PRIVACY POLICY
Updated on:12/08/2025
Throughout this Privacy Policy we refer to "Services", which means our websites, game services, surveys, promotions, contests, purchases, community support, and other activities related tothe Game. Also, when we use the terms " YOOKU ", "we", "us" or their derivatives, we are referring to YOOKU GAMES PTE. LTD and YOOKU 's affiliates. Affiliate in this Privacy Policy shall mean an entity that directly or indirectly controls, is controlled by or is under common control with YOOKU GAMES PTE. LTD hereto.
With so many users using YOOKU Services, we, YOOKU , understand the importance of your privacy and respect the privacy and security of every user. Maintaining the privacy and the trust of our users is important to us. This Privacy Policy summarizes our policies and processes on how we collect, use, disclose, transfer and store your personal information.
OUR SERVICES ARE NOT DESIGNED FOR MINOR, AND SINCE A "MINOR" IS USUALLY CONSIDERED TO BE UNDER THE AGE OF [13 (THE USA AND OTHER COUNTRIES OR REGIONS)/12 (BRAZIL AND OTHER COUNTRIES OR REGIONS) / 16 （EU AND UK）SUBJECT TO THE LAWS OF YOUR COUNTRY] UNDER APPLICABLE LAW OF MOST REGIONS, WE DO NOT DIRECTLY PROVIDE SERVICES TO MINOR UNDER THE AGE OF [13/12] IF YOU ARE UNDER THE [13/12/16] YOU SHALL ASK FOR THE CONSENTS OF YOUR PARENT OR LEGAL GUARDIAN BEFORE USING OUR SERVICES. We also do not knowingly collect Data from Minor through the Service. If you are the parent or guardian of a Minor and you believe that we have inadvertently received your child's information, please contact us through the methods listed in Section IX. We will delete the Data from our records as soon as possible after verifying your identity. If you are not a parent or legal guardian but believe that we might possess any Data from or about a Minor under the age of [13/12/16], you are also encouraged to contact us as well. We encourage parents to instruct their Children to never give out personal data when online.
in the event of a merger, acquisition, reorganization, bankruptcy or other similar event, we will make an announcement in advance, disclose the details of the event and information about the successor, and with the express consent of you or your guardian in advance again, your personal data may transfer to the successor of yooku .
This Privacy Policy explains how we collect, use, protect, and store your Personal Information (defined below) and how we comply with applicable data protection laws. It does not apply to other non- YOOKU service providers, including third-party services as described in Section II, which may be embedded in our Services in the form of Software Development Kit ("SDK"), Application Programming Interface ("API") or directly linked to our Services. Those third-party service providers may access your data as data controller and operate under their own privacy policies, and you can refer to Section IV for more details.
YOOKU 's Privacy Policy does not include the privacy policies of third-party service providers, nor does it bear any joint liability for them. If you need to exercise related rights or think that third-party service providers infringe your rights, please contact their corresponding DPO.
Personal information may be collected from you during your use of the Service, including, during (a) the registration process, (b) promotional activities, (c) customer support and technical service requests, and/or (d) ordering and use of products and other services, or from and through third-party service providers and partners.
We may also collect information that does not generally identify you but may become associated with your account. We reserve the right to use information that does not generally identify you in connection with any lawful purpose.
For using YOOKU 's Services, we may ask you to provide necessary information or you may provide information to us voluntarily. In general, we will collect the following information that you may provide to us :
1)Your user information will be stored locally on your device
2)Information you provide when you contact our support team or DPO team: Information that you provide in your communications; Specifically, For requests relevant to data or privacy subject, we may collect information to verify your identity, your rights and to process the requests, including country/region, alias, user email address, screenshot of Game, account ID.
We automatically collect certain data from you when you use the Services, namely:
1)IP address: we collect IP address to allow you to connect to the Game server; and suggest your country/region when you seek to change your location setting.
2)Device information: such as application version, battery level, WiFi strength, available space, network type, OS version, platform, carrier, country code, series ID, Android ID, IDFV, WiFi SSID (stored device-side only) and time zone settings, registration time, login time.
3)Game play statistics (e.g. level, scores, game settings).
Please note that if certain features on the Services are provided by third parties, those third parties may also use automated means of data collection and may record information about your use of the Services over time. These features are subject to those third parties' privacy notices and policies.
1) Data to measure the effectiveness of our advertising campaign from our advertisement service provider.
