Privacy Policy
1. Introduction
This Privacy Policy (“Privacy Policy”) describes how MartialTales Limited (“MartialTales Ltd.,” “we,” “us,” or “our”) collects, uses, and shares information about you.
This Privacy Policy applies to your use of our (mobile/online) novel platform (the “Platform”), content, and all services related to MartialTales (collectively, the “Services”).
Please note that our Terms of Service apply in connection with this Privacy Policy. By accessing and using our Services, you will be deemed to have agreed to this Privacy Policy. Please take a moment to read this Privacy Policy before you start using our Services.
If you do not agree to this Privacy Policy, you should immediately stop accessing or using our Services.
If you are a resident of the EU/EEA, please review the Privacy Policy addendum applicable to the GDPR. If you are a resident of California, USA, please review the Privacy Policy addendum applicable to the CCPA.
2. How Do We Obtain Information from You?
We and our service providers (as defined below) may collect your information directly through the Services. For example, we collect information when you engage in the following activities (depending on the country where the Services are provided, the personal information collected and the methods of collection may differ slightly):
Creating an account on the APP;
Registering or linking an existing MartialTales account with a social network service (“SNS”) (such as Google);
Accessing our Services;
Participating in any type of activity we organize through the Services;
Participating in any type of survey we organize through the Services;
Contacting us through the methods we provide.
3. What Is Personal Information?
“Personal Information” means any information that identifies, relates to, or could reasonably be associated with you.
4. What Personal Information Do We Collect?
A. Information You Provide
When you create a MartialTales account, you provide us with Personal Information such as a nickname and email address.
B. Information Collected Automatically
When you access or use our APP, we may automatically collect certain information about you (“Usage Information”). Usage Information may include operating system (OS), device model, country information, browser information, IP address, and other information about your use of the Services. Various tracking methods may be included in our Platform and third-party platforms, primarily through advertising SDKs. These are not browser-based and cannot be controlled through browser settings. Some use device identifiers or other identifiers (such as “Advertising ID”) to associate APP user activity with a specific APP and to track user activity across APPs.
C. Information from Other Sources
We may obtain information about you from other sources (where permitted by law), including service providers and third-party services, and combine such information with information we collect directly and/or automatically. When you register or link an existing account using an account from a third-party service provider (such as Apple) or an SNS (such as Google), the following information may be transmitted to us: the name of the third-party service provider or SNS, user ID, and email address.
D. De-identified Personal Information
Once Personal Information has been “de-identified,” it will no longer be subject to this Privacy Policy, and we and our support companies (as defined below) may treat it as non-personal information and use it as permitted by law, unless prohibited by applicable law.
E. Personal Information Obtained via Third-Party SDKs; Related Privacy Policies:
1) Pangle SDK: https://www.pangleglobal.com/zh/integration/app-privacy-details-gp ; https://www.pangleglobal.com/privacy/partner-en
2) Google SDK: https://policies.google.com/technologies/partner-sites
5. How Do We Process Personal Information?
We collect, use, process, share, and/or disclose your information for the following purposes:
To provide the Services under our contractual relationship with you; to provide, operate, and maintain our Platform and Services;
To verify, operate, and process user identity for membership services, including your MartialTales account;
To help you or your device register for our Services;
To verify, operate, and process your purchases, transactions, and refunds;
To operate our Platform and analyze your activity;
To provide customized Services;
To suggest and operate promotions and campaign activities;
To troubleshoot any issues;
To monitor and analyze in order to improve Service performance and quality;
To enhance the confidentiality, integrity, and availability of security;
To develop and improve the operating environment for better Services;
To allow you to manage your MartialTales account;
and/or
To perform other activities necessary to provide the Services; to enforce our Terms of Service, Privacy Policy (including related addenda), and other agreements with third parties; to detect, prevent, investigate, and report violations, unauthorized use and/or abuse of the Services, breaches of other agreements, and/or suspected illegal activities;
To resolve any issues and claims relating to you (including but not limited to collecting/reviewing documents, obtaining legal advice, and conducting dispute resolution);
To store dispute resolution records; to protect the rights, privacy, safety, and property of us and our service providers;
and/or
To enforce other policies and agreements; to comply with legal requirements; to comply with or conform to any rules, laws, regulations, and/or requirements applicable to us, and guidelines issued by any legal or regulatory authority to which we, our service providers, or you are legally subject;
To support criminal investigations pursuant to subpoenas, court orders, or legal process;
To support requests from governmental and/or investigative authorities within and outside the country where you reside; to provide customer service; to support customer inquiries and complaints made by you or on your behalf, and to carry out your instructions;
To notify you of administrative and other important information about the Services when necessary, and to contact you when necessary;
and/or
To provide you with other customer support and services; to promote Services, activities, and products; to send communications for various promotional and marketing purposes;
and/or
To provide targeted marketing and promotional offers;
We may process your information for additional purposes based on the following:
Disclosing additional purposes to you before collecting the information;
and/or
Your consent to the collection/use/processing/disclosure for such additional purposes.
6. When and with Whom Is Personal Information Shared and Provided?
In principle, we do not share your Personal Information with external parties. However, in the following circumstances, we may share and provide your Personal Information with agents, vendors, and advisors of “MartialTales Ltd.” (“Support Companies”) and companies that provide services for “MartialTales Ltd.” (“Service Providers”):
With your consent
When we obtain your consent to this Privacy Policy from you, or pursuant to your instructions, we may share your information with external parties.
