Privacy Protection Policy

Updated: October 20, 2024

Effective Date: October 20, 2024

Outline

Welcome to Fishing Frenzy: Sea World (hereinafter referred to as "the game") provided by [Homeland Interactive Entertainment & Technology Limited] (hereinafter referred to as "we")! In addition to the User Service Agreement, we will further explain to you in detail the collection, use, storage and sharing of personal information, and your rights and obligations in relation thereto through our Privacy Protection Policy (the "policy") when you use the Fishing Frenzy: Sea World game. If you are a minor, please read this policy with a guardian.

Please read this policy carefully. When you tick the box, agree or use this game service, it is deemed that you are aware of the content of this policy and agree to sign this policy.

1. Information we collect

In the course of your use of the Fishing Frenzy: Sea World Game Service, we will collect information that you voluntarily provide or as a result of your use of the Service in the following manner, in order to provide you with and optimize our services and to protect the security of your account:

1.1 When you register or use the Fishing Frenzy: Sea World game service, we will collect your network identification information and personal device information, which will be used to mark you as a user of the game. If you use a third-party platform and account to download and log in to Fishing Frenzy: Sea World, we will collect your unique identification, avatar and nickname, which will be used to save your login information so that you can log in on different devices.

In order to provide you with better game services and improve your gaming experience, we may collect your nickname, avatar, operation information and game information in Fishing Frenzy: Sea World (hereinafter referred to as "such information", including but not limited to your login status, battle information/status, and achievement information) from your game account, and may show such information to you or other users. Depending on the game product, we may provide you with the relevant permissions so that you can choose whether to display the aforementioned information accordingly.

1.2 To comply with the relevant laws, regulations, policies, and requirements of the competent authorities in Vietnam, users of Fishing Frenzy: Sea World are required to perform real-name authentication to continue accessing and enjoying the game. We will collect your real-name identity information (including name and ID number) only after obtaining your consent or when you voluntarily provide this information. This information is classified as sensitive. Refusal to provide real-name identity information may result in your inability to log in to the game or restrictions on using the game's certain features. If you are not a user located in Vietnam and will not be accessing the game in Vietnam, you may disregard this real-name authentication requirement.

1.3 To ensure the operation of our services, maintain the basic functionality of the game, optimize the performance of our game products, improve your gaming experience, and safeguard your account security, we will collect the following information: your device ID, device name, device type and version, system version, IP address, device identifiers (such as IMEI/IDFA/OpenUDID/GUID/SIM card IMSI, MAC address), application ID, and network type.

1.4 When you use the game service, we will collect your game log information, such as login logs, item logs, game match information, so that you can view your game history in the client, and also for the analysis of game operation statistics, customer service complaint handling and other game security analysis. You need to authorize the permission to write and read your external storage, which is used for reading and storing game data, downloading apk updates, and helping you to store and share exciting moments. In order to enhance your gaming experience, we may synchronize the aforementioned information to subsequent versions of the game or other products provided by us that you are using.

1.5 In order to ensure the safe and stable operation of the game and to realize certain functions, the game may access the Software Development Kit (SDK) developed by a third party. We will conduct security monitoring of the SDKs accessed by the game that involve the collection of personal information in order to ensure the security of your personal information. For details, please see the attached "Third Party SDK Catalog Accessed by Fishing Frenzy: Sea World".

1.6 When you use the consumption function of this game, we will collect your top-up record and consumption record information so that you can inquire about your transaction records, and at the same time ensure the safety of your virtual items to the greatest extent possible. Top-up records and consumption records are sensitive information, and the collection of such information is necessary for the realization of the game's consumption function, otherwise the transaction will not be completed.

1.7 In order to ensure the security of your game account and create a fair, healthy and safe gaming environment, we will collect your game identification information, hardware and operating system information, process and game crash record information to combat behaviors that undermine the fair gaming environment or interfere with or disrupt the normal operation of the game services (e.g., for detecting piracy, scanning for external plug-ins, and preventing cheating, etc.).

1.8 When you interact with other players through text, voice and other means in the game, we might collect and save the content of the above information you send for filtering pornography, violence, politics, insults, malicious advertisements and other inappropriate content, in order to purify the gaming environment and maintain a healthy online environment.

1.9 If you wish to interact with other game players through voice, send questions and suggestions to us with screenshots. After obtaining your authorization, the game will access your photos or storage files, microphone, and provide you with screenshot saving, picture uploading, voice chatting and other functions.

1.10 Mobile phone number and password are personal information that you voluntarily provide to us when you choose to use your cell phone number to register/activate your account. At the same time, we need your consent to obtain the permission to read the SMS of your cell phone, and we will verify the validity of your identity by sending an SMS verification code.

1.11 If you want to contact the game customer service quickly by phone, the game will obtain your phone call permission to provide the in-game customer service system for you to directly call customer service after your authorization and consent.

1.12 In order to facilitate avatar providing and picture uploading for feedback, the game will access your camera permission and provide you with photo and screenshot storage functions after your authorization and consent.

1.13 If you want to recommend the game to your friends and family, the game will access your contacts (read contacts) to provide you with the game-sharing function after your authorization and consent.

1.14 If you wish to interact with nearby game players, we will collect your geographic location information (e.g., IP address, GPS location, WLAN access point and Bluetooth that can provide the relevant information, and acquire sensor information) to search for nearby game players, so as to allow you to match with and team up with nearby players. Geographic location information is sensitive information, and refusal to provide such information will only result in your inability to interact with nearby game players, but will not affect your normal use of other features of Fishing Frenzy: Sea World, and you may cancel your authorization of geographic location information at any time.

1.15 In order to realize the purpose of inviting friends to play the game together, the game app will read your clipboard data when it starts, including group ID, room ID, inviter ID and other information.

1.16 According to relevant laws and regulations and national standards, we might collect and use your relevant personal information without seeking your authorization and consent in the following cases:

1) Directly related to national security, national defense security, and other national interests; directly related to public safety, public health, public knowledge, and other major public interests.

2) Directly related to crime investigation, prosecution, trial, and judgment execution.

3) For the purpose of safeguarding the life, property, reputation, and other important legal rights and interests of you or other individuals, but it is difficult to obtain your consent.

4) The collected personal information is voluntarily disclosed to the public by yourself.

5) The personal information is collected from legitimate publicly disclosed information, like legitimate news reports, government information disclosure, and other channels.

