Honor of Kings

Privacy Policy

Last Updated: July 25, 2022

Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Here is a summary of the information contained in this privacy policy (“Privacy Policy”). This summary is to help you navigate the Privacy Policy and it is not a substitute for reading everything! You can use the hyperlinks below to jump directly to particular sections.

 

What information do we need to provide the CBT?

If you register an account to use the CBT then we will need some information from you to set this up. If you choose to set up your profile using a social media account, we also collect information, including name and user ID from that social media account. We will also collect information for analytics purposes, to send you push notifications, and to ensure the security of the CBT. If you need to get in touch with us, we will retain some information so that we can get back in touch with you and address any concerns. More Information.

How will we use your information?

If you participate in the CBT we will use your information to provide the many functions that comprise the CBT. We also use your information for account verification, security purposes and to support and improve the CBT. We do not share your information with any third parties, except where we need to in order to provide the CBT (e.g., use local cloud providers or to back up your data; use our affiliates around the world to help us to deliver the CBT) or monitor the success of our marketing and advertising programs, or where we are instructed to by a court, authority or compelled by law. More Information.

Who do we share your information with?

We use some third parties to help us deliver the best possible experience (e.g., cloud services to back up your data and support services). When we use a third party, we only do this to process or store your information for the purposes described in this Privacy Policy. We also have affiliates around the world who help us deliver the CBT and we may be required by a court or legal obligation to disclose certain information in some circumstances. More Information.

Where do we process your information?

Our servers are located in Singapore. Your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including Singapore and the People’s Republic of China. More Information.

How long do we keep hold of your information?

We generally retain your information for the period during which you maintain an account for the CBT, after which time your data is deleted (as further described in this Privacy Policy), unless otherwise required by applicable laws. More Information.

How can I exercise my rights over my information?

Depending on where you are, you may have certain rights with respect to your information, such as rights of access, to receive a copy of your data, or to delete your data or restrict or object to our processing of your data. More Information.

How to get in touch with us

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, please contact us here.

How will we notify you of changes?

Changes to this Privacy Policy will be posted here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy. More Information.

Contact Information

Data Controller: Proxima Beta Pte. Limited | Email: dpo_hok@proximabeta.com

Turkey Data Controller Representative: Özdağıstanli Ekici Avukatlık Ortaklığı. Email: turkeydatarep_proximabeta@iptech-legal.com (Özdağıstanli Ekici Avukatlık Ortaklığı is our data controller representative and its authority is limited to the authorities stipulated under the Law on Protection of Personal Data w. no 6698. Özdağıstanli Ekici Avukatlık Ortaklığı is not authorised for any other matters such as in-CBT conduct, bans, investigations, civil or criminal complaints.

 

 


Welcome to the Honor of Kings Closed Beta Test!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with the Honor of Kings Closed Beta Test and its website(the “CBT”), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the CBT. By using the CBT you are acknowledging our rules regarding your personal information as described in this Privacy Policy.

 

For the purpose of data protection laws, the data controller of your personal information in relation to the CBT is Proxima Beta Pte. Limited (“we”, “us”, “our”). The registered address of Proxima Beta Pte. Limited is 10 Anson Road #21-07 International Plaza, Singapore. 

Our data protection officer can be contacted at dpo_hok@proximabeta.com.

Our representative for data protection purposes in certain jurisdictions is as follows:

Jurisdiction

Representative

Address

Contact details

Turkey

Özdağıstanli Ekici Avukatlık Ortaklığı.

Varyap Meridian Grand Tower ABlok Al Zambak Sok No: 2 K: 32 D. 270 Ataşehir Istanbul Turkey

turkeydatarep_proximabeta@iptech-legal.com

 

Please reach out to us if you have any questions or concerns regarding the processing of your personal information. You can contact us anytime at dpo_hok@proximabeta.com.

 

1.                 The Types of Personal Information We Use

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled How We Use Your Personal Information” below.

