MLBBEsports

LEGAL INFORMATION

GLOBAL CODE OF CONDUCT FOR MOONTON GAMES AND ESPORTS

This Code of Conduct outlines the standards of behavior we expect from everyone who engages with our games and esports events, both inside and outside of competitive play.

OVERVIEW AND ACCEPTANCE

This Code of Conduct applies to anyone who plays Mobile Legends: Bang Bang or any other a game that is published by Moonton or its affiliates, whether casually at home or competitively on the world stage. Some sections of this Code of Conduct apply to all players, while others apply specifically to esports competitions. Whether you are a player, coach, caster, or spectator, you are part of our gaming community, and a healthy community depends on fair play, mutual respect, and a shared commitment to keeping the experience safe and welcoming. This Code of Conduct outlines the standards of behavior we expect from everyone who engages with our games, both inside and outside of competitive play. This Code exists to protect our gaming community, and your compliance with its terms and conditions is a condition for your use of our games and participation in our esports events.

You accept this Code of Conduct and agree to be bound by its terms if you click “accept” when given the option to do so or if you download, access, or play any of our games, or participate in any tournament or event that features play of our games. This Code of Conduct forms part of the Terms of Service and governs your conduct whenever you interact with our games, related services, or the broader community. Your compliance with this Code of Conduct is a condition of your continued access to our games and participation in all related programs, tournaments, and events.

GENERAL PRINCIPLES

These general principles apply to all of our games and all esports events where our games are played. It’s not enough to comply with technical or specific requirements elsewhere in this Code of Conduct, you must also abide by these overarching principles.

Fair Play. You must compete honestly. Win or lose, the outcome must reflect skill, teamwork, and legitimate competition, not cheating, harassment, or manipulation.

Respect. Every participant must treat others with respect, fairness, and courtesy, whether they are competitors, fans, referees, or members of the event staff. Harassment, discrimination, threats, or abusive conduct erode the foundation of our community. Respect applies everywhere: in-game, in chat, in person, and in social media.

Accountability. You are responsible for your actions, your words, and their impact on others. If you lead or own a team, manage staff, stream to a large audience, or run an event, your responsibility is greater. You set the tone for others. Accountability means owning your conduct during play of the game, holding teammates to high standards, cooperating fully with investigations, respecting disciplinary processes, and accepting that consequences may follow not only from direct violations but also attempts to cover them up, enable them, or retaliate against those who report them.

STANDARDS OF CONDUCT FOR ALL PARTICIPANTS

These rules apply to everyone who plays our games or participates in our gaming community. Every person who engages with one of our games or its esports events must help protect the fairness, safety, and integrity of the community.

Harassment. Harassment of any kind is strictly prohibited. You must not engage in conduct that intimidates, insults, demeans, threatens, or otherwise harms another person or group. You may not use words, gestures, images, videos, emojis, objects, or any other means to transmit, promote, or facilitate messages or actions that encourage hatred, hostility, or contempt for any person or group. Harassment is prohibited everywhere, including during matches, in chat, on social media, at live events, and in any other context connected to one of our games.

Cheating. You must not use, or assist anyone in using, unauthorized software, hardware, bots, scripts, exploits, or any other method to: (1) gain an unfair advantage in our games, or (2) manipulate gameplay, game data, or game systems. You may not tamper with our anti-cheat software, bypass security protections, or help others do so.

Vulgarity. You must maintain a level of decorum and decency in all interactions related to our games. You may not use vulgar, obscene, or coarse language or engage in behavior that a reasonable person would find lewd, crude, or offensive. This includes words, gestures, usernames, profile images, voice chat, livestreams, in-game emotes, social media posts, or any other form of expression connected to our games or community.

Bad Behavior. You may not behave in any way that disrupts or diminishes the experience of others who play our games or participate in our esports tournaments and events. You must not interfere with another player’s ability to enjoy the game, access its features, or compete fairly. This includes actions such as griefing, trolling, spamming, intentional disconnections, delaying matches, exploiting systems to obstruct others, or otherwise creating an unfair or hostile environment. Everyone deserves a fair and enjoyable experience, and conduct that undermines that principle will be treated as a violation of this Code of Conduct.

Bad Content. You may not use our games, or their chat features, communication tools, or any related services to post, publish, stream, or otherwise make available content or material that: (1) promotes, glorifies, or depicts the use of illegal drugs or controlled substances; (2) is obscene, profane, pornographic, or sexually explicit; (3) is harmful to children in any way; (4) is excessively violent or depicts or promotes self-harm, harm to another person, or harm to animals; (5) is libelous, slanderous, fraudulent, defamatory, deceptive, or that gives rise to a criminal offence, civil liability, or otherwise violates any applicable law; (6) misappropriates, violates, or infringes the intellectual property, privacy, or other rights of any person or entity; (7) promotes extreme nationalism, political ideology, or divisive rhetoric or that is associated with movements that advocate national, ethnic, religious, or racial supremacy; or (8) provides unsolicited political or religious messaging. These prohibitions apply to all forms of expression connected to any of our games or communities, including in-game chat, voice communications, livestreams, social media, and user-generated content.

Impersonation. You may not use our games, their chat features, or any related services to impersonate or falsely represent yourself as another person or organization. This includes impersonating our employees or representatives, tournament organizers, or officials, as well as celebrities, streamers, influencers, or any other public or private individual or entity. You may not mislead others about your identity, affiliation, role, or authority, or create accounts, team names, or content that falsely suggests association with any person or organization.

Doxxing. You may not use our games, their chat or communication tools, or any related platform or service to post, share, threaten to disclose, or otherwise make available another person’s real-world personal information without their express permission. You may not encourage, assist, or participate in doxxing, stalking, or any similar activity intended to expose a person or endanger that person’s privacy or physical safety, whether the information you provide is accurate or not.

Scams and Solicitations. You must act honestly and in good faith in all interactions related to our games. You may not use our games or any related services to defraud others, conduct scams, solicit money or personal information under false pretenses, or attempt to obtain passwords, accounts, or other credentials through deception or phishing. You may not fabricate or falsify match results, rankings, or performance data, or spread misinformation intended to damage our reputation or the reputations of other players, teams, or officials.

STANDARDS OF CONDUCT FOR ESPORTS AND COMPETITIVE PLAY

These rules apply to everyone involved in organized esports tournaments, matches, and events, including players, coaches, team owners, team managers, referees, casters, tournament operators, talent, and any other individuals or entities participating in or supporting competitive play.

Match Fixing. You must compete honestly and to the best of your ability in every tournament, match, scrimmage, or event where our games are played. You may not attempt to influence the outcome of a match or any element of competition through deliberate underperformance, collusion, or any other coordinated behavior intended to predetermine results.

Bribes. You may not offer, request, or accept anything of value to improperly influence a tournament, match, or administrative decision related to our games or our esports tournaments or events. Bribery includes any payments, gifts, favors, services, or benefits intended to obtain preferential treatment, secure a decision, or gain an unfair advantage in a competition. You may not use intermediaries or third parties to conceal or transmit improper benefits, and you must immediately report any attempt by another person to offer or solicit a bribe.

Drugs and Alcohol. You must remain fit to compete and conduct yourself professionally at all times during tournaments, matches, and related events where our games are played. You may not possess, use, distribute, or be under the influence of illegal drugs, controlled substances, or performance-enhancing drugs at any tournament, event, venue, or activity connected to our games. You may not misuse prescription medication or share it with others. Alcohol may not be consumed before or during competitive play, and its use at official events is permitted only where expressly authorized by the tournament organizer, and only then in moderation consistent with local law and professional conduct. If an esports tournament or related event is held in a jurisdiction where alcohol consumption is restricted or prohibited, you must comply with the laws and customs of that jurisdiction. Participants must not appear intoxicated, impaired, or unfit to compete, whether in streams of gameplay or in front of spectators, broadcast audiences, or other participants.

Gambling. You may not engage in any form of gambling related to our games or any tournament, match, or event in which our games are played. This includes placing, accepting, promoting, or facilitating bets or wagers on the outcome of any match, tournament, or in-game event. You may not share inside information, match data, or other non-public information or materials that could be used for gambling or wagering purposes. You also may not participate in or promote any fantasy contests, pools, or prediction activities that offer money, prizes, or other things of value based on match results, player performance, or in-game events. These prohibitions apply to all participants, including players, coaches, team staff, officials, broadcasters, partners, and event personnel.

Public Conduct. If you participate in esports events where our games are played, you must act professionally and exercise good judgment in any public forum, whether online or in person. This includes social media, livestreams, interviews, press appearances, broadcasts, and any other form of communication associated with one of our games or its esports ecosystem. You may not use social media or other public platform to attack, ridicule, or harass other players, officials, fans, teams, sponsors, or partners. Honest criticism and humor are part of gaming culture, but when expression crosses into personal attacks, discrimination, hate speech, or incitement to violence it violates this Code of Conduct.

DISCIPLINARY PROCESS AND ENFORCEMENT

Decisions of Referees and Tournament Officials. Referees, judges, and tournament administrators are responsible for ensuring fair play, enforcing tournament rules, maintaining order, and protecting the integrity and safety of competition. They have full authority to interpret and apply rules, resolve disputes, assess penalties, determine match outcomes, and make any other rulings necessary to conduct an event. Decisions made by referees, judges, and tournament administrators during a competition are final, binding, and not subject to appeal or further review. All participants must comply immediately with their instructions and rulings. Failure to respect or follow an official’s decision may result in additional disciplinary action under this Code of Conduct.

Reporting Obligations. If you witness or experience conduct that violates this Code of Conduct, the Terms of Service, tournament rules, or any other applicable policy, you must promptly report it through the designated in-game reporting tools, official event channels, or any other reporting process established by the tournament organizer. Reports should be made in good faith and supported with accurate information. False, malicious, or bad-faith reports are themselves violations of this Code of Conduct.

Investigations. We may investigate any conduct that may violate this Code of Conduct, the Terms of Service, or any other applicable policy. Our investigations may include reviewing gameplay data, chat logs, communications, public statements, social media activity, video footage, or any other relevant information. We may also engage a qualified third party to conduct investigations on our behalf, and you agree to cooperate fully with any our designated representative. You agree to respond truthfully and provide accurate information when asked to assist in an investigation. You may not withhold, alter, or destroy information, or attempt to influence the testimony or cooperation of others. You are expected to respect the confidentiality of the investigation process and may not disclose, discuss, or publicize any investigation or disciplinary matter except as authorized by us or required by law. We may impose interim measures, such as a temporary suspension or removal from an event, while an investigation is pending.

Cooperation with Investigations. Failure to cooperate with an investigation, providing false or misleading information, or violating confidentiality requirements may be treated as separate and serious violations of this Code of Conduct, subject to additional disciplinary action.

Findings. When an investigation is complete, we will review the available evidence and determine whether a violation of this Code of Conduct, the Terms of Service, or any other applicable policy has occurred. Our decision will be based on the totality of the information available to us and may be made in consultation with tournament organizers, event partners, or third-party investigators engaged on our behalf. We may communicate the outcome of the investigation to the participants involved and, when appropriate, to other affected parties or the public.

Sanctions. If we determine that a violation has occurred, we may impose one or more sanctions appropriate to the circumstances. Sanctions may include: (1) a verbal or written warning; (2) temporary or permanent suspension of game accounts or online services; (3) disqualification from tournaments, matches, or events; (4) forfeiture of prizes, points, or standings; (5) removal from official programs, leagues, or partner networks; (6) revocation of titles, rankings, or achievements earned through misconduct; (7) temporary or permanent bans from the game, esports competition, or related activities; and (8) termination of agreements or contracts connected to the game or our esports leagues or events. We may also require corrective actions, such as apologies, training, or other remedial measures, as a condition of continued participation. The severity of any sanction will depend on factors such as intent, impact, prior conduct, and cooperation during the investigation. All enforcement decisions and sanctions we issue are final and binding and may be implemented immediately without further notice or process. You acknowledge that the enforcement measures described above are reasonable and necessary to maintain a safe, fair, and positive gaming environment.

Public Disclosures. If you are an esports professional, you acknowledge and agree that we may issue public warnings or reprimands and that any sanction imposed under this Code of Conduct or the Terms of Service may be disclosed to the public and discussed by us in public in order to provide guidance to the community. Once a sanction is imposed, you may discuss it publicly in a professional and respectful manner, provided that any such discussion complies with the General Principles in this Code of Conduct and does not misrepresent the facts, attack others, or undermine the integrity of the disciplinary process.

Expedited or Emergency Enforcement Procedures. We will use commercially reasonable efforts to follow the procedures set forth in this Section when investigating suspected violations of this Code of Conduct or the Terms of Service and determining and applying any resulting sanctions. Notwithstanding the foregoing, you acknowledge that certain circumstances may require our immediate action. Accordingly, we reserve the right, in our sole discretion, to take appropriate enforcement action against any user whose conduct we determine to be materially disruptive to, harmful to, or otherwise detrimental to the game, its services, or its community, whether or not that conduct is expressly described in this Code of Conduct. In such circumstances, we may, without prior notice, issue warnings, restrict or suspend account access, terminate accounts, remove content, reset or revoke in-game progress or entitlements, or implement any other corrective or protective measures we deem necessary or appropriate to safeguard the game and its users.

ADMINISTRATION AND UPDATES

Terms of Service and Other Rules. You are required to comply at all times with our Terms of Service, tournament-specific rules, and any other agreements, policies, or regulations that apply to your use of our games or your participation in our esports events. Each of these documents is binding and enforceable on its own, and a violation of any of them is also a violation of this Code of Conduct. You may be subject to disciplinary action under this Code of Conduct in addition to, and separate from, any actions or other consequences established in the Terms of Service or other applicable policies. If your conduct violates more than one policy, we may take action under any or all of them. In the event of a conflict between this Code of Conduct and another applicable policy, we will determine which provision governs, taking into account the nature of the conduct, the context in which it occurred, and the needs of the community. You are also required to comply with all applicable laws and regulations in every jurisdiction where you play or compete, and nothing in this Code of Conduct limits our right to enforce other agreements or exercise additional remedies available under law.

