AVENTIX is a company established in Hong Kong that provides games and other services to users around the world. This privacy policy explains how we collect, use, share, and protect your personal data when you use our services. Personal data means any information that can identify you or relate to you as an individual.

We are committed to respecting your privacy and complying with the Personal Data (Privacy) Ordinance (Cap. 486) (the PDPO), which sets out the rules and standards for processing personal data in Hong Kong.

When we refer to “AVENTIX” (or any similar terms like “we” or “us”) in this privacy policy, we mean AVENTIX and its subsidiaries that help us provide and support our services. When we say "services" or "AVENTIX Services", we mean any products or services that link to this privacy policy, such as our websites, applications, and games.

Please read this privacy policy carefully before using our services. By using our services, you agree to our collection, use, sharing, and protection of your personal data as described in this privacy policy. You also agree to our terms and conditions that apply to our services.

If you have any questions or concerns about this privacy policy or your personal data, please contact us as described in "CONTACT US" below.

1. HOW WE COLLECT YOUR PERSONAL DATA

The personal data we collect depends on your interactions with us. Typically, we collect personal data in three main ways: A) personal data you voluntarily provide to us, B) automatically when you use the AVENTIX Services, and C) from service providers and third parties who share it with us or who we engage to help us provide the AVENTIX Services in accordance with the PDPO and other applicable laws.

A. Personal Data You Voluntarily Provide To Us

You can provide us with different kinds of personal data depending on how you interact with the AVENTIX Services. We only collect personal data that is necessary and relevant for the purposes of providing and improving our products and services. We will inform you of the purposes for which we collect your personal data and obtain your consent before processing it. We will not use your personal data for any other purposes without your permission. Please note that if you choose not to provide us with certain personal data, you may not be able to access certain AVENTIX Services or features may not work as intended.

Some examples of personal data you provide to us are:

• Basic registration information, such as your name, a public-facing display name, password, the country you live in, and email address to create an AVENTIX account and access some of our games and features;

• Payment-related information, such as your credit card number and expiration date to complete purchases on the AVENTIX Game Launcher;

• Optional personal data that you provide voluntarily, such as email preferences, social features like forums or chat, early access request, surveys responses, or customer service inquiries, to personalize your experience and communicate with you;

• Application information and other relevant details that you provide to verify your eligibility and process payouts for contest or competitive event. We collect whatever information you choose to provide to us in those or other similar cases;

• Personal data of other individuals that you provide to us in certain circumstances. If you do so, you must ensure that they are aware of this Privacy Policy, the purposes for which we are collecting their personal data, and have consented to your disclosure of their personal data to us for those purposes. You agree to indemnify and hold us harmless from and against any and all claims by such individuals relating to our collection, use and disclosure of such personal data in accordance with the terms of this Privacy Policy.

B. Personal Data We Collect Automatically

We may collect some personal data automatically when you visit, access, or use the AVENTIX Services. This includes information about your gameplay or application usage, purchases, entitlements, and other activity in the AVENTIX Services, typically associated with your account (if you are logged into your AVENTIX account or use a third-party account to access the AVENTIX Services) or with an identifier we have assigned to your device or profile. While the specific types of personal data that we automatically collect may vary, they generally include:

• Usage information: This includes details about the games you play, the applications you use, how long and when you use them, your progress and achievements, your preferences and settings, crash reports, and other statistics about your interaction with our services. They also help us improve our services, personalize your experience, manage advertising, conduct data analytics, and prevent fraud and cheating;

• UTechnical information: This includes information about your device, such as IP address, device identifiers, internet service provider, browser type and version, operating system and platform, hardware specifications, and other device-related information;

• Location information: This includes an approximate location of your device based on your IP address.

We use various technologies to collect this information automatically. These include cookies, log files, web beacons, and other similar tools that store or access data on your device. They help us, our service providers, and third parties recognize your device and provide information about how you use and interact with the AVENTIX Services. For example, they support our ability to authenticate users, remember preferences, manage to advertising, personalize experiences, and conduct data analytics. Please note that if certain features on the AVENTIX Services are provided by third parties, those third parties may also use automated means of data collection and may record information about your use of the AVENTIX Services or others’ websites over time. These features are subject to those third parties’ privacy notices and policies.

We will obtain your consent before using cookies or similar technologies that collect personal data on your device. You can control the use of cookies by adjusting the settings of your browser or device. However, if you disable cookies or similar technologies, some features of the AVENTIX Services may not function properly.