2) Safety observation and security related information: such as game crashes and errors data.
We collect the above information for the purposes to update your profile, perform market analysis, and/or otherwise improve the YOOKU Services. We abide by this Privacy Policy when we use Personal Information provided to us by third-parties.
we will use a runtime permissions request whenever available, prior to accessing data gated by Android or IOS permissions. For example，if you want to store/read game data, or want to store/read/post/share photos or screenshots, you will be required to grant the Write/Read-External-Storage permission (or other similar permission with different name in the operating system), etc.
1) The principle of lawfulness, fairness and transparency;
2) Your consent that we may obtain from you time to time;
3) Specified, explicit and legitimate purposes;
4) The extent that is adequate, relevant and limited to what is necessary in relation to the purposes, such as to perform the obligations under END USER LICENSE AGREEMENT and to provide our Services;
5) Your or our other legitimate interests;
6) Necessity for protecting the vital interests of you;
7) Other legal bases including if required under any law or required by governmental and regulatory bodies.
1) Software: For example, identify, fix, and troubleshoot bugs and service errors; provide software updates;
2) Gaming Functions: For example, facilitate your gameplay on multiple devices; enable online matchmaking; enable purchasing related functions; monitor, analyze, test, improve, and develop our Service, etc.;
3) Marketing/Advertising(optional): For example, serve and measure the effectiveness of advertising; adhere to your preferences and to deliver dynamic and personalized content;
4) Compliance and security: help identify fraud and illegal behaviors, comply with the law or to enforce our agreements and policies, ensure the security of our services, to maintain a fair gaming environment in the Game and to prevent the sale of plug-ins or the availability of pornographic content on the services.
1) Help identify and troubleshoot problems with your account or Services;
2) Collect your opinions through surveys or questionnaires;
3) Communicate with you and respond to your specific requests or questions;
4) Help you find your friends or share your related gaming experience;
For the purposes set forth above and to successfully operate the Services, our affiliates may be commissioned to access and process your information from time to time. All related affiliates may only use your Personal Information in accordance with this Privacy Policy. In all of the above cases and purposes, you acknowledge and confirm that we may analyze, profile, segment, merge and/or update all collected data (regardless of an aggregated or individualized manner) for the purposes of improving service quality and providing a better experience to users.
To protect the privacy of your information, we verify your identity and processes rights requests through our in-game help ticket system.
Although we do not sell your personal information, under certain laws such as the CCPA, some jurisdictions may consider the sharing of personal information with third-party service providers to constitute a “sale.” For example, we allow third parties, such as Facebook and Google, to place technologies (e.g., cookies) on our website for the purpose of marketing to users of our website. Other than this type of sharing, we do not sell any of your information. In the interest of full disclosure, we have indicated that your personal information may be considered a “sale” in certain states (such as California), but in most states such sharing is not deemed to be a sale.
In the past twelve (12) months, we have disclosed personal information for the above-mentioned business purposes to service providers and contractors, and to third-party advertising and marketing companies for cross-context behavioral or targeted advertising. You may opt out of cross-context behavioral or targeted advertising at any time by using the opt-out consent option made available to you.
You have the right to learn more about the details of information sharing by sending an email, and you also have the right to refuse sharing at any time.
Subject to your legal rights, we may disclose the information we collect about you, and may enable you to share this information, with a variety of third parties in various ways, including:
YOOKU will share the information we collect from you, information collected automatically, and information collected from third parties with service providers and other third parties only in the ways described in this Privacy Policy.
We may also share de-identified, aggregated, and/or public information with third parties. Additionally, we may share unique identifiers specific to your device with service providers and third parties to tailor content, personalize advertising, and adjust or improve our services.
We may share your personal information with our affiliated companies, including for their own marketing purposes (such as personalized advertisements). YOOKU is not responsible for the privacy practices of our affiliates, and the use of your information by those companies (such as for product improvement) will be governed by their own privacy policies, which you may find on their respective websites.
If you purchase a product or license a game from another company through the YOOKU platform, or when you link accounts or otherwise interact directly with another company, we may share information we collect (such as your account information and gameplay data, including purchase history, friends list, and gamertag) with that company so they may establish or maintain a direct relationship with you. Because of this sharing, you may receive communications from that company, including for their own marketing purposes (such as personalized advertisements). YOOKU is not responsible for the privacy practices of those companies and the use of your information by those companies.