The following is a high-level summary of the types of personal information we use:

1. Information you provide to us (either directly or through a third party) 

2. Information about you generated as part of the CBT

 

We automatically collect certain data from you when you use the CBT, namely:

 

 

 

2.                 Cookies

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience using the Honor of Kings website. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities.

For more information about our Cookies policy, click here.

 

3.                 Children

Children must not use the CBT for any purpose, except where their parent or guardian has provided consent (to the extent this option is available in your jurisdiction).

By children, we mean users under the age of 18 years old; or in the case of a region where the minimum age for processing personal information differs, such different age. For users located in certain regions we have listed the relevant minimum age in the table below.

Region in which the user is located

Minimum age of the user

Brazil

18

Egypt

18

Mexico

18

Turkey

18


We do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without parental/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at dpo_hok@proximabeta.com and we will delete such information.

 

4.                 How We Use Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why. For users who live in Brazil (“Relevant Jurisdiction”), it also identifies the legal basis under which we process your data.

Personal Information

Use

Legal Basis (only relevant if you are located in a Relevant Jurisdiction)

Information you provide to us (either directly or through a third party) 

Account Creation (guest log-in): nickname, guest ID

We use this information to create your account for the CBT in accordance with your request.

Necessary to perform our contract with you to provide the CBT.

Account Creation (if you choose to log in via your social media account):

  • Facebook: Name, Facebook ID, profile picture, user token, OpenID
  • Google Play: User ID, nicknames, profile picture, user token, OpenID
  • Twitter: User ID, nickname, profile picture, user token, OpenID

If you create and log in via your social media account, your social media profile picture will be set as your CBT profile picture by default. You can elect to change your default profile picture to other options in the CBT.

We use this information to create your account for the CBT in accordance with your request.

We will use your social media account profile picture as your default profile picture in the CBT.

Necessary to perform our contract with you to provide the CBT.

Compliance Data: OpenID, token, region, user name

We use this information to verify your eligibility to participate in the CBT.

Legitimate interest to ensure compliance with applicable age-gating rules.

Customer Support: name, OpenID, device ID, email address (if contacted via email), details of ticket, complaint and handling, content of correspondence, game data and details of gameplay under review, IP address

We use this information to improve our services and provide troubleshooting, such as addressing and remediating technical issues and bugs.

Necessary to perform our contract with you to provide and support the CBT.

Survey Information: User and contact information (age, gender, email, address, mobile number, select geographic location (country)), device information (phone model, device configuration preference), game information (game habits and preferences (including recently played games, game duration and favourite game categories and experience, language preference), and other content of survey responses user may choose to provide

If you choose to participate in an in-game survey via IMUR, we will only receive an aggregated report of the above data 

If you choose to participate in a survey via a channel other than IMUR, we will retain your survey response for 30 days 

Email address

We use the survey information to allow you to participate in surveys about the CBT to improve the CBT.

We may use your email address to invite you to participate in surveys after the CBT send you marketing information after the CBT, if we have obtained your consent to do so.

Consent.

Information generated as part of the CBT

Account Creation & Authentication: IP address, OpenID, system time

 

We use this information to create your account for the CBT in accordance with your request, and authenticate your log in.

Necessary to perform our contract with you to provide you with customised gender-specific CBT features.

Game Data: OpenID, IP address (only kept in aggregated format for server improvement), device model, game play statistics (e.g. level, heroes, scores)

We use this information to allow you to play the CBT.

Necessary to perform our contract with you to provide the CBT.

Geographic Matchmaking (optional): GPS information (approximate distance, but no exact location shown)

If you choose to use this feature, We use this information to allow you to connect with users nearby your location. Your and users’ exact location GPS information is not shared with other users.

Necessary to perform our contract with you to allow you to connect with users nearby.

