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Vertex Digital Entertainment Inc

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Privacy Policy

1. Introduction
This Privacy Policy applies to the game products (hereinafter referred to as the "Products") developed by Vertex Digital Entertainment Inc (hereinafter referred to as "we"). We fully recognize the significance of privacy protection to users and commit to strictly complying with relevant U.S. laws, regulations and Google Developer Policies, and making every effort to safeguard the security and legitimate rights and interests of your personal information. This Policy will elaborate on the specific methods by which we collect, use, store and share your personal information, as well as the relevant rights you are entitled to in accordance with the law.

2. Information Collection and Sharing
2.1 Permission Acquisition and Information Collection
We will obtain corresponding permissions and collect information only after obtaining your explicit authorization and consent, based on the functional needs of the Products. The following will explain them in the order of "sensitive permissions first, ordinary permissions second":
2.1.1 Sensitive Permissions and Related Information Collection
Location Permission: We will only request this permission when the Products include location-related game functions (such as regional leaderboards, location-linked tasks, etc.). After your authorization, we may collect your approximate location information (based on IP address) or precise location information (based on GPS). The collection is conducted in real-time through the location information acquisition module built into the Products, and the collection objects are users who use the relevant functions. We only use this information within the scope necessary to implement the above-mentioned specific game functions and will never use it for other irrelevant purposes.
Camera Permission: We will request this permission when the Products include camera interaction functions (such as custom avatar shooting, AR game scene interaction, etc.). After your authorization, we will only capture images or videos in real-time through the camera when you actively trigger the function. The information is only used to complete the game function of your current operation (such as generating a custom avatar, realizing AR interaction effects) and will not be automatically collected in the background. The collection objects are users who use the relevant functions.
Microphone Permission: We will only request this permission when the Products include voice interaction functions (such as in-game voice chat, voice command control, etc.). After your authorization, we will collect your voice information through the microphone only when you actively turn on the voice function. The collection method is real-time recording and temporary local storage. After the voice transmission or recognition is completed, whether to retain it will be determined according to your settings. The collection objects are users who use the voice function.
Contacts Permission: If the Products include functions such as friend invitations and address book friend matching, we will request this permission. After your authorization, we only collect the contact information (such as name, phone number) of the contacts you actively select in the address book for invitation or matching. The collection method is to read the specified contact information when you operate. The collection objects are users who use the friend function and their designated contacts (only on the premise of obtaining indirect authorization from the contacts or complying with relevant legal provisions).
2.1.2 Ordinary Permissions and Related Information Collection
Storage Permission: To implement game data storage functions (such as game progress, custom settings, cached resources, etc.), we will request this permission. After your authorization, we will collect and store your game operation data, custom configuration information and necessary resource cache files. The collection method is automatic recording and saving through the product background data storage module, and the collection objects are all users who use the Products.
Device Information Permission: To ensure the stable operation of the game, troubleshoot faults and optimize the game experience, we will request this permission. The collected information includes device model, operating system version, unique device identifier (such as IMEI, Android ID, which will strictly comply with the Google Developer Policy on the use of device identifiers), hardware configuration, etc. The collection method is automatic collection when the product starts and during operation, and the collection objects are all users who use the Products.
Network Permission: To implement functions such as game data synchronization, resource update, and online interaction, we will obtain this permission. Through this permission, we will collect your network connection status (such as Wi-Fi or mobile network), IP address and other information. The collection method is automatic detection and recording during the operation of the product, and the collection objects are all users who use the Products.
2.1.3 Information Sharing and Sale
We strictly comply with relevant laws, regulations and Google Developer Policies, and will never transfer your personal information to any third party for the purpose of sale to seek profits. In the following specific scenarios, we may share your personal information with third parties, and will strictly ensure that the third parties comply with this Privacy Policy and relevant legal provisions:
1. Third-party service providers necessary for implementing product functions, such as game server hosting service providers, payment service providers (only sharing necessary payment-related information when you perform payment operations), and data analysis service providers (only sharing desensitized statistical data, excluding personally identifiable information);
2. We need to provide your personal information to relevant third parties in accordance with the mandatory requirements of laws, regulations, judicial organs or administrative authorities;
3. Sharing relevant information when reasonable and necessary to protect the legitimate rights and interests of us, you or other third parties (such as dealing with fraud, infringement and other acts).
2.1.4 Information Storage Server
Your personal information collected by us will be stored on servers located in the United States provided by Google Cloud Platform. We will ensure that the server strictly complies with the requirements of U.S. data security-related laws, regulations and Google Developer Policies, and has a complete security protection system.

3. Information Security Assurance Measures
To protect the security of your personal information, we have established a complete security assurance system from both technical and management levels, with specific measures as follows:
Technical Assurance: Adopt data encryption technologies (such as SSL encrypted transmission and AES encrypted storage) to encrypt your personal information to prevent it from being stolen or tampered with during transmission and storage; deploy security equipment such as firewalls and intrusion detection systems to effectively resist network attacks; regularly conduct security vulnerability scans and penetration tests on servers and systems, and promptly fix potential risks.
Management Assurance: Establish a strict information security management system, clarify the information security responsibilities of personnel in various positions; regularly conduct privacy protection and information security training for employees to enhance their awareness of privacy protection; set up strict access authority control, only authorize necessary personnel to access your personal information, and record and audit all access behaviors.
Emergency Response: Formulate a complete emergency plan for data security incidents. When a security incident such as personal information leakage or loss occurs, the emergency plan can be quickly activated, effective remedial measures can be taken, and you and relevant regulatory authorities can be promptly notified in accordance with the requirements of relevant laws and regulations.

