Sigma Game Privacy Policy

Effective 2/1/2011
Sigma Game Limited (“Sigma Game”, “us” or “we”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of information we receive from users of our application, included but not limited to BendKick, Dungeons and coins, Defender of diosa, Christmas and Coin, for handheld mobile devices (collectively, the “Application”). This Privacy Policy applies only to information that you provide to us or that we collect via the Application. Our Privacy Policy may be updated from time to time, and we will notify you of any material changes by posting the new Privacy Policy through the Application or on our company website.

1. Information Collection: The Information We Collect

‧ When you download and use the Application, we will not collect any information that identifies you personally.

‧ When you download and use the Application, we may collect certain non-personal data (“Non-Identifying Information”). The type of Non-Identifying Information Sigma Game collects includes, but is not limited to: (i) mobile device type, device identification code and device properties; (ii) geographical data; (iii) scores and achievements within the Application; and (iv) ads you click on within the Application.

‧ We may also permit our Advertising Display Partners (defined below under Section 3) to collect Non-Identifying Information about you while you are using the Application. Please visit our Advertising Display Partners’ websites to find their own privacy policies regarding their use of your Non-Identifying Information. Please note that some of our Advertising Display Partners may send targeted advertisements based on user behavior.

2. How We Use Your Information

‧ We use the information we collect: (i) to provide and improve our Application, services, features and content, (ii) to administer your use of our Application, (iii) to enable users to enjoy and easily navigate the Application, (iv) to better understand your needs and interests, and (v) to provide you with further information and offers from us or third parties which we believe you may find useful or interesting, including marketing or promotional materials and other information on services and products offered by us or third parties.

‧ We also use information we collect to monitor and analyze use of the Application and our services and for the Application’s technical administration, to increase our Application’s functionality and user-friendliness, and to generate and derive useful data and information concerning the interests, characteristics and website use behavior of our users.

3. Information Sharing and Disclosure

Advertising Display Partners. We will share your Non-Identifying Information with advertising service provider companies with whom we have relationships, including, but not limited to Admob, Tapjoy and Greystripe, Mopub, Inmobi, Mobfox, Tapit(collectively, “Advertising Display Partners”). Please visit our Advertising Display Partners’ websites to find their own privacy policies regarding their use of your Non-Identifying Information. As noted above, some of our Advertising Display Partners may send targeted advertisements based on user behavior.

Service Providers. We may engage third party companies and individuals to facilitate our Application, to provide the Application on our behalf, to perform Application-related services (including but not limited to maintenance services, database management, web analytics and improvement of the Application’s features) or to assist us in analyzing how our Application and service are used. These third parties have access to your information only for purposes of performing these tasks on our behalf.

Compliance with Laws and Law Enforcement. Sigma Game cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information we have about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Sigma Game or a third party, to protect the safety of the public or any person, or to prevent or stop any activity we may consider to be, or to pose a risk of being, illegal, unethical, inappropriate or legally actionable.

Business Transfers. Sigma Game may sell, transfer or otherwise share some or all of its assets, including your Non-Identifying Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

4. Terminating the Collection of Non-Identifying Information

All Application users may cease the collection of their Non-Identifying Information as described in this Privacy Policy by deleting the Application from the mobile device from which they access the Application.

5. Links to External Websites

Our Application contains links to external websites. If you choose to visit an advertiser by “clicking on” a banner ad or other type of advertisement, or click on another third party link, you will be directed to that third party’s website. The fact that we link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites follow different rules regarding the use or disclosure of the information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

6. Security

Sigma Game is very concerned with safeguarding your information. We employ reasonable measures designed to protect your information from unauthorized access.

7. Our Policy Toward Children

This Application is not directed to children under 13. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, he or she should contact us at [email protected] If we become aware that a child under 13 has provided us with personal information, we will delete such information from our files.

8. International Data Transfers
Your personal information may be transferred to, and processed in, countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.
Specifically, our Game servers are currently located in United States, and our group companies and third party service providers and partners operate around the world. This means that when we collect your personal information we may process it in any of these countries. However, we ensure appropriate safeguards are in place so that your personal information will remain protected in accordance with this Privacy Notice. These include implementing the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and third party service providers and partners, which require all group companies to protect personal information they process from the EEA in accordance with European Union data protection law. It also includes transferring personal information to third party service providers and partners which are certified under the EU-US Privacy Shield.
Standard Contractual Clauses can be provided on request. We have implemented similar appropriate safeguards with our third party service providers and partners and further details can be provided upon request.

9. Date Retention
We retain personal information we collect from you where we have an ongoing legitimate business need to do so, for example, to provide you with a Service you have requested or to comply with applicable legal, tax or accounting requirements. We will for example periodically de-identify unused Game accounts and we regularly review and de-identify unnecessary personal information.
When we have no ongoing legitimate business need to process your personal information, we will either erase or de-identify it or, if this is not possible - for example, because your personal information has been stored in backup archives - then we will securely store your personal information and isolate it from any further processing until erasure is possible.

10. Your Data Protection Rights
You have the following data protection rights:
(a) To access correct, update or request deletion of your personal information. You may do so by contacting us using the details at "Contact Us" heading below.
(b) To object to processing of your personal information (which is processed on the grounds of legitimate interests), ask us to restrict processing of your personal information or request portability of your personal information. Again you may do so by opting out of personalised offers based on behaviour in-game, or by contacting us using the details at "Contact Us" heading below.
(c) To opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe / opt-out” link in the marketing communications we send you or by contacting us using the details at "Contact Us" heading below.
(d) If we are processing your personal information with your consent, you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent. You may do so by contacting us using the details at "Contact Us" heading below.
(e) You have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.
You can control and limit the nature of personal information that we collect and process about you in a number of ways. For example, you can disconnect your social media account from our games or control your social media privacy settings to limit the information shared with us. You could also reset your mobile advertising identifier or limit ad tracking altogether using the settings on your phone. You could also limit or disable the use of cookies (or similar technologies).
We will respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.

12. Updates to this Privacy Policy
We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make.

11. Contacting Us

If you have any questions about this Privacy Policy, please contact us at [email protected] or at:

Sigma Game Attn: Privacy Unit 306B, 3/F, InnoCentre, 72 Tat Chee Avenue, Kowloon Tong, Kowllon, Hong Kong SAR