Privacy Policy

Last Updated: September 17, 2026

Effective Date:September 17, 2026

Welcome to Mini Wild: Survival, and thank you for playing our game.

This Privacy Policy is designed to provide clarity about how Arclight Network Technology Limited ("the Company," "we," "us," or "our") collects, uses, discloses, stores, shares, transfers, and otherwise processes your personal information, as well as how you may exercise your privacy rights, where applicable.

This Privacy Policy applies whenever you play Mini Wild: Survival; access our related products, services, content, websites, customer support channels, communities, events, marketing activities, or other digital properties that link to this Privacy Policy; or otherwise use any of our related services (collectively, the "Services").

In this Privacy Policy, "Company" refers to Arclight Network Technology Limited and its Affiliates. "Affiliates" means our subsidiaries, parent companies, and other corporate entities under common ownership or control with the Company.

By using the Services, you agree to the collection, disclosure, storage, and use of your information as described in this Privacy Policy. If you do not want us to collect, store, use, or disclose your information in the ways described in this Privacy Policy, you should not access or use the Services.

This Privacy Policy applies to players worldwide. Supplemental sections below provide additional information for users in specific regions where additional legal requirements may apply, including the Kingdom of Saudi Arabia, the United Arab Emirates, Türkiye, and certain U.S. states.

If we make material changes to this Privacy Policy, we will notify you by updating the "Last Updated" date and posting the updated Privacy Policy on the Services or by other appropriate means, as required by applicable law.

1. WHO WE ARE

Arclight Network Technology Limited is the controller / data controller of the personal information processed under this Privacy Policy.

If you have questions about this Privacy Policy or our privacy practices, you may contact us at [email protected].

2. SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to Mini Wild: Survival and the related services operated by the Company that link to this Privacy Policy, including without limitation:

• related websites and web-based services;
• customer support channels;
• community features, events, and promotions; and
• other digital services that refer or link to this Privacy Policy.

This Privacy Policy does not apply to third-party websites, apps, platforms, or services that are linked to from, integrated with, or otherwise made available through our Services, unless they expressly state that they are governed by this Privacy Policy. Those third parties operate under their own terms and privacy policies, and we are not responsible for their privacy practices.

3. INFORMATION WE COLLECT

We may collect the following categories of information depending on the Services you use, the features you access, your device, your location, and your interactions with us.

3.1 Information You Provide to Us

You may provide us with information directly, including:

• Account information, such as your in-game username, user ID, and password, where applicable.
• Contact information, such as your email address.
• Profile information, such as your display name, linked social media or social networking service ("SNS") account identifiers, age range, gender, profile image, or other profile details you choose to provide.
• Communications and support information, such as support tickets, emails, chat messages sent to customer support, survey responses, feedback, or reports.
• User-generated content, such as profile images, community posts, messages, alliance/guild content, or other content you create or upload within the Services.
• Transaction-related information, such as records of your in-app purchases, order confirmations, item names, purchase dates, and transaction identifiers.
• Voice data, if you choose to use voice-chat or other voice-related features and grant the relevant permissions.
• Additional information you choose to provide to us in connection with customer support, account recovery, dispute handling, or other requests, such as information used to verify or recover a lost account.

3.2 Information We Collect Automatically

When you access or use the Services, we may automatically collect certain information from you and/or your device, including:

• Device and technical information, such as device identifiers, IP address (which may allow us to infer your approximate geographic area or country/region, but does not reveal your precise location), device type, operating system, device language, network and carrier information, and application performance or debugging information.
• Service usage and gameplay information, such as details about the games and platforms you use, your interactions with the Services, in-game events, game version, gameplay progress, and the date and time of your activity.
• Advertising, attribution, and diagnostic information, such as advertising identifiers, install attribution data, crash reports, error logs, performance metrics, and other information used for analytics, fraud prevention, service stability, and troubleshooting.

3.3 Information We Receive from Third Parties

We may receive information about you from third parties, including:

• login or social platform providers, if you choose to sign in through or link a third-party account (for example, Google or Facebook), such as your public profile identifier, display name, or profile image;
• payment processors, app stores, and platform providers, such as transaction confirmations and order status;
• analytics, attribution, and advertising partners, such as aggregated attribution, campaign, and conversion information;
• customer support, fraud prevention, moderation, or other service providers that assist us in operating the Services.

