This Privacy Policy (the “Policy”) explains when, how and why your personal data in connection with Amazing SeaSun Website(the “Website”) and Seasun Games Installer (the “Installer”) content, functionality, product and any related services, whether in whole or in part, provided by us (collectively, the “Services”) is processed. This Policy deals with where we are acting as a “Data Controller” under the data protection legislation, that is, where we are responsible for deciding what personal data we collect and how we use it. 

As your privacy matters to us, we encourage you to read this Policy carefully to understand how your data is collected, used, and controlled.

In this Policy:

“We”, “Us” and “Seasun” refer to SEASUN GAMES PTE.LTD. and its Affiliates.

“Affiliates” refer to entities that directly or indirectly control, are controlled by or are under common control with SEASUN GAMES PTE.LTD. In some cases, our Affiliates may be considered data controllers.

“Personal Data” refers to any information that can be used to identify you either directly or in combination with other data.

We are committed to protecting and respecting the personal data of everyone we deal with—this is important to us, and we know it's important to you.

In this Policy, you will find data about what types of personal data we hold about you, how and why we collect it, how we use it, and how we keep it secure. You will also find here information about your rights and how you can exercise them.

If you reside in or use our Services from a country or region specifically listed under the Section “Country/Region-Specific Terms” below, those specific terms and conditions under the relevant country/region will apply to you.

Please read this Policy carefully. For any inquiries regarding this Policy or your personal data, contact us by email at support@seasungames.com

 

You are deemed to accept the terms of this Policy, and to expressly acknowledge and, where required, consent to our processing of the information you provide to us for the purposes outlined in, or otherwise in accordance with this Policy. If you do not agree with the terms of this Policy, please do not continue to use our Services; and in the case of Seasun Games Installer/ Seasun Games Website, please uninstall the applications/ do not register an Amazing Seasun account immediately and do not continue to use the Service. Your access and use of Seasun Games Services is also subject to our Terms of Service, and all capitalized terms not defined in this Policy will have the meanings set forth therein.

 

1. Parental and Guardian Consent

2. What Data We Collect, How We Use It and The Legal Basis

3. Data Storage and Retention

4. Data Security and Protection

5. To Whom We May Disclose or Transfer Your Data

6. International Data Transfer

7. Your Rights and Choices

8. Cookies

9. Updates to the Policy

10. Contact Information

SUPPLEMENTAL TERMS: Country/Region Specific Terms

 

 

1 Parental and Guardian Consent

OUR SERVICES ARE NOT INTENDED FOR CHILDREN UNDER THE MINIMUM AGE, NOR DO WE KNOWINGLY COLLECT DATA FROM CHILDREN BELOW THIS AGE. 

1.1 ANYONE UNDER THE AGE OF 13 （US/JAPAN/UK）/ 14 (KOREA )/16(EU )OR THE MINIMUM AGE OTHERWISE DEFINED IN “COUNTRY / REGION SPECIFIC TERMS" UNDER THE APPLICABLE LAWS OF YOUR JURISDICTION (“MINIMUM AGE”) SHALL NOT USE SEASUN GAMES WEBSITE/INSTALLER OR CREATE A GAME ACCOUNT. WE DO NOT KNOWINGLY COLLECT OR STORE ANY PERSONAL DATA FROM CHILDREN UNDER THE  MINIMUM AGE WITHOUT PARENTAL PERMISSION.

 

1.2 If you are a minor in your country or region, your use of Seasun Games Website/Installer may be further restricted by age limitations imposed by us or third-party vendors providing certain Services. You may be unable to use or only have limited access to those Services, such as, where applicable, some games with age restrictions, participating in rewards programs, top-up and tipping, without the assistance of your parent or legal guardian.

 

1.3 If you discover that a child under the Minimum Age has registered an Amazing Seasun Games Account or an Account of a child under the Majority Age was not registered under proper supervision, representation or guardianship, you may alert us at support@seasungames.com. We will promptly investigate, remove the child’s Account information from Seasun Games Website/Installer and terminate the Account.

