PRIVACY POLICY

xiaocaixiaoru is the developer of the mobile application [Magic Tower] (address: Tianhe District, Guangzhou, Guangdong). We attach great importance to protecting the personal information and privacy of users (hereinafter referred to as "you"). When you use [Magic Tower], we will collect, use, save and share your relevant personal information. In order to present how we handle your personal information, we have specially formulated the "[Magic Tower] Privacy Policy" (hereinafter referred to as the "Privacy Policy"), and we promise to strictly handle your personal information in accordance with this Privacy Policy. We would like to remind you: Before you use [Magic Tower], please be sure to read this Privacy Policy carefully and fully understand the terms, including but not limited to the terms that exempt or limit our liability. You know and confirm that by checking "Agree" to this Privacy Policy and using [Magic Tower], you agree that we will process your personal information in accordance with this Privacy Policy. Please be aware that this policy only applies to the information we collect when providing services to you through [Magic Tower], and does not apply to information collected by third parties who access [Magic Tower] to provide you with products or services. This Privacy Policy will help you understand the following: 1. How do we collect and use your personal information? II. How do we store your personal information? 3. How we use Cookies IV. How do we share, transfer, and publicly disclose your personal information? V. How do third-party products or services obtain your personal information? VI. How do we protect your personal information? VII. How do you manage your personal information? 8. How do we handle personal information of minors? IX. How to update this privacy policy 10. How to contact us 1. How do we collect and use your personal information? 1. How we collect your personal information During your use of [Magic Tower], we will collect your personal information in the following ways: 1. Complete the registration When you register for a [Magic Tower] account, we need to collect your mobile phone number, login password, and [data type]. We collect the above information to help you complete the registration of your [Magic Tower] account and protect the security of your account. If you do not provide this information, we will not be able to create an account for you and provide you with services normally. 2. Game Services When you use game services, we need to collect the device ID, device name, device type and version, and [data type] that you use. We collect the above information from you to ensure that you can use our services normally, maintain the normal operation of basic game functions, optimize game product performance, and enhance your gaming experience. If you do not provide this information, you will not be able to use the game services. 3. Real-name authentication When you perform real-name authentication, we need to collect your name, ID type, ID number, and [data type]. At the same time, in order to achieve the purpose of real-name authentication, you agree and authorize us to provide, query, and verify your aforementioned identity information to relevant real-name authentication agencies (such as personal credit agencies, government departments, etc.) by ourselves or by entrusting a third party. We collect your above information in order to fulfill legal obligations, verify the true identity of users, identify the age of users, and ensure the security of systems and services. If you do not provide this information, you will not be able to log in to [Magic Tower] or be subject to corresponding restrictions during the use of [Magic Tower]. 4. Ensure the security of the network and services In order to ensure the security of the network and game services, we will collect your device identifier, IP address, access date and time, [data type]. We collect your above information to create a fair, healthy and safe gaming environment, to combat behaviors that undermine the fair gaming environment or interfere with or disrupt the normal operation of game services (such as detecting piracy, scanning plug-ins, preventing cheating, etc.). If you do not provide the above information, you will not be able to use the game services. 5. Recharge and consumption … 2. Device permission call status When you use [Magic Tower], we need to apply for device permissions from you within the necessary scope. Please be aware that we will not enable your device permissions by default. Only when you actively confirm to enable it, [Magic Tower] may collect your information through device permissions. (III) How we use your personal information 1. We will use the collected personal information in accordance with the provisions of this policy and for the purpose of providing our services. 2. Please note that all personal information you provide when using our services will continue to be authorized for us to use during your use of our services, unless you delete it or refuse us to collect it through system settings. When you cancel your account, we will stop using and delete your personal information. 3. We will collect statistics on the use of our services and may share these statistics with the public or third parties for the purpose of product development, service optimization, and security assurance. However, these statistics do not contain any of your personally identifiable information. 