3.4 Permissions and Device Features

Certain features may require access to device permissions or device features. Depending on the specific game build, platform, region, and feature set, we may request or use permissions or device features such as:

• internet and network access for core gameplay, resource downloads, service functionality, advertising, and communication with our servers;
• Wi-Fi and network connection information to check connection status and optimize network performance;
• notification permissions for service alerts, game updates, and event reminders;
• storage, media, photo, or file permissions for caching assets, downloading resources, uploading images, attaching screenshots for support, or saving game-related files;
• microphone or other audio-related permissions for voice-related features, where applicable;
• location permissions, including approximate or precise location, where enabled by the relevant game build or required for specific features, compliance, security, fraud prevention, regional availability, or service optimization;
• Bluetooth permissions for compatible audio accessories, where applicable;
• advertising identifier access and install referrer information for attribution, analytics, and advertising preferences;
• phone, device, or app status information to help identify device status, manage app behavior during calls or other device events, support compatibility, security, and service operation;
• vibration, wake-lock, and startup-related features for haptic feedback, gameplay continuity, scheduled reminders, service operation, and preventing important processes from being interrupted.

If you deny or disable certain permissions or device features, some features may not function properly, but the core Services may still remain available where applicable.

3.5 Publicly Visible Information

Some information you provide or generate through the Services may be visible to other users by design, such as your display name, avatar, leaderboard ranking, gameplay statistics, guild/alliance membership, and other similar in-game profile or gameplay information.

4. HOW WE USE YOUR INFORMATION

We may use your personal information for the following purposes, or as otherwise described at the time of collection:

4.1 Service Delivery, Operations and Account Management

We may use your information to:

• create, authenticate, and manage your account;
• provide, operate, maintain, and improve the Services;
• deliver gameplay features, multiplayer functionality, community tools, virtual items, and paid content;
• remember your devices, selections, preferences, and settings;
• establish and maintain your in-game profile;
• provide customer support and respond to your requests, questions, feedback, reports, or complaints;
• send service-related messages, such as account notices, technical notices, updates, security alerts, and administrative messages.

4.2 Improvement and Development

We may use your information to:

• analyze gameplay trends, usage patterns, and user interactions with the Services;
• troubleshoot bugs, crashes, and performance issues;
• improve features, balancing, content design, user experience, and service performance;
• conduct analytics, internal reporting, product testing, and A/B testing;
• develop new features, products, and services.

We may also create aggregated, de-identified, or anonymized data from personal information we collect by removing or modifying information that identifies you. We may use and share such aggregated, de-identified, or anonymized data for lawful business purposes, including analytics, service improvement, reporting, and business planning.

4.3 Marketing and Advertising

We may use your information to:

• send promotional messages, event information, and updates, where permitted by applicable law;
• provide marketing and advertising, including interest-based advertising where permitted and, where required, with your consent;
• measure the effectiveness of marketing campaigns and understand how users discover and interact with the Services.

You may opt out of marketing messages by using the unsubscribe option in the message, adjusting available in-game or device settings, or contacting us.

4.4 Safety, Security, Compliance and Anti-Fraud

We may use your information to:

• detect, investigate, and prevent cheating, fraud, abuse, cyberattacks, unauthorized access, and violations of our terms or policies;
• maintain the security, integrity, and fairness of the Services;
• audit our internal processes for compliance with legal, contractual, and policy requirements;
• comply with applicable laws, regulations, legal process, and lawful requests from public authorities;
• establish, exercise, or defend legal claims;
• protect the rights, privacy, safety, and property of the Company, our users, and others.

4.5 With Your Consent or for Further Uses

In some cases, we may ask for your consent to collect, use, or share your personal information, such as for surveys, certain marketing activities, or where required by applicable law.

If we need to use your personal information for a new purpose that is not compatible with the purpose for which it was originally collected, we will provide additional notice and, where required by applicable law, ask for your consent.

