Tides of Annihilation Official Website Privacy Policy

Effective Date: 【Feb. 13, 2025】

    Welcome to the official website of 【Tides of Annihilation】  to enjoy the services provided by Chengdu Ophiuchus Technology Co., Ltd. (hereinafter referred to as “We” or “this Website”). We pay great attention to your privacy and the protection of personal information. We are committed to strictly comply with PRC laws and regulations and take appropriate security measures to protect your personal information. We will handle your personal information only for the purposes set forth in this Privacy Policy (“Privacy Policy”); if we use your personal information for any other purposes not specified in the Privacy Policy, or use the collected personal information for other purposes, or if your separate consent is required according to the laws and regulations, we will inform you in a reasonable manner and seek your consent again before the use. Before using our website and services, please read this Privacy Policy carefully to understand how we collect,     use, store, share and protect your personal information. If you object to the manners by which we handle your personal information described in this Privacy Policy, please stop providing your personal information and do not use this website. By using this website/continued use of this website, you will be deemed to have accepted the terms of the Privacy Policy.

If you are under the age of 18 or do not meet the age requirements for using this Website in the place where you live, or if there are other legal requirements that are not compatible with user behavior, please follow the local legal requirements to (A) not use this Website, or (B) read this Privacy Policy under the supervision and guidance of your legal guardian (“Guardian”), and only use this Website after ensuring that your Guardian agrees to the content of this Privacy Policy as required by applicable laws.

1. The personal information we collect and use

In the process of your use of our website services, we will collect the information which you proactively provide or which is generated due to the use of website services: to provide you with services, to optimize our services and to protect your account security. We will only collect the necessary personal information within the scope permitted by laws and regulations, and for the purposes consented to by you, including but not limited to the following:

(1) Information proactively provided by you

We will collect your mobile phone number (mainland China users) or email address (users outside mainland China)  for completing the game reservation (processing your game reservation request, confirming the game reservation and update the release status to you), promotions and follow-up notifications (sending you promotional information before the game is launched, including but not limited to promotional activities, updates etc.).

(2) Information collected in your use of the website services

We will collect your device model, operating system version, unique device identifier, browser type and version, network type and other device information, for the purpose of ensuring the normal operation of the website services (including response to your consultation, complaints and suggestions, detection and prevention of possible security threats, fraud or other illegal acts); we will collect your IP address, access time, access pages, click records and other log information for website maintenance and user experience optimization. We will strictly comply with relevant laws and regulations and only collect the information necessary to achieve the above functions.

(3) Cookies and similar technologies

We use necessary cookies and similar technologies to ensure the normal operation of our website services. You can check and modify your cookie settings in the【cookie settings】. Please also note that third parties may also use cookies, over which we have no control.

(4) Information generated by your use of our website services

We will collect the frequency and situation of your use of our website services, failure information, performance information, etc., for analyzing the operation of our products to ensure the security of our services, optimize our products, and improve the quality of our services. However, we will anonymize or de-identify the above information for internal analysis, and we will not combine such information we store in the analysis software with the personally identifiable information you provide.

Please understand that the functions and services we provide to you are constantly updating and developing. If a function or service is not mentioned in the above which collects your information, we will explain the content, scope and purpose of such information collection to you separately through page prompts, interactive processes, website announcements and other manners, and obtain your consent again before use.

In addition, according to the relevant laws, regulations and national standards, we may collect and use your personal information in the following circumstances, which do not require your consent:

(a) it is necessary for the performance of legal duties or obligations;

(b) it is necessary for dealing with public events or protecting the life, health and property safety of natural persons under emergency circumstances;

(c) for the purposes of news reporting, supervision by the public opinion and other acts in the public interest, which handles the personal information within a reasonable scope;

(d) within a reasonable scope, to handle the personal information disclosed by an individual or other legally disclosed personal information in accordance with laws and regulations;

(e) it is necessary to sign and perform the contract required by you;

(f) Other circumstances stipulated by laws and regulations.

2. Storage and protection of personal information

(1) How we store the information and for how long the information is stored

We store your information in a secure way, including local storage, databases, and server logs. In general, we will only store your personal information for as long as is necessary to fulfill the purposes of the services or under the conditions required by laws and regulations. After the expiration of the retention period, we will delete or anonymize your personal information. We determine the retention period of personal information by referring to the following criteria, among which the longer shall prevail:

    (a) to complete the business functions that you have agreed to use;

    (b) to guarantee the safety and quality of the services we provide to you;

    (c) with a longer retention period to which you agree;

    (d) whether there are other provisions for the retention period.

