PRIVACY POLICY

NOTE: This Privacy Policy may be translated into other languages. In the event of any discrepancy between the English version and a translated version, the English version shall prevail, unless otherwise required by applicable laws or regulations.

Effective Date: April 10, 2026

1. Introduction

RIVER GAME HK LIMITED (“Company”, “we”, “our”, or “us”) develops, publishes, markets and/or commercializes a variety of games for use on various platforms, including mobile devices (“Applications”) through which we offer relating game play and gaming services. We also operate networks and platforms related to our Applications (collectively “Networks”) and web forums or messaging boards related to our Applications and Sites (collectively “Forums”). Any and all of our Applications, Networks, Forums and any other related services provided by us are referred to herein as our “Services”.

To the extent permitted by applicable law, children under the age of 13 (or other age thresholds required by local laws) are not allowed to use the Services. If you are 13 or older but considered a minor in your country (e.g. under 18 years old in some jurisdictions), you must have your parent or guardian read through this Privacy Policy with you and you represent that you have obtained the permission of your parent or guardian to use the Services, including making purchases in exchange for certain parts of our Services.

This Privacy Policy is intended to provide notice of the Company’s information practices, including the types of personal data gathered, how personal data is used and safeguarded, and how you may control the maintenance and sharing of your personal data. This Privacy Policy applies to personal data we collect through our Services. If you have any questions, please reach out to us as described in “Contact Us” below.

By clicking or checking “I agree”, “Accept”, “Next”, “Play” or similar statements on our Applications and Sites, or by accessing or using any part of our Applications, Sites and/or Services, you acknowledge that you have read and understood this Privacy Policy, and hereby agree to and consent to our collection, use, disclosure and/or processing of your personal data as described in this Privacy Policy. If you do not agree with any terms of this Privacy Policy, please do not access or use our Services. 

2. Contact Us

If you have questions about data protection or requests regarding your personal data, we encourage you to reach out to us primarily through the support features available in our games, as this allows us to respond to you more promptly. Alternatively, you can contact us at: privacy_th@rivergame.net

3. What Data We Collect and Process

Personal data means any information relating to an identified or identifiable natural person, such as full name, email address, contact address, postal code, location data, personal interests.

We may collect personal data about you in the following ways: (1) directly from you, (2) automatically through your use of our Services, or (3) from third parties. The personal data we receive depends on factors such as the Services you use, the third parties we partner with or you integrate with, and your privacy settings.

(1) Data that you provide directly: We may collect your personal data directly from you when you choose to provide us with such personal data online and through your other interactions with us (such as data collected via social media and any surveys, customer service communications, competitions or other promotional programs in which you may participate). Certain parts of our Services may ask you to provide personal data when you engage in activities such as linking an email address or social media accounts (such as Facebook or Google), contacting customer service and making purchases or arranging for delivery of goods/services.

(2) Data we collect automatically: We may automatically collect your personal data through technical means from your device when you use our Services. We may also use “cookies” and similar technologies to collect your personal data, as explained in the “Cookies and Tracking Technologies” section below.

(3) Data from third parties: We may also collect your personal data from third-party sources, including other users, service providers, advertising networks, analytics providers, business partners, and publicly available sources.

The table below describes the categories of personal data we collect from and about you through our Services.

For some websites, apps, or services provided by us, we may collect additional personal data beyond the data listed above. In such cases, we will develop individual privacy notices to inform you how we process your personal data when you use the specific Services. Such individual privacy notices will prevail in terms of the personal data processed for such individual Services.

When you are asked to provide personal data, you may decline. You may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow our collection, use, disclosure or processing of personal data that is necessary for certain Services or features, those Services or features may not be available or fully functional. For certain categories of personal data, provision of the information is required to enable us to fulfil our contract with you. If you do not provide this information, we will not be able to provide you with our Services.

4. Cookies and Similar Technologies

Cookies and other similar technologies (“cookies”) are small data files stored on your browser or device to enhance your experience on our Site and to prevent fraud when you use our websites. When you visit our Site, one or more cookies may be sent to your browser. Our partners may also place cookies and, in some cases, act as independent controllers of your data, as further described in the “Who May Access Your Personal Data” and “Third-Party Partners” section below.