Contracts. If this Code of Conduct is incorporated, linked, referenced, or attached to any contract, a violation of this Code of Conduct will constitute a breach of that contract.

Updates. We may update or replace this Code of Conduct from time to time to reflect changes in our games, community standards, or applicable law. When material updates are made, we will provide notice through appropriate means, such as in-game notifications, website postings, or announcements in tournament materials. Any update will take effect when published unless a later effective date is stated, and your continued use of our games or participation in any tournament or event after that date constitutes your acceptance of the revised version. In some cases, you may be required to review and affirmatively accept the updated Code of Conduct, such as by clicking to agree, before continuing to play or participate. If you do not agree to any updated version of this Code of Conduct, you must stop using our games and may not take part in any of our esports tournaments or related activities.

LEGAL INFORMATION

MOONTON GAMES GLOBAL PRIVACY POLICY

This Global Privacy Policy explains what personal information we collect, why we collect it, how we use and protect it, and what rights you have over it, wherever in the world you are.

OVERVIEW AND SCOPE

Moonton is made up of several different legal entities around the world. This Privacy Policy applies to Services offered by YoungJoy Technology Limited and Vizta Pte. Ltd. (collectively, “Moonton”, “we”, or “us”). Moonton is a global video game company dedicated to gaming development, publication, and esports. We’re the publisher behind the global blockbuster game Mobile Legends: Bang Bang and bold titles like Mobile Legends: Adventure, Acecraft, Silver and Blood, Magic Chess: Go Go, Watcher of Realms.

The data you share with us, either directly or through your use of our games, services or events, carries obligations we do not take lightly, and this Global Privacy Policy (“Policy”) explains what we collect, why we collect it, how we use and protect it, and what rights you have over it, wherever in the world you are.

This Policy applies to all of the businesses that operate under the Moonton brand and covers the full range of ways we interact with the people who play our games, use our websites and other services, and attend our events. It governs all video games developed or published by Moonton, regardless of the platform or storefront through which those titles are distributed. It also covers all esports competitions, tournaments, and leagues organized, hosted, co-hosted, or sponsored by or on behalf of Moonton or its affiliates, as well as all live events, fan conventions, community programs, and promotional activations associated with Moonton or its brands, whether held in person or online.

If you play one of our games, watch or compete in one of our events, or otherwise engage with any Moonton product or service, this policy applies to you.

Each of our games, and their related mobile apps, websites, software, and live gaming service, is referred to in this Policy as a “Game”. By accessing or using a Game or attending, participating, or competing in one of our live or online events (“Events”), you acknowledge that you have read this Policy and that you understand your rights in relation to your personal information and how we will collect, use and process it.

WHAT PERSONAL INFORMATION WE COLLECT

When you use our Games, we collect personal information from you and about you. This may include:

Identifiers. This includes your Moonton game user IDs and passwords, your email address, your profile photo (if you choose to provide one), and any other profile information you may choose to provide.

Characteristics of Protected Classifications. This includes your gender, birthday and/or age, and any information you provide to help us confirm your identity or verify your age.

Commercial Information. This includes your Moonton account activity such as surveys and messages.

Internet or other Electronic Network Activity. This includes technical information about the device you use to access our Games, such as your device type, and information related to usage of our Games such as information collected via your gameplay and other in-game interaction records.

Location Information. This includes approximate location from the IP address from which you are accessing our Games.

Sensitive Personal Information. With your consent, and in accordance with the laws of your jurisdiction, we may gather precise location data (such as GPS), as defined under certain privacy laws.

Audio Information. This includes recordings from conversations with our customer service representatives and in-game voice chats between players during matches. Where required by applicable law, we will obtain consent and apply appropriate safeguards before using audio data to identify your biometric characteristics.

Additional Contact and Payment Information. This includes additional information collected strictly on an as-needed basis for specific scenarios, including high-value prize fulfillment or offline event participation. The information collected may include first and last names, contact details beyond what is noted above, shipping addresses, and payment information. Further information may also be collected for specific events as notified via activity-specific rules.

Other Necessary Information. On a case-by-case basis, we may collect additional information that is necessary for providing and operating our Games. In such cases, we will notify you of the additional information to be collected and, if required by applicable laws and regulations, further obtain your consent before processing such information.

HOW WE COLLECT YOUR PERSONAL INFORMATION

We collect your personal information in three ways: Information You Provide, Automatically Collected Information, and Information From Other Sources.

Personal Information You Provide

Profile and Account Information. When you log in as a Guest, we may collect personal information such as your Guest ID, nickname and any other optional data you choose to provide on your personal profile page, such as your selected avatar, gender or country. This information is entirely voluntary and is used to improve your gaming experience. If you choose to register a full game account (“M Account”), we will collect additional personal information depending on the login method you select. For example, if you register using your email address, we will collect your email, password, and User ID. If you choose to log in via a third-party platform (e.g., Google, Apple, GameCenter, TikTok, Facebook, Telegram, X, or WhatsApp, as applicable), we may collect your platform-specific user ID and other information authorized by that platform. You may also choose to link your Guest account to an M Account at any time, which will allow you to save your game progress and access your account across devices.

Surveys. We collect information through surveys, challenges, and competitions in which you may participate, including gender, likeness, age and preferences.

Messages. If you communicate with others using direct messages, we may collect the content of the message and information about when the message has been sent, received and/or read, as well as the participants of the communication. We do this to block spam, detect crime, and to safeguard our users.

User Content. We may also collect the content you create or publish using tools provided with the Games, such as on the games’ message boards and chat rooms. This content may include texts or voice chats (“User Content”). Any actions you perform with other players are considered public and are solely at your discretion. You should be aware that any personal information you submit in the course of these public activities can be read, collected, or used by other users of the Games.

Information When You Contact Us. We also collect information and content of messages you provide to us through your feedback such as product reviews you write, or questions and information you provide for customer support. When you contact us, such as for customer support, phone conversations or chat sessions, communications with our representatives may be monitored and recorded.

Purchase Information. When you make a purchase or payment on or through a Game, we collect information about the purchase or payment transaction.

Your Contacts. If you choose to find other users through your social network contacts, we will collect your public profile information as well as names and profiles of your social network contacts.

Automatically Collected Personal Information

Technical Information. We automatically collect certain information about the device you use to access a Game, including device-related information (such as device ID, device brand, device model, Mac address, IMEI, IMSI, Android ID, IDFA, IDFV, GAID, and SIM card status), security-related information (such as installed APK names and external plugin programs), network-related information (such as Wi-Fi status, BSSID, IP address, operating system, network environment, and crash logs). Where you log-in from multiple devices, we may use your device-related information to identify your activity across devices to give you a seamless log-in experience and for security purposes.

Usage Information. We automatically collect information about how you engage with a Game, including the duration and frequency of your use and your settings. This includes information collected about your use of each specific Moonton game on your device and your activity on our game servers.

Cookies. We and our service providers and business partners may use cookies and similar tracking technologies (e.g., web beacons, flash cookies, etc.) (“Cookies”) to automatically collect information and to measure and analyze how you use a Game, including to understand how you interact with content, to enhance your experience using a Game, to improve the Game, to provide you with advertising, and to measure the effectiveness of advertisements and other content. We and our partners also use Cookies to promote the Games on other platforms and websites. Cookies enable the Games to provide certain features and functionality. We will obtain your consent to our use of Cookies where required by law.

Location Information. We may automatically collect information about your general location, which could include data based on your SIM card and/or IP address. With your consent, and in accordance with the laws of your jurisdiction, we may also gather precise location data (such as GPS). You can manage the sharing of your location information by adjusting your device's settings.

Personal Information from Other Sources

Third Party Platforms. We may receive information, including the following, from third party sources and combine it with the information we already directly and automatically collect from you:

Third party platforms may provide us with information (such as your user ID, user token, and your email address if linked to your accounts), when you choose to sign up for or log in to a Game using features provided by those third parties.
If you log in via a social media account, your profile picture and nickname from that account may be set as your default profile picture within our Games. You have the option to customize your profile picture at any time.
Other game, social media, or other information, from those third parties you link your account with, or who provide information to service our Games.
Information from other users, for example if those users have given us access to their profiles and if you are one of their connections, or information about you that is otherwise made accessible to us by them.
Information from third parties as appropriate given our relationship, for example from anti-fraud service providers we might obtain fraud risk scores; from law enforcement or partners, we might obtain IP addresses and details of suspected unlawful or malicious activity.

Payment and Transaction Fulfillment Providers. We receive information about you from payment and transaction fulfillment providers, such as payment confirmation details, including the purchases you make and the amount spent.

HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information to operate, provide, develop, and improve our Games, including for the following purposes.

Provide, operate, and administer the Games, such as enabling you to create, share, and consume content, to interact with other users, and provide user support.
Enable you to purchase virtual items and complete the related payment transactions.
Enforce our Terms of Service, Code of Conduct, this Policy, guidelines, and other policies that apply to you. We review user generated content and other information to protect the safety and well-being of our community.
Allow you to participate in social and interactive features of the Games.
Provide and improve our advertising initiatives, including to serve ads (including personalized ads, where permitted) and to measure and understand the effectiveness of the ads and other content. We may target and personalize our marketing communications and advertisements that we display based the information we have collected about you.
Maintain and enhance the safety, security, and stability of the Games by identifying and addressing technical or security issues or problems (such as technical bugs, spam accounts, and detecting abuse, fraud, and illegal activity) in order to help protect you or others. We may also use the information we have collected about you to identify fraudulent activity, prevent abuse of and/or prosecute any potential threat to or misuse of our Games, or protect your account from unauthorized access.
Detect breaches and enforce our Terms of Service, this Policy, and other applicable policies.
Review, understand, improve, enhance, and develop the Games, including by reviewing and analyzing interactions and usage across your devices.
Promote the Games or third-party services through marketing communications, contests, or promotions.
Comply with our legal obligations, for auditing or compliance purposes, or as necessary to perform tasks in the public interest, or to protect the vital interests of our users and other people.
Notify you about changes to the Games and send Game-related communications to you including information regarding other games that may interest you.

HOW WE SHARE YOUR PERSONAL INFORMATION

Service Providers

We engage service providers that help us develop a Game, provide support, and understand how the Game is used. These service providers may provide services such as cloud hosting, content delivery, customer and technical support, content moderation, marketing, analytics. Our service providers may include financial organizations who support online payment and carry out credit and anti-fraud checks. We may share your information with these service providers as necessary to enable them to provide their services.

Business Partners

Third Party Platforms. We share limited information with third party platforms whose platforms or services are integrated with the Games. We do this to give you a seamless experience, allow your content to be shared on other platforms, and/or enable third party platforms and partners to better authenticate users. Some examples include if you:

Sign-up or log-in to the Games using your account details from a third-party platform. We will share certain Technical Information to facilitate this.
Share User Content you publish on using the tools provided by a Game on other social media platforms.
We use the live streaming service provided by YouTube within the Games. We will collect and share certain technical information with YouTube to facilitate this. Note that while we collect your "sVideoId", a unique identifier associated with each video streamed within the platform, for these purposes, we will promptly delete this information at the conclusion of the live stream or, if that is not feasible, within a day of collection. YouTube will collect and process your information in accordance with YouTube’s Terms of Service available at https://www.youtube.com/t/terms and Google’s Privacy Policy available at https://policies.google.com/privacy.

Advertising and Analytics Partners. We may share information collected through your use of a Game with our advertising or analytics partners. These partners help us to display advertising to you on the Games and to promote the Games through advertising displayed on other platforms, some of which, in some jurisdictions, may be based on your activity across other sites and services. These partners may also help us and our partners measure the effectiveness of our advertising campaigns.

Our Corporate Group

As a global company, the Games are supported by certain entities within our corporate group (“Corporate Group”). These entities may process your information, as necessary to provide certain functions, such as storage, content delivery, security, research and development, analytics, online payments, customer and technical support, and content moderation.

Others

We share your information in other limited scenarios as follows:

Other Users. Your profile information and User Content may be visible to other users. Your profile and content may also be visible to third parties. You and other individuals may be able to share your User Content both on and off the Games, depending on the choices you make on your device or in the Games.

Corporate Transactions. Your information may be disclosed to third parties and business transfer partners in connection with a corporate transaction or restructuring, such as a merger, divestiture, sale of assets or shares, reorganization, financing, change of control, or acquisition of all or a portion of our business.

Legal Obligations and Rights. We may access, preserve, and share your personal information with law enforcement agencies, public government authorities, copyright holders, or other third parties if we have good faith belief that it is necessary to:

comply with any applicable laws, regulations, codes of practice, governmental guidelines, or other legal and regulatory obligations, or to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims, or government inquiries, as consistent with internationally recognized standards,
protect the rights, property, and safety of our users, copyright holders, and others, including to protect life or prevent imminent bodily harm. For example, we may provide information (such as your IP address) to law enforcement in the event of an emergency where someone’s life or safety is at risk,
investigate potential violations of and enforce our Terms of Service, Code of Conduct, this Policy, guidelines, or any other applicable terms, policies, or standards,
support the security of our Games, fraud prevention, or to protect personal information, or
detect, investigate, prevent, report, or address misleading activity, copyright infringement, or other illegal activity.

With Your Consent. We may share personal information with the proper authorization or to provide the Games you have requested or authorized.

Third-Party Content. The Games may contain links to policies, functionality, or content maintained by third parties who we do not control. We are not responsible for, and make no representations regarding, such policies, functionality, or content or any other practices or operations of such third parties. If there are links to third party websites, please note that these websites are governed by their own Terms and Conditions and Privacy Policies.

YOUR PRIVACY RIGHTS AND CHOICES

Depending on where you live, you may have certain rights with respect to your personal information, such as a right to know and be informed on how we collect and use your personal information. You may also have a right to access, modify, update, rectify, provide, erase, restrict and change your data, oppose its processing, request a copy of your authorization, file complaints before the competent authorities, consent and withdraw your consent, limit our collection and use of your personal information, request that we implement measures to protect your personal information, request that we delete it, and potentially others.

Please note that your exercise of certain rights may impact your ability to use some or all of Moonton’s features and functionalities. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

If you have registered for an account, you may also access, review, and update certain personal information that you have provided to us by logging into your account and using available features and functionalities.

