Privacy Policy  


Effective from January the 1st, 2019 


PLEASE READ THIS PRIVACY POLICY CAREFULLY. IT DESCRIBES DETAILS ABOUT HOW WE COLLECT, USE AND DISCLOSE PERSONAL INFORMATION YOU SHARED WITH US. IF YOU ARE UNDER 18, DO NOT PROVIDE ANY PERSONAL INFORMATION UNLESS YOU HAVE FIRST OBTAINED YOUR PARENT’S OR GUARDIAN’S PERMISSION. 


Thank you for reading our Privacy Policy.  Magic Design Studios. (“Perfect World”, “we” or  “us”) use and maintain this Privacy Policy (“Policy”) that summarizes when and how your personal information is collected, used, safeguarded and disclosed in connection with your use of single-player games, clients or servers operated by Perfect World (the “Games”), and all features, functions, software and services offered in our Service. The Games and the features, functions, software and services offered by us collectively constitute the “Service”. It also describes the choices available to you regarding the use of, your access to and rectification or erasure of your personal information, your right to request restriction of processing or to object to processing, as well as the right to data portability. We reserve the right to change the provisions of this Policy from time to time. If we make any material changes we will notify you by means of a notice in our Service. We encourage you to periodically review this page for the latest information on our privacy practices. 


What is personal information ? 


As used herein, the term “personal information” means information that specifically identifies an individual (such as a name, address, telephone number, mobile number, email address, or other account number), and information about that individual’s location or activities, such as information about his or her use of the Service, IP addresses or mobile device identifiers, when directly linked to personally identifiable information. Personal information also includes demographic information such as date of birth, gender, geographic area and preferences when such information is linked to other personal information that identifies you. Personal information does not include “aggregate” information, which is data we collect about the use of the Service or about a group or category of products, services or users, from which individual identities or other personal information has been removed. Aggregate data helps us understand trends and our users’ needs so that we can better consider new features or otherwise tailor our Service. This policy in no way restricts or limits our collection and use of aggregate information. 


What personal information do we collect ? 


Active Collection 


Personal information is collected in a number of ways when you visit or use our Service. For example, we will collect your email address, user name and other contact and demographic information when you register and set up an account only for our Service, in those situations where it is necessary to create an account for the Service, or contact us by email or other means for any reason. From time to time we will collect demographic, contact or other personal information you provide in connection with your voluntary participation in surveys, sweepstakes, contests, games, promotional offers, and other activities. You can access certain portion of our Service without providing us with any personal information. However, you will not be able to utilize certain features that require registration or receive materials unless certain information is provided. The processing of this personal information is lawful as it is necessary for the performance of our Service, in line with art. 
 6.1.(b) of the GDPR. Where processing is not necessary for the performance of the Service, your consent to such processing will be requested. From time to time we may change the information requested upon registration or with respect to certain features or services, so this may not be a complete list. 


Third Party Advertisement 


Third parties may provide serve ads on our Service. These third parties may place cookies, clear gifs or other devices on your device to collect information, including device identifiers, user identifiers and/or IP addresses, and information provided by these devices may be used, among other things, to deliver advertising targeted to your interests and to better understand the usage and visitation of our Service and the other sites tracked by these third parties. This policy does not apply to, and we are not responsible for, cookies in third party ads or for compliance with such third parties’ privacy policies or data collection practices. The advertising industries in EU have developed schemes to help you opt-out of receiving cookies used for these purposes. You can find out more about the EU scheme from www.youronlinechoices.eu. If you would like more information about cookies and targeted advertisements or to opt out of having this information used by companies that are part of the Network Advertising Initiative, please visit www.networkadvertising.org/choices. Please note this does not opt you out of being served advertising. You will continue to receive generic ads. Please note that we have no access or control of any third party tracking technologies.

