Privacy Policy

Last Modified: January 31, 2022

 

INTRODUCTION

Aquila Interactive Co., Limited (“Aquila Interactive”,” we”, “our”, or “us”) respects your privacy and are committed to protecting it through our compliance with this Privacy Notice (“Notice”).

This Notice describes our practices for collecting, using, maintaining, protecting, and disclosing your information through https://www.aquilainteractive.io (our “Website”) and our products, services, online forums, mobile applications, games (including PC and console games), and technology platforms (collectively, the “Service” or “Services”).

A core element of our mission is our commitment to protect your personal information and to be transparent about the data we collect about you, how it is used, and with whom it is shared.

Please read this Notice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our terms, your choice is not to use our Services. By accessing or using our Services, you agree to this Privacy Notice. This Notice may change from time to time (see Changes This Notice). Your continued access of our Services after we make changes is deemed to be acceptance of those changes, so please check the Last Modified Date at the top of this Notice, to ensure that you are viewing the most current version of this Notice.

 

CHILDREN’S PRIVACY

The Services are general audience and intended for users 16 and older. We do not knowingly collect Personal Information from anyone younger than age 16.

 

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We collect several types of information from you and about users of our Services, such as basic contact information when you sign up for an account. Other types of information we collect is information related to how you use our platform, which helps us improve our Services.

Information You Provide to Us or Received by Us on Your Behalf

The categories of information we collect are:

• • Personal Information: In the course of registering for an account, filling out a contact form on our Website, or using our Services we may require or otherwise collect information that identifies you as a specific individual and can be used to contact or identify you (“Personal Information”). Examples of Personal Information we collect for these purposes include your: Full name, email address, date of birth, username, password, interests, demographic information, gaming preferences, support-related information, and information related to your participation in contests or sweepstakes.
  • Payment Information: We also may collect your payment information, such as credit card, billing address, and other financial information necessary to purchase a product or otherwise use our Services. We will not retain Payment Information.
  • Non-Identifying Information: We also may collect non-identifying or non-personal information, such as zip codes, demographic data, age, gender, time zone, publicly available data, and general information regarding your use of the Service (“Non-Identifying Information”).
  • User Contributions: You have the ability to interact with parts of our Services, such as the ability to post public comments on our forum. Your feedback may be published or displayed on public areas of the Website or transmitted to other users of the Website or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Services with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed or accessed by unauthorized persons. Use precaution when posting any personal information online. Please review our Terms of Service for more information about our user guidelines.

When you provide us with information in connection with a particular activity or otherwise sign up for or order our products and Services or provide your contact information to us, including your email address or telephone number in connection with that activity, product, or service, you agree that such action constitutes a purchase or inquiry establishing a business relationship with us. You expressly consent to receiving communications from Aquila Interactive through the information you provided to us. For more information on how to access and control your communication preferences, please see YOUR RIGHTS AND CHOICES REGARDING YOUR INFORMATION, below.

 

Information Collected Automatically

As you navigate through and interact with our Services, We and our third-party service providers, including analytics and third-party content providers, may automatically collect certain information from you whenever you access or interact with the Service.

• • Usage Information. Details of your visits to our Website, including which links you clicked on, content response times, logs, and other similar communication data and statistics about your interactions.
  • Information about your computer and internet connection, including your Internet Protocol address, operating system, and browser type.
  • Gaming Analytics We may use third-party analytics service providers such as Google Analytics or AppsFlyer to capture analytical information about your use of our games and your experience while playing our games.
  • Advertising ID. Advertising IDs are used for interest-based advertising and other advertising related purposes. We collect your mobile advertising ID such as a Google Advertising ID (GAID) or an Apple Advertising Identifier (IDFA). We collect this information to keep track of your subscription status, and to decide which information to show in our apps. You can remove this by resetting advertising ID on Android or limiting ad tracking on your Apple device.

We may combine this automatically collected log information with other information we collect about you. We do this to deliver features of our Services to you, improve the Services we offer you, analytics, and to engage new customers.