Please send an email to [email protected] if you would like to exercise any of your rights. We will respond to and handle your request consistent with applicable law of your jurisdiction and subject to proper verification.

In addition:

You may be able to refuse or disable Cookies by adjusting your browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies. For example, due to differences in how browsers and mobile apps function, you may need to take different steps to opt out of Cookies used for personalized advertising in a browser and to opt out of personalized advertising for a mobile application, which you may control through your device settings or mobile app permissions. In addition, your opt-out selection is specific to the particular browser or device that you are using when you opt out, so you may need to opt-out separately for each browser or device. If you choose to refuse, disable, or delete Cookies, some of the functionality of the Games may no longer be available to you.
You may opt out of receiving advertising and/or marketing communications by following the instructions in such communications or by using options that may be available to you in your app settings.
Your mobile device may include a feature that allows you to opt out of some types of personalized advertising (“Limit Ad Tracking” on iOS and “Opt out of Interest-Based Ads” on Android).
If you have used the YouTube live streaming service in our games or have used your Google account to log in or sign up for the Games, you may exercise choices related to our access to your data through the Google Security settings, available at https://security.google.com/settings/security/permissions.

DATA SECURITY AND RETENTION

Security of your information is important to us. We maintain appropriate technical, administrative, and physical security measures that are designed to protect your information from unauthorized access, theft, disclosure, modification, or loss. We regularly review our security measures to consider available new technology and methods. However, the internet is not 100% secure. We cannot promise that your use of our Games will be completely safe. We encourage you to use caution when using our Games and protect your user ID and passwords.

We retain information for as long as necessary to provide a Game and for the other purposes set out in this Policy. We may also retain information when necessary to comply with contractual and legal obligations, when we have a legitimate business interest to do so (such as improving and developing the Games, and enhancing their safety, security and stability), to enforce our agreements, and for the exercise or defense of legal claims.

INTERNATIONAL DATA TRANSFERS

Although we store the information we collect in secure servers located in different countries and territories, such as the United States, the European Union, Brazil, Hong Kong, Japan, India, Indonesia, the United Arab Emirates and Singapore, the personal information we collect from you may be stored on a server located outside the country where you live. If we transfer any personal information out of the country where you live, including for one or more of the purposes as set out in this Policy, we will do so in accordance with the requirements of applicable data protection laws and will ensure there are adequate safeguards in place when transferring your information outside your country. By using one of our Games or providing us with any information through it, you acknowledge this transfer, processing, and storage of your information in these countries in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen.

INFORMATION RELATING TO MINORS

Our Games are not directed at children under the age of 13 in some jurisdictions. The minimum age to use the Games may differ depending on the country or region you are in. If you believe that we have collected personal information from a minor under the digital age of consent, please contact us at [email protected].

We are committed to respecting children's privacy. We will not collect personal information from anyone we have actual knowledge is under the age of 13 (or the age otherwise specified in the Jurisdiction-Specific Supplemental Terms below), without a parent's consent. We do not share the personal information of children who we have actual knowledge are under the age of 16 for delivery of advertising purposes. If you are creating an account for your child, we recommend that you and your child read our Privacy Information for young players to help them understand how we handle their personal information and their rights over their personal information.

With parental consent, we will collect, use and share information collected from or about children in accordance with the practices described in this document, with the following exceptions:

We do not use personal information collected from children for behavioral or targeted advertising purposes.
We do not sell personal information collected from children, and we do not share such information with third parties for their own marketing purposes.
We collect only the minimum personal information reasonably necessary to enable participation in the Games and will not condition a child’s participation on the disclosure of more personal information than is reasonably necessary.
Parents or guardians may review the personal information we have collected from their child, request deletion of such information, and refuse to permit further collection or use of their child’s information by contacting us at [email protected]. We will take reasonable steps to verify the identity of anyone requesting information about a child.
In order to ensure compliance with this Policy for matters relating to minors, please read the jurisdiction-specific terms and conditions set out herein, where applicable.

PRIVACY POLICY UPDATES

We may amend or update this Policy from time to time. When we update the Policy, we will notify you of any material changes to this Policy by updating the “Last Updated” date at the top of the new Policy, posting the new Policy, or providing any other notice required by applicable law. Your continued use of a Game following the posting of changes to this Policy means you accept these changes. We recommend that you review this Policy from time to time to stay informed of our privacy practices.

CONTACT US

For questions, comments and requests regarding this Policy, please contact us at [email protected], unless specified below in the jurisdiction-specific supplemental terms below.

JURISDICTION-SPECIFIC SUPPLEMENTAL TERMS: ASIA-PACIFIC

If you are using the Games in the following jurisdictions, the respective jurisdiction-specific terms below would additionally apply. In the event of a conflict between the provisions of the Supplemental Terms–Jurisdiction-Specific that are relevant to your jurisdiction from which you access or use the Games, and the rest of this Policy, the relevant jurisdictions’ supplemental terms as disclosed in the sections below will supersede and control.

asia-pacific jurisdictions

Australia

The personal information that we collect about you may be transferred to, and stored at, a destination outside of Australia. The countries to which your personal information is likely to be disclosed are Singapore and the United States of America.

The following shall replace Section 10 (Contact Us):

If you have any questions about the Privacy Policy, would like to complain about a breach of the Australian Privacy Principles, or are concerned about the handling of your personal information, please contact the privacy officer at [email protected].
You have the right to access your personal information and seek correction of it. Please contact the privacy officer using the details provided in Section 5 of this Privacy Policy (Your Privacy Rights and Choices) if you wish to access your personal information and/or seek correction of your personal information.
If you make an enquiry or complaint with us, we will review and respond to you within a reasonable timeframe. Our aim is to respond to complaints and enquiries within 30 days, although in some cases an outcome may take longer. If you are not satisfied with the response or do not receive a response within a reasonable timeframe, you may have a right to complain to the Australian privacy regulator, the Office of the Australian Information Commissioner (OAIC). Current contact details for the OAIC are available on the OAIC's website at www.oaic.gov.au.

India

If you are using our Games in India, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall prevail.

Grievance Officer For India. In accordance with Information Technology Act 2000 and rules framed thereunder, a Grievance Officer has been appointed and a complaint or other issue faced by a user of our platform or other issue faced may be submitted through the email provided in the “Contact Us” section.

The complaint should provide: (i) username of the relevant account holder (ii) specific content that is of concern and (iii) reason(s) for the request.

Information Relating to Children. We do not knowingly collect personal information from individuals under the age of 18. If you indicate that you are under 18, we will seek verifiable consent from your parent or legal guardian before providing you access to the Games, unless otherwise permitted by applicable law.

Concerns. If you have a concern with respect to the manner in which we have handled your personal information, you have a legal right to approach the Data Protection Board of India. However, we encourage you to first contact us in the manner specified in this Policy, to allow us an opportunity to address your concerns.

South Korea

If you are using the Games in South Korea, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this policy, the following terms shall prevail.

How We Use Your Personal Information. In addition to the main text of this Policy, we intend to use your personal information (email address) to send you promotional messages concerning new products, features, enhancements, special offers, upgrade opportunities, contests and events of interest in relation to the Games. We require your express consent before we do so.

Types of Personal Information Collected and Purpose of Collection. We collect and use your personal information based on the following lawful bases under the Korean Personal Information Protection Act (“PIPA”).

We collect and use the below types of personal information with your consent:

Types of Collected Personal Information	Purpose of Collection	Period of Retention and Use	Legal Basis
Contact Information and Identifiers/Account Registration Information, Account Information, Date of Birth, Connected Social Media Account Information (Third Party), Personal Profile Information	• Account registration	Until account deletion	Article 15(1)(i) of the PIPA (Consent of the Data Subject)
Contact Information and Identifiers/Account Registration Information, Account Information, Game Data, IP address & Device Data, Advertising Information, Inferences	• Allow you to participate in social and interactive features of the Games. • Allow you to participate in Events. • Provide and improve our advertising initiatives, including to serve ads (including personalized ads, where permitted) and to measure and understand the effectiveness of the ads and other content. We may target and personalize our marketing communications and advertisements that we display based the information we have collected about you.	Until account deletion
Account Information, Date of Birth, Game Data, User Generated Content, User Service Information, Survey Information, Activity Participation Information, IP address & Device Data, Advertising Information, Payment Data, Inferences	• Review, understand, improve, enhance, and develop the Games, including by reviewing and analyzing interactions and usage across your devices. • Promote the Games or third-party services through marketing communications, contests, or promotions.	Until account deletion
Contact Information and Identifiers/Account Registration Information, Account Information, Game Data, Activity Participation Information, IP address & Device Data, Advertising Information, Inferences	• Notify you about changes to the Games and send Game-related communications to you including information regarding other games that may interest you.	Until account deletion

We collect and use the below types of personal information without your consent for the purposes below:

Types of Collected Personal Information	Purpose of Collection	Period of Retention and Use	Legal Basis
Account Information, Personal Profile Information, Connected Social Media Account Information (Third Party), Game Data, Chat Data, User Generated Content IP address & Device Data, Contact Information, Payment Data	• Provide, operate, and administer the Games, such as enabling you to create, share, and consume content, to interact with other users, and provide user support. • Enable you to purchase virtual items and complete the related payment transactions. • Enforce our Terms of Service, Code of Conduct, guidelines, and other policies that apply to you. We review user generated content and other information to protect the safety and well-being of our community.	Until account deletion	Article 15(1)(iv) of the PIPA (Fulfilment of Contract)
Contact Information and Identifiers/Account Registration Information, Account Information, Date of Birth, Connected Social Media Account Information (Third Party), Personal Profile Information, Game Data, Chat Data, User Generated Content, Malicious Content Information, User Service Information, Survey Information, Activity Participation Information, IP address & Device Data, Advertising Information, Payment Data, Inferences	• Maintain and enhance the safety, security, and stability of the Games by identifying and addressing technical or security issues or problems (such as technical bugs, spam accounts, and detecting abuse, fraud, and illegal activity) in order to help protect you or others. We may also use the information we have collected about you to identify fraudulent activity, prevent abuse of and/or prosecute any potential threat to or misuse of our Games, or protect your account from unauthorized access. • Detect breaches and enforce our Terms of Service.	Until account deletion	Article 15(1)(vi) of the PIPA (Legitimate Interest)
Contact Information and Identifiers/Account Registration Information, Account Information, Date of Birth, Connected Social Media Account Information (Third Party), Personal Profile Information, Game Data, Chat Data, User Generated Content, Malicious Content Information, User Service Information, Survey Information, Activity Participation Information, IP address & Device Data, Advertising Information, Payment Data, Inferences	• Comply with our applicable legal obligations, for auditing or compliance purposes, or as necessary to perform tasks in the public interest, or to protect the vital interests of our users and other people.	Until account deletion	Article 15(1)(vi) of the PIPA (Legitimate Interest)

Data Retention. We destroy personal information whose purpose of collection as consented to by you have been achieved, or whose periods of and use to which you consented to or which were provided in this privacy policy have expired; provided, however, we will continue to store your personal information for the following statutorily-prescribed periods, where applicable, including, but not limited to:

Act on Consumer Protection in Electronic Commerce:

Records on your cancellation of an order, your payment on a purchased item, and our supply of a good/service: 5 years

Records on the handling of consumer complaints or disputes: 3 years

Records on advertisements and labels: 6 months

Protection of Communications Secrets Act:

Records on your visits to our website: 3 months

Destruction of Your Personal Information. Subject to applicable retention requirements, we will promptly destroy your personal information in our possession once we achieve the purpose of collection and use of your personal information. Your personal information will be destroyed after storage for a certain period pursuant to our internal policy or applicable laws and regulations (please refer to the provisions on retention and use period). When we no longer need to use your personal information, we safely and securely destroy such information, according to the procedures and methods of destroying personal information as set forth below:

Destruction Procedure: We select the personal information for which needs to be destroyed, and destroy the personal information with the approval of our Chief Privacy Officer.
Destruction Method: We destroy personal information recorded and stored in electronic files so that the records cannot be reproduced, and destroy personal information recorded and stored in paper documents by the way that are not feasible to restore, such as dissolution, shredding or incineration.

Data Rights. You (or your legal guardian) have the right to access personal information we hold about you, to rectify any personal information held about you that is inaccurate, to request the deletion of personal information held about you, and the right to request the suspension of the processing of your personal information. You (or your legal guardian) can exercise such rights by contacting us at the information listed in the “Contact Us” of this Policy.

Data Security. We work hard to protect our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. To this end, we have in place technical, managerial and physical safeguards, including internal policy for data protection, limiting the access to personal information on a need-to-know basis and controlling access to the facilities where personal information is processed.

Information Relating to Children. The Games are not directed at children under the age of 14 and we do not knowingly collect or solicit personal information from children under 14. If you believe that we have personal information about or collected from a child under the relevant age, please contact us at [email protected] and we will ensure that it is deleted. For children under the age of 14, their legal guardians have the right to exercise the rights of their children with respect to data protection.

Entrustment and/or Overseas Transfer of Personal Information. We entrust your data to our affiliates, cloud storage providers, IT service providers, and data centers, some of whom are located abroad, subject to your consents or notifications to you, if applicable. The entities receiving and processing your data are committed to using and storing personal information in compliance with domestic and international regulations and to taking all available physical and technical measures to protect personal information. You may opt-out of such transfer so long as the transfer is not necessary to provide you with the Game, by contacting us at the information listed in the “Contact Us” section

Privacy Department. Our Privacy Department oversees the processing of your personal information and handles complaints and remedies related to such processing. For inquiries related to personal information processing, you may contact the Privacy Department as follows:

Email: [email protected]

Philippines

If you are using our Games in the Philippines, the following additional terms shall apply pursuant to the Data Privacy Act of 2012 (Republic Act No. 10173) and all relevant laws, rules and regulations and issuances by the Philippines National Privacy Commission (“NPC”) on data privacy.