 

2 What Data We Collect, How We Use It and The Legal Basis

 

We collect personal data to the minimum scope necessary for the provision of Seasun Games Website / Installer. The personal data we collect may be provided by you or, in case of usage data, collected automatically when using our Services.

 

2.1 We may collect the following categories of Data from and about you:

• Registration and contact information, such as email address,and other information such as nationality,When you sign into our Services via your third-party platform account (for example, Steam ID), we may collect personal data that you have agreed to share via social media or third-party platforms, such as your user ID, nickname .

• Age information, which will be verified to confirm whether we can provide you with our services and limit your top-up amount (Japan and Republic of Korea only)

• Network and device information, which is collected to ensure security and stable operation, resolve bugs or errors, provide a fair gaming environment, prevent cheating and improve the functionality and quality of our Services. We will collect relevant device information including but not limited to device ID, device model, device language and version, OS name, OS version, time zone, system logs at the time of the crash, server access log, user ID, password, token, digital certificate, IP address, device characteristics, and cookies;

• Payment Data, which is collected in order to enable you to buy virtual items and use the payment service. We will collect your payment data provided by a third party when you make purchases with your Account, such as Payment Status, Payment Order details;

• Location, such as information you provide to the platform relating to your address or location and geolocation information derivsed from your device information based on your,IP address;

• Behavioral information, such as the information generated when you use the platform and other products, including your browsing and operation records.

The categories and scope of Data we collect about you may vary from time to time, depending on your choice of and interaction with Seasun Games Website/Installer, as well as the country or region where you use Seasun Games Website/Installer.

Where application features are available, you may choose to browse certain content on the Website and Installer without logging in or registering.

 

2.2 We may collect Data from you and about you from the following sources:

2.2.1 From you: We collect information that you voluntarily provide when you download our application/using our Services, create an account, interact with Seasun Games Website/Installer, or otherwise contact us with a question, comment, or request.

2.2.1 From your devices: We and our service providers may automatically collect certain network and device information from your computers or mobile devices once you login or activate Seasun Games Website/ Installer service, such as your browser type, language and version, operating system, error and service access logs, clipboard information, model of your device, time zone settings, network type,Wi-Fi information, and user action logs on Website/Installer.

This information allows us to recognize you and personalize your experience if you return to Seasun Games Website. We and our service providers may collect this information using “Cookies”. More information about our use of cookies can be found in the “Cookies” section below. We may collect such information over time and across different websites or services or across different devices from which you surf on Seasun Games Website/Installer.

2.2.3 From third parties: We may obtain information about your Seasun Games Services usage from third parties and other sources, such as other users of Seasun Games Website/Installer and vendors, including creator agencies, webhosting providers, analytics providers, or other business partners. To the extent we allow for third party social media integrations in Seasun Games Services, the information we may obtain from third party services depends on your account/privacy settings with those third parties and the third parties’ privacy policies. When accessing Seasun Games Website/Application through third party-platforms, you authorize us to collect, store and use such information according to this Policy. Information provided by third parties may also be subject to their privacy policy.

 

2.3 How We Use Your Data

We may use your Data for various of purposes related to operating our business and providing Seasun Games Website/Installer, including:

 

2.3.1 Account registration and signing in

When you set up or sign into Seasun Games Website/Installer, your registration and contact information such as email address and other information you choose to provide may be collected to create your Account.

When you sign into Seasun Games Website/Installer via your third-party platform account (for example, Steam ID), we may collect personal data that you have agreed to share via social media or third-party platforms, such as your User ID. Such data obtained from third-party social media providers will be incoperated into your account information.

The processing activity is necessary for the performance of the contract between you and us.

 

2.3.2 Identification and authentication

We use your Data to verify your identity and eligibility across Seasun Games Website/Installer when you access and use our services, such as receiving rewards or prizes, or otherwise engaging with us, and to protect the security of your data. In some instances, we use your data to verify your age in order to provide certain services to you in order to fulfill your request in relation to your Data.

