Privacy Policy – Loong Rising Limited

Last Updated: January 10, 2025

LOONG RISING LIMITED (hereinafter “LOONG RISING“，“we”, “us” or “our”) places great importance on protecting your privacy and safeguarding your personal information. We understand how crucial your personal information is to you and are committed to handling it with care and transparency.

This privacy policy (“Privacy Policy”) describes the ways we collect, manage, store, use, and protect the information, including personal information, and data that you provide or we collect in connection with any LOONG RISING’s game, website or application (“Service”). By using our Service, you agree to the collection and use of your personal information as outlined in this Privacy Policy.

Your personal data will be held by us in accordance with applicable data protection laws. For the purposes of data protection laws, the data controller will be LOONG RISING.

This Privacy Policy informs you of the following information::

1. Persons Under The Age of 1

2. Personal Information We Collect And How We Collect It

3. The Purpose of Collecting Your Personal data

4. Cookies

5. Sharing Information

6. Your Rights

7. How to Exercise Your Rights

8. Account Deletion

9. RETENTION

10. International Transfers of Data

11. Security

12. Update of the Policy

13. Contacting Us

Persons Under The Age of 16

This Service and its content are not directed to children younger than sixteen (16) years of age. We do not knowingly collect or solicit personal information from individuals under 16 years old or knowingly allow such persons to use our Services. If you are under 16, please do not use the Service and do not send any information about yourself to us.

Personal Information We Collect And How We Collect It

We collect personal data about you in the following situations during your use of LOONG RISING’s services:

When you use our game applications.
When you create or manage a user account.
When you connect your user account to Facebook.
When you participate in interactive features of the Service.
When you communicate with us or interact through the Service.

Please note that when you use our services , we won’t collect your legally-sensitive data (i.e. race, ethnicity, religious or philosophical beliefs, trade union membership, genetics, biometrics, health, sexuality and/or criminality) and other sensitive data (i.e. child data, social security numbers, bank account or payment card details).

We may collect user’s data from you, which includes:

1) Personal Identification Information:
We collect details such as your name, date of birth, email address, and personal description.

2) Demographic, Location, and Device Information:
This includes demographic and location data, along with device-specific details like your IP address, device UDID, IDFA, IDFV, Android ID, software, applications, hardware specifications, browser information, internet usage patterns, and in-game activity data.

3) Technical Information for Security and Verification:
To ensure account security and verify account activity, we collect technical data such as your IP address, log-in details, access time and date, time zone, visited web pages, software crash reports, browser type and version, browser plug-ins, and operating system and platform.

4) Browsing and Interaction Information:
We track your visit details, including the complete URL clickstream (to, through, and from our websites and apps), services viewed or searched for, page response times, download errors, length of page visits, interaction methods (e.g., scrolling, clicks, and mouse-overs), and methods used to navigate away. Additionally, we record any phone numbers used to contact our customer service team.

5) In-Game and Social Interaction Information:
While you play games, participate in discussion boards or social media features, or report issues on our websites or mobile apps, we collect information about your in-game behaviors and interactions.

We may also employ third party ad-serving and/or analytics technologies that may use various methods to collect information through our software and the Service. These technologies may be embedded within our software and the Service and may collect, amongst other things, the above information.

Depending on the type of personal data in question and the grounds on which we may be processing it, should you decline to provide us with such data, we may not be able to fulfil our contractual requirements or, in extreme cases, may not be able to continue with our relationship. We will inform you if your failure to provide any requested personal information is going to result in these consequences.

For California Consumer Privacy Act of 2018 (CCPA) Consumers (Notice of Collection of Information)

We collect the categories of personal information about California consumers identified in the chart below. As further set forth in the chart below, in the past 12 months we have disclosed and “sold” (as defined in the CCPA) California consumers’ personal information to third parties for business or commercial purposes.

