ELSIAVERSE LLC (collectively the "Company", "we", "us", and "our"), takes the protection of our users' personal information collected through our products, services, and websites accessed through gaming consoles, personal computers, mobile devices, and in-game applications or software platforms including third-party hosts (collectively the “Gaming and Online Services“) and privacy of our users very seriously. Our Privacy Policy explains what personal data we may collect about you when you use or access our Gaming and Online Services and how we collect, store, disclose, transfer, protect, and otherwise process that information for the purposes of operating and providing our Gaming Services.

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Please be sure to read this Privacy Policy carefully and fully understand the contents of the terms, including but not limited to the terms that exempt or limit our liability. By accepting its terms, you agree to our processing of your personal data in accordance with the terms of this Privacy Policy. We may also transfer, process, and store your account information in other countries that may have different privacy protections 

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We reserve the right to make changes to this Privacy Policy in order to reflect any changes in data protection laws or our internal policies. We will notify you of such changes and if necessary, will give you additional choices regarding such changes. However, in accepting these terms, you hereby undertake to regularly check for an updated version of this document at www.sulaboxgames.com for as long as you use our Gaming and Online Services. As far as permitted by applicable law, your continued use of our Gaming and Online Services will signify your acceptance of these changes in the Privacy Policy.

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This Privacy Policy will explain the following:

1. Who this Privacy Policy applies to

2. How we collect and use our users' personal information

3. How we store your personal information

4. How we use cookies

5. How we share, transfer and publicly disclose your personal information

6. How third-party products or services obtain your personal information

7. Your rights as a data subject

8. How we handle the personal information of minors

9. Potential updates to this Privacy Policy

10. How to contact us

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1. Who this Privacy Policy applies to

This Privacy Policy applies to all users of our Gaming and Online Services

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2. How we collect and use our users' personal information

Our users' personal data will be collected when users:

• Access and use our websites

• Purchase a product or service through our website or online stores

• Purchase downloadable content, virtual items, or virtual currency for use with our software and/or Gaming and Online Services

• Register for Gaming and Online Services, products, and special events

• Subscribe to newsletters or alerts

• Request technical support

• Download demos, programs, or other software

• Participate in polls, surveys, and questionnaires

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The information collected in connection with the activities listed above will vary depending on the activity. The information we collect may include personal data such as your first and/or last name, e-mail address, phone number, photo, mailing address, post code, location, payment information, age, gender, date of birth, hardware configuration, console ID, software products played, survey data, purchases, IP address and the systems you have played on. We may combine the information with your personal data and across other devices that you may use to access our products and services. 

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Additionally, we use third-party service providers as our official online re-sellers and for certain in-game sales functions, so please check the terms and policies at point of sale. Other third-party service providers may be connected to other in-game sales functions so please review the Terms & Conditions of each product for more details. As indicated at the point of purchase, such transactions are between you and the third-party service provider and they are subject to the third-party service provider’s privacy policy and terms of service. For the avoidance of doubt, the terms of this Privacy Policy shall continue to apply, to the extent applicable, as between you and the Company.

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We will use the personal information collected in accordance with the terms of this Privacy Policy and for the purpose of realizing our services. This includes, but is not limited to:

• Providing you with access to our products and services

• Fulfilling product orders

• Responding to questions, comments or technical problems

• Market research and demographic studies

• Sending you promotional materials

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We will collect statistics on the usage of the services we provide and may share this statistical information with the public or third parties for the purposes of product development, service optimization, and security assurance. However, these statistics do not contain any identifying information about our users. 

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When we want to use your personal information for other purposes not specified in this Privacy Policy, we will ask you in advance by asking for your consent. Please note that all personal information you provide when you use our services will continue to be used by us during your use of our services unless you delete it or refuse us to collect it through system settings. When you cancel your account, we will stop using your personal information and delete it.

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3. How we store and protect your personal information

We will keep your personal information within the shortest retention period required by the purposes stated in this Privacy Policy and required by laws and regulations. After the aforementioned period expires, we will delete or anonymize your personal information. To protect your personal data, we follow generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity, and privacy of the information you have provided. We have security measures in place designed to protect against the loss, misuse, and alteration of the information under our control. Personal data collected by us is stored in secure operating environments that are not available to the public. However, no Internet environment is 100% secure and, to the fullest extent permitted under applicable law, we assume no liability for unauthorized access to your information. In addition, you are responsible for maintaining the strength and confidentiality of your login credentials.

