Privacy Policy

Privacy Policy for all products of Brave1pct.

Privacy Policy

Updated: July 16, 2024
Effective Date: July 16, 2024
Brave1pct Studio (hereinafter referred to as “Brave1pct”, “we”, contact details regarding the protection of personal information: brave1pct@163.com) understands the importance of privacy to you. We are committed to maintaining your trust in us. While striving to provide good products and services, we will also do our best to protect and respect the personal information and privacy security of users (hereinafter collectively referred to as “Users” or “you”).
This policy applies to all Brave1pct services provided by us. When you use any of our individual Services, you agree to be protected by this policy and the specific privacy information policy terms that we issue in that individual service (hereinafter referred to as the “Specific Terms”), in which case the specific terms apply to you simultaneously with the terms of this Policy. If you are a minor under the age of 18, you need to read this policy with your guardian. If you are a child under the age of 14, you and your guardian also need to read the Brave1pct Children’s Personal Information Protection Guidelines carefully (see Annex I). If there is any inconsistency between a particular provision and the provisions of this Policy, the specific provision shall prevail within the scope of the specific provision. If a single service provided by us does not apply to this Policy, the service will expressly exclude the application of this policy in an appropriate manner.
Before using our services, please be sure to carefully read and thoroughly understand this policy, especially the terms marked in bold/red font, you should focus on reading, after confirming full understanding and agreement before starting to use. If you do not agree to the contents of this policy, it may cause our products and services to fail to operate normally, or fail to achieve our expected service effect, you should immediately stop accessing/using our products and/or services. If you read and click to agree to this policy, you consent to our collection, use, storage, sharing, transfer and public disclosure of your personal information in accordance with the purposes and methods described in this policy.
This policy sets out how Brave1pct collects and uses your Personal information, but this policy cannot address all possible information processing situations. Changes and updates to this Policy can be found through the in-game Settings page “Privacy Policy” link or through the Brave1pct official website. If you have any questions about this policy, you can contact us through this policy or the contact information published on the official website.
Contents:

1.Information we may collect

2.How do we use Personal Information

3.How do we use cookies and similar technologies

4.Circumstances under which we may share, transfer and publicly disclose personal information

5.How do we store and protect Personal Information

6.Your Rights

7.Protection of minors

8.Scope of application of privacy policy

9.Notices and changes

10.How to contact us

11.Application of law and jurisdiction

1.Information We may Collect

In order to make it easier and more satisfactory for you and other users to use the products and services provided by Brave1pct, we only collect and use the personal information necessary to achieve the functions of the products according to the principles of legality, legitimacy and necessity.
(A) You must authorize us to collect and use your personal information circumstances
Our products and/or services include some core functions, which contain the functions necessary to enjoy the online game services and the functions necessary to ensure the security of transactions. We may collect, store and use the following information about you in order to perform these functions. If you do not provide this information, you may not be able to register as a user with us or enjoy some or all of the products and/or services we offer. This information may include:

Information needed to help you register for an account and log in
In order to help you register and log in, you will need to provide us with your mobile number or email address to accept the verification code to complete the registration. Only by providing the true and accurate above information can you successfully register an account and use the related services of Brave1pct.
In order to meet the National Press and Publication Administration’s Notice on Preventing Minors from Becoming Addicted to Online Games, Notice on Further Strict Management to Effectively Prevent Minors from Becoming Addicted to Online Games and other relevant laws, regulations and policies as well as the real-name system requirements of relevant competent departments, We require you to provide us with your name and identification information (citizen identification number for Chinese citizens) when registering an account or using Brave1pct services. Such information is sensitive personal information, and refusal to provide such information may result in your inability to log in to Brave1pct or your use of Brave1pct related products or services being restricted.

Information you need to collect when you are a minor
If you are a minor, in order to meet the requirements of laws and regulations, when the guardian applies for parental guardianship, we also need to collect and use your guardian’s personal information, including the guardian’s name, mobile phone number, identification information (Chinese citizens for citizenship number) and other information provided by the guardian.
3, the information needed to achieve payment settlement
When you recharge and consume, in order to comprehensively judge your account and transaction risks, conduct identity verification, detect and prevent security incidents, we will collect your recharge record and consumption record information, so that you can query your transaction records, and provide customer service staff with information to support the processing of dispute claims in case of transaction disputes. Top-up records and consumption records are sensitive personal information. In order to realize the consumption function of Brave1pct products, the above information must be collected, otherwise the top-up cannot be completed.

Information required for the normal operation of the game
In order to ensure that you can normally use our services, maintain the normal operation of the basic functions of the game, optimize the performance of the game product, improve your game experience and ensure the security of your account, We will collect your IP address, device ID, device model, operating system type, operating system and version, MAC address, serial number, software installation, software list only device identifier (contain IMSI/IMEI/androidID/IDFA/IDFV/ODID/OAID, a description of the individual are commonly used Basic information about the device), running processes, network type, device language information.

Information that players need to collect during the use of the game
When you use Brave1pct service, in order to enable you to view your game history on the client side, and at the same time for game operation statistical analysis, customer service complaint handling and game security analysis, we will collect your game log information. Including login log, item log, recharge log, binding information change log, virtual currency change log, purchase record, friends record, so that you can view your game history record, and at the same time for game operation statistical analysis, customer service complaint processing and other game security analysis. In order to improve your game experience, after obtaining your consent, we may also synchronize the above information to the subsequent version of the game or other Brave1pct services that you are using.

Information collected to maintain a healthy network environment
When you interact with other players in the game by text or other means, we may collect and save your in-game chat records or other information sent by you for filtering inappropriate content such as pornography, violence, politics, abuse, malicious advertisements, in order to purify the game environment and maintain a healthy online environment.
7, to ensure the security of the game and the normal service of the game needs to collect information
In order to ensure the safety of your game and create a fair, healthy and safe game environment, we may collect and analyze your game identification information, operating system information, game crash records and other information to combat the behavior that damages the fair environment of the game or interferes with the normal operation of the game service (such as scanning for plug-ins, preventing cheating, etc.).
8, for the message notification function needs to collect information
After your consent, we may collect information about your geographic location to provide you with the message notification function. Geographical location information is sensitive personal information, refusing to provide this information will only cause you to be unable to use our message notification function, but will not affect your normal use of the main functions of Brave1pct service, you can also cancel your geographical location information authorization at any time.