4. When we want to use your personal information for other purposes not specified in this policy, or use information collected for specific purposes for other purposes, we will ask for your consent in advance by asking you to actively check the box. (IV) Other rules In accordance with relevant laws, regulations and national standards, we may collect and use your personal information without your authorization or consent in the following circumstances: (1) Related to our performance of obligations prescribed by laws and regulations; (2) Those directly related to national security or national defense security; (3) Directly related to public safety, public health, or major public interests; (4) Directly related to criminal investigation, prosecution, approval, and execution of judgments; (5) For the purpose of protecting the life, property, and other major legitimate rights and interests of the personal information subject or other individuals, but it is difficult to obtain the authorization and consent of the individual; (6) The personal information involved is disclosed to the public by the personal information subject or guardian on his/her own initiative; (7) Necessary for signing and performing a contract at the request of the personal information subject; (8) Collecting personal information from legally disclosed information, such as legal news reports, government information disclosure, etc.; (9) Necessary to maintain the safe and stable operation of the products or services provided, such as discovering and resolving product or service failures. II. How do we store your personal information? 1. We will keep your personal information for the shortest period required by the purposes set out in this policy and the laws and regulations. After the expiration of the aforementioned period, we will delete or anonymize your personal information. 2. Personal information collected and generated during our operations in China will be stored in China (for the purpose of this Privacy Policy, "China" does not include Hong Kong, Macao and Taiwan), except in the following circumstances: (1) There are clear provisions in the law; (2) obtain your explicit authorization; (3) Your personal initiative such as requesting to obtain overseas services. In response to the above situations, we will ensure that your personal information is adequately protected in accordance with this Privacy Policy and relevant laws and regulations. III. How do we use Cookies and similar technologies 1. How we use Cookies (1) By using Cookies, we provide users with a secure and personalized service experience. We and our third-party partners will store Cookies, Flash Cookies, or other local storage provided by the browser (or associated applications) that usually contains identifiers, site names, and some numbers and characters (collectively referred to as "Cookies") on your computer or mobile device. We and our third-party partners may collect your information through Cookies and use the information for the following purposes: Security Cookies: Cookies can help us ensure the security and efficient operation of our products and services. Recommendation Cookies: Cookies can help us recommend, display and push content that you may be interested in. …… (2) The collection and use of your information by third-party partners through Cookies is not subject to this Policy but to their own information protection statements. We are not responsible for third-party Cookies or similar technologies. (3) If your browser or browser add-on allows, you can modify the degree of acceptance of Cookies or reject our Cookies. For more information, please see https://www.aboutcookies.org/. However, if you do so, it may affect your safe use of our products or services in some cases. At the same time, you will still receive product or service information, but the relevance of such product or service information to you will be reduced. 2. How we use similar technologies … IV. How do we share, transfer, and publicly disclose your personal information? 1. Entrusted processing We will entrust a third-party service provider to process your personal information collected by us so that they can provide us with products or technical support such as infrastructure technology, data analysis, advertising, marketing decision-making, etc. The above-mentioned entrusted processing behavior is subject to the purposes stated in this policy, and we will supervise the above-mentioned entrusted third-party service providers in the form of contracts. 2. Sharing (1) Obtain your explicit consent or authorization in advance, or you request us to share your personal information with a third party via email or other means; (2) Providing in accordance with applicable laws and regulations, or in accordance with mandatory requirements of government authorities; (3) Sharing with our affiliates: We may share your personal information with our affiliates; however, we will only share necessary personal information and will be subject to the purposes stated in this Policy; our affiliates will also take the same security measures in accordance with this Policy to protect the security of your personal information; (4) Sharing with our business partners. We may share your personal information with [type of business partner]. We share this information for the purpose of providing services. For example, we need to share your [data type] with [type of business partner] to provide you with [service name] services. 3. Transfer We will not transfer your personal information to any company, organization or individual. However, in the event of a merger, acquisition, asset transfer or bankruptcy liquidation, if personal information is transferred, we will inform you of the relevant circumstances and require the new company or organization holding your personal information to continue to be bound by this policy. Otherwise, we will require the company or organization to obtain your authorization and consent again. 