Categories of Personal Information:	Categories of sources from which information is collected:	Business or commercial purposes for collection, use and sharing:	Disclosed for business purposes to the following categories of third parties:	Sold to the following categories of third parties:
Personal and online identifiers (such as unique online identifiers, IP address)	Consumers	Marketing; Advertising; Authentication; Identity resolution; Fraud detection; Fulfillment services; Facilitating transactions; Auditing related to our interactions with you; Legal compliance; Detecting and protecting against security incidents, fraud, and illegal activity; Debugging; Performing services (for us or our service providers) such as account servicing, processing orders and payments, and analytics; Internal research for technological improvement; Internal operations; Activities to maintain and improve our services; and Other one-time uses	Affiliates; Service providers; and Government agencies	Advertising/marketing companies; Advertising networks; Social networks
Internet or other electronic network activity information (such as interactions with an application, or advertisement)	Consumers; Service Providers	Marketing; Advertising; Authentication; Identity resolution; Fraud prevention; Fulfillment services; Facilitating transactions; Auditing related to our interactions with you; Legal compliance; Detecting and protecting against security incidents, fraud, and illegal activity; Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics; Internal research for technological improvement; Internal operations; Activities to maintain and improve our services; and Other one-time uses	Affiliates; Service providers	Advertising/marketing companies; Advertising networks; Social networks
Commercial or transactions information (such as records of personal property or products or services purchased, obtained or considered; purchasing or consuming histories or tendencies)	Consumers; Service Providers; App store providers	Fulfillment services; Facilitating transactions; Auditing related to our interactions with you; Debugging; Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics;Internal research for technological improvement; Internal operations; Activities to maintain and improve our services;and Other one-time uses	Affiliates; Service providers; App store providers
Geolocation information	Service Providers	Marketing; Advertising; Fulfillment services; Facilitating transactions; Auditing related to our interactions with you; Legal compliance; Debugging; Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics; Internal research for technological improvement; Internal operations; Activities to maintain and improve our services; and Other one-time uses	Affiliates; Service providers	Advertising/marketing companies; Advertising networks; Data analytics providers; and Social networks
Inferences drawn from the above information about your predicted characteristics and preferences	Consumers	Marketing; Advertising; Legal compliance; Detecting and protecting against security incidents, fraud, and illegal activity; Debugging; Performing services (for us or our service provider) such as account servicing, processing orders and payments, and analytics; Internal research for technological improvement; Internal operations; Activities to maintain and improve our services; and Other one-time uses	Affiliates

The Purpose of Collecting Your Personal Data

General

We collect, use and disclose personal data about you, which we collect through our Service for a number of reasons, including:

To administer and improve our websites, products, and services, including troubleshooting, data analysis, testing, research, statistical analysis, and survey purposes.
To allow you to participate in interactive features of our products and services (including casino products) and ensure their technical functionality and security.
To fulfill our contractual obligations to you, including setting up, managing, and administering your account (e.g., for identity verification, anti-money laundering, prevention of terrorist financing, self-exclusion requests, and processing bets and payments).
To notify you about changes to our products and services and, with your consent, to directly market them to you.
To send you relevant communications, such as confirmations, invoices, updates, security alerts, and administrative messages.
To inform you about promotions, rewards, upcoming events, and other news related to our products and services.
To measure and understand the effectiveness of our advertising and marketing efforts.
To identify and analyze user behavior, preferences, and credit risk (if applicable).
To ensure compliance with licensing and regulatory requirements and support anti-money laundering, prevention of terrorist financing, and disaster recovery efforts.
To handle payment and collection processes.
For customer service improvements, audits, and market research.
For other purposes with your consent.

Marketing

We may use your personal data to send you updates by email or by Facebook Messenger or iMessage about our services, including exclusive offers, promotions or new services.

This marketing may relate to:

products and services we (or permitted third parties) feel may interest you;
information about other goods and services we offer that are similar to those that you have already used or enquired about;
upcoming events, promotions and new products/services or other opportunities as well as those of selected third parties; and
information regarding any applicable loyalty programs (including points earned and free, bonus and promotional points).

If you no longer wish to receive marketing communications when using our apps, you may: contact us at support@loongrising365.com for direct marketing opt-out; orusing the “unsubscribe” link in emails, or let us know you intent to opt-out in our phone calls to you.

Cookies

A cookie is a small data file sent by a website to your computer that is stored on your hard drive when you visit certain online pages of our website.We use cookies to store users’ preferences, and collect aggregated demographic data. Cookies allow the website to identify and interact with your computer (for example so we can remember your login details if you have opted to ‘stay signed in’). We do not use cookies to retrieve information that was not originally sent by us to you in a cookie.

You can set your browser to accept or reject all cookies, or notify you when a cookie is sent. If you reject cookies or delete our cookies, you may still use our websites, but you may have reduced functionality and access to certain areas of our websites or your account. You may disable or accept cookies at any time by changing your web browser’s options.

In addition to the express notice provided on our website when you first visit, your continued use of our website is your acceptance of our continued use of cookies on our website.

Sharing Information

We may share your information with the following categories of recipients:

Related Entities

Your personal data will be used by us and disclosed to our group companies, including LOONG RISING LIMITED and all of its subsidiaries.

Selected Business Partners and Advertising Partners

Your personal data will be disclosed by us to our business partners and advertising partners who will use your data, amongst other things, to review and improve their products and services, to help them identify new products and services, for statistical analytical purposes and for the purpose of directly marketing their products and services to you, subject to you consenting to their private policies as presented in each of their websites.

