Privacy Policy of Tongits Soga

The Introduction

Thank you for choosing Tongits Soga app. Tongits Soga app (hereinafter referred to as the "Tongits Soga", "The Application" or "Application Service") is a social application developed by Tongits Soga (hereinafter referred to as "We" or "Us").Before you use the application services provided by us, you need to read this Privacy Policy to understand how we collect, use, protect and share your personal information, and what rights you have to dispose of your personal information.

If you choose to enter the application, you agree to the content of this privacy policy by default.

If you do not agree to our Privacy Policy after reading it, you may choose to refuse to use our application services. If you refuse to provide relevant information in the application, you may not be able to use certain functions in the application.

The complete content of this Privacy Policy is as follow:

In order to provide you with application and to support the related user interaction, consumption and other services, we need to collect information such as your application history, device information, login data and others. You hereby consent to provide the following specific information for the purpose:

• username(s);

• details of the application you use;

• approximate location information;

• your application history;

• your device's operating system and version;

• your mobile device's identifiers, like your MAC Address, Identifier for Advertising (IDFA), and/or International Mobile Equipment Identity (IMEI);

• your login data;

• other information that helps us make sure it's you accessing your account, information necessary for us to provide the support you request, or information you provide to help us improve our Service (such as answers to an online survey or a feedback form).

We adopt a wide range of security measures to ensure that your personal information is protected under a reasonably safe manner.

Data We Collect and Use

When you start to use our application services, we will obtain your information based on the application. This includes information that you agree to or voluntarily provide, information that is automatically submitted, and information collected by third parties that we work with. Details are as follows.

2.1 Information you voluntarily provide to us

We may collect information you voluntarily submit to us, including, but not limited to the user name you set, your email address, the questionnaire you submit, and your feedback.

2.2 Information you may need to submit and the Application Services automatic/request submission

Information you may need to submit includes:

The username you create to log in;

The password of created account.

Information that is automatically submitted or requested to be submitted by the Application Services includes:

Basic information: device brand, model, operating system and version, screen size, resolution, application ID, network connection and running memory, etc;
Advertising information: The Android advertising ID of your mobile device, the advertising content shown to you, whether you click on the advertisement, and the website you visit through the advertisement;
Location information: your country or region code, your IP address or MAC address, the time you log in to the mobile device of this application.If you wish to interact with nearby application users, upon your authorization we will collect the information of your geographic location to search for nearby application users, so that you can match with them or team up with them, etc. Geographic location information is a type of sensitive information. Your refusal to provide this information will only result in your incapability to interact with nearby application users, and will not affect your normal use of other functions provided by application. You can also withdraw your authorization for the geographic location information at any time.
Sensitive Information: We may ask you for permission to store images shared in the application, as well as your microphone permissions, your WLAN connection information, and your device ID.If you wish to interact with other application users through voice, upon your authorization, Application will access your microphone to accommodate you with voice chatting. But we will never violate the privacy of your voice. You can also revoke the authorization of the microphone at any time.
Partial screenshot of application video:Pictures and other information from your Device's camera and photo library.We use this information to provide features of Our Service, to improve and customize Our Service. The information may be uploaded to the Company's servers and/or a Service Provider's server or it may be simply stored on Your device.

You can enable or disable access to this information at any time, through Your Device settings.

If You decide to register through or otherwise grant us access to a Third-Party Social Media Service, We may collect Personal data that is already associated with Your Third-Party Social Media Service's account, such as Your name, Your email address, Your activities or Your contact list associated with that account.

You may also have the option of sharing additional information with the Company through Your Third-Party Social Media Service's account. If You choose to provide such information and Personal Data, during registration or otherwise, You are giving the Company permission to use, share, and store it in a manner consistent with this Privacy Policy.

When you use the consumption function of Application products, we will collect your recharge history, purchase records and other information, so that you can check your transaction records, and at the same time to protect your virtual items to the greatest extent possible. Recharge history and purchase records are sensitive information. It is necessary to collect the above information in order to enable the consumption function of Application product, otherwise the transaction could not be completed.
To protect the security of your application account and to create a fair, healthy and safe gaming environment, we will collect information such as your application identity information, hardware and operating system information, processes and breakdown records and other information, for the purposes of fighting against the behaviors that destroy the fair gaming environment or that interfere and disrupt normal application services (such as detecting counterfeits, scanning plug-ins, preventing cheating, etc.).
According to reports and targeting of keywords involving pornography, violence, political and abusive content, terrorism, malicious advertising, and other legally prohibited content, we may store temporarily and filter the information when you interact with other players through text, images, voice, video and other means in the application, for the purpose of purifying the application environment and maintain a healthy Internet environment.
In accordance with relevant laws, regulations and standards, we may collect and use your personal information in the following situations without obtaining your authorization:1.where it is directly related to national interests such as national security and national defense security; and directly related to major public interests such as public security, public health, and public knowledge;2.where it is directly related to criminal investigations, prosecutions, trials and enforcement of judgments, etc.;3.where it is for protecting the fundamental legal rights of you or other individuals, such as life, property and reputation, but it is also difficult to obtain consent from you or the related individual;4.where the personal information we collected is disclosed to the public by yourself;5.where the personal information is collected through legitimate and public channels, such as legitimate news reports, government information disclosure, etc.;6.where it is necessary to sign and perform the contract according to your requests;7.where it is necessary to maintain a safe and stable operation of the products or services provided by us, such as the discovering and treating of the malfunctions of such product or service. But we will continue to protect the security of your personal information and ensure that it will not be used for other purposes;8.where it is necessary to conduct statistical or academic research for public interests; and when externally providing the results of academic research or description, applying de-identification method to the personal information contained in the results. In addition, it will not be used for any other purposes and activities; or other circumstances as stipulated by the laws and regulations.