Information collected for functions necessary to ensure the security of transactions
In order to provide you with security protection and better prevent phishing websites, fraud, network vulnerabilities, computer viruses, network attacks, network intrusion and other security risks, we will collect, use or integrate your account information, transaction information, device information, log information or information shared in accordance with the law to comprehensively assess the possible risks of your account operation and transactions.

Information to be collected for customer service and after-sales functions
When you use our customer service, seek help, manage information, or cancel your account through our customer service, we may collect the information you provide to our customer service or submit when participating in activities, including your name, contact phone number, mailing address, email information. The third-party customer service SDK will be activated and may collect your device information. Ask for your microphone permission, camera permission, album permission, or photo permission authorization (for details, please see Article 4 of this policy).
For the security of your account and system, and to optimize the quality of service, we may contact and indirectly collect your personal information from third-party customer service SDKS, including your device information and the content of your communication with customer service (in the form of text/pictures/audio/video/call records) in order to contact you or help you solve the problem, or record the solution and result of the relevant problem. Please be aware and understand that if your communication with customer service involves account or personal sensitive issues, we may ask you to provide your name, mobile phone number, ID number for verification with the real name authentication information of the account to determine your real identity; The above sensitive information is for verification purposes only, and the customer service will not retain it.

Please understand that the functions and services we provide to you are constantly updated and developed. If a function or service needs to collect your information that is not listed in the above description, we will separately explain the content, scope and purpose of information collection to you through page prompts, website announcements and other ways to obtain your consent.
(2) In order to realize the additional functions of the various services provided by Brave1pct, you understand and agree that some individual services may require you to open specific access rights in your device to achieve the collection and use of information related to these rights. The details are as follows:
1, after you open the storage permission, you allow us to access your storage space, so that you can download and save the content, or through the cache to achieve the corresponding services and other functions;

After you enable the device information rights, you allow us to obtain your device information as a unique identifier of your device, understand the product suitability, identify abnormal states, and ensure the network and operation security of Brave1pct service;

After you open the permission of album and/or camera (camera), you can upload and take photos/pictures/videos to achieve communication with customer service to provide proof and other functions;
4, after you open the microphone and related voice rights, you can use the voice function to contact customer service, etc.;
5, after you open our permission to read/write your calendar, we can obtain your schedule time, in order to provide you with records, reminders and other functions;
6, after you open the phone rights, you allow us to identify the information of the device, in order to ensure the security of your account;
7, after you open the network permission, you allow us to access the network status, so that we can perform network diagnosis, check the network signal status to provide you with game services;

We may collect and use advertising identification information in line with national or industry group standards, which is generated based on non-private information such as device model and system configuration, so as to ensure your privacy and service security at the same time, for advertising attribution analysis. At present, the Advertising ID we use is CAID (China Advertising Association Internet Advertising ID, CAA Advertising ID), the generation of CAID and its related services are provided by CAID Advertising Information and Culture Communication Co., LTD. It may collect your device startup time, language, device name (MD5), system version, device machine, operator, physical memory, hard disk, system update time, device model, time zone and other information through CAID API. If you would like to know more, you can visit the website of China Advertising Association http://www.china-caa.org/ or contact China Guangdong Association Advertising Information and Culture Communication Co., LTD via digitalad@china-caa.org. If you do not want us to use advertising logo information for the above purposes, you may contact us according to the contact information set out in Article 10 of this policy. After closing, we will no longer obtain and process the Internet advertising logo.
When you need to disable these functions, you can disable the corresponding permissions in the App Settings - Privacy Permissions View guide, or through the device system Settings to disable the corresponding permissions, most mobile devices will support your needs, the specific method can also refer to or contact your mobile device service provider or manufacturer. Please note that if you turn on any permission, you authorize us to collect and use relevant information to provide you with the corresponding service. If you turn off any permission, you cancel the authorization. We will no longer collect and use relevant information based on the corresponding permission, nor can we provide you with the corresponding service. However, your decision to close the permission will not affect the previous information collection and use based on your authorization.
(3) According to relevant laws and regulations, the collection and use of your information does not require your authorization and consent in the following circumstances:

Related to our performance of obligations stipulated by laws and regulations, including necessary for the performance of statutory duties or statutory obligations;

related to national security and national defense security;
3, related to public security, public health, major public interests, including in response to public health emergencies, for the public interest to carry out news reports, public opinion supervision and other acts to process personal information within a reasonable range;
(4) In connection with criminal investigation, prosecution, trial and execution of judgments;
(5) In order to protect the life, property and other major legitimate rights and interests of the information subject or other individuals, but it is difficult to get your consent;
(6) The collected information is disclosed to the public by you;

Information collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;

Necessary for the signing and performance of the contract according to your requirements;
9, necessary for maintaining the safe and stable operation of network services, such as discovering and disposing of faults of products or services;
(10) necessary for legitimate news reporting;
(11) When it is necessary for academic research institutions to carry out statistics or academic research in the public interest and provide the results of academic research or descriptions to the outside world, the information contained in the results is de-identified;

Other circumstances stipulated by laws and regulations.

2.How do we use Personal Information

(1) Rules for the use of personal information

We will use the personal information collected in accordance with the provisions of this Privacy Policy and to achieve the functions of our products and/or services.

After collecting your personal information, we will de-identify the data through technical means, and the de-identified information will not be able to identify the subject. Please understand and agree that in this case, we have the right to use the de-identified information; And without disclosing your personal information, we have the right to analyze the user database and use it commercially.

Please note that all personal information provided by you when using our products and/or services will continue to be authorized by us during your use of our products and/or services unless you delete it or refuse to collect it through system Settings.
4, we will collect statistics on the use of our products and/or services, and may share these statistics with the public or third parties to show the overall use trend of our products and/or services. However, these statistics do not contain any identifying information about you.