Cookies and Other Automatic Data Collection Technologies

Aquila Interactive and its partners use cookies or similar technologies, which store certain information on your computer and allows us to, among other things, analyze trends, administer the Website, and to gather demographic information about our user base. The technology used to collect information automatically from Aquila Interactive users may include the following:

• • Cookies: Like many websites, we and our operational partners, affiliates, analytics, and service providers use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use both persistent cookies that remain on your computer or similar device (such as to save your registration ID and login password for future logins to the Service and to track your compliance with the Aquila Interactive Terms of Use) and session ID cookies, which expire at the end of your browser session (for example, to enable certain features of the Service, to better understand how Aquila Interactive Users interact with the Service and to monitor aggregate usage by Aquila Interactive Users and web traffic routing on the Service). You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functionality of the Service.
  • Web Beacons: We and our operational partners, affiliates, analytics, and service providers may also employ software technology known as “web beacons” and/or “tracking tags” to help us keep track of what content on our Service is effective and to serve relevant advertising to you. Web beacons are small graphics with a unique identifier that may be invisible to you, and which are used to track the online activity of Internet users. Web beacons are embedded in the web pages you review or email messages you receive. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to our Service, to monitor how Aquila Interactive Users navigate the Service, to count how many emails that were sent were actually opened, or to count how many particular articles or links were actually viewed.
  • Embedded Scripts: We and our operational partners, affiliates, analytics, and service providers may also employ software technology known as an Embedded Script. An Embedded Script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your computer or other device and is deactivated or deleted when you disconnect from the Service.

Information Received from Third Parties

We also may receive information about you from third parties. For example, we and our partners, affiliates and service providers may use a variety of other technologies (such as tags) that collect statistical data relating to your Website activity for security and fraud detection purposes.

 

Third-Party Services

When you connect with us through a third-party platform we may, depending on your privacy settings, receive some information from your third-party account, and what we collect depends on your privacy settings with that service.

You may register to join our Services directly via the Website, through a specific gaming interface, or by logging into your account with a third-party service (“TPS”) via our Service (e.g., Steam, Facebook, Google, Apple, and other third-party services that let you sign in using your existing credentials with those services). If you choose to register via a TPS, or to later link your account with the Service to your account with an TPS, we will use the Personal Information you have provided to the TPS (such as your name, email address, and other information you make available via the TPS) to create your account. For example, if you connect your Steam account to ours, we can see what games you own. This helps us provide ownership medals on our forum as well as get a better picture of cross game ownership. Note that the information we collect from and through a TPS may depend on the privacy settings you have set with the TPS and the permissions you grant to us in connection with linking your account with the Service to your account with an TPS. Other than what we may share with the TPS as described below, the Personal Information a TPS has about you is obtained by the TPS independent of our Service, and Aquila Interactive is not responsible for it.

 

Do Not Track Signal

Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. We do not honor browser requests not to be tracked online (known as “Do Not Track”), but our cookie Notice below describes how you can opt out of receiving cookies.

 

HOW WE USE YOUR INFORMATION

We may use information that we collect about you or that you provide to us, including any personal information:

• • To deliver, provide, and process payment for the Services or for a product you have requested.
  • To enforce our Terms of Service.
  • To improve our Services.
  • To address your inquiries.
  • To tailor content we display to you and offer we may present to you, both on the Service and elsewhere online.
  • To communicate and promote to you products, services, offers, and events offered by Aquila Interactive.
  • To administer surveys, contests, sweepstakes, or surveys.
  • To comply with legal requirements and assist law enforcement.
  • To protect the property rights of Aquila Interactive or a third party.
  • To protect the safety of the public or any person.
  • To stop any activity, we may consider to be, or to pose a risk of being, illegal, fraudulent, unethical or a legally actionable activity.
  • To identify Aquila Interactive users.
  • For the purposes disclosed at the time you provide your information, and
  • As otherwise permitted with your consent.

 

Legal Bases

To process your information as described above, we rely on the following legal basis:

• • Contractual Necessity: To provide you with the Aquila Interactive Service and perform the contract that you have with us.
  • Legitimate Interests: It is in our legitimate interests to improve and analyze our Service, promote our products, prevent fraudulent transactions, maintain security of our Services, and provide functionality.
  • Consent: In instances where we have indicated we will ask for consent within this Privacy Notice, you may withdraw your consent at any time by contacting us. Please see the How to Contact Aquila Interactive section for more information.

