Elements Culture Limited
玖坊文化有限公司
What we doing?
Elements Culture Limited is the Cultural and Creative Company, we are provided design service on IP Character, Social Media Apps, Product Development and Merchandise etc...
Terms of Service
Effective Date: June 14, 2024.
Welcome to our services. These Terms of Service (hereinafter referred to as "Terms") constitute an agreement between you and Elements Culture Limited (address: Room 2306, 23/F, Hing Yip Commercial Centre, 272-284 Des Voeux Road Central, Sheung Wan, Hong Kong, hereinafter referred to as "Elements") governing your use of Elements' games, websites, forums, and related services (hereinafter referred to as "Services"). Your use of the Services is also governed by the [Elements Culture Limited Privacy Policy](https://www.elementsculture.com/), which is incorporated herein by reference.
For residents of the United States, these Terms include a binding arbitration clause and a waiver of certain rights to participate in class actions as described in the "Binding Arbitration/Class Action Waiver" section. Please read this section carefully as it affects your rights on how disputes are resolved. Except for certain types of disputes described in that section, you agree that any disputes between you and Elements will be resolved by binding individual arbitration, and you waive any right to participate in a class action or class arbitration.
Your agreement to these Terms is a prerequisite to your use of the Services. If you accept these Terms, you represent that you have reached the age of majority in your country/region of residence. If you are a minor or otherwise lack the legal capacity to enter into contracts (such as these Terms), you represent that your legal guardian or parent has reviewed and agreed to these Terms on your behalf.
By using or otherwise accessing the Services, you agree to these Terms. If you do not agree to these Terms, you must not use or otherwise access the Services.
Unless otherwise specified, the Services do not require payment to use or download, but they may contain features that allow you to make purchases within the Services. You may need an internet connection to access or use the Services, and you are responsible for any internet or mobile charges that may apply to accessing or using the Services.
If you access the Services through a third-party platform such as Facebook or other social networking sites, you agree to comply with the terms of service of that platform as well as these Terms.
Elements may publish additional terms or policies related to specific Services or components of the Services (including but not limited to forums, contests, sweepstakes, or loyalty programs). Your right to use the Services is subject to these applicable terms and policies in addition to these Terms.
1. Right to Use the Services
Subject to these Terms, Elements grants you a non-exclusive, non-transferable, non-sublicensable, limited right and license to use the Services for your personal, non-commercial use. This grant of rights is conditioned on your compliance with these Terms.
Apart from the limited rights set out above, no other rights are granted to you. Elements retains all rights, title, and interest in and to the Services, including but not limited to all copyrights, trademarks, trade secrets, trade names, proprietary rights, patents, ownership rights, computer code, audio-visual effects, themes, characters, character names, stories, dialogues, settings, artwork, sound effects, musical works, and moral rights, whether registered or not, and all applications thereof. Except as explicitly permitted by applicable law, you may not copy, reproduce, or distribute the Services in any way or medium without prior written consent from Elements. Elements reserves all rights not expressly granted to you herein.
The Services and their content are licensed, not sold. You agree that you do not have any ownership rights or title in any content appearing in or originating from the Services, including but not limited to virtual goods, regardless of whether they are earned or purchased from Elements or its authorized partners.
2. Purchases Within the Services
Elements may grant you a license to use certain virtual goods or other content (e.g., in-game items or currency) that can be used within the Services, which you can purchase with "real-world" money or earn or exchange through gameplay ("Virtual Items"). Virtual Items are licensed to you on a limited, personal, non-transferable, non-sublicensable, revocable basis, solely for non-commercial use.
Unless expressly authorized in the Services, you may only purchase Virtual Items from Elements or its authorized partners, and you are prohibited from transferring or selling Virtual Items.
Virtual Items do not have any real-world value, and they cannot be exchanged for real-world currency. Elements or any other person or entity has no obligation to exchange Virtual Items for anything of value. If your Virtual Items are hacked or lost, Elements has no liability for compensation.
Prices and availability of Virtual Items are subject to change without notice.
All Virtual Item purchases and redemptions through the Services are final and non-refundable. You acknowledge and agree that Virtual Items will be provided to you immediately upon purchase and that you forfeit any right to cancel or withdraw your purchase. Therefore, you agree not to request a refund for any reason. You further acknowledge that you will not receive any money or other compensation for unused Virtual Items, whether your license under these Terms is terminated voluntarily or involuntarily. The foregoing does not affect your statutory rights under applicable law, including any rights you may have under conformity guarantees as described in the "Disclaimer" section.
If you request deletion of your personal data as described in the Elements Privacy Policy, you will permanently lose all Virtual Items and will not be entitled to any refund, as Elements will no longer be able to associate such Virtual Items with you.
3. Right to Withdraw
If you are a consumer residing in a member state of the European Union or the European Economic Area ("EEA"), this section applies to you.
You may have the right to withdraw from your acceptance of these Terms within 14 days of your consent. You may also have the right to withdraw from the purchase of Virtual Items or services within 14 days of the purchase. You do not need to provide a reason to exercise your right of withdrawal. However, if you have agreed to the immediate provision of Virtual Items or services during the withdrawal period and acknowledged that you lose the right of withdrawal, you will not have the right to withdraw the purchase.
To withdraw your acceptance of these Terms, you must notify Elements of your decision to withdraw and cease using the Services. To withdraw from the purchase of Virtual Items or services, you must notify the merchant from whom you made the purchase, which may be Elements or its authorized partner. Please note that if Elements is not the merchant of record, Elements cannot and will not process your withdrawal request.
To notify Elements of your decision to withdraw, you must send a clear statement regarding your decision to info@elementsculture.com. You may use the attached model withdrawal form, but it is not obligatory. To meet the withdrawal deadline, it is sufficient for you to send your communication concerning your exercise of the right of withdrawal before the withdrawal period has expired.
If you withdraw from the purchase of Virtual Items or services, you will receive reimbursement without undue delay and no later than 14 days after the merchant is informed of your decision to withdraw. The reimbursement will use the same payment method you used for the initial transaction unless you have expressly agreed otherwise. You will not incur any fees as a result of the reimbursement.
4. Code of Conduct
You agree not to:
- Directly or indirectly use any cheating tools, Trojan horses, automation software, bots, intrusion programs, modules, or unauthorized modifications or disruptions to any third-party software of this service.
- Use this service in a manner that violates any applicable laws or regulations.
- Use this service for commercial purposes, including but not limited to advertising, solicitation, or transmitting any commercial advertisements such as spam, chain letters, pyramid schemes, or other get-rich-quick schemes.
- Use this service for fraudulent or abusive purposes, including but not limited to impersonating any individual or entity using this service, or falsely stating your relationship with any person, entity, or service.
- Disrupt or interfere with this service, or otherwise negatively impact the normal operation of this service or the service experience of other users.
