UNTAG LAB Privacy Policy


UNTAG LAB's Privacy Policy for gaming services (hereinafter referred to as this "Policy") is generally applicable to all games and related services (hereinafter referred to as the "Service") developed or owned by UNTAG LAB. (hereinafter referred to as the "Company"). To protect your rights and interests, please carefully read the following provisions before using the Service. By using the Service, you acknowledge that you have read, understood, and agreed to this Policy.


  1. Introduction


    You are very welcome to use the Service. We attach great importance to your privacy. We will adhere to the fundamental principles detailed below to fulfill our commitment to respecting and protecting your privacy, and will formulate this Policy in accordance with the fundamental principles:

    1. You will be deemed to have agreed to this Policy when you use the Service, whether using the account you registered, as a guest, or via other means.

    2. We will ensure that you are notified when we collect your personal data, and will bear any responsibility for the collection, use (including international transmission), or disclosure of your personal data in accordance with applicable laws.

    3. We will clearly state the specific purpose when we collect your personal data.

    4. When we collect your personal data, we will only collect the information necessary for the specific purpose.

    5. We will only use (including international transmission) or disclose your personal data for the specific purpose, and will only retain the personal data necessary for the specific purpose, unless when acting in accordance with applicable laws and with your consent, or when required or permitted by law.

    6. We will ensure that your personal data is accurate, complete, and up-to-date to the extent possible.

    7. We will use appropriate security measures to protect your personal data.

    8. We will be as transparent as possible with regard to our policies and actions when processing your personal data.

    9. You have all applicable rights to your personal data as a data subject, including but not limited to the right to view, correct, delete, restrict processing, data portability, and object.

    10. We will be accountable to you and welcome your feedback at any time regarding our compliance with the abovementioned principles, this Policy, and applicable laws.

    11. We will ensure that relevant measures remain appropriate, suitable, and effective for our operational needs, information security, and privacy protection, and will monitor the requirements of relevant stakeholders, such as requirements of the

      competent authority, requirements set forth in relevant laws and regulations, and contractual obligations.

    12. We will identify and comply with the requirements regarding privacy protection and personally identifiable information (PII) protection in accordance with Taiwan's Personal Data Protection Act, the EU's General Data Protection Regulation (GDPR), the US California Consumer Privacy Act/California Privacy Rights Act (CCPA/CPRA), and laws and regulations of other countries or regions applicable to the Service.


  2. Applicability of this Policy


    1. This Policy explains how the Service will process and protect your personal data, as well as your options for viewing and controlling your personal data. This Policy is generally applicable to all games and related services developed or owned by UNTAG LAB. and its affiliated companies.

    2. This Policy is only applicable to the collection, processing, use, and protection of your personal data when you actually access or use the Service (i.e., this game) as a user. While this Policy generally applies to the Company's games, in principle, other personal data collected by the Service (i.e., this game) will be kept strictly isolated and will not be circulated or shared with other independent game services or products operated by the Company, unless the purpose of information use is to fulfill the game service contract, based on legal rights, or with your consent.

    3. This Policy does not apply to games or services for which the Company acts only as an agent, publisher, or distributor, and where a third-party developer or other third party is the primary controller of the information.


  3. Types of Information Collected


    The Service collects and uses (including international transmission) the following types of information for the purpose of serving you:

    1. Information necessary to create an account and provide core services:

      The Company needs to collect the following information to perform your game service contract and provide core service functions. If you refuse to provide the information, you might not be able to create an account or use all services.

      1. [Identification and Contact Information]:

        You will be required to provide contact information, such as your e-mail or mobile phone number, to register and create an account to use the Service. When you choose to register or log in to your account through a third-party service (such as Google, Apple, or Facebook), we will collect the unique user identifier provided by that service. The information is used to verify your identity and ensure the uniqueness of your account, in order to perform the game service contract and synchronize your game records in the cloud.

      2. [Third-party Login Information]:

        If you log in through a third party to use the Service, the Company will only obtain the information necessary to provide the Service from the third party (such as platform UID and e-mail address), and the information will be managed by a specific authorized department in the Company in accordance with the data minimization principle.