6) Necessary for the conclusion and fulfillment of a contract at your request.

7) Necessary for maintaining the safe and stable operation of the products or services provided, such as discovering and processing product or service failures.

8) Necessary for carrying out legitimate news reporting.

9) Necessary for carrying out statistical or academic research in the public interest, and to de-identify personal information contained in the results of academic research or descriptions when they are provided to the public.

10) Other cases stipulated by laws and regulations.

1.17 Please understand that the functions and services we provide to you are constantly updated and developing, and if a certain function or service is not in the foregoing description and collects your information, we will separately explain the content, scope, and purpose of the collection of information to you by means of page prompts, interactive processes, website announcements, etc., in order to obtain your consent.

At present, except for collecting game research information from third-party research organizations to help us improve our game products, we will not actively obtain your personal information from third parties outside of this game. If we need to obtain your personal information indirectly from a third party outside the game for business development in the future, we will make clear to you the source, type, and scope of use of your personal information before obtaining it, and if we need to carry out personal information processing activities for conducting our business beyond the scope of the authorization and consent that you originally gave to the third party outside Fishing Frenzy: Sea World for the provision of your personal information, we will obtain your explicit consent before processing your personal information. In addition, we will strictly comply with relevant laws and regulations and require the third party to ensure the legitimacy of the information it provides.

1.18 You (the user) understand and agree that in order to provide you with better products/services and experience, we may provide your real-name authentication information, including your name, ID card number, and cell phone number, to the third-party service organization we commissioned to validate the authenticity of the authentication information provided by you. The third-party service organization we work with may use your information for comparison with external legitimate databases for verification results. In order to ensure the security of your information, we will require the third-party partner organization to have sufficient data security capabilities and provide an adequate level of security protection. Without your consent, we will not use the information you provide for any other purpose not expressly authorized by you.

2. Storage of information

2.1 How and for how long information is stored

We store your information in secure ways, including local storage (e.g. data caching using an app), databases, and server logs.

In general, we will only store your personal information, including local storage (e.g. data caching using the APP), databases, and server logs, for the period of time necessary to fulfill the purpose of the service or under the conditions stipulated by laws and regulations. Minimum storage periods required by law: such as the minimum retention time for specific information under the Cybersecurity Law, etc.

The period necessary for providing the products/services of Fishing Frenzy: Sea World, such as when you use the corresponding function of Fishing Frenzy: Sea World after registering/logging in with your cell phone number, we will continue to store your cell phone number during this period, so that you can access this function normally. After the above-mentioned period of storage of personal information, we will delete or anonymize your personal information.

2.2 Notification of discontinuation of products or services

When our products or services cease to operate, we will make announcements and notifications in accordance with relevant laws and regulations, and protect your legal rights and interests.

Please note that we are not liable in any way when our products are taken down and/or discontinued due to the decision of a regulatory agency or application platform.

3. Information Security

3.1 Security Measures

We strive to protect the security of our users' information against leakage, loss, misuse, unauthorized access and disclosure. We use multi-faceted security protection measures to ensure that the protection of users' personal information is at a reasonable level of security, including technical protection means, management system control, security system guarantee, and many other aspects. In addition, the relevant systems of our game have passed the filing and evaluation of the National Network Security Level Protection (Level II).

We use industry-leading technical protection measures. The technical means we use include, but are not limited to, firewalls, encryption (e.g., SSL), de-identification or anonymization, and access control measures. In addition, we'll continually enhance the security capabilities of the software installed on your device. For example, we complete some of the encryption of information locally on your device to consolidate secure transmission; we learn information about applications installed on your device and processes running to prevent viruses, Trojans, and other malicious programs.

We strictly limit the scope of people who access the information, require them to comply with confidentiality obligations and conduct audits, and those who violate their obligations are penalized according to the regulations. We also review this management system, process, and organization to prevent unauthorized personnel from accessing, using, or disclosing user information. We recommend that you pay due attention to the protection of your personal information when using the products and services, and we provide a variety of security features to assist you in protecting the security of your personal information.

We recommend that you pay due attention to the protection of your personal information when using the products and services, and we provide a variety of security features to assist you in protecting the security of your personal information.

3.2 Security Incident Disposal Measures

In the event of a security incident, such as the leakage of personal information, we will activate our emergency response plan to prevent the security incident from expanding. After a security incident occurs, we will inform you of the basic situation of the security incident, the disposal measures and remedial measures that we are going to take or have taken, as well as our suggestions for you to cope with the situation, by means of announcements, push notifications or emails. If it is difficult to realize the one-by-one notification, we will issue warnings through announcements and other means.

3.3 Safekeeping of Game Accounts

Although we have taken reasonable and effective measures as described above and have complied with the standards required by the relevant laws and regulations, please understand that the Internet environment is not 100% safe, and because of technological limitations and the possible existence of a variety of malicious means, it is not always possible to ensure that 100% of the information is safe, even if every effort is made to strengthen security measures. We will do our best to ensure the safety of the personal information you provide to us. You are aware and understand that the systems and communication networks you use to access our services may experience problems due to factors beyond our control. Therefore, we recommend that you take proactive measures to protect the security of your personal information, including, but not limited to, using complex passwords, changing passwords regularly, and not disclosing personal information such as your account password to others.

4. How we use information

We strictly abide by the laws and regulations as well as the agreement with the users, and use the collected information in accordance with this policy and the User Service Agreement in order to provide you with better services.

4.1 Rules of Information Use

We will use the collected information in accordance with the following rules:

1) We will provide you with various features and services based on the information we collect, including basic game features, player interaction features and consumption features.

2) We will analyze the operation of our products based on the frequency and circumstances of your use of Fishing Frenzy: Sea World, fault information, and performance information to ensure the safety of our services and to optimize our products and improve the quality of our services. We do not combine the information we store in our analysis software with the personally identifiable information you provide.

4.2 Method of obtaining consent after notification of the purpose of the change

We will use the information collected for the purposes covered by this policy. If we use your personal information beyond the scope that is directly or reasonably related to the purpose for which it was collected, we will inform you again and obtain your express consent first.