When we display your personal information, we will desensitize your information by means of content replacement and anonymous processing to protect your information security.
6, when we want to use your personal information for other purposes not specified in this policy, or the information collected for a specific purpose is used for other purposes, we will ask for your consent in advance through your initiative to make the form of check.
(2) How do we use your Personal Information
1, to provide you with product functions and services. Based on the collected information, we will provide you with various functions and services, including basic game functions, consumption functions, etc.

Provide security guarantee. We will use your information for identity verification detection, security prevention, anti-fraud monitoring, archive backup, fight against external cheating, customer security services and other purposes.
3, for the collected user information, we may be used for internal audit, data analysis and research, analysis of business operations and measure market share and other situations.
4, with your consent, we will send you the application and version update and installation notice, if you do not agree, we may not be able to provide you with related products or services.

We may use your information to comply with and enforce applicable legal requirements, relevant industry standards, etc.
When you use our services, we may send emails, text messages, information or notices to your device, mobile phone number or email address about the game electronic journal or related market activity information, which is an integral part of the services provided by Brave1pct. If you do not wish to receive such information, you can choose to unsubscribe on your device according to our relevant prompts, or ask us to stop using your personal information for the above purposes. If you choose to unsubscribe by phone or SMS, you should bear the corresponding telecom charges.
Please note that if you want to use your personal information for other purposes not specified in this policy or collect additional personal information not mentioned, we will separately obtain your consent through page prompts, interactive processes, announcements or other means. Once you confirm your consent, such additional use will be considered as part of this Policy, and such additional information will be subject to this Policy.

3.How do we use COOKIES or similar technologies

(a) The log saving function embedded in each game may collect behavioral information of game users (including game character information) and store such information as log text and use it to improve our games.
(2) We or our third party partners may collect and use your information through cookies and network beacons, and store such information as log information. Cookies usually contain an identifier, a site name, and some numbers and characters. Cookies help us identify you as a registered user of ours, or save information you provide to us about your preferences or otherwise help us identify you as a registered user of ours, or save information you provide to us about your preferences or other information about what activities you use the Services for, or which services or services are most popular; And help us to optimize our services and provide you with a better gaming experience based on your information.
(3) We will not use cookies for any purpose other than the purposes described in this Policy. You may set up to manage or delete cookies through your browser or other means according to your preferences.

4.Circumstances under which we may share, transfer and publicly disclose personal Information

(1) Sharing

In general, without your consent or authorization, we will not share your personal information with any third party other than Brave1pct, except in the following cases:
(1) obtain your express consent or authorization in advance;
(2) where necessary in accordance with applicable laws and regulations, legal process requirements, mandatory administrative or judicial requirements;
(3) within the scope permitted by laws and regulations, it is necessary to protect Brave1pct, Brave1pct’s affiliates or partners, you or other players or the public interest, property or safety from damage;
(4) Only by sharing your personal information can we achieve the core functions of our products and/or services or provide the services you need;
(5) to handle disputes or disputes between you and others at your request;
(6) in accordance with the relevant agreement signed with you (including the online signed electronic agreement and the corresponding platform rules) or other legal documents provided;
(7) for use based on academic research;
And (8) based on the social and public interest in accordance with laws and regulations.

When you use the Brave1pct service, you will also use the SDK that provides some services for us. The SDK may collect your personal information for the purpose of providing the above services. The list of SDKS can be found in Brave1pct Access to Third-Party SDKS Directory. For details about the legal liabilities of third-party SDKS, please refer to the Privacy Policy of the SDK operator.

If you obtain the software and access the Brave1pct service through non-Brave1PCT platforms such as game intermodal channels (such as branded mobile phones or third-party application stores), some channels will access the SDK of the Intermodal channel in the software, which is used to log in to our game products through the channel, pay in advance and provide real-name system functions. In order to ensure that you can successfully log in to our game products and use related services, you need to authorize the SDK of the channel party to provide corresponding services; After your authorization, the channel party will collect your relevant personal information. Regarding the types and purposes of information collected by the channel party, the rules for the protection of personal information and the withdrawal mechanism, please refer to the corresponding privacy policy of the Intermodal SDK in Brave1pct Access to Third-party SDK Directory to understand the specific mutual information collected by the channel SDK and the scope of use according to the specific intermodal SDK you obtain. And the legal liability it bears.
4, to fulfill our obligations under this policy or other agreements we have with you and to exercise our rights.
(2) Assignment
We will not transfer your personal information to any company, organization or individual, except in the following cases:

Transfer with express consent: After obtaining your express consent, we will transfer your personal information to other parties;

When a merger, acquisition or bankruptcy liquidation is involved, such as the transfer of personal information, we will separately inform you of the relevant situation by issuing notices, announcements or other means, and continue to protect your personal information in accordance with the standards required by laws and regulations or require new managers to continue to protect your personal information in accordance with this policy.
(3) Public disclosure
We will only disclose your information in the following circumstances and under the premise of taking security measures:

According to your request, disclose the information you specify under the disclosure method you expressly agree to;

We may disclose your personal information based on the mandatory requirements of laws and regulations, judicial organs or administrative departments;

If we are involved in reorganization, merger or bankruptcy and liquidation proceedings, your personal information may also be disclosed to the counterparties.
(4) Exceptions where prior authorization is required for sharing, transferring, and publicly disclosing information:
(1) Related to the performance of obligations stipulated by laws and regulations by the personal information controller;

directly related to national security and national defense security;
(3) directly related to public security, public health or major public interests;
(4) directly related to criminal investigation, prosecution, trial and execution of judgments;
(5) For the purpose of safeguarding the life, property and other major legitimate rights and interests of the personal information subject or other individuals, but it is difficult to obtain the authorization and consent of the person;

Personal information disclosed to the public by the personal information subject;
(7) Personal information collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.