- Interfere with, burden, or assist in disrupting or overloading any computer or server used to provide or support this service.
- Attempt to access this service, others' registered accounts, or connections to computers, servers, or networks of this service in an unauthorized manner outside of Elements-provided user interfaces, including but not limited to circumventing or modifying, attempting to circumvent or modify, or encouraging or assisting others in circumventing or modifying any security measures, technology, devices, encryption, or software that is part of this service.
- Publish any information, content, or other materials (or publish links to any information or content) that includes nudity, excessive violence, insults, threats, obscenities, defamation, harm to reputation, or offends race, sexual orientation, religion, or other sensibilities.
- Engage in persistent harmful behaviors such as repeatedly posting information without request.
- Attempt or actually harass, insult, or harm, or incite or instigate harassment, insults, or harm against other individuals or groups, including Elements' staff, directors, senior executives, or customer service representatives.
- Provide through this service any materials that infringe on any person's or entity's copyright, trademark, patent, trade secret, privacy, publicity, or other rights, or impersonate any other person, including but not limited to Elements' staff, directors, or senior executives.
- Attempt to decompile, reverse engineer, decode, or intrude upon any portion of this service without specific authorization under applicable law; or crack or bypass any encryption technology or security measures of data transmitted, processed, or stored by Elements; or use methods explicitly prohibited by Elements to obtain any information from this service.
- Solicit or attempt to solicit login information or any other login credentials or personal information from other users of this service.
- Obtain, capture, or collect any information about or regarding other individuals using this service through the use of pixel tags, cookies, GIFs, or similar items (sometimes referred to as spyware).
- Publish any individual's private information through this service, including personally identifiable information/personal data (whether in text, image, or video form), identification documents, or financial information.
- Engage in behavior that Elements considers contrary to the spirit or purpose of this service, or abuse Elements' support services.
5. Accounts and Login Information
Certain elements of this service may allow you to create accounts or register for this service in other ways ("Accounts"). You may need to select a password for your Account or you may use other credentials to access such Account ("Login Information").
You agree not to provide your Login Information to any other person or allow any other person to use your Login Information or Account. You are responsible for maintaining the confidentiality of your Login Information. Elements reserves the right to assume that any use of your Login Information or Account is conducted by you personally, and you are responsible for any actions taken with your Account or Login Information (including but not limited to any purchases). You agree to indemnify Elements for any loss or damage caused by your failure to keep your Login Information confidential.
You agree that you have no ownership or property rights to any Account. Elements reserves the right to delete your Account if there has been no activity associated with your Account for 180 days or more. In such event, you may lose access to and/or use of any virtual items associated with such Account and will not receive any refund.
6. User Submissions
This service may allow you to create content, including but not limited to game maps, game settings files, characters, items, screenshots of gameplay, or videos ("User Submissions").
In exchange for access to this service, you hereby grant Elements a non-exclusive, royalty-free, perpetual, irrevocable, fully transferable and sublicensable worldwide right and license to use your User Submissions in any manner and for any purpose, including but not limited to reproducing, copying, adapting, modifying, performing, displaying, publishing, broadcasting, transmitting, or otherwise communicating to the public rights, and distributing your User Submissions without further notice or compensation to you. To the extent permitted by applicable law, you waive any moral rights, publication rights, or rights of integrity relating to your User Submissions used and enjoyed by Elements (including its licensees, successors, and assigns) and other players in connection with this service and related goods and services. The foregoing grant of rights to Elements and waiver of any applicable moral rights shall survive termination of these terms.
Elements and its directors, senior executives, and employees do not accept or consider any unsolicited content (such as game or other product concepts, stories, scripts, original artwork, music or audiovisual works, concepts, or any other creative materials) from any undisclosed sources. Please do not submit any unsolicited content to Elements or its directors, senior executives, or employees. However, if you provide us with unsolicited content, you agree that we are not required to treat such unsolicited content as confidential, regardless of any conflicting statements in the unsolicited content, accompanying message, or elsewhere. You further agree that Elements may use and exploit such unsolicited content without compensation to you or any third party, and you grant Elements a perpetual, non-exclusive, irrevocable, fully paid, royalty-free, sublicensable, transferable (in whole or in part), worldwide license to use, exploit, reproduce, distribute, modify, perform, display, and create derivative works based on such unsolicited content.
7. User Interactions
Elements assumes no responsibility for the conduct of other users of this service and is not responsible for monitoring inappropriate content or behavior in the service. Elements cannot and does not pre-screen or monitor all content or behavior of users. Your use of this service is at your own risk.
By using this service, you may encounter content or behavior that you find offensive, indecent, or inconsistent with your values. Elements may employ technology to monitor and/or record your interactions with this service or communications within this service (including but not limited to chat text or voice communications). You irrevocably consent to such monitoring and recording and agree that your transmissions of any content through this service are not expected to be private, including but not limited to chat text or voice communications. You understand that your User Submissions, communications content within this service, and/or interactions with this service may be visible to other users of this service or the general public, or viewed by them.
Elements reserves the right to review, monitor, prohibit, edit, delete, or disable access to any content provided by users of this service at any time and without notice or reason. If Elements decides at any time to monitor this service on its own, it still assumes no responsibility for any content provided by users of this service and is not obligated to modify or remove any inappropriate content.
You acknowledge that Elements is not a party to any disputes you may have with other users of this service. Elements has no obligation to become involved in any such disputes. You waive any and all claims, demands, and damages against Elements and its subsidiaries (including Elements' senior executives, directors, agents, joint ventures, shareholders, and employees) relating to any such disputes.
8. Binding Arbitration/Waiver of Class Action
As stated herein, if you are a resident of the United States or bring any claims against Elements in the United States, you expressly agree that any legal claims, disputes, or other controversies between you and Elements arising from or related to the Services, including disputes regarding the applicability, enforceability, or validity of these Terms or the Elements Privacy Statement ("Disputes"), shall be resolved exclusively through binding confidential arbitration (and not in court) in accordance with these Terms by a single commercial arbitrator from the American Arbitration Association ("AAA"). The arbitration shall be conducted under the AAA Commercial Arbitration Rules and, if deemed appropriate by the arbitrator, the AAA's Supplementary Procedures for Consumer-Related Disputes. You acknowledge that you voluntarily waive your right to a jury trial and to initiate litigation in state or federal court, having been fully informed.
Arbitration fees shall be allocated according to the AAA fee schedule, unless you can demonstrate that such fees are prohibitively higher than litigation costs, in which case Elements will share the arbitration costs as determined by the arbitrator to avoid disproportionately high arbitration costs compared to litigation costs. Elements also reserves the right to decide to pay the AAA's arbitration fees in full. Except where applicable law requires the losing party to pay the prevailing party's attorneys' fees and related expenses, each party agrees to bear its own attorneys' fees and related expenses.
