Last updated: 21 January 2023
This Privacy Policy (the “Policy”) is established to protect our customers’ personal information under Xoin Inc. (“Xoin Games”, “Xoin”, “The Company”, “we”, “our” or “us”). The Policy explains the way of treatment of the information which is provided or collected on the websites on which this Policy is posted. In addition, the Policy also explains the information which is provided or collected in the course of using the applications of the Company which exist on the websites or platforms of other companies.
The Company is the controller of the information provided or collected in the websites on which this Policy is posted and in the course of using the applications of the Company which exist in the websites or platforms of other companies.
Through this Policy, the Company regards the personal information of the users as important and informs them of the purpose and method of the Company’s using the personal information provided by the users and the measures taken by the Company for the protection of that personal information.
This Policy is established on the 10th day of January. Modified on the 21st day of January. This Policy will be effective on the 21st day of January 2023 and, in case of modification thereof, the Company will make a public posting on the Company’s website.
By using the Services you consent to the use of your Personal Information as described in this Privacy Policy. Please note that it is always your choice whether or not to provide Personal Information.
Two types of information may be collected through the Services: Personal Information and Non-Personal Information. This Privacy Policy does not extend to the collection, use, or disclosure of the following information which is currently not limited: (a) information that is publicly available, such as names, addresses, telephone numbers, and electronic addresses when listed in a directory or made available through directory assistance; or (b) Non-Personal Information (as defined further below).
“Personal Information” is personally identifiable information, such as your name and e-mail address. We may retain this information for the purpose of providing the Services and for communication with you.
“Non-Personal Information” is information of an anonymous nature, such as an Internet Protocol Address (IP Address) and information that our web servers may automatically collect through your browser or through cookies when you visit the Website. We may also collect aggregate information such as demographic statistics of our users (e.g. number of visitors and geographical allocation of our users).
The obligations in this Privacy Policy relate to Personal Information, however, we provide information about our use of Non-Personal Information for the sake of transparency with respect to the operation of the Services.
1) Information to be collected and method of collection
1.1) Personal information items to be collected
The personal information items to be collected by the Company are as follows:
1.1.1) Information provided by the users
The Company may collect the information directly provided by the users.
Registration & Forums
∘ In order to utilize the Services, you must create a user account and select a user name. While registering, you may provide us with your email, username, etc. Your username may be visible to the public; all who access the Services (Games). The chat, profile walls, and forums within our Services (Games), allow you to communicate with members of the online community. Whenever you give out information in public areas, that information can be collected and used by people you do not know. We recommend that you should not give out your Personal Information in public. Also, giving out other people’s Personal Information within the services is against the Terms of Service.
Support
∘ Certain parts of our Services may ask you to provide personal information voluntarily; your name, email address, or other details, are necessary to process your inquiries; and any information you submit to our support team via email.
∘ The personal information that you asked to provide and the reasons why you are asked to provide it, we will try to explain to you at the point we ask you to provide your personal information.
Applications from Xoin Inc. on Partner-Operated Websites or applications from Xoin Inc. in Partner-Operated Services
∘ In order to use the Services (Games) on third-party operated websites (e.g., Facebook) we may require you to
1. be a registered member of a partner site, and
2. install a Xoin Inc. application on your partner site account. If your use of Service (Games) requires app installation on a third-party-operated website, you generally must agree to the partner site’s Terms of Service.
∘ In order to use the Services (Games) with a third-party operated website account (e.g., Google account) we may require you to
1. be a registered member of a partner site, and
2. Provide your information on the partner site’s profile information. If your use of the Service requires agreement, you generally must agree to both Xoin inc. and the partner site’s Terms of Service.
1.1.2) Information collected while the users use services
Besides information directly provided by the users, the Company may collect information in the course that the users use the service provided by the Company.
Device IDs
∘ When downloading or installing our Games (apps), information such as a unique device identifier will be provided to us. We use this information in order to sync your specific Game with your device. The unique device identifier does not include or give access to the owner’s name, address, or other personal information registered to that device.
Log information
∘ IP address, log data, use time, search word input by users, internet protocol address, cookie, and web beacon
∘ Your IP address is reported by your web browser when you visit a page on the Website. This information is recorded together with your user account information on our databases. We use this to:
•Diagnose problems and any issues reported by users that are related to the IP addresses controlled by specific parties.