 

Notwithstanding the foregoing, we will notify you as soon as reasonably practicable if we have reason to believe that there has been a personal data breach by us. In the event of an unfortunate personal information security incident, we will promptly inform you in accordance with the requirements of laws and regulations: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, and how you can prevent or reduce the risk on your own. Advice on risks, remedies for you, etc. will promptly be sent to you, detailing relevant information of the event by means of app push, email, text message, phone call, etc. When it is difficult to inform affected users one by one, we will take a reasonable and effective way to publish an announcement. At the same time, we will also proactively report the handling of personal information security incidents in accordance with the requirements of regulatory authorities.

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4. How we use cookies

By using cookies, we provide users with a safe and personalized service experience. We and third-party partners store cookies, Flash cookies, or other local storage provided by your browser (or associated application) on your computer or mobile device that typically includes identifiers, site names, and some numbers and characters (collectively "Cookies"). We and our third-party partners may collect your information through Cookies and use the information for the following purposes:

• Security Cookies: Cookies can help us ensure the safe and efficient operation of our products and services.

• Recommendation Cookies: Cookies can help us recommend and display content that may be of interest to you.

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The collection and use of your information by third-party partners through Cookies is not bound by this Privacy Policy, but by their own information protection statements, and we are not responsible for third-party cookies or similar technologies.

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General and additional information regarding Cookies can be found at https://allaboutcookies.org/. 

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5. How we share, transfer and publicly disclose your personal information

We may entrust third-party service providers to process the personal information we have collected so that they can provide us with products or technical support such as infrastructure technology, data analysis, advertisement placement, and marketing decisions. The aforementioned entrusted processing is subject to the purposes stated in this Privacy Policy, and we will contractually supervise the aforementioned entrusted third-party service providers.

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Please note that according to relevant laws and national standards, we may share, transfer, and publicly disclose personal information in the following situations:

• Those related to obligations stipulated by laws and regulations

• Those directly related to national security, public safety, public health, and major public interests

• Those directly related to criminal investigation, prosecution, trial and execution of judgments

• When personal information is disclosed by the subject in question or guardian to the public on their own

• Collecting personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels

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6. How third-party products or services obtain your personal information

Certain Gaming and Online Services offered by the Company use third-party services to provide authentication for our Gaming and Online Services; or associate a Company service account with a third-party account, such as a Gaming Console ID, Gaming Network Service account, or Social Network Service account. When you use a third-party authentication service or link your Company account with a third-party account, you will be asked to provide account information associated with that third-party account. Certain membership information may be transferred automatically to the Company when you register to join a Gaming or Online Service from a third-party gaming network system or link your Gaming and Online Service membership with a third-party service.
 

7. Your rights as a data subject

During your use of our Gaming and Online Services, you may have the following rights in relation to the personal data we hold about you:

• The right to request a copy of your personal data held by us

• The right to correct any inaccurate or incomplete personal data held by us

• The right to request that we delete your personal data

• The right to request that we restrict the processing of your data

• The right to have your personal data transferred to another organization;

• The right to object to certain types of processing of your personal data by us

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In order to make an inquiry about any of these rights, please email us at sia@sulaboxgames.com or contact us via our website.

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8. How we handle the personal information of minors

We attach great importance to the protection of minors' personal information. According to relevant laws and regulations, the collection and use of the personal information of minors under the age of 14 requires the authorization and consent of a parent or guardian; the collection and use of the personal information of minors over the age of 14 but under the age of 18 can be authorized and consented by the parent or guardian, or the minor.

If you are a minor (especially a minor under the age of 14), we require you to ask your parent or guardian to read this Privacy Policy carefully, and use our services with the authorization and consent of your parent or guardian. If you are the parent or guardian of a minor, please pay attention to whether the minor under your guardianship is using our products or services with your authorization and consent. If you have questions about the personal information of the minor under your guardianship, please contact us through the methods set out in this Privacy Policy.
 

9. Potential updates to this Privacy Policy
Our Privacy Policy may change from time to time. We will post any changes to this Privacy Policy on this page. For major changes, we will also provide a more prominent notice (we may explain the specific changes to our Privacy Policy by means of special prompts on the main page). We will not reduce your rights under this Privacy Policy without your express consent.

The major changes referred to in this Privacy Policy include, but are not limited to: major changes in our service model; changes in the main objects of personal information sharing, transfer or public disclosure; major changes in your rights to participate in the processing of personal information and the manner in which it is conducted; changes in our contact information; and when the personal information security impact assessment report indicates that there is a high risk. We will also archive older versions of this Privacy Policy for your review.
 
10. How to contact us

If you have any questions about this Privacy Policy or personal information protection, you can send your questions, comments or suggestions to sia@sulaboxgames.com.