Arbitration may be conducted in Los Angeles, California, or at the AAA office nearest to your location upon your request. The arbitrator's decision shall be final and binding on you and Elements and may be enforced in any court of competent jurisdiction.
For further information about AAA, its rules and procedures, and how to initiate arbitration, please contact AAA at 800-778-7879 or visit the AAA website at www.adr.org.
The following disputes are exceptions to the binding arbitration rules:
- Any form of infringement claims against Elements' intellectual property.
- Claims involving theft, piracy, unauthorized use, or violations of the U.S. Computer Fraud and Abuse Act or the "Code of Conduct" section of these Terms, or claims arising from such incidents.
- Any claims for equitable relief.
Both parties agree that a party may seek injunctive relief (or similar urgent legal relief) in any court of competent jurisdiction regarding the disputes mentioned above. Except as provided herein, a party may file individual lawsuits in small claims court within the court's jurisdiction instead of arbitration.
All disputes shall be resolved individually through binding confidential arbitration to the fullest extent permitted by applicable law. You expressly agree that other disputes may not be consolidated with your disputes or joined with your disputes, whether through collective arbitration procedures or otherwise. You and Elements agree that all disputes are subject to neither party's right or authority to conduct collective arbitration or use collective litigation procedures, to assert claims on behalf of a class, or to be represented by a private attorney general. All arbitration cases shall not be consolidated with other arbitration cases.
You have the option to decline arbitration. If declined, neither you nor Elements may demand the other party to participate in arbitration proceedings. To decline, you must notify Elements in writing within 30 days from the first day these arbitration terms bind you. Please send your notice to: Room 2306, 23/F., Hing Yip Commercial Centre, 272-284 Des Voeux Road Central, Sheung Wan, Hong Kong, Attn: Elements Culture Limited. Specify your name and residential address and clearly state your decision not to accept these arbitration terms.
For arbitration requests, please write to: Room 2306, 23/F., Hing Yip Commercial Centre, 272-284 Des Voeux Road Central, Sheung Wan, Hong Kong, Attn: Elements Culture Limited, requesting arbitration and detailing your claims.
This "Binding Arbitration/Waiver of Class Action" section shall be subject to notice by Elements 30 days in advance through the Service or similar means. Changes shall take effect on the 30th day and shall apply only to claims arising after that day.
9. Suspension and Termination for Violation
Without limiting any other remedies available to Elements, if Elements believes you have violated these Terms, Elements reserves the right, with or without notice to you, to take any or all of the following actions: (i) delete, suspend, and/or modify your account or any part thereof; (ii) restrict, suspend, and/or terminate your access to the Services; (iii) modify and/or delete any virtual items associated with you; (iv) reset and/or modify any game progress or benefits and privileges associated with you in the Services, such as any levels or scores achieved by you in the Services.
10. Availability, Compatibility, and Changes to the Service
Elements does not guarantee the availability of the Services at all times or that the Services will remain available in the future. The Services may be temporarily unavailable due to technical issues or maintenance reasons, which may occur periodically or sporadically. Additionally, the Services or certain content may be designed to be available for a limited time (e.g., seasonal content or early access provided for game development versions), or their lifecycle may be affected by technological advancements or changes in consumer behavior. Furthermore, Elements reserves the right to discontinue providing and/or supporting the Services or any of its content (such as a particular game or game feature), in which case your authorization to use the Services or any of its content will automatically terminate. In such cases, except where applicable law mandates, Elements shall not be obligated to refund any fees for the Services or any virtual items. Reasonable steps will be taken by Elements to notify in advance of any termination of any Services or its content. However, Elements may limit, suspend, or terminate all or any portion of the Services and prevent your access to the Services and take technical and legal measures if Elements believes you or any other user may present a risk of legal liability or violate the content or spirit of these Terms. No further notice will be given.
Compatibility between different devices and operating systems for the Services may be limited. You are responsible for confirming whether the Services are compatible with your device and its operating system. In general, more information on compatibility requirements may be obtained at the time of first use or download (for example, in the relevant application store).
The Service will gradually evolve and upgrade. Therefore, Elements may change, manage, modify, or update the Services or their content (including but not limited to virtual items) from time to time. This may result in additions, removals, or modifications to content or features (e.g., adding or removing game modes or areas, or changing the appearance or effectiveness of virtual items). Elements may decide to make any such changes as it deems necessary to maintain and improve the Services, including but not limited to introducing, modifying, or deleting game content and features according to Elements' development blueprints, adapting to new technologies, reflecting changes in Elements' agreements with third parties, preventing abuse or technical issues, and addressing any legal, security, or regulatory requirements. If changes are made to the Services, you may need to download and install updates to continue using them. Failure to do so may prevent you from accessing or using the Services or their content (for example, online games and features may only be provided to those using the latest game version).
11. Disclaimer
To the fullest extent permitted by applicable law, the Service is provided on an "as is" basis without any warranties, guarantees, or representations of any kind. The Service may have defects, and you use it at your own risk. Elements makes no representations or warranties of any kind, express, implied, or statutory, including but not limited to warranties of condition, uninterrupted use, accuracy of data (including location data), merchantability, quality, fitness for a particular purpose, non-infringement, or any warranties arising from course of dealing, usage, or trade practice, and hereby disclaims all such warranties. Elements does not warrant that the Service will be uninterrupted, meet your requirements, operate without error, or be compatible or interact with any other service. Any oral or written advice provided by Elements, its employees, or representatives does not constitute a warranty.
Some jurisdictions do not allow the exclusion of certain warranties, so the above exclusions may not apply to you. In such jurisdictions, the liability of Elements shall be limited only to the extent permitted by law in that jurisdiction. Additionally, you may have other statutory rights in your jurisdiction that these terms do not affect as a consumer of services. Specifically, if you are a consumer in the EEA, you may have certain statutory rights under applicable law, and Elements may be liable for failures to comply with those rights as follows: (i) within two years from the first supply of the Service, such as virtual goods; or (ii) at any time during the period in which the Service is supplied continuously.
12. Limitation of Liability
Elements shall not be liable for any special, indirect, or consequential damages arising out of or in connection with the access to, use, or operation of the Service, including but not limited to damages for loss of property, loss of reputation, device failure or malfunction, and (to the extent permitted by law) personal injury, property damage, loss of profits, or punitive damages arising from or related to this Agreement or the Service, whether in tort (including negligence), contract, strict liability, or otherwise, even if Elements has been advised of the possibility of such damages. In no event shall Elements' cumulative liability under this Agreement, the Privacy Statement, or the Service exceed the greater of (i) the actual price paid by you for the authorization to use virtual goods or the Service (if any); or (ii) one hundred Euros (€100). The exclusion and limitation of damages set forth herein are fundamental elements of the agreement between Elements and you. For purposes of the "Limitation of Liability" section, the licensors and other partners of Elements are third-party beneficiaries of this provision.
