Privacy Policy
Updated: November 22, 2023
Super Drawl Studio LTD (“company”, “we”, “us” or “our”) respect our users’ privacy, and take personal information seriously. This Privacy Policy explains our data practices for the software, services, and websites (collectively the "Services") that we offer to our users.
This Privacy Policy is incorporated into, and is part of, our Terms and Conditions, which govern your access to the site and your use of the Site and/or Services. Unless otherwise defined herein, capitalized terms shall have the meaning assigned to such terms in the Terms and Conditions.
As defined in GDPR (General Data Protection Rights) of the European Union and Council, the company is a data controller (i.e., the company that is responsible for, and controls the processing of your personal data).
By accessing any part of our Site or using any of the Services, you agree to be bound by this Policy. This Policy does not govern information we receive from third parties. If you do not agree to the terms of this Policy, please do not use the Site, or any of our Services. Each time you use any Sites or Services, the current version of this Privacy Policy will apply. Accordingly, when you use any Sites or Services, you should check the date of this Policy (which appears at the top) and review any changes since you last reviewed the Policy.
1. Who We Are
We are Super Drawl Studio LTD ("company," “we,” “us” and “our”), a leading developer, publisher and marketer of interactive entertainment. In this Privacy Policy, the company is the data controller and responsible for information for Services offered by.
2. Information We Collect
You provide us with information directly, such as when you set up an account with us. We also collect information about you and your activity when you use our Services – whether through devices, computers, mobile devices, in-game applications, software platforms, third party social or gaming networks. We may use online tracking, such as cookies and similar technology, to collect information, when you share in-game content with friends, or connect to our Services, and we collect information from third parties (such as advertising networks and external business partners).
The types of information that we collect depend on how you use the Services and interact with us. You can control the personal information we collect from you unless we need it for the requested activity (e.g., to provide the Services you’ve requested or purchased, to confirm who you are, or to participate in an event). We will let you know when information is necessary.
Information You Provide
You provide us with information when you use the Services, such as when you:
·create an account, or register for or use the Services;
·subscribe to newsletters and communications;
·comment on our message boards, forums, chat rooms, feeds, sites, or other Services;
·purchase or redeem one of our products or services, including physical items, virtual items, virtual currency, or add-ons;
·download, install, or access demos, programs, or other software;
·contact us for support or other purposes;
·use our email / share features;
·participate in events, contests, promotions, or surveys; or
·participate in an activity where you can provide, or need to provide, your information.
·Depending on the Service or your activity, we collect information such as your name, email address, phone number, photo, mailing address / zip code, payment or purchase information, age, gender, hardware configuration, console ID, software products played, survey data, IP address, geolocation, and the systems you play on. We combine this information across computers or other devices that you use.
3. Purposes for which we will use your personal information
Below is a chart of some of the common ways in which we process your personal information. We have identified what our legitimate interests are where appropriate. Note that we may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground, we are relying on to process your personal information where more than one ground has been set out in the table below.
|
Purpose/Activity |
Type of data (varies depending on circumstances) |
Lawful basis for processing including basis of legitimate interest |
|
To register you as a user of our Services. |
Contact Information Account Information |
Performance of a contract with you. |
|
Notifying you about changes to our terms or Privacy Policy. |
Contact Information |
Necessary to comply with a legal obligation |
|
To enable you to participate in a game, contest, competition, survey, or similar event. |
Identifiers Contact Information Technical Information Usage Information |
Performance of a contract with you. Legitimate Interests (to learn how our users use our Services, to improve our Services, to grow our business). |
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data). |
Identifiers Contact Information Technical Information Usage Information |
Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) |
|
To provide you with information and marketing communications about our products and services. |
Identifiers Contact Information Marketing and Communications Information |
Consent Legitimate Interests (in marketing goods or services in which you may have a personal interest based on our ongoing business relationship). |
|
To provide you with third party offers that may be relevant to you. |
Identifiers Contact Information Marketing and Communications Information |
Consent |
|
To respond to customer service requests including order status and chat communications. |
Identifiers Contact Information Technical Information |
Legitimate Interest (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) Consent |
4. OUR LAWFUL BASES FOR PROCESSING
We collect, use, and otherwise process your information when we have a lawful basis, as follows:
Consent: We ask you for consent to collect or use your personal information for specific purposes, such as when we want to send you emails about special offers or competitions, or if you decide to link your account with a third-party service.