We share certain players’ game data with our developer community, who create applications and websites that benefit our player community. You may opt out of having your game data included in this program by disabling game-data sharing in the Privacy section of your YOOKU account management settings.
We may share your information with vendors engaged by YOOKU to perform services for us (for example, platform providers, media partners, event ticket providers, merchandise vendors, survey providers, billing processors, customer support providers, and information technology service providers). In these situations, a written contract between YOOKU and the vendor will govern such disclosure, the vendor must agree to reasonable levels of security regarding your data, and the vendor will not be permitted to use your data except as required to perform those services for YOOKU. If your data is anonymized, the vendor may use it for other purposes.
As with any business, your personal information is also a business asset of YOOKU and will become part of our normal business records. As such, we may disclose your personal information to a third party if we decide to sell a line of business to that third party, so you can continue to receive service and information related to that line of business with as little disruption as possible. Similarly, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, your personal information may be transferred to YOOKU’s successor or assignee.
YOOKU may also host message boards, forums, and/or chat areas where users can exchange ideas and communicate with one another. When posting to a message board, forum, or chat area, the information is made publicly available online and you do so at your own risk. For certain forums, anyone posting or replying may be doing so using their Real ID — that is, their full first and last name — with the option to also display the name of their primary in-game character. If your personal information is posted on one of our community forums, you may contact us at developer@yookugame.com to request removal. In some cases, we may not be able to remove your personal information, in which case we will inform you and explain why.
If you are a California resident, the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA), grants you specific rights regarding your personal information. These include the right to:
Request to know what personal information we collect, use, disclose, and sell/share.
Request deletion of your personal information.
Request correction of inaccurate personal information.
Opt out of the sale or sharing of your personal information for targeted advertising.
Limit the use and disclosure of sensitive personal information.
We do not sell personal information for monetary consideration, but we may share personal information for targeted advertising purposes as defined under California law. You may opt out of such sharing at any time by emailing us at developer@yookugame.com
If we have actual knowledge that a user is under the age of 13, we will comply with the U.S. Children’s Online Privacy Protection Act (“COPPA”) by obtaining verifiable parental consent before collecting, using, or disclosing that child’s personal information. In such cases, we will only share a child’s personal information with:
Service providers who perform necessary business functions on our behalf and who are contractually obligated to protect the confidentiality and security of that information;
Other players and/or the public, only if parental consent has been provided for such sharing;
Government authorities or law enforcement when required by law.
Parents or legal guardians may review, delete, or refuse further collection or sharing of their child’s personal information by contacting us through the methods described in Section developer@yookugame.com of this Privacy Policy.
Email: Contact our Privacy Team at developer@yookugame.com with “Opt-Out Request” in the subject line. Include sufficient information for us to verify your identity.
We will no longer share or sell your personal information with unaffiliated third parties for their own direct marketing or targeted advertising purposes.
You may still receive service-related communications and contextual advertising based on your activity within our services.
We may continue to process your personal information for service delivery, security, compliance, and other legitimate purposes described in this Privacy Policy.
We may request that you verify your identity before we process you opt-out request. This could include confirming account credentials or responding to a verification message.
In addition to YOOKU and/or its affiliates, other parties may also access your personal data in the following situations. You acknowledge that you have foreseen and agreed to the occurrence of such disclosure when you provide your personal data.
We may provide certain portion of your Personal Information to judicial or administrative authorities when we are required to do so by law, legal process, or a reasonable request from law enforcement authorities or other government officials. Besides, we may disclose certain portion of your Personal Information within a strictly limited scope of recipients when we reasonably think it is necessary to protect us, our users or a portion of the public.
In addition to be required by applicable laws, we reserve the right to disclose your Personal Information 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 agreements between us, such as the END USER LICENSE AGREEMENT and 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.
We ensure that, even in this case, we will not provide your Personal Information to third parties.
YOOKU works with some (if any) third-party service providers and business partners to support the operation and provision of our Services. For example, we may share certain limited information, such as device identifiers, with marketing partners for purposes of executing and optimizing campaigns, and gauging the effectiveness of advertising and other marketing strategies solely on YOOKU 's behalf. These service providers are not authorized by us to use or disclose personal information except as necessary to perform services on our behalf or comply with legal requirements and we do not share Personal Information with third parties for their direct marketing purposes.