Some jurisdictions do not allow certain limitations of liability as set forth in this section, so the above limitations may not apply to you. In such jurisdictions, the limitations of liability in this section shall apply only to the extent permitted by law in that jurisdiction. Additionally, you may have other statutory rights in your jurisdiction that these terms do not affect as a consumer of services. If any third party brings a claim, demand for damages, or other losses against Elements or its subsidiaries (including officers, directors, agents, joint ventures, shareholders, and employees) arising from your use of the Service or your breach of this Agreement, you agree to indemnify Elements and its subsidiaries, and to defend them against any claims, damages, costs, or expenses (including reasonable attorneys' fees), unless such claims are attributable to your intentional or negligent acts.
13. Copyright and DMCA
If you believe that the Service or any content thereof infringes your copyright, please send a notice to: Elements Culture Limited, Hing Yip Commercial Centre, 272-284 Des Voeux Road Central, Sheung Wan, Hong Kong, or email to: info@elementsculture.com. Notices sent to the designated address will be delivered to Elements' registered DMCA agent. Your DMCA notice must include all of the following:
- Identification of the copyrighted work claimed to have been infringed. If your DMCA notice covers multiple works, you may provide a representative list of such works.
- Identification of the infringing material, including a description of where the material is located. Your description must be sufficient to allow Elements to locate the material.
- Your full legal name, mailing address, telephone number, and (if available) email address.
- A statement in the body of the DMCA notice: "I hereby declare that I have a good faith belief that the disputed use of the material is not authorized by the copyright owner, its agent, or the law. I declare under penalty of perjury that the information in this DMCA notice is accurate and that I am the copyright owner or authorized to act on behalf of the copyright owner."
Please note that under 17 U.S.C. 512(f), if you knowingly misrepresent material or activity as infringing, you may be liable for damages, including costs and attorneys' fees incurred by Elements or its users. If you are unsure whether material or activity infringes your copyright, you may wish to contact an attorney before sending notice to Elements.
14. Third-Party Products and Services
The Service may link to third-party products or services or otherwise offer such products or services, including but not limited to through third-party advertisements, connections with social media or community services, or game recording or sharing services. These products and services are governed by the individual third-party terms and conditions. Please carefully review these third-party terms and conditions as they constitute an agreement between you and the respective third-party service providers, and Elements is not a party to such agreements. You understand that Elements does not endorse and is not responsible for any content, goods, or services provided by such third parties. Elements shall not be liable for any losses or damages caused by such third parties or any expenses you incur from such third parties. You understand that when you provide information to such third parties, you are providing it in accordance with their privacy policies (if any), and the Elements Privacy Statement does not apply to such data.
15. Amendment of These Terms
Despite the provisions of "Binding Arbitration/Waiver of Class Action," Elements reserves the right to amend these terms from time to time to reflect changes in law, technology, or business developments. When amending these terms, Elements will take appropriate measures to notify you through the Service or other means, depending on the significance of the amendments. Your continued access to or use of the Service after such amendments become effective indicates your acceptance of the amended Terms of Service.
16. Governing Law
If you are a resident of the United States, except for the "Binding Arbitration/Waiver of Class Action" section, these terms are also governed by the laws of the State of California and applicable federal regulations, without regard to conflict of law principles. If you are not a resident of the United States, you agree that all disputes between you and Elements shall be governed by Finnish law, without regard to conflict of law principles. You agree that any claims or disputes against Elements must be exclusively brought in the courts of Espoo, Finland. If you are a consumer in the EEA, you may also use the online dispute resolution platform provided by the European Commission as an alternative dispute resolution method. Please note that Elements may not be required to accept the use of this platform or any other alternative dispute resolution platform.
If the jurisdiction where you reside prohibits Elements from applying the governing law provisions, the terms of this section shall not restrict any rights granted to you under the laws of your jurisdiction.
17. Entire Agreement
Complete Agreement. These terms constitute the entire agreement between you and Elements regarding the Service, replacing all prior agreements and understandings between you and Elements.
Assignment. Elements may assign these terms in whole or in part to any person or entity at any time without your consent, provided that such assignment does not diminish the rights you are entitled to under these terms. You may not assign or delegate any rights or obligations under these terms without prior written consent from Elements; any unauthorized assignment or delegation by you shall be null and void.
Severability. If any provision of these terms is found to be invalid or unenforceable, that provision shall be limited or eliminated to the minimum extent necessary, and the remaining provisions of these terms shall remain in full force and effect. The failure of Elements to exercise any particular right or provision of these terms shall not constitute a waiver of such right or provision.
Contact Information. If you have any questions about these terms, please contact us at info@elementsculture.com.
18. Additional Terms for Apple Users
In addition to the above terms, if you access the Service through the Apple Inc. operated App Store, the following terms apply.
You acknowledge and agree that these terms are between you and Elements, not Apple, and that Elements is solely responsible for the Service and its content, not Apple. Your use of the Service is governed by the Apple App Store Terms of Service and any third-party terms specified in those terms allowing rules of use. Elements (not Apple) is responsible to you for the following: (i) providing any maintenance or support for the Service under these terms; (ii) addressing any claims you have regarding the Service, including product liability claims, any claims that the Service fails to conform to any applicable legal or regulatory requirement, and claims arising under consumer protection or similar laws. If the Service does not conform to these terms or any applicable legal or regulatory requirement, you may notify Apple, and Apple may refund the purchase price of the Service (if any). To the maximum extent permitted by applicable law, Apple has no other warranty obligations regarding the Service.
Apple shall have no responsibility for investigating, defending, settling, or discharging any claim of infringement of intellectual property rights regarding the Service or your ownership and use thereof by any third party.
You represent and warrant that: (i) you are not located in a country or region embargoed by the United States government or designated by the United States government as a "terrorist-supporting" country or region; (ii) you are not listed on any United States government prohibited or restricted party list.
Apple and its subsidiaries are third-party beneficiaries of these terms. Upon your acceptance of these terms, you agree that Apple has the right to enforce these terms against you as a third-party beneficiary.
Privacy Policy Statement
Elements Culture Limited Privacy Policy Statement
Last updated: July 11, 2024
This statement aims to explain how Elements Culture Limited (referred to as "we" in this statement) collects, stores, uses, or otherwise processes the personal data of end users (referred to as "you" in this statement) of our services, and what rights you have regarding your personal data.
In this statement, "services" refers to our games, websites, and any related services or properties under our control; "games" refers to our games, applications, and other products, including all games in the "Meteor Fall" series and other products; "website" refers to websites and other online properties under our control, including https://www.elementsculture.com. When referring to personal data related to you as an identifiable or identifiable individual, this statement will use "your data."