      3. [Connection and System Technical Records]:

        The Company will collect your connection and system technical records when you use the Service, such as the IP address of the connected device, connection time, the browser used, browsing history, click information, and application diagnostics and error reports, in order to maintain system stability, ensure network connection quality, and localize content display for the Service. The Company will only collect information on your precise location to provide the services you request after obtaining your explicit consent, and you can withdraw this consent at any time in your device settings.

      4. [Device Information]:

        When you use the Service, the Company will collect your device information, such as the operating system, language settings, device identifier, hardware model, and advertising identifier (IDFA/AAID), to provide you with a stable connection, improve the quality of the Service, and detect abnormal user behavior.

      5. [Gaming Activity]:

        We will record all of your gaming activities when you use the Service, including but not limited to playtime, challenge records, character data, and other game-related data, to ensure service continuity and save your progress. The data will also be used to improve the quality of the Service, detect abnormal user behavior, and analyze service usage based on legal rights and interests.

      6. [Transaction Information]:

        1. Direct payments of the Service (including transactions using the Company's points)

          When you choose to conduct a transaction using online payment, official points redemption, or other direct payment methods through the Company provided by the Service, the Company will collect information on the transaction number, transaction amount, goods purchased, player UID, and virtual points change records to process the transaction, issue an invoice, or handle taxes in order to perform the Service contract. The Company may directly collect, process, and use your financial information (including but not limited to payer's name and billing address) to comply with the law.

        2. Third-party Payment

          When you make a purchase through a third-party payment channel provided by the Service (including but not limited to Google Play, Apple App Store, and other third parties), the Company will collect information on the transaction number, transaction amount, goods purchased, player

          UID, and transaction result. The information will be used to perform the game service contract, including but not limited to managing top-up records, checking the status of transactions, processing refunds, assisting with handling consumer disputes, and other matters provided by the law. In addition, third-party payment service providers (including but not limited to the App Store, Google Play, or other payment service providers) may directly collect, process, and use your financial information (including but not limited to the payer's name, credit card number, and payment authentication records) when processing your transactions. The Company will not collect, process, or use such financial information. Third-party payment service providers will process your financial information in accordance with their terms of service and privacy policies. Please refer to their terms of service and policies.


    2. When using the Service, you agree to voluntarily provide the following information to use specific services:

      To perform the game service contract, exercise legal rights, fulfill legal obligations, or with your consent, the Company will collect, process, and use the following information when specific functions are enabled or when you actively choose to use the service.

      1. [Personal Settings and Public Information]:

        You can set up a profile (such as gender, birthday, and interests) for your account to help other users get to know you better.

      2. [Contact Information for Customer Service or Support]:

        If you contact us for needs related to the Service, or when we request information from you for the purpose of providing support, ensuring account security, or maintaining the integrity of the Service (including but not limited to account security, issues with game functions, event reward collection, or disputes related to service use), we will notify you of the information you are required to provide, including but not limited to your name, e-mail, and phone number, as well as information about your mobile device or personal computer, such as device type and operating system. We may collect and process the information you provide as needed to perform the game service contract. We may also use (including international transmission) the information to process and look into the issues you have reported, in order to provide you with support and to improve our customer support services.


  4. Purpose and Scope of Information Use


    1. To perform the game service contract, exercise the Company's legal rights, or after obtaining your consent, the Company will use (including international transmission) your information as the information controller or co-controller for the following purposes.

      1. To verify your identity.

      2. To make public the multimedia content, images, and text that you have publicly provided on the Service or that you have agreed to making publicly available, along with your account, on the website or advertisements related to the Service.

      3. To allow you to use your account for the Service on a variety of devices, and also allow you to transfer your account to other devices.

      4. To help you find other users of the Service you know and stay connected with them through the Service. You can also make a request to allow other users to contact you.

      5. To allow you to synchronize the Service or the Company's products to your account and share information across multiple apps that you use.

      6. To respond to your request services not provided by the Service.

      7. To discover and stop unauthorized use of services, improper acquisition of services, or misuse of services.

      8. To elevate service standards and/or optimize service quality.

      9. To ensure that support is provided to customers and respond to your questions or claims in a timely and effective manner.

      10. To conduct customer satisfaction surveys or analyze data for customer experience optimization, either independently or by outsourcing it to a contractor.