•Gauge how many users are visiting the Website from different geographical regions and using the Services.
•Trace back the source of any malicious or illegal use of the Services (such as having interacting multiple accounts) so that we can more easily track and disable such usage as it arises.
Other information
∘ Preference, advertisement environment, visited pages regarding service use of users, Apple Identifier for Advertisers, Google Advertising Identity
1.2) Method of collection
The Company collects the information of users in a way of the following:
• webpage, written form, fax, telephone calling, e-mailing, tools for collection of created information (e.g., Google Analytics, Firebase, Unity Analytics, etc)
• provided by partner companies
1.3) Advertising ID
Advertising ID means Apple Identifier for Advertisers (“IDFA”) on Apple and Google Advertising Identity (“GAID”). These are unique identifiers for the mobile devices that advertisers use for personalized advertising. They are consistent across all mobile applications and thus allow cross-app tracking. On Apple, you can opt out of it by choosing the “limit ad tracking” option in your privacy settings. On Google Android, you can opt out of these ads by choosing “Opt-out of personalized ads”. Advertising IDs are non-permanent, non-personal identifiers, which are uniquely associated with your device.
2) Use of collected information
2.1) Use
The Company uses the collected information of users for the following purposes:
• Member management and identification
• To detect and deter unauthorized or fraudulent use of or abuse of the Service and penalize
• Performance of the contract, service fee payment, and service fee settlement regarding the provision of services demanded by the users
• Improvement of existing services and development of new services
• Making notice of the function of company sites or applications or matters on policy change
• To make statistics on member’s service usage, to provide services, and place advertisements based on statistical characteristics
• To provide information on promotional events as well as the opportunity to participate
• To comply with applicable laws or legal obligations
• Use of information with the prior consent of the users (for example, utilization of marketing advertisement)
The Company agrees that it will obtain consent from the users if the Company desires to use the information other than those expressly stated in this Policy.
2.2) In-App Purchases
Our Games enable in-app purchases. But we do not process payments for in-app purchases nor have access to your credit card information.
Payment transactions for in-app purchases are completed through the app store via your App Store account, Google Play account. Any post-purchase processes are controlled by Apple, and Google stores and are subject to specific terms such as Apple, and Google stores. Please review the privacy policy and terms of service of your Apple, and Google stores.
You can always request a refund from the applicable link below:
iOS: https://support.apple.com/en-us/HT204084
Google Play: https://support.google.com/googleplay/answer/7205930
To cancel your subscription please visit the applicable link below and follow the instructions:
iOS: https://support.apple.com/en-us/HT202039
Google Play: https://support.google.com/googleplay/answer/7018481?hl=en&co=GENIE.Platform%3DAndroid
3) Disclosure of collected information
Except for the following cases, the Company will not disclose personal information with a 3rd party:
• when the Company discloses the information with its affiliates, partners, and service providers;
– when the Company’s affiliates, partners, and service providers carry out services such as bill payment, execution of orders, products delivery, and dispute resolution (including disputes on payment and delivery) for and on behalf of the Company
• when the users consent to disclose in advance;
– when the user selects to be provided with the information of products and services of certain companies by sharing his or her personal information with those companies
– when the user selects to allow his or her personal information to be shared with the sites or platforms of other companies such as social networking sites
– other cases where the user gives prior consent for sharing his or her personal information
– when disclosure is required by the laws:
– if required to be disclosed by the laws and regulations; or
– if required to be disclosed by the investigative agencies for detecting crimes in accordance with the procedure and method as prescribed in the laws and regulations
• Important Exceptions
– if we have reason to believe that disclosing this information is necessary to identify, contact, or bring legal action against someone who may be causing injury to, or interference with (either intentionally or unintentionally), our rights or property.
– other Website members, other users of the Services, or anyone else (including the rights or property of anyone else) that could be harmed by such activities
– when we believe in good faith that such disclosure is required by and in accordance with the law
• Re-organization of the Company
– a merger or amalgamation with another entity, a sale of all or a substantial portion of our assets or stock, including any due diligence exercise carried out in relation to the same
– provided that the information disclosed continues to be used for the purposes permitted by this Privacy Policy by the entity acquiring the information
• Third-party sites and advertisers
– Our Services may contain third-party tracking and data collection and analytics tools from our service providers, examples of which include Game Analytics, Facebook, Fyber, and Singular. Such third parties may use cookies, APIs, and SDKs in our Services to enable them to collect and analyze user and device-related data and information on our behalf. The third parties may have access to and collect data and information about you, such as your device identifier, MAC address, IMEI, locale (specific location where a given language is spoken), geo-location information, IP address, application usage, access and session times, applications present on the device or in use at a particular time on the device, and your viewing of and interactions with advertising, for the purpose of providing their services, including, for example, enabling, providing and delivering advertising.