(2) Where the information is stored

We will store the collected personal information in the People's Republic of China, in accordance with the laws and regulations. In the following circumstances, we will ensure that we provide your personal information to foreign entities, which are located outside of the People's Republic of China, subject to compliance with our obligations under laws:

    (a) expressly required by the applicable laws;

    (b) your express consent is obtained;

    (c) for your cross-border transactions via the Internet or other personal activities.

    For the above situations, we will ensure that your personal information is protected to a degree no less than that described in this Privacy Policy through contracts and other means.

(3) Notices when the product or service ceases operation

When our products or services ceases operation, we will make notices in accordance with relevant laws and regulations, and protect your legitimate rights and interests according to laws and regulations.

3. Sharing, transfer and public disclosure of personal information

(1) Sharing

We do not share your personal information with third parties except in the following circumstances. If there are other sharing of your personal information or you require us to share your personal information to a third party for purposes beyond the original consent, we will directly or indirectly obtain your express consent through the third party.

    (a) to achieve basic functions or to provide services: such as sharing with SMS or email service providers, which are used to send you reservation confirmations or promotion contents. We will require third parties to strictly comply with the privacy protection requirements and not use your information beyond the scope.

    (b) to comply with law: to comply with laws and regulations or the requirements of the authorities.

    (c) to obtain your separate consent: we will inform you in a prominent way and share your information after obtaining express consents.

    (d) to conduct statistical analysis and research: to improve our security management and technical research capabilities, promote service security and technology levels, in order to provide the users with better services, we will share the de-identified or anonymized information with research institutions, scientific institutes, universities and other institutions to the extent reasonably necessary to ensure the proper purposes and security. Without your express consent, we will not share information that can be used to identify you personally with such institutions.

    (e) to share with third parties: we may share de-identified or anonymized device information or statistical information with advertising service providers or other partners, or share de-identified or anonymized label information with third party platforms when you download/access the product through the platforms, in order to analyze and optimize the effectiveness of the feeds, and/or to confirm the results of your participation in the platform activities. The above information cannot be associated with your identity, and we will require the use of such information in strict compliance with relevant laws and regulations to protect your legitimate rights and interests.

(2) Transfer

We will not transfer your personal information to third parties without your consent. With the continuous development of our business, we may carry out mergers, acquisitions, asset transfers and other transactions, we will inform you of the relevant circumstances in accordance with laws and regulations and no less than the standards set in this Privacy Policy, to continue to protect your personal information, or require the new handlers to continue to protect your personal information.

(3) Public disclosure

We will not publicly disclose the personal information we collect unless required by laws and regulations or with your express consent. We will only publicly disclose your personal information in the following circumstances: according to your requirements in the manner that you have explicitly agreed to, to publicly disclose the personal information you have specified required; where it is necessary to provide your personal information in accordance with the requirements of laws, regulations, mandatory administrative law enforcement or judicial requirements, we may publicly disclose your information according to the type of information and disclosure manner required.

4. Security Protection measures

(1) We strive to provide protection for the security of the users' information to prevent information leak, loss, improper use, unauthorized access and disclosure. We use multi-dimensional security protection measures to ensure that users' personal information is protected at a reasonable level of security, including technical protection measures, management system control, security system guard and many other aspects.

We adopt technical protection measures in line with the industry standards, including but not limited to firewalls, encryption (such as SSL), de-identification or anonymization, access control, etc. We regularly conduct security audits and risk assessments to prevent information leakage, tampering and loss.

(2) Please note that no measure can completely protect your personal information. In the event of a security incident such as a personal information leak, we will implement an emergency plan to prevent the expansion of the incident. After the occurrence of a security incident, we will inform you of the basic situation of the security incident, the disposal measures and remedial measures that we will take or have taken, as well as our suggestions for you, in the form of announcements, notifications or emails. If it is difficult to notify you individually, we will issue a warning through public announcements on the website or other manners.

5. Your Rights

During your use of our services, we may provide you with operational settings according to the specific circumstances of the game products, so that you can query, copy, correct, supplement, delete or withdraw your personal information. You may refer to the specific guide of the corresponding game products for operation. In addition, we have also set up a complaint channel, and your feedbacks will be dealt with in a timely manner.

(1)    Rules for collection and use of personal information your query and access

You can query and access our rules for collection and use of your personal information at any time on the homepage of our website【www.playtoa.com】.

(2)    Query, copy, correction, supplementation and deletion of personal information

You can contact us to make requests through the contact information described in this Privacy Policy. However, please note that when you contact us for a personal information request, in order to protect the security of your account and personal information, we may verify your identity. For your reasonable request, we will do our best to support. However, we may not be able to respond to your request under circumstances which exceed the scope of our personal information storage, exceed the reasonable limits, or if your request will cause serious damage to the legitimate rights and interests of you or other third parties.

