Welcome to use Heropub software and related services. “Hero Entertainment” refers to the service provider -- HK HERO ENTERTAINMENT CO., LIMITED. -- with which you sign this Policy, and any affiliates that may exist when you receive or use an individual service, also known as “we”, “us” or “our” in this Policy. The registered address of HK HERO ENTERTAINMENT CO., LIMITED. is FLAT/RM 1903 19/F LEE GARDEN ONE 33 HYSAN AVENUE CAUSEWAY BAY, HK.
To protect the privacy rights of users during usage of Game Community Services, we have specially formulated this Privacy Policy to explain how we collect, use, store, and share your personal information when using our services and what rights you have over your data, regardless of whether the data is provided by you voluntarily or collected by us. Unless otherwise stated herein, all terms used in this Policy shall have the same meaning as those used in the Heropub User Terms.
If you have any doubts, opinions or suggestions, please contact us via email at heroboxglobal@gmail.com
This Policy will help you understand the following:
1. What User Information We May Collect
2. Storage and Protection of User Information
3. Purpose of Collecting User Information
4. Entrusted Processing, Sharing, Transfer or Disclosure of User Information
5. SDK and Other Similar Applications
6. Your Rights
7. Reminder for Minor Users
8. Scope of This Policy
9. Changes to This Policy
10. Contact Us
11. Law and Jurisdiction
1. What User Information We May Collect
The minimum age to create our user account is 13 in principle. We will basically not knowingly collect personal data from minor under this age. We may (not must) allow a minor under 13 to register an account with consent from his legal guardian TO THE EXTENT PERMITTED BY APPLICABLE LAW AND APPLICABLE THIRD-PARTY PLATFORM POLICIES. IN SUCH CASE, We may ask the legal guardian to provide additional documentation or perform additional actions as part of the verification and approval process pursuant to applicable law.
1.1 We may collect your personal information as follows:
(1) The information you voluntarily provide to us when using the services, including:
① Information you provide when registering as a user of Hero Entertainment.
② Information uploaded, published or provided by you when you obtaining specific services or functions, including creating or sharing content, and communicating with others, etc.
This includes information contained in or related to the content you provide (such as metadata), such as the date a file was created. It also includes content that you see or use through the functions we provide (e.g., photo-taking function, photo upload function, content upload function).
③Information submitted when you participate in online and offline activities organized by Hero Entertainment.
④ Information you provide to Hero Entertainment service team or other official channels.
Unless we obtain your consent, we will not collect personally identifiable information or sensitive personal information, such as your true name, address, telephone number, fax number. You confirm that if you elect to submit any personal data, your submission is subject to this Privacy Policy and you consent to the terms therein.
i) Contact data (such as email address or telephone number)
ii) Account Registration (such as your gender, username, and account ID）
iii) Your selected interest tags
iv) Other personally identifiable information or sensitive personal information.
(2) Information we obtain when you receive or use Game Community Services, including:
① Log information. When you obtain Game Community Services, we may automatically collect relevant information and store them as service log information.
② Device Information. Includes your IP address, version information, browser type, operating system, and other information.
③ Time Zone Information and Cookies Information. You can manage Cookies through browser settings. If you do not want to accept customized services, you can turn off the Cookie function at any time in browser settings. After this, we will delete or anonymize your user information collected based on the Cookie function.
④ Your usage behavior. We collect information on how you use our products, such as the types of content viewed or interacted with, functions used, operations performed, the users or accounts that you interact with, as well as the time, frequency and duration of your online activities.
⑤ Cross-device personalization. When you log into Heropub on a browser or device, we will link the browser or device to your account for the purposes of ID verification, security, and personalization, etc.
6Other information. In order to provide better services to you and improve service quality of Hero Entertainment, we may need to collect other relevant information of you upon obtaining your consent.
(3) Your information provided or shared by other parties.
① Information of you or relevant to you that other users provide upon their access to Game Community Services.
② Information that third-party partners share with Hero Entertainment which you generate, provide or share upon your access to their services, such as when you make a third-party login via Facebook, Google, Apple. In this case, please carefully read the user terms and privacy policy of the services of such third-party partners. We will comply with both this Policy and the privacy policy of such third-party partners for the purpose of “minimum utilization and maximum protection” of your user information.
(4) Data shared from other Hero Entertainment products or third parties’ game products
Hero Entertainment may obtain your game character data and game behavior data from other Hero Entertainment products or third party partner’ games in order to provide services for you. In this case, please carefully read the user terms and privacy policy of the services of such products.
1.2 If you choose to use Heropub, you may need to provide us with or allow us to collect and use the following types of your user information or grant us necessary permissions. Please particularly note that the service functions involved, the corresponding types of personal information collected, or the scope of permissions may vary according to the actual service content you choose. For details see the actual product/service in use. Especially, regarding your personal sensitive information/permission, we may remind you of it by prompts or other means before you receive relevant services and ask for your permission. Please pay attention to them.