5.How do we store and protect Personal Information

We store your personal information only for the period necessary for the purposes described in this Policy and for the shortest period required by law and regulations. If we terminate our services or operations, we will promptly stop the activities of continuing to collect your personal information, and we will notify you in advance in accordance with relevant laws and regulations, and delete or anonymize your personal information after terminating our services or operations, except as otherwise stipulated by laws and regulations or regulatory authorities.
(1) Storage of your information

The way and period of information storage
We will store your information in a secure way, including local storage, databases, etc.
Under normal circumstances, we will only store your personal information for the time necessary to achieve the purpose of the service or under the conditions stipulated by laws and regulations. After the above storage period is exceeded, we will delete or anonymize your personal information. However, unless you exercise the right to delete, cancel your account or otherwise stipulated by laws and regulations (for example, the Electronic Commerce Law stipulates that the storage time of commodity and service information and transaction information shall not be less than three years from the date of completion of the transaction).

Location of information storage
We will store users’ personal information collected and/or generated within the territory of the People’s Republic of China (hereinafter referred to as “China”) in the territory of the People’s Republic of China in accordance with the provisions of laws and regulations, except where clearly stipulated by laws and regulations.

Notice when the product or service ceases operation
When our products or services stop operation, we will make a notice in accordance with relevant laws and regulations, and protect your legitimate rights and interests according to law.
(2) Information protection

Technical measures
We will adopt security measures that meet industry standards, including the establishment of reasonable regulations and security technologies to prevent unauthorized access to your personal information, use, modification, and avoid data damage or loss.

System measures
We have full security control over data through access confidentiality agreements, monitoring and auditing mechanisms. We also conduct security and privacy training courses to enhance employee awareness of security and the importance of protecting information.
We only allow Brave1pct employees and partners who need to know this information to access your personal information, and set up strict access control and monitoring mechanisms for this purpose. At the same time, we require all personnel who may have access to your personal information to fulfill the corresponding confidentiality obligations. Failure to comply with these obligations may result in legal liability or suspension/termination of our partnership with Brave1pct.
(3) Response to security incidents
Please be aware that the Internet is not an absolutely secure environment, and the means of communication with other users such as email, instant messaging, social software or other service software cannot be determined to be fully encrypted. We recommend that you use complex passwords when using such tools and pay attention to the security of your information. We will do our best to ensure or guarantee the security of the personal information you send to us. At the same time, you should be aware that due to technical limitations and the limitation of risk prevention, no security measures can be impeccable, and the systems and communication networks used by you to access Brave1pct services may be subject to problems due to circumstances beyond our control.
If an information security incident unfortunately occurs, we will inform you in a timely manner in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, the suggestions you can independently prevent and reduce risks, and the remedial measures for you. At the same time, we will timely inform you of the relevant information of the incident by email, letter, telephone, notice and other means. When it is difficult to inform the information subject one by one, we will take a reasonable and effective way to issue an announcement. At the same time, we will also take the initiative to report the handling of information security incidents in accordance with the requirements of the regulatory authorities.

6.Your Rights

Brave1pct will do its best to maintain the accuracy and completeness of the personal information, and update it in a timely manner, provided that you should ensure that all personal information submitted is accurate.

You have the right to inquire, copy and modify the specific personal information we hold about you
When you need to query, copy and modify your information, you can query and access the basic information of your game account (including avatar, nickname, number, district dress and other your personal information) by clicking “Avatar” - “Settings” in the Brave1pct products you use. The specific game setting function shall prevail), game history information (such as character level, battle power, ranking or specific game information of each product). You can also contact us by clicking the in-game [Feedback] button or by emailing brave1pct@163.com to inquire about the information, and we will process your request within 15 natural days after we receive your question and verify your user identity.

Change the scope of your authorization
If such consent is not necessary for the use of Brave1pct Services, you can change or withdraw your consent for some of your personal information by viewing the “Settings - Privacy Rights” guidelines in the app, or by contacting us at brave1pct@163.com. We will process your request within 15 natural days. After you withdraw your authorization, we will no longer process the corresponding personal information, but your decision to withdraw your authorization will not affect the processing of personal information previously carried out based on your authorization.

You have the right to ask us to delete your personal information
In the following circumstances, you can make a request to us to delete your personal information:
(1) if our processing of personal information violates laws and regulations;
(2) if we collect and use your personal information without your consent;
(3) if we process your personal information in violation of this policy;
(4) If you no longer use the Brave1pct Service, or you cancel your account;
(5) if we no longer provide you with Brave1pct services.
You can contact us through the in-app Settings screen - Feedback - Contact customer service or email brave1pct@163.com, we will process within 15 natural days. If we decide to respond to your deletion request, we will also notify the third party who has obtained your personal information from us and ask it to delete it in a timely manner, unless otherwise agreed by laws and regulations, or the third party has obtained your sole authorization. When you delete information from our services, we may not immediately delete the corresponding information in the backup system, but we will delete such information when the backup is updated.

You have the right to cancel your account at any time
You can contact us at brave1pct@163.com and we will help you close your account within 15 days. After you cancel your account, we will stop providing you with products or services, and the contents, information, data and records under the account will be deleted or anonymized (except as otherwise stipulated by laws and regulations or required by regulatory authorities); At the same time, Brave1pct account, once cancelled, will not be restored.
When you choose to cancel Brave1pct account, or in the case of relevant national laws and regulations, your Brave1pct account will be cancelled. After the account is cancelled, we will delete your personal information according to your request, except as otherwise stipulated by laws and regulations.
Please note that when querying, copying, correcting, updating, changing or deleting the aforementioned information or cancelling the account, we may ask you to provide your mobile phone number, ID number and other personal sensitive information for verification with the real-name authentication information of the account to determine your real identity; The above sensitive information is for verification purposes only, and the customer service will not retain it. Please also understand that, due to technical limitations, legal or regulatory requirements, we may refuse to process a request if we have reasonable grounds to believe that such request is deceptive, unenforceable, or impairs the privacy of others.
If you have logged in to Brave1pct service through game shipping channels (such as branded mobile phones or third-party app stores) and requested to cancel your account, you need to apply to those channels to cancel your account or cancel your authorization to log in to our service. Cancellation of account means that you can no longer log in to Brave1pct service through the channel account, and once the channel account is cancelled, it will not be restored. Please backup all relevant information and data before operation.