1. How do we use Cookies?

Our Services primarily use first-party cookies, which are set and controlled by us. However, certain features of our Services may require you to accept third-party cookies. Please note that such third parties may operate under their own privacy policies.

We use Cookies that perform the following functions:

Strictly Necessary Cookies, which are essential to the functioning of our Services, to provide a service requested by you or to comply with the law (e.g. the security requirements of data protection law). These Cookies are always active and cannot be turned off as we cannot provide the Services without them.

Statistics Cookies, which allow us to collect statistics about the user such as the number of visits, traffic sources, and time spent on pages. This helps us measure and improve performance.

Preferences Cookies, which enable us to collect information about your online activity (e.g. the duration of your use of the Services). They allow us to provide you with a better user experience and to maintain, operate and continually improve the Services.

2. Changing your settings

We use Cookies when providing our Services to make sure you benefit from the best experience. Some of these Cookies are essential and we can’t provide our Services without them. Others are not essential, and you can turn them off and have the right to choose whether or not to accept them. However, if you choose to refuse Cookies you may not be able to use the full functionalities of our Services.

You can change your Cookie preferences by accessing the cookie banner displayed upon your first visit to our website. Your preferences can be updated at any time.

Most browsers and devices allow you to change your settings. If you choose to delete certain Cookies, settings and preferences stored in those Cookies may also be deleted and may need to be reset.

If you disable one or more Cookies, we will still use the information collected via these Cookies prior to your disabled preference being set; however, we will stop using the disabled Cookies to collect any further information.

Please note that the necessary cookies will always remain active on your device. Where required by law, we seek your consent before using non-essential cookies or sharing cookie data with third parties. You may reject or delete cookies in your browser settings as described in the “Your Rights and Choices” section below. You may also email your request to privacy_th@rivergame.net. However, please note that if you reject or delete certain cookies, some parts of the Services may not be available or may not function properly. 

5. How We Use, Disclose or Process Your Personal Data

We may use, disclose or process the personal data we collect for purposes described in this Privacy Policy or for purposes that we explain to you at the time we collect your data. We are required to disclose the legal basis for processing your data under certain applicable laws, including the GDPR. To the extent that such laws apply to you, we rely on the following legal bases to collect and process your personal data:

Contract – we require certain personal data in order to provide and support the Services you purchase or request from us;

Consent – in certain circumstances, we may ask for your consent (separately from any contract between us) before we collect, use, or disclose your personal data, in which case you may freely choose to give or withhold your consent without any negative consequences to you;

Legitimate interests – we may use or disclose your personal data for the legitimate business interests of either us or a third party, provided that such legitimate interests are not overridden by your privacy rights. If we rely on our (or a third party's) legitimate interests, these interests will normally be to: operate, provide and improve our business, including our Services; communicate with you and respond to your questions; improve our Services or use the insights to improve or develop marketing activities and promote our products and services; detect or prevent illegal activities (for example, fraud); and/or to manage the security of our IT infrastructure, and the safety and security of our employees, customers and vendors. Any reliance on our legitimate interests or the legitimate interests of a third party will be consistent with your reasonable expectations to be part of the operation of our business and will not materially affect your rights and freedoms. We have identified below what our legitimate interests are; or

Legal obligation – there may be instances where we must process and retain your personal data to comply with laws or to fulfil certain legal obligations.

The following table provides more details on our purposes for processing your personal data and the related legal basis. The legal basis under which your personal data is processed will depend on the data concerned and the specific context in which we use it. If we process your data for other purposes, we will provide you with a specific notice at the time of collection.

We may combine data we collect from different sources for these purposes and to give you a more seamless, consistent, and personalized experience.

6. Who May Access Your Personal Data

In addition to the Company and/or its affiliates, other parties may also access your personal data in the following situations. You acknowledge that you have foreseen the occurrence of such disclosure when you provide your personal data.

* Public: Some of your profile information can be seen by other users in the games such as your profile name (either the default name or the profile name of your choosing), your profile image (the default image, an image you select, the photo you take, or the profile photo associated with a linked account), your comments and the level of the game you are playing. You may select options available to edit your profile name, change your profile picture, and certain other information. Any data you post to any communication area is publicly viewable. We strongly recommend that all users avoid posting personal or sensitive data at any time on or through our Services.

