PRIVACY POLICY

Effective Date: January 28, 2018

This Privacy Policy applies to Hikers Games Joint Stock Corporation’s (“Hiker Games”) games, websites and services on which it is placed (“Product” or “Products”) and details information we collect, use and disclose about our users, including you. This privacy policy applies to WWW.HIKERGAMES.COM and any products downloaded from us.

BY USING ANY OF OUR PRODUCTS, YOU ARE AGREEING TO THE TERMS OF THIS PRIVACY POLICY AND ANY UPDATES YOU ARE NOTIFIED OF AS PROVIDED HEREIN. IF YOU DO NOT WANT INFORMATION COLLECTED OR DISCLOSED, DO NOT USE THE PRODUCTS.

We collect and use your information internally and may disclose your information to third parties, outside of HIKER GAMES, in certain situations described in the Privacy Policy.

The Privacy Policy addresses two kinds of information that we collect from you: (1) personal information, and (2) anonymous information. Personal information identifies you and includes, for example, your name, telephone number, address, email address and other information that you provide to us. Anonymous information does not identify you, such as statistical data about how you use the Products and can be combined with anonymous information about other users.

This privacy policy answers the following questions and provides other important information:

· What personal information do we collect?

· What anonymous information do we collect?

· How do we use your information?

· To whom do we disclose your information?

· Do we use third-party services?

· Do advertisers collect information?

· What information is disclosed to other users?

· What is our cookies policy?

· Can you enable Do Not Track on my browser?

· How can you request information about disclosures (California “Shine The Light” Requests)?

· How is your information stored and retained?

· What if you are under the age of 13?

· What if you are between the ages of 13 and 18?

· What if you are a parent or guardian?

· Is your personal information secure?

· How will I know if this privacy policy changes?

1. PERSONAL INFORMATION WE COLLECT

We collect your personal information in the following circumstances:

• to register for accessing the Product, we may collect your name, email address, state/province and country of residence, zip/postal code, birthdate and gender;
• when you sign up for a HIKER GAMES newsletter, we collect your name and email address;
• if you connect the Products to a social media account, such as Facebook, we collect your name, email address, profile picture, age range, gender and other information you make public on Facebook, in addition to your friend list (unless you affirmatively revoke such collection);
• we collect your geolocation data when you use the Products, which we associate with your personal and anonymous information;
• if you create an account to access with the Products, or connect the Products to a social media account, such as Facebook, your personal information may be linked to otherwise anonymous information collected in accordance with the Privacy Policy, such as how you use the Products or items you purchased at online stores associated with the Products; and
• if you contact us for customer service, we may collect your email address, first and last name and, if required, Facebook information, and associate this personal information with anonymous information, such as information about your device.

Please note that while the Products may allow you to visit as a guest and remain anonymous, you may not be able to access all content and features without providing personal information.

2. ANONYMOUS INFORMATION WE COLLECT

We collect anonymous information from you, which may be provided to us by a third-party, including but not limited to:

• metrics and other types of statistical data, which could be derived from your use of the Products, for example how you interact with the Products;
• how you access the Products, for example, computer operating system and web browser, type of mobile device and unique device identifier, device settings, SDK version, mobile advertising identifier (Apple IDFA, Google Advertising ID or Android ID), MAC address, IP address, Wi-Fi information, your “click path” through the Products and the web site or advertisement that was linked to or from the Products;
• diagnostic information concerning the Products, for example, logs, error reports and events and the type, number, date and page relating to this information; and
• apps you have installed and enabled and how you use those applications.

Please note that while your computer or mobile device may allow you to turn off the collection of some of the above information, you may not be able to access all content and features on the Products.