Restrict the automatic decision-making of the information system
In some business functions, we may only make decisions based on non-manual automatic decision-making mechanisms including information systems, algorithms, etc. If these decisions significantly affect your legitimate rights and interests, you have the right to ask us for an explanation, and we will provide appropriate remedies.

Respond to your above request
For security purposes, you may be required to provide a written request, or otherwise prove your identity. We may ask you to verify your identity before we process your request. If you have any questions or other requests, you may also contact us using the contact details published in Section 10 of this Policy. For your reasonable request, we do not charge fees in principle, but for repeated requests that exceed the reasonable limit, we will charge a certain cost fee according to the situation. We may refuse requests that are unnecessarily repetitive, require too much technology (e.g., development of new systems or fundamental changes to existing practices), pose a risk to the legitimate interests of others, or are highly impractical (e.g., involving information stored on backup tapes).

We will not be able to respond to your request under the following circumstances:
(1) related to the performance of obligations stipulated by laws and regulations by the personal information controller;
(2) directly related to national security and national defense security;
(3) those directly related to public security, public health or major public interests;
(4) those directly related to the exercise of investigation, prosecution, trial or enforcement of judgments;
(5) where the personal information controller has sufficient evidence to show that the personal information subject has subjective malice or abuse of rights;
(6) In order to protect the life, property and other major legitimate rights and interests of the personal information subject or other individuals, but it is difficult to get the consent of the person;
(7) Responding to the request of the personal data subject will cause serious damage to the legitimate rights and interests of the personal data subject or other individuals or organizations;
(8) where trade secrets are involved.

7.Protection of minors

We will protect minors’ information in accordance with relevant national laws and regulations.
If you are a minor under the age of 18, you should read this policy accompanied by a guardian before using our products and services, and you should ensure that you have obtained the consent of your guardian to use our services and provide us with your information.
If you are the guardian of a minor, if you have any questions about the use of our services by a minor under your custody or the user information provided to us by the minor, please contact us in a timely manner. If we discover that we have collected personal information from a minor without the prior consent of a verifiable parent or legal guardian, we will delete the data as soon as possible.
Please note that we will check the real name information of the relevant account to determine whether the real name information is a minor and your age range, and then decide whether to include this account in the anti-addiction system. In addition, we will collect your login time and game duration information to judge and decide the anti-addiction measures to take, guide minors to play reasonably, and try to contact the guardian of suspected minors after consumption to remind, confirm and deal with, to help minors healthy online.
In particular, if you are a child under the age of 14, in order to protect children’s personal information, we will also comply with the Brave1pct Children’s Personal Information Protection Guidelines (Annex I). Children and their guardians should also read the Brave1pct Children’s Personal Information Protection Guidelines carefully before using Brave1pct services. You may use the Brave1pct Service only after obtaining the consent of the guardian to the Brave1pct Children’s Personal Information Protection Rules and Guardian Instructions.

8.Scope of application of the Privacy Policy

This policy applies to all of our services except for some specific services. Specific Personal Information protection policies for certain specific services will be more specific about how we use your personal information in those services. The Personal Information Protection policies for those specific services form part of this Policy. If there is any inconsistency between the Personal information protection policy of the particular service and this Policy, the Personal information protection policy of the particular service shall apply.

Please note that this policy only applies to the processing of personal information by Brave1pct and does not apply to services provided by other companies or individuals. Specifically, this policy does not apply to information collected by third party services (including any third party websites and applications) that are accessed through our services. This policy only applies to the information we collect and does not apply to any third party services or third party information use rules. If you find that these third party social media or other services are at risk, you are advised to terminate the relevant operations to protect your legitimate rights and interests. We are not responsible for the collection and use of your personal information by these third parties.
Please be aware that if you provide your personal information to a third party while browsing its website or using its products/services, your information shall be subject to the personal information protection policy or similar policy of the third party, and you need to read its policy carefully. We do not bear any legal responsibility for any third party’s improper use or disclosure of the information provided by you, regardless of whether you log in to or browse the above websites, software, or use their products/services based on our links or guidance.

9.Notices and Changes

In order to provide you with a good user experience, we may revise this policy from time to time. When the terms of this Policy are changed, we will inform you of the changed Privacy Policy by announcement, notice, in-game login pop-up or other appropriate means before this policy becomes effective. Please read the changed Privacy Policy carefully. Your continued use of our services means that you agree to our collection, processing or use of your personal information in accordance with the updated Privacy Policy.
This Policy is updated on July 16, 2024 and will become effective on July 16, 2024.

10.How to contact us

If you have complaints and reports about network information security, or you have any questions, comments or suggestions about the privacy measures of this policy and your information, please contact us in time. You can contact Brave1pct customer service through QQ800180502 or email brave1pct@163.com.
We will review the problem involved as soon as possible, and deal with it in a timely manner after verifying your identity, and reply to it within no more than 15 days or within the time limit stipulated by laws and regulations.

11.Application and Jurisdiction of Law

In case of any dispute arising from this policy (including but not limited to the content and implementation of the Privacy Policy), both parties shall settle the dispute through friendly negotiation. If no agreement can be reached through negotiation, both parties agree to submit the dispute to the Tianhe District People’s Court of Guangzhou for jurisdiction and settlement.
Brave1pct Studio
July 16, 2024

Annex I:

Brave1pct Guidelines on the Protection of Children’s Personal Information

Updated: July 16, 2024
Effective Date: July 16, 2024

Brave1pct Studio (hereinafter referred to as “Brave1pct” and “We”), the contact information for personal information protection is: brave1pct@163.com) fully understands the importance of personal information and privacy security of children (refers to minors under 14 years old, the same below). On the basis of Brave1pct Privacy Policy, we set out in Brave1pct Guidelines on the Protection of Children’s Personal Information (hereinafter referred to as the “Guidelines”) our rules on the collection, use, sharing, storage and protection of children’s personal information and other related matters.
Special note:
These Guidelines provide enhanced instructions and guidance on the parts of children’s personal information that need to be strengthened and apply to our activities of collecting, using, storing, sharing, transferring and disclosing children’s personal information through the Internet in the People’s Republic of China. In respect of the rules for the protection of children’s personal information, if there is any inconsistency between this Guideline and the text of Brave1pct Privacy Policy, this Guideline shall prevail. If there is any inconsistency between this Guideline and the text of Brave1pct Privacy Policy, the Brave1PCT Privacy Policy shall prevail.
Before using our products and services, please make sure that children, their parents or other guardians (hereinafter collectively referred to as “guardians”) carefully read and thoroughly understand this Guideline, especially the terms marked in bold/red should be read, and start using after confirming that you fully understand and agree to all the terms.
If you are the guardian, please help us protect your children’s personal information and privacy security, ask them to read and accept this guideline together under your custody, and should use Brave1pct services and submit personal information under your consent and guidance. If you do not agree with the content of this Guideline, Brave1pct service may not operate normally, or cannot achieve the service effect we intend to achieve, you should ask your child to stop accessing/using Brave1pct service immediately. By clicking your consent to these Guidelines, or your child’s use/continued use of the Brave1pct Service or submission of Personal Information, you consent to our collection, use, storage, sharing, transfer and disclosure of your child’s personal information in accordance with these Guidelines (including updated versions).
If you are a child, please inform your guardian to read these guidelines together and to seek your guardian’s consent and guidance before you use Brave1pct Services and submit personal information. By clicking your consent to these Guidelines, or by using/continuing to use the Brave1pct Services or submitting Personal Information, you have obtained your guardian’s permission and your guardian has consented to our collection, use, storage, sharing, transfer and disclosure of your personal information in accordance with these Guidelines (including updated versions).
Please note that we may revise and update these guidelines from time to time, and new policies will be updated in a timely manner. Please keep an eye on our official website to ensure that you are always aware of the latest version of these Guidelines. By continuing to use our Services, you agree to be bound by the revised Policy.
After reading these Guidelines, if you have any questions about these Guidelines or matters related to these Guidelines, you may contact us through the feedback channels listed in the “How to Contact Us” section of these Guidelines and we will answer them as soon as possible.
Contents
1.Personal Information we may collect from children

2.How do we use Children’s Personal Information

3.Circumstances under which we may share, transfer, or disclose children’s personal Information

4.How do we store and protect children’s Personal information

5.Rights of children and guardians

6.Notices and Changes
7.how to contact us

8.Application of law and jurisdiction

1.Personal Information we may collect from children

(1) We will strictly fulfill the obligations and responsibilities for the protection of children’s personal information stipulated by laws and regulations, follow the principles of due necessity, informed consent, clear purpose, security and legal use, and collect children’s personal information after obtaining the consent of the guardian:

In some individual services, we may ask the user to fill in personal birthday information or according to the identity information filled in by the user to identify whether the user is a child, and in accordance with the provisions of laws and regulations, children are allowed to continue to use the relevant Brave1pct services after obtaining the consent of the guardian.
when we identify the user as a child, we may collect the guardian’s contact information (such as mobile phone number, email address), and contact the guardian to verify the guardianship relationship with the child. In order to better protect the rights and interests of the child, we may also collect more information from the guardian (such as the guardian’s name, ID card, household register or other proof of guardianship relationship) to further verify the guardianship relationship between the guardian and the child.

In the process of children using Brave1pct services, we may also collect other children’s personal information. For details, please refer to Article 1 “Information we may Collect” and Article 7 “Protection of Minors” of “Brave1pct Privacy Policy” for detailed understanding. If we need to collect children’s personal information beyond the above scope, we will once again obtain the consent of the guardian.
(2) According to relevant laws and regulations, it is not necessary to obtain the authorization and consent of the child and/or guardian for the collection of children’s information in the following circumstances:
(1) It is related to national security, national defense security, public safety, public health and major public interests;
(2) those relating to criminal investigation, prosecution, trial and enforcement of judgments;
(3) in order to safeguard the life, property and other major legitimate rights and interests of the information subject or other individuals, but it is difficult to obtain the consent of the guardian;
(4) the collected information is disclosed to the public by the child or guardian;
(5) Information is collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels;
(6) Necessary for signing a contract at the request of the guardian;
(7) necessary to maintain the safe and stable operation of the Brave1pct service, such as detecting and disposing of faults of the Brave1pct service;
(8) automatically retaining and processing information through the computer information system and failing to identify the retained and processed information as personal information of the child;
(9) When an academic research institution carries out statistics or academic research in the public interest and provides the results of academic research or description to the outside world, the information contained in the results is de-identified;
(10) other circumstances provided for by laws and regulations.
(3) Tips concerning children’s personal sensitive information
Please note that children’s personal information is sensitive personal information.
The child’s information provided by the child or guardian or collected by us may contain sensitive personal information of the child, such as ID card number, personal biometric information, bank account number, communication records and contents, property information, credit information, whereabouts and track, accommodation information, health and physical information, and transaction information. Guardians and children are requested to be careful and pay attention to children’s sensitive personal information. If guardians or children click to agree to this guideline, or children use/continue to use Brave1pct services and submit personal information, guardians agree to our processing of children’s sensitive personal information according to the purposes and methods described in this Guideline.

2.How do we use Children’s Personal Information

We strictly abide by the provisions of laws and regulations and the agreement with you, in accordance with this guide and the “Brave1pct Privacy Policy” to use the collected information, in order to provide better services to children.

We will use the collected personal information of children in accordance with the provisions of this Guideline and for the realization of the functions of our products and/or services.

After collecting children’s personal information, we will de-identify the data through technical means, and the de-identified information will not be able to identify the subject. The guardian and the child should understand and agree that in this case we have the right to use the de-identified information; And on the premise of not disclosing the child’s personal information, we have the right to analyze the user database and use it commercially.

Please note that all personal information provided by children when using our products and/or services will continue to be authorized to be used by us during the use of our products and/or services unless deleted or refused to be collected by us through system Settings.

We collect statistics on the use of our products and/or services and may share these statistics with the public or third parties to show the overall usage trend of our products and/or services. However, these statistics do not contain any identifying information of children.