* Service providers: We may provide personal data to third-party vendors, service providers, contractors or agents who perform functions on our behalf for the purposes described in this Privacy Policy. For example, this includes companies we hire to provide customer services support and game play analysis.

* Financial services and payment processing:  When you provide payment information, for example, to make a purchase, such payment and transactional data will be used by the banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, analytics, and/or other related financial services.

* Affiliates: We enable access to personal data across our subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access helps us to provide our Services and operate our business.

* Corporate transactions: We may disclose personal data as part of a corporate transaction or proceeding such as a merger, financing, acquisition, bankruptcy, dissolution, or a transfer, divestiture, or sale of all or a portion of our business or assets.

* Legal and law enforcement: We will access, disclose, and preserve personal data when we believe that doing so is necessary to comply with applicable law, a judicial proceeding, court order, or other valid legal process, including from law enforcement or other government agencies, whether within or outside Hong Kong.

* Security, safety, and protecting rights: We will disclose personal data if we believe it is necessary to: to protect us, our users, and others, for example to prevent spam or attempts to commit fraud, or to help prevent the loss of life or serious injury of anyone; to operate and maintain the security of our Services, including to prevent or stop an attack on our computer systems or networks; or to protect the rights or property of ourselves or others, including to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, enforce our agreements, terms, and policies, or as support or evidence in any dispute or litigation in which we are involved.

* Business Partners: Depending on the third-party platform policies and only at your direction, we will share personal data including your profile name, your UID, your profile picture and certain in-game content (such as the level of game you are playing, screenshots of your gameplay) to your accounts with third-party platforms. Additionally, we may run collaborations and special events with our business partners. These events may be run locally or globally, online or offline. If you participate in these special events, your personal data may be shared with these business partners in order to carry out the event, delivery of any prizes, to follow up on any events which you had opted in for, etc.

* Third-party analytics and advertising companies: These parties may collect personal data through our Services, including identifiers and device information (such as device IDs), IP address, usage data, and inferences based on and associated with that data. If some of the disclosures to these third parties are considered a “sale” or “sharing” of personal data as defined under the laws of California and other U.S. states, you may see the “Your Rights and Choices” section and relevant subsection in the “Supplemental Terms – Jurisdiction-Specific” section below for more details.

We may also disclose personal data if we believe it is necessary to protect us, our users, and others, for example to prevent spam or attempts to commit fraud, or to help prevent the loss of life or serious injury of anyone; to operate and maintain the security of our Services, including to prevent or stop an attack on our computer systems or networks; or to protect the rights or property of ourselves or others, including to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, enforce our agreements, terms, and policies, or as support or evidence in any dispute or litigation in which we are involved.

Please note that some of our Services also include integrations, references, or links to services provided by third parties whose privacy practices differ from ours. If you provide personal data to any of those third parties, link or bind your accounts, or allow us to share personal data with them, that data is governed by their privacy statements.

7. Your Rights and Choices

We provide a variety of ways for you to control the personal data we hold about you, including choices about how we use that data. In some jurisdictions, these controls and choices may be enforceable as legal rights under applicable law. If you are a resident of the UK, EEA, Switzerland, or California, please see the relevant subsections in the “Supplemental Terms – Jurisdiction-Specific” section below.

(1) Access, portability, correction, and deletion. In some jurisdictions, you have the right to access, receive a copy of, correct, and delete your personal data. If you reside in one of these jurisdictions, and you wish to access, receive a copy of, correct, or delete personal data about you that we hold, you may make your request by emailing privacy_th@rivergame.net. Subject to applicable laws, we may require you to provide some personal data so that we can verify your request and locate your personal data to fulfill your request.

Please note that certain records, for example those relating to payments or customer service matters, will be held for legal and accounting purposes.

If you have previously received push notifications through your device, you can stop receiving push notifications by visiting your mobile device's settings for the relevant Application or in some cases, through the Application itself.

You acknowledge and agree that as a result of deleting your account, you will lose access to game-related services, including the account data and game-related data linked to such account and lose the possibility to access other services through the account.