(1) Registration and login. For the purpose of successful registration and access to our services, when you register and log in to the Heropub community account, you need to register in accordance with our guidelines and provide us with your basic registration or login information, i.e. email and password .
(2) Basic functions of online community. When you receive or use the services provided by Hero Entertainment, we may collect, use and store your log information. Log information is classified into device information (about the device you use when you access to Game Community Services) and user behavior logs. The above device information includes configuration information, IP address, version used by the terminal device, device identification code, device ID, device name, device type and version, system version, MAC address, application ID, network type information, UUID, IDFA, and device unique identity information -- International Mobile Equipment Identity (IMEI), which are mainly used to maintain the normal operation of basic functions of Heropub and further improve our products and services. User behavior logs include login logs, posting logs, and comment logs, which are mainly used to facilitate you to view the use history records in Heropub on the client, and for us to conduct operation statistics analysis, customer service complaint handling and other network security analysis.
(3) Game account binding. You can choose whether to allow Heropub to obtain the game data corresponding to Hero Entertainment’s other game products or third party partner’ game products, including but not limited to your game account, game character, character level, game equipment, friend history, behavior data, etc. After you click on “Agree”, we will retrieve or legally obtain your corresponding game data and synchronize them to your Heropub community account. If you do not agree with this authorization, you can continue to use the basic community functions of Heropub, such as posting, replying to posts, etc., but you cannot use the corresponding functions related to the game account data, including game record query, game props acquisition, and consumption query.
(4) Customer service. When providing you with customer service consultation, explanation, complaint, appeal, after-sales service, dispute resolution, and other customer services, we may need you to provide necessary account information and user behavior log information to match and verify your user identity, to track down the problems and disputes involved, and to respond to your requests in a timely manner. At the same time, we may also need to collect and save your contact information, records of calls between you and us and other contact records and the specific contents of them, as well as other necessary information for processing your requests.
(5) Interaction. When you upload or publish texts, pictures, audios, videos and other information in the process of using our products or services, or interact with other players through texts, pictures, audios, videos and other ways (e.g., chatting, commenting, and sharing), we will collect and store the above information provided by you voluntarily. If the contents contain your personal sensitive information, please consider carefully before publishing them. If the contents involve the personal information of others, please obtain the legal authorization of others before publishing them. If the contents violate the provisions of laws, regulations or other normative documents, violate public order and good customs or public moral standards, infringe upon the rights and interests of others, or involve other illegal or improper circumstances, we will delete or block the contents to maintain a healthy online environment. Depending on the specific interactive service requirements, we may require you to enable the corresponding device access permission. For example, for graphic and video sharing services, you need to enable camera permission and mobile album access permission.
2. Storage and Protection of User Information
2.1 Storage of user information.
(1) Storage period. Except otherwise stipulated in applicable laws and regulations, Hero Entertainment stores necessary information of you for the shortest possible period of time only for the purpose of providing services to you. After you cancel the authorization or the storage period expires, we will delete or anonymize your user information.
(2) Storage area. For the purposes described in this policy, your information may be transferred to countries/regions outside of your residence, or may be stored or processed in these countries/regions. These data transfers are necessary to provide our services, to operate our products worldwide, and to make them available to you. Regardless of where our servers are located, we will take reasonable steps to protect your rights in accordance with the provisions of this Privacy Policy.
2.2 Protection of user information. We are well aware that personal information is important to you and will do our best to protect your personal information safely and reliably. In order to protect users’ information security, Hero Entertainment will take various reasonable security measures at physical, technical and management levels to protect your data and information and prevent information leakage, loss and damage. These security measures include technical measures such as SSL, information encryption storage, access control of data centers, dedicated network channels, and agents, as well as personnel or institutional management measures such as access control and management of employees or outsourcers, signing of confidentiality agreements, and formulation of the company’s confidentiality system. If unfortunately, the user information security incident occurs, we will – according to relevant laws and regulations -- timely inform you of the basic information of the related incident, possible adverse effects, and measures we have taken or will take via public announcement, SMS, phone call, email notification, etc., in order to remedy the situation as soon as possible. At the same time, we will also proactively report the handling of relevant incident in accordance with the requirements of the regulatory authorities.
3. Purpose of Collecting User Information
3.1 Hero Entertainment will strictly abide by laws, regulations and relevant government policies, and comply with this Policy and the Heropub User Terms to use your information collected for the following purposes:
(1) To provide services for you.
(2) To guarantee the security of services.
(3) To understand the operation and development of services, improve existing services, and develop new high-quality services.
(4) To carry out internal audit, user survey, data analysis and to communicate with you and send out surveys and event invitations. Hero Entertainment promises not to match the information stored in the analysis software with the personal identity information provided by you in the application when analyzing user data.
