Privacy Policy

LAST UPDATED: December 02, 2013


1. Your Privacy

This privacy policy (this “Privacy Policy”), as amended from time to time, applies to all of the products and services offered by XiaProjects.

XiaProjects respects the privacy rights of its customers and visitors (“Users”) and is committed to protecting the information collected through its online or mobile applications, services and websites (collectively, “Services”). XiaProjects has adopted this Privacy Policy to explain how XiaProjects collects, stores, and uses the information collected in connection with XiaProjects’s Services.

The English version of the Privacy Policy is the governing version. Any translation of the Privacy Policy is just a reference for your convenience and should not be relied on in legal proceedings.


2. Information We Collect & How We Use It

XiaProjects may collect and use both personal and non-personal data from Users using XiaProjects’s Services. This section of the Privacy Policy will describe the type of information that may be collected and how the information may be used.

2.1. Personal Data

2.1.1. Definition

For the purposes of this Privacy Policy, “personal data” means personally identifiable information that specifically identifies you as an individual and includes those items specifically listed below.

2.1.2. Registering for Services

Users may make personal data such as their name, email address, username and password available to XiaProjects when they register for Services, enter contests and special events, subscribe to newsletters, request technical support or otherwise communicate with XiaProjects, and when using XiaProjects’s Services where personal data is required for use and/or participation.

2.1.3. Information about Users Received from an SNS

When Users access the Services through a social networking site (“SNS”) such as Facebook, Twitter or Google +, Users allow XiaProjects to access certain information from their profile for that site. The information Users allow XiaProjects to access varies by application and SNS, and it is affected by the privacy settings you and your friends establish at the SNS. You can control and find out more about these settings at the SNS where you play our games. For example, XiaProjects may access and store some or all of the following information, as allowed by Users, the SNS and their preferences:

  • first and last name;
  • profile picture or its URL;
  • user ID number, which is linked to publicly available information such as name and profile photo;
  • the user ID numbers and other public data for Users’ friends;
  • the login e-mail provided to that SNS when Users register;
  • Users’ physical location and that of Users’ access devices;
  • gender; and birthday.

By using the Services through an SNS, Users are authorizing XiaProjects to collect, store, and use, in accordance with this Privacy Policy, any and all information that Users agreed the SNS could provide to XiaProjects through the SNS Application Programming Interface (“API”).

2.1.4. Optimize Interactive Experience

XiaProjects may collect, store and use personal data to provide Users with an optimized interactive experience. For example, the information collected may be used to create Users’ accounts, provide enhanced interaction with XiaProjects’s apps and websites, manage any in-game voting features, notify Users of in-game updates, provide technical support and respond to Users’ inquiries.

2.1.5. Other Purposes

Additionally, XiaProjects may collect, store, and use personal data to solicit Users’ feedback to help improve the Services and other XiaProjects products, inform Users about new products or promotional material offered by XiaProjects or its trusted third party business partners and affiliates, notify Users about changes to XiaProjects’s Services or other products, provide Users with advertising and marketing material from XiaProjects and its trusted business partners and communicate with Users for other commonly accepted purposes such as notifying them that they are a potential winner of a contest.

Finally, XiaProjects may collect and use personal data as required or permitted by applicable law.

2.1.6. Mobile Devices

If Users access XiaProjects’s Services on mobile and tablet devices, XiaProjects may collect mobile device identifiers, including MAC Address and IP Address, and XiaProjects may assign to your device an identifier that is similar to an account number. XiaProjects may collect the name you have associated with your device, device type, telephone number, country, and any other information you choose to provide, such as user name, character name, geo-location or e-mail address. We may also access your contacts to enable you to invite friends to join you in the Services.

2.1.7. SMS Notifications, Push Notifications & Local Notifications

XiaProjects may store the information you provide, including your telephone number, when you sign up to have SMS notifications sent directly to your mobile phone. These messages notify you of in-game activity and may allow you to play the game from your phone. With your consent XiaProjects may send push notifications and local notifications to your mobile device to provide game updates and other relevant messages.