The processing activity is necessary for the performance of the contract between you and us.

 

2.3.3 Fairness, security and service improvement

To ensure security, stable operation, bug resolution, fair gaming environment, cheat prevention and Services improvement, we may collect specific device information and your activity operation records, including your IP address, MAC address, Browser Type, Device Language and Version, Operating System Name and Version, Error and Service Access Logs, Device Model, Time Zone Settings, CPU, GPU, RAM, Device ID, Network Type, Wi-Fi Information and User Action Logs on the platforms, and we may conduct data analysis as appropriate.

The processing activity is based on our legitimate interest.

 

2.3.4 Payment processing

To enable you to buy virtual game coins and use the payment service, we will collect your purchase order details and payment data provided by third parties when you make purchases with your Account, such as product details, product prices, and purchase order number etc. We may use this data for billing and payment processing purposes, to distribute awards to you, or to enable payments through third-party payment systems.

The processing activity is necessary for the performance of the contract between you and us.

 

2.3.5 Customer support

When you contact us for customer support, we need to collect your personal data, such as your email address, region, server, platform type, issue description and communication records of the issues you experience.

The processing activity is necessary for the performance of the contract between you and us.

 

2.3.6 Newsletter or promotion

When you subscribe to our newsletter or promotional information, we may collect your email address to send you messages. Newsletter or promotion service may include, for example, providing information about our products and services, changes to the terms of service, updates regarding our services, user information reports on users who are minors.

The processing activity is based on your consent.

 

2.3.7 Survey

When you participate in our survey, we will collect your email address and feedback to help us improve the quality of our products and services.

The processing activity is based on our legitimate interests in improving our products and services.

 

Our legitimate interests

We process your personal data based on our legitimate interests as a commercial organization. Our legitimate interests include maintaining and administrating services, providing the services to you, managing the content ecosystem across Seasun Games Website/Installer, enabling application features or special effects, facilitating third-party partnerships or integration, monitoring and testing Seasun Games Website/Installer, troubleshooting, allowing you and other users to connect with each other, maintaining and improving algorithm, ensuring your account is adequately protected, and, complying with any contractual, legal or regulatory obligations under any applicable laws.

 

Other legal bases

Beyond the aforementioned legal basis for processing, we may process your personal data when:

l Processing is necessary for compliance with a legal obligation to which we are subject;

l Processing is necessary to protect the vital interests of the data subject or of another natural person;

l Processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us;

l Processing is for scientific or historical research purposes or statistical purposes in accordance with applicable laws.

 

For the purposes set forth above, our Affiliates may be commissioned to process your data, provided that such Affiliates comply with the terms in this Policy.

 

3 Data Storage and Retention

3.1 We store your data on our servers located in Singapore. Our global support, engineering, content moderation, and other functional teams are located around the world to support Seasun Games Website/Installer. We have rigorous internal control measures in place to strictly limit data access to designated personnel only. We take appropriate steps to ensure that recipients of your personal information are bound to duties of confidentiality and we implement appropriate technical and organizational measures to ensure your personal information will remain protected in accordance with this Privacy Policy, such as standard contractual clauses.

3.2 We retain your data only while your account is active or as needed for our Services, unless you request deletion of such data or the law requires otherwise. Retention purposes include:

(i)  Achieve the purposes as set out in this Policy;

(ii) Meeting applicable laws and regulations, including any requirements to retain data for a certain period of time, taking into account the statute of limitations under applicable laws and regulations;

(iii) Serving our legitimate and lawful purposes, including for our business, and provision of Seasun Games Website/Installer; and/or

(iv) Defend against any actual, threatened or potential claims or disputes.

3.3 If you opt out from marketing, we retain your data to ensure compliance with your marketing preferences

4 Data Security and Protection

4.1 We will take appropriate technical and organizational measures to protect your data against unauthorized or unlawful processing, accidental loss, destruction, or damage through these measures, including:

(i) using encryption techniques;

(ii) establishing specialized systems and procedures, such as strictly limiting the scope of personnel with access to your data, and requiring those who have such access to comply with relevant confidentiality obligations; and

(iii) forming a specialized department in charge of information security. In the event of incidents such as information leakage or data or security breach, we will take timely measures to handle such incidents, and we will notify you promptly in an appropriate manner, including through messages or announcements.