Your Rights. To the extent that the relevant laws, rules and regulations on data privacy recognize your rights and freedoms as data subjects, you shall have the right to information, object, access, rectification, erasure or blocking, lodge complaints before the NPC, damages and data portability. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

Contact Us. If you have any questions about the Privacy Policy, or would like to complain about a violation of the Data Privacy Act of 2012, or are concerned about the handling of your personal information, please contact the data protection officer (DPO) at [email protected]. You have the right to access your personal information and seek correction of it. Please contact the DPO on the details provided in this Privacy Policy if you wish to access your personal information and/or seek correction of your personal information. If you are not satisfied with the response or do not receive a response within a reasonable timeframe, you have the right to file a complaint with the National Privacy Commission (NPC). Current contact details for the NPC are available on the NPC's website at www.privacy.gov.ph.

Indonesia

If you are using the Games in Indonesia, the following additional terms apply in accordance with Indonesia’s Personal Data Protection Law (Law No. 27 of 2022) (the “PDP Law”). In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall prevail.

Legal Bases for Processing. For users in Indonesia, we process personal information only where permitted under the PDP Law, including where we have obtained your express consent for specific purposes, where processing is necessary to fulfill contractual obligations, comply with legal requirements, protect your vital interests, serve the public interest, or pursue legitimate interests permitted by applicable law.

Your Rights. Subject to applicable law, you have the right to receive clear information regarding the identity of the party requesting personal information, the legal basis and purposes of processing, and the accountability of the party collecting the data; to complete, update, and correct your personal information; to access and obtain a copy of your personal information; to end processing and request deletion or destruction of your personal information; to withdraw consent; to object to decisions based solely on automated processing, including profiling, that produce legal effects or significant consequences for you; to restrict or postpone processing; to seek compensation for unlawful or improper processing; and to obtain and use your personal information in a structured, commonly used, and system-readable format and transmit it to another controller where the applicable systems can securely exchange the information.

Requests and Complaints. You may exercise your rights by submitting a written request, electronically or in physical form, to us using the contact information in the “Contact Us” section. You may also submit rights-related complaints to the Indonesian data protection authority or other competent authority in accordance with applicable law.

Cross-Border Transfer of Personal Information. If we transfer personal information from Indonesia to a recipient outside Indonesia, we will ensure that the recipient country provides a level of personal information protection equivalent to or higher than the protection required under the PDP Law or, where that is not available, ensure adequate and binding safeguards. If neither condition is met, we will obtain your explicit consent to the transfer where required under applicable law.

Age, Parental and Guardian Consent. Children’s data is specific personal information under applicable Indonesian law. By accessing and/or using the Games, you represent that you are at least 18 years of age. To verify your age (where applicable) or obtain your parent or guardian’s consent, we may collect the following personal information:

your Nomor Induk Kependudukan (“NIK”) number for age verification;
Facial Age Estimation data, if NIK-based verification is unavailable or unsuccessful; and
your parent’s or guardian’s email address, for the purpose of notifying them and obtaining their consent where required.

If you are under 18 years of age, you may be subject to parental or guardian consent, authorization, supervision, or control, as required by applicable law and our age-verification mechanism. If you do not have the required consent from your parent(s) or legal guardian(s), you must cease accessing or using the Games.

Where required, minors will continue to use their own accounts, subject to any applicable parental or guardian consent, authorization, supervision, or parental controls made available through our age-verification system.

Your Choices. You may withdraw your consent to Moonton’s disclosure of personal information to third parties. Upon your request, we will cease to display, publish, transmit, disseminate, and/or open the access to your personal information to third parties. Please note that by withdrawing your consent to the disclosure and/or collection of your personal information, we may not be able to fulfill your requests and you may not be able to use some features and functionality of the Games.

You may request Moonton to (i) disclose the history of personal information that we have collected; and/or (ii) erase and dispose of your personal information that we have collected on our server. Please note that by requesting us to erase and dispose of your personal information, you may not be able to use some features and functionality of the Games. To exercise any of your rights, contact us at the information listed in the “Contact Us” section.

Data Breach. In the event of a personal information protection failure affecting you, we will notify you and the Indonesian data protection authority within 72 hours as required by applicable law, and the notice will include the information required under the PDP Law.

Data Retention. We retain your information for as long as it is necessary to provide you with the service. Where we do not need your information in order to provide the service to you, we retain it only for so long as we have a legitimate business purpose in keeping such data. However, there are occasions where we are likely to keep this data for five (5) years (or longer if required) in accordance with our legal obligations or where it is necessary for the establishment, exercise or defense of legal claims.

After you have terminated your use of our Games and the five (5) years retention period has lapsed, we store your information in an aggregated and anonymized format. Non-personally identifiable information may be retained indefinitely for analytics.

DPO Requirements. Where required under the PDP Law, we will appoint a Data Protection Officer to oversee data protection compliance and serve as a liaison for data protection matters.

JURISDICTION-SPECIFIC SUPPLEMENTAL TERMS: EUROPEAN REGION (EEA, SWITZERLAND & UK)

If you are using the Games in the EEA, Switzerland, or the UK (the “European Region”), the following additional terms apply.

Legal Bases for Processing

We use your personal information only as permitted by law. Our legal bases for processing your personal information are listed in the table below:

Processing Purpose	Legal Basis for Processing
We use the “Information You Provide”, “Automatically Collected Information”, and “Information From Other Sources”, for example: Profile and Account Information; User Content and Usage Information; Messages; Purchase Information; Location Information; and Technical Information to provide and administer the Games, such as enabling you to create, share, and consume content, to interact with other users and allow you to participate in social and interactive features of the Games.	Processing is necessary to perform the contract governing our provision of the Games or to take steps that you request prior to signing up for an account to use the Games.
We use the “Information You Provide”, “Automatically Collected Information”, and “Information From Other Sources”, for example: Profile and Account Information Purchase Information Payment and Transaction Fulfillment Providers Technical Information to facilitate the purchase and delivery of products, goods and services made through the shopping features on our Games. This includes sharing your information with payment and transaction fulfillment providers, and other service providers in order to process your orders.	Processing is necessary to perform the contract governing our provision of the Games or to take steps that you request prior to signing up for an account to use the Games.
We share your information with third parties whose platforms or services are integrated with the Games. For example, if you: sign-up or log-in to the Games using your account details from a third party platform (such as Facebook or Google), we will facilitate the process by sharing certain Technical Information. share User Content you publish on the Games with other social media platforms, we will share your User Content and related information.	This processing is necessary for our legitimate interests, namely to provide you with a seamless experience, allow your content to be shared on other platforms, enable third parties to authenticate users, and optimise user experience.
We use the “Information You Provide”, “Automatically Collected Information”, and “Information From Other Sources”, for example: Profile and Account Information; User Content and Usage Information; Surveys; Location Information; Information When You Contact Us; and Technical Information to review, improve, and develop the Games, including by reviewing interactions and usage across your devices and analyzing how you are using the Games.	The processing is necessary for our legitimate interests, namely, to improve and develop the Games.
The categories of information that we use will depend on the specific circumstances of each request or obligation. Depending on the circumstances, we could use the “Information You Provide”, “Automatically Collected Information”, and “Information From Other Sources”, for example: Profile and Account Information; User Content and Usage Information; Purchase Information; Location Information; Messages; and; Technical Information to comply with our legal obligations and rights, including where necessary to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority.	In some circumstances, this processing is necessary in order to comply with our legal obligations under European Union or Member State law. This includes situations where we have obligations to take measures to ensure the safety of our users or comply with a valid legal request such as an order from law enforcement agencies or courts. Similarly, processing may be necessary to respond to regulatory requests requiring the processing of information under Chapters IV and VI of the GDPR. In other circumstances, the processing is necessary for our legitimate interests, namely, to disclose and share information with regulators or other government entities.
We use the “Information You Provide”, “Automatically Collected Information”, and “Information From Other Sources”, for example: Profile and Account Information; Information When You Contact Us; and Technical Information to communicate with you, including to notify you about changes to the Games, provide customer support to you and send you other service-related messages.	The processing is necessary for the performance of a contract with you.
We use the “Information You Provide”, “Automatically Collected Information”, and “Information From Other Sources”, for example: Account and profile information; User Content and usage information; Location information; and Technical information to send you marketing communications in accordance with your preferences. This includes sending Game-related communications to you including information regarding other games under Moonton. We may also send you contests or promotions.	The processing is necessary for our legitimate interests, namely to promote new developments and features of the Games. We will obtain your consent to send you messages where required by law.
We use the “Information You Provide”, “Automatically Collected Information”, and “Information From Other Sources”, for example: Profile and Account Information; User Content and Usage Information; Purchase Information; Location Information; Messages; and Technical Information to enforce our Terms of Service, guidelines and policies.	The processing is necessary for the performance of a contract with you.
We use the “Information You Provide”, “Automatically Collected Information”, and “Information From Other Sources”, for example: Profile and Account Information; User Content and Usage Information; Purchase Information; Location Information; Messages; and Technical Information to maintain and enhance the safety, security, and stability of the Games by identifying and addressing technical or security issues such as technical bugs and spam accounts, and detecting abuse, fraud, and illegal activity on the Games including by scanning and reviewing User Content and other information.	The processing is necessary for our legitimate interests, namely to ensure that the Games are safe and secure.
In some cases, we may aggregate or anonymize the “Information You Provide”, “Automatically Collected Information”, and “Information From Other Sources” and use it in a way that is designed to be unable to identify you, for research or other purposes, to the extent allowed by applicable law.	The processing is necessary for our legitimate interests, namely to conduct research and protect personal information through aggregation or anonymization, consistent with data minimization and privacy by design principles.
We may use the “Information You Provide”, “Automatically Collected Information”, and “Information From Other Sources” where it is necessary to protect your or someone else's life, physical integrity, or safety. This could include providing law enforcement agencies or emergency services with information in urgent situations to protect health or life. The specific types of information we use will depend on the specific situation.	The processing is necessary to protect the vital interests of you or other individuals.
We may use your information where it is necessary to perform a task in the public interest, including undertaking research, preventing and detecting crime, safeguarding children and promoting public safety, security, and integrity as laid down by applicable law. We generally use “Information You Provide” and “Automatically Collected Information”, although it depends on the specific situation.	We process your information where it is necessary to perform a task in the public interest.

International Data Transfers

If you normally reside in the European Region, the personal information that we collect about you may be further transferred to, and stored at, a destination outside of the European Region (for instance, to our service providers and partners). For example, we may store the information that we collect in secure servers located in the United States and Singapore.

When we transfer your information outside of the European Region, we ensure it benefits from an adequate level of data protection by relying on:

Adequacy Decisions. These are decisions from the European Commission under Article 45 GDPR (or equivalent decisions under other laws) where they recognise that a country offers an adequate level of data protection. We transfer your information as described in What Information We Collect to some countries with adequacy decisions; or

Standard Contractual Clauses. The European Commission has approved contractual clauses under Article 46 of the GDPR that allows companies in the EEA to transfer data outside the EEA. These (and their approved equivalent for the UK and Switzerland) are called standard contractual clauses. We rely on standard contractual clauses to transfer information as described in What Information We Collect to certain entities in our Corporate Group and third parties in countries without an adequacy decision.

For a copy of these adequacy decisions or standard contractual clauses, please contact us by using the contact information for your region provided in the “Contact Us” section.

Your Rights

You have the following rights if you are a resident of the European Region:

The right to request free of charge (i) confirmation of whether we process your personal information and (ii) access to a copy of the personal information retained;
The right to request proper rectification or erasure of your personal information or restriction of the processing of your personal information;
Where processing of your personal information is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the personal information concerning you in a structured, commonly used and machine-readable format or to have your personal information transmitted directly to another company, where technically feasible (data portability);
Where the processing of your personal information is based on your consent, the right to withdraw your consent at any time (withdrawal will not impact the lawfulness of data processing activities that have taken place before such withdrawal);
The right not to be subject to any automatic individual decisions, including profiling, which produces legal effects on you or similarly significantly affects you unless we have your consent, this is authorised by Union or Member State law or this is necessary for the performance of a contract;
The right to object to processing if we are processing your personal information on the basis of our legitimate interest unless we can demonstrate compelling legitimate grounds which may override your right. If you object to such processing, we ask you to state the grounds of your objection in order for us to examine the processing of your personal information and to balance our legitimate interest in processing and your objection to this processing;
The right to request the restriction of the processing of your information where (a) you are challenging the accuracy of the information, (b) the information has been unlawfully processed, but you are opposing the deletion of that information, (c) where you need the information to be retained for the pursuit or defence of a legal claim, or (d) you have objected to processing and you are awaiting the outcome of that objection request.
The right to object to processing your personal information for direct marketing purposes; and
The right to lodge complaints before your local supervisory authority in your Member State through your local data protection authority.

Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

Representatives

If you are based in the United Kingdom, our designated GDPR representative is: [email protected]

Cosmo Technology Private Limited

2 Temple Back East

Temple Quay

Bristol, United Kingdom, BS1 6EG

If you are based in the EEA (except for Switzerland), our designated GDPR representative is:

Mikros Information Technology Ireland Limited

Mespil Business Centre

Mespil House

Sussex Road

Dublin 4, Ireland

If you are based in Switzerland, our designated representative is:

Mikros Information Technology Ireland Limited

Mespil Business Centre

Mespil House

Sussex Road

Dublin 4, Ireland

For more information about cookies, including your rights and preferences, please visit our Cookie Policy.

JURISDICTION-SPECIFIC SUPPLEMENTAL TERMS: THE AMERICAS

Canada

If you are using the Games in Canada, the following additional terms apply

Information Relating to Minors. We do not knowingly collect or solicit personal information from children under 14 without a parent or legal guardian’s consent. If you believe that we have personal information about or collected from a child under the age of 14 for whom you are a parent or legal guardian, please contact us at [email protected] and we will ensure that it is deleted.

Your Rights. Subject to limited exceptions under applicable law, you have the right to access, update, rectify and correct inaccuracies in your personal information in our custody and control and to withdraw your consent to our collection, use and disclosure of your personal information. To exercise these rights, you may contact us using the contact information set out below. We may require certain personal information for the purpose of verifying the identity of the individual making the request.

Your Choices. You can unsubscribe from our marketing emails at any time by clicking the “unsubscribe” link included at the bottom of each email we send.