 
When you run our Software by or through a mobile device, information may also be collected and processed in the following manner: 


                  (i)  PW may collect aggregate statistics regarding game play, provided by the Apple App Store and Google Play marketplace, which does not include personal data of individual users, for the purpose of improving the Software; 


                  (ii)  PW integrates mobile advertisement network functionality within the Software.  PW may collect from such advertisement networks aggregate statistics regarding user clicks, views and interaction with advertisements, which does not include personal data of individual users, for the purpose of confirming the validity of advertisements delivered through the Software and determining accurate payment between PW and advertisement networks.  The identity of the mobile advertisement network or networks will be displayed within the advertisement screen of the Software and provide a link to the advertisement network’s own privacy policy.  The data collection and processing activities of the advertisement network is governed by its own privacy policy.  Please review the privacy policy of the advertisement networks so that you understand the advertisement networks collection and processing activities. You can find a list of such third parties’ privacy policies here.

 
                 (iii)  PW integrates advertisement attribution functions, provided by a company called Apps Flyer, within the Software. When PW advertises the Software on various platforms, Apps Flyer tracks the attribution of end users downloading the Software to identify which downloads of the software correspond to advertising campaigns on the platforms.  Apps Flyer collects at least end users’ device ID and IP address to carry out this activity. The purpose of this is to identify which advertising campaign on a platform resulted in end users downloading the Software and determining accurate payment between PW and the platform. Apps Flyer collects and processes personal data on PW’s behalf. Additional information on how such data are processed, can be found in its privacy policy, available at https://www.appsflyer.com/privacy-policy.  Apps Flyer provides to PW only aggregate information regarding downloads of the Software corresponding to certain advertising campaigns on platforms, but does not provide any personal data to PW. 


Device Identifiers 

 When you access the Service by or through a mobile device (including but not limited to smart-phones or tablets), we may use, access, collect, monitor and/or remotely store one or more “device identifiers,” such as a universally unique identifier (“UUID”). Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device’s operating system or other software, or data sent to the device by us. A device identifier may convey information to us about how you browse and use the Service. A device identifier may remain persistently on your device, to help you log in faster and enhance your navigation through the Service. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.  When you run our software by or through a mobile device, we may also access, collect, monitor and/or remotely store IP address. IP address may convey to us information about from where you download the Software or receive the Service. 


User Identifiers 


When you access the Service, we use, access, collect, monitor and/or remotely store one or more “user identifiers.” User identifiers are small data files or similar data structure assigned to a user that will be used to enable you to continue in-game progress, use games across multiple platforms and help associate your identity across multiple platforms. A user identifier may convey information to us about how you browse and use the Service. A user identifier may remain persistently on your device or computer, to help you log in faster and enhance your navigation through the Service. Some features of the Service may not function properly if use or availability of user identifiers is impaired or disabled. 


We see this processing as necessary for the purposes of the legitimate interests pursued by us, in line with art. 6.1.(f) of the GDPR. You have the right to object to this type of processing by contacting us as indicated above. In such case, we will carefully assess whether there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.  


For which other purposes do we use personal information ? 


In general, we use personal information we collect to process your requests or transactions, to provide you with information or services you request, to inform you about other information, events, promotions, products or services we think will be of interest to you, to facilitate your use of, and our administration and operation of, the Service, to better understand the needs of our visitors, and for the purpose for which the information was provided. For example, we may use the information we collect: 


                             • to provide the services, products or information you request and to process any transactions in connection therewith;

                             • to provide technical support, customer service and ensure the continued smooth operation of our service;

                             • to respond to your submissions, comments, requests or complaints; • to analyze user characteristics and usage patterns in order to better understand how our products and service are used and market them more effectively;

                             • to request feedback, perform research and analysis and to enable us to operate, develop, customize and improve the Service and our publications, products and services; • to prevent or investigate actual or suspected fraud, hacking, infringement, or other misconduct involving the Service or any of our products and services. 

 
The above purposes are necessary for the performance of our Service, in line with art. 6.1.(b) of the GDPR 


In order to offer you more consistent and personalized experience in your interactions with us, information collected through one offering or portion of the Service may be combined with information obtained through other offerings or portions of the Service. We may also supplement the information we collect with information obtained from other companies. For example, we may use services from other companies that enable us to derive a general geographic area based on IP address in order to customize certain services to your geographic area. 


We see this processing as necessary for the purposes of the legitimate interests pursued by us, in line with art. 6.1.(f) of the GDPR. You have the right to object to this type of processing by contacting us as indicated above. In such case, we will carefully assess whether there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.  