– When using the Services, you may be introduced to a variety of third-party vendors and websites. We do not share Personal Information with these third-party vendors or websites and we do not control the privacy policies of these third parties. The use of any information that you may provide to any third party or the use of cookie or web beacon technology by any third party, will be governed by the privacy policy of the operator of the website you are visiting. If you have any questions about providing Personal Information on another website, we recommend that you contact that website directly for more information and review their Privacy Policy.
– Advertisements appearing on the Xoin Inc. website, and within the Services (Games), may be delivered by us or one or more third-party web advertisers. Wherever you click on an advertisement, you may be taken to another service where we do not monitor or control your privacy. Third-party web advertisers may set cookies to allow the advertisement server operated by that third party to recognize your computer each time they send you an online advertisement. Accordingly, advertisement servers may compile information about where or whether you viewed their advertisements and which advertisements you clicked on. Xoin Inc.’s Privacy Policy does not cover the use of cookies by any third-party web advertisers and you should consult the applicable privacy policy for the relevant third-party web advertiser(s).
4) CCPA
As of January 1, 2020, the California Consumer Privacy Act (CCPA) was implemented and provides certain privacy rights to consumers in the state of California. The CCPA provides protections for individuals in California pertaining to how their personal information is collected, what personal information is collected, and options for exercising their data privacy rights under that Act.
The stated aim of the CCPA is to ensure six rights for Californian consumers:
• To know what personal data you hold about them
• To access the personal data without charge
• To know whether you sell or share their personal data (and if so, who gets it)
• To demand that you don’t sell their personal data
• To demand that you delete their personal data
• To exercise these rights without it affecting the services
We will not sell your personal information to any party. If that changes in the future, we will provide you with an opt-out capability as well as inform you of your opt-out rights as required by the CCPA.
If you require more information or need clarification, please reach out to privacy@xoingames.com
5) CASL Policy
We are committed to compliance with Canada’s Anti-Spam Legislation (“CASL”). Any electronic communication we send to outside parties is protected by a range of business procedures, processes, and policies to ensure that such communication is done in compliance with CASL. In our electronic communications with outside parties, we comply with the rules established by CASL and enforced by various Canadian authorities including the Canadian Radio-television and Telecommunications Commission. CASL regulates, and our policies generally apply to, each commercial electronic message (a “CEM”) that we send. A CEM is an electronic message sent to an electronic address that, among its purposes, encourages participation in a commercial activity.
In addition to adopting and updating this Policy, we undertake various transparency initiatives to ensure we comply with CASL, which include:
• Consent: we do not send you CEMs without your consent. This consent typically must be “express” (expressly acknowledged by you), but in certain circumstances can be “implied”. In other limited circumstances, consent is not required. We modified or adopted our sign-up, registration, and consent forms in order to ensure that your consent is meaningful (i.e. informed and freely given) as required by CASL. When we collect your electronic contact information, you will know the exact purposes behind the collection.
• Content: we adopted processes to ensure that our CEMs contain the following requirements prescribed under CASL, which will usually be in the footer of the CEM. We will:
- Identify ourselves as the party sending the CEM, and whether we are sending the message on our own behalf or on behalf of someone else;
- Provide you with our contact information; and
- Set out a clear, working unsubscribe mechanism or preference centre that is easy to use, automatic, and at no cost to you (other than your own cost of connecting to the Internet).
• Clarity— we ensured that each aspect of a CEM, including its header, content, or any links or URLs in the CEM) conveys the appropriate information, whether viewed individually or taken as a whole so that you always know what you are clicking on.
If you receive a CEM from us but believe that you should not have or no longer wish to receive CEMs, we will aim to respect your preferences in a timely manner once you update them through our unsubscribe mechanism. CASL requires us to process unsubscribe requests within 10 business days. If you have any questions or concerns about our unsubscribe options, you may contact us at the address indicated in Section 10 below.
