Road to Empress

Privacy Policy

1. Introduction

Welcome! We value your privacy and appreciate your trust and confidence in us.

Who are we?

We are Sixjoy Hong Kong Limited, an Hong Kong-incorporated company. Together with our group companies, we operate globally to provide you services and products and a lot of fun!

What does this policy apply to?

• This Privacy Policy describes how we handle, collect, use, share and process your personal information when you use our Services.
• By "Services", we mean any of our products or services – including games available on PC, mobile and/or website and relevant eSports, events and activities – that link to this Privacy Policy.
• Only Services that link to this Privacy Policy are covered by it. Some other Sixjoy products and services have their own specific privacy policies and will not link to this Privacy Policy – in those cases, please read the product or service-specific policy.

How to read this policy.

We want to make this Privacy Policy easy to understand and concise, so you know where to find the relevant information:

-          For our general principles and practices for handling personal information across our Services, please read this Privacy Policy.

-          For other details about our privacy practices, please scroll down to the Privacy Portal’s Additional Information section where you can find information such as our Children’s Privacy Policy, our contact information, etc..

-          If you have further questions or need more information, please refer to the Contact Us section below. Our team is ready to assist you with any privacy-related inquiries.

 

2. Data controller and how to contact us

In this Privacy Policy, we will call the entity that is responsible for your information "Sixjoy" (and terms like "we", "us", etc.).

However, you can find information about the name of the specific data controller for your Service, as well as their contact details and local representatives (if applicable), in the Privacy Portal’s Additional Information section below.

 

3. Children

ⓘ Younger users and people with parental responsibility should read sections 3 and 4 carefully.

For those Services that are available to children, users who are under the age set out in the table below should not access our Services for any purposes unless your parent or guardian has agreed to this by providing their consent (if this option is available in your location). If you are located in a region not listed below, or if you are unsure, you should not access our Services for any purposes and you should seek guidance from your parent or guardian.

 

Other than as provided in this Privacy Policy, we do not knowingly process personal information from children for any purpose. If you believe that we have personal information concerning a child under the age set out above without lawful basis, or if you are the parent, guardian or other person with parental responsibility of the child user and wish to withdraw consent, please contact us (see Contact Us section in the Privacy Portal).

For information about our practices regarding children's personal information, please read our Children's Privacy Policy. 

 

4. Parents and guardians

If you are a parent, guardian or other person with parental responsibility and want to know more about how we process personal information concerning a child you are responsible for, please read this notice Information for Parents.

 

5. What information do we process?

We process information in the following ways:

• when you directly provide it to us;
• when you interact with us;
• when you use our Services; and
• when we receive information from third parties.

The following is a summary and provides relevant examples of the types of personal information we process:

A. Information you directly provide to us

ⓘ We will process personal information that you directly provide to us, such as: If you create an account with us, we will process basic registration information that you provide such as your nickname, the country you live in, your email address, mobile phone number, etc. When you make purchases on our platform, we will ask for your payment-related information such as credit card number and expiration date. We will also process information you voluntarily provide, such as when you use our social features to send a message or share a photo or sign up for/or attend an event.

Examples of information you directly provide to us include:

• When you create and manage an account, we will process the registration and account information you provide such as your nickname, date of birth (though date of birth is not stored), email address, mobile phone number, password and similar.

 

• If you make a purchase or transact on our platform, we will process payment and billing information such as your credit card number, expiry date, CVC, first name and family name, email address, billing address and similar.

 

• If you use social features within our Services, such as finding your friends that use the same Service and sending, uploading or publishing text, audio, visual and/or other electronic communications information to us, to another user or to a wider group or forum, we will process the information you provide.

 

• If you respond to our surveys and other enquiries in relation to our Services, we will process your feedback (in particular, your user ID, age, gender, contact information, other responses you choose to provide and similar).

 

• If you interact with us, such as seeking customer support (either through chatting with our staff or interacting with an AI-powered chatbot) or submitting a data request, we will process the information you provide such as user ID, email, any evidence you submit for investigation and similar.

 

• If you sign up for our communications or email alerts, for example, about our Services updates and exciting upcoming games, events or activities, we will process the information you voluntarily provide to us.

 

• If you sign up and participate in events we organise (such as e-sports events or community events), we will process the information you provide such as your user ID, your team's name, team's logo, date of birth, country, contact information, name on your passport, postal/zip code and address and similar.