If you provide us personal information about others, you should make sure you have obtained their consent to do this. In such case, or if others give us your information, we will only use that information for the specific reason for which it was provided to us. 


Do we share personal information ? 


We will share your personal information with third parties only in the ways that are described in this privacy statement. We do not sell or trade any personal information about our visitors and users to any third parties. 


We may share personal information with vendors, consultants and other service providers (“Service Providers”) such as our data analytic processor who are engaged by or working with us in connection with the operation of the Service and who need access to such information to carry out their work for us. We provide access to the information they may need to perform our services under reasonable confidentiality terms. In some cases, the Service Provider may be directly collecting the information from you on our behalf. We inform Service Providers that they are not permitted to use personal information they obtain from us other than to provide the services for us. However, we are not responsible for any additional information you provide directly to these Service Providers and we encourage you to become familiar with their practices before disclosing any personal information directly to such Service Providers. 


We may allow third party partners to collect information from you directly in order to provide services to us, including surveys or marketing messages or providing analytic services.  


We may share information with companies in the same group of companies as Perfect World, which includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Policy. 


We see this processing as necessary for the purposes of the legitimate interests pursued by us, in line with art. 6.1.(f) of the GDPR. You have the right to object to this type of processing by contacting us as indicated above. In such case, we will carefully assess whether there are compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.  


We may access, disclose or preserve personal information, including the content of your communications, in the good faith belief that we are lawfully authorized by public authorities or required to do so, including to meet national security or law enforcement requirements or that doing so is reasonably necessary or appropriate to comply with the law or with legal process or authorities, respond to any claims, or to protect the rights, property or safety of Perfect World, our users, our employees or the public, including without limitation to protect Perfect World or our users from fraudulent, abusive, inappropriate or unlawful use of our Service. Information we collect, including personal information, may also be disclosed or transferred as part of, or during negotiations of, any merger, sale, divestiture, or transfer of all or a portion of the company assets, financing or acquisition or in any other situation where personal information may be transferred as one of the business assets of Perfect World. You will be notified via email and/or a prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We may also disclose your personal information to any other third party with your prior consent.

 
You understand that when you use the community features of our Service, information you post in public or private groups, forums, and other interactive areas of the Service, as well as any information you share with individuals through the Service, will be available to other users and in some cases (such as when you post to a public area of the Service) may be publicly available. We recommend you be cautious in giving out personal information to others or sharing such information in public or private online forums. We are not responsible for the actions of any third parties with whom you share personal information. To request removal of your personal information from our community forums or other public areas, contact us. Even if you remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other users have copied or saved that information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. 


Please note that nothing herein restricts the sharing of aggregate information, which may be shared with third parties without your consent. 


International Transfer 


In order to be able to provide you our Service and to be able to choose a proper server for gaming, the information relating to your use of our games is transferred to companies in the same group of companies as Perfect World located in People’s Republic of China. 


Links to third party locations

 
Our Service may contain links to third party ad services. We do not control such services or their activities. Any personal information you provide on the linked pages is provided directly to that third party and is subject to that third party’s privacy policy. We are not responsible for the content or privacy and security practices and policies of websites to which we link. Links from our Service to third parties or to other sites are provided for your convenience only. We encourage you to learn about their privacy and security practices and policies before providing them with personal information. 


Game Updates 


When we update or “patch” any of our games or other software, we may utilize a patch routine to verify whether the most recent version is installed on your computer. If not, the most recent version may, with your consent, be pushed to your device. You can manage push notifications from your mobile device’s settings page for the relevant game and/or from the settings page within the relevant mobile game.. 
 
Push Notifications  


We may, with your consent, send push notifications to your mobile device to provide game updates and other relevant messages. You can manage push notifications from your mobile device’s settings page for the relevant game and/or from the settings page within the relevant mobile game.  


What steps do we take to protect personal information online ? 


