect your username: for the purpose of user identification.
d) We will collect your game data: (such as operating System, area ID, role ID, game server ID, zone ID, player name, character ID, level of character, player’s remaining balance, account status, account binding status, registration time, latest login time, player type) for the purpose of providing the Game Services and provide troubleshooting such as addressing and remediating technical issues and bugs.
e) We will collect your transaction records (including transaction number, transaction amount, transaction time) to record our users in-game payment information to avoid missing orders, etc. We do not receive and/or process any of your actual payment details such as card number or security code.
f) We will collect your chat data (solely in the form of text) in order to deliver your messages to other users and ensure a harmonious and healthy online environment in the Game, we collect the above information to avoid some words that may offend or distress others (which breaches the Terms of Service, (e.g. pornographic content). It is in our legitimate interest to ensure the security of our services and a harmonious online environment within our services.
g) We will collect your chat data from manual sessions of customer service: getting a clearer picture of your customer service experience. We will use this information to help you solve issues in accordance with your request. It is necessary to perform our contract with you to resolve customer service issues and support the Game.
h) If you agree to participate in a survey conducted by us, we may collect survey information. (e.g. Country, Age, Profession, Email, and content of survey response) with your consent to improve our services.
In addition, in order to provide you with better services, we may conduct internal research on the number, preferences and behaviour of all users; this research is based on the analysis of the overall behaviour of all users, and does not analyze individual users.
2. Information Collected When You Use the Game Services:
a) Guest log in information: A new OpenID (Account ID) will be generated every time you log into the Game as a “guest”.
b) When you use the Game on a mobile platform, We may collect your device data (including application version, unique device identifier, advertisement identifier, system language, model, device name and type, the version of your operating system, MAC address,) every time you log in to the Game or make an in-game purchase for the purpose of ensuring game security and verification , identify and address bugs and assess game function for optimization, and monitor the success of our advertising and marketing programs (if any).
c) We will collect your IP address to determine the country or regions you are in and lock the game region, to allow you to connect to the Game and we may use your IP address to help and solve disputes concerning game account.
d) We will generate a unique user ID for you to track your usage and store your Game Data, and we collect and store your Game play statistics (e.g. level, scores) in order to provide you with feedback and information about your Game play and progress.
e) We will collect Security Related information (e.g. SDK log data, server IP, system information, application version, start-up time, device information) for security purposes in order to detect offensive and sensitive wording to provide a fair and secure gaming environment.
3. We use your personal data within the scope of fulfilling the purposes of the agreement. Except for if we have your explicit consent, and in the following situations, we will not use your personal data beyond the scope of the specific purposes of the Policy:
a) Where it is related to national security and national defense security.
b) Where it is related to major public interests, public security and public health.
c) Where it is directly related to criminal investigations, prosecutions, trials and enforcement of judgments, etc.
d) Where it is for the purpose of protecting the life, property or other fundamental legal rights of you or other individuals, and when it would be difficult to obtain your consent.
e) Where the personal information collected is voluntarily disclosed to the public by yourself or through legitimate and public channels (such as legitimate news reports, government information disclosures, etc.)
f) Where it is necessary for the signing or implementation of related agreements or other written documents.
Where it is necessary to maintain a safe and stable operation of the products or services provided by us, such as for discovering and dealing with issues of such products or services.
h) Where it is required by the authorities or other circumstances as stipulated by laws and regulations.
In specific cases, we may collect other personal data apart from the categories stated herein based on your consent. When this occurs, we will, upon requiring your additional consent, provide more information about any change to the way or purpose of our collection or processing which might be different from or not clarified in the details in this Privacy Policy. Under any circumstance where our collection or processing of your personal data is based on your consent, you may withdraw such consent at any time with no impact on the validity and lawfulness of collection or processing based on the consent made before its withdrawal.
II. Sharing Your Personal Data with Third Parties
Only where necessary will we share your personal information with third parties:
1. We may share some of your personal information with third parties that provide services in support of the Game Services according to your request:
a) When you use the Game, your device information and other personal data may be shared with our market analysis service provider (such as AppsFlyer, firebase) in order to optimize advertising effectivity and conduct market analysis. We will only share necessary personal information. If we adjust our purpose of using and processing personal information, we will once again ask for your authorization and consent.
b) We may share your personal data with logistics service providers who provide shipping services such as delivering physical prizes to users.
c) Other contractors if any for the purpose of providing our services to you. Each third-party has its own privacy policy and security measures for processing data and information, so when specific third parties are involved in collecting data and information, please participate in their privacy policies. Since those contractors may access, collect, or process your data as the data controller and operate under their own privacy policies, please refer directly to their privacy policies on their official websites and learn more about their data processing practices.