2.1.8. Payment Information

If you purchase a license to use in-game virtual currency or virtual items directly from XiaProjects, we will collect the billing and financial information necessary to process your charges, which may include your postal or ZIP code and e-mail address. XiaProjects may also receive the billing and payment information that you provide when your purchase is processed by another party, such as Facebook (for Facebook Credits) or Apple (for purchases on iOS devices), Google, Amazon.

Please refer to XiaProjects’s Terms of Service to review the policies and terms relevant to our charges and billing practices and the terms of service of third party channels (such as those mentioned above) for their practices and terms of service.

2.1.9. Data Storage

XiaProjects may store and/or transfer your personal data outside of the United States in accordance with applicable legislation and this Privacy Policy.

2.1.10. Third Party Privacy Policies

While accessing or using XiaProjects’s Services, Users may interact with third parties, such as application stores, mobile software platforms, social networking services and payment providers. Users recognize and agree that XiaProjects is not liable for their use of Users’ personal data and Users should review the privacy policies of these third parties.

XiaProjects may make available links through advertisements or otherwise enable you to access third party products or services. While using such products or services, you are using products or services that are not affiliated with or controlled by XiaProjects. XiaProjects is not responsible for those people or companies, the content of their products or services, the use of information you provide to them, or any products or services they may offer. Providing links or otherwise enabling access to third party products or services does not constitute sponsorship of, or affiliation with those people or companies.

2.1.11. User Generated Content

Users should be aware of the open nature of certain social networking and other open features of the Services XiaProjects may make available to you. You may choose to disclose data about yourself in the course of contributing user generated content to the Services. Any data that you disclose in any of these forums, blogs, chats or the like is public information, and there is no expectation of privacy or confidentiality. XiaProjects is not responsible for any personal data you choose to make public in any of these forums.

2.1.12. Minors

Before disclosing a minor User’s personal data to a third party, XiaProjects shall disclose:

  • the kinds of businesses in which the third parties are engaged;
  • the general purposes for which the information is used; and
  • whether the third parties have agreed to maintain the confidentiality and security of the information.

A legal guardian may provide consent to XiaProjects collecting and using the minor’s personal data, without consenting to the disclosure of the minor’s personal data to third parties.

A legal guardian may review or require XiaProjects to delete or stop collecting and further using or disclosing the minor’s personal data at any time by contacting XiaProjects at the coordinates found at the end of this Privacy Policy. In this case, XiaProjects may no longer be able to provide the same level of Services.

XiaProjects does not knowingly collect any personal data from children below the aforementioned age without receiving the consent of a legal guardian. If XiaProjects learns that it has inadvertently collected or stored personal data from children under the aforementioned age without the consent of their legal guardian, XiaProjects will take reasonable measures to promptly erase such personal data from their records.

2.2. Non Personal Data

2.2.1. Definition

For the purpose of this Privacy Policy, “non-personal data” means: (1) information that does not directly identify you; and (2) “aggregate” and “de-personalized” information, which is data XiaProjects collects about the use of XiaProjects Services, from which any personally identifiable data has been removed.

XiaProjects may use tools or third party analytical software to automatically collect and use certain non-personal data. You will not be identifiable through the use of these tools or third party analytical software. The types of non-personal data XiaProjects may collect and use include, but are not limited to:

1. Device properties, including, but not limited to:

(a) IP address;

(b) Media Access Control (“MAC”) address; and

(c) Unique device identifier or other device identifier (“UDID”);

2. Device software platform and firmware;

3. Mobile phone carrier;

4. Geographical data such as zip code, area code and coarse location;

5. Game progress, score and achievements; and

6. Other non-personal data that XiaProjects may require to enhance the Services and other XiaProjects products.

2.2.2. Trusted Partners and Contractors

XiaProjects may use and disclose to its affiliated companies, contractors or other trusted businesses or persons the collected non-personal data for the purpose of auditing, researching and analyzing usage of the Services, ensuring the technical functionality of XiaProjects’s Services and to further develop the Services and other XiaProjects products.