Perfect World endeavours to take reasonable precaution to safeguard and secure the personal information we collect through the Service. We have put in place physical, electronic, and managerial procedures that are designed to prevent unauthorized access, loss, or misuse.  
In addition, we restrict internal access to personal information to employees who need the information to perform their duties. The unauthorized access or use of such information by an employee is prohibited and constitutes grounds for disciplinary action. Additionally, our information management systems are configured in such a way as to block or inhibit employees from accessing information that they have no authority to access. You should note that our Service Providers may be responsible for processing, handling or storing some of the personal information that we receive. They are not authorized to market to you independently. These Service Providers are contractually required to safeguard and secure the personal information they received from us. Although we strive to protect your personal information, you should be aware, however, that information sent over the Internet is not necessarily secure and may be intercepted or accessed by third parties. Therefore, we cannot guarantee the security of such information, and we are not responsible or liable for any such interception.  


What choices do you have regarding the use of your personal information ? 


Perfect World gives you certain options to control the collection, use, and disclosure of your personal information. We will ask for your consent before sharing your personal information with third parties in ways not covered by this Policy (including any use for direct marketing purposes). 
Please refer to your browser’s or mobile device’s technical information for instructions on how to delete and disable cookies, and other tracking/recording tools. Depending on your type of browser or mobile device, it may not be possible to delete or disable tracking mechanisms. Note that disabling cookies and/or other tracking tools prevents our business partners from tracking your browser’s activities in relation to the Service, and for use in targeted advertising activities by third parties. If you would like more information about cookies and targeted advertisements or to opt out of having this information used by companies that are part of the Network Advertising Initiative, please visit www.networkadvertising.org/choices. 


Children’s Privacy 


Children under the age of 13 are not eligible to use our Service. The Services are not directed to children under 13. If we discover that we have inadvertently collected information from children under 13, we will delete the child’s information from our systems as soon as possible. If you become aware that personal information about a person under 13 has been provided to us, please immediately contact us.

 
If you are under age 18, do not provide any personal information unless you have first obtained your parent’s or guardian’s permission. 


How to review, update, correct, or delete personal information

 
Upon request Perfect World will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please  contact us. 


Under the conditions provided for by applicable law, you have the right to request from us access to and rectification or erasure of personal information or restriction of processing or to object to processing as well as the right to data portability, please contact us. 


Please note that certain types of personal information that is necessary to check eligibility, such as birth date or age, cannot be deleted unless you close your Account. However, such information may be modified with sufficient verification of the new information. Note that the deletion of your data may lead to the termination of your account and applicable services. 


To have access to your personal information, you must provide sufficient proof of identification as we request, and we reserve the right to deny access to any user if we believe there is a question about your identity. We will respond to all access requests within 30 days.

 
Moreover, we reserve the right to retain your information in our files if we believe it is necessary or advisable to resolve disputes, enforce the Terms of Service, and for technical and legal requirements and constraints related to the Service. 


Where processing is based on your consent, you have the right to withdraw consent at any time. Furthermore, you have the right to lodge a complaint with the supervisory authority. 


Data storage 


Your personal data collected according to this Privacy Policy will be held for as long as your account remains active, or until the Games’ Service expires. 


Security 


The security of your personal information is important to us. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL). 
We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Service, you can contact us. 


General Data Protection Regulation 


When you are in the European Union, the European Regulation (EU) 2016/679, also referred to as the “General Data Protection Regulation” or “GDPR”, applies to the collection and processing of your personal data by Perfect World.  
Perfect World is a French based company and our servers and main business operations are located primarily in China. In order to be able to also use your account on our Website and in our Service and to be able to choose a server located in the United States or in Europe for the Games or our Services, the information relating to your account and use of our Games is transferred between Perfect World Entertainment, Inc. located in the United States and Perfect World Europe B.V. located in The Netherlands. 


By using our Service and providing us with information, you are consenting to the transferring, storing and processing of your information on computers located in China in the manner described in this Policy.  You acknowledge and understand that the laws regarding personal information in China may be less stringent than the laws of your country and may not offer the same protections or rights as those laws. If you object to your personal information being transferred or used as described in this Policy, please do not use this Service. 


If you have any thoughts or questions about this Privacy Policy, you may contact us. 
 
Perfect World’s representative for GDPR purposes in the European Union is Perfect World Europe B.V., with registered address in NL-1096 CJ Amsterdam, Joan Muyskenweg 22-4, The Netherlands, with corporate identification number 24484242.  


Contact Us 


If you have any questions, concerns, or comments regarding this Policy, please contact us via email at privacy@magicdesignstudios.com