2. We may provide a certain portion of your personal data to judicial or administrative authorities as so requested.
Besides, we may disclose certain portion of your personal data within a strictly limited scope of recipients when we reasonably think it is necessary to protect us, our users or portion of the public. In addition to be required by applicable laws, we reserve the right to disclose your personal data in the cases if we , in our good faith believe that disclosing such data is necessary to identify, contact, or bring legal action against you, if (a) you are violating any other agreement(s) between you and us, such as the Terms of Service, this Privacy Policy or otherwise damage us; (b) you are infringing third-parties’ rights and interests (including but not limited to intellectual property rights); and/or (c) we believe that it is necessary to prevent fraud or other illegal activities.
3. We will only share your data with third parties (such as our affiliate companies or suppliers) under the following circumstances:
a) Where we obtain your permission (including permissions stipulated in the Policy).
b) Where we share your data in reasonable and necessary circumstances for the purpose of fulfilling contracts.
c) Where, if your data is anonymous or presented in aggregate form, others cannot identify that it is your personal data.
d) Where it is necessary for us to share data so as to fulfill our legal obligations as a data controller.
e) Where it is necessary for protecting the rights and interests, property or safety of our users or other individuals.
Should we sell our properties or reorganize our corporation, or should the right of control change for us or any of our affiliate companies, or prepare to implement any of the aforementioned changes, we will require the new transferee company or organization holding your personal information to continue to be bound by the Policy, adopt the same standards and requirements to process and protect your data; otherwise, we will require that said company or organization requests your authorization and consent anew. If we do not transfer your personal data to said company or organization, we will fully inform you and delete or anonymize all your personal data under our control.
III. How We Protect Your Personal Data
1. The safety of your personal data is of utmost importance to us.
We will do our best to implement technologies and procedures reasonable at the time, including but not limited to physical, technical, and organizational safeguards to protect all personal data against unauthorized access, disclosure, misuse, alteration, damage and loss. Unfortunately, as the Internet is not entirely secure, we cannot guarantee that the information you transmitted via the game will not be accessed, disclosed, altered or destroyed in the event of a security breach. While we strive to protect your personal data, we also remind you to be aware of hacking, cyber-attacks, and other risks on the Internet.
2. We strongly urge you to take every possible precaution to protect your personal data when using our services.
Including but not limited to changing your passwords from time to time, not reflecting your real name or other personal data in registration, using a combination of letters and numbers when creating passwords, using a secure browser and/or taking other possible security measures.
3. Please be aware that advertisers or websites with links to and/or from our websites may collect personal data about you.
This Privacy Policy does not apply to, and cannot control the activities of, those other advertisers or websites. We highly recommend that you read the privacy policy of such third-party websites which you may be directed to before providing any personal data.
IV. How We Retain Your Personal Data
1. We will only retain your personal data for as long as reasonably necessary to fulfil the purposes stated in the Policy or to provide services to you.
The retention time for personal data we collect is the shortest period necessary to achieve the collection purposes described in the Policy. After the necessary period expires, we will delete or anonymize your personal information, unless extending the retention period is for the purposes of satisfying any legal or regulatory requirements, or assisting us in resolving user disputes, preventing fraud, deception, foul behaviour, or helping us fulfill the content stipulated in the Policy. We will retain your personal data after you delete your account or after we stop providing the services to you.
2. Should we stop operating some or all of our products or services due to special reasons, we will promptly inform you and stop the collection and processing of your personal data in related products or services.
And at the same time, we will delete or anonymize your personal data we possess related to said products or services, unless otherwise stipulated by laws and regulations.
V. Push Notifications
1. We may send you push notifications with your consent from time to time through our game application.
Informing you of game updates, high score lists and other service-related notifications that may be important to you. You can access your device settings such as tapping Settings – Notifications and choose to disable this function to disable our push notification services at any time. The specific process depends on your operating system.