For the following processes, we share your Personal Information with Service Providers (and affiliates):
Billing and payment processes;
Charging and payment processes;
Data storage and development;
and/or
Administrative services and other third-party services necessary to provide the Services. On our behalf, our affiliates, group companies, and/or subsidiaries may share Personal Information with you for the following processes:
Personalized content and experiences;
and/or
Providing promotions and campaigns for our products and Services or those of third parties. Sharing with law enforcement agencies and appropriate third parties for legal reasons; investigating criminals, fraud, intellectual property infringement, or other suspected illegal activities, or as required by applicable law, or as we deem necessary to protect our legitimate legal and commercial interests, or in our sole discretion;
Corporate reorganization: In a transaction involving the sale or transfer of all or part of our business or assets, we may share Personal Information.
Such transactions may include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
Except as disclosed in this Privacy Policy, we do not sell, trade, or lease any Personal Information we collect online (or via mobile), unless we have your express permission.
7. How Long Do We Retain Personal Information?
We may process and store your information based on the following:
During the period you use our Platform (while your account is active, not closed, and not deleted);
As required by law, regulation, contract, or statutory obligation; and/or only for as long as your information is necessary for the purposes described in this Privacy Policy.
8. When and How Is Information Deleted?
We will take steps to ensure that Personal Information we hold or control is deleted and/or de-identified in an irreversible manner once it is reasonably considered that both of the following are true:
(1) the purpose for which the Personal Information was collected is no longer served by retaining such Personal Information; and
(2) retention is no longer necessary for legal or business purposes. If certain Personal Information must be retained under applicable laws and regulations, we will retain it as required by such laws and regulations before destruction. Personal Information stored and managed by us will not be used for purposes other than those permitted by law or authorized by you.
However, some information you have shared with others on the Platform—such as comments, message board posts, and your communications with other Platform users—may remain visible and may be retained after you close your account. Please contact MartialTales at privacy@MartialTales.com, and MartialTales will, in MartialTales Ltd.’s sole and reasonable judgment, assist you in deleting such content promptly to the extent permitted by law.
9. Children’s Personal Information
MartialTales is sensitive to privacy issues involving children who use the Internet, and we strive to protect the privacy of children who use the Internet. As further described in the Terms of Service, the Platform is intended for users who are eighteen (18) years of age or older. In accordance with the laws of the applicable jurisdiction, we do not knowingly collect, process, use, or share information from users under the age of 13 (hereinafter “Child” or “Children”). However, where collection, processing, use, sharing, and disclosure of Children’s information is required, we will obtain the relevant consent of a parent or legal guardian. Parents or legal guardians should supervise their children’s participation in online (mobile) activities. If you become aware of any child using our Platform, please notify us so that we can take immediate action to prevent access to our Platform.
10. Do We Transfer Your Information Abroad?
When you use our Services, your information may be transferred, stored, and processed inside or outside the country where you reside, in accordance with this Privacy Policy. Information you provide to us will be stored in our IT infrastructure located in Hong Kong (Tencent Network Services), and may subsequently be transferred to IT infrastructure in your country. We endeavor to implement appropriate technical, physical, and administrative safeguards to protect the privacy and security of your information, and to use it only consistent with our relationship with you and the terms described in this Privacy Policy. In addition, where possible and appropriate, we enter into service agreements and related terms with our Service Providers.
11. What Types of Security Measures Have Been Implemented to Protect Personal Information?
We take Personal Information seriously and implement appropriate physical, technical, and administrative security measures to prevent loss, theft, disclosure, unauthorized alteration, and deletion of Personal Information, including but not limited to the following: access control (including secure password policies); pseudonymization and encryption of Personal Information; installation of antivirus software and firewalls; implementation of firewalls; and/or management and monitoring of event logs to ensure accountability.
12. What Rights Do You Have Regarding Personal Information?
You may exercise the following rights regarding Personal Information: Right of access — You may request a copy of your Personal Information, including how we collect, store, use, process, share, and/or disclose information about you. This right always applies unless certain exemptions apply. Right to rectification — If you find inaccurate information about you that we hold, please contact us. You may ask us to correct, update, and supplement such inaccurate information. Right to erasure (right to be forgotten) — Where certain conditions are met, you may ask us to delete information about you that we have collected, stored, processed, and shared. Right to restrict processing — If you are concerned about how we use your information, you may restrict the ways we collect, process, use, store, share, and disclose your information. Right to data portability — This right applies only to information you provide to us directly. You may ask us to transfer such information in a usable format from one organization to another, or to provide it to you. Right to object — Where certain conditions are met, you may ask us to stop processing your information.
13. Changes to This Privacy Policy
We reserve the right, in our sole and absolute discretion, to change, modify, add to, or delete portions of this Privacy Policy at any time, and such new Privacy Policy will become effective immediately upon posting on the Platform. We will not provide any other notice of such changes. Please note that your use of the Platform means you will be bound by the latest version of the Privacy Policy. We encourage you to return frequently to review the latest version of the Privacy Policy, as it is your responsibility to stay informed of any changes to this Privacy Policy. If you do not agree to any changes to this Privacy Policy and do not wish your Personal Information to be subject to the revised Privacy Policy, please close your account and/or stop using the Services.
14. How to Contact Us for Inquiries, Concerns, and Complaints?
If you have any questions about your rights, please contact us at changyuntao@rayenergytech.com
If you have any questions or comments about our Privacy Policy, or wish to access the Personal Information we have collected, please contact us at changyuntao@rayenergytech.com
15. Date of Last Revision
March 4, 2024