5. External Provision

5.1 At present, except for the circumstances stipulated in this policy and the User Service Agreement, we will not actively share, provide, or transfer your personal information to third parties outside Fishing Frenzy: Sea World. If there are other circumstances of sharing, providing, or transferring your personal information, or you need us to share, provide, or transfer your personal information to third parties outside Fishing Frenzy: Sea World, we will directly seek your consent or confirm that the third party has obtained your consent to the above actions.

5.2 We will try to contact the guardians of suspected minors after they have made purchases or confirm with them through operational channels, and then inform their guardians of the relevant consumption record information or pass it on to their guardians through the channels for reminder, confirmation, and processing.

5.3 In order to enhance your user experience, we may need to share information that has been anonymized or de-identified with third-party partners, and require them to strictly comply with our data privacy protection measures and requirements, including but not limited to processing in accordance with the Data Protection Agreement, the Commitment Letter and the relevant data processing policies, to avoid identifying individuals and to safeguard privacy and security.

We will not share information that can be used to identify you personally (e.g. your name or email address) with our partners unless you expressly authorize us to do so.

5.4 We will not publicly disclose the personal information we collect, except as otherwise provided in this policy and the User Service Agreement. If public disclosure is necessary, we will inform you of the purpose of the public disclosure, the type of information to be disclosed, and the sensitive information that may be involved, and obtain your express consent.

5.5 As our business continues to develop, we may engage in transactions such as mergers, acquisitions, asset transfers, etc. We will inform you of the relevant circumstances and continue to protect or require the new controller to continue to protect your personal information in accordance with laws, regulations and standards no less stringent than those required by this policy.

5.6 In accordance with relevant laws and regulations and national standards, we may share, transfer, and publicly disclose personal information without obtaining your prior authorization and consent in the following cases:

1) Directly related to national security and national defense security.

2) Directly related to public safety, public health, and major public interests.

3) Directly related to criminal investigation, prosecution, trial, and judgment execution.

4) For the purpose of safeguarding the life, property, and other important legal rights and interests of the subject of personal information or other individuals, but it is difficult to obtain the consent of the person himself/herself.

5) When the subject of personal information discloses personal information to the public by himself/herself.

6) Collecting personal information from legitimate publicly disclosed information, such as legitimate news reports, government information disclosure, and other channels.

6. Your Rights

You have the right to inquire about personal information, delete personal information, correct personal information, withdraw consent, deactivate accounts, etc., as detailed below. You are aware and understand that the settings from different channels may vary, and the details are subject to the display of your game interface. If you are unable to operate on your own, you can also contact customer service for advice and assistance.

6.1 Inquiry of personal information

1) Tap the "avatar" icon to inquire about your account, ID, and nickname information.

2) Inquire about the news and interactive information posted.

6.2 Delete Personal Information

In the following cases, you can tap on "Customer Service" at the bottom of the page to make a request to delete your personal information:

1) If our handling of your personal information violates laws and regulations.

2) If we collect or use your personal information without your consent.

3) If our handling of your personal information violates our agreement with you.

4) If you no longer use our products or services, or if you deactivate your account.

5) if we no longer provide products or services to you.

If we decide to respond to your request for deletion, we will also notify the entities that received your personal information from us at the same time and ask them to delete it promptly, unless otherwise required by law or regulation, or those entities are independently authorized by you.

When you delete information from our Services, we may not immediately delete the corresponding information in our backup system, but will delete the information when the backup is updated.

6.3 Correction of Personal Information

1) You can correct your avatar, nickname, and gender by tapping the avatar icon in "My Profile".

2) You can change your login password by tapping your avatar icon and "Change Password".

3) You can tap the icon of your avatar to change the binding of your cell phone in "Change Binding".

6.4 Withdrawal of Consent to Collect Personal Information

Each game feature requires your authorization and consent to the collection of some basic personal information in order to be completed. You can give or withdraw your consent to the collection and use of additional personal information at any time.

You can do this on your own by tapping "Settings" at the bottom of the page, tapping "Privacy Settings", finding "Permission Settings", and after entering the "Go to Settings" page, tap "Permissions" and choose to turn on or off the corresponding information collection permissions, or change the scope of your authorization for us to continue to collect information or withdraw your authorization through turning off the functions of your device or other ways.

When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the processing of personal information previously carried out on the basis of your authorization.

6.5 Way to deactivate your account

Once your game account is deactivated, unless otherwise specified by laws, regulations, or the Agreement, your personal information under the account will be deleted or anonymized, and will no longer be associated with the related products and services. Account deactivation is irreversible, so please proceed with caution.

If, after careful consideration, you still decide to deactivate your game account, you must read and fully understand this Game Account Deactivation Agreement ("Agreement") and agree to all its contents, especially the disclaimers and limitation clauses (such as Article 1 and Article 3.3) and the methods of dispute resolution and jurisdiction clauses (Articles 4.2, 4.3, and 4.4). These clauses may be highlighted for your attention in bold, colored text, or other reasonable means. This agreement is entered into between you and [Homeland Interactive Entertainment & Technology Limited] ("we", "our", or "us") and has a contractual effect. By starting the deactivation process according to our deactivation procedures or by checking the Deactivation Agreement and proceeding to the next step, you are deemed to have agreed to and shall abide by all the contents of this agreement.

To ensure the successful completion of the deactivation, please do not log into the game with the account during the processing period of your deactivation request. Otherwise, you are deemed to have withdrawn your deactivation request.

If you wish to use our services again after deactivation, you are welcome to re-register and log in through an account created by recognized channels (accounts that support user login will be provided by the game).

1. You understand and agree that once your game account is deactivated, it may result in, but is not limited to, the following consequences, and you must bear the responsibility for them:

1.1 You will no longer be able to log in or use the game account, and your friends will not be able to interact with you within the game.

1.2 Since game accounts may be logged in from multiple devices, all login information for the same account will be deactivated. Unless otherwise specified by laws, regulations, or the Agreement, your personal information under the account will be deleted or anonymized. You will no longer be able to retrieve your personal information, nor can you request that we recover it. This personal information includes, but is not limited to, your avatars, nicknames, achievements, in-game purchases and spending records, geographic location, and other data.

If your account was subject to a suspension or other penalties for violating national laws, regulations, or platform-related policies, we may retain data related to the account's violations for at least 180 days upon deactivation to protect the legal rights and interests of you and other relevant parties. During the retention period, we will only use this data to protect these rights and interests and will not use it for other purposes.