4.2 We endeavor to ensure that, by default, we only collect and process your data needed to provide Seasun Games Website/Installer. We also apply this principle to our data privacy and protection controls into our processing activities. This means that we will neither publish nor share your data by default.

4.3 While we are committed to protecting your data, no electronic data transmission or storage of information can be completely secure. If you do not accept these risks and conditions, you must discontinue using Seasun Games Website/Installer.

5 To Whom We May Disclose or Transfer Your Data

5.1 We will not disclose or transfer any of your data to any third parties except as explicitly stated in this Policy. We will only share your data with third parties in the following circumstances:

(i) you (or your parent/legal guardian) have approved;

(ii) as required for administrative or judicial purposes, including any requirements of competent authorities, courts and regulatory bodies;

(iii) necessary to protect our legal rights in proceedings against you;

(iv) permitted under the terms of service;

(v) required to protect our, your, or public interests; or

(vi) pursuant to the agreements made by you with any other third parties.

5.2 We may share your data with our Affiliates, group members, and the following third parties (“Details”), who will only use your data in accordance with this policy to facilitate the provision of Seasun Games Website/Installer to you or for other purposes as indicated below.

(i) Affiliates

Seasun is a global company and has Affiliates all over the world. In order to provide our Services, we will share your personal data with our Affiliates based on the respective legal basis and data processing agreements signed between us.

（ii）Mergers, acquisitions or asset sales

We may transfer your data to another legal entity for the purposes of a collaboration, joint venture, corporate reorganization, change of legal form or other similar event. In order to develop our business, we may engage in transaction such as mergers, acquisitions, sales and asset transfers. In these circumstances, we will inform you of the related transactions, and will continue to protect or require the successor to protect your data in accordance with applicable laws and regulations and this Policy.

(iii) Third parties in support of Seasun Games Website/Installer

We may engage or cooperate with third parties to perform functions or provide services. We share your data with these service providers for purposes such as hosting or operating our Services, payment and transaction processing, rewards, vouchers and commercial goods delivery (where applicable), cloud services, e-mail communication, research, survey, marketing and data analysis services. We will only share your data on a need-to-know basis with third parties in order for them to perform corresponding functions and services, and we will request such parties to maintain appropriate security measures to protect such data from unauthorized access or processing.

(iv) Legal, regulatory or government authorities

We may in limited cases transfer game data to local (where you reside) or overseas authorities such as legal, regulatory, law enforcement, government and tax authorities, to satisfy our obligations or those of third parties (when they receive a request from an authority empowered by law to do so), pursuant to applicable laws and regulations.

(v) Promotion service provider

If you choose to register for a promotion, such as a competition, sweepstakes, lucky draw, contest, reward program for user or creators, your data may be disclosed to third parties for the purposes of administering such promotion.

 

5.3 Except as otherwise provided in this Policy, we will not disclose any of the data collected from your use of Seasun Games Website/Installer to the public, unless otherwise stipulated by applicable laws and regulations. 

6 International Data Transfer

We process and back up personal information through a global operating and control infrastructure. Currently,we have support, engineering, content moderation, and other functional teams located around the world to support our Services.

Data disclosure under in this Policy may involve a transferring of your data to countries and regions with provide different levels of data protection. The aforementioned countries or regions may not have the same data protection standards as your jurisdiction and will not afford many of the rights conferred upon data subjects in your jurisdiction. We carefully evaluate that applicable legal and regulatory requirements are taken into consideration before any cross-border transfer of your data takes place, and our policies are as follows:

(i) We may share your data with group entities in other jurisdictions for internal, business and operational purposes in order to provide Seasun Games Website/Installer. We implement rigorous internal control measures in place to strictly limit data access to designated personnel only.