      11. To assess the effectiveness of our advertisements online or on other media.

      12. To notify users of other important information related to the Service when necessary.

      13. To verify the identity of winners in promotions, send gifts to winners, deliver purchased products, and similar activities.

      14. To accumulate anonymous statistical information related to the Service.

      15. To improve the quality of services, the Company may analyze or process statistics and data, including your personal information and browsing behavior. The Company may use (including international transmission), share, or disclose the processed information for promotion, rewards, or to provide you with a wider and more convenient social circle. However, the Company will not run analysis on individual users.

      16. If payment or logistics services are required for your purchases or donations, the Company may provide your PII to relevant authorities, partners, or contractors to verify transactions or deliver goods or rewards within the aforementioned scope.

      17. The Company may request your assistance in providing the original, fax, or photocopy of your ID document, as well as your mailing address and bank account information, when providing services, authenticating your identity, or awarding prizes, in order to ensure the security of your account and verify that you are the user.

      18. If the Company provides bonus points or rebates, you agree to authorize the Company to provide your personal data to the vendors providing goods or

        services or government agencies for collection, processing and use (including international transmission) to the extent necessary for the specific purpose of redemption (including taxation).

      19. When you become a member or use the Company's website or its affiliated websites, web pages or other services, the Company will share information on promotions of the Company and its partners through push notifications, SMS, e-mail, or other means for marketing, cross-selling with partners, or to provide other services. If you do not wish to receive promotion or marketing information of the Company and its partners, you may cancel the notification service at any time. If you have any questions regarding settings, please feel free to contact us at any time.

      20. For the purpose of providing better services, the Company may use (including international transmission), share, or disclose processed information (including your personal information and transactions) to the Service or the Company's products and business partners for market analysis, statistics, or surveys for promotions, rewards, or to provide you with a wider social circle.

      21. To comply with applicable laws and fulfill legal obligations.


    2. We use cookies and similar technologies, including local storage, for the following purposes:

      1. To help us maintain the Service while you are using it.

      2. To improve security.

      3. To remember information related to your browser and your preferences.

      4. To help us understand how users use the Service and improve the quality of services.

        For example, we might use Google Analytics to help us achieve this goal. Except for EU/EEA users, by continuing to use the Service, you agree to our use of cookies and similar technologies in accordance with this Policy. For EU/EEA users, we will ask for your explicit consent to non-essential cookies through the settings or pop-ups on your device or service interface.


    3. However, if we need to use your information in specific circumstances, we will request it from you or notify you through other means, and such notification will take precedence over the general circumstances described in Article 4 of this Policy.


  5. Information Security Measures and Protection


    1. Protective measures adopted by the Company

      1. All information of the Service is processed and stored on secured servers to provide secure and reliable services. Your personal data will be protected by a reasonable security system, such as a firewall or password protection. The Company adopts technical and organizational security measures that meet

        industry standards to prevent unauthorized access, disclosure, modification, or damage.

      2. These measures include, but are not limited to:

        1. Data encryption: Data is encrypted in transit and at rest.

        2. Permissions and logs: Only personnel who need access to your personal data to perform their duties are authorized to do so. We implement the principle of least privilege and keep logs for all operations.

        3. Backup and disaster recovery: The system automatically backs up game data and transaction records once a day. The backup file is kept for 90 days and then automatically archived and deleted. Backup data is for disaster recovery only and is not publicly accessible.

      3. Although we have made every reasonable effort to protect your data, please understand that absolute security cannot be guaranteed for data transmission or electronic storage methods online.


    2. Security Incident Handling and Leakage Reporting

      1. The Company has established internal procedures for monitoring abnormalities and auditing all access to and processing of personal data.

      2. In the event of a security incident, such as leak, loss, or theft of personal data, the Company will immediately initiate response procedures, investigate the cause of the incident, take remedial measures, and notify relevant authorities and users in a timely manner in accordance with internal procedures and relevant regulations.


    3. User's Responsibility for Information Security

      Since no electronic transmission or information storage method is invulnerable, we cannot guarantee that your information will be 100% secure and will not be attacked during the system's transmission or storage process. For the protection of your privacy and information security, please do not share your password with others or use the same password as other devices. Additionally, if you suspect any unauthorized use of your account or any other unsafe activity, please notify us immediately.