 

• If you engage with certain functions of our Services, for example, sending text, audio or images to our AI-driven functions for creative output or granting us access to specific content such as a selected photo album on your device, we will process the information you provide.

 

B. Information we process when you interact with us

ⓘ Information we process when you interact with us (e.g. when you play games or participate in relevant activities and events) includes: Depending on the game you play, we will generally process information about your in-game profile, your gameplay data and your other interactions with us and other players. If you sign up to participate in certain tournaments or events, we may take photos, video record and/or livestream these tournaments or events, in which case certain data relating to you or your team (such as your game performance) will be processed, captured and displayed on public platforms for a broader audience to enjoy.

 

Information we process includes:

• Player's identity, role and appearance: user ID, role name, role ID, skin and similar.

 

• Gameplay data: your in-game actions (e.g., movement, hit and kill), weapons, level, scores, in-game currency, gameplay performance, start and end times, task completion records, achievements and other relevant behaviour and performance information about your interaction with the game.

 

• Team and social: information such as your performance with friends and other players, rankings, leaderboards and similar.

 

• Gameplay time: for users in certain regions, we will process gameplay time data such as your daily cumulative gameplay time and your daily rest time to prevent gaming addiction.

 

• Photos, video clips and livestreams: in some cases, such as when you enable our replay function (if applicable) or when we capture in-game video clips for anti-cheating and security review, we will collect and process game photos, screenshots, video clips and similar. If you choose to participate in the events and tournaments, we may also take photos, video and/or livestream these events and tournaments.

 

C. Other information we automatically process when you use our Services

ⓘ We also process some information automatically when you use our Services, such as: Your usage information reflecting how you interact with us. Information about your device and hardware. Your transaction information. Approximate and precise geolocation data. Data that allows us to prevent cheating and verify compliance with our terms with you.

 

Information we automatically process when you use our Services includes:

• Usage information and statistics about how you interact with our Services, including your website/application usage, saved preferences, crash reports, the URLs of websites that you have visited, time spent on a page, last active time, session count, your clicks on certain pages, your interaction with ads such as any ads you click and the type of ad you view and similar.

 

• Technical information about your device, hardware, software and network, such as your hardware identifiers, hardware-related information, device brand and manufacturer, screen resolution, recharge and consumption record, WiFi-related data such as strength and speed and other network information.

 

• Browser information, including your browser type, browser version, language preference and similar.

 

• Limited approximate geolocation data that is derived from your IP address, internet connection or device (if applicable) in Services with enabled features including finding your friends or locating players near you, etc.

 

• Precise geolocation data that is derived from your GPS in Services with enabled features, including finding your friends or matches, etc.

 

• Transaction information such as purchase history, details of transaction (such as transaction time, items purchased, cost and currency) and similar.

 

• Anti-cheating and security- related information including your hardware information, data relating to the presence of restricted files and emulators or restricted modifications to files and other data revealed by anti-cheat testing.

 

• Information used for checking your compliance with terms you agreed with us, including the end-user licence agreement (EULA) and other similar agreements.

 

ⓘ Cookies and other technologies We use a variety of technologies such as cookies, software development kits (SDKs), log files and analytics tools to automatically process types of information listed above. If the Services you use that have cookies: You can control the use of cookies at the individual browser level. If you reject some or all cookies, you will usually still be able to use our websites and Services, but your ability to use or enjoy features or areas of our websites may be limited or deactivated. For further information, please refer to our Cookies Policy in the Privacy Portal.

 

D. Information we receive from third parties

ⓘ In some cases, we will process information about you received from third parties, including: Information we receive from third parties in connection with your use of our Services, for example, when you login through your account from a third-party platform (such as QQ, WeChat, Meta, Vkontakte, X, Google Play, Line, Apple, Steam, XBOX, etc.), we will process information such as your user ID, nickname, profile picture, user token and email address associated with that account. Information we receive when other players share their friend/contact list from a third-party platform with us. Selected partners who are permitted to share additional information or insights about or similar to you (specifically, to help our understanding what you are enjoying about our Services or advertisements you may enjoy). If you interact with an advertisement on an external website, the company that operates that website may share some information with us in accordance with its own privacy practices.