When we display children’s personal information, we will desensitize children’s information by means of content replacement and anonymous processing to protect children’s information security.

When we want to use a child’s personal information for other purposes not specified in this Guideline, or when the information collected for a specific purpose is used for other purposes, we will inform the guardian again and obtain consent before using the child’s personal information.

3.Personal information about children that we may share, transfer or disclose

(1) Sharing

In general, we will not share children’s personal information with any third party outside Brave1pct, except in the following cases:
(1) obtain prior express consent or authorization from the guardian;
(2) where necessary in accordance with applicable laws and regulations, legal process requirements, mandatory administrative or judicial requirements;
(3) within the scope permitted by laws and regulations, it is necessary to protect Brave1pct, Brave1pct’s affiliates or partners, children or other players or the public interest, property or safety from damage;
(4) only by sharing children’s personal information can we achieve the core functions of our products and/or services or provide services needed by children;
(5) handle disputes or disputes between the child and others on behalf of the child at the request of the guardian;
(6) provided in accordance with the relevant agreements signed with the guardian and the child (including the electronic agreement signed online and the corresponding platform rules) or other legal documents;
(7) for use based on academic research;
And (8) based on the social and public interest in accordance with laws and regulations.

We may share children’s personal information with our affiliates. However, we will only share necessary personal information about children, subject to the purposes stated in this Guideline and Brave1pct Privacy Policy. If our affiliates want to change the purpose of processing personal information, they will again seek the authorized consent of the guardian.

We may share children’s order information, account information, device information and location information with partners and other third parties to ensure the smooth completion of services provided for children. For details, see Brave1pct Access to Third-Party SDK Directory. However, we will only share children’s personal information for legal, legitimate, necessary, specific and clear purposes, and will only share children’s personal information necessary to provide services. Our partners do not have the right to use the shared personal information of children for any other purpose. For example, companies we hire to provide third-party statistical and analytical services may need to collect and access children’s personal data for statistical and analytical purposes. In such cases, these companies must comply with our data privacy and security requirements. We will only share children’s personal information for lawful, legitimate, necessary, specific and explicit purposes, and only as much as is necessary to provide the service.
We will sign strict confidentiality agreements with the companies, organizations and individuals with whom we share children’s personal information, requiring them to process children’s personal information in accordance with our instructions, these guidelines, Brave1pct Privacy Policy and any other relevant confidentiality and security measures.

To fulfill our obligations and exercise our rights under this Guideline and Brave1pct Privacy Policy or other agreements we have with guardians and children.

To the extent permitted by laws and regulations, we may exchange information with other companies and organizations in order to comply with the law, protect us and our affiliates or partners, children, guardians or other Brave1pct users or the public from damage, property or safety, such as to prevent fraud and other illegal activities and reduce credit risks. However, this does not include information that is sold, rented, shared or otherwise disclosed for profit in violation of the commitments made in these Guidelines.
6, in response to the legitimate needs of the child or authorized by the guardian;
7, at the legal request of the guardian;
8, based on the social public interests in line with laws and regulations.
We will only share children’s personal information for legal, legitimate, necessary, specific and clear purposes. We conduct security assessments and sign strict confidentiality agreements with the companies, organizations and individuals with whom we share personal information, requiring them to process the information in accordance with our instructions, these Guidelines and any other relevant confidentiality and security measures.
(2) Transfer
We will not transfer children’s personal information to any company, organization or individual, except in the following cases:

Transfer with the express consent of the guardian: After obtaining the express consent of the guardian, we will transfer the child’s personal information to other parties;

When a merger, acquisition or bankruptcy liquidation is involved, if the transfer of children’s personal information is involved, we will separately inform the guardian of the relevant situation through notices, announcements or other means, and continue to protect the children’s personal information in accordance with the standards required by laws and regulations or require the new manager to continue to protect the children’s personal information in accordance with this Guideline.
Item (3) Public Disclosure
Please note that we do not disclose personal information of children except in the following circumstances and under the premise of adopting industry-standard security measures
1, according to the needs of children or guardians, in the manner of disclosure agreed by the guardian to disclose their designated information;

Where children’s information is required by laws, regulations, mandatory administrative law enforcement or judicial requirements, we may disclose children’s information according to the type of information and disclosure method required. Under the premise of complying with laws and regulations, when we receive the above request for disclosure of information, we will require the recipient to produce the corresponding legal documents, such as subpoenas or investigation letters. We strongly believe that we should be as transparent as possible about the information we are asked to provide to the extent permitted by law. We carefully review all requests to ensure that they have a legitimate basis and are limited to data that law enforcement has a legitimate right to obtain for specific investigative purposes.
(4) Exceptions to obtaining prior authorized consent for sharing, transferring or disclosing information:
In the following circumstances, it is not necessary to obtain the prior authorization and consent of the guardian for the sharing, transfer and disclosure of children’s information:
(1) Related to national security and national defense security;
(2) related to public security, public health or major public interests;
(3) Related to judicial or administrative law enforcement such as criminal investigation, prosecution, trial and execution of sentences;
(4) In order to safeguard the life, property and other major legitimate rights and interests of children or other individuals, but it is difficult to obtain the consent of the guardian;
(5) Information disclosed to the public by the child or guardian;
(6) Information collected from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.
According to the law, sharing, transferring and disclosing personal information that has been de-identified, and ensuring that the data recipient cannot recover and re-identify the information subject, does not belong to the sharing, transfer and public disclosure of personal information to the outside world, and the preservation and processing of such data will not need to notify the guardian and obtain the consent of the guardian.

4.How do we store and protect children’s Personal Information

(1) The storage of children’s personal Information
We store children’s personal information only for the period necessary for the purposes described in these Guidelines and for the shortest period required by law and regulation. If we terminate our services or operations, we will promptly stop the activities of continuing to collect children’s personal information, and we will comply with the requirements of relevant laws and regulations to notify the guardian in advance, and delete or anonymize children’s personal information after the termination of services or operations, except as otherwise stipulated by laws and regulations or regulatory authorities.
(2) Protection of children’s Personal Information

Technical measures
We will adopt industry-standard security measures, including the establishment of reasonable rules and regulations, security technology to prevent children’s personal information from being unauthorized access, use, modification, to avoid data damage or loss.