Public Authorities/Regulatory Bodies/Industry Bodies

We may disclose your personal data:

to regulators and law enforcement agencies (including those responsible for enforcing anti-money laundering legislations);

in response to an enquiry from a government agency.

Service Providers

We may disclose your personal data to third party service providers (including our professional advisors, data analysis processors and data storage service providers) who require access to such information for the purpose of providing specific services to us. These third parties will generally only be able to access your data in order to provide us with their services and will not be able to use it for their own purposes.

Replacement Providers

If the management and operation of LOONG RISING and its affiliates are transferred from us to another company, we may disclose your personal data to the other company so the products and services can continue to be provided to you. In the event that we sell or buy any business assets, we may disclose your personal data to the prospective seller or buyer of such business or assets. If LOONG RISING or substantially all of its assets are acquired by a third party, personal data held by us about our customers will be one of the transferred assets.

Your Rights

You have several rights regarding the data we hold about you, which are explained below. If you want to exercise any of these rights, please contact us using the details in the “Contacting Us” section. We will aim to respond to your request as quickly as possible, and within one month (unless we are allowed more time). Please note that we may keep a record of your communication to help us address your concerns.

1) Data subject access requests

You may ask us for a copy of the information we hold about you at any time, and request us to modify, update or delete such information. If we provide you with access to the information we hold about you, we will not charge you for this unless permitted by law. If you request further copies of this information from us, we may charge you a reasonable administrative cost. Where we are legally permitted to do so, we may refuse your request. If we refuse your request we will always tell you the reasons for doing so.

2) Right to object

This right enables you to object to us processing your personal data where we do so for one of the following reasons:

because it is in our legitimate interests to do so (for further information please see section 11 below);
to enable us to perform a task in the public interest or exercise official authority;
to send you direct marketing materials; or
for scientific, historical, research, or statistical purposes.

2) Right to opt-out of targeted advertising

You have the right to opt-out of targeted advertising. This means you can choose not to receive targeted ads based on your interests. To do so, you can adjust your settings in our app or website, or follow the instructions provided in the ads you see. Opting out will stop us from using your information for personalized advertising, but you may still see general ads that are not based on your preferences.

3) Right to withdraw consent

Where we have obtained your consent to process your personal data for certain activities (for example, for marketing), you may withdraw this consent at any time and we will cease to use your data for that purpose unless we consider that there is an alternative legal basis to justify our continued processing of your data for this purpose, in which case we will inform you of this condition.

4) Right to erasure

You have the right to ask us to erase your personal data in certain situations, such as when:

The data is no longer needed;
You withdraw your consent, and we have no other reason to keep it;
The data was processed unlawfully;
We need to erase the data to follow the law; or
You object to the processing, and we have no valid reason to continue.

We can only refuse to erase your data in specific cases, and we will explain why. If your request is valid, we will take reasonable steps to erase the data.

5) Right to restrict processing

You have the right to request that we restrict our processing of your personal data in certain circumstances, for example if you dispute the accuracy of the personal data that we hold about you or you object to our processing of your personal data for our legitimate interests. If we have shared your personal data with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal data.

6) Right to rectification

You have the right to request that we rectify any inaccurate or incomplete personal data that we hold about you. If we have shared this personal data with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. You may also request details of the third parties that we have disclosed the inaccurate or incomplete personal data to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.

7) Right of data portability

If you wish, you have the right to transfer your personal data between service providers. In effect, this means that you are able to transfer the details we hold on you to another third party. To allow you to do so, we will provide you with your data in a commonly used machine-readable format so that you can transfer the data. Alternatively, we may directly transfer the data for you.

8) Right to complain

You have the right to complain to a data protection authority about our collection and use of your personal information.

California Privacy Rights

If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (“CCPA”), you have certain rights with respect to that information.

Disclosure of Personal Information We Collect About You

You have the right to know: The categories of personal information we have collected about you;The categories of sources from which the personal information is collected;Our business or commercial purpose for collecting or selling personal information;The categories of third parties with whom we share personal information, if any; andThe specific pieces of personal information we have collected about you.Please note that we are not required to;Retain any personal information about you that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered personal information; orProvide the personal information to you more than twice in a 12-month period.

Personal Information Sold or Used for a Business Purpose

In connection with any personal information we may sell or disclose to a third party for a business purpose, you have the right to know: The categories of personal information about you that we sold and the categories of third parties to whom the personal information was sold; and The categories of personal information that we disclosed about you for a business purpose. You have the right under the California Consumer Privacy Act of 2018 (CCPA) and certain other privacy and data protection laws, as applicable, to opt-out of the sale of your personal information. If you exercise your right to opt-out of the sale of your personal information, we will refrain from selling your personal information, unless you subsequently provide express authorization for the sale of your personal information. To opt-out of the sale of your personal information, you may contact us using the contact details under the “Contacting Us” heading below.