Transfer Outside Your Jurisdiction. We and our service providers (including members, subsidiaries, or affiliates of our corporate group) may access, store and otherwise process personal information outside of Canada (and, for residents of Quebec, outside of Quebec), including in the United States and Singapore, and other foreign jurisdictions where we or our service providers are located. When your personal information is transferred to a jurisdiction outside of your province or Canada, it may be subject to the law of that foreign jurisdiction, including any law permitting or requiring disclosure of the information to the government, government agencies, courts and law enforcement in that jurisdiction. For more information about the manner in which we or our service providers (including service providers outside Canada) process personal information, please review the sections entitled “How We Use Your Personal Information” and “How We Share Your Personal Information” above or contact us using the contact information set out below.

Contact. If you are a resident of Canada, you can contact our Privacy Office using the contact information provided in the “Contact Us” section.

Data Security. We work hard to protect our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. To this end, we have in place technical, managerial and physical safeguards, including internal privacy policies and procedures to protect personal information, respond to privacy questions, complaints or breaches, and destroy information that is no longer required.

United States

If you are using our Games in the United States, please refer to our local agent, SkyStone’s Privacy Policy here.

Brazil

If you are using our Games in Brazil, the following additional terms apply:

Data Controller and Data Protection Officer. For the purposes of the LGPD, the data controller responsible for your personal information is YoungJoy Technology Limited and Vizta Pte. Ltd., operating under the “Moonton” brand. We have appointed a Data Protection Officer for Brazil, who can be reached at [email protected] for any questions, requests, or complaints regarding this Policy or the processing of your personal information.

Legal Bases for Processing. For users in Brazil, we process personal information under the legal bases set out in the LGPD, which may include consent, performance of a contract, compliance with a legal or regulatory obligation, regular exercise of rights, protection of life, legitimate interests, and credit protection, depending on the specific processing activity.

Exercise of data protection rights. Brazilian law provides certain rights to individuals with regard to their personal information. Thus, we seek to ensure transparency and access controls in order to allow users to benefit from the mentioned rights.

We will respond to and/or fulfill your requests for the exercise of your rights below according to the applicable law, including, when applicable, the Brazilian General Data Protection Law (the “LGPD”) Requests for confirmation of processing or access to personal information will be fulfilled immediately in simplified format or within fifteen (15) days by a clear and comprehensive statement, as required by applicable law:

confirmation of whether your data are being processed;
access to your data;
correction of incomplete, inaccurate or outdated data;
anonymization, blocking or erasure of data;
portability of personal information to a third party;
object to the processing of personal information;
information of public and private entities with which we shared data;
information about the possibility to refuse providing personal information and the respective consequences, when applicable;
withdrawal of your consent.
request an analysis of decisions taken exclusively based on the automated processing of personal information that affect your interests, including decisions taken to define your personal, professional, consumer or credit profile, or aspects of your personality.
file a complaint with the Brazilian National Data Protection Authority (ANPD).

Verifying Your Identity. For your safety and to allow us to make sure that we do not disclose any of your personal information to unauthorized third parties, in order to verify your identity and guarantee the adequate exercise of your rights, we may request specific information and/or documents from you before we can properly respond to a request received concerning your data. All data and documents received from you in the process of responding to your requests will be used for the strict purposes of analyzing your request, authenticating your identity, and finally responding to your request.

Limitations to Your Rights. In certain situations, we may have legitimate reasons not to comply with some of your requests. For instance, we may choose not to disclose certain information to you when a disclosure could adversely impact our business whenever there is a risk of violation to our trade secrets or intellectual property rights. In addition, we may refrain from complying with a request for erasure when the maintenance of your data is required for complying with legal or regulatory obligations or when such maintenance is required to protect our rights and interests in case a dispute arises. Whenever this is the case and we are unable to comply with a request you make, we will let you know the reasons why we cannot fulfill your request.

In case of doubt about your privacy, your rights or how to exercise them, please contact us using the information in the "Contact Us" section. If you have any questions about the processing of your personal information, we would like to clarify them.

Data Security Incidents. In the event of a security incident that may create a relevant risk or damage to you, we will notify the ANPD and, where required by applicable law, affected users within a reasonable period of time, in accordance with Article 48 of the LGPD, and we will take appropriate measures to remedy the incident and mitigate its effects.

Data Retention. We retain your personal information only for as long as necessary to fulfil the purposes described in this Policy, to comply with legal or regulatory obligations, or to exercise or defend rights in judicial, administrative, or arbitration proceedings, in accordance with Articles 15 and 16 of the LGPD. Once these purposes have been fulfilled, we will delete, anonymize, or block the personal information, except where further retention is required or permitted by applicable law.

International Transfer of Data. We share your personal information globally with companies of our business group to carry out the activities specified in this Policy. We may also subcontract the processing of data involved in the Games or share your personal information with third parties located in other countries. Your personal information may therefore be subject to privacy laws other than those applicable in your country.

Whenever we transfer your personal information to third parties located in other countries, we will ensure that these companies comply with applicable data protection laws and we will take all measures that are reasonably necessary to ensure the existence of adequate safeguards to protect your personal information and to ensure that it is processed safely.

Language. The Policy may have been prepared in the English language and in the Portuguese language, and if you are a user located in Brazil, you shall refer to such Portuguese version if available, which shall prevail.

Children and Adolescents. In accordance with Article 14 of the LGPD and applicable consumer protection laws, the processing of children’s personal information requires specific and highlighted consent provided by at least one parent or legal guardian. Certain game and in-Game content, including loot boxes, may be restricted or unavailable to minors under applicable Brazilian law. We may implement additional age-verification mechanisms to enforce these restrictions as required by applicable law, regulatory guidance, or enforcement expectations. Should we identify the processing of children’s data without the required parental consent, we will proceed with the immediate erasure of such information. However, children’s personal information may be collected without such consent when the collection is strictly necessary to contact the parent or legal guardian.

DPO. If you wish to contact the Data Protection Officer, please contact us at [email protected].

Argentina

If you are using our Games in Argentina, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall prevail.

Governing Law and Dispute Resolution. By using our Games in Argentina, this Privacy Policy will be governed by and interpreted in accordance with the laws of Argentina, pursuant to Section 2655 of the Civil and Commercial Code.

In the event of a dispute arising between the parties in connection with this Privacy Policy, jurisdiction shall be determined pursuant to Section 2654 of the Civil and Commercial Code.

Data Controller. Vizta Pte. Ltd with a registered address at 9 Battery Road #28-01 MYP Centre Singapore, 049910 Singapore, and YoungJoy Technology Limited with a registered address at Room 06, 13A/F, South Tower, World Finance Center, Harbour City, 17 Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong, are the data controller of your personal information. The personal information provided will be incorporated into the database owned and controlled by Vizta Pte. Ltd and YoungJoy Technology Limited.

Mandatory or Voluntary Provision of Personal Information. Providing certain personal information is necessary for us to deliver the gaming services you have requested and to comply with our contractual and legal obligations. In addition, we may process certain personal information that is provided on a voluntary basis, such as data related to personalized content, tailored recommendations, or enhanced gaming features. You are free to choose not to provide optional data without any adverse effect on your ability to use our services.

Consequences of Providing, Refusing to Provide or Providing Inaccurate or False Data. When you provide your personal information, it will be processed in accordance with this Policy and the purposes described herein. Providing mandatory data enables us to deliver the services you have requested, fulfil our contractual obligations to you, and comply with legal requirements. If you choose not to provide mandatory data, we may be unable to create or maintain your account, process your transactions, or provide certain features or services that depend on that information. Refusal to provide optional data will not affect your access to our core services. If the personal information you provide is inaccurate, incomplete, or outdated, it may impair our ability to deliver our services effectively, lead to errors in your account or transactions, or prevent us from meeting our legal obligations.

International transfer. Your personal information may be transferred to countries outside of Argentina, which may not provide the same level of data protection as that afforded in Argentina, a circumstance that you acknowledge and expressly consent to. In such cases, we shall ensure that such transfers are carried out on the basis of valid legal grounds, including your consent granted herein and, where necessary, the implementation of appropriate contractual arrangements and technical and organizational measures, thereby ensuring a level of protection consistent with applicable law.

Age, Parental and Guardian Consent. By accepting this Policy, you represent that you are at least 18 years of age. If you are below 18 years old:

you must obtain approval from your parent(s) or legal guardian(s); and
your parent(s) or legal guardian(s) are responsible for: (i) all your actions in connection with your access to and use of the Games; (ii) your compliance with this Policy; and (iii) ensuring that any of your participation in the Games will not, in any event, result in any violation of applicable laws and regulations relating to child protections.

If you do not have consent from your parent(s) or legal guardian(s) and your parent(s) or legal guardian(s) is not willing to open the account under their name, you must cease accessing the Games.

Your Rights and Options. According to Law No. 25,326, Regulatory Decree No. 1558/2001 and the provisions and/or binding resolutions issued by the Agency for Access to Public Information (the “AAIP”), you have the following rights with respect to your personal information: access, rectification, opt-out to marketing communications and deletion regarding data protection.

If you have questions about your rights or how to exercise them, please contact us using the information in the "Contact Us" section. If you have any questions about the processing of your personal information, we would like to clarify them.

We encourage you to contact us if you are not satisfied with how we have responded to any of your rights requests. The Agency for Access to Public Information, in its capacity as the Supervisory Authority of Law No. 25,326, is empowered to receive and address complaints and claims filed by individuals whose rights have been affected by non-compliance with the applicable personal data protection regulations. You can contact AAIP through the site: https://www.argentina.gob.ar/aaip/datospersonales/derechos and at: Av. Pte. Gral. Julio A. Roca 710, 2nd Floor – City of Buenos Aires; (54-11) 3988-3968.

Consent. By clicking on the acceptance button, you grant your prior, free and express consent to the collection, use, disclosure and otherwise processing of your personal information as outlined in this Policy and to the transfer of your personal information outside my country of residence to any country or location as outlined in this Policy.

Mexico

If you are using our Games in Mexico, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall prevail:

Data Controller. YoungJoy Technology Limited located at Room 06, 13A/F, South Tower, World Finance Center, Harbour City, 17 Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong, and Vizta Pte. Ltd located at 9 Battery Road #28-01 MYP Centre Singapore, 049910 Singapore.

How We Use Your Personal Information. Almost all of the purposes of the processing data indicated above in the main section of this Privacy Policy are necessary purposes. However, the following are secondary purposes:

Provide you with personalized advertising, marketing communications, contests and promotions.

These purposes are not necessary for us to provide the Games but allow us to provide you with a better experience. You can opt-out of these at any time as explained in Section 5 (Your Privacy Rights and Choices) above.

Your Rights. You have the following rights with respect to your personal information: access, rectification, cancellation, objection, consent withdrawal, limitation to the use and disclosure of your data. You can exercise your rights by contacting us at the information listed in the “Contact Us” section. To know more about the applicable requirements and procedure to exercise your rights, contact us to the mentioned email address. If you are under 18 years, you may exercise your rights through a parent or guardian. Your rights requests will be resolved as soon as possible according to the applicable data protection law and the nature of your request.

How We Share Your Personal Information. We may share your personal information with a third party for purposes other than processing on our behalf. We will obtain your consent to such disclosure as required by applicable law.

By providing us with your personal information and using the Games, you agree to transfers that require your consent. You can always revoke your consent and exercise your rights as outlined below

Information Relating to Children. You may review more information on parental consent in the Terms of Service.

Language. The Policy may have been prepared in the English language and in the Spanish language. If you are a user located in Mexico, you shall refer to the Spanish version, which shall prevail

JURISDICTION-SPECIFIC SUPPLEMENTAL TERMS: MIDDLE EAST & AFRICA

Israel

If you are using the Games in Israel, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall prevail.

Transparency and Consent. Unless we state otherwise at collection, providing personal information is voluntary. If you do not provide personal information that is necessary for a requested Game, Platform, Service, Event, account feature, purchase, security function, or legal requirement, we may be unable to provide the relevant feature or service. We process personal information on the basis of informed consent or another legal authorization permitted by Israeli law, and the categories of personal information, purposes of processing, and intended recipients are described in the main body of this Policy.

Your Rights. Subject to applicable law, you may inspect personal information about you that is held in a database, request correction of personal information that is incorrect, incomplete, unclear, or outdated, and request deletion where applicable. You may also request removal from a direct mailing database, restrict transfer of personal information in the direct-mailing context, and submit a query or complaint to the Israel Privacy Protection Authority.

Marketing Communications. Where required under Israeli law, we will send electronic marketing messages only with prior consent or under an applicable exception, and marketing communications will identify the advertiser, provide contact information, and include a simple opt-out mechanism.

International Transfers. If personal information from a database in Israel is transferred outside Israel, we will do so only in accordance with the applicable Israeli transfer rules, including where the recipient jurisdiction provides an adequate level of protection, where you have consented, where the transfer is otherwise permitted by law, or where the recipient has agreed to comply with applicable Israeli data protection requirements such as purpose limitation, data-subject rights, confidentiality, and data security.

DPO Contact. Where a Data Protection Officer is required under Israeli law, communications with the Data Protection Officer may be sent to [email protected].

Data relating to children. We do not knowingly collect or solicit personal information from children under 18 for prohibited purposes under applicable Israeli law. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 13 and that you have read and acknowledged Moonton Privacy Policy and Terms of Service and agree to the use by your child of the Games and registration for an account. Further, if you believe that we have personal information about or collected from a child under the relevant age, please contact us at [email protected] and we will ensure that it is deleted.

Türkiye

If you are using the Games in Türkiye, the following additional terms apply. In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall prevail.

Identity of the Data Controller

Pursuant to the Turkish Personal Data Protection Law No. 6698 (the “TPDPL”), your personal information may be processed by YoungJoy Technology Limited (“YoungJoy”), acting as the data controller, within the scope described below.

Data Controller Information

Legal Name: YoungJoy Technology Limited
Address: Room 06, 13A/F, South Tower, World Finance Center, Harbour City, 17 Canton Road, Tsim Sha Tsui, Kowloon, Hong Kong
E-mail: [email protected]

Categories of Personal Information Processed. The categories of personal information processed by the Company are set out under Section 1 (What Personal Information We Collect) of this Policy and may include account and profile information, user content and communications, purchase and transaction information, technical and usage information, location information, audio information, contact information and other personal information collected in connection with the provision of the Services.