(2) Withdrawal of consent. If we have collected and processed your personal data with your consent, you can withdraw your consent in accordance with applicable laws. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data based on lawful processing grounds other than consent. In many circumstances, we need to use your personal data to provide you with our Services you require. If you do not provide us with the required personal data, or if you withdraw your consent to our use and/or disclosure of your personal data for these purposes, it may not be possible for us to continue to serve you or provide you with the Services that you require.

(3) Communications preferences. If any promotional communication has been made to you, you may opt out of promotional communications by following the opt-out instructions contained in the promotional communications, or by contacting us as described in the “Contact Us” section above. Please note that it may take some time for us to process opt-out requests. If you opt out of receiving promotional emails, we may still send you emails about your account or any Services you have requested or received from us.

(4) Data sales. Some laws define “sale” broadly to include certain disclosures described in the “Who May Access Your Personal Data” section above. For more details, please refer to the “13（2）Additional Information for US Residents” section below.

(5) Browser or platform controls.

• Cookie controls. Most web browsers are set to accept cookies by default. If you prefer, you can adjust your browser settings to learn how to reject or delete certain cookies. Please note that rejecting or deleting certaincookies may affectthe functionality of some features or services of our Sites. If you choose to deletecertain cookies, settings and preferencesstored in those cookies may also be deleted and may need to be reset.

• Mobile advertising ID controls. iOS and Android operating systems provide options to limit tracking using advertising IDs and/or reset the advertising IDs.

• Do Not Track (DNT). Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is no common understanding of how to interpret the DNT signal, our Sites do not currently respond to DNT signals. Instead, you may use other tools described above, to control data collection and use, including the cookies controls and advertising controls described above.

(6) Email web beacons. Most email clients have settings which allow you to block the automatic downloading of images, including web beacons, which prevents the automatic connection to the web servers that host those images.

Except for the automated controls described above, if you send us a request to exercise your rights or choices, we may decline requests in certain cases to the extent permitted by applicable law. For example, we may decline a request if granting it would be prohibited by law, would adversely affect the privacy or rights of another person, would reveal a trade secret or other confidential information, or would interfere with a legal or business obligation that requires us to retain or use the data. Furthermore, subject to applicable laws, we may also decline a request if we are unable to authenticate you as the person to whom the data relates, if the request is unreasonable or excessive, or if otherwise permitted by applicable law. If we decline your requests in whole or in part, we will notify you that we have declined your request, and you may appeal that decision by submitting your appeal using the contact methods described at the beginning of this Privacy Policy.

8. Third-Party Partners

Our partners use technologies to enhance and customize your experience, analyze usage, and prevent fraud. If you click on a link to a third-party website, including, without limitation, an advertisement, you will leave our website and go to the website you selected. Please be aware that our partners may have their own privacy policies governing their use of these technologies (as illustrated in the examples below). When specific third parties are involved in collecting data and information, please refer directly to their privacy policies and learn more about their data processing practices.

9. Retention of Personal Data

We retain personal data for as long as necessary to provide the Services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes. Because these needs vary for different data types in the context of different services, actual retention periods can vary significantly based on criteria such as whether we need the information to continue providing you the Services, resolve disputes, enforce our policies, prevent harm, promote safety, security and integrity, user expectations or consent,, our rights, the rights of our users, or others, the sensitivity of the data, the availability of automated controls that enable users to delete data, to protect or defend the Services, and our legal or contractual obligations. 

In the case you request to remove or delete your personal data, we will retain your data as long as necessary for applicable laws and regulations, such as to comply with our legal obligations, resolve disputes, and/or enforce the agreements between you and us. Please note that the removal or deletion of any of your data may result in the termination of some of our applicable Services.

10. Location and International Transfer of Personal Data

To the maximum extent permitted by the applicable laws and regulations, the personal data we collect from you may be accessed from, transferred to, stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, partners, or service providers process data. The storage locations are chosen to operate efficiently and improve performance. Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction. We take steps with the intent of processing and protecting personal data as described in this Privacy Policy, wherever the personal data is located.

11. Security of Your Personal Data

Please note that the transmission of data via the Internet is not completely secure. While we strive to protect your personal data, we also remind you to be aware of hacking, cyberattacks, and other risks on the Internet.

Therefore, we strongly urge you to take every possible precaution to protect your personal data when using our Services, including but not limited to using a secure browser and/or taking other possible security measures.