4. Public Disclosure Unless otherwise agreed in this contract or expressly required by law, we will not disclose your personal information publicly. 5. Exceptions In addition, in accordance with relevant laws and national standards, we may share, transfer, and publicly disclose personal information without obtaining your prior authorization or consent in the following circumstances: (1) Related to our performance of obligations prescribed by laws and regulations; (2) Those directly related to national security or national defense security; (3) Directly related to public safety, public health, or major public interests; (4) Directly related to criminal investigation, prosecution, trial and execution of judgment; (5) For the purpose of protecting the life, property, and other major legitimate rights and interests of the personal information subject or other individuals, but it is difficult to obtain the authorization and consent of the individual; (6) Personal information that the personal information subject or guardian voluntarily discloses to the public; (7) Collecting personal information from information that is lawfully disclosed to the public, such as legitimate news reports, government information disclosure, and other channels. 6. Please note that the information you voluntarily share or even publicly share when using our services may involve your or others' personal information or even personal sensitive information. Please share or disclose with caution. If the information involved contains other people's personal information, please obtain the consent of others before sharing or disclosing it. 7. Please be aware that, according to legal provisions, if we take technical measures and other necessary measures to process personal information so that the data recipient cannot re-identify a specific individual and cannot restore it, the sharing, transfer, and public disclosure of the data after the above processing does not require additional notification to you and your consent. V. How do third-party products or services obtain your personal information? In order to provide you with richer and more complete functions, we will use the following third-party software development kits ("SDKs") to provide you with services. Please refer to the privacy policy or relevant statements of the SDK operator for the specific information collection and use of the SDK. Click "Catalog of Third-Party SDK Service Providers" to view the details of the SDKs of the authorized partners we have accessed. 1 taptap SDK (1) Used for taptap authorization login and advertising delivery. (2) Types of personal information that may be collected: network status, device information (system name, system version, device model), and read application list (3) Privacy Policy: https://developer.taptap.cn/docs/sdk/start/agreement/ 2 PocketAD SDK (1) For advertising purposes. (2) Types of personal information that may be collected: network status, device information (system name, system version, device model), and read application list 3 Tapjoy SDK (1) For advertising purposes. (2) Types of personal information that may be collected: network status, device information (system name, system version, device model), and read application list 4 Talking SDK (1) Used for applied statistical analysis. (2) Types of personal information that may be collected: network status, device information (system name, system version, device model, MEID, MAC address, BSSID, Android ID), and reading application list 5 Pangolin SDK (1) For advertising purposes. (2) Types of personal information that may be collected: network status, device information (system name, system version, device model, MEID, MAC address, BSSID, Android ID), and reading application list VI. How do we protect your personal information? We attach great importance to personal information security and take all reasonable and feasible measures to protect your personal information: 1. We have adopted industry-standard data protection technologies and management measures, such as network isolation, data encryption, employee access control, etc., to prevent unauthorized access, disclosure, tampering, loss or destruction. 2. Please be aware that although we will try our best to ensure or guarantee the security of any information you send to us, the Internet environment is not 100% secure and we are not responsible for any risks or losses arising therefrom or related thereto. 3. After a personal information security incident unfortunately occurs, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, your suggestions for self-prevention and risk reduction, and your remedial measures, etc. We will promptly inform you of the relevant situation of the incident by application push, email, SMS, phone call, etc. When it is difficult to inform the subject of personal information one by one, we will take reasonable and effective means to issue an announcement. At the same time, we will also proactively report the disposal of personal information security incidents in accordance with the requirements of the regulatory authorities. VII. How do you manage your personal information? During your use of Magic Tower, you may contact us through the corresponding page prompts or the methods specified in this Privacy Policy to access, correct, delete your personal information, and exercise the right to change the scope of authorization and cancel your account. Your opinions will be processed in a timely manner. 