Purposes of Processing Personal Information. The purposes for which your personal information is processed are set out in Section 3 (How We Use Your Personal Information) of this Policy.

Legal Bases for the Processing of your Personal Information Under Turkish Law. Moonton relies on the following legal bases while processing your personal information in accordance with Article 5 of the Law No. 6698 on Protection of Personal Data:

processing is explicitly laid down or dictated by laws
processing of your personal information is necessary provided that it is directly related to the conclusion or fulfilment of the contract between us
processing is mandatory for us to be able to comply with our legal obligations
the relevant data is made available to the public by yourself
processing is mandatory for the establishment, exercise or protection of a right
processing is mandatory for our legitimate interests, provided that it does not violate your fundamental rights and freedoms
your explicit consent (Please note that we rely on this legal basis only when we require your consent for the processing and we do not rely on this legal basis if and when we rely on one of the other legal grounds above)
Sensitive personal information will only be processed in accordance with Article 6 of the TPDPL and other applicable legal requirements.

Recipients and Purposes of Transfer. The categories of recipients to whom personal information may be transferred are described in Section 4 of this Policy (How We Share Your Personal Information). Depending on the purposes of processing and the nature of the Services, personal information may be shared with

Payment service providers;
Customer support providers;
Content moderation providers;
Security, fraud prevention and analytics service providers;
Advertising and marketing service providers;
Group companies and affiliates;
Business partners;
Professional advisors, auditors and legal consultants;
Competent courts, enforcement offices and public authorities;
Legally authorized public institutions and organizations.

Where personal information is transferred abroad, such transfers shall be carried out in accordance with Article 9 of the TPDPL and applicable secondary legislation.

International Data Transfers. If you normally reside in Türkiye, the personal information that we collect about you may be transferred to and stored outside Türkiye, including by our affiliates, service providers and business partners. For example, we may store information on secure servers located in the United States, Singapore and other jurisdictions where our service providers operate.

When we transfer your information outside Türkiye, we ensure that such transfers are carried out in accordance with Article 9 of the TPDPL and applicable legislation by relying on one or more of the following transfer mechanisms:

Appropriate Safeguards. As no adequacy decision has currently been issued by the Turkish Personal Data Protection Authority, personal information may be transferred abroad on the basis of appropriate safeguards provided under applicable law. Such safeguards include standard contracts announced by the Turkish Personal Data Protection Authority, binding corporate rules approved by the Turkish Personal Data Protection Board, approved undertakings, or other transfer mechanisms permitted under Article 9 of the TPDPL.

Incidental Transfers. In limited circumstances where neither an adequacy decision nor appropriate safeguards are available, personal information may be transferred abroad on an occasional basis, provided that one of the derogations set out under applicable law applies. These include where the transfer is necessary for the establishment or performance of a contract, necessary for the establishment, exercise or protection of a legal claim, necessary for overriding public interest reasons, necessary to protect the life or physical integrity of a person who is unable to provide consent, or where another derogation expressly provided under applicable law applies.

For more information regarding international transfers, please contact us using the contact information provided in the “Contact Us” section.

Method of Collection. The methods by which personal information is collected are described in Section 2 ("How We Collect Your Personal Information") of this Privacy Policy. In this regard, we use the Information You Provide, Automatically Collected Information, and Information From Other Sources. Personal information may be collected directly from users, automatically through the use of the Services and related technologies, or from third-party sources, in each case through the means and channels described in Section 2 of this Privacy Policy.

Retention Period. Personal information shall be retained for the period required by applicable legislation or for as long as necessary for the purposes for which it is processed. Upon expiration of the applicable retention period or once the purpose of processing ceases to exist, personal information shall be deleted, destroyed or anonymized in accordance with the TPDPL and relevant legislation.

Personal Information Relating to Minors. The Games are not directed at children under the age of 18 and we do not knowingly collect or solicit personal information from children under 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent/legal guardian of a user who is under the age of 18, you hereby declare that such user is above the age of 12 and that you have read and acknowledged Moonton Privacy Policy and Terms of Service and agree to the use by your child of the Games and registration for an account. Further, if you believe that we have personal information about or collected from a child under the relevant age, please contact us at [email protected] and we will ensure that it is deleted.

Data Controller Representative. You may contact our data controller representative in Turkey by email at [email protected] to handle questions and complaints in connection with the processing of your personal information if you are in Turkey.

Your Rights. According to Article 11 of the TPDPL, you have the following rights with respect to your personal information:

the right to learn whether we process your personal information;
the right to request information with regard to such processing, if we process your personal information;
the right to learn the purposes of the processing and whether they are used for such purpose or not;
the right to know the third parties within or outside the country, to whom we transfer your personal information;
the right to request correction of incomplete or inaccurate personal information;
the right to request deletion or destruction of your personal information under the conditions set forth in Article 7 of the TPDPL;
the right to request that we notify the third parties, to whom we transferred your personal information, about the correction, deletion and/or destruction of your personal information per your request within the scope of the foregoing two items;
the right to object to the negative results about you that are due to the analysis of your personal information processed solely by automated means; and
the right to claim indemnification for damages incurred due to illegal processing of your personal information.

Please send an e-mail to [email protected] if you would like to exercise any of your rights. Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

We will respond to your request as soon as possible according to the nature of your request and within thirty days at the latest, free of charge. However, if your request incurs additional cost to us, then you may be charged over the tariff fee determined by the Turkish Personal Data Protection Board.

Egypt

If you are using the Games in Egypt, the following additional terms apply in accordance with the Egyptian Personal Data Protection Law. In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall prevail.

Consent and Lawful Processing. We will collect, process, disclose, or reveal your personal information only with your explicit consent or where otherwise permitted by applicable law. We will process personal information for legitimate, specific, and transparent purposes and will retain it only for as long as necessary to fulfill those purposes, unless retention is otherwise permitted by applicable law.

Your Rights. Subject to applicable law, you have the right to know, review, access, and obtain your personal information; withdraw prior consent for retention or processing; correct, edit, delete, add, or update your personal information; limit processing to a specified purpose; be notified of any infringement affecting your personal information; and object to processing or its results where it contradicts your fundamental rights and freedoms. You may submit requests to exercise these rights using the contact information in the “Contact Us” section, and we will respond within the period required by applicable Egyptian law.

Electronic Marketing. We will send electronic marketing communications to you only with your consent and in accordance with applicable Egyptian law. Each such communication will identify the sender, include a valid address or contact method, clearly indicate that it is for direct marketing, and provide a clear and uncomplicated mechanism to opt out or withdraw consent.

Cross-Border Transfer of Personal Information. If we transfer, store, share, process, or disclose personal information outside Egypt, we will do so in accordance with the requirements of applicable Egyptian law, including obtaining any required license or permit from the Personal Data Protection Center and ensuring that the applicable level of protection is met or that another lawful exception applies. Where Egyptian law requires explicit consent for a cross-border transfer, we will obtain that consent.

Data Breach. Where an infringement of personal information occurs, we will notify the Personal Data Protection Center within 72 hours and notify affected data subjects within three days after notifying the Center, in each case as required by applicable Egyptian law.

DPO and Local Representative. Where required under applicable Egyptian law, we will appoint, register, and announce a Data Protection Officer, and controllers or processors outside Egypt will appoint a representative in Egypt in accordance with the Executive Regulations.

Age, Parental and Guardian Consent. You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent or legal guardian of a user who is under the age of 18, you represent that you have read and acknowledged the Privacy Policy and Terms of Service and consent to the processing of the child’s personal information for the child’s use of the Games and registration for an account. We will not condition a child’s participation in a game, competition, or other activity on the child providing more personal information than is necessary for that participation.

South Africa

If you are using the Games in South Africa, the following additional terms apply in accordance with the Protection of Personal Information Act, 2013 (the “POPI Act”). In the event of any conflict between the following additional terms and the provisions of the main body of this Policy, the following terms shall prevail.

Responsible Party and Collection Notice. For South African users, the responsible party is Vizta Pte. Ltd. The categories of personal information collected, the sources from which we collect it, the purposes for collection, and the categories of recipients are described in the main body of this Policy. Unless we state otherwise at collection, providing personal information is voluntary; however, if you do not provide personal information that is necessary for a requested Game, Platform, Service, Event, account feature, purchase, security function, or legal requirement, we may be unable to provide the relevant feature or service.

Your Rights and Complaints. Subject to applicable law, you have the right to access and rectify personal information collected about you, to object to the processing of your personal information, to object to direct marketing, to avoid unsolicited electronic direct marketing except as permitted by the POPI Act, not to be subject to certain decisions based solely on automated processing, to submit a complaint to the Information Regulator, and to institute civil proceedings regarding alleged interference with the protection of your personal information. You may contact us using the contact information in the “Contact Us” section. You may contact the Information Regulator at https://inforegulator.org.za/contact-us/

International Transfers. If we transfer your personal information from South Africa to a third party in another country, we will do so only as permitted by the POPI Act, including where the recipient is subject to a law, binding corporate rules, or binding agreement providing an adequate level of protection, where you consent, where the transfer is necessary for the performance of a contract or for a contract concluded in your interest, or where another lawful basis under the POPI Act applies.

Direct Marketing. We will process personal information for direct marketing by unsolicited electronic communications only where permitted by the POPI Act. Each such communication will identify the sender or the person on whose behalf it is sent and will include an address or other contact details through which you may request that the communications stop.

Age, Parental and Guardian Consent. You declare that you are over the age of 18. If you are under the age of 18, please have your parent or legal guardian read this with you. If you are reviewing these terms as the parent or legal guardian of a user who is under the age of 18, you represent that you have read and acknowledged the Policy and Terms of Service and consent to the processing of the child’s personal information for the child’s use of the Games and registration for an account, to the extent required under the POPI Act.

LEGAL INFORMATION

MOONTON GAMES TERMS OF SERVICE

Please read these Terms of Service carefully before accessing or using our Services.

WHO ARE WE?

We’re Vizta Pte. Ltd., better known in some jurisdictions as “Moonton”. “Moonton” is made up of several different legal entities around the world. These Terms of Service apply to Services offered by Vizta Pte. Ltd. and Youngjoy Technology Limited (collectively referred to as “Moonton,” “we,” “us,” or “our”). We are the publisher behind the global blockbuster game Mobile Legends: Bang Bang and bold titles like Magic Chess: Go Go, Watcher of Realms, Acecraft. Each of our games, and their related mobile apps, websites, software, and online gaming service, is referred to in these Terms of Service as a “Game”.

HOW THIS WORKS

These Terms of Service set the legal terms for how our Games and related content can be used. When you play one of our Games, you’re entering into a contract with us (or our affiliate group company that publishes the Game in your jurisdiction). These Terms of Service are a legally binding agreement. If you don’t agree to these Terms of Service, then don’t play our Games. If you click to accept these Terms of Service, or if you keep playing a Game after reading this, you’re telling us that you accept these Terms of Service and agree to be bound by them.

HEADS UP

These Terms of Service include a binding arbitration clause and a class action waiver. That means most disputes between you and Moonton will be handled by arbitration, not in court, so you won’t get a jury trial. You’re also giving up the right to participate in class actions that may be brought against Moonton in the future. All of this is discussed in greater detail below, but the basic concept is that you can’t bring claims against us in court; you have to use confidential arbitration (on an individual basis) to resolve all claims. We wanted to flag this upfront, in case it’s a dealbreaker for you.

PARENTAL CONSENT

If you are under the digital age of consent in the jurisdiction where you live, your parent or guardian must accept these Terms of Service before you can play any of our Games. The digital age of consent is the minimum age at which a person is legally permitted to consent to the collection and processing of their personal data online without parental involvement. This age varies by country, but in many places it is between 13 and 16 years old. If you are unsure whether you have reached the digital age of consent in your jurisdiction, you should ask a parent or guardian to review and accept these Terms of Service on your behalf to be on the safe side. If we determine that a player has not met the digital age of consent and does not have valid parental consent, we may disable the player’s account.

Attention Parents and Guardians: By clicking to accept these Terms of Service or allowing a minor to play a Game, you accept and agree to be bound by these Terms of Service for yourself and on behalf of the minor. You also assume responsibility for all use of the Game and compliance with these Terms of Service by the minor, including responsibility for purchases made by the minor using a Game account.

OWNERSHIP OF GAMES AND GAME CONTENT

You acknowledge and agree that the Games are and will remain our sole and exclusive property. This includes the artwork, graphics, designs, characters, skins, heroes, environments, maps, music, sound effects, dialogue, storylines, cinematics, animations, visual effects, in-game currencies, and any other virtual items or creative elements used in or generated by the Games and all intellectual property rights to the Game (“Game Content”). Our Game Content also includes all gameplay data and statistics collected or generated as you play, such as match results, rankings, win/loss records, player behavior data, customization history, and other performance metrics. You do not acquire any ownership or property rights in a Game or its Game Content through your play of a Game, and you may only use a Game and its Game Content as expressly licensed under these Terms of Service. You further agree not to contest, challenge, or otherwise interfere with our ownership or other rights in the Games and Game Content, or assist any third party in doing so.

RIGHTS GRANTED TO YOU

If you accept these Terms of Service and follow them, we will grant you a non-exclusive, limited license to: (1) play the Game you have selected, and (2) stream your own personal gameplay of the Game (“Gameplay Stream”) on lawful user-generated content platforms such as TikTok, YouTube, X, or Meta. This license is personal to you, non-transferable by you, and revokable by us. What this means is that you have the right to play the Game and stream your own gameplay, but you can’t give this right to someone else. It also means that we can terminate your license to play or stream a Game at any time and for any reason if the law in your jurisdiction permits termination for convenience. You may receive compensation from a streaming platform for your Gameplay Streams in the same manner as other casual streamers (ad revenue, subscriptions, tips, or similar platform-based payments), but all other commercial uses of a Game and its Game Content are strictly prohibited. You may not use any Moonton trademark, service mark, or logo in a Gameplay Stream or anywhere else without our prior, written approval. You may not use a Gameplay Stream in a way that suggests or implies Moonton’s sponsorship, endorsement, or approval. All Game Content and Gameplay Streams remain the sole and exclusive property of Moonton. We may require removal of a Gameplay Stream from any platform at any time and for any reason, and you agree to take down a Gameplay Stream within 48 hours of our request.