Please understand that the functions and services we provide to you are constantly updated and developed. If a certain function or service is not included in the above descriptions herein but your information is collected there, we will separately explain to you the content, scope and purpose of such collection through prompts, interaction process, website announcement and other ways in order to obtain your consent.

2.3 When you use Application Service, we will collect your application log information, including:

(1) log-in data;

(2) item logs;

(3) crash logs;

(4) friends relation records;

so that you can view the records of your application history on your terminal and we can use the above information for analyzing application operation statistics, handling customer service complaints and other application security analyses.

Storage of Information

3.1 Manner and Term of Storing Information

We will store your information in a secure manner, including storing it locally (such as data caching via APP), using database and server logs. In general, we will only store your information for a necessary period for achieving the purpose of providing our services or as required by laws and regulations.

3.2 Territory of Storing Information

Personal information collected would be stored within [Alibaba servers located in Philippines] pursuant to the laws and regulations.

3.3 Termination Notice of the Product or Service

In the event the operation of a product or service is terminated, we will make an announcement in accordance with the relevant laws and regulations, and will protect your legitimate rights and interests.

How the Collected Information is Used

4.1 Improving our services

We will improve our application services based on your feedback and other information.

4.2 Processing payments related to the application

When a uesr makes a payment in this application, we will associate the information provided by the player when making the payment with the player's own information. This information is only used as a service for players and their orders.

In addition, we will try to contact the parent or legal guardian after a person that is suspected to be a minor has made consumption, and inform the parent or legal guardian of the consumption records and other information to remind the parent or legal guardian to confirm and handle this issue.

4.3 Push application-related activities and notifications, etc

We may push application-related activity notifications, update notifications and other information to users based on the information provided by users.

4.4 Sending Emails

We may send reply emails to users based on questions, feedback and other contents sent to us by email. We may also send orders or in-application events to users from time to time based on the email address they entered into the application.

Personal Information Security

5.1 Security measures adopted

We will strive to protect the security of users' information to avoid any information loss, disclosure, unauthorized use, etc. We have implemented physical, technical and administrative security measures for application services. To avoid any kind of doubt, it is neccessary to specify to you that all the application products of us have nothing to do with money, all golds and props in our application products are only for purpose of entertainment in the application. In addition, we have formulated relevant internal management regulations for personal information, requiring staff who have access to such information to comply with the regulations to ensure that information will not be disclosed at will, otherwise penalties will be imposed in accordance with the regulations. At the same time, we also prohibit users from arbitrarily using other people's information obtained through the application service.

5.2 Security incidents

If any security incident occurs during the operation of the application service, such as the disclosure of personal information, we take several measures to mitigate the damage. In addition, we will inform you of the basic information, measures to be taken and personal information suggestions of this event through announcements, application notifications, pop-ups, emails and other means within 72 hours.

Sharing with External Entities

Presently, apart from scenarios outlined in the Policy and "Pusoy Soga Terms and Service Agreement," we do not proactively share, provide, or transfer your personal information to any third party. Should the need arise to share, provide, or transfer your personal information to a third party, we will seek your prior explicit approval, or confirm that the third party has obtained your explicit approval.

However, it's important to note that we may provide your login information and relevant data (such as login records, item logs, etc.) generated within the application to overseas developer entities or pertinent third parties. This is primarily for conducting security analyses and aiding in the enhancement of application services to further optimize users' experiences.

Integration with IM SDK

Our products or services may include products or services of third parties, which may also collect and use your personal information. We have integrated Tencent IMSDK to implement instant messaging services. Tencent IM will act as a data processor and collect, use and protect your personal information in accordance with the instructions of our company and the IM SDK Privacy Protection Guidelines.