 

6. How do we use your information?

We use your information to help us provide, improve, customise, analyse and promote our Services, including:

 

• providing the experiences, products and services you request and engage with, such as enabling and facilitating your participation in games and events and fulfilling orders you request.

 

• providing customer support, such as addressing a complaint and handling a data request.

 

• operating, developing and improving our Services and enhancing user experience.

 

• managing alpha, beta, early access and patch tests and collecting feedback from players who seek to participate in tests.

 

• personalising your experience, including presenting content or features better tailored to your interests and leveraging AI tools to generate content (e.g. personalised gaming content).

 

• identifying, fixing and troubleshooting bugs or functionality errors.

 

• assessing and improving the quality of our Services and products, such as using your device and network information to analyse gaming performance quality on different device models and networks to optimise your experience.

 

• undertaking data analysis and research to better understand our players and market and further develop and update our Services.

 

• securing our Services by detecting security incidents and protecting against cheating, malicious, deceptive, fraudulent or illegal actions.

 

• communicating our new products, services, enhancement, offers, promotions or other information to you.

 

• marketing and showcasing our Services, such as promoting our Services in our platform as well as third-party platforms, managing and measuring the effectiveness of our advertisements and sending you information about our products, services and events tailored to your interests.
• performing or providing information in connection with audits, transactions and other compliance activities as well as complying with our legal or contractual obligations.

 

• other purposes that are set out in the Privacy Portal’s Additional Information section or are otherwise disclosed to you on or prior to processing your personal information.

 

We also handle information that does not personally identify you, such as aggregated or de-identified data that we generate. This data helps us gain insights into larger user groups. Our Privacy Policy does not limit our ability to process data that does not personally identify you, and we may use and share aggregated or de-identified data for any legally permissible purpose.

 

7. Legal basis for processing

The legal bases we rely on to process your personal information vary and depend on multiple factors, including: (i) the Services you use; (ii) the type of personal information involved; (iii) the context within which we process your information; and (iv) your country of residence.

The following table provides you an overview of legal bases we rely on, the corresponding purposes for processing, and the types of processed information.

If the legal bases below are not applicable in your jurisdiction, by using the Service you consent to the collection, use, disclosure, transfer, processing, export (to the extent permitted by applicable laws) and storage of your personal information as described in this Privacy Policy.

 

Basis	Why	Examples of data categories
Contract	It is necessary to perform our contract with you to: provide the experiences, products and services you request and engage with, such as enabling and facilitating your participation in games and events (including using the social features therein) and fulfilling orders you request.	Registration and account information (e.g., nickname, date of birth (though date of birth is not stored), age, email address, mobile phone number and other registration info when you sign up for activities and tournaments) Account linking (e.g. if you log in using Meta, we import information such as user ID, nickname, profile picture, email address associated with that account) Information we process when you use social features within our Services (e.g., text, audio, visual communications) Payment and billing information (e.g., credit card number, expiry date, CVC, email address, billing address)
Legitimate Interests	For our legitimate interests or those of a third party (such as a transaction counterparty or lender) to: provide you with customer support.	Information we process when you seek customer service (e.g., user ID, email, any evidence you submit for investigation)
	identify, fix and troubleshoot bugs or functionality errors.	Information we process for data analytics to fix bugs and monitor quality (e.g., device and network information)
	undertake data analysis and research to better understand our players and market, personalise your experience and further develop our Services.	Gameplay information (e.g. in-game actions and behaviours, in-game currency, gameplay time) Transaction information (e.g. purchase history)
	assess and improve the quality of our Services and products, such as analyse gaming performance quality on different device models and networks to optimise your experience.	Technical information about your device, hardware, software and network (e.g., hardware-related information, device brand and manufacturer, WiFi-related data)
	secure our Services by detecting and preventing security incidents and protecting against cheating, malicious and deceptive actions and to maintain a fair environment for our games and Services.	Anti-cheating and security- related information (e.g., hardware information, cheat tool detection information (e.g. device data), data relating to the presence of restricted files and emulators, reported chat messages or screenshots, player reports, data of players suspected of cheating, malicious content information (e.g. nicknames, profile photos, chat histories, audio self-introductions))
	monitor compliance with our terms.	Information used for checking your compliance with terms you agreed with us (e.g., the end-user licence agreement (EULA))
	engage in commercial transactions (for example, if a third party acquires our business)	Registration and account information
	manage and measure the effectiveness of our advertisements.	Advertising engagement and interaction information (e.g., information about your interaction with ads)
Legal Obligations	It is necessary to fulfil an applicable legal or regulatory obligation to which we are subject, in order to: comply with requests from regulatory, governmental, tax and law enforcement authorities. carry out audit checks. prevent and detect fraud.	Information we process to identify abuse, harassment or illegal actions (e.g., user ID, nickname, profile picture, reported chat messages or screenshots) Information we provide in response to requests from law enforcement or other government authorities
	meet the legal obligations we have to you, such as handling a data access request.	Information we process when you initiate a data subject request (e.g., user ID, email address)
Consent	We also process your information based on your consent (where such consent is required by law) to: send you email or in-game notifications about our new promotions, products and activities.	Email address and user ID
	participate in our surveys or tests.	Information we process when you respond to our surveys and other enquiries (e.g., user ID, age, gender, nickname, location, contact information)
	participate in our events and activities that may capture and showcase your performance.	Information we process when you participate in tournaments or events (e.g., user ID, gameplay data, game photos, screenshots, video clips)