If we plan to use your user information for other purposes not specified in this Policy or use the collected personal information collected for a specific purpose for other purposes, we will ask for your permission.
3.2 We use Cookies to collect usage data of websites and to operate our services, in order to facilitate your operation.
You can disable Cookies in your browser settings, but some parts of our services may not function properly afterwards.
4. Entrusted Processing, Sharing, Transfer or Disclosure of User Information
At present, in order to provide better services for you and improve your user experience, Hero Entertainment may entrust a third party to process, share, transfer or disclose your information in the following circumstances.
4.1 Certain specific modules or functions in our products and services may be provided by external suppliers. We will conduct security assessment on the companies, organizations and individuals entrusted to process personal information and the entrusted behavior, sign strict confidentiality terms or agreements with them, and specify the entrusted matters, processing period and purpose, and the responsibilities of the trustee. And we will require the trustee to process and protect your information in accordance with the privacy policy, information usage description and other relevant confidentiality measures and security measures of Hero Entertainment.
4.2 We will not share your personal information with any other company, organization or individual unless we obtain your express consent. Hero Entertainment may share necessary user information of you with necessary third-party partners. Regarding such third-party partners, we will sign strict confidentiality terms or agreements with them and require them to process and protect your information in accordance with the privacy policy, information usage description and other relevant confidentiality measures and security measures of Hero Entertainment.
(1) Generally, our third-party partners are of the following types:
① Third-party service providers and contractors.
② Agents or intermediaries.
③ Legal, accounting, business and other professional consultants.
④ Advertising partners.
⑤ Third-party SDK service providers.
(2) Use of your information by such a third-party partner is mainly for the following purposes:
① To provide services for you.
② To achieve the purpose of Article 4.1.
③ To perform our obligations under the Heropub User Terms, this Policy or any other agreement between Hero Entertainment and you.
④ To exercise our rights in the Heropub User Terms, this Policy or any other agreement between Hero Entertainment and you.
⑤ To maintain and improve services and optimize user experience. If this third-party partner changes the purpose of your user information usage, you will be asked for permission.
4.3 We will not transfer your personal information to any other company, organization or individual unless we obtain your express consent. When it comes to mergers, acquisitions, asset transfer or similar transactions, Hero Entertainment may transfer your personal information to third parties associated with such transactions and your personal information is likely to be part of such transactions. In this circumstance, Hero Entertainment will require new managers to continue to do a good job in protecting users’ personal information in accordance with the provisions of laws, regulations and policies and provisions of this Policy. If the new manager changes the purpose of your user information usage, you will be asked for permission then.
4.4 We may disclose your information for the following purposes or according to the following requirements:
(1) You or your guardian authorizes or requires us to do so.
(2) We are required to do so by relevant laws and regulations.
(3) The disclosure is required by judicial or administrative authorities based on legal procedures.
(4) When the disclosure is a necessary way to safeguard the public interests, the interests of partners, your own interests, the interests of other users, the interests of employees or other people’s legitimate rights and interests.
(5) If you are a minor, your information will be disclosed at the lawful request of your guardian.
5. SDK and Other Similar Applications
We may access SDKs or other similar applications provided by third-party service providers for the purpose of implementing relevant services. At present, please refer to the Appendix Heropub Third-party SDK List for details about the third-party SDK service providers and their service functions that we have accessed and the information we have collected/ the permissions we have opened.
The aforesaid third-party services are operated by relevant third parties. Your use of such services shall be bound by the third-party service providers’ service terms and privacy policy, and not subject to this Policy. To better protect your legitimate rights and interests, you are advised to read the service terms and privacy policy of such third-party service provider carefully before using any third-party SDK service. If you find that these SDKs or other similar applications are at risk, you are advised to terminate relevant operations immediately and contact us in time.
6. Your Rights
When you receive or use the services provided by Hero Entertainment, we will do our best to ensure that you exercise the following rights with respect to your personal information:
6.1 Query, access, modify and delete your personal information. You have the right to query, access, modify and delete your personal information. You can log in to your account at any time according to your needs. On the interface of “Me”, you can query, access, modify or delete your posts and comments. And on the “Me -- Settings” interface, you can modify your profile picture, gender, personality signature, etc. Unless otherwise provided by law, we will delete or anonymize your information once it is deleted. We will also simultaneously notify entities who have obtained your personal information from us and request them to promptly delete such information, unless otherwise provided by law or unless that entity has obtained your independent authorization. If you modify or delete information from our products or services, we may not immediately modify or delete the corresponding information in the backup system, but we will modify or delete the information when the backup is updated.