2.2.3. Cookies, Beacons and Tracking

XiaProjects may use “cookies” and other technologies such as pixel tags, locally shared objects, clear GIFs and web beacons. XiaProjects treats information collected by cookies and similar technologies as non-personal data.

A “cookie” is a small bit of record-keeping information that is sent to the Users’ computer. XiaProjects’s cookies do not include personal data and may be used to: (1) facilitate Users’ login authentication, (2) help Users navigate around the XiaProjects’s websites, (3) monitor how many people are using XiaProjects’s Services, and (4) store Users preferences and track trends.

Most browsers are initially set up to accept cookies, but Users can disable cookies or set their browser to indicate when a cookie is being sent. However, disabling cookies may affect your ability to use the Services.

XiaProjects may also use Flash cookies (locally shared objects) and HTML5 storage (locally stored objects). Locally shared objects are small files similar to browser cookies and are used to remember your settings to personalize the look and feel of the Services. Locally shared objects only collect data in the aggregate.

You may prevent locally shared objects from being placed by disabling locally stored objects in your browser or by visiting Locally stored objects, such as HTML5 Web Storage, are used for similar purposes as cookies but typically may contain a greater amount and different types of data than browser cookies.

XiaProjects may also use web beacons and pixel tags to count Users who have visited certain pages or viewed certain advertisements. Web beacons, like cookies, do not include personal data. E-mails and other electronic communications XiaProjects sends to you may contain pixel tags that enable XiaProjects to track your usage of the communication, including whether the communication was opened and/or what links were followed.

2.2.4. Ad Serving Technology

XiaProjects reserves the right to use and disclose the collected non-personal data for purposes of advertisement by XiaProjects or XiaProjects’s trusted partners and contractors. XiaProjects may employ third party ad serving technologies that use certain methods to collect information as a result of ad serving through the Services.

XiaProjects or third parties operating the ad serving technology may use demographic and location information as well as information logged from your hardware or device to ensure that appropriate advertising is presented within the Service. XiaProjects or third parties may collect and use data for this purpose including, but not limited to IP address (including for purposes of determining your coarse location), UDID, MAC, software, applications, hardware, browser information, internet and on-line usage information and in-game information.

The foregoing data may be used and disclosed in accordance with this Privacy Policy and the privacy policy of the company providing the ad serving technology. You recognize and agree that the advertising companies who deliver ads for XiaProjects may combine the information collected with other information they have independently collected from other services or products. These companies collect and use information under their own privacy policies. These ad serving technologies may be integrated into the Services; if you do not want to be subject to this technology, do not use or access the Services. Although XiaProjects may take commercially reasonable steps to instruct such advertising companies to comply with the terms and conditions of this Privacy Policy, XiaProjects does not have access to or control of third party technologies.

2.2.5. Location Data

If XiaProjects makes location enabled Services available and you use such Services, then XiaProjects may collect and process your location data to provide location related Services and advertisements. XiaProjects may use various technologies to determine location, such as GPS, Wi-Fi or other network-based data such as IP address. Your GPS location is not accessed without your consent. Notwithstanding XiaProjects’s partners who are providing location related parts of the Service, XiaProjects will not share your geo-location with third parties without your consent. To the extent XiaProjects makes available geo-location to third parties in accordance with this Privacy Policy, it will be provided anonymously. Please note that XiaProjects may share your anonymous coarse location with its partners.

3. Who We Disclose Personal Data To

3.1. Disclosure of Personal Data

In providing the Services, XiaProjects may disclose the personal data to other companies or individuals in the following limited circumstances:

1. In cases where XiaProjects receives Users’ consent;

2. With applications stores as part of Users’ purchase and use of the Services (including in-app purchases);

3. XiaProjects has a good faith belief that access, use, preservation or disclosure of such personal data is reasonably necessary to;

(a) satisfy any applicable law, regulation, legal process or enforceable governmental request;

(b) enforce applicable Terms of Use including investigation of potential violations thereof;

(c) detect, prevent, or otherwise address fraud, security or technical issues; or

(d) protect against imminent harm to our rights and/or property, or

4. As required or authorized by applicable law.

3.2. Data Processing

XiaProjects may also disclose Users’ personal data to its affiliated companies, contractors or other trusted businesses or persons for the purpose of processing personal data on its behalf. XiaProjects requires that these parties agree to process such personal data based on XiaProjects’s instructions and in compliance with the Privacy Policy and any other appropriate confidentiality and security measures.