Analytics, Crash Reporting & Performance: 

  • User Region: country, province, city, carrier id, region, IP address
  • Device Information: application version, application ID, battery information, WiFi strength, available space, network type, OS version, OS name, carrier, country code,  device language, device resolution, brand, manufacturer, device model, RAM, ROM and CPU information, GPU information, Google advertising ID, Game Frame information, mobile signal strength, network round trip time, network bytes received/sent, login/pay step event information, XWID

We use this information to perform general and game data analytics, including for the purposes of track which advertisements have been successful for future campaigns and for payment to advertising partners (such analytics also includes reviewing game performance and payments) and for the purposes of error-fixing, troubleshooting and debugging.

It is in our legitimate interest to carry out data analytics to track which advertisements have been successful for future campaigns and for payment to advertising partners, and for the purposes of solving game crashes.

Push Notifications (Firebase):

  • Device information: Device model, device name, device manufacturer, running process information
  • Other:  SDK version, application package name, application version, operator name, network type

We use this information to send you push notifications in the CBT.

Necessary to perform our contract with you to provide  the CBT.

Payment Information (Midas in-app purchases - only via Google Play and App store): OpenID, product cost, product purchased, IP address, device information (OS version, phone model, device root status) and details of transactions linked to player ID

We use this information to process your payments in the CBT.

Necessary to perform our contract with you to process your payments in the CBT.

Service Information & Connection Management Data:  OpenID, device name, device model, login channel ID

We use this information to allow game servers to communicate.

Necessary to perform our contract with you to provide the CBT.

Game Update & SDK Data: OpenID, device information (device name and model, login channel ID)

We use this information to detect and download version updates and manage integrated SDKs.

Necessary to perform our contract with you to allow you to play the latest version of the CBT and use all functions of the CBT.

Text Chat Data

 

We use this information to facilitate the posting of your communications with other users.

Necessary to perform our contract with you to facilitate the posting of your communications with other users.

Voice Chat Data (real-time voice): OpenID, device information (device name, device model, client exports IP, device brand, UUID, system time), SDK version IP address, network type, OpenID, model

Please note voice chat contents data is only stored on your device, and is not processed by our servers

We use this information to facilitate the posting of your communications with other users.

Necessary to perform our contract with you to facilitate the posting of your communications with other users.

Voice Chat Data (non-real time voice messages): OpenID, device information (device name, device model, client exports IP, device brand, UUID, system time), SDK version IP address, network type, OpenID, model, voice file, report data

We use this information to facilitate the posting of your communications with other users.

Necessary to perform our contract with you to facilitate the posting of your communications with other users.

Anti-Cheat Data: Android: OS version, manufacturer, CPU, country code and language, root/simulator status, APK data, process data, SD card cache, APK name and version, start time, SD card target file, host file, screenshots of gameplay (if you are suspected of cheating behaviour), sensor data, critical system library data, Open ID

We use this information to ensure the security of the CBT.

It is in our legitimate interest to ensure the security of the CBT.

Gift Data: IP address, device model platform data (including device ID, username, token, phone and email), game play statistics, task completion status, game account credits, user gift pack collection record, gift pack distribution status, activity points, identity information (Open ID, role ID), eligibility for gift package distribution, package contents

We use this information to facilitate gift delivery.

Necessary to perform our contract with you to facilitate the distribution of gifts.

Data analytics / profiling (Appsflyer):

  • Technical information: browser, device, CPU, language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier
  • Technical identifiers: IP address, user agent; Google Advertising ID, Open ID
  • Engagement information: ad clicks/impressions, audiences or segments to which an ad campaign is attributed, the type of ads and the webpage or application from which such ads were displayed, URL from the referring website, downloads and installations

We use this information for ad attribution purposes.

It is in our legitimate interest to carry out data analytics and profiling for ad attribution purposes to understand how our users interact with advertisements.

