Last Updated: November 25, 2024

WELCOME TO AVENTIX!

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

If you have any questions or concerns about this privacy policy or your personal data, please

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;

• Technical 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 use and share this information for any lawful purpose.

3. 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.

End.