Contract Performance: We process your personal information when we need to perform and manage a contract with you, such as our Terms of Service, or to take steps at your request before we contract with you, such as to complete transactions with you and to allow you to play our games online.
Legal Requirement: We process your personal information when required by law.
Legitimate Interest: We process your personal information when necessary for our, or others', legitimate interests and when these interests do not outweigh your own rights and interests. This covers processing for purposes such as improving our products and services; performing analytics and using surveys to better understand our users; conducting direct marketing (when we do not need your consent); otherwise supporting our business, operations, and services; ensuring the proper function, security, and integrity of our services; dealing with user questions; enforcing our Terms of Service and EULA; preventing fraud; preventing illegal activity; preventing violations of our EULA, Terms of Service, Code of Conduct, or other policies; and preventing intellectual property right infringement.
5. Data Storage and Transfer
Your information collected through our Service may be stored and processed in the United States or any other country in which we or our affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including your Personal Information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and we will take all steps reasonably necessary to ensure that any Personal Information are treated securely and in accordance with this Privacy Policy and applicable law. Such transfers are made pursuant to appropriate safeguards as provided by applicable law. If you wish to enquire further about these transfers, please contact us using the details set out at the end of this Privacy Policy.
For individuals based in the EU or Switzerland, we store personal data for as long as necessary to fulfill the purposes for which we collect the data (see above under “Categories of Information We Collect”), except if otherwise required by law.
6. Data Security
We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorized way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal information on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal information breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Data Retention
We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. In some circumstances you can ask us to delete your data (see “EU Data Subjects Legal Rights”). In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
8. Children’s Policy
Generally, we direct our Services to a general audience and we do not knowingly collect personal information from children under 13 years old (or older, if applicable law provides for different protections). We may direct certain Services to an audience of all ages—including children. For these Services, we may restrict the collection of personal information on the Services from anyone, apply an age gate allowing children to use the Services while restricting the collection of personal information on the Services from children, or get a parent’s permission to collect personal information from children. If we become aware that a child has provided personal information without a parent’s permission, we will promptly delete this information. We encourage parents to instruct their children to never give out their real names, addresses, or phone numbers, without permission, when using the Internet.
9. EU Data Subjects Privacy Rights
EU data subjects have certain rights with respect to your personal information that we collect and process. We respond to all requests we receive from individuals in the EEA wishing to exercise their data protection rights in accordance with applicable data protection laws.
Access, Correction or Deletion. You may request access to, correction of, or deletion of your personal information. You can often go directly into the Service under Account Settings to take these actions. Please note that even if you request for your personal information to be deleted, certain aspects may be retained for us to: meet our legal or regulatory compliance (e.g. maintaining records of transactions you have made with us); exercise, establish or defend legal claims; and to protect against fraudulent or abusive activity on our Service. Data retained for these purposes will be handled as described in Section 9 “Data Retention”, above.
Objection. You may object to processing of your personal information where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Restriction. You have the right to ask us to suspend the processing of your personal information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Portability. You have the right to request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw Consent. If we have collected and processed your personal information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
File a complaint. You have the right to file a complaint with a supervisory authority about our collection and processing of your personal information.