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will: Delete your personal information from our records; andDirect any service providers to delete your personal information from their records. Please note that we may not delete your personal information if it is necessary to: Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;Debug to identify and repair errors that impair existing intended functionality;Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;Comply with the California Electronic Communications Privacy Act;Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;Comply with an existing legal obligation; orOtherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Protection Against Discrimination

You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, among other things: Deny goods or services to you;Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;Provide a different level or quality of goods or services to you; orSuggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services. Please note that we may charge a different price or rate or provide a different level or quality of services to you, if that difference is reasonably related to the value provided to our business by your personal information.

How to Exercise Your Rights

If you would like to exercise any of your rights as described in this Privacy Policy, please contact us using the contact details under the “Contacting Us” heading below.

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

If you choose to contact us directly by email, you will need to provide us with:

Enough information to identify you [(e.g., your full name, address and customer or matter reference number)];
Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information, or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

Account Deletion

You have the right to delete the account which you have registered with us to access its products or services at any time. We will delete the account after verifying your identity information. To ensure the security of your account and property, you shall submit your account deletion request to us by clicking the account deletion option provided in the APP.

Unless otherwise stipulated by laws and regulations, after account deletion, we will delete all information related to your account, including personal information and game logs, thus you will be unable to normally use the products or services provided by us. After you complete the deletion, your account cannot be retrieved and your account data cannot be recovered. Please maintain your account information properly.

RETENTION

We will not keep your personal data for longer than is necessary for the purposes for which we have collected it, unless we believe that the law or other regulation requires us to keep it (for example, because of a request by a tax authority or in connection with any anticipated litigation) or if we require it to enforce our agreements.

In general, we will retain your personal data for as long as we provide services to you and your account is active and following that period, for as long as we provide you directly with any other service offering.

When it is no longer necessary to retain your personal data, we will delete the personal data that we hold about you from our systems. While we will endeavour to permanently erase your personal data once it reaches the end of its retention period, some of your personal data may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this data has been put beyond use, meaning that, while it still exists in the electronic ether, our employees will not have any access to it or use it again.

International Transfers of Data

The data that we collect from you will be transferred to, and stored at, destinations both within and outside the EEA. As mentioned above, we may disclose your personal data to our group companies and their service providers located in US and elsewhere, and to employees operating outside of the EEA who work for us or for one of our group companies or their respective service providers.

We want to make sure that your personal data is stored and transferred in a way which is secure. We will therefore only transfer data outside of the EEA where it is compliant with data protection legislation and the means of transfer provides adequate safeguards in relation to your data. We may transfer your personal data in the following ways:

through an intra-group agreement between LOONG RISING entities, using the European Commission’s standard clauses for data transfers to countries without adequate data protection laws.
through a data transfer agreement with a third party, also using the European Commission’s standard clauses.
By transferring your data to a company that is part of the EU-U.S. Privacy Shield Framework (or an equivalent agreement for other countries).
To a country that the European Commission has deemed to have adequate data protection laws.
If it’s necessary for a contract between us and a third party, and the transfer benefits you (e.g., to a provider outside the EEA).
If you have given us your consent for the transfer.

Where we transfer your personal data outside the EEA and where the country or territory in question does not maintain adequate data protection standards, we will take all reasonable steps to ensure that your data is treated securely and in accordance with this Privacy Policy.

Security

We will take all reasonable precautions necessary to protect your personal data from

loss, theft, misuse and interference;
unauthorised access, disclosure, use or modification.

Such measures will vary depending on the sensitivity, amount, format, nature and storage of the information and will involve, as applicable, physical, organizational and electronic security measures.

This includes, for example, the protection of passwords using industry standard encryption, measures to preserve system security and prevent unauthorised access and back-up systems to prevent accidental or malicious loss of data. We may use third party data storage providers to store personal data electronically. We take reasonable steps to ensure this information is held as securely as information stored on our own equipment.

Unfortunately, there is always risk involved in sending information through any channel over the internet. You send information over the internet entirely at your own risk. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted over the internet and we do not warrant the security of any information, including personal data, which you transmit to us over the internet.

Update of the Policy

We may update this Privacy Policy to reflect changes to our data and information privacy practices, so we encourage you to check this page periodically. We will try to notify you in advance where there are any significant or very important changes.

Contacting Us

Should you have any questions or concerns about this privacy policy or data processing, or intend to file a complaint about potential violations of local privacy laws, please contact us through the following method：support@loongrising365.com.