Please be aware that advertisers or websites with links to and/or from our websites may collect personal data about you. This Privacy Policy does not apply to such third-party services, and we cannot control the activities of those third parties. We highly recommend that you read the privacy policies of such third-party websites which you may be directed to before providing any personal data.

12. Age Limits and Children Protection

Protecting children’s privacy online is important to us. Generally, our Services are not directed to children under the age of 13 (or such other age as required by applicable local law), and we do not knowingly collect personal data from children, except as described below.

For Services that are not specifically directed to children but may nonetheless appeal to them, we take additional measures to restrict access to certain features based on the user’s age. Where a user indicates that they are under 13 (or the applicable age in their jurisdiction), access to certain features, such as social or chat-related functionalities, may be limited.

In certain jurisdictions and for certain Services, a higher age threshold than described above may apply. This is intended to help provide a safer experience, protect users, or comply with applicable legal requirements. Depending on the features available in a particular Service, some functionalities may be accessible to child users only with verifiable parental or guardian consent. Parents or guardians may have the ability to review and modify the permissions they have provided regarding their child’s use of specific features.

We may engage one or more third-party service providers to support age verification and parental consent processes. In such cases, we may collect and process certain data from child users to operate and maintain our Services and comply with applicable law, including date of birth, country or inferred location to determine age and apply appropriate settings; parent or guardian email address to provide notice and seek verifiable consent (which will be deleted if no response is received within a reasonable time), and persistent identifiers such as IP addresses, game IDs, and device identifiers to support service operation, analytics, and security functions. Such data may be collected and processed prior to obtaining parental or guardian consent to support these purposes and internal operations, for example, to trigger age verification or other operational requirements.

13. Supplemental Terms – Jurisdiction-Specific

(1) Additional Information for UK, EEA or Swiss Residents

1. Your Privacy Rights.

If the processing of personal data about you is subject to UK or European Economic Area (EEA) or Swiss data protection law, you have certain rights with respect to your personal data:

l You can request access to, and rectification or erasure of, your personal data;

l If any automated processing of personal data is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal data in a usable and portable format;

l If the processing of personal data is based on your consent, you can withdraw consent at any time for future processing using the contact details provided under the “Contact Us” section above. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal data based on lawful processing grounds other than consent;

l You can object to, or obtain restriction of, the processing of personal data under certain circumstances as permitted by the applicable laws or regulations;

l You have the right to opt out of marketing communications we send to you at any time. You can usually exercise this right by following the opt-out instructions contained in our marketing communications sent to you. You can also contact us using the contact details provided under the “Contact Us” section above. If you choose to opt out of marketing communications, we will still send you non-promotional emails, such as emails about your account or our ongoing business relations;

l You have the right to complain to a supervisory authority about our collection and use of your personal data. For more information, please contact your local supervisory authority. Please note that certain supervisory authorities require you to exhaust our internal complaints process before looking into your complaint；

l To the extent the UK GDPR applies, you have the right, at any time, to make a complaint to us about how we process your personal data, and we will respond to your complaint without undue delay. You may also raise a complaint to the Information Commissioner’s Office; and

l For residents of France, you can send us specific instructions regarding the use of your personal data after your death; and

Please note that a number of these rights only apply in certain circumstances, and all of these rights may be limited by law. For example, if fulfilling your request would adversely affect other individuals or our trade secrets or intellectual property, if there are overriding public interests or if we are required by law to retain your information.

To make such requests to exercise your rights, contact us at privacy_th@rivergame.net. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

Regarding matters pertaining to the GDPR or UK GDPR, please also note that we have appointed the following representatives as required by law:

General Data Protection Regulation (GDPR) – European Representative

Pursuant to Article 27 of the General Data Protection Regulation (GDPR), we have appointed European Data Protection Office (EDPO) as our GDPR Representative in the EU. You can contact EDPO regarding matters pertaining to the GDPR:

- by using EDPO’s online request form: https://edpo.com/gdpr-data-request/;

- by writing to EDPO at Avenue Huart Hamoir 71, 1030 Brussels, Belgium

UK General Data Protection Regulation (GDPR) - UK Representative

Pursuant to Article 27 of the UK GDPR, we have appointed EDPO UK Ltd as our UK GDPR representative in the UK. You can contact EDPO UK regarding matters pertaining to the UK GDPR:

- by using EDPO’s online request form:https://edpo.com/uk-gdpr-data-request/

- by writing to EDPO UK at EDPO UK Ltd, Unit 33, Waterside, Schooner Court, 44-48 Wharf Road, London, N1 7UX, United Kingdom

To make such requests to exercise your rights, contact us at DPO_th@rivergame.net.