To file a request or take action on one of your rights, please contact us at the contact details provided. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response. We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
10. Your California Privacy Rights (Under California Civil Code Section 1798.83)
California residents have the right to request and obtain from us, once a year and free of charge, a list of the third parties to whom we have disclosed certain types of personal information (if any) for their direct marketing purposes in the prior calendar year. At our option, we may respond to such requests by providing instructions about how our users can exercise their options to prevent our disclosure of personal information to third parties for their direct marketing purposes. You can read these instructions above in the “Marketing and Advertising Practices” section of our Privacy Policy. Or, if you are a California resident and prefer that we send you a separate response, please email your request to at this time, our Website does not respond to browser “Do Not Track” signals.
11. Disclosures of Your Personal Information
From time to time, we may need to share your personal information with others, including in the following circumstances.
Disclosures to the Public. Some of your personal information will be shared with the general public, including your first name and last name initial, avatar picture, city, state, country and other materials. When information is made publicly available it may be accessed by anyone with access to the platform to which the information is posted. It may also be indexed by third-party search engines, and be imported, exported, distributed, aggregated, and redistributed by others without our knowledge.
Third Party Service Providers. We may share your personal information with third party service providers who perform various functions to enable us to provide our services and help us operate our business, such as website design, sending email communications, fraud detection and prevention, customer care, payment processing, or performing analytics. Our contracts with these third parties require them to maintain the confidentiality of the personal information we provide to them, only act on our behalf and under our instructions, and not use personal information for purposes other than the product or service they’re providing to us or on our behalf.
With our Affiliates and Partners. When participating in events or activities that we offer along with our partners and/or affiliates, you may be asked to share personal information with those affiliates and/or partners. For example, a game, contest, competition, contest or other offering may be co-sponsored by another company or companies. In such a situation, the information we obtain from you in connection with such contest or offering may be shared with our co-sponsor, unless you instruct us not to (which may result in you not being able to participate). In some of those cases, we may act as co-controllers of your personal information, depending on the circumstances.
With Unaffiliated Controllers. In some cases, we may transfer personal information to unaffiliated third-party data controllers. These third parties do not act as agents or service providers and are not performing functions on our behalf. We may transfer your personal information to third-party data controllers for the following purposes: 1) to provide you with third-party offers; 2) to provide us information about the quality of our services offerings. We will only provide your personal information to third-party data controllers where you have not opted-out of such disclosures, or in the case of sensitive personal information, where you have opted-in if the disclosure requires consent. We enter into written contracts with any unaffiliated third-party data controllers requiring them to provide the same level of protection for your personal information that is required of us. We also limit their use of your personal information so that it is consistent with any consent you have provided and with the notices you have received.
Protection and Others. We may share personal information when we believe it is appropriate to enforce or apply our Terms of Service and other agreements; or protect the rights, property, or safety of our products and services, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and risk reduction. This does not include selling, renting, sharing, or otherwise disclosing personal information of our customers for commercial purposes in violation of the commitments set forth in this Privacy Policy.
Response to Subpoenas and Other Legal Requests. We may share your information with courts, law enforcement agencies, or other government bodies when we have a good faith belief we’re required or permitted to do so by law, including to meet national security or law enforcement requirements, to protect our company, or to respond to a court order, subpoena, search warrant, or other law enforcement request.
Sale of Our Business. If we sell, merge, or transfer any part of our business, we may be required to share your information. If so, you will be asked if you’d like to stop receiving promotional information following any change of control.
With your Consent. Other than as set out above, we will provide you with notice and the opportunity to choose when your personal information may be shared with other third parties.
12. Changes to our Privacy Policy
This Policy is expected to change from time to time. We reserve the right to amend this Privacy Policy at any time and provide notice to you by posting of the amended Privacy Policy on the website. We may also email you to give you notice of material changes to this Privacy Policy. The provisions contained herein supersede all previous notices or statements regarding our privacy practices and the terms and conditions that govern the use of this Services.
13. Contact us
If you have any questions or wish to register a complaint in relation to this Privacy Policy or the manner in which your personal information is used by us, please contact us by any of the following means:
Super Drawl Studio LTD
362 Nguyou Castle Peak Road, Sham Shui Po District, Hong Kong