For further information on how IM processes your personal information, please refer to the following privacy policy:

https://trtc.io/document/48827?product=privacysla

Data Retention and Deletion

7.1 Data Retention

How long we retain your personal information depends on why we collected it and how we use it, but we will not retain your personal information for longer than is necessary for our business purposes or for legal requirements.

As a general rule, we retain your personal information only as long as required to perform the Services or other purpose that was the reason for the collection of the information. We will retain most of your personal information as long as you use the Services (i.e., until account deletion in accordance with your request) with the following exceptions: Contact Information that is obtained as a result of you participating in our promotional activities will be retained during such activities as expressly designated in the corresponding activities.

We will retain personal information about you and connected with your account and/or the Services you use from us for as long as you have an active account with us. We will take reasonable measures to delete this personal information if you delete your account. However, you acknowledge that we will keep certain records (e.g., personal information relating to payments or customer service matters) where we need (and have rights) to, such as for legal or accounting purposes. We'll also keep information in order to exercise, defend, or establish our rights.

In the event that the processing and retention period have terminated, but personal information is required to be retained continuously for other reasons including for archiving purposes as prescribed under applicable laws, the relevant personal information will be stored and maintained separately from other types of personal information. If you require us to destroy your personal information before the end of its life cycle (as set out in the retention policy above), we will destroy your personal information in accordance with local laws).

7.2 Data Deletion

You can delete your account, or remove certain personal information.If there is any other personal information you believe we process that you would like us to erase, please contact us at support@SOGA.com.com.Please state your account ID and deletion request in your email clearly. We will usually process your request within 48 hours of receiving your email.

You may request that we erase the personal information we hold about you in the following circumstances:
you believe that it is no longer necessary for us to hold such personal information; or
you believe the personal information we hold about you is being unlawfully processed by us.
You can also exercise your right to restrict our processing of your personal information (as described below) while we consider your request.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (e.g., for the defense of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Services and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.

When destroying personal information, measures will be taken to make the personal information irrecoverable or irreproducible, and electronic files which contain personal information will be deleted permanently using a technical method which makes the files irreproducible.

Your Rights

During the time you use Application Service, we may provide you with the corresponding operation settings based on the specific situation of the application products, so that you can search, delete, change or withdraw your relevant personal information. You can refer to the specific instructions of the corresponding application products to guide your operation. In addition, we have set up the channel to receive complaints and reports, and your opinion will be dealt with in a timely manner. To exercise any of your rights regarding personal information, please contact us at support@SOGA.com.

Changes to the Privacy Policy

We may revise and update this Privacy Policy from time to time and it will take effect immediately after the update. After each update, we will notify you to review the updated policy through the corresponding prompt in the application.

Protection of Minors

We attach great importance to the protection of minors'personal information, and we will keep exploring new ways to protect minors'personal information.

We will protect the legitimate rights and interests of minors by initiating anti-addiction system in accordance with relevant regulations on online application anti-addiction policies. We will make a judgment on whether the name information of an account belongs to a minor via the identification result of information such as name identity, based on which we decide whether the account shall be included in the anti-addiction system. In addition, we will collect information such as your login time, length of using applications, etc., and guide the minors to use applications rationally through ways such as automatically intervening and limiting the application duration of the minors in our system, enabling the function of mandatorily exiting the application, etc. When the consumption is conducted by a person suspected to be a minor, we will then try to contact his or her parent or legal guardian for reminders, confirmations and deposition, so as to help the minors have a healthy access to the Internet.

At the same time, in order to better protect both the physical and mental health of minors and facilitate a healthy access to the Internet for them, we may employ stricter anti-addiction measures on the basis of relevant anti-addiction policies related to online applications. Further, we will keep conducting researches and testing various technologies to protect the minors. For example, in order to further improve the accuracy of name verification on identities and to try best to prevent minors from impersonating the identity of others, we may enable verifications in some applications or for some users (subject to specific application strategies) under specific situations (for example, when you log into a application, or when you top up, purchase or make transactions during the application).

Besides, we may also collect your application behavior data generated during the application (for example, the data such as the click pressure and radius, the relative position of the click, the acceleration direction, and the direction of gravity formed when you operate the application on the terminal device, and the voice data generated when you interact with other players through online voice in the application) to preliminarily determine whether the user is a minor (regarding the voice data, the system will only randomly use some of your online voice to judge whether it is from a child or an adult). If the preliminary determination shows you are a minor, we may enable the verification in accordance with the foregoing prescriptions.

If you are the parent or legal guardian of a minor, please pay attention to whether the minor uses Application Service or provides his or her personal information after obtaining your authorization and approval. Please contact us if you have questions about the personal information of the minor under your guardian.

If you have any questions about these terms, please contact us and be sure to state your name and questions in the message to support@SOGA.com.
We will review the relevant questions as soon as possible, and will respond within 15 days upon verifying your user identity.