Privacy Policy

Last update: [24 October 2024] 

Winter Warriors  ("we," "our," or "us") highly values your privacy. This privacy policy (the “Policy”) sets out how we collect, use and protect your personal data when you access, use and play games, features, content and services via websites, mobile applications and other channels or portals developed and managed by Winter Warriors (the “Services”).

1. The Data We Collect about You
   • We collect both personal and non-personal data when you useour Services 。Personal data means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier of that natural person.
   • We collect the following types of data for the purposes stated below:

No.	What we collect	How we use it
(1)	Google AID	Analytics
(2)	Network Status	Game performance optimization

2. Special Categories of Personal Data
   • Certain categories of personal data, such as details about your race or ethnicity, religious or philosophical beliefs and so on, are considered more sensitive than other categories of personal data in certain jurisdictions and require a higher level of protection.
   • Toclarify, our Services do not collect any types of those special categories of personal data.
3. How Your Personal Data isCollected

We don`t collect your personal data through our Services, or by post, phone, email or other means you choose to interact with us.

4. Legal Basis for Collection and Use of Personal Data

We only process your personal data where this is a legal basis permitted by the applicable law. The legal basis will depend on the context and purpose for which we collect and use your data, which may include:

• Consent: certain data will be collected when you have given us informed consent. You may withdraw your consent at any time but this will not affect the validity of the processing activities prior to the withdrawal.
• Contractual necessity: it is necessary for us to collect and process certain data to enable us to enter into a contract with you and perform our contractual obligations.
• Fulfilment of legal obligation: we may be required by the applicable law to collect and use your personal data to comply with our legal obligations.
• Legitimate interests: in certain jurisdictions we may rely on legitimate interests to collect and use your personal data to operate and improve our business.
• Other: we may also collect and use your personal data based on other legal bases under the applicable law.

5. Cookies, SDK and Similar Technologies
   • Our Services use cookies, SDK and similar technologies to deliver essential and additional functions.
   • The information collected by the SDKs are for the purposes of:
     • providing and improving our Services;
     • analyzing how our Services are used by users;
     • displaying and running in-app advertisements;
     • studying and analyzing the functionality and performance of the Services and activities related to the Services;
     • protecting the Services and usersfrom fraud, misuse and unlawful use of the Services’ and related data and assets.

We do not have access to the information collected by the SDKs.

6. Disclosure
   • We will not disclose your personal data to third parties unless we have obtained your consent or there are other legal bases for such disclosure.
   • We may engage a data processor (and/or sub-processor) to process your personal data for the purposes in this Policy, in which case we will request the data processor (and/or sub-processor) to keep your personal data in strict confidence and only process data to the extent it is necessary to perform its contractual or statutory obligations.
   • We may disclose your personal data to third parties to whom we may choose to sell, transfer or merge parts of our business or our assets, in which case the new owners will assume all our rights and obligations in this Policy.
   • We may also disclose your personal data for the purposes of national security, law enforcement, or public interests.

7. Data Retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes set out in this Policy. We will either delete or anonymize your personal data when it is no longer required to satisfy the purposes set out in this Policy.

8. Your Legal Rights
   • You may have certain legal rights in relation to processing of your personal data, which may include:

• Access right: you may request access to your personal data in our possession.
• Rectification right: you may request us to correct your personal data if it is inaccurate.
• Erasure right: you may request us to delete your personal data.
• Restriction right: you may request us to restrict how we process your personal data.
• Portability right: you may request us to help you transfer your personal data to other entities.
• Withdrawal of consent: you may withdraw your consent at any time.
• Right to complain and report: you have the right to complain to the relevant supervisory authority.
  • The above rights may only apply in limited circumstances under the applicable law and if we decide not to respond to your claim for the above rights, we will explain reasons.

9. Children’s Data
   • Our Services are designedand provided to users of various age groups. We will not collect personal data from any users who are under the age of 13. If parents or legal guardians suspect that their children, under the age of 13, have provided us with personal data inadvertently, they may request such personal data be removed by contacting us at [email protected].
   • Users who are between 13 and 18 years old (or the relevant age defined as a minor in the respective jurisdiction) should seek the consent of their parents or legal guardians before using our Services.

10. Data Security

    We are committed to keeping your personal data safe. We take reasonable and appropriate administrative, technical, organizational, and physical security and risk management measures in accordance with applicable laws to ensure that your personal data is adequately protected against accidental or unlawful destruction, damage, loss or alteration, unauthorized or unlawful access, disclosure or misuse, and all other unlawful forms of processing of your personal data in our possession.