1.3 You understand that after the game account is deactivated, all related game earnings will be deleted. Therefore, we remind you to handle your in-game earnings before deactivating your account or ensuring that they have been settled. Once your game account is deactivated, any in-game earnings (including those accrued during your game time and potential future earnings) will be considered voluntarily forfeited. We will have the right to delete all game earnings under this account, and you will bear the consequences. You agree not to request us to restore or compensate for these game earnings. These game earnings include, but are not limited to: user rights, levels, all data related to character growth and upgrades (including but not limited to experience points, honor points, reputation points, titles, etc.), unused in-game virtual currency, virtual items (such as fish coins, crystals, items, etc.), purchased but unexpired services, and other in-game earnings that have been generated but not fully used as well as expected future earnings.

1.4 Game deactivation is irreversible. Even if you re-register with the same account through recognized channels, it will be treated as a new user account. Therefore, we kindly remind you to back up any important content before submitting the deactivation request.

1.5 Game account deactivation does not affect the obligations or responsibilities that you incurred while using the game before deactivation. You are still responsible for any actions under the game account prior to deactivation, including, but not limited to, breach of contract, damage compensation, and performance of obligations.

1.6 Other potential consequences arising from the account deactivation.

2. Before submitting/proceeding with your request to deactivate your game account, to protect the security of your account and related rights and interests, you must check and ensure that the game account meets the following conditions, including but not limited to:

2.1 You legally own and use the game account, and it complies with the platform agreements and rules regarding game accounts.

2.2 The account is in a secure and normal state, with no actions involving sensitive information, such as enabling two-factor authentication or password-free operations, taken for two weeks prior to your deactivation request. Additionally, the account has been in regular use with no risk of theft. Additionally, the account is not under any penalties (such as suspension or other actions due to violations of the game's agreements or rules).

2.3 All in-game earnings under the account have been settled or properly handled. This includes, but is not limited to, fish coins, crystals, items, trial cards, and other in-game earnings. Please ensure you handle these properly, as failure to do so will be considered a voluntary forfeiture.

2.4 There are no unfinished orders under the game account. This includes, but is not limited to, orders for virtual in-game currency, virtual items, or merchandise generated by the account.

2.5 The game account has no ongoing disputes, including complaints, investigations by government agencies, arbitration, litigation, or other disputes.

2.6 Any other conditions published by the game's official channels.

You may attempt to resolve the above issues yourself first. If you are unable to resolve them or encounter any questions during the process, please contact customer service for assistance.

3. How to Deactivate Your Game Account?

(1) You can cancel your Fishing Frenzy: Sea World game account to ensure that the game no longer collects your personal information. You can follow the account cancellation guidelines provided by the game official, and should ensure that you meet the relevant conditions of the game account cancellation announced by the game official, and agree to the "Game Account Deactivation Agreement" and other relevant rules announced by the game official. Before canceling your account, we will verify your personal identity, account security status, commonly used devices, and other information. The act of canceling your account is an irreversible act. Once the cancellation is successful, we will delete or anonymize all information about your account and ensure that such information will not be disclosed, at the same time, you will not be able to use Fishing Frenzy: Sea World game services, so please proceed with caution.

3.2 You have agreed to all the contents of the Deactivation Agreement. Additionally, you have checked and confirmed that you meet the requirements outlined in Article 2 of the Agreement.

3.3 After completing Article 3.2, to further protect your legal rights and interests, we reserve the right to verify whether you meet some or all of the deactivation conditions specified in Article 2 of the Agreement. In order to complete the verification, we will assess your account's security status and your usage of related products and services to determine if your account meets the deactivation criteria. To ensure the security of your account and your property rights and interests, we reserve the right to conduct identity verification for the deactivation request to confirm that you are the authorized user of the game account. If we find, after our assessment, that the account does not meet the deactivation conditions or if the identity verification fails, your deactivation may be unsuccessful, and you may follow our instructions for further action or contact customer service for assistance. Even if we determine that you meet the deactivation conditions, it is done through a procedural review based on your word of honor (i.e., your affirmation that the game account meets the aforementioned deactivation conditions). You remain responsible for ensuring that the game account meets the above deactivation conditions, and we do not assume any legal responsibility for this.

3.4 Follow the official instructions to delete your account on the account settings page.

Confirm and agree to all terms of this agreement, while ensuring you meet the deletion requirements above.

We will review your account status and complete the deletion after a cooling-off period of 15 business days. (Please do not log in during the period, or your deletion request will be canceled.)

If the review or authentication fails, the deletion cannot be completed. You can follow the instructions for the next steps or contact customer support.

For any questions, feel free to email us at homelandhk@icloud.com. We are happy to help!

However, please note that if you log into and use the game with the account during the agreed deactivation processing period, you are deemed to have withdrawn your deactivation request. At the same time, you understand and agree that, before deleting or anonymizing personal information associated with the account, time is needed to appropriately organize and process the information to maximize the protection of your and other users' legal rights and interests. Therefore, there may be a delay in deleting or anonymizing the personal information associated with the account.

3.5 You understand and agree that during your request for account deactivation, if we need to verify related transactions, complaints, or other matters related to your account, or if we have other reasonable grounds, we reserve the right to freeze your deactivation request and suspend the deactivation services.

4. Others

4.1 This agreement is part of the User Agreement ("the main agreement"), and any matters not addressed in this agreement are applicable under the main agreement. In the event of any inconsistencies between this agreement and the main agreement, this agreement shall prevail. You also understand and agree that even if your game account is deactivated, it does not relieve or exempt you from any responsibilities you may need to bear under relevant laws, regulations, agreements, or rules.

4.2 The formation, effectiveness, execution, interpretation, and dispute resolution of the Agreement shall be governed by the laws of the country/region where the service operator is located (excluding contents in conflict with laws).

4.3 In the event of any dispute or controversy arising between you and us under the Agreement, both parties shall first attempt to resolve it through amicable negotiations. Should negotiations fail, you agree to submit the dispute or controversy to the judicial authorities in the country/region where the service operator is located.

4.4 If you encounter any issues during the account deactivation process that you cannot resolve or have any questions during the process, you may contact customer service for assistance.

6.6 Obtaining Copies of Personal Information

If you have the need to inquire, copy, correct, supplement, delete your personal information in the game, or obtain a copy of your personal information, you can contact [homelandhk@icloud.com] to do so.