XiaProjects may disclose Users’ personal data to its affiliated companies, contractors or other trusted businesses or persons for the purpose of providing marketing and advertising content to Users. XiaProjects requires that these parties agree to process such personal data based on XiaProjects’s instructions and in compliance with this Privacy Policy and any other appropriate confidentiality and security measures. Users can unsubscribe from this service at any time.

3.3. Sale of Business

As XiaProjects continues to develop and grow, we may buy or sell parts of a business, which could include personal data as one of the transferred business assets. If XiaProjects becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, it will provide notice before personal data is transferred and becomes subject to a different privacy policy.

4. Choices for Personal Data

If XiaProjects proposes to use personal data for any purpose other than those described in this Privacy Policy, XiaProjects will obtain the Users’ prior consent or offer the Users an effective way to opt out of the use of personal data for those other purposes.

Users may choose to withdraw their consent to the use, collection or disclosure of personal data outlined in this Policy at any time. If a User withdraws his or her consent, then XiaProjects may no longer be able to provide the same level of Services.

Users are also given the opportunity to “opt-out” of having their personal data used for purposes such as receiving newsletters or other information from XiaProjects.

Withdrawals of consent will not have an effect on data that XiaProjects has provided to third parties in accordance with this Privacy Policy prior to such withdrawals.

5. Information Security

XiaProjects takes appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. XiaProjects employs physical, electronic and/or procedural safeguards to protect its systems and all personal data under its control against unauthorized access and use. All safety and security measures are appropriate to the sensitivity level of the information collected.

6. Accuracy and Access/Control over Personal Data

XiaProjects processes personal data only for the purposes for which it was collected and in accordance with this Policy. XiaProjects may take reasonable steps to ensure that the personal data processed is accurate, complete and current, but XiaProjects is not responsible for verifying the correctness of personal data.

XiaProjects will allow Users to access their personal data in the custody or control of XiaProjects, and will allow them to:

1. update or correct such personal data;

2. change User preferences with respect to communications, push notifications and other information received from XiaProjects or third parties; or

3. delete the personal data of the Users on XiaProjects’s systems (by submitting a request to XiaProjects Support).

Users can turn off push notifications (if applicable) by visiting the “options” or “settings” page within the relevant app. Users can turn off local notifications by visiting the “options” or “settings” page within the relevant app.

Users can stop further use of your geo-location (for example through “check-ins”) (if applicable) by visiting their device’s settings for the relevant application or the “settings” page for the relevant game. Users can also stop checking in.

Such updates, corrections and changes will not have an effect on other information that XiaProjects maintains, or information that XiaProjects has provided to third parties in accordance with this Privacy Policy prior to such update, correction or change.

7. Retention of Personal Data

XiaProjects stores personal data collected pursuant to this Privacy Policy only as long as is reasonably required to fulfil the purposes for which it was collected or as required or authorized by law.

XiaProjects may still retain some of the data to the extent such retention is necessary to resolve disputes, enforce XiaProjects’s user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of the Services.

8. Enforcement

It is XiaProjects’s policy to contact a complaining user regarding his or her concerns. XiaProjects will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between XiaProjects and an individual.

9. Changes to this Policy

XiaProjects reserves the right to modify this Privacy Policy from time to time, so please review it frequently. If XiaProjects makes material or significant changes to this Privacy Policy, XiaProjects may post a notice on XiaProjects’s website along with the updated Privacy Policy. Your continued use of the Services will signify your acceptance of the changes to this Privacy Policy.

10. Contact Information

Should you have any questions relating to this Privacy Policy, please contact XiaProjects at