5. LEGAL BASES FOR PROCESSING

Where required by applicable law, we process personal information only where we have a valid legal basis, including:

• performance of a contract with you;
• compliance with a legal obligation;
• our legitimate interests, such as operating, improving, and securing the Services, provided those interests are not overridden by your rights;
• your consent, where required by applicable law.

Additional region-specific legal basis information is provided in the supplemental sections below where applicable.

6. HOW WE SHARE YOUR INFORMATION

We do not sell your personal information for monetary consideration. However, we may share your information in the following circumstances:

6.1 Service Providers

We may share your information with vendors and service providers that perform services on our behalf, such as cloud hosting, content delivery, analytics, crash reporting, customer support, moderation, fraud prevention, and communication services. These parties are authorized to process personal information only as necessary to provide services to us or on our behalf, and are subject to contractual and/or legal restrictions.

6.2 Payment Processors and Platform Providers

Transactions may be processed through third-party app stores, payment processors, and platform providers (such as Google Play or Apple App Store). We may receive transaction confirmations and related records, but we do not typically receive or store full payment card or bank account details.

6.3 Advertising, Analytics, and Attribution Partners

We may share device identifiers, advertising identifiers, and certain interaction data with analytics, attribution, and advertising partners to measure campaign performance, understand installs, prevent fraud, and, where permitted, support advertising and personalization.

6.4 Affiliates and Corporate Group

We may share information with our Affiliates (including parent companies, subsidiaries, and entities under common ownership or control) for internal business, operational, security, legal, compliance, and customer support purposes, consistent with this Privacy Policy.

6.5 Third Parties at Your Direction

We may share your information with third parties where you instruct us or provide your consent to do so, such as when you link your account with a third-party service or use a feature that involves third-party integration. The third party’s use of your information will be governed by its own privacy policy.

6.6 Legal, Safety, and Business Transfers

We may disclose information:

• when required by law, regulation, court order, or legal process;
• to respond to lawful requests from public authorities;
• to protect our rights, property, systems, users, or others;
• to investigate or prevent fraud, abuse, cheating, or security incidents;
• in connection with a merger, acquisition, reorganization, financing, or sale of assets.

If a business transfer occurs, we will take reasonable steps to require the recipient to handle your information in accordance with applicable law.

7. THIRD-PARTY SERVICES, SDKS, AND SIMILAR TECHNOLOGIES

Our Services may integrate third-party SDKs, APIs, platform services, and similar technologies to support the operation, security, analytics, advertising, payment, login, customer support, crash reporting, content delivery, and other functionality of the Services.

These third-party services may process certain personal information, such as device information, identifiers, advertising identifiers, usage data, diagnostic data, purchase-related information, or information you choose to provide through the relevant features. Depending on the nature of the service, they may process such information on our behalf or as independent controllers under their own privacy policies.

We use these services for purposes such as:

• login and authentication;
• payment processing and platform services;
• analytics, attribution, and performance monitoring;
• crash reporting and diagnostics;
• notifications and messaging;
• advertising, fraud prevention, and security;
• content delivery, resource management, and service operation.

Examples of major third-party SDKs or platform services that may be integrated into the Services include:

• Facebook SDK, for social login, sharing features, advertising, and analytics;
• Google Play Services, for platform services, authentication, advertising identifier access, and related Google services;
• Android Billing Client, for in-app purchase and billing processing;
• Firebase/Crashlytics, for analytics, remote configuration, push notifications, crash reporting, diagnostics, and app performance monitoring;
• Bugly, for crash reporting, error analysis, and app stability improvement;
• ThinkingSDK, for in-game analytics and user behavior analysis.

The actual integrations may vary depending on the game version, platform, region, and distribution channel.

Where you interact directly with a third-party platform or service, such as a login provider, app store, payment platform, or linked external service, your information may be processed by that third party in accordance with its own privacy practices.

We take reasonable steps to require that third-party service providers process personal information in accordance with applicable laws and contractual obligations, where applicable.

8. SENSITIVE PERSONAL INFORMATION

We do not generally collect sensitive personal information through ordinary gameplay.

