Privacy Policy
Thank you for using the games provided by Xfire Games Pte. Ltd. (" Xfire " "we" or "us" or "our"). We greatly recognizes and values the privacy of your personal information and will do our utmost to protect the security of your personal information.
1. Introduction
1.1 This Privacy Policy (“Policy”) sets out the basis which Xfire may collect, use, disclose or otherwise process personal data of our users in accordance with the Applicable privacy laws and regulations (“Privacy Laws”). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organizations which we have engaged to collect, use, disclose or process personal data for our purposes.
1.2 To the extent permitted by applicable law, children under the age of 13 (or other age threshold required by local laws) are not allowed to create any Xfire Account (“Account”) for the Xfire Services. If you are 13 above but are considered a minor in your country (e.g. under 18 years old in some jurisdictions), you must have your parent or legal guardian read through this Privacy Policy with you and you represent that you have obtained the permission of your parent or guardian to create your Account.
1.3 If you are a parent or legal guardian of a minor in your country, please make sure that you have read this Privacy Policy before allowing your children to create their own accounts or to use the Services. You agree that you will be subject to this Privacy Policy and be responsible for your children ’ s activities while using the Xfire Services. You agree to supervise your children’s use of the Xfire Services and make sure that your children only view the contents that are age appropriate to your children.
1.4 In the event of a merger, acquisition, reorganization, bankruptcy or other similar events, your personal data may be transferred to the successor, we will endeavor to make an announcement in advance, disclose the details of the event and information about the successor, and request the successor to process your personal data in accordance with this Privacy Policy as well. In case the successor needs to process your personal data beyond the scope authorized in this Privacy Policy, the successor will be responsible for notifying you of details about their intended processing of your personal data and obtaining the consent of you and/or your parent and/or guardian (if applicable) again if required by applicable laws and regulations.
1.5 This Privacy Policy informs you of the following information:
(1) What personal information we process and collect
(2) Why we collect and process your personal information
(3) Cookies and similar technologies
(4) Who may access your personal data
(5) Data Retention
(6) Your Rights
(7) Protection of personal data
(8) Information about children
(9) Transfers of personal data outside of Singapore
(10) Changes
(11) Choice of law
(12) Contact and complaints
2. What personal information we process and collect
Personal data means any information relating to an identified or identifiable natural person, such as full name, email address, contact address, postal code, position data, title, occupation, personal interests, etc.
2.1 Account Registration Information: When you create the Account, we may collect your username, email address, password, verification code and character ID, to help you create and manage the account for your use of our services, to provide game login services .
2.2 Personal Profile Data: You have the option to create personalized profiles (where applicable) in our Services by selecting a nickname, crafting a personal signature, uploading an avatar, and providing other relevant details based on our service setup.
2.3 Connected Social Media Account Information (Third Party) : If you choose to log in to our services via your social media account(s), in order to better serve you with games, we will get information via the third party account (including the third party account number, username, nickname, email address and other information authorized by you) in accordance with your authorization. If you refuse to authorize such information, you will not be able to log in to our game services using your account on the third party platform, but this will not affect the normal use of other products and services provided by us. You can check up and manage the authorization of the above information in the third party account platform. You can also choose to fill in gender, region and other information to improve your Xfire account information depending on the game .
2.4 Game Data : We collect information about your in-game experience points, game progress, your level, score, and user statistics, and other similar data generated while using our Services. This information helps us understand your gaming preferences, provide personalized feedback, and enhance your overall experience with our Services.
2.5 Chat Data : If you use the chat function in our S ervices (e.g. the in-game chat), we may process the communication record.
2.6 IP Address, Location Information, and related Device Information: We collect information like IP address, location data such as geographical location, network status information, and device information such as device ID, device name, device type/model, MAC address, IMEI data, CPU data, graphics card model, OS version and language, time zone, screen DPI, device resolution, memory data, and graphics card model. Additionally, we gather information related to bugs, errors, crashes, and diagnostics, including registration/login time, game version, stack trace, crash reports, and abnormal process data to better understand your device, usage patterns, and location.
2.7 Payment D ata : If you choose to make purchase(s) with your Account, we may need to collect your payment data in order to process your purchase(s) and related activity .
2.8 User Service Information : When you seek our technical and/or customer service support and/or exercise any of your legal rights as the data subject, we may collect the information that you provide in communications with our support team.