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

2. International Transfer

If we transfer your personal data outside of the EEA, UK or Switzerland to a country that is not recognized by the European Commission or relevant UK or Swiss authority (as applicable) as ensuring an adequate level of data protection, we endeavor to apply suitable measures to safeguard your personal data in accordance with applicable data protection and privacy laws. These safeguards may include data transfer agreements implementing the latest standard contractual clauses (a form of data transfer agreement pre-approved by the European Commission as providing adequate safeguards for personal data, or a form of addendum to the foregoing pre-approved by the relevant UK or Swiss authority) unless the data transfer is to a country that has been determined by the European Commission or relevant UK or Swiss authority (as applicable) to provide an adequate level of protection for individuals’ rights and freedoms for their information. If applicable, you may ask for a copy of the relevant data transfer agreement by contacting us as set out in this Privacy Policy.

(2) Additional Information for US Residents

This section provides additional details about how we collect, use, disclose and otherwise process U.S. residents’ personal information, and rights that certain US residents may have under the California Consumer Privacy Act (“CCPA”) and other applicable US state privacy laws.

Categories of Personal Information Collected or Disclosed

In the past 12 months, we have collected the following categories of personal information listed in the CCPA:

1. Identifiers, such as real name, alias, postal address, unique personal identifiers, online identifiers, IP address, email address, account name, and similar identifiers.

- Collection: Collected directly from you when you access or use our Services.

- Disclosure: With our affiliates and service providers (e.g., platform providers, anti-cheating service providers, cloud storage providers, payment processors, online survey providers and customer support providers).

2. Commercial Information, including records of products or services purchased or obtained, such as purchase history, purchase dates, and items acquired.

- Collection: Collected automatically when you make purchases within our Services, including information received from third-party payment providers.

- Disclosure: With our affiliates and service providers (e.g., platform providers, cloud storage providers, payment processors, and customer support providers).

3. Geolocation, such as device IP address.

- Collection:Collected automatically when you access or use our Services.

- Disclosure: With our affiliates and service providers (e.g., platform providers, anti-cheating service providers, cloud storage providers and customer support providers).

4. Internet or other Electronic Network Activity Information, including information about your interactions with our Services (such as device model, operating system version, language, game-related data) and identifiers such as IP address.

- Collection:Collected automatically when you access or use our Services.

- Disclosure: With our affiliates and service providers (e.g., platform providers, anti-cheating service providers, cloud storage providers and customer support providers).

5. Device identifiers, such as device IP address and identifiers that identify a computer or mobile device.

- Collection: Collected automatically when you access or use our Services.

- Disclosure: With our affiliates and service providers (e.g., platform providers, anti-cheating service providers, cloud storage providers and customer support providers).

6. Geolocation Information. Your general location based on your IP address.

- Collection: Collected automatically when you access or use our Services.

- Disclosure: With our affiliates and service providers (e.g., platform providers, anti-cheating service providers, cloud storage providers and customer support providers).

7. Electronic, visual or similar information, such as textual chat data.

- Collection: When you access or play our Services, we collect this automatically.

- Disclosure: With our affiliates and service providers (e.g., platform providers,anti-cheating service providers, cloud storage providers and customer support providers)

8. Inferences.  

- Collection: When you access or play our Services, we collect this automatically and based on information collected directly from you.

- Disclosure: With our affiliates and service providers (e.g., platform providers,anti-cheating service providers, cloud storage providers and customer support providers)

9. Sensitive Information, such as certain user-to-user communications and personal information of users known to be under the age of 16.

- Collection: When you access or play our Services, we collect this automatically and based on information collected directly from you.

- Disclosure: With our affiliates and service providers (e.g., platform providers, anti-cheating service providers, cloud storage providers and customer support providers)

Sensitive Personal Information. We collect, use, and disclose sensitive personal information only for the permissible business purposes for sensitive personal information (as defined under the California Consumer Privacy Act) or without the purpose of inferring characteristics about consumers. We do not sell or share sensitive personal information.