6.2 Change or withdraw the scope of your authorization. You have the right to change or withdraw the scope of your authorization. Part of our service functions require some basic personal information or relevant permissions of the devices you use (refer to Article 1 of this Policy and see the information or function that the specific product or service actually intends to obtain for details). You have the right to give or change or withdraw authorization at any time. You can change or withdraw the scope of your authorization by deleting information, disabling device functions, etc., or you can cancel your account to permanently withdraw all the authorization for us to continue to collect your personal information. Please note that when you withdraw your authorization, we will no longer process the corresponding personal information and will not be able to continue to provide specific service functions or services based on such authorization. However, your decision to withdraw authorization will not affect the personal information processing carried out based on your previous authorization.
6.3 Cancel your account. You have the right to cancel your account. You can request to cancel your account by sending an email to us. Please know, understand and agree that the account cancellation is irrevocable and irreversible upon completion. After the account is canceled, your account and all its contents cannot be recovered. And we will stop providing you with products or services and delete your personal information at your request, unless otherwise stipulated in laws and regulations.You can directly initiate an application to delete your account information by contacting the customer service email: herobox@yingxiong.com
6.4 Your above requests shall be responded. Generally, the above requests can be completed by yourself on the corresponding interface of our products and services according to the notification or guidelines published online. If there is a request that may not be able to be meet through online processing services at present, or if you encounter any problems or obstacles or have any opinions or suggestions in the process of exercising your rights, you can also send email to the official mailbox to contact us, and we will handle it. Please know, understand and agree that in response to your above requests, in order to protect the security of your account and information, we may need to verify your identity first, then process your request after you complete your identity verification in accordance with relevant instructions. For your reasonable requests, the verification and processing time will be 15 working days after you contact us and after the identity verification is successfully completed (if necessary). Such response period may be extended for your own reasons or for other reasons beyond our control. We may refuse requests that are repeated for many times for no reason, exceed reasonable limits, require excessive technical means (such as developing a new system or fundamentally changing the current practice), bring risks to the legitimate rights and interests of others, or are highly impractical. However, we will explain to you the reasons and grounds for the refusal.You can directly initiate an application to delete your account information by contacting the customer service email: herobox@yingxiong.com
6.5 Depending on your place of residence, you may be able to exercise your right to data portability and right of refusal, etc. on your information in accordance with applicable legal requirements.
6.6 In the case of push notifications related to marketing or advertising communications, you can object to our right to process your data for direct marketing purposes by using the "Unsubscribe" link in such marketing communications.
7. Reminder for Minor Users
You confirm that you are either: (1) at least 13 above; or (2) younger than 13 years old, but are permitted by APPLICABLE LAW AND APPLICABLE THIRD-PARTY PLATFORM POLICIES to use our Services and your legal guardian have performed verification and approval process as well.
If you are the guardian of a minor, please contact us through the contact information specified in this Policy if you have any doubts about the personal information of the minor under your guardianship or require us to query, access, modify, correct, or delete the information. We strongly urge parents to supervise minors to protect their personal information. If we learn that we have collected personal data about a minor unlawfully, we will delete such data immediately. Also, if you believe that we might have collected data from or about a Minor unlawfully, please contact us immediately.
8. Scope of This Policy
This Policy applies to Heropub services provided by Hero Entertainment except certain specific services. However, when a specific service has its own privacy policy, the special provisions of such privacy policy shall prevail.
This policy does not apply to services provided to you by other companies or individuals. Your use of such third-party service is subject to its privacy policy.
9. Changes to This Policy
We may amend the contents or terms of this Policy in due course. Such amendments or changes may result in a material derogation of your rights under this Policy, and we will notify you of the changes or amendments via prompts in prominent positions on the page, email to you, etc., before the changes or amendments become effective. In this case, if you do not agree to such amendments or changes, you have the right to and shall immediately stop using our products or services.
10. Contact Us
If you have any doubts, opinions or suggestions regarding the protection of your personal information under this Policy and in the process of receiving or using our products and services, please contact us via email as listed in the first page. Normally, after receiving your email and verifying your user identity (our verification and processing time is 15 working days), we will get back to you as soon as possible. However, please know, understand and agree that we will not be able to respond to your requests in the circumstances listed in Article 6.4 of this Policy.
11. Law and Jurisdiction
The conclusion, interpretation and performance of the provisions of this Policy shall be governed by the laws of the People's Republic of China,excluding the application of all provisions of conflict of laws.
Any dispute arising from or in connection with this Policy shall be submitted to China International Economic and Trade Arbitration Commission (CIETAC) for arbitration which shall be conducted in accordance with the HKIAC's arbitration rules in effect at the time of applying for arbitration. The arbitration place shall be Hong Kong. The arbitral award is final and binding upon both parties.
Any such arbitration shall be conducted solely by the parties in their individual capacities, and by entering into this Policy, you and Hero Entertainment expressly waive the right to participate in a class action.
Released on: December,8, 2022