2.9 Advertising Information : Advertising ID and select device information, we store the Advertising ID for that advertisement and the other device information with your profile to track the success of our advertising and marketing programs. Besides, after taking appropriate technical security measures (such as encryption and hashing) to de-identify your email address, including email address collected from third party social media providers when you log in via your social media account(s), we may use your de-identified email address to track the success of our advertising and marketing programs.
2.10 Activity Participation Information : If you agree to participate in any activities organized by us (such as sweepstakes), we may collect your participation information including your name, UID, email address, mobile phone number, nickname, country/region. Where you win any prizes, you may also need to provide us your mailing address for us to send you the prize. Your activity participation information may be added to your account.
2.11 Survey Information : We will collect your survey responses, if you participate in our surveys.
2.12 Security-Related Information: We collect, and process data related to the security of your account and our Services, such as password changes and login history, to ensure the safety and integrity of our platform .
2.13 Anti-Cheating and Fraud Detection: We may collect certain data and utilize various methods to detect and analyse instances of cheating or fraud within the Services. These methods include but are not limited to monitoring the presence of external programs that may affect the Services, identifying attempts by external programs or plugins to access the Services, and other similar techniques aimed at ensuring the integrity of gameplay. The collected data is used solely for the purpose of detecting and preventing cheating and fraud, with the objective of providing a fair gaming experience for all users .
2.14 Other Information Subject to Specific Notice : For some websites, apps, or services provided by us, we may collect additional information beyond the above listed information. We will develop individual privacy notices to inform you how we process your personal data when you use the specific services. Such individual privacy notices will prevail in terms of the personal data processed for such individual services.
3. Why we collect and process your personal information
In order to provide Xfire Services to you, we collect and process your personal data for one or multiple purposes including to:
3.1 help you create Account and enable you to manage your Account and maintain your personal profile;
3.2 to facilitate your use of various Services with your Account;
3.3 allow you to access or restrict your access to the Xfire Services;
3.4 provide you the services required by you and perform our contractual obligations towards you;
3.5 analyze and manage Xfire Services for system administration, user service, security, fraud-detection, check the authenticity of an account owner, archival and/or backup purposes;
3.6 correct bugs or errors, improve our services and respond to customer desires and preferences;
3.7 verify and confirm payment;
3.8 provide you offers on or through the Xfire Services and deliver advertising that may be relevant to your interests;
3.9 keep you up to date on the latest product announcements, notify special events and offer other data pertaining to our Services;
3.10 fulfill our obligations under applicable laws and regulations, respond to requests of government authorities;
3.11 establish, exercise or defend legal claims;
3.12 analyze, profile, segment, merge and/or update all collected data (regardless of an aggregated or individualized manner) for the purposes of improving service quality and providing a better experience;
3.13 protect the integrity, information safety, and financial security of our services or our users, comply with legal obligations, and enforce compliance with the Terms of Service or other restrictions placed on your use of the Xfire Services;
3.14 track your process across our websites and applications to verify that you are not a bot and to optimize our services;
3.15 for any other purposes for which we provide specific notice at the time the information is collected.
3.16 for the purposes set forth above, our affiliates may be commissioned to process your information, provided that such affiliates comply with terms in this Privacy Policy. Affiliate in this Privacy Policy shall mean an entity that directly or indirectly controls, is controlled by or is under common control with Xfire .
4. Cookies and Similar Technologies
4.1 In order to measure the effectiveness of our services, we may use cookies, which are small text files for added functionality or for tracking site usage. We may use cookies and/or authorize a third-party’s tracking-utility, from time to time, (a) to log your IP address in determining the path that users take on our sites and identifying repeated users of our sites, (b) to collect the websites or sources that linked or referred you to our services, and/or (c) to collect technical data about the devices and software you use to access our services, the operating system of your devices, and other similar technical data. If you do not wish to accept cookies or want to be notified of when they are placed, you may set your web browser to do so, if your browser permits.
4.2 We use the cookies, web beacons and similar technologies to personalize your experiences on our services and for various other purposes, including:
(1) remembering you: cookies, web beacons and similar technologies help us identify you as a registered user and keep the preferences or data that you have previously provided;
(2) analyzing how you use our services: cookies, web beacons and similar technologies help us understand what visitors (including users) are doing on our services, or what pages or sections are most popular;
(3) deliver advertising: cookies, web beacons and similar technologies help us provide you with advertising that we believe is relevant to you or of interest to you, on the basis of the data you provide; and/or
(4) other related functions or purposes mentioned in Article 3 herein.