  6. Data Retention Policy and Period


    1. The term "personal data" in this Policy refers information that can be used to identify a specific person, but does not include information provided anonymously.

    2. Retention Policy

      The Service will retain your personal data under the following circumstances:

      1. Your account remains active;

      2. During the period required to fulfill the specific purpose set forth in this Policy;

      3. Or within the period required by applicable laws.

    3. Retention Period

      Except for the following purposes or with your written consent, due to the needs of our duties or business, we will delete your personal data no later than six months after your account is closed:

      1. To comply with applicable laws and regulations or to fulfill legal obligations.

      2. To provide and complete customer support services.

      3. To resolve disputes between users of the Service or between the Company and users.

      4. To detect or prevent unauthorized, improper, or misuse of the Service.


  7. Information Sharing, Disclosure, and International Transmission


    1. Information Sharing and Disclosure

      The Company will only provide your personal data to partners (including but not limited to the Company's affiliated companies and contractors) to the extent necessary to meet your purpose of information use, perform the game service contract, exercise the Company's legal rights, or the extent you consented to (including but not limited to customer support, information security services, payment processing, identity verification, and messaging services). Except as stated in this Policy or other applicable terms of the Service, the Company will not sell or directly lease your personal data to any third party without your consent, unless we believe that we are required or permitted to do so by applicable laws, or to protect the rights and interests of the Company or the Service, based on the principle of good faith.

    2. Marketing and Advertising Partners

      The Company might share your advertising identifier (IDFA/AAID) or processed data that cannot be used to directly identify you with advertisers, in order to assess the effectiveness of advertisements, for joint marketing campaigns, or to improve the Service.

    3. Legal Requirements and Protection of Rights

      The Company might disclose your information without your consent or without notifying you to comply with court orders, subpoenas, requests from government agencies, or other legal requirements.

    4. International Transmission

      1. Your personal data might be transferred, stored, processed, or used outside your country/region of residence or nationality (e.g., the United States, Singapore, Japan) if the Company and its partners provide services worldwide.

      2. To ensure the security of your information, we only transfer data internationally to perform the game service contract, after obtaining your consent, or according to contracts that are legally binding as required by law, and require all overseas partners to abide by confidentiality agreements.


  8. Third-party Website Disclaimer and Risk Statement

    1. We might provide links to the services of third-party websites or place third-party websites in the Service in an attempt to provide greater value, and will allow you to read or access their content, products, and services, including but not limited to the users, advertisers, affiliated companies, and sponsors of the third-party websites.

    2. You agree and understand that the Service cannot guarantee the security of your personal data and/or other information provided on third-party websites. The third-party websites you link to have their own privacy policies and security measures. Even if the third-party website is related to the services provided by the Company, the Company has no control over the third-party website and assumes no responsibility or obligation for the third-party website or its content, products, services, and security measures. Therefore, you should assess the risks before accessing these websites.

    3. If you see any content that you do not like or agree with, we suggest you leave the website immediately. The Company shall not be liable, directly or indirectly, for any loss or damage caused by or in connection with the use of or reliance on the content, goods, or services on or obtained from such third-party websites. Nevertheless, the Company strives to protect the integrity of the Service and all links provided by the Service, and therefore welcomes your opinions regarding such third-party websites.


  9. Your Rights


    1. You enjoy the following rights to your personal data in accordance with the law:

      1. The right to make an inquiry of and to review your personal data;

      2. The right to request a copy of your personal data;

      3. The right to supplement or correct your personal data;

      4. The right to demand the cessation of the collection, processing or use of your personal data;

      5. The right to delete your personal data.

      6. The right to data portability.

      7. The right to withdraw consent.

    2. Methods and Time Limits for Exercising Rights

      In addition to modifying contents on your own through the Service, you may make a request to exercise the abovementioned rights at any time using the contact methods provided by the Company. We will respond to and process your request within the time limit required by the applicable law.


  10. Protection of Children and Minors


    1. The Company will implement the most appropriate age verification and service restriction measures based on the characteristics and risk assessment of different products. Users must reach the specified age to use the Service. If the user is a minor, the user declares and guarantees that he/she has obtained the consent of his/her legal representative to use the Service.