6.7 Responding to your request for rights

Please understand and agree that you may be required to provide a written request or otherwise prove your identity for security purposes. We may ask you to verify your identity before processing your request.

In principle, we do not charge you for reasonable requests, but for requests that are repeated more than reasonably possible, we will charge a fee of a certain cost, depending on the circumstances. We may refuse requests that require excessive technical means, high costs, or other significant difficulties (for example, the need to develop new systems or fundamentally change existing practices), or that pose a risk to the legal rights and interests of others. After verifying your identity, we will respond to you or provide you with an explanation within the time period required by local laws and regulations, regardless of whether your request will be fulfilled.

We will not be able to respond to your request in the following cases:

(1) Related to our fulfillment of obligations under laws and regulations.

(2) Directly related to national security and national defense security.

(3) Directly related to public safety, public health, and major public interests.

(4) Directly related to criminal investigation, prosecution, trial and execution of judgment, etc.

(5) We have sufficient evidence that you have subjective malicious intent or abuse your rights.

(6) For the purpose of safeguarding the life, property, and other important legal rights and interests of you or other individuals, but it is difficult to obtain your consent.

(7) Responding to your request will seriously harm the legal rights and interests of the subject of personal information or other individuals and organizations.

(8) Where trade secrets are involved.

7. Cookies and Similar Technologies

We want you to learn about our use of these technologies, so this section explains the types of technologies we use, what they are used for, and your choices regarding their use.

(1) What are Cookies and Advertising Identifiers?

Cookies are small data files that are usually stored on your device as you browse and use websites and online services. They are widely used to make websites work more efficiently and to provide report information and assistance services.

(2) Why do we use cookies and advertising identifiers?

The use of Cookies allows us to provide you with a more convenient service while you are online.

(3) How do I select cookies and advertising identifiers?

When using the customer service function before logging in, a random string is generated to identify an anonymous user, so that the anonymous user can get the previous chat history when he/she uses the customer service next time.

8. Changes

We may revise this policy from time to time. When the terms of this policy are changed, we will notify you of the changed guidelines in an appropriate manner when the version is updated. Please read the changed privacy protection policy or the content of the policy carefully. Your continued use of Fishing Frenzy: Sea World indicates your consent to our collection, processing, or use of your personal information in accordance with the updated privacy protection policy.

9. Protection of Minors

We attach great importance to the protection of minors' personal information and continue to explore ways to update the protection of minors' personal information. In order to better protect the physical and mental health of minors, we recommend that minor users should read and agree to this policy under the supervision of their parents or other guardians before using the game.

10. Contact Us

When you have other complaints, suggestions, or questions related to minors' personal information, please contact us through the game's customer service. You can also send your question to [homelandhk@icloud.com]. We will review the issue as soon as possible and respond within fifteen days after verifying your user identity.

[Homeland Interactive Entertainment & Technology Limited]

Third-Party SDK Catalog Accessed by Fishing Frenzy: Sea World

1. Ruixue SDK

Third-party subject: Jilin Haiqi Technology Co., Ltd

Purpose of Use: To ensure your normal use of our services, to maintain the normal operation of the basic functions, to optimize product performance, to enhance your experience and protect your account security, and to achieve the purpose of inviting friends to play together.

Types of personal information involved: device ID, device name, device type and version, system version, IP address, device identifier (e.g., IMEI/Android ID/IDFA/OpenUDID/GUID/SIM card IMSI, MAC address), application ID, network type information, generated device code, clipboard data, including the inviter ID, shared material ID and other information.

Link to official website/privacy policy: https://doc.ruixuecloud.com/#/view?path=efed7e47-08dc-4ea0-861a-277bd8bc1721

2. FMOD

Third-party subject: Firelight Technologies Pty Ltd

Purpose of use: In-game audio play

Type of Personal Information Involved: name, address, e-mail address, phone number, fax number

Link to official website/privacy policy: https://www.fmod.com/privacy

Privacy Protection Policy

Updated: October 20, 2024

Effective Date: October 20, 2024

Outline

Welcome to Fishing Game Zone (hereinafter referred to as "the game") provided by [HOMELAND INTERACTIVE TECHNOLOGY & ENTERTAINMENT PTE. LTD.] (hereinafter referred to as "we")! In addition to the User Service Agreement, we will further explain to you in detail the collection, use, storage and sharing of personal information, and your rights and obligations in relation thereto through our Privacy Protection Policy (the "policy") when you use the Fishing Game Zone game. If you are a minor, please read this policy with a guardian.

Please read this policy carefully. When you tick the box, agree or use this game service, it is deemed that you are aware of the content of this policy and agree to sign this policy.

1. Information we collect

In the course of your use of the Fishing Game Zone Game Service, we will collect information that you voluntarily provide or as a result of your use of the Service in the following manner, in order to provide you with and optimize our services and to protect the security of your account:

1.1 When you register or use the Fishing Game Zone game service, we will collect your network identification information and personal device information, which will be used to mark you as a user of the game. If you use a third-party platform and account to download and log in to Fishing Game Zone, we will collect your unique identification, avatar and nickname, which will be used to save your login information so that you can log in on different devices.

In order to provide you with better game services and improve your gaming experience, we may collect your nickname, avatar, operation information and game information in Fishing Game Zone (hereinafter referred to as "such information", including but not limited to your login status, battle information/status, and achievement information) from your game account, and may show such information to you or other users. Depending on the game product, we may provide you with the relevant permissions so that you can choose whether to display the aforementioned information accordingly.

1.2 To comply with the relevant laws, regulations, policies, and requirements of the competent authorities in Vietnam, users of Fishing Game Zone are required to perform real-name authentication to continue accessing and enjoying the game. We will collect your real-name identity information (including name and ID number) only after obtaining your consent or when you voluntarily provide this information. This information is classified as sensitive. Refusal to provide real-name identity information may result in your inability to log in to the game or restrictions on using the game's certain features. If you are not a user located in Vietnam and will not be accessing the game in Vietnam, you may disregard this real-name authentication requirement.

1.3 To ensure the operation of our services, maintain the basic functionality of the game, optimize the performance of our game products, improve your gaming experience, and safeguard your account security, we will collect the following information: your device ID, device name, device type and version, system version, IP address, device identifiers (such as IMEI/IDFA/OpenUDID/GUID/SIM card IMSI, MAC address), application ID, and network type.