4.3 We or our authorized contractors may use cookies and similar technologies to provide and personalize services, prevent fraud and fulfil other purposes mentioned above. Please note you may be able to disable cookies in your browser settings, but if you do so some parts of our services may then not function properly.
5. Who May Access Your Personal Data
In addition to Xfire and/or its affiliates, other parties may also access your personal data in the following situations. You acknowledge that you have foreseen the occurrence of such disclosure when you provide your personal data.
5.1 Other In-Game Users of Our Services
Other users may, for example, in a group challenge, access your in-game activities in the process of such group challenge. Other users may also see your displayed data and read the messages you have posted on or through our services. You acknowledge and agree that our services may also include message boards, communities, forums, and/or other chat areas, where users may exchange ideas or communicate with other users, and that any data you post to any communication area is publicly viewable. We strongly recommend that all users avoid posting personal or sensitive data at any time on or through our services.
5.2 Competent Authorities
We may provide a certain portion of your personal data to governmental authorities as so requested according to applicable laws and regulations. Besides, we may disclose certain portion of your personal data within a strictly limited scope of recipients when we reasonably think it is necessary to protect us, our users or a portion of the public.
In addition to be required by applicable laws and regulations, we reserve the right to disclose your personal data in the cases if we, in our good faith, believe that disclosing such data is necessary to identify, contact, or bring legal action against you, if we reasonably believe that (a) you are violating any other agreement(s) between you and us, such as the Terms of Service, this Privacy Policy or otherwise damage us; (b) you are infringing third-parties ’ rights and interests (including but not limited to intellectual property rights); and/or (c) it is necessary to prevent fraud or other illegal activities.
5.3 Third-Party Vendors
(1) Xfire may work with the following types of third parties on or through our services to help us provide services and functionalities to you:
i. Social networking portals who provide login and/or content-sharing service to and in our services;
ii. Logistics service providers who provide shipping services such as delivering physical prizes to users;
iii. Information communication service providers who provide SMS-messaging services;
iv. Payment service providers who provide payment services, such as assisting our services to run on, facilitating users’ payment, and maintaining a record of the users’ transaction history;
v. Advertising service contractors who provide marketing and advertising activities, including showing you ads that we think may interest you, conducting the programs, tracking the success, and analyzing the effect thereof; and
vi. Other contractors if any for the purpose of providing our services to you.
(2) Besides, such contractors may use cookies, web beacons, and/or other tracking technologies to collect or receive data about you. For example, users purchasing and/or subscribing products or services will be required to provide additional data to third-party payment contractors, such as a valid credit card number and expiration date. Such third-party payment contractors may collect, process and retain your data to process payments and resolve subsequent payment disputes and inquiries. We may also receive, process and store the provided information from you and/or such third-party payment contractors to confirm payment, record purchase history and/or protect our legitimate interest when resolving subsequent payment disputes and inquiries.
(3) When specific third parties are involved in collecting data and information, please refer directly to their privacy policies on their official websites and learn more about their data processing practices.
(4) We may also disclose your information with your permission.
6. Data Retention
6.1 We will keep your data for as long as your Account is active or only for as needed to provide you the Xfire Services unless deletion is carried out in accordance with your request or as otherwise required by law. The location of servers for our servic es is Singapore.
You acknowledge and agree that your data will be processed on our servers which may not be located in your country/region of residence and can be accessed by our support, engineering and/or our affiliates around the world. No matter where our servers are located, we will make efforts to take the appropriate safeguards to guarantee your rights in conformity with this Privacy Policy and any applicable laws and regulations.
6.2 In the case you request to remove or delete your personal data, we will retain your data as long as necessary for applicable laws and regulations, such as to comply with our legal obligations, resolve disputes, and/or enforce the agreements between you and us. Please note that the removal or deletion of any of your data may result in the termination of some of our applicable services.
6.3 Where required by law, we will only store your information as long as necessary to fulfill the purposes for which the information is collected and processed or where the applicable laws and regulations provide for longer storage and retention period. Upon the expiration of such period, your personal data will be deleted, blocked or anonymized, as provided by and in accordance with applicable laws and regulations.
7. Your Rights
Subject to the applicable laws and regulations, you may have the following data protection rights as a user of our services. You also have the right to complain to the local authorities. To exercise any applicable rights below or to exercise any other statutory data subject rights you may enjoy under applicable laws and regulations, you may contact us using the contact details under the "Contact and Complaint" heading below.