 

HOW WE DISCLOSE AND SHARE YOUR INFORMATION

We may share information we receive about you as follows or as otherwise described in this Privacy Notice:

• • Depending on the game and your privacy settings, some in-game information, such as your username or gameplay statistics, may be viewable to other gamers.

• • With our service providers and network partners:
    • We employ third party companies and individuals to provide Services on our behalf, to perform Service-related operations (e.g., without limitation, maintenance services, database management, web analytics, payment processing, fraud detection and improvement of Aquila Interactive’s features) or to assist us in analyzing how our Service is used. These third parties may have access to your Personal Information in order to perform these tasks on our behalf.
  • For corporate transactions
    • Aquila Interactive may share information, including Personal Information, with any current or future subsidiaries or affiliates, primarily for business and operational purposes. We may sell, transfer, or otherwise share some or all our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets (including, in each case, as part of the due-diligence process with any potential acquiring entity) or in the event of bankruptcy.
  • When required by law
    • Aquila Interactive will share information with government agencies as required by law in response to lawful requests by public authorities, including to meet national security or law enforcement requirements and, including without limitation, in connection with reporting earnings. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), or, at the request of governmental authorities or other third parties conducting an investigation where we determine in our sole discretion the disclosure is necessary to (a) protect the property and rights of Aquila Interactive or a third party, (b) protect the safety of the public or any person, or (c) prevent or stop activity we may consider to be, or pose a risk of being, illegal, fraudulent, unethical or legally actionable activity. We may also use Device Identifiers to identify Aquila Interactive Users, and may do so in cooperation with third parties at our discretion.

• • You may submit Personal Information to us through a form on the Website and consent to receive communication from us or our business affiliates and non-affiliates based on the information in the form.

 

YOUR RIGHTS AND CHOICES REGARDING YOUR INFORMATION

You have several ways to exercise control over your information:

• • Account Settings:

• • • Registered users may access, update, or delete their personal information by accessing the applicable feature in their Account settings.
    • Registered users may also update their choices regarding the types of communications they receive from us through the online Account settings.

• • Contact Us: You may contact us to access, update or delete your personal information by contacting us at [email protected]
  • E-Mail: You also may opt-out of receiving marketing emails from us by following the opt-out instructions provided in those emails. Please note that we reserve the right to send you certain communications relating to your account or use of the Service (for example, administrative and service announcements) via email and other means and these transactional account messages may be unaffected if you opt-out from receiving marketing communications.

 

European Residents

European residents may submit requests to access, rectify or delete their personal information to their respective data controllers.  Aquila Interactive will complete a request from a data subject to exercise any rights under the GDPR only upon direction from a data controller. Upon instruction from a data controller, Aquila Interactive will provide the data controller with information about whether we hold any of your personal information and assist the data controller in responding to your request.

Aquila Interactive may be considered a data controller to the extent that we process personal information directly from European residents. To the extent that Aquila Interactive is a data controller, European residents may access, correct, update, or delete your personal information; object to our processing of this information, ask us to restrict our processing of your personal information, or request portability of your personal information through the methods outlined above.

Upon request, Aquila Interactive will provide you with information about whether we hold any of your personal information. You are responsible for maintaining the accuracy of the information you submit to us, such as your contact information. If you submit a request to access all personal information you’ve submitted, we will respond to your request to access within 30 days or as otherwise required by law

We will use commercially reasonable efforts to honor your requests for deletion; however, certain residual information may actively persist on the Service even if you close your account. In addition, the rights described above may be limited, for example, if fulfilling your request would reveal personal information about another person, or if you ask us to delete information, we are required by law to keep or have compelling legitimate interests in keeping (such as for fraud prevention purposes). Your Personal Information may remain in our archives and information you update or delete, or information within a closed account, may persist internally for our administrative purposes, to the extent permitted by law. It is not always possible to completely remove or delete information from our databases. In addition, we typically will not remove information you posted publicly through or on the Service. Bear in mind that neither you nor Aquila Interactive can delete all copies of information that has been previously shared with others on the Service. If your information is deleted, then your account may become deactivated. If your account is deactivated or you ask to close your account, you will no longer be able to use the Services.