1.4 When you use the game service, we will collect your game log information, such as login logs, item logs, game match information, so that you can view your game history in the client, and also for the analysis of game operation statistics, customer service complaint handling and other game security analysis. You need to authorize the permission to write and read your external storage, which is used for reading and storing game data, downloading apk updates, and helping you to store and share exciting moments. In order to enhance your gaming experience, we may synchronize the aforementioned information to subsequent versions of the game or other products provided by us that you are using.

1.5 In order to ensure the safe and stable operation of the game and to realize certain functions, the game may access the Software Development Kit (SDK) developed by a third party. We will conduct security monitoring of the SDKs accessed by the game that involve the collection of personal information in order to ensure the security of your personal information. For details, please see the attached "Third Party SDK Catalog Accessed by Fishing Game Zone".

1.6 When you use the consumption function of this game, we will collect your top-up record and consumption record information so that you can inquire about your transaction records, and at the same time ensure the safety of your virtual items to the greatest extent possible. Top-up records and consumption records are sensitive information, and the collection of such information is necessary for the realization of the game's consumption function, otherwise the transaction will not be completed.

1.7 In order to ensure the security of your game account and create a fair, healthy and safe gaming environment, we will collect your game identification information, hardware and operating system information, process and game crash record information to combat behaviors that undermine the fair gaming environment or interfere with or disrupt the normal operation of the game services (e.g., for detecting piracy, scanning for external plug-ins, and preventing cheating, etc.).

1.8 When you interact with other players through text, voice and other means in the game, we might collect and save the content of the above information you send for filtering pornography, violence, politics, insults, malicious advertisements and other inappropriate content, in order to purify the gaming environment and maintain a healthy online environment.

1.9 If you wish to interact with other game players through voice, send questions and suggestions to us with screenshots. After obtaining your authorization, the game will access your photos or storage files, microphone, and provide you with screenshot saving, picture uploading, voice chatting and other functions.

1.10 Cell phone number and password are personal information that you voluntarily provide to us when you choose to use your cell phone number to register/activate your account. At the same time, we need your consent to access your SMS reading permissions. We will verify the validity of your identity by sending an SMS verification code.

1.11 If you want to contact the game customer service quickly by phone, the game will obtain your phone call permission to provide the in-game customer service system for you to directly call customer service after your authorization and consent.

1.12 In order to facilitate avatar providing and picture uploading for feedback, the game will access your camera permission and provide you with photo and screenshot storage functions after your authorization and consent.

1.13 If you want to recommend the game to your friends and family, the game will access your contacts (read contacts) to provide you with the game-sharing function after your authorization and consent.

1.14 If you wish to interact with nearby game players, we will collect your geographic location information (e.g., IP address, GPS location, WLAN access point and Bluetooth that can provide the relevant information, and acquire sensor information) to search for nearby game players, so as to allow you to match with and team up with nearby players. Geographic location information is sensitive information, and refusal to provide such information will only result in your inability to interact with nearby game players, but will not affect your normal use of other features of Fishing Game Zone, and you may cancel your authorization of geographic location information at any time.

1.15 In order to realize the purpose of inviting friends to play the game together, the game app will read your clipboard data when it starts, including group ID, room ID, inviter ID and other information.

1.16 In accordance with relevant laws and regulations and national standards, in the following cases, we may collect and use your personal information without asking for your authorization and consent:

1) Directly related to national security, national defense security, and other national interests; directly related to public safety, public health, public knowledge, and other major public interests.

2) Directly related to crime investigation, prosecution, trial, and judgment execution.

3) For the purpose of safeguarding the life, property, reputation, and other important legal rights and interests of you or other individuals, but it is difficult to obtain your consent.

4) The collected personal information is voluntarily disclosed to the public by yourself.

5) The personal information is collected from legitimate publicly disclosed information, like legitimate news reports, government information disclosure, and other channels.

6) Necessary for the conclusion and fulfillment of a contract at your request.

7) Necessary for maintaining the safe and stable operation of the products or services provided, such as discovering and processing product or service failures.

8) Necessary for carrying out legitimate news reporting.

9) Necessary for carrying out statistical or academic research in the public interest, and to de-identify personal information contained in the results of academic research or descriptions when they are provided to the public.

10) Other cases stipulated by laws and regulations.

1.17 Please understand that the functions and services we provide to you are constantly updated and developing, and if a function or service is not described above and collects your information, we will separately explain the content, scope, and purpose of the information collection to you through page prompts, interactive processes, website announcements, etc., in order to obtain your consent.

At present, except for collecting game research information from third-party research organizations to help us improve our game products, we will not actively obtain your personal information from third parties outside of this game. If we need to obtain your personal information indirectly from a third party outside the game for business development in the future, we will make clear to you the source, type, and scope of use of your personal information before obtaining it, and if we need to carry out personal information processing activities for conducting our business beyond the scope of the authorization and consent that you originally gave to the third party outside Fishing Game Zone for the provision of your personal information, we will obtain your explicit consent before processing your personal information. In addition, we will strictly comply with relevant laws and regulations and require the third party to ensure the legitimacy of the information it provides.

1.18 You (the user) understand and agree that in order to provide you with better products/services and experience, we may provide your real-name authentication information, including your name, ID card number, and cell phone number, to the third-party service organization we commissioned to validate the authenticity of the authentication information provided by you. The third-party service organization we work with may use your information for comparison with external legitimate databases for verification results. In order to ensure the security of your information, we will require the third-party partner organization to have sufficient data security capabilities and provide an adequate level of security protection. Without your consent, we will not use the information you provide for any other purpose not expressly authorized by you.

2. Storage of information

2.1 How and for how long information is stored

We store your information in secure ways, including local storage (e.g. data caching using an app), databases, and server logs.

In general, we will only store your personal information, including local storage (e.g. data caching using the APP), databases, and server logs, for the period of time necessary to fulfill the purpose of the service or under the conditions stipulated by laws and regulations. Minimum storage periods required by law: such as the minimum retention time for specific information under the Cybersecurity Law, etc.

The period necessary for providing the products/services of Fishing Game Zone, such as when you use the corresponding function of Fishing Game Zone after registering/logging in with your cell phone number, we will continue to store your cell phone number during this period, so that you can access this function normally. After the above-mentioned period of storage of personal information, we will delete or anonymize your personal information.