 

8. Where do we store your information?

Data storage: Our corporate group operates around the world and we have servers in different locations including (but not limited to) Singapore, Japan, Korea, Malaysia, the United States of America and Germany. Depending on your location, your personal information will be processed on servers that may not be located where you live. The servers applicable to your use of our Services will also depend upon your location.

Data transfers:

• Where? We may transfer your information outside the location in which you are based for the purposes described in this Privacy Policy. Additionally, your information can be accessed from places outside where you live by our supporting, engineering and other teams around the world, and may be transferred to our affiliates, group members, service providers and business partners in accordance with this Privacy Policy. Furthermore, if we undergo a business transition such as merger or acquisition by another company, or sale of all or part of our business or assets, your information may be among the assets transferred (and handled in accordance with applicable law). Those countries may not have the same data protection laws as the country in which you initially provided the information.
• How? Some countries impose restrictions on data transfers outside their territories. This includes, for example, transfers outside the UK and the European Economic Area ("EEA"). Where we transfer personal information across borders, we will ensure we implement appropriate safeguards to protect your information as required under applicable data protection law. Specifically: (i) for transfer between our group companies, we have put in place intragroup data transfer agreements that incorporate applicable standard contractual clauses ("SCCs") approved by relevant authorities; (ii) for transfers not covered by point (i) or to third parties and vendors located outside of the UK, EEA or other territories with data transfer restrictions, we rely on various legally recognized transfer mechanisms including your explicit consent, agreements incorporating SCCs, adequacy decisions issued by relevant authorities and other appropriate safeguards. The specific transfer mechanism used depends on the recipient party, their location and the applicable legal requirements.

Please refer to the Privacy Portal’s Additional Information section for more information regarding where the data is stored and may be further transferred for that specific game. Some of these countries benefit from adequacy decisions, which can be found here for transfers from the EEA, and here for transfers from the UK. The SCCs for transfers from the EEA are available here and from the UK are available here (we generally rely on Modules 1 and 2).

 

9. Who do we share your information with?

Only where necessary, we may disclose your personal information to the following recipients. Please refer to Privacy Portal’s Additional Information section for specific disclosure (if applicable).

• Third-party providers that provide services in support of our Services, including providers of cloud services, ad attribution providers, providers that carry out surveys, providers and carriers who send authentication messages, service providers that conduct data analytics, push notifications and payment and marketing services. All third-party service providers providing services for us are prohibited from retaining, using or disclosing your personal information for any purpose except where strictly necessary for supporting our Services.
• Third-party partners that we collaborate with in providing and delivering our Services, including app stores where you download our applications, social media platforms if you select to login through your account on those platforms or otherwise choose to share certain information on social media platforms linked through our Services, and analytics and marketing companies. These companies will process your personal information and govern your use of their services and products in accordance with their terms and privacy policies.
• Companies within our corporate group who process your personal information where necessary for purposes set out in this Privacy Policy, including delivering and securing our Services and conducting data analytics to improve and promote our Services or the products and services of our corporate group.
• Regulators, judicial authorities and law enforcement agencies: there are circumstances where we are legally required to disclose information about you, such as to comply with legal obligations or processes or where we have determined that it is necessary to share your personal data to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries. In complying with the terms of valid legal processes, such as a subpoena or search warrant, we may not be able to seek your consent to or notify you in advance of such disclosure.
• Third parties to ensure safety, security, or compliance with laws: we may also disclose your information to:
  • enforce our terms and conditions and other agreements, including investigation of any potential violation;
  • detect, prevent or otherwise address security, fraud or technical issues; and
  • protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (such as exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
• A third party that acquires all or substantially all of us or our business: we may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner or other third party involved in such sale or transfer.