Please note that our Services require a minimum amount of Personal Information in order to function. European residents who do not provide Personal Information (e.g., by not filling out a profile) may not be able to access the full functionality of features found on Aquila Interactive.

 

California Residents

If you are a California resident, the California Consumer Privacy Act (CCPA) may provide you with additional privacy rights with respect to our collection, use and disclosure of your Personal Information. To the extent that Aquila Interactive is a covered business under the CCPA, you may contact us for more information regarding the following rights:

• • The right to know what Personal information we have collected and how we have used and disclosed that Personal Information in the 12-month period preceding your request;
    • Please see the above section within this Policy titled INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT, to see the categories of Personal Information we have collected about you.
    • Please see the above sections within this Policy titled HOW WE USE YOUR INFORMATION and HOW WE DISCLOSE AND SHARE YOUR INFORMATION, to see applicable use and disclosures of your Personal Information.
  • The right to request deletion of your Personal Information, and;
  • The right to be free from discrimination related to the exercise of any of your privacy rights.
  • The right to opt out of the sale of your personal information, and to request information about whether we have sold your personal information in the past 12 months.

For more information on how to exercise your rights, please contact us at [email protected] Please note that we may require you to verify your credentials, by matching your e-mail address, or other account information to the information in our systems, before you can submit a request to exercise any of these rights. If you authorize another person to act as your agent to submit requests on your behalf, then unless you provide the agent with power of attorney under the California Probate Code, we will ask the agent to provide us the written and signed authorization that you provided to the agent, we will confirm with you that you did provide the authorization, and we will verify your identity.

 

INTERNATIONAL JURISDICTIONS

Please be advised that we are based in Hong Kong and that you may be transferring your personal information to our global servers, which may be located in the US, Hong Kong, and other countries as applicable; and you consent to that transfer, processing, and storage of your personal information in accordance with this Privacy Notice. You also agree to abide by the applicable laws concerning your use of the Services and your agreements with us. Any persons accessing our Services from any jurisdiction with laws or regulations governing the use of the Internet, including the collection, use, or disclosure of personal information, different from those of the jurisdictions mentioned above may only use the Services in a manner lawful in their jurisdiction. If your use of the Services would be unlawful in your jurisdiction, you may not use our Services.

 

SECURITY

We use physical, technical, and organizational measures designed to protect your information against unauthorized access, theft, and loss. We restrict access to your personal information to those employees who need to know that information to service your account or perform their job functions.

Although we take precautions intended to help protect information that we process, no system or electronic data transmission is completely secure. Any transmission of your personal data is at your own risk, and we expect that you will use appropriate security measures to protect your personal information.

You are responsible for maintaining the security of your account and the information in your account. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. You understand and agree that we may deliver electronic notifications about breaches of security to the email address on record on your account.

 

DATA RETENTION

Unless you request that we delete certain information (see Your Rights and Choices Regarding Your Information), We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Notice unless a longer retention period is required or permitted by law.

The criteria used to determine our retention periods include:

• • The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using the Website).
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period before we can delete them)
  • Whether retention is advisable; and considering our legal position (such as, for statutes of limitations, litigation, or regulatory investigations).

 

LINKS TO OTHER SITES

Our Services may include links to third-party websites and services that are not operated by us. When you click these links, you will be directed away from our Services. A link to a third-party website or service does not mean that we endorse it, or the quality or accuracy of information presented on it. If you decide to visit a third-party website or service, you are subject to its privacy practices and policies, not ours. This Privacy Notice does not apply to any personal information that you provide to these other websites and services.

CHANGES TO THIS NOTICE

Aquila Interactive may update this Privacy Notice at any time and any changes will be effective upon posting. In the event that there are material changes to the way we treat your Personal Information, we will update the Last Modified date at the top of this Notice upon becoming effective. We may also notify you by email, in our discretion.

 

HOW TO CONTACT AQUILA INTERACTIVE

If you have any questions about this Privacy Notice, please contact us at [email protected]