In limited circumstances, we may process information that may be regarded as sensitive or subject to heightened protection under applicable law, for example:

• voice-chat data, only if you choose to use voice-related features and grant the relevant permissions;
• payment or transaction-related information, only to the extent such information is regarded as sensitive under applicable law and is necessary to confirm purchases, address payment issues, or comply with legal obligations;
• other information requiring heightened protection under applicable law, but only where necessary for a specific feature, security purpose, legal obligation, dispute handling, or where your consent is required and obtained.

We do not generally collect government-issued identification numbers, health data, or biometric identifiers for the ordinary operation of the game unless specifically stated in a feature notice, required by law, or voluntarily provided by you in the context of a support request, account recovery, dispute handling, or legal process. We do not generally collect precise geolocation for ordinary gameplay. If a specific feature, device permission, legal requirement, security purpose, fraud prevention purpose, regional service requirement, or service optimization purpose involves precise location data, we will process such information only as necessary and in accordance with applicable law.

Where applicable law requires additional notice, separate consent, or other safeguards for the processing of sensitive personal information, we will provide them.

9. DATA RETENTION

We retain personal information for as long as reasonably necessary for the purposes described in this Privacy Policy, unless a longer retention period is required or permitted by law.

As a general guide:

• account information: for the life of the account and for a limited period afterward as necessary for dispute handling, fraud prevention, and legal compliance;
• transaction records: for the period required by tax, accounting, payment, and legal obligations;
• gameplay, usage, and analytics data: for as long as needed for operational, product improvement, and security purposes, after which it may be deleted or anonymized;
• crash and diagnostic data: for as long as needed to identify, resolve, and analyze technical issues;
• customer support communications: for as long as reasonably necessary to handle the request, maintain service records, and protect legal rights.

When we no longer need personal information, we will delete it, anonymize it, or securely isolate it as permitted by law.

10. INTERNATIONAL DATA TRANSFERS

Because we operate globally, your personal information may be transferred to, stored in, or accessed from countries other than the country in which you reside, including countries that may have data protection laws different from those in your jurisdiction.

Where required by applicable law, we will implement appropriate safeguards for international data transfers, which may include:

• standard contractual clauses or equivalent transfer mechanisms;
• adequacy decisions where recognized;
• contractual protections with service providers and affiliates;
• other lawful transfer mechanisms permitted under applicable law.

You may contact us for more information about the safeguards relevant to transfers of your personal information.

11. SECURITY

We use reasonable technical, administrative, and organizational measures designed to protect personal information against unauthorized access, destruction, loss, alteration, disclosure, or misuse. These measures may include access controls, encryption in transit, logging, internal security procedures, and service-provider due diligence.

However, no system can be guaranteed to be completely secure. You are responsible for keeping your account credentials confidential and for contacting us promptly if you believe your account or personal information has been compromised.

If we become aware of a security incident involving your personal information, we will take appropriate steps to respond to the incident and, where required by applicable law, notify affected users and/or relevant authorities.

12. CHILDREN’S PRIVACY

The Services are not directed to children below the minimum age permitted under applicable law in their jurisdiction.

Where required by applicable law, users below the applicable minimum age may only use the Services with the consent or authorization of a parent or legal guardian.

Parents or legal guardians who believe that a child has provided us with personal information may contact us to request review, correction, or deletion of that information.

13. YOUR PRIVACY RIGHTS

Depending on where you live, you may have some or all of the following rights, subject to applicable law and certain exceptions:

• the right to know or be informed about how your personal information is processed;
• the right to access or obtain a copy of your personal information;
• the right to correct inaccurate or incomplete information;
• the right to request deletion of your personal information;
• the right to withdraw consent where processing is based on consent;
• the right to object to, or request restriction of, certain processing;
• the right to data portability, where applicable;
• the right to opt out of certain forms of targeted advertising, sale, or sharing, where applicable;
• the right to appeal a denied request, where applicable.

To exercise your rights, you may contact us at [email protected]. We may need to verify your identity before responding to your request.

14. ACCOUNT DELETION

If you have created an account for the Services, you may request deletion of your account and associated personal information through:

• the in-game path: Settings →  Account Management → Delete Account; or
• by contacting us at [email protected] with the subject line "Account Deletion Request."