2.2 Region of information storage

We will store your personal information collected in [Singapore] in accordance with laws and regulations.

2.3 Notification of discontinuation of products or services

When our products or services cease to operate, we will make announcements and notifications in accordance with relevant laws and regulations, and protect your legal rights and interests.

Please note that we are not liable in any way when our products are taken down and/or discontinued due to the decision of a regulatory agency or application platform.

3. Information Security

3.1 Security Measures

We strive to protect the security of our users' information against leakage, loss, misuse, unauthorized access and disclosure. We use multi-faceted security protection measures to ensure that the protection of users' personal information is at a reasonable level of security, including technical protection means, management system control, security system guarantee, and many other aspects. In addition, the relevant systems of our game have passed the filing and evaluation of the National Network Security Level Protection (Level II).

We utilize industry-leading technical protection measures. The technical means we use include, but are not limited to, firewalls, encryption (e.g. SSL), de-identification or anonymization, and access control measures. In addition, we continually enhance the security of the software installed on your device. For example, we will complete some of the information encryption work locally on your device to consolidate the secure transmission; we will learn the information of the application installed on your device and the running process information to prevent viruses, Trojan horses, and other malicious programs.

We strictly limit the scope of people who access the information, require them to comply with confidentiality obligations and conduct audits, and those who violate their obligations are penalized according to the regulations. We also review this management system, process, and organization to prevent unauthorized personnel from accessing, using, or disclosing user information. We recommend that you pay due attention to the protection of your personal information when using the products and services, and we provide a variety of security features to assist you in protecting the security of your personal information.

We recommend that you pay due attention to the protection of your personal information when using the products and services, and we provide a variety of security features to assist you in protecting the security of your personal information.

3.2 Security Incident Disposal Measures

In the event of a security incident, such as the leakage of personal information, we will activate our emergency response plan to prevent the security incident from expanding. After a security incident occurs, we will inform you of the basic situation of the security incident, the disposal measures and remedial measures that we are going to take or have taken, as well as our suggestions for you to cope with the situation, by means of announcements, push notifications or emails. If it is difficult to realize the one-by-one notification, we will issue warnings through announcements and other means.

3.3 Safekeeping of Game Accounts

Although we have taken reasonable and effective measures as described above and have complied with the standards required by the relevant laws and regulations, please understand that the Internet environment is not 100% safe, and because of technological limitations and the possible existence of a variety of malicious means, it is not always possible to ensure that 100% of the information is safe, even if every effort is made to strengthen security measures. We will do our best to ensure the safety of the personal information you provide to us. You are aware and understand that the systems and communication networks you use to access our services may experience problems due to factors beyond our control. Therefore, we recommend that you take proactive measures to protect the security of your personal information, including, but not limited to, using complex passwords, changing passwords regularly, and not disclosing personal information such as your account password to others.

4. How we use information

We strictly abide by the laws and regulations as well as the agreement with the users, and use the collected information in accordance with this policy and the User Service Agreement in order to provide you with better services.

4.1 Rules of Information Use

We will use the collected information in accordance with the following rules:

1) We will provide you with various features and services based on the information we collect, including basic game features, player interaction features and consumption features.

2) We will analyze the operation of our products based on the frequency and circumstances of your use of Fishing Game Zone, fault information, and performance information to ensure the safety of our services and to optimize our products and improve the quality of our services. We do not combine the information we store in our analysis software with the personally identifiable information you provide.

4.2 Method of obtaining consent after notification of the purpose of the change

We will use the information collected for the purposes covered by this policy. If we use your personal information beyond the scope that is directly or reasonably related to the purpose for which it was collected, we will inform you again and obtain your express consent first.

5. External Provision

5.1 At present, except for the circumstances stipulated in this policy and the User Service Agreement, we will not actively share, provide, or transfer your personal information to third parties outside Fishing Game Zone. If there are other circumstances of sharing, providing, or transferring your personal information, or you need us to share, provide, or transfer your personal information to third parties outside Fishing Game Zone, we will directly seek your consent or confirm that the third party has obtained your consent to the above actions.

5.2 We will try to contact the guardians of suspected minors after they have made purchases or confirm with them through operational channels, and then inform their guardians of the relevant consumption record information or pass it on to their guardians through the channels for reminder, confirmation, and processing.

5.3 In order to enhance your user experience, we may need to share information that has been anonymized or de-identified with third-party partners, and require them to strictly comply with our data privacy protection measures and requirements, including but not limited to processing in accordance with the Data Protection Agreement, the Commitment Letter and the relevant data processing policies, to avoid identifying individuals and to safeguard privacy and security.

We will not share information that can be used to identify you personally (e.g. your name or email address) with our partners unless you expressly authorize us to do so.

5.4 We will not publicly disclose the personal information we collect, except as otherwise provided in this policy and the User Service Agreement. If public disclosure is necessary, we will inform you of the purpose of the public disclosure, the type of information to be disclosed, and the sensitive information that may be involved, and obtain your express consent.

5.5 As our business continues to develop, we may engage in transactions such as mergers, acquisitions, asset transfers, etc. We will inform you of the relevant circumstances and continue to protect or require the new controller to continue to protect your personal information in accordance with laws, regulations and standards no less stringent than those required by this policy.

5.6 In accordance with relevant laws and regulations and national standards, we may share, transfer, and publicly disclose personal information without obtaining your prior authorization and consent in the following cases:

1) Directly related to national security and national defense security.

2) Directly related to public safety, public health, and major public interests.

3) Directly related to criminal investigation, prosecution, trial, and judgment execution.

4) For the purpose of safeguarding the life, property, and other important legal rights and interests of the subject of personal information or other individuals, but it is difficult to obtain the consent of the person himself/herself.

5) When the subject of personal information discloses personal information to the public by himself/herself.

6) Collecting personal information from legitimate publicly disclosed information, such as legitimate news reports, government information disclosure, and other channels.

6. Your Rights

You have the right to inquire about personal information, delete personal information, correct personal information, withdraw consent, deactivate accounts, etc., as detailed below. You are aware and understand that the settings from different channels may vary, and the details are subject to the display of your game interface. If you are unable to operate on your own, you can also contact customer service for advice and assistance.

6.1 Inquiry of personal information

1) Tap the "avatar" icon to inquire about your account, ID, and nickname information.

2) Inquire about the news and interactive information posted.

