Privacy Protection Policy
Smilecobra Capital LTD ("we", "us", or "our") understands that protecting your privacy is our priority. We are based on different legal reasons and permissions to process your data when we get your consent, we will balance the interest and your right. This policy explains what personal information we collect, how we process it, and for what purpose. Please read it carefully, as it is important for you to understand your rights.
To the extent permitted by applicable law, children under the age of 13 (or other age threshold required by local laws) are not allowed to create an account for our services. If you are 13 above but are considered a minor in your country (e.g. under 18 years old in some jurisdictions), you must have your parent or legal guardian read this Privacy Policy with you and you represent that you have obtained the permission of your parent or guardian to create your Account.
If you are a parent or legal guardian of a minor in your country, please make sure that you have read this Privacy Policy before allowing your children to create their own accounts or to use the Services. You agree that you will be subject to this Privacy Policy and be responsible for your children’s activities while using our Services. You agree to supervise your children’s use of our services and ensure they access only age-appropriate content .
What is ‘personal data’?
‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
We collect data that you have produce or input through our products, we hope to give you a better experience with our products.
We collect your data to be able to offer you products that are adapted to you and your needs.
We may collect your data when:
A. You create an account (hereinafter referred to as your ‘account’).
When you create the Account, we may collect your username, email address, mobile phone number, birthday, password, verification code and Open ID, to help you create and manage the account for your use of our services, to provide game login services.
B. You sign into our services with a social login（for instance like, Google, Facebook）.
When you log in through Google or Facebook or other third-parties on our platform, we collect your third-party email account, profile picture, and nickname that you have agreed to share with us in question.
C. You make a purchase in our games or in our online services.
We need the data to process your purchase requirements, such as your email address, bank details and purchase history. These data are sent to our partner who provides in charge of the payment and the delivery of your purchase.
D. You use our games, applications, websites and online services on a computer or mobile phone.
we collect:
l Your game data, to improve your game experience and the security of our services such as: statics data including the use of the various features as well as the data associated with any bugs or malfunctions.
l Your login and browsing data, to make sure your account is in a safe situation, such as: identifier of your device, connection information(IP address, mac address), login dates and times, information about the browser and the operating system you use.
E. You interact with other players.
We collect Data such as your user name, IP address, date, time, communication record and we save the content of your messages from allowing you to interact with other players in a secure and friendly environment.
F. You are exposed to personalized advertisements or content by our services or those of our partners.
We collect data such as: your gender, age, location and the identifier of your advice.
G. You take part in a contest or survey organized by us.
We collect your last name, first name, date of birth, mailing and email addresses.
We use this Data to administer the contest or the survey for internal statistical purposes.
H. You contact us via the customer support portal or social media.
If you contact us via the Customer Support portal, we collect data such as your last name, first name, username, email address, date of birth, country, console identifier and games registered on your Account, depending on your questions or requests.
If you contact us via social media, we collect some of the Data included on your profile.
We only use this Data to respond to your questions and requests appropriately.
I. For the security of game operations.
To ensure security and stable operation, provide a fair gaming environment, prevent cheating and improve the functionality and quality of COGNOSPHERE services and other purposes as set forth in Section 2 of this Privacy Policy, we may automatically collect data using mechanisms like cookies, browser web storage, and application data caches. The categories of data we automatically collect include device related data (including device ID, device name, device type/model, MAC address, IMEI data, OS version and language, time zone, screen DPI, device resolution and memory data), data related to bugs, errors, crashes and diagnosis (including registration/login time, game version, UID, stacktrace, crash reports, abnormal process data) and other data related to security (including installed APK names , startup time, request and referral URLs, and system activity details, game-related plug-in and runtime data, and data related to external plugin programs) . We also automatically collect data about your interactions with our services, such as the pages and other content you view, any content you post, and the dates and times of your visits.
Whether minors could use our services or products depends on the law of each country.
We use your data to:
l Verify and confirm payments.
l Ensure you can access or restrict your access to our services.
l Correct bugs or errors.
l Establish, exercise, or defend legal claims.
l Improve our products and enhance your user experience.
l Analyze our products and services for business purposes.
l Offer personalized services or products and provide recommendations.
l Conduct advertising and marketing, including targeted advertising and applicable discounts.
l Communicate with users (including sending text messages and/or push notifications) and address violations.
We process your data using automated and manual methods, also we improve our processing method continually.
Unless the law specifies a precise period, we will only store your personal data for the minimal time necessary to guarantee our service.
For instance, we will keep your personal data associated with your account live until you log-off your account. In some situations, we need to keep the data longer, such as when it is needed for some legal issues.
The locations of servers for the game services include:
l HongKong China
l TaiWan
l Singapore
To implement some services, we need to share your data with third parties, but we do that only to get your consent or if it`s necessary for you.
l We share your data with our subsidiaries.
l The technical service providers who provide our services (for instance: product delivery, promotion of the Services, to act against inappropriate conduct, cheating and toxic behavior).
l Judicial authorities, we will verify if they have permission and the data use of the purpose, in compliance with applicable law.
l To protect our customers, for instance, to prevent spam or criminal attempts to defraud the users of our products.
l Social networking portals who provide login and/or content-sharing service to and in our services;
l Logistics service providers who provide shipping services such as delivering physical prizes to users;
l Information communication service providers who provide SMS-messaging services;
l Payment service providers who provide payment services, such as assisting our services to run on, facilitating users’ payment, and maintaining a record of the users’ transaction history;
l Advertising service contractors who provide marketing and advertising activities, including showing you ads that we think may interest you, conducting the programs, tracking the success, and analyzing the effect thereof; and
l Other contractors if any for the purpose of providing our services to you.
We may also disclose your information with your permission.
We are respectful of your rights, for instance, if you no longer wish to receive marketing messages anymore, you may click the unsubscribe button to stop receiving that messages.
l Right of access and data portability: you could request a copy of your data associated with your account. You could check your data or transfer it to other service providers at any time. You could contact our customer services to take your data.
l Right to rectification: you have the right to correct your data if it is inaccurate (for instance, change your age, gender, or other profile). You could visit our website or app to correct your profile.
l Right to object and withdraw your consent: you could withdraw your consent or object to the receipt of newsletters or advertising email, you could change the setting:
n For some of our mobile games, in privacy settings.
n On the app to change your permission of receipt advertising email.
n on your telephone or your tablet, in the settings, by activating “Limit Ad Tracking” on Apple telephones, or activating “Opt-out of Ads Personalisation” on Android telephones.
l Right to erasure(right to be forgotten): you could request us to closure your account and delete the associated data with it. If you want to do so, please contact our customer services they will help you to finish it.
l Right to restriction of processing: You also have the right to request that your Data no longer be used during the time we are processing your request. To do so, please contact our customer services.
We take a range of measures to protect your information.
l We encrypted your personal data.
l We have various security equipment like IDS, IPS, etc.
l We have an internal security management procedure to constrict people to access your data.
Even we do so, no security measure is perfect. We cannot guarantee the security of your data and do not assume any responsibility for the unauthorized use or access to your information under our control.
We may update this privacy policy by law issues or other regulatory requirements. When we update this document, we will meanwhile update the “last updated” date. If there are some material changes to this policy.
If you have any questions about this document, please contact:
l The data protection team email address: Smilecobra2025@outlook.com
If you have any question about this document, please contact us we will respond to you as soon as possible. You have your right come from the law you could contact a data protection authority if you prefer. Data protection authorities in Europe list at:
https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080