Please include your game name, in-game username or user ID, email address, and any information reasonably necessary for us to locate your account and process your request.

Please note that we may retain certain information after account deletion where required or permitted by law, including for fraud prevention, security, dispute resolution, tax and accounting obligations, enforcement of our agreements, and compliance with legal obligations.

15. COOKIES, TRACKING, AND ADVERTISING CHOICES

Like most online services, we may use cookies and similar technologies on our websites or web-based services to help operate the Services, improve user experience, understand usage, measure campaign effectiveness, and prevent fraud. Cookies are small text files stored by your browser on your device. Most browsers accept cookies automatically, but you can change your browser settings to decline cookies. If you do so, some features may not function properly.

In our games and mobile applications, we and our partners may use advertising identifiers, SDKs, APIs, and similar technologies for analytics, attribution, fraud prevention, advertising, and service improvement, where permitted by applicable law. You may limit certain advertising or tracking through your device settings, available in-game privacy or ad settings, or by contacting us.

16. LINKS TO THIRD-PARTY SERVICES

The Services may contain links to third-party websites, games, platforms, or services. We do not control and are not responsible for the privacy practices, content, or security of those third parties. Please review the privacy policies of those third parties before providing any personal information.

17. CHANGES TO THIS PRIVACY POLICY

We may update this Privacy Policy from time to time to reflect changes in our business, technology, legal obligations, or data practices.

When we make material changes, we will take reasonable steps to notify you as required by applicable law, which may include posting the updated version on our website or within the Services, updating the "Last Updated" date above, and/or providing in-game or email notice where appropriate.

Your continued use of the Services after the effective date of the updated Privacy Policy means that you acknowledge the updated Privacy Policy to the extent permitted by law.

18. CONTACT US

If you have any questions, comments, complaints, or requests regarding this Privacy Policy or our privacy practices, you may contact us at [email protected].

19. SUPPLEMENTAL NOTICE FOR THE KINGDOM OF SAUDI ARABIA

This section applies to users in the Kingdom of Saudi Arabia and supplements the rest of this Privacy Policy in accordance with applicable Saudi data protection laws and regulations.

19.1 Legal Bases

We may process personal information where necessary for:

• performance of a contract;
• compliance with legal obligations;
• our legitimate interests, where permitted;
• your consent, where required.

19.2 Your Rights

Subject to applicable law, you may have rights including:

• the right to be informed;
• the right to access;
• the right to obtain a copy;
• the right to correction;
• the right to request destruction/deletion where applicable;
• the right to withdraw consent where processing is based on consent.

19.3 Cross-Border Transfers

Where personal information is transferred outside Saudi Arabia, we will implement safeguards and comply with applicable requirements under Saudi law.

19.4 Children and Guardians

If we become aware that a user is a child or otherwise lacks full legal capacity under applicable Saudi law, we will handle that user’s personal information in accordance with applicable legal requirements. A parent or legal guardian may contact us to exercise applicable privacy rights on behalf of that user, where permitted or required by law.

19.5 Contact

You may exercise your rights by contacting us at [email protected].

20. SUPPLEMENTAL NOTICE FOR THE UNITED ARAB EMIRATES

This section applies to users in the United Arab Emirates and supplements the rest of this Privacy Policy in accordance with applicable UAE data protection laws.

20.1 Legal Bases

We may process personal information where necessary for:

• performance of a contract;
• compliance with legal obligations;
• our legitimate interests, where permitted;
• your consent, where required.

20.2 Your Rights

Subject to applicable law, you may have rights including:

• access;
• correction;
• erasure;
• restriction of processing;
• objection in certain circumstances;
• data portability where applicable.

20.3 Cross-Border Transfers

Where personal information is transferred outside the UAE, we will take steps required by applicable law to ensure an appropriate level of protection.

20.4 Children under 13

For users in the United Arab Emirates, if we become aware that we have collected personal information from a child under the age of 13 without the consent or authorization required by applicable law, we will take appropriate steps in accordance with applicable legal requirements, which may include deleting the information or restricting its processing.

