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Privacy Policy

1. Introduction

Zenergy Labs Limited (“Company,” “we,” “us,” or “our”) is committed to protecting the privacy of our users. This Privacy Policy explains how we collect, use, process, share, and safeguard your personal data when you access or use any of our Services, including our websites, games, mobile applications, social features, customer support, and other online functions (collectively, the “Services”).

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This Privacy Policy applies globally and includes specific provisions for users residing in the European Economic Area (EEA), California, and other regions with data protection laws.

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2. Information We Collect

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We collect personal information directly from you, automatically when you use our Services, and from third-party sources.

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2.1 Information You Provide

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You may provide us with:

• Account Registration Data: Username, linked third-party account ID (e.g., Facebook)

• Profile Information: Avatar, game display name

• Payment Information: Purchase history, transaction ID

• Support Communication: Customer support messages, feedback, in-game reports

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2.2 Information Collected Automatically

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When you use our Services, we automatically collect:

• Device Information: IP address, device ID, OS version, device type

• Usage Data: clicks, session length, in-game events, in-app purchases

• Advertising Data: Advertising IDs, interaction with ads

• Geolocation Data: Approximate location

• Crash Reports and Diagnostic Data: Error logs, performance statistics

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2.3 Information from Third Parties

• Social Networks: If you choose to link or login via social accounts (e.g., Facebook, Google)

• Advertising and Analytics Partners: For analytics, ad serving, attribution (e.g., Appsflyer, Adjust)

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3. How We Use Your Information

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We use your data for the following purposes:

• To personalize content, recommendations, and in-game experiences

• To conduct analytics and service improvements

• To detect fraud, cheating, and ensure Service integrity

• To comply with legal requirements

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4. Legal Bases for Processing (EEA/UK Users)

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We process your data under one or more of the following:

• Contractual necessity: Operating the Services and fulfilling our contract with you

• Legitimate interests: Improving and securing our Services

• Consent: For optional features like personalized ads (opt-out available)

• Legal obligation: To comply with applicable laws

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5. Information Sharing

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We may share your information with:

• Service Providers: Hosting, customer support, analytics, payment processing

• Advertising Partners: For delivering, measuring, and improving ads (subject to applicable consent)

• Social Networks: Only when you opt-in (e.g., social login or friend invite)

• Platform Providers: App Store, Google Play

• Authorities: If legally required or to protect rights and safety

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We do not sell your personal information.

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6. International Transfers

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Your data may be transferred to, and processed in, countries outside of your jurisdiction, including Hong Kong, where our headquarters is located. For EEA users, such transfers rely on recognized safeguards like Standard Contractual Clauses (SCCs).

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7. Data Retention

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We retain your data for:

• As long as you maintain an account with us

• As required to provide the Services

• As necessary for legal compliance, dispute resolution, and fraud prevention

• Inactive accounts may be anonymized or deleted after 3 years unless otherwise required by law

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8. Your Rights

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Depending on your region (GDPR, CCPA, etc.), you may have:

• Access: Request a copy of your data

• Rectification: Correct inaccurate data

• Erasure: Request data deletion (“right to be forgotten”)

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You can exercise these rights by contacting us at feedback@zenergygame.com.

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9. Children’s Privacy

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We do not knowingly collect personal data from users under:

• 13 years old globally, or

• 16 years old within the EEA

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If we discover such data has been collected without parental consent, we will delete it promptly.

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10. Data Security

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We implement technical and organizational measures such as:

• Data encryption (at rest and in transit)

• Secure servers and access controls

• Periodic security reviews

• Staff training on data protection

However, no system is completely secure. You use the Services at your own risk.

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11. Advertising and Analytics

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We use analytics and advertising services to:

• Measure service usage and engagement

• Serve relevant ads (where allowed)

• Optimize user experience​​

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12. Changes to this Privacy Policy

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We may revise this Policy from time to time. We will notify users through in-app notices or other reasonable means when material changes occur. Continued use of the Services constitutes acceptance of the updated policy.

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13. Contact Information

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