    2. The Company does not intentionally collect personal data from minors, nor does it target them with interest- or location-based advertisements.

    3. Commitment to Strict Data Protection for Specific Countries/Regions

      We understand that the personal data of underage users who use the Service in specific countries or regions require special protection. We undertake that we will not knowingly collect personal data from users under certain ages (e.g., under 13 in the United States, under 16 in the European Union, and under 11 in Thailand).

    4. Reporting, Deletion, and Parental Rights

      If you believe that we have information obtained from or about children under the abovementioned age limits, you can contact us at any time using the contact methods provided by the Company. If we discover that we accidentally collected such information, we will immediately deactivate the account and take reasonable measures to delete the personal data from the Company's records as soon as possible.


  11. Changes to this Policy


    The Company reserves the right to announce modifications or changes to the contents of this Policy on the Service at any time. The updated content will take effect immediately once a modification or change is announced on the Service. We suggest you pay attention to any modifications and changes that are made. If the revised version involves substantial changes to the purpose of personal data collection, processing methods, subjects the personal data is shared with, or other changes that may affect your core privacy rights, the Company will announce the update on the Service 30 days in advance. After the 30-day period expires, the Company will officially implement the aforementioned privacy policy. If you continue to use the Service, you will be deemed to have read, understood, and agreed to accept all modifications.


  12. Governing Law and Dispute Resolution


    1. The interpretation and application of this Policy, as well as any disputes relating to this Policy, shall be governed by the laws of the Republic of China, unless otherwise provided by the law.

    2. In the event of any dispute between the Company and the user arising out of or related to the use of the Service, both parties agree to negotiate in good faith. If an agreement cannot be reached after negotiation, both parties agree to submit the dispute to the Chinese Arbitration Association, Taipei for arbitration. If one or both parties do not accept the arbitration award, both parties agree that Taiwan Taipei District Court shall be the court of first instance.

    3. For EU/EEA users, this clause does not affect your rights under the laws of your member state, and you still have the right to file a complaint or request with the data protection authority (DPA) of your member state.


  13. Supplementary Provisions for Specific Jurisdictions

    1. Applicability: This section is intended to meet the specific disclosure requirements of certain jurisdictions and is only applicable to residents of those jurisdictions.

    2. Rights of California Residents (CCPA/CPRA) and Disclosures

      1. As a resident of California, in addition to the rights described in Chapter 9 of this Policy, we undertake to disclose the following information to you:

        1. Types and Sharing of Information

          We have collected the following types of personal information for the purposes described in Article 3 of this Policy over the past 12 months: Identification information (such as IP address and e-mail), business information (such as transaction records), online activity information (such as browsing history), geographic location data, and inferences derived from the aforementioned information. In addition, we will share the aforementioned personal information with third parties, such as affiliated companies and providers of data analytics, advertising, and customer services.

        2. Exclusive Rights and Commitments

          We will not sell your personal data without permission. You have the right to choose not to sell or share your personal data, especially in the context of advertising and marketing. You may also restrict our use of your sensitive personal data (such as geographic location).

        3. You may make a request to exercise the abovementioned rights at any time using the contact methods provided by the Company.

    3. Other Major Jurisdictions

      Residents living in regions where the Service is operated also enjoy specific rights granted by their local laws. The Company undertake to comply with local laws and regulations. You may exercise all of your rights under local laws using the contact methods provided by the Company.


  14. Contact Us


    1. The Company is the sole data controller of this Policy. Contact Us : https://www.facebook.com/UNTAGLAB/

    2. To make a request to exercise your rights over your personal data (including access, correct, delete, and restrict processing) or file a complaint in accordance with applicable laws, please contact the Company through our mailbox.


  15. Effect of Provisions


    1. If any provision of this Policy is determined to be invalid or unenforceable by a court or other competent authority, the invalid or unenforceable provision shall not affect the validity or enforceability of other provisions or related regulations. The provision will only be modified to the extent necessary to make it valid and

      enforceable, and the modified provisions will be interpreted in accordance with the legal and economic effects originally intended to be achieved.

    2. All terms and conditions in this Policy shall be based on the Traditional Chinese version. In the event of any discrepancy between the Traditional Chinese version and the English version or other language translations of this Policy, the Traditional Chinese version shall prevail.