A parent or legal guardian may contact us to request review, correction, deletion, or restriction of the child’s personal information, where permitted or required by applicable law.

20.5 Contact

You may exercise your rights by contacting us at [email protected].

21. SUPPLEMENTAL NOTICE FOR USERS IN TÜRKIYE

This section applies to users in Türkiye and supplements the rest of this Privacy Policy in accordance with the Turkish Personal Data Protection Law No. 6698 ("KVKK").

21.1 Data Controller

Arclight Network Technology Limited is the data controller for the processing described in this Privacy Policy.

Where required or applicable, the Company may act through a local representative or contact point in Türkiye.

21.2 Information We Provide to You

In accordance with applicable Turkish data protection requirements, we inform users in Türkiye about:

- the identity of the data controller and, where applicable, its representative;

- the purposes for which personal data are processed;

- the categories of recipients to whom personal data may be transferred and the purposes of such transfer;

- the method and legal basis for collecting personal data; and

- the rights of the data subject under applicable law.

21.3 Your Rights

Subject to applicable law, you may have the right to request information about whether your personal data is processed, request access to your personal data, request correction of incomplete or inaccurate data, request deletion or destruction where the conditions are met, and request information about transfers to third parties.

21.4 Children and Minors

For users in Türkiye, if we become aware that a user is under the age of 18 or otherwise lacks full legal capacity under applicable Turkish law, we will process that user’s personal information in accordance with applicable legal requirements. A parent or legal guardian may contact us to exercise applicable privacy rights on behalf of that user, where permitted or required by law.

21.5 Contact

You may exercise your rights by contacting us at [email protected].

22. U.S. STATE PRIVACY RIGHTS NOTICE

This section applies to residents of U.S. states with applicable privacy laws, including California, Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, and other states to the extent their privacy laws apply to our processing of personal information (collectively, "U.S. State Privacy Laws").

This section describes how we collect, use, disclose, sell, or share personal information of U.S. residents, and the rights that may be available to them. Not all rights apply in all states, and certain exceptions may apply. We may deny or limit requests where permitted by applicable law, including where we cannot verify your identity or where an exception applies.

For purposes of this section, "personal information," "personal data," "sensitive personal information," "sensitive data," "sale," "sell," "share," "targeted advertising," and similar terms have the meanings given to them under the applicable U.S. State Privacy Laws.

22.1 Categories of Personal Information We Collect

Depending on how you use the Services, we may collect the following categories of personal information:

• Identifiers, such as user ID, in-game username, email address, IP address, device identifiers, advertising identifiers, and third-party account identifiers.
• Customer records information, such as contact information or account-related information you provide to us.
• Commercial information, such as in-app purchase history, transaction identifiers, order confirmations, item names, purchase dates, and related purchase information.
• Internet or other electronic network activity information, such as gameplay activity, log-in records, usage data, interaction data, advertising attribution data, crash logs, and diagnostic data.
• Geolocation information, such as country or region inferred from IP address or device settings, and precise location only where enabled by the relevant game build, device permission, or specific feature. We do not generally collect precise geolocation for ordinary gameplay.
• Audio or visual information, such as voice-chat data or profile images, only if you choose to use relevant features and grant the required permissions.
• Inferences, such as gameplay preferences or advertising segments derived from your use of the Services, where applicable.
• Sensitive personal information, only in limited circumstances as described in the "Sensitive Personal Information" section of this Privacy Policy.

We may also collect other information that you choose to provide to us, such as information submitted in support requests, surveys, account recovery requests, reports, or free-form communications.

22.2 Sources of Personal Information

We may collect personal information from:

• you directly;
• your device or your use of the Services;
• app stores, payment processors, and platform providers;
• login providers or social platforms, such as Facebook or Google Play Games;
• analytics, attribution, advertising, crash reporting, fraud prevention, and other service providers;
• our Affiliates and business partners, where applicable.

22.3 Purposes for Collection, Use, Disclosure, Sale, or Sharing

We may collect, use, and disclose personal information for the purposes described in this Privacy Policy, including:

• service delivery, account management, gameplay, purchases, and customer support;
• analytics, service improvement, product development, testing, and reporting;
• advertising, attribution, campaign measurement, and personalization where permitted;
• security, fraud prevention, anti-cheating, and abuse prevention;
• legal compliance, dispute handling, enforcement of our terms, and protection of rights;
• creation of aggregated, de-identified, or anonymized data.