C. Personal Data We Collect From Other Sources

We may also receive information about you from service providers and third parties in connection with your use of the AVENTIX Services or your interactions with us on other platforms. For example:

• If you link your AVENTIX account with a third-party account (such as Facebook or Steam), the third-party may share some personal data with AVENTIX, such as your display name, user ID, device information, name, and email address. You can control the information they share with us by changing your privacy settings on their websites or services;

• If you buy, download, or access our services on or through services operated by third parties (such as gaming consoles), they may provide us with personal data to facilitate your access and use of our services. This may include your display name, user ID, device and region information. For example, if you play our games on a gaming console through your console account, the console provider may share some personal data with us to help us track your gameplay and entitlements;

• If you participate in alpha, beta, or early access tests of our games or services, we may receive feedback and other personal data from you or from third parties who help us conduct these tests.

2. HOW WE USE YOUR PERSONAL DATA

We use the personal data we collect (either individually or in combination with other information collected as described in this policy) for various purposes related to your services. These include:

• Providing and improving our services, such as creating, verifying, and managing your account and features, delivering, and updating our games and applications, processing transactions and requests, communicating with you, developing new features and products, and conducting data analytics;

• Personalizing your experience, such as tailoring our services to your preferences and interests, or making recommendations based on your activity and feedback;

• Promoting the AVENTIX Services, such as managing and measuring the effectiveness of our advertisements, promotional offers, surveys, and events. We may also send you marketing communications if you have consented to receive them or if we are otherwise permitted by law;

• Managing alpha, beta, or early access tests (and collecting feedback);

• Conducting data analytics (like analyzing how the AVENTIX Services are used so we can better understand, improve, and personalize them);

• Complying with our legal obligations and responding to lawful requests from authorities;

• Securing the AVENTIX Services, such as by detecting fraud, cheating, hacking, unauthorized access, or other harmful or illegal activities on our services. We may also enforce our terms and policies and protect our rights and interests.

We may also use your personal data in other ways that we will notify you at the time of collection or before we start using it.

We may also process information that does not identify you individually, such as aggregate or de-identified information. This information helps us better understand larger groups of users and improve our services. We may user and share this information for any lawful purpose.

HOW WE SHARE YOUR PERSONAL DATA

We may share some of the personal data we collect to help operate and improve the AVENTIX Services. These include:

• With other AVENTIX entities that help us operate and support our service globally;

• With service providers that act on our behalf to help us provide the AVENTIX Services in accordance with our instructions. They only use your personal data in accordance with our instructions and for the purposes described in this privacy policy;

• With other users if you use social features of our services such as chat or forums. You can control what personal data you share with others by changing your privacy settings on our services;

• Publicly if you create or share content on our services that is accessible to others. This may include your display name, content you create or share, basic game statistics, and other similar personal data;

• With console and platform partners if you access our services through a third-party console or platform. They may use your personal data in accordance with their own privacy policies;

• With law enforcement or other authorities if we believe we must do so to comply with the law or to protect you, AVENTIX, or others from harm or illegal activities. This may include responding to court orders, subpoenas, warrants, or other legal requests, or cooperating with investigations of fraud or other illegal activities;

• With other parties in connection with certain corporate transactions, such as a merger, acquisition, sale, or reorganization of our business. We will take steps to ensure that your personal data continues to be protected in accordance with this privacy policy;

• With your consent or at your direction, such as if you link your AVENTIX account with a third-party account, or use your AVENTIX account to sign in to third-party games and services or participate in cross-promotional events.

We may also share information that does not identify you with third parties, such as aggregate or de-identified information.

Third parties you interact with through AVENTIX Services may have different privacy practices than AVENTIX, so we encourage you to review their privacy policies before sharing your personal data with them.

4. AVENTIX SERVICES AND CHILDREN

The AVENTIX Services are intended to be appropriate for general audiences and not intended to be accessed or used by children under the age of 18. AVENTIX does not knowingly collect personal data from children without obtaining parental consent in accordance with applicable laws and regulations. If you are a parent or guardian and you believe your child has provided us with their personal data without your consent, please contact us and we will take steps to delete it.