3. HOW WE USE YOUR INFORMATION

We use your personal and anonymous information internally for purposes that include:

• to provide the Products to you, such as hosting and displaying information, providing updates, developing, improving or expanding the Products and addressing technical issues;
• to generate and analyze information about our users so we can better understand them and how they use the Products and draw trends and predictions based on this information;
• to serve you advertisements, provided by HIKER GAMES or third parties, on the Products, as well as for marketing and promotional purposes;
• to send Service-related push notifications to your device;
• to establish and maintain your account on the Products and to protect the security of your account;
• to provide customer support or to resolve customer issues;
• to inform you of changes to the Products, such as outages, suspensions or other material changes, which could occur through email or a push notification sent to your device; and
• if you signed up for any HIKER GAMES newsletter, to contact you by email for HIKER GAMES news, promotional purposes or market research and that you may opt-out of by clicking an opt-out link located in such an email.

4. INFORMATION DISCLOSURE

We disclose your information outside of HIKER GAMES for the following purposes:

• we disclose your information to third parties who provide services on our behalf, as described below in this Privacy Policy;
• for internal HIKER GAMES purposes, we may disclose your personal and anonymous information to our parent companies, affiliates, subsidiaries and contractors;
• we disclose your information to law enforcement or other appropriate third parties in connection with criminal investigations, investigation of fraud, infringement of intellectual property rights, other suspected illegal activities or as otherwise may be required by applicable law or, as we deem necessary in our sole discretion, in order to protect the legitimate legal and business interests of HIKER GAMES; and
• in the event of, or in preparation for, a change of ownership or control of HIKER GAMES, a business transition, such as the sale of some, or all, HIKER GAMES assets, or the bankruptcy of HIKER GAMES, we may disclose and or assign your personal and anonymous information to third parties who will have the right to continue to use such information in the manner set forth in the Privacy Policy.

5. THIRD-PARTY SERVICES

We use third parties, who we share your information with and who may collect information from you to assist us with, for example, serving advertisements, fulfilling a purpose you requested of us (for example, billing services), customer support and feedback, analyzing Products functionality and technical issues, sending useful notifications to user devices, tracking use of the Products and generating reports and data models that we use to improve the Products. These third-party services may be embedded into the Products, such as through an API or SDK, or may take the form of tracking technologies, such as cookies, web beacons and clear gifs (“Tracking Technologies”), which enable these third parties to collect information on our behalf.

Information collected by third parties is governed by the applicable third-party privacy policy, which may provide for broader information collection than collected by HIKER GAMES. These third parties may use your information internally and disclose your information to others and we strongly recommend that you read each third-party privacy policy carefully before providing your information.

A list of third-party services used by HIKER GAMES, and corresponding privacy policies, is available by contacting us at: contact@hikergames.com

6. ADVERTISING

The Products may contain advertisements served by third parties. These advertisements use Tracking Technologies to collect information about you, for example, demographics, location and device information, in order to serve you appropriate advertisements and to recognize your device each time a third-party serves you an advertisement. Based on this information, third parties may be able to resolve your identity across multiple devices, for example, matching your IP address across multiple devices, in order to target advertisements to you based on your online behavior. This information is collected, used and disclosed in accordance with the terms of the applicable third-party privacy policy, as described in section 5 above.

You may be able to opt-out of mobile behavioral advertising by accessing the settings on your Apple or Android device and selecting the appropriate advertisement tracking settings.

7. SERVICE COMMUNICATION FEATURES

Your username and profile picture on the Products are visible to other users of the Products. We recommend you exercise discretion when selecting your username and profile picture and when using the Products. Personal information disclosed by you within our chat areas, instant message service, message boards or during use of the Products can be collected by other users and may result in unsolicited messages. We are not responsible for protecting such information that you may disclose to third parties through our Products (for example, sending your telephone number to another user through the chat service). To the extent that you create a public profile that may be available to others on our Products, you are solely responsible for its content and accuracy. To edit, change, or delete the above information, follow the instructions provided in the Products.