1. Access and Correction of Your Personal Information If you wish to access or correct your personal information, you can click "[ ] - [ ]" and perform corresponding operations according to the prompts on the page, or you can contact us through the methods specified in this Privacy Policy, and we will respond to your request in a timely manner. 2. Delete your personal information In the following circumstances, you may request us to delete your personal information through the methods specified in this Privacy Policy: (1) We collect or use personal information in violation of laws, administrative regulations or your agreement; (2) If we share or transfer your personal information with a third party in violation of laws, administrative regulations or your agreement, we will immediately stop sharing or transferring your personal information and notify the third party to delete it in a timely manner; (3) If we disclose your personal information in violation of laws, administrative regulations or our agreement with you, we will immediately stop the disclosure and issue a notice requiring the relevant recipient to delete the corresponding information; (4) You no longer use our products or services, or you cancel your account, or we terminate our services and operations. 3. Change the scope of your authorization You can change the scope of consent or withdraw your authorization through device permission settings or by contacting us as specified in this Privacy Policy. Please understand that [Magic Tower] may require you to enable certain permissions and collect necessary personal information to be implemented. When you withdraw your consent, we will no longer be able to provide you with the services corresponding to the withdrawal of consent, but it will not affect the personal information processing services previously carried out based on your authorization. 4. Respond to your above requests If you are unable to exercise your rights in the above manner, you may contact us using the contact information set out in this Privacy Policy. For security reasons, you may need to provide a written request or prove your identity in other ways. We may ask you to verify your identity before processing your request. In principle, we do not charge any fees for your reasonable requests, but we will charge a certain cost for repeated requests that exceed reasonable limits. We may reject requests that are unreasonably repeated, require too many technical means, pose risks to the legitimate rights and interests of others, or are extremely unrealistic. 5. Exceptions for Response Situations We will be unable to respond to your request in the following circumstances: (1) Related to our performance of obligations prescribed by laws and regulations; (2) Those directly related to national security or national defense security; (3) Directly related to public safety, public health, and major public interests; (4) Directly related to criminal investigation, prosecution, trial and execution of judgment; (5) We have sufficient evidence that the subject of personal information has subjective malice or abuses his rights; (6) For the purpose of protecting the life, property, and other major legitimate rights and interests of the personal information subject or other individuals, but it is difficult to obtain the consent of the individual; (7) responding to the request of the personal information subject will cause serious damage to the legitimate rights and interests of the personal information subject or other individuals or organizations; (8) Involving trade secrets. 8. How do we handle personal information of minors? We attach great importance to the protection of minors' personal information. According to relevant laws and regulations, the collection and use of personal information of minors under the age of 14 requires the authorization and consent of their guardians; the collection and use of personal information of minors aged 14 to 18 can be authorized and consented by their guardians or by themselves. If you are a minor (especially a minor under the age of 14), we require you to ask your parents or other guardians to read this Privacy Policy carefully, and use our services or provide us with information only with the authorization and consent of your guardian. If you are the guardian of a minor, please pay attention to whether the minor you are protecting uses our products or services with your authorization and consent. If you have any questions about the personal information of the minor you are protecting, please contact us through the methods specified in this Privacy Policy. IX. How to update this privacy policy Our Privacy Policy may change from time to time. We will post any changes to this Privacy Policy on this page. For major changes, we will also provide more prominent notices (we may explain the specific changes to the Privacy Policy by making special reminders on the browsing page, etc.). Without your explicit consent, we will not reduce your rights under this Privacy Policy. The major changes referred to in this Privacy Policy include but are not limited to: major changes in our service model; changes in the main objects of sharing, transfer or public disclosure of personal information; major changes in your rights to participate in the processing of personal information and how to exercise them; changes in our contact information and complaint channels; when the personal information security impact assessment report indicates a high risk. We will also archive previous versions of this Privacy Policy for your reference. 10. How to contact us If you have any questions about this policy or personal information protection, you can contact us with your written questions, comments or suggestions through the following methods: Developer: xiaocaixiaoru (individual developer) QQ: 2591993194