(ii) To provide Seasun Games Website/Installer to you, we may transfer your data internationally to non-affiliated entities, strictly following international transfer mechanisms permitted under applicable laws and regulations.

If you wish to understand appropriate or suitable safeguards and the means by which to obtain a copy of them or where they have been made available, you can contact us by email at support@seasungames.com.

7 Your Rights and Choices

7.1 Under applicable laws and regulations, you may have the right to access, rectification, erasure, and certain other rights in relation to your personal data that we collect and process (hereinafter referred to as the "Request"). These rights will be subject to specific exclusions and exceptions under applicable laws.

(i) You have the right to be informed in a concise, transparent, intelligible and easily accessible form of the way in which your data is processed. You also have the right to obtain confirmation as to whether your data is being processed, and where that is the case, to access such information and obtain a copy thereof.

(ii) You have the right to request rectification of your data. You also have the right to have incomplete data completed, and have the data out of date updated.

(iii) You have the right to request us to erase some or all your personal data.

(iv) Where you have provided your consent, you may withdraw your consent. If you withdraw your consent, we may continue processing your data to the extent permitted by applicable laws.

(v)  You have the right to request us to restrict the further processing of your personal data. In such cases, the respective data will be marked as restricted, and may only be processed by us for certain purposes.

(vi) You have the right to object, on grounds relating to your situation, to the processing of your personal data by us, and we may be required to no longer process some or all your personal data. You have the right to object to the processing of your personal data for direct marketing purposes.

(vii) You have the right not to be subject to a decision based solely on automated processing where the decision has a significant legal impact on you.

(viii) You have the right to receive a copy of your personal data which you have provided to us, in a structured, commonly used, and machine-readable format, and you have the right to request the transfer of that personal data to another entity without hindrance from us.

(ix) You can ask us to delete your Account, which is an irreversible process as you will not be able to access your Account upon deletion, and all data in relation to the Account will be deleted or de-identified, subject to any statutory retention requirements under applicable laws and regulations.

 

You may also have other rights as described under the "Country/Region-Specific Terms" section below or otherwise under local laws.

 

7.2 Before fulfilling your Request, we will verify your identity. We will respond to your Request within legal timeframes. We may refuse your Request (for example, if your Request may infringe on the privacy of others, exceed the provisions of applicable laws, etc.), and when we refuse, we will inform you of the specific reasons. For unresolved concerns, you can hand over the complaint to the data protection regulatory authorities in your jurisdiction. We'll provide relevant complaint mechanism information upon request.

 

7.3 If you are one of our customers or have otherwise agreed to be contacted for marketing purposes, we may use your personal data to send you information about us and our Services. You can unsubscribe from receiving direct marketing at any time and details of how to unsubscribe will be included in any marketing communications we send you. You also have the option of "unsubscribing" from our mailing list at any time, thereby disabling any further such email or other communication from being sent to you by emailing support@seasungames.com.

8 Cookies

To enable our systems to recognize your browser or device and to provide and improve our services, we or our authorized service providers may use cookies, beacons and/or other similar technologies (collectively, “Cookies”). For more information about the types of Cookies we use, why, and how you can control them, please read our Cookies Policy.

 

9. Updates to the Policy

We may update, change or modify this Policy from time to time, and such changes shall form a part of this Policy. You'll be notified through Service announcements or login notifications when you log into the Website/ Installer or update the Installer. Updates are effective upon notification and apply to all data unless stated otherwise.

For significant changes affecting your rights, we will notify you and obtain your consent.

 

10. Contact Information

For any complaints, suggestions or inquiries regarding this Policy or the collection, usage, storage, protection and other functions of your data, please contact us or our Data Protection Officers via emailing support@seasungames.com

We will respond to your inquiry as soon as possible, within the timeframes required by applicable laws. If you are not satisfied with our response to your privacy or data protection concern, please submit a complaint to our independent U.S.-based dispute resolution provider at no cost to you: https://feedback-form.truste.com/watchdog/request.