Sale and Sharing. We do not “sell” or “share” (as those terms are defined under the CCPA) personal information, nor have we done so in the preceding 12 months. Further, we do not have actual knowledge that we “sell” or “share” personal information of residents under 16 years of age.

Data Retention. We retain each category of personal information for as long as reasonably necessary based on our business or commercial purposes, applicable legal or regulatory requirements, and the need to establish, exercise, or defend legal claims.

US State Privacy Rights

Certain US state privacy laws may provide residents with some or all of the rights listed below. However, these rights are not absolute and may be subject to certain exceptions. Therefore, we may decline your request in certain cases as permitted by law. To submit a request, please contact us at privacy_th@rivergame.net.

1. Right to Know. You have a right to request that we disclose to you the personal data we have collected about you. You also have a right to request additional information about (1) the categories and/or specific pieces of personal data we have collected about you, (2) the categories of sources for that personal data, (3) the purposes for which we use that personal data, (4) the categories of third parties with whom we disclose the personal data, and (5) the categories of personal data that we sell or disclose to third parties. Additionally, in certain states, you have a right to request that we provide a list of third parties to which we have disclosed your personal data.

2. Right to Request Deletion. You also have a right to request that we delete personal data under certain circumstances, subject to a number of exceptions. However, if certain personal data is necessary for us to provide you with our Services, and you refuse to provide such personal data to us or ask us to delete or stop processing such personal data, we may not be able to provide some parts of our Services.

3. Right to Opt-Out of Selling/Sharing for Targeted Advertising Purposes. We do not “sell,” or “share” personal information of users. We are therefore not required to provide an opt-out.

4. Right to Correct. You may ask us to correct inaccurate information that we have about you.

5. Right to Limit Use and Disclosure of Sensitive Personal Data. We do not process sensitive personal information for purposes that trigger the “Right to Limit.”

6. Right to Non-Discrimination. You have a right not to be retaliated against for exercising these rights.

7. Right of Opt Out of Profiling. We do not process personal data for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers.

Verification. To provide, correct, or delete specific pieces of your personal data, we may need to verify your identity to the degree of certainty required or permitted by applicable law. We may do this by asking you to submit your request or confirm your request from the email address associated with your account or requiring you to provide additional information necessary to verify your account, depending on the rights you request to exercise.

Authorized Agent. You may designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.

Appeal. Should you disagree with our decision pertaining to your rights request, you may have the right to appeal our decision if we deny your request. To appeal, please contact us at privacy_th@rivergame.net and specify what you wish to appeal. We will review and respond to your appeal in accordance with applicable law.

California “Shine the Light” Law. Under California Civil Code section 1798.83, also known as the “Shine the Light” law, California residents who have provided personal data to a business with which the individual has established a business relationship for personal, family, or household purposes (“California Customers”) may request information about whether the business has disclosed personal data to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure of personal data, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom personal data was disclosed in the preceding calendar year, as well as a list of the categories of personal data that were disclosed. California Customers may request further information about our compliance with this law by emailing privacy_th@rivergame.net. Please note that businesses are required to respond to one request per California Customer each year and may not be required to respond to requests made by means other than through the designated email address.

California “Eraser” Law. California residents under the age of 18 who are registered users of online sites, services, or applications have a right under California Business and Professions Code Section 22581 to remove, or request and obtain removal of, content or information they have publicly posted. To request that we remove content or information you have publicly posted, email us at privacy_th@rivergame.net. Please be aware that your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

14. Effective Date; Policy Changes

Each time you use our Services, the current version of the Privacy Policy will apply. Accordingly, when you use our Services, you should check the date of this Privacy Policy (which appears at the top of the Privacy Policy) and review any changes since the last version.

This Privacy Policy is subject to changes from time to time. Unless stated otherwise, our current Privacy Policy applies to all personal data that we have about you. If we make material changes to the Privacy Policy, we will provide notice or obtain consent regarding such changes as may be required by law. Your continued access to or use of our Services after such notice had been given and such revised Privacy Policy had come into effect shall constitute your acceptance of the revised Privacy Policy.