11. Changes to this Policy
    • This Policy may be changed from time to time.
    • If we change anything important about this Policy (e.g., the type of personal data we collect), we will provide a prominent link together with the updated policy for your reference onour Services.
12. Contact Us

If you have any questions about this Policy, including any requests to exercise your legal rights, please contact our data protection department at [email protected].

Date: [24 October 2024]

Winter Warriors ("we," "our," or "us") is a game developer that provides games, features, content and services to users via websites, mobile applications and other channels or portals (the “Services”).

1. Acceptance of Terms

By accessing and using our Services, you consent to the terms and conditions in these Terms of Use (the “Terms”).

2. Eligibility for Using Services
   • The Services are designed and provided to users of various age groups and please see the instructions for eligibility when users download and use a specificService. If you are between the ages of 13 and 18 (or the relevant age defined as a minor in your jurisdiction), you should seek the consent of your parents or legal guardians before using our Services.
   • If parents or legal guardians consider that the Services are not suitable for their children, please contact us at [email protected] and we will respond to your requests and take actions we consider appropriate.
3. Services
   • Winter Warriors provides users with the following Services:
     • games, features, content;
4. Purchase and Refunds
   • Users may pay fees for certain functions and features of the Services, including virtual items and ads-free services, and users understand and agree that due to the nature of our Services, purchase of those functions and features are non-refundable. If users consider that fees should be refunded under exceptional circumstances, please contact us and we will consider the request on a case-by-case basis.
   • Users understand that users may only use the virtual items in the games and virtual items have no real-world value and cannot be redeemed for actual currency, goods or other items of monetary value.
   • Virtual items include virtual coins, points, props, and other in-game things related to the functions and features of the Services.
5. Users’ Conduct
   • Users shall use the Services in a lawful, fair and reasonable manner.
   • In using the Services, users may not
     • interfere with, damage or disrupt any part of our Services;
     • transmit or upload viruses and harmful programs;
     • copy, reproduce or sell any part of our Services; and
     • infringe the intellectual property rights and legitimate interests of any person.

6. Intellectual Property Rights

All intellectual property rights, including trademarks, patents, copyrights and other kinds of intellectual property rights, whether registrable or not, in relation to all the trade or business names, domain names, logos, content, layout, text and graphics, source codes, algorithms, software, database, applications, content and information of our Services are legally owned or acquired by Winter Warriors.

7. Disclaimer and Limitation of Liability
   • Users acknowledge and understand that Winter Warriors cannot guarantee a 100% safe operating environment, and Winter Warriors assumes no liability of whatsoever nature arising out of any failure, interruption and discontinuance of the Services due to the limitation of internet communication technologies and events of force majeure, attacks, viruses worms and malicious codes, system vulnerability, failure of third-party services and other factors which are beyond the control of Winter Warriors.
   • To the extent permitted by applicable law, Winter Warriors will not be responsible for any loss of profits, revenues, or indirect, special, consequential, or punitive damages.
8. Personal Data Protection

Please refer to our Privacy Policy for information on how we collect, use and share your data.

9. Indemnity

Users shall defend and indemnify Winter Warriors and its affiliates, directors, officers, employees, and users against all liabilities, damages, losses, costs, fees (including legal fees) and expenses relating to claims arising from or in connection with the violation of the Terms by users.

10. Termination
    • Users may stop using the Services at any time with or without notice.
    • We may terminate the Terms if
      • users violate the Terms, or
      • the Services are no longer available to users.

11. Miscellaneous
    • Interpretation

Headings are for reference purposes only and in no way limit the scope or extent of each section and shall not affect the meaning of the language in each section.

• Notice

Users shall send all the communications and correspondence to Winter Warriors to [email protected].

• Severability

If for any reason any provision of the Terms becomes unenforceable, that provision will be enforced to the maximum extent permitted so as to give effect to the intent of the Terms, and the remainder of the Terms will remain in full force and effect.

• Amendment

The Terms may be amended from time to time, and we will notify users by publishing an updated Terms on the websites, mobile applications and channels or portals to which users have access.

• Assignment

Users may not assign or transfer any rights and obligations under the Terms without Winter Warriors’s prior written consent.

• Waiver

The failure by users or Winter Warriors to enforce any provision of the Terms will not constitute a waiver of future enforcement of that or any other provision.