(3)    Withdrawal of consent

You may withdraw the consent you have granted to handle your personal information at any time, but the withdrawal will not affect the legality of the personal information handling activities based on your consent before withdrawal.

(4)    Cancellation of account

You can request for cancellation of your reservation account, after cancellation we will delete or anonymize your personal information.

You may submit the above request through the contact information set out in this Privacy Policy.

6. Protection of Minors

We attach great importance to the protection of personal information of minors (persons under the age of 18 in China, and other persons pursuant to the applicable laws governing such age requirements in other relevant jurisdictions) and children (persons under the age of 14 in China, and other persons pursuant to the applicable laws governing such age requirements in other relevant jurisdictions). Children shall not purchase our products or services without the consent of their Guardians. We recommend that minors and children purchase and use our products or services, and provide personal information only with the consents of your Guardians. In cases where we have collected personal information from minors or children with their Guardian’s consent, we will only use or publicly disclose the personal information as permitted by the applicable laws or as necessary to protect minors and children. And if we become aware that we have collected personal information from minors or children without their Guardian’s prior consent, we will delete the personal information as soon as possible, and take measures as required by the applicable laws. You may also submit a request for correction or deletion to us. If you have any questions, suggestions or complaints on minor and children's personal information, you may contact us through the contact information set out in this Privacy Policy.

7. Updates of Privacy Policy

We may update this Privacy Policy from time to time according to the changes in laws and regulations or the service needs. After the update, we will publish the latest version in a reasonable manner on this Website, and explain the updated contents. When significant changes are made, we will notify you in a reasonable manner.

8. Contact Us

If you have any questions, comments or complaints about this Privacy Policy or matters on the protection of personal information, you can contact us by:

Email: 【customerservice@cd-ophiuchus.com】

We will review as soon as possible and respond to your request within 15 working days or within the time limit set by laws and regulations.

9. Miscellaneous

(1)    If there is any dispute arising out of this Privacy Policy and our handling of your personal information, you may file a complaint with【Chengdu Gaoxin District People’s Court】.

(2)    If you believe that our handling of personal information has harmed your legitimate rights or interests, you may also file a complaint with relevant government authorities.

10. Supplemental EEA+ Privacy Statement

If you are located in the European Economic Area (EEA), the United Kingdom or Switzerland (collectively, the “EEA+”), please see our Supplemental EEA+ Privacy Statement at this Section. We address this Supplemental EEA+ Privacy Statement to individuals located in the EEA+ only. This document supplements our Privacy Policy and describes how we process your personal data. If there are any inconsistencies between the Privacy Policy and this Supplemental EEA+ Privacy Statement, this Statement prevails.

If you are located in the EEA, the EU General Data Protection Regulation applies to our processing of your personal data, as well as local data protection laws, as the case may be. If you are located in the UK, the UK General Data Protection Regulation applies to our processing of your personal data. References to the "GDPR" are references to the General Data Protection Regulation as it applies in the country where you are located. If you are located in Switzerland, the Swiss Federal Data Protection Act (the "FDPA") applies to our processing of your personal data, and references to the GDPR below shall be interpreted analogously for the purposes of applying the FDPA.

(1)    Who is the data controller?

The data controller is Chengdu Ophiuchus Technology Co., Ltd., the registered address is 【No. 22-31, 5th Floor, Building 2, No.1366 Middle Tianfu Avenue, Chengdu Gaoxin District, Sichuan Province, China】. To contact our EEA and UK GDPR representatives, please contact【customerservice@cd-ophiuchus.com】.

(2)    What types of personal data do we collect and how do we collect it?

Please see Article 1 above.

(3)    For what purposes do we process personal data?

Please see Article 1 above.

(4)    What lawful bases of processing and legitimate interests do we rely on?

If we have entered into a contract with you and the processing is necessary for us to perform our contract with you or take steps at your request prior to entering into the contract, the lawful basis is that it is necessary per Article 6(1)(b) GDPR.

If the processing is necessary for us to comply with an applicable legal obligation under EEA or UK laws, the lawful basis is that it is necessary per Article 6(1)(c) GDPR.

In some cases, the processing is necessary for us to realize a legitimate interest based on an assessment of that interest and your privacy and other fundamental interests, including where we endeavor to provide you with a positive user experience, seek to comply with the laws or regulations outside of the EEA or UK, to maintain the security and integrity of our products and services, operate and optimize our business, improve our products and services, develop new services, and manage our relationships with users. In these cases, the lawful basis is that it is necessary per Article 6(1)(f) GDPR. More information on our assessments of legitimate interests balanced against privacy and other fundamental interests is available on request.