4. Data Retention and Deletion Mechanism
4.1 Data Retention Period
We will retain your personal information within the scope necessary to achieve the purpose of information collection in accordance with the functional needs of the Products and relevant legal and regulatory requirements. The specific retention rules are as follows:
1. For game operation data (such as game progress, points, etc.), we will retain it continuously during your use of the Products; after you stop using the Products, it will be retained for an additional 12 months to meet your possible account recovery needs;
2. For information collected to implement specific functions (such as geographic location, camera images, etc.), after you stop using the specific function, we will delete this part of the information within 30 calendar days;
3. If relevant laws and regulations have longer requirements on the data retention period, we will strictly retain the corresponding information in accordance with the provisions of laws and regulations.
4.2 Data Deletion Mechanism
You can apply to delete your personal information through the following methods, and we will handle your request in accordance with laws and regulations:
1. In-product operation: After the Products are launched, if a data deletion function entrance is provided (such as "Settings - Account Security - Delete Personal Data"), you can directly submit a deletion application through this entrance;
2. Contact customer service: Contact our customer service team through the contact information provided in Article 9 of this Policy, submit a deletion application and provide necessary identity verification information (such as account registration email, mobile phone number, etc.); we will process your deletion request within 15 working days after receiving the application and completing the identity verification, and promptly feedback the processing result to you.
After the data is deleted, we will take technical measures to ensure that the data cannot be recovered, unless relevant laws and regulations clearly require the data to be retained.

5. Your Rights
In accordance with relevant U.S. laws, regulations and Google Developer Policies, you are entitled to the following rights regarding your personal information in accordance with the law:
1. Right of Access: You have the right to access all personal information about you collected by us. You can submit an access application by contacting customer service, and we will provide you with a copy of the personal information (such as in the form of an electronic document) within 10 working days.
2. Right of Correction: If you find that your personal information collected by us is incorrect or incomplete, you have the right to request us to correct it. You can make corrections through the personal information editing function in the product (provided after launch) or by contacting customer service. We will complete the correction and provide feedback within 5 working days after receiving the application.
3. Right of Deletion: As stated in Section 4.2 of this Policy, you have the right to apply for the deletion of your personal information.
4. Right to Withdraw Authorization: You have the right to withdraw your authorization for various permissions at any time. You can withdraw the corresponding permission through the "Settings - Apps - Product Name - Permissions" interface of the device, or operate through the permission management function in the product (provided after launch). After withdrawing the authorization, we will no longer collect the information corresponding to the permission, but it will not affect our legal use of the information collected before the authorization is withdrawn.
5. Right to Object: If we use your personal information for direct marketing purposes, you have the right to object. You can submit an objection application by contacting customer service, and we will immediately stop the relevant marketing activities.

6. Regulations on Minors' Use
We pay special attention to the privacy protection of minors and formulate the following regulations on minors' use in accordance with the requirements of the U.S. Children's Online Privacy Protection Act (COPPA) and relevant laws and regulations:
1. This Product does not provide services to minors under the age of 13. If we find that a minor (especially under the age of 13) uses the Products, we will immediately stop providing services to him/her and delete his/her relevant personal information, unless we obtain the explicit written consent of his/her parent or legal guardian.
2. For minors aged 13 to 18, before using this Product, they must obtain the consent of their parents or legal guardians, and the parents or legal guardians must assist them in reading this Privacy Policy to ensure that they understand the relevant terms.
3. If a parent or legal guardian finds that their minor child has used this Product without consent, they can contact us through the contact information in Article 9 of this Policy and provide necessary certification materials (such as guardian's identity certificate, minor's identity certificate, etc.). We will stop providing services to the minor and delete his/her personal information within 5 working days after verifying the information.

7. Use of Cookies
To improve your game experience, realize personalized services and conduct data analysis, we may use Cookies technology on your device:
1. The information we collect using Cookies includes your game login status, preference settings (such as picture quality, sound effect settings, etc.), and browsing history (such as visited game scenes, clicked function buttons, etc.).
2. You can refuse or delete Cookies by adjusting browser settings, but this may cause some game functions to not work normally (such as being unable to maintain the login status, unable to save preference settings, etc.).
3. We will not collect your sensitive personal information through Cookies, and will encrypt and protect the information in Cookies.

8. Policy Updates
With the revision of relevant laws and regulations, the update of Google Developer Policies or the adjustment of product functions, we may revise this Privacy Policy. The revised Privacy Policy will notify you through the following methods:
1. After the Products are launched, we will pop up a policy update notification on the product login interface, homepage or settings interface to ensure that you are aware of the updated content before using the Products;
2. We will send you a policy update email through your account registration email, detailing the updated content and effective time;
3. The revised Privacy Policy will be published on our official website (if any).
The revision of this Privacy Policy shall take effect from the date of publication or notification. If you continue to use our Products after the policy update, it means you agree to the revised Privacy Policy; if you disagree, you should immediately stop using the Products and contact us to delete your personal information.

9. Contact Information
If you have any questions, suggestions about this Privacy Policy, or need to exercise your relevant rights, please contact us through the following methods:
1. Email: info@vertexdigitalentertainment.com
2. Company Address: 1800 Wazee St Denver, CO 80202 USA
We will reply to you within 10 working days after receiving your contact information.

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