For a list of overseas third parties we may transfer your information to, please refer to this table.

10. How do we protect your personal information?

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We use a range of technical and organisational measures designed to protect your personal information from accidental, unlawful or unauthorised destruction, loss, alteration and access. In addition, we request vendors who process personal information on our behalf to take reasonable measures designed to help protect your personal information.

However, the transmission of information via the internet is never completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted as part of our Services or otherwise via the internet; any transmission is at your own risk. You also play an important role in the security of your account, and we encourage you to set a reasonably complex password and change your password periodically.

 

11. How long do we retain your information?

The retention period for your information varies depending on the categories of personal information we process and how you interact with our Services. We retain your personal information for as long as necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required by applicable laws.

We will retain your information in line with our retention policies, and the main criteria we consider in determining specific retention periods includes relevant legal requirements and industry standards, the types and nature of information involved and relevance to potential dispute. Look below for an overview of our general practices on information retention.

 

Kindly note that there will be a gap between the time you request us to delete your information and the day we execute your instructions. For further information, please see section 12 (What are your rights and how to exercise your rights?).

We conduct periodic review of our retention policy to ensure it aligns with our commitment to protecting your privacy and best practices.

12. What are your rights and how to exercise your rights?

You have certain rights in relation to the personal information we hold about you. We respect and uphold your rights and, depending on where you are located, your rights to your personal information vary and may include the following rights:

 

Access

The right to access personal information we hold about you, how we use it and who we share it with.

 

Portability

The right to receive a copy of certain personal information we process about you. For example, in certain jurisdictions this can comprise personal information we process on the basis of your consent (e.g. survey information) or pursuant to our contract with you (e.g. account name), as described above in section 6 (How do we use your information?). We will provide further information to you about transferring this data if you make such a request.

 

Correction

The right to correct personal information we hold that is inaccurate.

 

Erasure

The right to delete your account or remove certain personal information. We may need to retain personal information if there are valid grounds under data protection laws.

 

Restriction of processing to storage only

The right to require that we stop processing the personal information we hold about you (other than for storage purposes in certain circumstances). Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another's protection).

 

Objection

The right to object to our processing of your personal information. If you wish to do so, please contact us (see section 2 (Data controller and how to contact us)) and we will review your request.

 

Consent withdrawal

To the extent provided by applicable laws and regulations, you can withdraw consent you previously provided to us for certain processing activities by contacting us. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent, we may not be able to deliver the expected service. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.

 

Advertising: We will only send marketing messages to you if we have your consent. You may can choose to stop receiving marketing messages from us by using the unsubscribe option in our messages or reach out to us via Contact Us section in the Privacy Portal.

 

Announcements: We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to any game for maintenance or security reasons). There are essential system and service-related announcements (which are not promotional in nature) that you cannot opt out of as we believe they are important to your interests.

 

Complain

The right to make a complaint to the data protection regulator in your country. However, we always hope that we can resolve any questions or concerns directly – and you can always contact us through the details included in the Contact Us section in the Privacy Portal.

 

Not all of the rights described above are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request because a right is not granted by the laws that apply. Individuals in certain jurisdictions may have other rights. You can exercise some of these rights directly by accessing and updating the information in your account. To help you better understand your rights, see the applicable Privacy Portal’s Additional Information section.

If you wish to exercise any of your rights, or you believe we hold any other personal information about you, please contact us through the details included in the Contact Us section in the Privacy Portal

 

13. Changes

If we make any changes to this Privacy Policy, we will post the updated Privacy Policy here and notify you in accordance with applicable legal requirements. We encourage you to check this page frequently to stay tuned and informed.

 

14. Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this Privacy Policy, the English version shall prevail.