This statement applies to all our services unless a separate statement is provided for a specific game or other service. If a separate statement is provided, that statement will apply. Additionally, our services may link to or otherwise allow you to access properties controlled by third parties. Please note that this statement does not apply to properties controlled by third parties, whose operators may collect and use your data according to their own policies.
Please read this statement before accessing or using our services to understand how and why we use data related to you. Although many sections contain brief summaries for easy reference, we recommend reading the entire statement. Besides this statement, we also suggest you carefully read our Terms of Service to understand the terms of use of our services.
1. Data Controller
The "data controller" is the entity that determines the purposes and means of processing personal data. For the activities described in this statement, we are the data controller. Our company name is Elements Culture Limited. Our address is Room 2306, 23/F, Hing Yip Commercial Centre, 272-284 Des Voeux Road Central, Sheung Wan, Hong Kong.
When operating the services, we may share your data with partners. Some of these partners act as independent data controllers who independently determine how and why they process your data. For more information about these partners and how they handle your data, please see Section 6 of this statement.
2. Contact Information
For matters related to this statement, you can contact us via email: info@elementsculture.com.
We have also appointed a Data Protection Officer ("DPO") to oversee our data protection matters. If you have any questions or concerns about how we use your data, you can contact our Data Protection Officer via email: info@elementsculture.com.
3. Why and How Do We Process Your Data?
We may use your data for various purposes related to our services. For a complete view of these purposes, please click the plus sign. If you want a quick summary, we hope the following content helps:
When you use our services, we process your data in ways that allow us to provide the services to you (e.g., saving your game progress & global leaderboard).
Your data also enables us to provide related services (e.g., account services and support), maintain our services (e.g., troubleshooting issues or adjusting our games), and improve service quality (e.g., conducting surveys to get your feedback).
Additionally, we may serve advertisements in our games or promote our services on third-party properties, using your data to achieve this function and provide relevant ads.
Sometimes, we may need to use your data for other purposes, such as fraud prevention, auditing, or compliance.
3.1 Ad Serving
Advertisements fund our services and allow us to offer our games for free. We serve our own ads and third-party ads in our games. We also serve ads on third-party properties (e.g., websites or applications). In both cases, we and our advertising partners typically use anonymous identifiers related to your device to select relevant ads, measure ad effectiveness, and for other related purposes. Where permitted by applicable laws and regulations, using our services indicates your consent to share your data with our advertising partners (listed here) for behavioral advertising and other related purposes. You can manage your preferences in our games or your device settings. For more information on how we and our advertising partners may use your data for advertising and how you can control data use for these purposes, please click the plus sign.
3.1.1 Google Play's data disclosure requirements
In May 2021, Google Play announced the new Data safety section, which is a developer-provided disclosure for an app's data collection, sharing, and security practices.
This page can help you complete the requirements for this data disclosure in regards to your usage of the Google Mobile Ads SDK. On this page, you can find information on whether and how our SDK handles end-user data, including any applicable settings or configurations you can control as the app developer.
We aim to be as transparent as possible in supporting you; however, as the app developer, you are solely responsible for deciding how to respond to Google Play's Data safety section form regarding your app's end-user data collection, sharing, and security practices.
How to use the information on this page
This page lists the end-user data collected by only the latest version (version 23.2.0) of the Google Mobile Ads SDK.
If you are using a prior version of the Google Mobile Ads SDK, consider updating to the latest version to ensure your app's disclosures are accurate. The Google Mobile Ads SDK will continue to be updated over time. This article will reflect these changes, so make sure to check back and update your disclosures as necessary.
To complete your data disclosure, you can use Android's guide about data types to help you determine which data types and purposes best describe the collected data. In your data disclosure, make sure to also account for how your specific app shares and uses the collected data.
Data collected and shared automatically
The Google Mobile Ads SDK collects and shares the following data types automatically for advertising, analytics, and fraud prevention purposes.
Data - By default, the Google Mobile Ads SDK...
IP address - Collects device's IP address, which may be used to estimate the general location of a device.
User product interactions - Collects user product interactions and interaction information, including app launch, taps, and video views.
Diagnostic information - Collects information related to the performance of your app and the SDK, including crash logs, app launch time, hang rate, and energy usage.
Device and Account identifiers - Collects Android advertising (ad) ID, app set ID, and, if applicable, other identifiers related to signed-in accounts on the device.
All of the user data collected by Google Mobile Ads SDK is encrypted in transit using the Transport Layer Security (TLS) protocol.
Data handling
Android ad ID collection is optional. The ad ID can be reset or deleted by users using ad ID controls in the Android settings menu. As the app developer, you can prevent the collection of ad IDs by updating the app's manifest file.
Certain other features in the Google Mobile Ads SDK, such as the Limited Ads feature, may also disable transmission of the ad ID and other data.
Data collected and shared depending on your usage
If you are using any optional product features that involve additional data (such as advance reporting) or participating in any tests of new product features that involve additional data, be sure to check if those features or tests require additional data disclosures.
3.1.2 Apple App Store's data disclosure requirements
Apple requires that developers publishing apps on the App Store disclose certain information regarding their apps' data use. Apple has announced that these disclosures will be required for new apps and app updates starting December 8, 2020. This guide explains the Google Mobile Ads SDK's data collection practices as of 7.68.0, to make it easier for AdMob developers to answer the questions in App Store Connect.
To improve the performance of AdMob, the Google Mobile Ads SDK may collect certain information from apps, including:
- IP address, which may be used to estimate the general location of a device.
- Non-user related crash logs, which may be used to diagnose problems and improve the SDK. Diagnostic information may also be used for advertising and analytics purposes.
- User-associated performance data such as app launch time, hang rate, or energy usage, which may be used to evaluate user behavior, understand the effectiveness of existing product features, and plan new features. Performance data may also be used for displaying ads, including sharing with other entities that display ads.
- A Device ID, such as the device's advertising identifier or other app- or developer-bounded device identifiers, which may be used for the purpose of third-party advertising and analytics.
- Advertising data, such as advertisements the user has seen, may be used to power analytics and advertising features.
- Other user product interactions like app launch taps, and interaction information, like video views, may be used to improve advertising performance.
If you are using any optional product features that involve additional data (such as advance reporting) or participating in any tests of new product features that involve additional data, be sure to check if those features or tests require additional data disclosures.
If you are using a prior version of the Google Mobile Ads SDK, consider updating to the latest version to ensure your app's disclosures are accurate. The Google Mobile Ads SDK will continue to be updated over time. This article will reflect these changes, so make sure to check back and update your disclosures as necessary.
Apple's privacy manifest files
Google Mobile Ads SDK version 11.2.0 and higher supports privacy manifest declarations. You are responsible for checking the privacy manifest and ensuring that your application's data disclosures are up to date. Refer to Apple documentation for details on interpreting a privacy report and their enforcement update for app submission requirements.