Institutional measures
We implement the principle of minimum authorization for staff, strictly set information access rights, and control the scope of children’s personal information; Staff accessing children’s personal information shall be subject to the approval of the person in charge of the protection of children’s personal information or their authorized managers, record the access situation, and take technical measures to avoid illegal copying and downloading of children’s personal information.
(3) Handling of security incidents
If we find that children’s personal information has or may be leaked, damaged or lost, we will immediately launch an emergency plan, take remedial measures, and inform the affected guardians and children of the relevant circumstances of the incident by mail, letter, telephone, notice, announcement and other means.
Please be aware that due to technical limitations and risk prevention limitations, even if we have tried to strengthen security measures, we can not always guarantee the safety of information 100%. Guardians are aware that the systems and communication networks used by children to access Brave1pct services may be compromised due to circumstances beyond our control.
Please keep Brave1pct pass account number, password and other identification information. When children use Brave1pct services, we will use the account number, password and other identification information to identify them. Once the guardian and children disclose the above information, they may suffer losses and may have adverse effects on themselves. If the guardian or child finds that the account number, password and/or other identity information may be or has been leaked, please contact Brave1pct at brave1pct@163.com immediately, so that we can take appropriate measures in time to avoid or reduce related losses.

5.How do we manage children’s personal information

(1) Access to children’s Personal Information
Guardians and children can query and access the basic information of your game account through the main interface [Avatar] - [Settings] in the app; They can also contact us at brave1pct@163.com to view the children’s personal information provided or generated by them in using Brave1pct service, such as personal information, some usage records, and published content.
(2) Modifying and correcting children’s Personal Information
We encourage guardians and children to update, correct and correct children’s personal information to make it more accurate and effective. Guardians and children who find errors in the personal information collected, used and processed by us can contact us at brave1pct@163.com to correct them. We will take timely steps to correct them after completing identity verification and verifying the problem.

Delete children’s personal information
According to the specific circumstances of the child’s choice of Brave1pct service, the guardian and the child can delete the child’s personal information by contacting us at brave1pct@163.com during the use of Brave1pct service, and we will deal with it within 15 natural days. In the following cases, the guardian and the child can directly make a request to us to delete the child’s personal information, and we will take timely measures to delete it after completing the identity verification and verification questions, including:

We collect, store, use, transfer or disclose children’s personal information in violation of laws and regulations or the agreement with the guardian and children;
(2) Collecting, storing, using, transferring or disclosing children’s personal information beyond the scope of the purpose or the necessary time limit;
(3) where the guardian withdraws consent;

The guardian or the child terminates the use of Brave1pct services through cancellation or other means.
However, please note that if the guardian or child deletes or requests us to delete certain children’s personal information, it may result in the inability to continue to use all or part of Brave1pct services.

(4)Cancel your account
Under the conditions stipulated in the Brave1pct service Agreement and relevant laws and regulations, we also provide the cancellation of registered accounts. Guardians and children can contact us at brave1pct@163.com to cancel the account, and we will assist you to cancel the account within 15 natural days. After cancelling your account, we will stop providing you with products or services.
(5) Change the scope of authorization
Guardians and children always have a choice whether or not to disclose information. Some information is necessary to use Brave1pct services, but most other information is provided at your discretion. Guardians and children can change the extent to which they authorize us to continue to collect information or withdraw their authorization by deleting the information, turning off device features, etc.
When guardians and children withdraw authorization, we cannot continue to provide the services corresponding to the withdrawal of authorization, and we will no longer process the corresponding information. However, the decision to withdraw authorization will not affect the information processing previously carried out based on the authorization of the guardian and the child.
(6) Contact and consultation
When querying, copying, correcting, deleting the aforementioned information or applying for the cancellation of the account, we may require the guardian and/or the child to verify their identity in order to ensure information security. Unless otherwise provided by laws and regulations, when guardians and children correct or delete children’s personal information or apply for account cancellation, we may not immediately correct or delete the corresponding information from the backup system, but we will correct or delete such information when the backup is updated. If you need, you can contact the customer service of Brave1pct at brave1pct@163.com. We will respond to your request within a reasonable time.
Please also understand that, due to technical limitations, legal or regulatory requirements, we may refuse to process a request if we have reasonable grounds to believe that such request is deceptive, unenforceable, or violates the privacy of others.

6.Notices and Changes

In order to provide you with a good user experience, we may revise these guidelines in due course. When the terms of these Guidelines are changed, we will notify you by notice, notice or other appropriate means before the new Guidelines become effective. Please ask your guardian to read the changed guidelines carefully, and if the guardian does not agree with such changes, he/she should ask the child to stop using Brave1pct services; If the child still continues to use Brave1pct services, the guardian has fully read, understood and agreed to be bound by the revised guidelines.
Such third party social media or other services are operated by the relevant third party. Your use of such third parties’ social media services or other services (including any information you provide to such third parties) is subject to the third parties’ own Terms of Service and Information Protection Statement (not this Policy), and you are required to read their terms carefully. This policy applies only to the personal information we collect and does not apply to any third party services or third party rules on the use of that information. If you find that these third party social media or other services are risky, we suggest that you terminate the relevant operations to protect your legitimate rights and interests.

7.How do I contact Us

If you have complaints or reports about online information security, or if you have any questions, comments or suggestions about the privacy measures in this Guideline or about children’s personal information, please contact us in time. You can contact game customer Service through in-game feedback or email to brave1pct@163.com.
We will review the problem as soon as possible, and deal with it in a timely manner after verifying your identity, and give a reply within no more than 15 natural days or within the time limit stipulated by laws and regulations.

8.Application of law and jurisdiction

Any dispute arising from these Guidelines (including but not limited to the content and implementation of these Guidelines) shall be settled by both parties through friendly negotiation. If no agreement can be reached through negotiation, both parties agree to submit the dispute to the Tianhe District People’s Court of Tianhe for jurisdiction and settlement.

Brave1pct Studio
July 16, 2024

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