VI. Policies Regarding Children
Our Game Services are not intended for children. Children must not use the Game Services for any purpose, except where their parent or guardian has provided consent (to the extent this option is available in your jurisdiction). By children, we mean users under the age of 18 years old; or in the case of a country where the minimum age for processing personal information differs, such different age. For users located in certain countries we have listed the relevant minimum age in the table below.
| Country in which the user is located | Minimum age |
| Algeria | 19 |
| Canada | 13 |
| European Economic Area/United Kingdom/Switzerland | 16 |
| Indonesia | 21 |
| Kingdom of Saudi Arabia | 15 |
| Kuwait | 21 |
| New Zealand | 16 |
| Russia | 14 |
| Thailand | 20 |
| United States | 16 |
If the applicable laws in your jurisdiction provide otherwise, the corresponding laws shall govern.
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 without parental or guardian consent, or if you are the parent or guardian of the user and wish to withdraw the consent, please contact us and we will delete such information immediately after verification.
VII. Other Related Matters Needing Attention.
1. Please keep your password and any personal data safe.
And do not provide any personal data, especially your password, to anyone. If you no longer use our services, you can choose to delete your account.
2. All types of personal data that you voluntarily disclose through the Internet, such as posting your email address or birthday in comment sections, chat rooms, etc., may be collected and used by others.
If you publish personal data that can be read by others, you may receive unsolicited emails from other entities. Therefore, you are solely responsible for the confidentiality of your password and any account data. Treat your personal data with care and be sure to ensure its safety.
VIII. Your Rights to Your Personal Data
We respect your rights to your personal data. The following is a list of the rights you enjoy in accordance with the applicable law and regulations and how we will protect your rights, except for when we are unable to confirm your identity.
1. Right to information:
We inform you how we handle your personal data by publishing the Policy. We are committed to ensuring transparency in the use of your information. You may also find our policy for the protection of your personal data on our website.
2. Right of access:
You have the right to access personal information we hold about you, how we use it, and who we share it, including your username, registration time, etc. You can query and access your personal data through the User Center, or by contacting us via the contact information disclosed in the Policy to request access. We will process your request and give feedback within the time required by laws and regulations.
3. Right to rectification:
Should you notice that your personal data processed by us is wrong or incomplete, you have the right to request us to make corrections or supplements.
You may contact us with a request to make corrections or supplements through the contact information disclosed in the Policy. We will process your request and give feedback within the time required by laws and regulations.
4. Right to erasure:
You may contact us with a request to delete your personal data if we collect and use your personal data in a manner that violates the Policy through the contact information disclosed in the Policy. We will process your request and give feedback within the time required by laws and regulations. Should you share your data on any social network or third-party platform through the Game, the content of your data will be controlled by the aforementioned social network or third-party platform, and we may not be able to revise or delete any data shared with us via third-parties through your use of our services (for example, if you allow friends to interact with your accounts on social networking platforms), because the aforementioned data is not under our control. We will notify third-parties immediately and give feedbacks to you.
5. Right to cancel account:
We provide you with the service of account cancellation. You may contact us (or customer service) to request cancellation through the contact information disclosed in the Policy. Should you choose to cancel the Game account, we will delete or anonymize all relevant personal data generated by you in the Game in a timely manner in accordance with relevant laws and regulations, unless otherwise required by laws and regulations. Should you choose to cancel your Fraser Game platform account, you are particularly reminded that once you do, you may not be able to access any data of any games on the platform previously associated with your account (including but not limited to levels or scores reached in the game, or any virtual items (currency) associated with the account). Once the cancellation is complete, your account cannot be restored again, so please exercise this right with caution. We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case.
6. Right to restrict processing:
You have the right to request that we restrict the processing of your personal data. This means that we can retain your personal data but cannot process it. We will only retain the data needed for responding to your future requests. You may contact us to request for your exercising of the right to restrict processing of your data through the contact information disclosed in the Policy. We will process your request and give feedback within the time required by laws and regulations. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection).
7. Right to data portability:
You have the right to receive your personal data in a structured, commonly used and machine-readable format in accordance with related laws and regulations. For instance, should you decide to change to a new service provider, this right allows you to reliably, securely and easily copy or transfer your personal data between our IT system and their IT system without hindrance. We would like to note you that this right is highly depend on technical support.
8. Right to object:
You have the right to object to our processing of your personal data. You may contact us to request for your exercising of the right of objection through the contact information disclosed in the Policy.
9. Right to withdraw consent:
Each part of the services we provide require some basic personal data to realize its full features (Please refer to the content under the “How we Collect and Use Your Personal Data” section of the Policy). You may change the scope of the authorized personal data collection by deleting your personal information or cancelling your account, or contact us to withdraw your consent through the contact information disclosed in the Policy.
Should you not want to receive commercial advertisements (if any) sent to you by us, you have the right to opt out from these at any time. Simply follow the unsubscribe process clearly stated in the marketing emails.