6) Cookies, Beacons, and Similar Technologies
The Company may collect collective and impersonal information through ‘cookies’ or ‘web beacons’.
Cookies are very small text files to be sent to the browser of the users by the server used for the operation of the websites of the Company and will be stored on hard disks of the user’s computer.
A web beacon is a small quantity of code that exists on websites and e-mails. By using web beacons, we may know whether a user has interacted with certain webs or the contents of the email.
These functions are used for evaluating, improving services, and setting-up users’ experiences so that many improved services can be provided by the Company to the users
The items of cookies to be collected by the Company and the purpose of such collection are as follows:
performance cookies
This cookie collects information on how the users use the website of the Company such as the information of the pages which are visited by the users most. This data helps the Company to optimize its website so that users can search that website more comfortably. This cookie does not collect any information about who are the users. Any and all the information collected by this cookie will be processed collectively and anonymity will be guaranteed.
∘ Web analysis: provide statistical data on the ways of using the website
∘ Management of error: measure an error that may occur so as to give help for improving the website
∘ Design testing: test other designs of the website of the Company
functionality cookies
This cookie is used for memorizing the set-ups so that the Company provides services and improves the visits of users. Any information collected by this cookie does not identify the users individually.
∘ Memorize set-ups applied such as layout, text size, basic set-up, and colors
∘ Memorize when the customer responds to a survey conducted by Company
7) USER’S RIGHT
The users or their legal representatives, as main agents of the information, may exercise the following rights regarding the collection, use, and sharing of personal information by the Company:
• exercise the right to access personal information;
• make corrections or deletions;
• make temporary suspension of treatment of personal information; or
• request the withdrawal of their consent provided before
If, in order to exercise the above rights, you, as a user, use the menu of ‘amendment of member information of webpage or profile of the application. You can contact the Company by sending a document or e-mail to the company(or the person in charge of the management of personal information or a deputy), the Company will take measures without delay: Provided that the Company may reject the request you only to the extent that there exists either proper cause as prescribed in the laws or equivalent cause.
8) Security
The Company regards the security of personal information of uses as very important. The company constructs the following security measures to protect the user’s personal information from any unauthorized access, release, use, or modification
• Encryption of personal information
– Transmit users’ personal information by using an encrypted communication zone
– Store important information such as passwords after encrypting it
• Countermeasures against hacking
– Install a system in the zone the external access to which is controlled so as to prevent leakage or damage of users’ personal information by hacking or computer virus
• Establish and execute an internal management plan
• Install and operate the access control system
• Take measures to prevent forging or alteration of access record
9) Data security
The security of your Personal Information is very important to us. We take technical, contractual, administrative, and physical security steps to protect the Personal Information that you provide to us. We have procedures in place that limit the dissemination of your Personal Information to only such designated staff as necessary.
You are also responsible for helping to protect the security of your Personal Information. Never give out your passwords, real name, or address. Do not choose a username that is your real name, and remember to log out of your account and close your browser window when you have finished using the Website or accessing the Services (Games) online.
10) Protection of personal information of children
If you are a child under the age of 13, you must obtain parental consent prior to using our Services. The Company will not knowingly contact or engage with children under the age of 13 without said parental consent. If you have reason to believe that a child has provided us with their PII, please contact us at the address given below and we will endeavor to delete that PII from our databases.
11) Modification of Privacy Policy
We reserve the right to change this Privacy Policy at any time. If changes are made to this Privacy Policy in the future, an appropriate notice will be posted on the home page at www.xoingames.com. Any non-material change (such as clarifications) to this Privacy Policy will become effective on the date the change is posted and any material changes will become effective 30 days from their posting on the Website and notice in the Service(Game). Unless stated otherwise, our current Privacy Policy applies to all Personal Information. The date on which the latest update was made is indicated at the bottom of this document. Your continued use of the Services signifies your acceptance of any changes.
12) Access to the data
You have the right to access the Personal Information we hold about you in order to verify the Personal Information we have collected with respect to you and to have a general account of our uses of that information. Upon receipt of your written request, we can provide you with a copy of your Personal Information, however, we may not be able to make all relevant information available to you such as where that information also pertains to another user.
13) Contact information of the Company
Please use one of the following methods to contact the Company should you have any queries with respect to this policy or wish to update your information:
E-mail: privacy@xoingames.com