Where applicable, we may sell or share personal information, or process personal information for targeted advertising, as described in Section 22.5.

22.4 Categories of Third Parties to Whom We Disclose Personal Information

We may disclose personal information to the following categories of third parties:

• service providers and contractors;
• app stores, payment processors, and platform providers;
• advertising, analytics, attribution, and measurement partners;
• login providers and linked third-party services;
• Affiliates and corporate group entities;
• professional advisors, such as lawyers, auditors, and accountants;
• government authorities, law enforcement, courts, and other parties where required or permitted by law;
• parties involved in a business transfer, such as a merger, acquisition, restructuring, financing, or sale of assets.

22.5 Sale, Sharing, and Targeted Advertising

We do not sell personal information for money. However, like many mobile game companies, we may use advertising, analytics, attribution, and measurement technologies that may be considered a "sale," "sharing," or "targeted advertising" under certain U.S. State Privacy Laws.

The categories of personal information that may be sold or shared, or processed for targeted advertising, may include:

• identifiers, such as advertising identifiers, device identifiers, IP address, and other online identifiers;
• internet or other electronic network activity information, such as usage data, interaction data, and attribution data;
• approximate geolocation, such as country or region;
• inferences, such as advertising segments or gameplay preferences, where applicable.

The categories of third parties to whom such information may be sold or shared, or with whom it may be processed for targeted advertising, may include advertising networks, analytics providers, attribution partners, and measurement partners.

You may opt out of the sale or sharing of your personal information, or processing for targeted advertising, by:

• adjusting your device privacy settings or resetting / limiting your advertising identifier;
• using available in-game privacy or ad settings, if such settings are made available in the Services;
• contacting us at [email protected] with the subject line "Privacy Request – Opt Out," and providing your game name, username, email address, and any information reasonably necessary for us to locate your account.

22.6 Sensitive Personal Information

We do not use or disclose sensitive personal information for purposes other than those permitted by applicable law. We do not use sensitive personal information to infer characteristics about you except as permitted or required by law.

22.7 Children Under 16

We do not have actual knowledge that we sell or share the personal information of consumers under 16 years of age. We do not knowingly collect personal information from children under 13 in violation of applicable law.

22.8 Your Privacy Rights

Depending on your state of residence, you may have some or all of the following rights:

• Right to know or confirm whether we process your personal information.
• Right to access personal information we hold about you.
• Right to obtain a portable copy of certain personal information.
• Right to correct inaccurate personal information.
• Right to delete personal information, subject to exceptions.
• Right to opt out of sale, sharing, targeted advertising, or certain profiling.
• Right to limit certain uses or disclosures of sensitive personal information, where applicable.
• Right to appeal a denied request, where applicable.
• Right not to be discriminated against for exercising your privacy rights.

We do not use your personal information for profiling or automated decision-making that produces legal or similarly significant effects, such as decisions concerning housing, education, employment, healthcare, criminal justice, or access to essential goods or services.

22.9 How to Exercise Your Rights

To exercise your rights, please contact us at [email protected]. Please include your game name, in-game username or user ID, email address, state of residence, and the nature of your request.

We may need to verify your identity before processing your request. Depending on the request, we may ask you to provide information that allows us to match your request with information we maintain about you. If we cannot verify your identity or locate your account, we may be unable to fulfill your request.

Where applicable, you may designate an authorized agent to make a request on your behalf. We may require proof of the agent’s authority and may also require you to verify your identity directly with us, unless prohibited by applicable law.

22.10 Appeals

If we deny your privacy request and your state law provides a right to appeal, you may appeal our decision by contacting us at [email protected] with the subject line "Privacy Request – Appeal." We will respond to your appeal as required by applicable law.

22.11 California "Shine the Light" Notice

California Civil Code Section 1798.83 permits California residents who have an established business relationship with us to request certain information regarding our disclosure of certain personal information to third parties for their direct marketing purposes during the preceding calendar year, where applicable.