Mediation
The following table lists the minimum third-party adapter and SDK versions that contain a privacy manifest declaration.
Ad Source Adapter version (Unity) Adapter version (iOS) Third-party iOS SDK version Third-party SDK documentation
AppLovin 7.2.1 12.4.1.0 12.4.1 Privacy Manifests
Chartboost 4.6.0 9.7.0.0 9.7.0 Privacy Manifest
DT Exchange 3.1.10 8.2.7.0 8.2.7 Privacy Manifest File Data Transfer
i-mobile N/A N/A Not supported
InMobi 4.5.1 10.7.2.0 10.7.2 Privacy Manifest
ironSource 2.6.0 7.9.0.0.0 7.9.0.0 Privacy Manifest Support
Liftoff Monetize 5.1.0 7.3.1.0 7.3.1 Adapting to Privacy Changes
Line 1.1.0 2.7.20240318.0 2.7.20240318 App Store Disclosure
maio 2.0.2 2.1.4.0 2.1.4 Release Notes
Meta Audience Network 3.12.0 6.15.0.0 6.15.0 App Store Review requirements
Mintegral 1.6.0 7.6.2.0 7.6.2 SDK Privacy Compliance Statement
myTarget 3.16.2 5.21.2.0 5.21.2 iOS SDK: Version history
Pangle 2.6.0 5.8.0.8.0 5.8.0.8 Privacy Manifests
Unity Ads 3.10.0 4.10.0.0 4.10.0 Apple privacy survey for Unity Ads
3.2 Cookies and Other Similar Technologies on Our Website
Like most modern websites, our website may use cookies or similar technologies (e.g., local shared objects or web beacons).
"Cookies" are small files stored in your browser by websites. Cookies can be set by the website you visit ("first-party cookies") or by third parties that provide content, functionalities, or services for the website you visit (e.g., analytics or advertising) ("third-party cookies"). Cookies are commonly used to identify or "remember" your device, such as to enable functionalities, simplify audience assessment, improve performance, or save your preferences.
When you visit our website, you may be prompted to make choices regarding cookies. Some cookies may be essential for the website's operation. These cookies will be placed on your device regardless of your preferences for other types of cookies. You can control the use of cookies through your browser or device settings, such as disabling some or all cookies or setting your browser or device to notify you when cookies are being set. However, please note that disabling cookies may affect your ability to use the services.
4. What Data Do We Process?
When you access and use our services, we may collect information you submit to us or through the services, such as when creating an account, sending messages in games, or contacting us for support. We may also automatically collect information about your use of the services and the devices you use to access the services, including identifiers such as advertising IDs. When you see our advertisements outside of our services, we may collect information about your interactions with those ads. We may use the data we collect to infer other information, such as your content preferences. For more information, please click the plus sign.
4.1 Information we may collect about you
We may collect and process the following personal data from you when you use our Online Services (together, the “Submitted Information”):
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Information provided by you when using a Game or Community (“Game Information”)
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Your mobile device’s unique device ID (e.g. for our mobile Games);
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Your age bracket (e.g. above or below 18);
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Your Facebook User ID;
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Your user/account avatar;
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Your user/account profile picture;
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Your user/account username;
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Your name;
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IP address;
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MAC address;
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System, browser and device settings and information (including make, model and operating system of your device, device properties such as orientation, mobile network operator, Games played, country and locale settings, network connection speed and type and browser type).
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Advertiser and platform (e.g. Apple or Google) IDs, which are unique to you but which do not reveal your name.
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Your email address;
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Your user/account ID; and
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‘Events’ related to your gameplay in our Games, such as your achievement of a milestone, the occurrence of other particular events during your gameplay (such as completing a tutorial, game level, making a purchase or viewing an advertisement).
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Information provided by you when using the Communities or that may be provided by you when you contact us for support (“Contact Information”)
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Your name;
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Your Steam ID / Steam profile identifier / display name or your username/identifier on another platform or account;
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Your email address;
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User-generated content and score information hosted and displayed in our Online Services (“User Content”)
When using our Online Services, you may decide to post information that may or may not contain personal data, in accordance with the rules of the relevant Online Service (such as the relevant forum rules applicable to our Communities). Similarly, when using some of our Games or other Online Services (where this functionality is provided by us) you may decide to post certain content such as leaderboard information and messages to other users, in accordance with the terms of use applicable for the relevant Online Service.
In some Online Services, the provision of User Content (e.g. leaderboard / ‘scoring’ information between users and/or in a public manner within the Online Service or similar) (“Leaderboards”) is a significant or essential part of the functionality and/or gameplay or user experience and may be posted automatically. We may, but we are not required to, provide you with a means to still play / use the Online Service without taking part in this functionality (e.g. without having your information on the leaderboard) within the Online Service. You can also contact us to enquire further about User Content at info@elementsculture.com. Please be aware that it may not be possible for us to turn off this type of User Content functionality for you within the Online Service without affecting your user experience.
We cannot control the wider dissemination via the public internet of personal data that you may choose to post, or make available, in User Content.
Information about your activites and cookies ("Analytics")
We may collect technical information about your use of our Online Services through the use of tracking technologies and analytics.
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Your IP address and MAC address;
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User ID;
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Device country;
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Advertisements viewed and clicked;
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Time, date and install source of your first download (e.g. from a clicked advertisement);
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Purchase transaction types and spend made in an Online Service;
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Session start, duration and end timings;
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Identifying information about crashes and defects;
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Device information (e.g. device identifier and browser);
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Game results, progress and timings; and
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Page usage (e.g. buttons clicked, screens viewed).
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This also includes the use of ‘cookies’ and similar technologies such as SDKs and APIs in our mobile games.
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Cookies and similar technologies
A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. Cookies and similar technologies are widely used in order to make websites and mobile apps work, or work more efficiently, as well as to provide information to the owners/operators. Elements Culture uses cookies and similar technologies to help Elements Culture identify and track visitors / players, their usage of Online Services and their access preferences. We also use some cookies and SDKs for advertising purposes as further detailed in this policy.
Third party vendors and partners are used by Elements Culture when conducting our Analytics and for our other data processing activities set out in this policy, including in relation to our advertising purposes. The following cookies and similar technologies are used on the Online Services (but differ between each Online Service) and you can find out more information about their processing activities through the links provided:
GOOGLE ANALYTICS
Google Analytics is a service offered by Google that generates detailed statistics about a website’s traffic and traffic sources and measures conversions and sales.
LINKS:
https://www.google.com/analytics
https://policies.google.com/privacy
GOOGLE ADMOB
We may use a Google AdMob SDK to enable us to serve advertising to you. Google’s use of the SDK enables Google to serve you with more relevant advertising based on your experiences on our services and others.