8. COOKIES

When you use our site, we will store cookies on your computer in order to facilitate and customize your use of our site. A cookie is a small data text file, which a Web site stores on your computer’s hard drive (if your Web browser permits) that can later be retrieved to identify you to us. Our cookies store randomly assigned user identification numbers, the country where you are located, and your first name to welcome you back to our site. The cookies make your use of the site easier, make the site run more smoothly and help us to maintain a secure site. You are always free to decline our cookies if your browser permits, but some portions of the Products might not function properly.

We may use an outside ad serving company to display banner advertisements on our site. As part of their service, they will place a separate cookie on your computer. We will not provide any third-party ad server with any of your Personally Identifiable Information or information about your purchases. These third-party ad servers may collect information from you such as your device identifier, MAC address, IMEI, locale (specific location where a given language is spoken), geo-location information, IP address, application usage, access and session times, applications present on the device or in use at a particular time on the device, and your viewing of and interactions with advertising, for the purpose of providing their services, including, for example, enabling, providing and delivering advertising.

Other advertisers and third parties that provide services on our website may also place cookies on your computer and those cookies are subject to each advertiser’s own cookie policy which we cannot control. You should check with each advertiser to see what its cookie policy is.

8. THIRD-PARTY PRIVACY POLICIES

Other sites accessible through our site have their own privacy policies and data collection, use and disclosure practices. Please consult each site’s privacy policy. We are not responsible for the policies or practices of third parties. Additionally, other companies which place advertising on our site may collect information about you when you view or click on their advertising through the use of cookies. We cannot control this collection of information. You should contact these advertisers directly if you have any questions about their use of the information that they collect.

9. CALIFORNIA DO NOT TRACK DISCLOSURE

Do Not Track, or DNT, is a web browser setting that requests that a web application disable its tracking of you. When you choose to turn on the DNT setting in your browser, your browser sends a special signal to websites, analytics companies, advertising networks, plug in providers and other web services you encounter while browsing to stop tracking your activity. Currently, there is no DNT technology standard and, as a result, the Products do not respond to DNT signals.

10. CALIFORNIA “SHINE THE LIGHT” RIGHT

If you are a California resident, California Civil Code Section 1798.82 grants you the right to request HIKER GAMES’s disclosure of the categories of personal information we provided to third parties, and the names and addresses of these third parties, for direct marketing purposes during the preceding calendar year. If you are a California resident and would to make this request, please contact us at contact@hikergames.com or:

Hiker Games Joint Stock Company
No 63 Hoang Cau Street,

O Cho Dua, Dong Da, Hanoi, Vietnam

Please note that you may only make this request once per year.

11. ACCESSING OR CHANGING INFORMATION YOU PROVIDED TO US

You may contact HIKER GAMES to obtain a copy of any personal information we have collected about you, the production of which may be subject to a fee as permitted by applicable law. In addition, you may contact HIKER GAMES to correct or delete such information, except to the extent that retention is necessary for our legitimate business purposes, required by applicable law, in the control of a third-party or where correction or deletion is not technically feasible.

If you have any questions or would like to access or change your information via email, please contact us at contact@hikergames.com

12. INFORMATION STORAGE AND RETENTION

While HIKER GAMES is a Vietnamese company, the data you provide through the Products is stored and processed by third parties in countries around the world. You authorize HIKER GAMES and third parties acting on HIKER GAMES’s behalf to use and process your data in any country of their choosing, which may cause your data, including personal and anonymous information, to be subject to privacy protections and legal rights that may not be equivalent to those in your country.

Your personal information is retained until you request its deletion pursuant to section 11 or until HIKER GAMES no longer requires such information for the purpose for which it was collected.

13. INFORMATION FOR EUROPEAN UNION PERSONS

For persons in European Union countries, terms such as “personal information” as used herein refer to “personal data” as defined by the Directive 95/46/EC of the European Parliament and of the Council of 24 October 1995 on the protection of individuals with regard to the processing of personal data and on the free movement of such data. We will not collect any personal data from you unless you provide it under the terms of the Privacy Policy. By using the Products, you agree that we may transfer your personal information outside the European Union in connection with the purposes stated in the Privacy Policy. Your personal data will be transferred to the United States (and/or other non-EU jurisdictions, as applicable).