6.2 Delete Personal Information

In the following cases, you can tap on "Customer Service" at the bottom of the page to make a request to delete your personal information:

1) If our handling of your personal information violates laws and regulations.

2) If we collect or use your personal information without your consent.

3) If our handling of your personal information violates our agreement with you.

4) If you no longer use our products or services, or if you deactivate your account.

5) if we no longer provide products or services to you.

If we decide to respond to your request for deletion, we will also notify the entities that received your personal information from us at the same time and ask them to delete it promptly, unless otherwise required by law or regulation, or those entities are independently authorized by you.

When you delete information from our Services, we may not immediately delete the corresponding information in our backup system, but will delete the information when the backup is updated.

6.3 Correction of Personal Information

1) You can correct your avatar, nickname, and gender by tapping the avatar icon in "My Profile".

2) You can change your login password by tapping your avatar icon and "Change Password".

3) You can tap the icon of your avatar to change the binding of your cell phone in "Change Binding".

6.4 Ways to withdraw consent to the collection of personal information

Each game feature requires your authorization and consent to the collection of some basic personal information in order to be completed. You can give or withdraw your consent to the collection and use of additional personal information at any time.

You can do this on your own by tapping "Settings" at the bottom of the page, tapping "Privacy Settings", finding "Permission Settings", and after entering the "Go to Settings" page, tap "Permissions" and choose to turn on or off the corresponding information collection permissions, or change the scope of your authorization for us to continue to collect information or withdraw your authorization through turning off the functions of your device or other ways.

When you withdraw your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the processing of personal information previously carried out on the basis of your authorization.

6.5 Way to deactivate your account

(1) You can cancel your Fishing Game Zone game account to ensure that the game no longer collects your personal information. You can follow the account cancellation guidelines provided by the game official, and should ensure that you meet the relevant conditions of the game account cancellation announced by the game official, and agree to the "Game Account Deactivation Agreement" and other relevant rules announced by the game official. Before canceling your account, we will verify your personal identity, account security status, commonly used devices, and other information. The act of canceling your account is an irreversible act. Once the cancellation is successful, we will delete or anonymize all information about your account and ensure that such information will not be disclosed, at the same time, you will not be able to use Fishing Game Zone game services, so please proceed with caution.

6.6 Obtaining Copies of Personal Information

If you have the need to inquire, copy, correct, supplement, delete your personal information in the game, or obtain a copy of your personal information, you can contact [wlgame03@weile.com] to do so.

6.7 Responding to your request for rights

Please understand and agree that you may be required to provide a written request or otherwise prove your identity for security purposes. We may ask you to verify your identity before processing your request.

In principle, we do not charge you for reasonable requests, but for requests that are repeated more than reasonably possible, we will charge a fee of a certain cost, depending on the circumstances. We may refuse requests that require excessive technical means, high costs, or other significant difficulties (for example, the need to develop new systems or fundamentally change existing practices), or that pose a risk to the legal rights and interests of others. After verifying your identity, we will respond to you or provide you with an explanation within the time period required by local laws and regulations, regardless of whether your request will be fulfilled.

We will not be able to respond to your request in the following cases:

(1) Related to our fulfillment of obligations under laws and regulations.

(2) Directly related to national security and national defense security.

(3) Directly related to public safety, public health, and major public interests.

(4) Directly related to criminal investigation, prosecution, trial and execution of judgment, etc.

(5) We have substantial evidence indicating that you have acted with subjective malice or abused your rights.

(6) When it is necessary to protect the life, property, or other significant legitimate rights and interests of you or other individuals, but it is difficult to obtain your consent;

(7) When responding to your request would severely harm the legitimate rights and interests of the personal information subject or other individuals or organizations;

(8) When it involves trade secrets.

7. Cookies and Similar Technologies

We want you to learn about our use of these technologies, so this section explains the types of technologies we use, what they are used for, and your choices regarding their use.

(1) What are Cookies and Advertising Identifiers?

Cookies are small data files that are usually stored on your device as you browse and use websites and online services. They are widely used to make websites work more efficiently and to provide report information and assistance services.

(2) Why do we use cookies and advertising identifiers?

The use of Cookies allows us to provide you with a more convenient service while you are online.

(3) How do I select cookies and advertising identifiers?

When using the customer service function before logging in, a random string is generated to identify an anonymous user, so that the anonymous user can get the previous chat history when he/she uses the customer service next time.

8. Changes

We may revise this policy from time to time. When the terms of this policy are changed, we will notify you of the changed guidelines in an appropriate manner when the version is updated. Please read the changed privacy protection policy or the content of the policy carefully. Your continued use of Fishing Game Zone indicates your consent to our collection, processing, or use of your personal information in accordance with the updated privacy protection policy.

9. Protection of Minors

We attach great importance to the protection of minors' personal information and continue to explore ways to update the protection of minors' personal information. In order to better protect the physical and mental health of minors, we recommend that minor users should read and agree to this policy under the supervision of their parents or other guardians before using the game.

10. Contact Us

When you have other complaints, suggestions, or questions related to minors' personal information, please contact us through the game's customer service. You can also send your question to [wlgame03@weile.com]. We will review the issue as soon as possible and respond within fifteen days after verifying your user identity.

[HOMELAND INTERACTIVE TECHNOLOGY & ENTERTAINMENT PTE. LTD.]

Third-Party SDK Catalog Accessed by Fishing Game Zone

1. Ruixue SDK

Third-party subject: Jilin Haiqi Technology Co., Ltd

Purpose of Use: To ensure your normal use of our services, to maintain the normal operation of the basic functions, to optimize product performance, to enhance your experience and protect your account security, and to achieve the purpose of inviting friends to play together.

Types of personal information involved: device ID, device name, device type and version, system version, IP address, device identifier (e.g., IMEI/Android ID/IDFA/OpenUDID/GUID/SIM card IMSI, MAC address), application ID, network type information, generated device code, clipboard data, including the inviter ID, shared material ID and other information.

Link to official website/privacy policy: https://doc.ruixuecloud.com/#/view?path=efed7e47-08dc-4ea0-861a-277bd8bc1721

2. FMOD

Third-party subject: Firelight Technologies Pty Ltd

Purpose of use: In-game audio play

Type of Personal Information Involved: name, address, e-mail address, phone number, fax number

Link to official website/privacy policy: https://www.fmod.com/privacy