Besides, some of third-party services being linked to or embedded in YOOKU Service may use cookies, web beacons, and/or other technologies to collect or receive data about you according to their own Privacy Policy, and we cannot control the information that these third parties collect or how they use that information. We strongly encourage you to check their own Privacy Policies on their official websites and learn more about their data processing practices. Notwithstanding the foregoing, if you discover that any third party collects or processes your Personal Information illegally or in a manner which worries you, you are encouraged to contact us, and we will make reasonable efforts to help you.
Main third-party services embedded in our Services which may collect your Personal Information and links to their Privacy Policy are as follows (the concrete scope of Third-party services embedded in each YOOKU Service may vary depending on the services we provide):
【APPSFLYER】
Market advertising monitoring
`https://support.appsflyer.com/hc/en-us/articles/4417197430289-Fill-out-Google-safety-section-form`
【THINKDATA】
Data analysis
`https://docs-v2.thinkingdata.cn/?version=latest&lan=en-US&code=te_googleplay&anchorId=`
【FIREBASE】
Game performance monitoring, crashes, etc.
`https://firebase.google.com/docs/android/play-data-disclosure`
Our Service is global by nature and you understand and agree that we may store or process your Personal Information outside of the country where we collect it or in which you reside; You hereby unconditionally agree and permit that we may transfer, share, disclose all or any of your Personal Information to third parties or service providers or other entities where necessary in relation to the purposes identified in this Privacy Policy. As different countries may have different Data Protection and Privacy laws, policies, and other regulations, you are fully aware that applicable laws in some country may not offer you privacy protection which is in the same level as such offered in the country where you live or work. In such cases, we will take steps to ensure adequate safeguards are in place to protect your data, for example, we will contractually oblige the receiving parties to ensure that same level of data protection is accorded to your information that is adhered to by us under applicable law. Further, we contractually ensure that such information is not disclosed, published, or transferred further.
Security of our users' Personal Information is a priority at us, and we are continuously implementing and updating administrative, technical, and physical security measures such as access control, compressed encryption to help protect your data against unauthorized access, loss, destruction, or alteration. As part of our privacy compliance processes we review these security procedures on an ongoing basis to consider new technology and methods as necessary. Due to the continuous updating of technology, we will try our best to continuously improve our information protection measures. If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. If there is a security breach, we may also post a notice on our Website or by other effective means to notify you for you to take steps to protect the safety of your information as well as your property. We will send an emergency report to authorities in case that the security breach is serious and assist authorities as well to take steps to prevent further harm.
The specific personal information we process and our reasons for doing so often vary depending on how you use the Services. Therefore, the length of time that we retain personal information can also vary. We generally retain personal information for as long as we reasonably need it for the purposes described in this Privacy Policy (such as complying with our legal obligations, where we have an ongoing legitimate business need to do so, managing internal records, enforcing our contracts and terms, fraud prevention, resolving disputes, and for safety reasons), unless a longer retention period is required or permitted by law.
The primary factors we consider in determining retention periods can include minimum requirements under applicable law, relevant industry standards, the types of data in question (such as its level of sensitivity), relevance to potential litigation or similar proceedings (such as defending ourselves against legal claims), and whether the personal information is required to prevent fraud or similar abuse of the Services (including to enforce prohibitions against cheating and other unauthorized behavior and to prevent banned players from using the Services).
Subject to any limitations under applicable law, you have the right to request access to your Personal Information and exercise the following rights :
1)You have the right to access, correct or update your Personal Information. In many cases, you can review or update the Personal Information in your account by accessing your account online or contacting us.
2)You have the right to request deletion of your account and related Personal Information. If you choose to have your Personal Information removed from our active databases, we will carry out your request within15 days after we verify your identity unless otherwise required by applicable laws and regulations. After deletion, we will only retain necessary information to document your request and the actions we took to carry out your request. And you are fully aware that once your personal information is deleted, we will not be able to provide you with corresponding services or recover the information with current technology.
3)Where you have provided your consent to our collecting and processing of your personal information, you can always withdraw your consent at any time by turning off it in your mobile device settings or contact us through developer@yookugame.com. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal. Upon receiving your request to withdraw your consent we will stop the process and delete the corresponding information as well.
4)You have the right to restrict certain processing of your Personal Information, and the right to object to some types of processing of your Personal Information subject to Section VI of this Privacy Policy.
5)You have the right to object to the usage of your Personal Information for marketing or advertising purposes.