Should you withdraw your consent or authorization, we may no longer continue to provide you with the services related to the withdrawal of the consent or authorization, and will no longer process your related personal data. However, your decision to withdraw your consent or authorization will not affect the processing of personal data previously carried out based on your authorization.
10. Right to refuse automated decision-making:
You have the right not to be subject to decisions based solely on automated processing, including profiling. Should any such decision notably affect your legal rights, you may contact us to request your exercising of the right to refuse automated decision-making through the contact information disclosed in the Policy. We will respond to your request and take appropriate measures when necessary.
11. Right to complain:
You have the right to lodge a complaint with us through the contact information disclosed in the Policy, or lodge a complaint regarding how we process your personal data with your local data protection authority.
We will respond to your request within 30 days from the date of receiving your request and communicate with you in an appropriate way. If necessary, we may extend the aforementioned period (for up to 30 days), and inform you of the reason for the extension within 30 days from the date of receiving your request. If we have reason to believe that there is no need to take any action on your request, we will inform you of our decision within 30 days from the date of receiving your request and provide an explanation. If you are not satisfied with the response you received, you can lodge a complaint with or report to a supervisory authority within your jurisdiction, or file a lawsuit to a judicial authority within your jurisdiction.
12. Right to Opt-out of the Sale of Personal Information (if any)
You have the right to opt-out of the sale of your personal data (if any) and require us to make a statement regarding whether or not we sell your personal data and provide an opt-out mechanism or link to it except as otherwise stipulated in the CCPA.
We may disclose your Personal Information for the following purposes, which are not a Sale: (i) if you direct us to share your Personal Information; (ii) to comply with your requests under the CCPA; (iii) disclosures amongst the entities that constitute Company as defined above, or as part of a merger or asset Sale; and (iv) as otherwise required or permitted by applicable law.
In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” in the CCPA.
13. Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights
You have the right not to receive discriminatory treatment by us for the privacy rights conferred by the CCPA, namely that we shall not offer a financial incentive or a price or service difference due to your exercise of any of your rights under the CCPA unless such difference is reasonably related to the value of your personal data. Notwithstanding the foregoing, we have the right to deny your request to know, request to delete, or request to opt out for reasons permitted by the CCPA or those regulations thereof, and such denial shall not be considered discriminatory.
14. Right to Authorize an Agent to Make a Request on Your Behalf
You have the right to authorize an agent on your behalf to make a request to know, delete, or opt out under the CCPA. When you use an authorized agent to submit any request provided above, we may require you to provide signed permission to authorize your agent to do so for the purpose of verifying your own identity, and the official permission by your agent to submit this request. In the case of failure to provide any of the requested materials, to protect the user’s information and data security, we are entitled to deny such request.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. To protect the security of your account and your personal information, we may ask you to provide certain additional information to verify your identity before we respond to your requests.
You may have certain other rights under the applicable laws in your country of residence. Notwithstanding the foregoing, if the applicable laws in your country of residence provide otherwise, the corresponding laws shall govern.
IX. International Transfers of Your Personal Data
We provide the products and services of the Game across the globe. Therefore, your personal data (including the types of information listed under the “How We Collect and Use Your Personal Data” section of the Policy) may be transferred to or accessed from other jurisdictions outside your country/region of residence. For any cross-border data transfer, we will request your express consent to the cross-border transfer of personal data and strictly follow applicable laws and regulations to ensure the security of your personal data.
X. Revisions to the Policy
We reserve the right to amend the Policy as appropriate. If major changes are made to the Policy, we will release the latest version of the Policy on our website or notify you through appropriate channels. Please make sure to check these frequently. Should you not accept all of the amended content, please discontinue usage of the services at once and notify us about terminating this contract. Should you continue to use our services, you are deemed to have fully understood and agreed to be bound by the updated provisions of the Policy.
XI. Disputes and Jurisdiction
This Agreement shall be governed by and construed under the laws of the Province of British Columbia, Canada, and the federal laws of Canada applicable therein, without giving effect to principles of conflict of laws of any jurisdiction. All litigation, court proceedings, arbitration proceedings, mediation proceedings, lawsuits, court hearings and other hearings or actions initiated in connection with the Sites, Apps and/or the Content must and will be venued exclusively in Vancouver, BC, Canada.
XII. Contact Us
If you have any questions about this Agreement or have any requests for resolving issues arising from or in connection with this Agreement, please contact us in the first instance through email at support@heroicfates.com.