LINKS:
https://policies.google.com/technologies/partner-sites
https://support.google.com/ads/answer/2662856?co=GENIE.Platform%3DAndroid&hl=en&oco=0
UNITY ADS SDK
This SDK enables advertising to be served to you within certain of our Games. Unity’s use of the SDK may enable Unity to serve more relevant advertising to you.
LINKS:
https://unity3d.com/legal/privacy-policy
IRONSOURCE ADS
This SDK enables advertising to be served to you within certain of our Games. IronSource’s use of the SDK may enable IronSource to serve more relevant advertising to you.
LINKS:
https://developers.ironsrc.com/ironsource-mobile/air/ironsource-mobile-privacy-policy/
TAPJOY ADS
This SDK enables advertising to be served to you within certain of our Games. Tapjoys’s use of the SDK may enable Tapjoy to serve more relevant advertising to you.
LINKS:
https://www.tapjoy.com/legal/#privacy-policy
VUNGLE ADS
This SDK enables advertising to be served to you within certain of our Games. Vungle’s use of the SDK may enable Vungle to serve more relevant advertising to you.
LINKS:
META ADS
We may use Meta Ads SDKs and cookies to allow us to: (i) serve more relevant advertising to you; (ii) understand how users are using and interacting with our Online Services; and (iii) to enable you to log into or connect the Online Service with your Meta user account.
LINKS:
https://www.facebook.com/help/238318146535333?helpref=hc_global_nav
https://www.facebook.com/help/193677450678703?helpref=uf_permalink
GOOGLE PLAY SERVICES API
We may use this API to enable you to log into / connect your profile in our Online Service with your Google account.
LINKS:
https://policies.google.com/privacy
FIREBASE SDK
We may use this SDK to help us understand how you use our Online Service so that we can develop and improve our Online Services.
LINKS:
https://firebase.google.com/support/privacy/
One Signal
We may use this to deliver bespoke push notifications.
LINKS:
https://onesignal.com/privacy_policy
Singular SDK
We may use this SDK to help us understand how you use our Online Service so that we can develop and improve our Online Services.
LINKS:
https://www.singular.net/privacy-policy/
Most web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit http://www.allaboutcookies.org/. To opt out of being tracked by Google / Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
To opt out of being tracked by advertising providers you can access a general opt out at http://www.networkadvertising.org/managing/opt_out.asp.
Information about you collected from third parties("Third Party account information")
If you choose to access or log into our Online Services via a third party social media platform such as (without limitation) Facebook, we may collect and store personal data and other information made available by that third party platform, such as your profile username, profile picture, user ID and public information about your friends, provided that you have expressly agreed to the use of such information within the relevant Online Service.
We may also collect technical information in order to ensure that our Online Service connects correctly with your social media user account. This information may be obtained via a Facebook cookie or other similar device in our Online Service. The third party platform is responsible for obtaining your consent before sharing such data with us.
4.2 Why we collect information about you
To provide the Online Services to you
We will use information about you (including the Game Information, User Content, Contact Information and Third Party Account Information) to deliver our Online Services to you under the terms of use agreed between us. The processing of information in this way is necessary, for example, for us to record your progress and current status within an Online Service such as a Game, and to ensure the Online Services deliver the features promised and function properly.
Where we process your personal data for Leaderboards, or other User Content, in our Online Services, we also rely upon our legitimate interests as a legal basis for undertaking that processing, being our commercial interests in providing an enhanced experience in our Online Services (though, depending on the nature of our particular Online Service, the Leaderboard or User Content may be a part of the core functionality of the Online Service).
To enable purchases
If you make purchases through the Online Services, your order and Game Information and Contact Information may be processed so that you can access these features within the Online Service.
For the above purposes, we rely upon the legal basis of performance of a contract (being performance of the terms of use agreed between us).
Moderation and preventing spam
Certain Game Information and User Content which you supply through our Online Service may be shared with other users of the Online Service. In some cases you may be able to select specific recipients (for example, if you are sending a forum post, or a private message, to a particular forum or individual) and then only those recipients will receive it, however in all other cases, your information may be made publicly available.
We may make your Game Information and User Content available to forum moderators. Moderators are crucial to the Communities and help make them the place that they are. Moderators are directed to only act in accordance with our instructions and to adhere to the moderator rules. We may moderate content, but we are not required to do so. Please see our relevant terms of use with you for the relevant Online Service for more information about content moderation.
Spam is a problem for many forums and websites. In order to minimise this we may use IPS Spam Defense Service to check that any new registration is not spam. In order to do this certain information may be provided to IPS Spam Defense Service for the sole purpose of checking that it is not spam. You can find out more about how the IPS Spam Defense Service uses this information on their website available here: https://invisioncommunity.com/legal/privacy.
For the above purposes, we rely upon the legal basis of performance of a contract (being our terms of use with you for the relevant Online Service) and our legitimate interests, being our commercial interests to moderate the services and to prevent spam.
To respond to your enquiries and requests for support
We may process Submitted Information so that we are able to properly respond to your enquiries and support requests, in accordance with the terms of use agreed between us.
As part of this we may also share this Submitted Information with the developers of the Games that we publish and with our vendors who may assist us with managing support queries.
For the above purposes, we rely upon the legal basis of performance of a contract (being our terms of use with you for the relevant Online Service) and our legitimate interests, being our commercial interests to respond to your queries and requests for support.
For advertising purposes
We may process your Submitted Information so that we can serve untargeted advertisements to you in the relevant Online Service. For this purpose, your personal data is processed on the basis of our legitimate interests, being our commercial interests for advertisement-supported services.
For some of our Online Services, we may process Submitted Information to show you more relevant advertisements (on our Online Services or on third party services), based on your perceived preferences, for our products and services or for other third party products and services. Where we process your Submitted Information for this type of advertising, we rely upon your consent for our data processing. You have the right to withdraw this consent at any time by letting us know by email to: info@elementsculture.com
For the purposes of serving you with more relevant advertising in our Online Services and on other third party services and platforms, we work with advertising networks including the following:
Facebook (https://www.facebook.com/privacy/explanation)
Unity (https://unity3d.com/legal/privacy-policy)
Google (https://policies.google.com/privacy)
If you would like to find out more about the way these third parties collect and process your information please refer to their respective privacy policies and/or terms and conditions by clicking on the links provided above.
We will not process your information for the purposes of targeted marketing or pass your information on to third parties for the purposes of such marketing unless you give your consent or you have given it already. After you have given your consent, you may withdraw it at any time.
For some of our Online Services, Analytics information may be shared with advertisers on an anonymous aggregate basis. We may also publicise anonymous, aggregate statistics through our websites or other channels although this will not include your personal data (this might be, for example, aggregated visitor numbers).