Data analytics / profiling (Firebase): device data (OS, model, app store, app version), event data (session duration, geography, open/launch/update, purchase,, country,  interests, language, new/established, ad clicks and impressions), analytics data (usage, clearance, crashes, removal, payment)

We use this information for user acquisition purposes and to monitor the effectiveness of our advertisements.

 

Legitimate interest to allow us to acquire users and to monitor the effectiveness of our advertisements.

 

Data analytics (Facebook):

  • Event Data: information shared by the user about people and the actions that they take on the relevant website, app or shop

We use this information for user acquisition purposes and to monitor the effectiveness of our advertisements.

We also use the aggregated and anonymised data for analytics purposes.

It is in our legitimate interest for us to monitor the effectiveness of our campaigns.

 

Bug fixing and analysis: UUID and Android ID

We use this information to determine which devices commonly encounter bugs and crashes.

It is in our legitimate interest to monitor, analyse and fix bugs.

 

5.                 How We Store and Share Your Personal Information

Our corporate group operates around the world. Pursuant to our contract with you to provide you with the CBT, your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this Privacy Policy. Our servers for the CBT are located in Singapore.

In addition, your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including Singapore and the People’s Republic of China.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

 

6.                 The Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the CBT or otherwise via the Internet; any transmission is at your own risk.

 

7.                 Data Retention

We do not keep your data for longer than is necessary unless we are required to do so under law. For further details on how long we keep your data, please refer to the time periods set out below.                                          

Personal Information

Retention Policy

Account Creation, Game Data, Analytics Crash Reporting & Performance, Push Notifications (Firebase), Payment, Information, Data Analytics (Appsflyer, Firebase, Facebook), Geographic Matchmaking, Service Information & Connection Management Data, Game Update & SDK Data, Text Chat Data, Bug Fixing and Analysis Data

Stored for the lifetime of your use of the CBT (i.e. until account deletion in accordance with your request) and then for 30 days.

Compliance Data

1 year after the CBT is shut down.

Voice Chat Data (real-time voice)

Voice Chat Data (non-real time voice messages)

Real-time voice chat will not be stored. Other information: stored for one month.

Voice files will be retained for seven days. All other information: 1 month.

Anti-Cheat Data

90 days or until account deletion in accordance with your request and then for 30 days.

Any screenshots taken will only be retained for seven days.

Gift Data

Within 6 months after end of an activity.

Survey Information (Email)

Email collected for marketing information: retained for 1 year after the end of CBT.

Email collected to carry out surveys after the CBT: 30 days.

 

Survey information (IMUR)

Any aggregated survey responses collected via IMUR will be retained for one year,

Survey Information (non-IMUR)

30 days.

Customer Support information

3 months or within 7 days of a deletion request.

 

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information.

 

8.                 Your Rights

Some jurisdictions’ laws grant specific rights to users of the CBT, which are set out in this section.

This section entitled “Your Rights” applies to users that are located in Brazil. If you are located in a territory outside Brazil, please refer to the Supplemental Jurisdiction-Specific Terms for an overview of your rights and how these can be exercised.

The sub-section entitled “Advertising” also applies to users that are located in Brazil, Egypt, Mexico and Turkey.

You have certain rights in relation to the personal information we hold about you, depending on where you are located. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at dpo_hok@proximabeta.com.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by contacting us at dpo_hok@proximabeta.com.

Portability

You have the right to receive a copy of certain personal information we process about you. This comprises any 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 the section “How We Use Your Personal Information”. You have the right to receive this information in a structured, commonly used and machine-readable format. You also have the right to request that we transfer that personal information to another party, with certain exceptions. We will provide further information to you about this if you make such a request.

If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with another’s rights (for example, where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).

Correction

You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by contacting us at dpo_hok@proximabeta.com.

Erasure

You can delete your account, or remove certain personal information, by contacting us at dpo_hok@proximabeta.com.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the CBT and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only

You have a right to require us to 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). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You have the right to object to our processing of your personal information. We will consider your request in other circumstances as detailed below by contacting us at dpo_hok@proximabeta.com.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us at dpo_hok@proximabeta.com. 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.