5. YOUR CHOICES AND RIGHTS

We respect your choices and rights regarding your personal data. Depending on the exact nature of our relationship with you and how you use the AVENTIX Services, you may have different options and rights available to you. These include:

• You can request access to, correction of, or deletion of your personal data we’ve collected. You can also request to restrict or to stop processing your personal data in certain circumstances;

• You can change your email marketing preferences at any time, such as by using the opt-out mechanism provided in our marketing emails, updating your AVENTIX account settings, or contacting us with your request;

• You can change your privacy settings on other parties’ websites (such as social networks) or platforms (like console providers) to limit the personal data they may share with us;

• You can change your browser or mobile device settings to block, manage, delete, or limit tracking technologies like cookies. In some cases, blocking or disabling cookies may cause the AVENTIX Services not to work as intended and some features may not be available;

• If you’re under the age of 18 and have an AVENTIX account, you can ask that we remove or anonymize certain content you’ve provided on the AVENTIX Services;

Some jurisdictions may provide you with additional rights under their laws. For example, if you are in the European Union (EU), you may have the right to object to our processing of your personal data based on our legitimate interests, the right to data portability, and the right to lodge a complaint with a supervisory authority. To learn more about these rights and how to exercise them, please contact us as described in "CONTACT US" below.

Please be noted that we may ask you for additional information to verify your identity before completing your request.

6. OUR GLOBAL OPERATIONS

AVENTIX is based in Hong Kong, but we operate globally to help provide users all around the world with a better experience on the AVENTIX Services. We have subsidiaries, offices, service providers, and partners worldwide to support these operations in a number of different ways. This means that AVENTIX may transfer and process the personal data we collect in countries outside the country where you live.

The data protection laws and rules in these countries may be different than those where you live. We rely on various legal mechanisms to lawfully support these transfers, such as adequacy decisions, standard contractual clauses, or your consent. By using our services, you agree to our transfer and processing of your personal data in any of the locations where we operate.

If we transfer your personal data outside Hong Kong, we will comply with the PDPO and its related provisions when they come into effect.

7. DATA RETENTION

We retain your personal data for as long as we reasonably need it for the We retain your personal data for as long as we reasonably need it for the purposes described in this privacy policy. This may vary depending on how you use the AVENTIX Services and the nature of your personal data. The main criteria we consider in determining how long we keep your personal data include:

• The minimum retention periods required by law or regulation;

• The relevant industry standards and best practices;

• The types of personal we have collected and how sensitive they are;

• The potential risk of harm or liability from unauthorized use or disclosure of your personal data;

• The purposes for which we process your personal data and whether we can achieve those purposes through other means; and

• The necessity of your personal data for legal claims or disputes.

We may also retain some information that does not identify you individually, such as aggregate or de-identified information. We may use and share this information for any lawful purpose.

We will erase your personal data when it is no longer necessary for the purposes for which it was collected or any directly related purpose, unless we are required or authorised by law to retain it.

8. DATA SECURITY

We take data security very seriously and we use appropriate technical and organisational measures to protect your personal data from unauthorized access, use, disclosure, alteration, or destruction. However, no method of transmission or storage is completely secure and we cannot guarantee the absolute security of your personal data. We recommend that you take precautions to protect your personal data, especially your account credentials and password. You agree not to hold us liable for any loss or damage resulting from any unauthorized or unintended access that is beyond our control, or abuse of your personal data by third parties. We also do not warrant or represent that your use of our services is safe and protected from malware, viruses, or other vulnerabilities. We also do not guarantee the security of data that you send us electronically. Sending such data is entirely at your own risk.

We maintain appropriate safeguards to protect your personal data from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use and other unlawful forms of processing. We also limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We will notify you and the Privacy Commissioner for Personal Data without undue delay if we become aware of any breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to your personal data (a "data breach"). We will also inform you of the likely consequences of the data breach and the measures taken or proposed to be taken to address it.

9. UPDATES

We update this policy from time to time to reflect changes in our practices or relevant laws. When we do, we’ll change the date noted at the top of the policy. We may also notify you of the changes by email or within the AVENTIX Services. Please review this policy regularly to stay informed about how we collect, use, share, and protect your personal data.

10. CONTACT US

If you have questions or concerns about this Privacy Policy or your personal data, please contact us at

Email: publishing@aventixgames.com.

Rm A , 12/F , Wing Cheong Commercial Building,

19-25 Jervois Street,

Sheung Wan, Hong Kong SAR.

We will respond to your request as soon as possible and in any event within one month of receipt of your request.

AVENTIX is the data controller for the personal data we collect through our services, except where we act as a data processor on behalf of another data controller (such as a console or platform provider). In such cases, the data controller will be responsible for their own privacy practices, and you should refer to their privacy policy for more information.

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AVENTIX. PRIVACY POLICY