14. IF YOU ARE UNDER THE AGE OF 13

HIKER GAMES complies with the U.S. Children’s Online Privacy Protection Act and all other applicable laws and regulations concerning children and the Internet. If you are under the age of 13, you may not create an account on or use the Products. HIKER GAMES will not knowingly collect, maintain, or disclose any personal information from children under the age of 13.

15. IF YOU ARE BETWEEN THE AGES OF 13 AND 18

If you are between the ages of 13 and 18, please have your parent or guardian read the Privacy Policy and get his or her permission before you provide any personal information and before you sign up for or use the Products. Never tell anyone online anything private about yourself or your family, including your phone number and address, unless your parent or guardian has approved. Understand that certain social media platforms that you use to access the Products may have this information visible. Use screen names whenever possible to protect your identity. Some areas of the Products may have special rules for children under the age of 18. When you are in those areas, you must follow those rules.

16. INFORMATION FOR PARENTS/GUARDIANS

HIKER GAMES encourages parents and guardians to spend time online with their children to become familiar with the types of content available on the Internet, including our Products. Parents and guardians should regularly oversee their children’s use of e-mail and other online communications and transactional features. Control tools are available from online services and software manufacturers that can help provide a safe online environment for kids.

If you are a parent or guardian who has discovered that your child has submitted his or her personal information without your permission or consent, HIKER GAMES will take reasonable steps to remove that information from the HIKER GAMES database at your request. To request removal of your child’s information, please send an e-mail to at contact@hikergames.com

17. SECURITY

While HIKER GAMES takes precautions against possible breaches in the Products, no website, application or Internet transmission is completely secure. For example, HIKER GAMES employs a security technology known as a secure-socket-layer, or SSL, to protect the transmission of critical account information through the Products. However, HIKER GAMES cannot guarantee that unauthorized access, hacking, data loss, or other breaches will never occur. Your use of the Products is at your own risk. HIKER GAMES urges you to take steps to keep your personal information safe by memorizing your password or keeping it in a safe place (separate from your account information), logging out of your account and closing your web browser.

18. UPDATES

HIKER GAMES reserves the right, at its sole discretion, to change or modify or to add or remove portions of the Privacy Policy at any time (“Updates”). We agree to notify you of Updates through a Products message and to make them available at WWW.HIKERGAMES.COM or any subsequent URL that HIKER GAMES may use. You are deemed to have accepted any Update by continuing to use the Products. Unless HIKER GAMES states otherwise, Updates are automatically effective 30 days after being posted on WWW.HIKERGAMES.COM or any subsequent URL that HIKER GAMES may use.

19. EMAIL AND PUSH NOTIFICATION PREFERENCES

We communicate with our users primarily by email. If you would like to change the email preferences we associate with you (for example, unsubscribing from receiving certain types of email) you may do so by clicking a link within emails that we send to you. If you would like to opt out of receiving push notifications from HIKER GAMES, to the extent permitted, you may do so by changing the notification settings on your device.

20. OTHER IMPORTANT AGREEMENTS THAT GOVERN YOUR USE OF THE PRODUCTS

In addition to the Privacy Policy, your rights and obligations concerning our Products are governed by the HIKER GAMES Terms of Use and other applicable policies, guidelines and requirements. When you sign up to use our Products, please review each agreement carefully as you must agree to be bound by each agreement before you may use the Products.

21. CONTACT US

If you have questions or comments about the Privacy Policy or HIKER GAMES’s information collection in general, please contact us at at contact@hikergames.com or by mail to:

Attn: Legal Department

Hiker Games Joint Stock Company
No 63 Hoang Cau Street,

O Cho Dua, Dong Da, Hanoi, Vietnam

All personal information you provide via email or mail concerning the Privacy Policy or HIKER GAMES’s information collection practices will be kept confidential.