CODE OF CONDUCT

Our Games are designed to be competitive, fun, and welcoming for all players. To keep them that way, we maintain a Code of Conduct that sets clear expectations for respectful behavior, fair play, and good sportsmanship. The Code of Conduct addresses issues such as harassment, cheating, exploiting game mechanics, and other actions that undermine the integrity or enjoyment of the Game. We take violations of the Code of Conduct seriously and may, in our discretion, issue warnings, impose temporary suspensions, restrict access to certain features, remove in-Game content or progress, permanently suspend or terminate accounts, or report serious violations to platform operators or authorities when required by law or necessary to protect the community. By accepting these Terms of Service, you (1) accept and agree to be bound by the Code of Conduct, which is an essential element of these Terms of Service; and (2) acknowledge that the enforcement measures described above are reasonable and necessary to maintain a safe, fair, and positive gaming environment.

RESTRICTIONS ON USE OF A GAME

You agree to use the Game only for lawful purposes and in accordance with these Terms of Service. You may not, directly or indirectly: (1) use the Game for any commercial purpose, except as expressly provided above with respect to compensation from a streaming platform for your Gameplay Streams; (2) interfere with or disrupt the operation of the Game or the experience of other players, including through cheating, exploiting bugs or vulnerabilities, or using unauthorized software or hardware; (3) use automated scripts, software, code or systems to collect data or information from or otherwise interact with the Game; (4) reverse engineer, decompile, disassemble, or otherwise attempt to access or modify the Game’s code or underlying infrastructure, except where such restrictions are prohibited by law; (5) use the Game or any of its communications technology to impersonate other players, Moonton staff, celebrities, or any other person or entity, misrepresent your identity, or engage in fraudulent activity; (6) use the Game to engage in or promote unlawful, harassing, abusive, or hateful conduct; or (7) access or attempt to access the Game or any related system in a manner not expressly permitted by us. We reserve the right to suspend, restrict, or terminate access to the Game if we determine that you have violated any of these restrictions.

ACCOUNT LOGIN AND AUTHENTICATION

When you launch a Game, you may be offered one or more methods of authentication. For example, you may authenticate by linking an eligible third-party account (such as an account provided by Apple, Google, Meta, or TikTok) or by registering with an email address and creating login credentials. Where supported by the applicable Game or region, your authentication will result in the creation of, or association with, an “M Account,” which will be used to store and manage your Game-related data, settings, and progression. Certain Games or regions may permit access through a guest session without linking a third-party account or creating an M Account; however, guest sessions may be device-specific and may not be recoverable if you change, lose, or reset your device, reinstall the Game, or clear local data. You acknowledge that linking a third-party account or creating an M Account may be required to preserve, synchronize, or transfer your Game data and progression across devices. If you log in using a third-party platform, you agree that we have no responsibility or liability for that platform or its services, and any disputes or issues relating to the third-party platform are strictly between you and that provider. You are solely responsible for maintaining the security of your login credentials and for any activity that occurs under your game account. We are not responsible for any loss of progress, virtual currency, or digital goods resulting from your failure to properly secure or maintain your account or login credentials. You may not sell, rent, loan, trade, gift, or otherwise transfer your game account or its login credentials. We may suspend or terminate access to the Game if we reasonably believe that your account has been compromised or is being used in violation of these Terms of Service of the Code of Conduct. We reserve the right to monitor all transactions involving your game account and may, without notice or liability to you, limit transactions and report suspicious activity to relevant law enforcement agencies.

ANTI-CHEAT SOFTWARE

To protect the fairness and integrity of our Games, we may use anti-cheat and fraud-prevention technologies. By using a Game, you consent to the operation of such anti-cheat technologies, which are designed to detect and prevent cheating, unauthorized modifications, exploits, or the use of hacks, bots, or other similar third-party software. We may update or modify our anti-cheat technologies at any time, with or without notice, to respond to new or emerging threats. If cheating or other prohibited conduct is detected, we may suspend or terminate your game account, restrict or terminate your access to a Game, or take other disciplinary actions, and we reserve all rights and remedies available at law, including the right to assert a claim for damages. You must not interfere or tamper with, disable, or circumvent any security or anti-cheat measures, and doing so constitutes a violation of these Terms of Service.

IN-GAME CURRENCIES

Players can obtain in-game currencies or digital credits in our Games (like Diamonds, Battle Points, or other game-specific currencies) by buying them with real money or by earning them through gameplay, participation in special events, and other in-game or social media activities. Our in-game currencies and digital credits are called “Game Currencies” in these Terms of Service. A Game Currency is licensed to you on the same terms that the Game is licensed to you, and it remains part of the Game at all times. Our Game Currencies have no monetary value and cannot be redeemed for real money, real-world goods, or other items of monetary value. A Game Currency is not transferable between users or accounts. Any attempt to sell, rent, loan, trade, gift, or otherwise transfer a Game Currency outside of a Game is strictly prohibited and may result in the suspension or termination of your game account.

SKINS AND OTHER VIRTUAL ITEMS

In Moonton’s games, players can obtain a variety of digital items that enhance their experience, including playable heroes, cosmetic skins for characters, animated avatar borders, recall effects, elimination animations, and other digital content, features, and entitlements. These digital items are referred to in these Terms of Service as “Virtual Items”. Virtual Items may be made available through direct purchase, in-game events, exchange programs, or other promotional activities, and their availability may vary by time, region, or platform. Virtual Items are licensed to you on the same terms that the Game is licensed to you, and they remain part of the Game at all times. In other words, Virtual Items are licensed, not sold, and you do not own any Virtual Items. Virtual Items have no real-world monetary value and cannot be redeemed for cash or real-world goods. You may not sell, rent, loan, trade, gift, or otherwise transfer Virtual Items outside of the Game.

CHANGES TO THE GAME, GAME CURRENCIES, AND VIRTUAL ITEMS

We reserve the right to change, modify, or update a Game and its maps, characters, and other Game Content at any time. We may, if permitted by applicable law, change the availability, functions, or purchasing power of any Game Currency at any time by email notice to you or by posting a notice in the Game client or on our website. This includes adjusting how much Game Currency is required to obtain certain items, features, or services in a Game. For example, in Mobile Legends: Bang Bang, we may change the number of Diamonds required to purchase a hero skin or Battle Points required to unlock an item. We may also modify, rebalance, remove, or replace Virtual Items from time to time, including buffing or nerfing the performance of characters, heroes, equipment, or other gameplay elements. These adjustments are part of the ongoing development and balancing of our Games, and you acknowledge that the value, function, or utility of Game Currency and Virtual Items may change over time and may vary from one jurisdiction to another. Game Currencies are not real money, do not have any intrinsic or monetary value outside of the Game, and may not be redeemed for cash or transferred except as expressly permitted in these Terms of Service. We may require you to install updates or patches to continue using a Game. You acknowledge that our changes to a Game may result in a change to the system requirements for that Game, and you are responsible for upgrading your hardware and software to continue using the Game.

FEES, TAXES, AND SUBSCRIPTIONS

When you buy Game Currency, Virtual Items, subscriptions, or other paid features in our Games, you agree to pay the full price shown at checkout, along with any applicable taxes, duties, or fees required by law. All payments are processed through your chosen platform or payment provider (such as Apple, Google, or another authorized partner), and their terms and conditions and privacy policies apply. Prices may change from time to time, but any change will not affect purchases you have already made. You are responsible for any taxes or charges that apply to your purchases. We are not responsible for notifying you of tax obligations beyond what is required by law. If you sign up for a subscription (for example, a monthly pass or similar recurring feature), you authorize the platform or payment provider to automatically charge you at the beginning of each billing cycle until you cancel. Subscriptions may renew automatically unless you turn off auto-renewal in your platform account settings before the start of the next billing cycle. We may change the price or features of a subscription, and if we do, we will give you notice before the next renewal. You may cancel a subscription at any time through your platform account settings. We reserve the right to terminate subscriptions without notice if payments are not made when due.

REFUNDS AND CANCELLATIONS

All sales of Game Currency, Virtual Items, subscriptions, and other paid features of a Game are final and non-refundable, except where otherwise required by applicable law. We do not provide refunds except where required by applicable law. If you believe you are entitled to a refund, you must request it directly through the platform (such as Apple or Google) where you made the purchase, and their policies will control. If you obtain a refund or chargeback through a platform, payment provider, or app store, we may reclaim or remove any Game Currency, Virtual Items, or packages corresponding to the refunded amount, whether or not they have been redeemed or used, and this includes any bonus or complimentary items associated with the transaction. Users who repeatedly request refunds within a short period may be subject to additional corrective measures, including email warnings and temporary or permanent account suspension. We may also suspend or terminate your account if we are unable to fully recover the value of refunded amounts. You acknowledge and agree that using refund or chargeback mechanisms to retain both funds and in-game benefits constitutes a breach of these Terms of Service and unlicensed use of the Game.

USER GENERATED CONTENT

Our Games may allow you to create, upload, or share content such as text, images, video, audio, gameplay clips, or other content or materials (“User Generated Content” or “UGC”). You are responsible for any UGC you create, upload, or share, and you must ensure that all of your UGC complies with these Terms of Service, the Code of Conduct, and applicable law. You may not create, upload, or share UGC that is illegal, infringing, defamatory, obscene, harassing, hateful, or otherwise violates the rights of others. In particular, you must not create, upload, or stream UGC that infringes the intellectual property rights, privacy rights, or publicity rights of any third party. We reserve the right (but have no obligation) to review, remove, or disable access to any of your UGC at any time, in our sole discretion, without notice or liability to you. If your UGC includes or makes use of any Game Content (for example, characters, artwork, music, storylines, or other elements of a Game), then you agree that all intellectual property and other rights in that UGC will be owned exclusively by Moonton. In that case, Moonton grants you a limited, personal, non-exclusive, non-transferable, and revocable license to use and share that UGC for non-commercial purposes only, such as your personal enjoyment or sharing with friends. If your UGC does not include or make use of any Game Content, then you retain ownership of that UGC, but if you create the UGC with our tools or apps, or share it using our platforms or services, then you grant Moonton a non-exclusive, worldwide, perpetual, irrevocable, royalty-free, fully paid-up license (with the right to sublicense) to use, reproduce, distribute, adapt, modify, publicly display, publicly perform, and otherwise exploit that UGC in any manner and for any purpose, including for commercial purposes. To the maximum extent permitted by law, you waive all moral rights you may have in your UGC, including any rights of attribution, integrity, withdrawal, or objection to modification, and you agree not to assert such rights against Moonton or its licensees.

CLOSING YOUR GAME ACCOUNT

You may close your game account at any time, for any reason, by following the account closure instructions provided in the Game. Closing your game account is permanent, and once complete, you will lose access to your account, your Game progress, customizations, Game Currency, Virtual Items, username, avatar, and any other chat histories, community posts, personal identifiers, or other assets associated with your game account, with no option for recovery or backup. We may suspend or close your account if you violate these Terms of Service or the Code of Conduct, engage in cheating, fraud, or other harmful conduct, fail to comply with applicable laws, or if, in our opinion, continued operation of your game account would be unlawful or harmful to the community or to Moonton’s business interests or reputation. We may also close your account if you haven’t logged in for an extended period and don’t respond to a reactivation notice within thirty days. Once your account is closed (whether by you or by Moonton) your license to play and stream a Game ends immediately, your access to the Games and related Game Content is terminated, and you will not receive a refund or compensation for unused Game Currency or Virtual Items, except as required by applicable law. Some data associated with your game account may be retained for a period of time as necessary for legal, regulatory, security, or backup purposes, as further described in our Privacy Policy. We have no obligation to store, maintain, or provide you with copies of any User Generated Content or other content linked to your account after closure. You acknowledge that closing your account does not necessarily remove User Generated Content that you have already made public (such as forum posts, chats, or Gameplay Streams), which may remain visible to other players.

FEEDBACK AND GOOD IDEAS

We love hearing from our gamer community, but because we receive lots of feedback, suggestions, comments, bug reports, feature requests, and other good ideas (“Feedback”), we need to set some clear rules. You are never obligated to share Feedback with us, but if you do, you agree that we may use, copy, modify, adapt, publish, or exploit your Feedback for any purpose, including commercial purposes, without compensation, credit, or obligation to you. You acknowledge that all Feedback you provide will be considered non-confidential, and you grant us and our licensees a perpetual, irrevocable, worldwide, royalty-free license (with the right to sublicense) to use such Feedback in any manner we see fit. You also acknowledge and agree that if we develop or implement features, functionality, technology, processes, or content that is similar to your Feedback, that does not mean the idea came from you, and you will not have any claim against us for its use.

ESPORTS

You may not use any of our Games to organize, operate, or promote an esports competition, tournament, or league without our prior written consent. This restriction includes hosting esports events for profit, selling sponsorships, collecting entry fees, distributing prize pools, or otherwise commercializing competitive play. Small-scale community or casual esports events that are free to enter, not commercially sponsored, and limited to personal or local use are permitted, provided they comply with these Terms of Service and the Code of Conduct and do not harm Moonton’s rights or reputation. However, we reserve the right, in our sole discretion, to restrict, suspend, or shut down any such event at any time if it conflicts with our brand, esports programs, or other business interests. We retain the exclusive right to authorize, license, and manage all organized competitive uses of our Games. The license for Gameplay Streams granted to you in these Terms of Service applies only to your personal streaming of casual gameplay. It does not apply to the live streaming, rebroadcasting, or recording of esports competitions, tournaments, leagues, or other organized competitive events involving a Game. Any such streams or broadcasts are subject to separate agreements or licenses with Moonton and may only be carried out with our prior written consent.

PRIVACY

The collection, use, and disclosure of information about you and your use of the Games is governed by Moonton Games Privacy Policy. You are encouraged to review the Privacy Policy before playing our Games.