To submit a request under California’s "Shine the Light" law, please contact us at [email protected] with the subject line "Shine the Light Request." Please include your name, email address, game name, user ID or username, and information sufficient for us to verify your California residency and process your request.

23. SUPPLEMENTAL NOTICE FOR USERS IN THE EUROPEAN ECONOMIC AREA AND THE UNITED KINGDOM

This section applies to individuals located in the European Economic Area ("EEA") and the United Kingdom ("UK") and supplements the other provisions of this Privacy Policy.

23.1 Data Controller

Arclight Network Technology Limited is the controller of the personal information processed in connection with Mini Wild: Survival.

You may contact us at:

Arclight Network Technology Limited

Room 1104A, 11/F, Kai Tak Commercial Building

317-319 Des Voeux Road Central

Sheung Wan, Hong Kong

Email: [email protected]

23.2 Legal Bases for Processing

We process personal information under one or more of the following legal bases:

Performance of a contract. We process information where necessary to provide the Services you request and perform our agreement with you, including to create and manage your account, provide gameplay and multiplayer functionality, deliver Virtual Items and paid content, process and confirm transactions, provide customer support, and maintain your game progress and settings.

Legitimate interests. We process information where necessary for our legitimate interests or those of a third party, including to operate, maintain, improve and develop the Services; understand how users interact with Mini Wild: Survival; maintain the security, integrity and fairness of the Services; prevent and investigate fraud, cheating, abuse and unauthorized access; troubleshoot technical problems; enforce our Terms and policies; and establish, exercise or defend legal claims. When relying on legitimate interests, we consider whether those interests are overridden by your rights and interests.

Compliance with legal obligations. We process information where necessary to comply with applicable laws, regulations, court orders, legal processes, tax and accounting requirements, and lawful requests from competent authorities.

Consent. We rely on your consent where required, including for certain optional device permissions, marketing communications, advertising or personalization activities, or other processing for which consent is required. Where processing is based on consent, you may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before your withdrawal.

23.3 Information Required to Provide the Services

Certain personal information is necessary for us to provide Mini Wild: Survival and perform our agreement with you, including certain account, device, gameplay, security and transaction-related information.

If you do not provide information that is necessary for a particular feature or for the operation of the Services, we may be unable to provide that feature or all or part of the Services to you.

Other information, including information collected through optional device permissions or used for optional marketing or advertising activities, may not be necessary for you to access the core Services unless otherwise stated when the information is requested.

23.4 Your Rights

Subject to applicable data protection law and applicable exceptions, you may have the right to:

• request access to the personal information we process about you;
• request correction of inaccurate or incomplete personal information;
• request deletion of your personal information;
• request restriction of the processing of your personal information;
• object to processing based on our legitimate interests;
• object at any time to the processing of your personal information for direct marketing purposes;
• receive certain personal information in a structured, commonly used and machine-readable format and request its transmission to another controller, where applicable;
• withdraw your consent at any time where we rely on consent as the legal basis for processing; and
• lodge a complaint with a competent data protection supervisory authority.

If you are located in the EEA, you may lodge a complaint with the supervisory authority in the country in which you live or work or where you believe an infringement of applicable data protection law has occurred.

If you are located in the United Kingdom, you may lodge a complaint with the UK Information Commissioner’s Office ("ICO").

You may exercise your rights by contacting us at [email protected].

We may request information reasonably necessary to verify your identity before processing your request.

23.5 International Transfers

Arclight Network Technology Limited is located in Hong Kong, and we and our service providers may process personal information in Hong Kong and other countries or regions outside the EEA or UK.

Where required, we use appropriate safeguards for transfers of personal information outside the EEA or UK.

For transfers subject to the GDPR, these safeguards may include adequacy decisions issued by the European Commission and the European Commission’s Standard Contractual Clauses ("SCCs").

For transfers subject to the UK GDPR, these safeguards may include applicable UK adequacy regulations, the UK International Data Transfer Agreement ("IDTA"), or the International Data Transfer Addendum to the European Commission’s SCCs.

You may contact us at [email protected] for additional information about the safeguards applicable to transfers of your personal information.