To protect the security of your Account and your personal data, we may ask you to provide certain additional information to verify your identity before we respond to your requests. Under some circumstances, we may refuse to comply with your request as permitted by applicable laws and regulations. We may also charge a reasonable fee for complying with your request in accordance with applicable law, e.g. if your request is clearly repetitive or excessive.
7.1 Right to Know about Personal Data Collected or Disclosed
You may have the right to access your personal data that we hold about you, i.e.: (i) information whether your personal data is collected or disclosed, (ii) categories of your personal data which has been collected or disclosed, (iii) categories of sources from which your personal data is collected, (iv) business or commercial purpose for collecting or disclosing your personal data (if any); and you have the right to require us to provide a duplicate of your personal data undergoing processing, subject to submitting a verifiable request to us using the contact information in section "Contact and Complaint" below.
7.2 Right to Rectify
If we process your personal data, we shall endeavor to ensure by implementing suitable measures that your personal data is accurate and up-to-date for the purposes for which it was collected. If your personal data is inaccurate or incomplete, you have the right to request for rectification of your inaccurate personal data according to applicable laws and regulations and you can modify the information through in-game settings or contact customer service to deal with.
7.3 Right to Request Deletion of Personal Data
You may have the right to request the deletion of your personal data, if the reason as stated in Article 3 of this Privacy Policy does not exist anymore or if there is another legal ground for its deletion, subject to submitting a verifiable request to the contact details under the "Contact and Complaint" below.
You acknowledge and agree that as a result of deleting your Account, you will lose access to game-related services, including the Account information, subscriptions and game-related information linked to such Account and lose the possibility to access other services through the Account.
7.4 Right to Opt-out of Marketing Communications
You can exercise this right by clicking on the "unsubscribe" or "opt-out" link in the marketing messages we send you.
7.5 Right to Complain
You may have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
7.6 Right to Withdraw Your Consent
If we have collected and processed your personal data with your consent, then 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 the processing of your personal data conducted in reliance on lawful processing grounds other than consent. In many circumstances, we need to use your personal data in order for us to provide you with our services which you require. If you do not provide us with the required personal data, or if you withdraw your consent to our use and/or disclosure of your personal data for these purposes, it may not be possible for us to continue to serve you or provide you with the services that you require.
8. Protection of Personal Data
8.1 To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as minimized collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, etc.
8.2 You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
9. Information About Children
9.1 This service is not targeted at children under the age of 13. We do not knowingly collect or maintain personal data or non-personally identifiable information about any person under the age of 13, nor is any part of our website, games or other services targeted at them.
9.2 As a parent or legal guardian, please do not allow any child in your care to submit personal data to us.
9.3 If personal data of a child under the age of 13 in your care is disclosed to us, you hereby consent to the processing of the child's personal data and accept and agree to be bound by the terms of this Policy on behalf of the child.
9.4 If you do not in fact consent to the processing of personal data of a child under the age of 13 in your care, please contact our Data Protection Officer. We will close any account used exclusively by such a child and delete and/or delete any personal data submitted by such a child without parental consent, or as otherwise required by applicable law.
10. Transfers of Personal Data Outside of Singapore
10.1 You understand and agree that we may transfer your personal data outside of Singapore for the purpose of providing services to you and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the Personal Data Protection Act (“PDPA”).
11. Changes
If we make any material changes to this Privacy Policy we will post the updated Privacy Policy here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy.
12. Choice of Law
This policy and any action related thereto will be governed by the laws of Singapore without regard to its conflict of law’s provisions. Any dispute arising out of or in connection with this Agreement, including any question regarding its existence, validity, or termination, shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre (“SIAC”) in accordance with the Arbitration Rules of the Singapore International Arbitration Centre ("SIAC Rules") for the time being in force, which rules are deemed to be incorporated by reference in this clause. The seat of the arbitration shall be Singapore. The Tribunal shall consist of 3 arbitrator(s). The language of the arbitration shall be English.
13. Contact and complaints
You may contact us if you have any enquiries or feedback on our personal data protection Policy and procedures, or if you wish to make any request, in the following manner:
Name: Data Protect Officer
Email Address: support@xfire.games
Effective date : 2023 - 09- 01
Xfire Games Pte. Ltd.