You may exercise any of the rights described above by using any functionality available while using the Service and/or sending an email to the DPO email as listed in Section IX and we will respond within 15 days or other shorter period (if any) as required by applicable laws or policies in the country where you live or work after. To protect your privacy, we may need to take steps to verify your identity before fulfilling your request.
the CCPA requires us to provide our users who reside in california with the additional notice below. for the purposes of this notice, personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the california consumer privacy act of 2018 (california civil code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”).
personal information does not include information that is:
You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.
Further, to provide, correct, or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We will verify your request through common market practices, including by asking you to send it from the email address associated with your account or requiring you to provide information necessary to verify your account.
You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.
Additionally, under California Civil Code section 1798.83, also known as the “Shine the Light” law, California residents who have provided personal information to a business with which the individual has established a business relationship for personal, family, or household purposes (“California Customers”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes.
Please be aware that we do not disclose personal information to any third parties for their direct marketing purposes as defined by this law.
California Customers may request further information about our compliance with this law by emailing the address provided in the "Contact Us" section above. Please note that businesses are required to respond to one request per California Customer each year and may not be required to respond to requests made by means other than through the designated email address.
California residents under the age of 18 who are registered users of online sites, services, or applications have a right under California Business and Professions Code section 22581 to remove, or request and obtain removal of, content or information they have publicly posted. To remove content or information you have publicly posted, or to request that we remove such content or information, please send us a detailed description of the specific content or information you wish to have removed using the details provided in the "Contact Us" section above. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.
An authorized agent may submit an access or deletion request on your behalf by sending a written authorization signed by you using the contact information in the “Contact Us” section. We may still require you to directly verify your identity and confirm that you provided the authorized agent permission to submit the request.
In order to measure the effectiveness of our services, some pages on our websites may use cookies, which are small text files for added functionality or for tracking site usage. We may use cookies and/or authorize third party's tracking-utility, from time to time, (a) to log your IP address in determining the path that users take on our sites and identifying repeat users of our sites, (b) to collect the websites or sources that linked or referred you to our services, and/or (c) to collect technical data about the devices and software you use to access our services, the operating system of your devices, and other similar technical data. Notwithstanding the foregoing, we do not link your IP address to your other Personal Information. If you do not wish to accept cookies or want to be notified of when they are placed, you may set your web browser to do so, if your browser permits.
We use the cookies, web beacons and similar technologies to personalize your experiences on our services and for various other purposes, including:
1)remembering you: cookies, web beacons and similar technologies can help us identify you as a registered user or keep the preferences or data that you have previously provided;
2)analyzing how you use our services: we can use cookies, web beacons and similar technologies to understand what visitors (including users) are doing on our services, or what pages or sections are most popular;
3)serving advertising: cookies, web beacons and similar technologies help us provide you with advertising that we believe is relevant to you or of interest to you, on the basis of your provided data; and/or
4)other related functions or purposes mentioned in Section II & III.
If you are a resident of Virginia, you have specific rights under the Virginia Consumer Data Protection Act (“VCDPA”). This section describes those rights and how you can exercise them.
YOOKU collects and processes categories of personal data as described in this Privacy Policy, including identifiers, commercial information, internet or other electronic network activity information, and other categories specified by the VCDPA.
Your Rights Under the VCDPA
You have the right to:
Access the personal data we have collected about you;
Correct inaccuracies in your personal data;
Delete personal data we have collected from you, subject to certain exceptions under law;
Obtain a copy of your personal data in a portable and readily usable format;
Opt out of the processing of your personal data for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects.
To exercise any of these rights, please submit a request through one of the following methods:
If you have any privacy request, please contact us with developer@yookugame.com
Email us at: developer@yookugame.com with “Virginia Privacy Rights Request” in the subject line; or
Mail a request to: YOOKU Privacy Department, Mail a request to: YOOKU Privacy Department, 112 ROBINSON ROAD #03-01 ROBINSON 112, SINGAPORE 068902.
We may need to verify your identity before processing your request to protect your privacy and security.
If you are dissatisfied with our response to your request, you have the right to appeal directly with us by contacting developer@yookugame.com. You also have the right to submit a complaint to the Virginia Attorney General’s office.
If you have questions, comments and requests regarding this privacy policy and/or your rights, or you want to exercise any of the rights described above or if you have questions regarding your rights, Please contact our Data Protection Officer (DPO) by sending an email to developer@yookugame.com.