Please note that we use third party providers of adverts and the advert content is provided by these third parties and not Elements Culture. Elements Culture does not control and is not responsible for third party advert content. If you have concerns about specific advert content, you can contact us at: info@elementsculture.com
To understand which publisher of our advertisements referred you to us
We process personal data, including without limitation the Game Information and Analytics, so that we can understand which publisher of our advertisements referred you to us and, for example, to which advertisement and/or advertising or marketing campaign that referral related. This information is helpful for our purposes of understanding which marketing and advertisement activity is successful. We process this personal data on the basis of our legitimate interests, being our commercial interests in promoting and improving our Games and their commercial success (including by improving our advertising and marketing).
To acquire new users and engage current users
We use various forms of marketing to acquire new users. The information we collect about you may be used to improve the relevancy of our marketing, including the creation of ‘lookalike’ audiences. This allows us to offer more relevant marketing to potential new service users without using information that personally identifies you.
We may also process this information to pursue our legitimate interests of acquiring new users for our Games.
Your Steam ID / Steam profile identifier / display name or your username/identifier on another platform or account;
To prevent fraudulent or illegal activity
We may process your Submitted Information for our legitimate interests of ensuring that your use of our Online Services is lawful and in compliance with our agreement (being the terms of use agreed between us), to prevent disruption to our Online Service, to enforce our rights, to protect any individual or otherwise to ensure our compliance with our legal obligations.
Where we reasonably believe that you are or may be in breach of any applicable laws or our terms of use, we may use your personal information to inform relevant third parties such as your law enforcement agencies about the content.
We reserve the right to disclose your identity to any third party who is claiming that any User Content posted by you constitutes a violation of their intellectual property rights, or of their right to privacy. You may not copy, download, or embed any User Content without the express written permission of the content owner. You may not use any User Content for any commercial purposes, or any public performances.
We work with Apple and Google to assist us with fraud prevention and the detection of any illegal activity (e.g. to verify in-app purchases made through iTunes and Google Play).
To help us to improve the Online Services and help us fix any problems
We may process information about you (being the Submitted Information or any part thereof) so that we can analyse and improve our Online Services and also for us to develop new Online Services or new parts thereof.
This processing is necessary for us to pursue our legitimate interests, being our commercial interests of: (i) ensuring that our Online Services function properly so that you and other users have the best experience when, for example, playing the Games and using the other Online Services; (ii) improving the quality of our Online Services, and providing a better experience to our users; and (iii) identifying and correcting any bugs or problems with the Online Services.
To help us to understand your usage of the Online Services
We may process information (being the Submitted Information or any part thereof) to understand how users use our Online Services, and to compile statistical reports regarding that activity, as well as understanding how users progress within a particular Online Service such as a Game. This processing is necessary for us to pursue our legitimate interests, being our commercial interests in continually improving the Online Services, understanding and fixing problems (such as when users may frequently be ‘stuck’ in a particular Game level) and to improve our future products and services.
To keep you up to date
Where you have consented, or where it is otherwise lawful for us to do so, we use your Submitted Information to send you emails in order to keep you informed about our news and products. You can withdraw your consent at any time by letting us know by email to: info@elementsculture.com.
Push notifications about our Game and similar notifications
Where you have consented or where it is otherwise lawful to do so, we may use your Submitted Information to send you ‘push notifications’ or in-service notifications (for example, on your device and in relation to the Game). The third party platform (i.e. your device provider such as Apple) is responsible for obtaining your consent to activities such as push notifications.
5. Where Do We Collect Your Data From?
Primarily, we collect data from you or your device when you use our services. However, we may also receive data about you from other companies, such as third-party login providers if you choose to use them, companies that assist you with purchases in our games, or advertising partners needed to serve you our advertisements outside of our services. For more information, please click the plus sign.
6. With Whom Do We Share Your Data?
As we operate our services globally, your data may be transferred to or processed in locations outside your country/region when you access or use our services. Where permitted by applicable laws and regulations, using our services indicates your consent to such data transfers. We routinely share data within the Elements Culture Limited group and with service providers and partners who help us deliver our services. By design, certain information (e.g., your in-game alias or chat messages) may also be visible to other users of our services. We may also need to share data in case of corporate restructuring, legal requirements, or to protect our legitimate rights or someone's vital interests, although such occurrences are rare. For more information, please click the plus sign.
7. How Long Do We Retain Your Data?
We will retain your data for as long as necessary to fulfill the purposes for which it was collected, including providing services to you or complying with any legal, accounting, or reporting requirements. We may periodically delete or de-identify inactive accounts or other data in our games or other services.
Once the applicable retention period has ended, we will delete or de-identify your data. If deletion or de-identification is not possible (e.g., because the data is stored on backup servers), we will isolate your data from further processing until deletion or de-identification is possible. We may continue to use data that cannot identify you (e.g., aggregate data). When using such de-identified data, we will not attempt to re-identify you.
8. How Do We Ensure the Security of Your Data?
We have implemented measures to provide an appropriate level of security for your data, taking into account the risks associated with the processing activities described in this statement. These measures are designed to protect your data from accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. The specific measures we use vary but typically include encryption during transmission, anonymizing identifiable data where feasible, access controls to restrict access to services or systems containing personal data, and maintaining procedures for handling suspected security incidents. Please note that while we strive to protect your data, the internet is inherently an insecure environment, and we cannot guarantee the absolute security of your data.
9. Your Rights
Under applicable laws and regulations, you have various rights concerning your data. If we are processing your data, you may exercise these rights, such as requesting access to your data, requesting its deletion, or withdrawing your consent where applicable. Please check the settings menu of our games for options to exercise these rights or contact us at info@elementsculture.com. For more information, please click the plus sign.
10. Specific Region Information
10.1 California Residents
If you are a California resident, please note that you have specific rights under the amended California Consumer Privacy Act (CCPA) regarding how we handle your data. These include the right to know what personal information we collect, the right to request deletion of your personal information, and the right to opt-out of the sale of personal information. For more details on your rights under the CCPA, please see our California Residents Supplementary Privacy Statement.
11. Children
Our services are generally intended for adults and designed primarily for adults. When you access and use our services, we may require you to confirm your age or otherwise determine your age. If we find that you are a minor or below the age threshold we apply, and we believe it is necessary according to applicable laws, regulations, or platform requirements, we may take steps to restrict, suspend, or terminate your access to the services. If your access to the services is not restricted or terminated, we will limit the use of your personal data to what is necessary for the internal operation of our services and other purposes allowed by applicable laws, regulations, and platform policies. This may include removing access to certain parts or features of our services.
12. Changes
We may update this statement from time to time to reflect operational changes or changes in legal obligations. Updates will be made available here. We may also notify you of any significant changes in other ways.
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+852 2851 0886
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