COPYRIGHT INFRINGEMENT NOTICES AND PROCEDURES

Moonton respects the intellectual property rights of others and, in accordance with the Digital Millennium Copyright Act of 1998 (“DMCA”) and similar laws in other jurisdictions, will respond to properly submitted notices of alleged infringement involving its games or platforms. If you believe that material available through our Games or platforms infringes your copyright, you may send a notice to Moonton’s Designated Agent ([email protected], Attn: Copyright Agent) that includes: (1) your physical or electronic signature; (2) identification of the copyrighted work claimed to be infringed or a representative list; (3) identification of the allegedly infringing material and information sufficient to locate it (such as a URL or in-game location); (4) your contact information; (5) a statement of your good faith belief that the use is unauthorized; and (6) a statement, under penalty of perjury, that the information you have provided is accurate and that you are the copyright owner or authorized to act on behalf of the copyright owner. If we remove or disable access to material in response to a notice, we may notify the user who uploaded it, and that user may have the right to file a counter-notification under applicable law. Upon receipt of a valid counter-notification, we may restore the material unless the copyright owner seeks a court order. We have a policy of terminating, in appropriate circumstances, the accounts of users who are repeat infringers, and you acknowledge that filing a false notice may result in liability for damages, including costs and attorneys’ fees, under the DMCA or similar laws.

USE OF ARTIFICIAL INTELLIGENCE

You acknowledge that Moonton may use AI technologies in connection with its Games, including for purposes such as gameplay balancing, anti-cheat detection, automated moderation, personalization, bug detection, analytics, and improving overall player experience. In some cases, AI may also be used to generate dialogue for non-player characters or other dynamic in-game interactions. These AI systems may analyze gameplay data, communications, or user behavior to help us keep the Games fair, safe, and engaging. Moonton does not guarantee that its AI systems will be error-free, uninterrupted, or capable of preventing all cheating, misconduct, or harmful behavior. You agree not to use any Game, Gameplay Stream, or Game Content to develop, train, tune, or improve any AI model, system, or dataset, whether for personal or commercial use. We reserve all rights in all gameplay data, player statistics, communications, and other Game Content, and you agree not to extract, copy, use, or otherwise exploit such data, statistics, or communications for AI-related purposes or for any purpose not expressly authorized by these Terms of Service.

COMPLIANCE WITH LAW

You may not access or play any of our Games if doing so would be unlawful under the laws, rules, or regulations of the country or jurisdiction where you reside or from which you access the Game. You are responsible for understanding and complying with all applicable laws, including laws relating to online conduct and the purchase or use of digital goods. By using the Game, you represent and warrant to us that your play of the Game is lawful where you live and where you access the Game. You agree that we may suspend, close or restrict access to your game account immediately if we determine that your use of a Game violates any applicable law or regulation, including export control or sanctions laws, or exposes Moonton or its licensors or service providers to legal risk.

WARRANTY DISCLAIMERS

To the fullest extent permitted by law, the Games, Virtual Items, Game Currencies, and all other Game Content are provided “AS IS” and “AS AVAILABLE,” without warranties of any kind, express or implied. We do not guarantee that a Game will be error-free, uninterrupted, secure, compatible with your device, or that any defects will be corrected. We only make our Games available to you for your personal, non-commercial use. Accordingly, we are not liable for business losses of any kind, such as loss of profit, business interruption, loss of goodwill, or loss of business opportunity. Just to be clear, we disclaim and exclude all warranties of merchantability, fitness for a particular purpose, title, and non-infringement, as well as any warranties arising from course of dealing or usage of trade. No advice, promise, statement, or information, whether oral or written, obtained from us or through a Game creates any warranty not expressly stated in these Terms of Service.

LIMITATIONS OF LIABILITY

To the fullest extent permitted by law, Moonton and its licensors, and service providers will not be liable to you, or any person or entity claiming through you or on your behalf, for any indirect, incidental, special, consequential, exemplary, or punitive damages arising out of or in connection with the Games, Virtual Items, Game Currencies, or Game Content, whether based on contract, tort, strict liability, or any other legal theory, even if Moonton has been advised of the possibility of such damages. Moonton’s total liability to you for all claims or losses arising out of or relating to the Games, Virtual Items, Game Currencies, or Game Content will not exceed the greater of: (1) the amount you paid for Games and Virtual Items in the twelve months preceding the claim, or (2) one hundred U.S. dollars (US $100). Multiple claims will not increase these amounts. Some jurisdictions do not allow the exclusion or limitation of certain damages, so some of the above limitations may not apply to you. Nothing in these Terms of Service excludes or limits Moonton’s liability where such exclusion or limitation would be unlawful, including liability for death or personal injury caused by negligence, fraud or fraudulent misrepresentation, or any liability that cannot be excluded or limited under applicable consumer protection or statutory rights laws (including, where applicable, the consumer laws of the European Union or the United Kingdom).

SEIZURE WARNING

A small percentage of people may experience seizures, blackouts, or other adverse effects when exposed to certain visual images, flashing lights, or patterns that may appear in video games, even if they have no history of epilepsy or seizures. If you have an epileptic condition, consult a doctor before playing. Stop playing immediately and seek medical attention if you experience symptoms such as dizziness, altered vision, eye or muscle twitches, loss of awareness, disorientation, or involuntary movements. Parents and guardians should monitor children when they play games, as they may be more susceptible to these effects. To reduce the risk, play in a well-lit environment, avoid playing when drowsy or fatigued, and take regular breaks.

INDEMNIFICATION

You agree to indemnify, defend, and hold harmless Moonton and its respective officers, directors, employees, and agents from and against any third-party claims, losses, costs, and expenses (including reasonable legal fees) arising out of or related to your violation of these Terms of Service or the Code of Conduct, your unlawful acts, or your User Generated Content, except to the extent such claims, losses, or costs result from Moonton’s gross negligence or willful misconduct.

HONG KONG LAW AND ARBITRATION OF DISPUTES

These Terms of Service, and the contract formed hereby, are governed by and will be interpreted in accordance with the laws of the Hong Kong Special Administrative Region of the People’s Republic of China, without regard to its conflict of law rules. Any dispute or claim arising out of or relating to these Terms of Service, including the existence, validity, interpretation, performance, breach or termination thereof, or any claim or dispute regarding non-contractual obligations arising out of or relating to these Terms of Service, shall be referred to and finally resolved by arbitration administered by the Hong Kong International Arbitration Centre (HKIAC) under the HKIAC Administered Arbitration Rules in force when the Notice of Arbitration is submitted. The law of this arbitration clause shall also be Hong Kong law. The seat of arbitration will be Hong Kong, the language of the arbitration will be English, and the tribunal will consist of one arbitrator. The arbitral award will be final and binding on the parties. You acknowledge and agree that where an affiliate or group company of Vizta Pte. Ltd. acts as the publisher of a Game in your jurisdiction, that affiliate or group company is a party to these Terms of Service. Any dispute or claim between you and such affiliate or group company arising out of or relating to a Game or these Terms of Service will be resolved in accordance with this provision. Notwithstanding the foregoing, we may seek injunctive or other equitable remedies in any court of competent jurisdiction to protect our intellectual property or preserve the status quo, and you consent to the jurisdiction of such courts for that purpose.

CLASS ACTION WAIVER AND INDIVIDUAL ARBITRATION

You and Moonton agree that any claims or disputes subject to arbitration under these Terms of Service must be brought on an individual basis only, and not as a plaintiff or class member in any purported class, collective, consolidated, representative, or mass action or proceeding. The arbitrator may not consolidate more than one person’s claims, and may not otherwise preside over any form of class, collective, consolidated, representative, or mass proceeding. You and Moonton further agree to work in good faith to minimize the administrative burden and cost of arbitration, and to avoid filing duplicative or abusive claims. If multiple substantially similar arbitration claims are filed, the parties agree that the arbitration provider may group such claims together for administrative efficiency (without consolidating the merits of the cases) and may stay, sequence, or otherwise manage proceedings to prevent unfair cost-shifting or abusive “arbitration bombing.” By accepting these Terms of Service, you waive the right to pursue or participate in class, collective, consolidated, representative, or mass actions or arbitrations against Moonton, whether in court or in arbitration.

NO CLAIMS AGAINST PARENT COMPANY

Your sole and exclusive remedy for any claim or dispute subject to arbitration under these Terms of Service is an arbitration claim against Vizta Pte. Ltd. or, where applicable, the affiliate or group company that acts as the publisher of the Game in your jurisdiction. You acknowledge and agree that you do not have any claim or cause of action against any other Moonton affiliate or member of the Moonton group of companies in connection with a Game or these Terms of Service.

WHAT HAPPENS IF A PROVISION IS INVALID?

If any provision of these Terms of Service or the Code of Conduct is found to be invalid, illegal, or unenforceable, that provision will be enforced to the maximum extent permitted by law, and the remaining provisions will stay in full force and effect. If a court or arbitrator requires modification to make a provision enforceable, the provision will be deemed modified to the minimum extent necessary to achieve its intent while remaining lawful.

KEEPIN’ IT FRESH

All video games change over time, and the rules applicable to a game have to change with it. We will update these Terms of Service and the Code of Conduct from time to time to reflect new features of a Game, to comply with new laws and regulations, to implement new business models, or just to keep things running smoothly across the many different countries where our Games are offered. When we make changes to these Terms of Service or the Code of Conduct, we’ll post them in-game or on our website. You are responsible for checking in-game notices and our website for updates. If you do not agree to the updated Terms of Service or Code of Conduct, you must stop playing our Games.

NOTICES

You agree that we may provide you with notices, disclosures, or other communications regarding the Games and these Terms of Service by sending them to the email address you provided when you created or updated your game account, or by posting them within a Game or on our official website. You are responsible for keeping your email address current and for regularly checking that account for messages. Where an affiliate or group company of Vizta Pte. Ltd. acts as the publisher of a Game in your jurisdiction, that entity may send notices on our behalf, and any notice sent by or to that affiliate or group company will be treated as notice sent by or to Moonton for all purposes under these Terms of Service. If you need assistance with technical support, billing, or other day-to-day issues, you should contact us through the customer support channels provided within the Game or on our website. If you want to provide formal legal notices to Moonton under these Terms of Service, you must send them by email to [email protected]. Legal notices will be effective only when actually received by us.

GENERAL TERMS

These Terms of Service are personal to you, and you may not assign or transfer them or any rights granted to you herein, in whole or in part, without our prior written consent. We may assign or transfer our rights and obligations under these Terms of Service without restriction. Our failure to enforce a provision of these Terms of Service is not a waiver of our right to do so later. Headings are for convenience only and do not affect interpretation. These Terms of Service, together with the Code of Conduct and any additional terms or policies incorporated by reference, constitute the entire agreement between you and Moonton regarding your use of the Games and supersede all prior understandings or agreements, whether written or oral, relating to the same subject matter. Provisions that by their nature should survive termination of these Terms of Service (including those relating to intellectual property ownership, restrictions on use of a Game, User Generated Content, feedback, disclaimers, limitations of liability, indemnification, governing law, dispute resolution, and general terms) will continue in effect after your account is closed or your license to use a Game ends.

APP STORE SPECIFIC TERMS

When you download or use a Game through an app store such as Google Play or the Apple App Store (“App Store”), you acknowledge that your use of the Game is also governed by the App Store’s terms and conditions. Those terms may include rules on purchases, billing, subscriptions, refunds, and account management. In the event of any conflict between these Terms of Service and the applicable App Store terms, the App Store terms will apply to the extent required by the store. The following supplemental terms shall apply when you access a Game through specific devices:

App Stores Specific - Notice Regarding Apple

These Terms of Service are a binding agreement between Moonton and you; Apple is not a party to these Terms of Service.

Apple is not responsible for the Game or the content thereof and has no obligation whatsoever to furnish any maintenance or support services with respect to the Game.
The license granted to you hereunder is limited to a personal, limited, non-exclusive, non-transferable right to install the Game on the Apple device(s) authorized by Apple that you own or control for personal, non-commercial use, subject to the Usage Rules set forth in Apple’s App Store Terms of Services. Moonton expressly authorizes use of the Game by multiple users through the family sharing or any similar functionality provided by Apple..
In the event of any failure of the Game to conform to any applicable warranty, you may notify Apple, and Apple will refund the purchase price for the Game, if any, to you. To the maximum extent permitted by applicable law, Apple will have no other warranty obligation whatsoever with respect to the Game.
Apple is not responsible for addressing any claims by you or a third party relating to the Game or your possession or use of the Game, including without limitation (a) product liability claims; (b) any claim that the Game fails to conform to any applicable legal or regulatory requirement; and (c) claims arising under consumer protection or similar legislation.
In the event of any third-party claim that the Game or your possession and use of the Game infringes such third party’s intellectual property rights, Apple is not responsible for the investigation, defense, settlement or discharge of such intellectual property infringement claim.
You represent and warrant that (a) you are not located in a country that is subject to a U.S. Government embargo, or that has been designated by the U.S. Government as a “terrorist supporting” country; and (b) you are not listed on any U.S. Government list of prohibited or restricted parties.
You must comply with applicable third party terms of agreement when using the Game, e.g., if you have a VoIP application, then you must not be in violation of their wireless data service agreement when using the Game.
Apple and its subsidiaries are third party beneficiaries of these Terms of Service and upon your acceptance of the terms and conditions of these Terms of Service, Apple will have the right (and will be deemed to have accepted the right) to enforce these Terms of Service against you as a third party beneficiary hereof.

Google Play Specific Terms - Notice Regarding Google

By downloading the Game from Google Play (or its successors) operated by Google, Inc. or one of its affiliates (“Google”), you specifically acknowledge and agree that:

to the extent of any conflict between (a) the Google Play Terms of Services and the Google Play Business and Program Policies or such other terms which Google designates as default end user license terms for Google Play (all of which together are referred to as the “Google Play Terms”), and (b) the other terms and conditions in these Terms of Service, the Google Play Terms shall apply with respect to your use of the Game that you download from Google Play, and
you hereby acknowledge that Google does not have any responsibility or liability related to compliance or non-compliance by Moonton or you (or any other user) under these Terms of Service or the Google Play Terms.

SUPPLEMENTAL TERMS

These Terms of Service contain a jurisdictional supplement that applies for certain countries or regions. In case of any inconsistency between the jurisdictional supplement and other provisions in these Terms of Service, the jurisdictional supplement will take priority.