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 the CBT for maintenance, or security, privacy or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.

Advertising

We will only send marketing messages to you if we have your consent. You may choose to stop receiving marketing messages from us by using the unsubscribe option in the message or contact us at dpo_hok@proximabeta.com.

 

9.                 Contact & Complaints

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to dpo_hok@proximabeta.com.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at dpo_hok@proximabeta.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the region in which you live or work where you think we have infringed data protection laws.

 

10.             Changes

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy.

 

11.             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.

 


SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the CBT, which are set out in this section.

If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.

Brazil

Whenever we use your personal information based on your consent, you may revoke the consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account or you can contact us as set out in Section 9 (Contact). This may affect our provision of the CBT to you.

 

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORISE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

Egypt

By clicking “accept” or by proceeding with the sign up process, you acknowledge that you have read, understood, and consented to this Privacy Policy. You are acknowledging your consent to the processing, storage, and cross-border transfer of your personal data. The cross border transfer may be to any country in which we have databases or affiliates, in particular to the jurisdictions specified in Section 5 (How We Store and Share Your Personal Information).

 

You also acknowledge your consent to receiving marketing messages from us, whether through e-mails or pop-ups or other such means.

 

If you are a new user, you have seven days to inform us of any objection you may have to this Privacy Policy.

 

As an Egyptian data subject, you have certain rights under the Egyptian Personal Data Protection Law.

 

Mexico

Some of the purposes of processing specified in Section 4 (How We Process Your Personal Information) are voluntary, which may include to show you personalised recommendations or advertising. We may also use your personal data for the voluntary purpose of sending information to your email or via SMS that we may consider relevant to you.

In general, we do not require your consent to carry out the transfers detailed in Section 5 (How We Store and Share Your Personal Information). In any case, by using the CBT and providing us with your personal data, you agree to the data transfers detailed therein that require your consent.

To understand more about and exercise your rights, as well as the applicable means, procedures and requirements to exercise any of your rights as specified in Section 9 (Contact).

You can register with the Public Registry to Avoid Advertising (‘REPEP’) (REPEP (profeco.gob.mx) ) to refuse to receive advertising to your phone number.

Turkey

Our Data Controller Representative in Turkey for the purpose of compliance with Turkish Law on Personal Data Protection Law (“DPL”) and its secondary regulations, Özdağıstanli Ekici Avukatlık Ortaklığı, can be contacted at turkeydatarep_proximabeta@iptech-legal.com. Please include the word “Turkey” in the subject line of your email.

You have legal rights, which are set forth in Article 11 of the DPL, in relation to the personal information data we hold about you. As a Turkish data subject, you may have the right to apply to the data controller and (to the extent permitted under applicable laws and regulations):

 

 

In accordance with Article 9 of the DPL, your personal data may be transferred abroad as follows:

 

Identity of the overseas recipient

Location of the recipient (or as otherwise stated in the recipient’s privacy policy)

Purposes of use of Personal Information by the recipient

Items of Personal Information to be provided

AppsFlyer

United States

For ad attribution purposes.

Technical information: browser, device, CPU, language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier

Technical identifiers: IP address, user agent; Google Advertising ID, Open ID

Engagement information: ad clicks/impressions, audiences or segments to which an ad campaign is attributed, the type of ads and the webpage or application from which such ads were displayed, URL from the referring website, downloads and installations

Firebase

United States

For user acquisition purposes and to monitor the effectiveness of our advertisements.

Device information: Device model, device name, device manufacturer, running process information

Other:  SDK version, application package name, application version, operator name, network type

Facebook

United States

For user acquisition purposes and to monitor the effectiveness of our advertisements.

We also use the aggregated and anonymised data for analytics purposes.

Event Data: information shared by the user about people and the actions that they take on the relevant website, app or shop