In some cases, we rely on your consent to process your personal data, per Article 6(1)(a) GDPR, including when we use non-essential cookies or other technologies to process your data. In these cases, you can withdraw your consent at any time with future effect by using the consent settings on our products and services or by emailing us at 【customerservice@cd-ophiuchus.com】 with a description of what data processing activities of ours you would like to withdraw your consent from. 

(5)    What categories of recipients receive personal data from us?

Please see Article 3 above.

(6)    Where is your personal data processed and on what basis do we transfer personal data across borders?

We may disclose personal data to third parties in locations including the People’s Republic of China. We take measures to ensure that our processors provide an adequate level of data protection by ensuring appropriate safeguards are in place and performing data transfer arrangements as appropriate. If you have any questions or would like more information, you can contact us at【customerservice@cd-ophiuchus.com】.

(7)    How long do we process personal data?

Please see Article 2 above.

(8)    What data protection rights do you have?

In the EEA, Switzerland and the UK you have the following rights, subject to the conditions under the GDPR and/or local data protection law:

- To object, on grounds relating to your particular situation, to the processing of your personal data by us. This includes the right to object to our processing of your personal data for direct marketing (also known as mass marketing under Swiss law, for which purpose we are not currently processing your personal information) and the right to object to our processing of our personal data where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party. If we process your personal data based on our legitimate interests or those of a third party, or in the public interest, you can object to this processing, and we will cease processing your personal data, unless the processing is based on compelling legitimate grounds or is needed for legal reasons. Where we use your personal data for direct marketing for our own products and services, you can always object and opt out of future marketing messages using the unsubscribe link in such communications or through other means.

- To obtain from us confirmation as to whether your personal data is being processed, and, where that is the case, to request access to details about how we process your personal data and copies of the personal data.

- To obtain from us the rectification of inaccurate personal data concerning you.

- To ask us to erase your personal data to the extent it is not required for legally required purposes or necessary for security and integrity purposes.

- To request restriction of processing of your personal data, in which case, it would be marked and processed by us only for certain purposes.

- To receive your personal data which you have provided to us in a structured, commonly used and machine-readable format and you have the right to transmit the personal data to another entity without hindrance from us.

- To withdraw your consent at any time. This will not affect the lawfulness of our use of your personal data before your withdrawal.

- To lodge a complaint with a supervisory authority.

- In some jurisdictions such as France and Portugal, you also have the right to provide us with guidelines as to the processing of your personal data after your death.

You may view a list of supervisory authorities in the EEA, UK and Switzerland and their respective contact information here:

- EEA: https://edpb.europa.eu/about-edpb/about-edpb/members_en

- United Kingdom: https://ico.org.uk/global/contact-us/

- Switzerland: https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html

To submit a request to exercise your privacy rights, you can contact us by emailing 【customerservice@cd-ophiuchus.com】. In your request, please describe what rights you are exercising and how you would like us to assist. We may need to request specific information from you to help us verify your identity and that you have the right to request what you are requesting. These are security measures to ensure that we do not disclose personal data to any person who has no right to receive it, or otherwise process the data in unauthorized ways. We may also contact you to ask for further information about your request to clarify the scope of your request and speed up our response. We will respond to requests to exercise privacy rights according to applicable laws.

(9)    Are you required to provide us with your personal data?

You are not legally required to provide personal data to us but we may not be able to provide our products and services without receiving some personal data from you as illustrated in Article 1.

11. Supplemental Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey or California Privacy Statement

If you reside in Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Hampshire, New Jersey or California, please refer to the Supplemental Privacy Statement in this Section.

We address this Supplemental U.S. Privacy Statement to U.S. residents only. This Statement does not reflect our collection, use or disclosure of U.S. residents’ personal information where an exception under U.S. privacy laws applies.

(1)    Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Hampshire And New Jersey

The following is only addressed to residents of Virginia, Colorado, Connecticut, Utah, Oregon, Texas, Montana, Delaware, Iowa, Nebraska, New Hampshire and New Jersey.

Subject to the conditions under applicable laws, you have rights to request that we:

- Confirm whether or not it is processing your personal data and provide copies of such data;

- Correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of processing of the consumer's personal data, except this right is unavailable in Iowa and Utah;

- Delete personal data provided by or obtained about you;

- Opt out of the processing of your personal data for the purposes of: (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.  Please note that we are not currently processing your personal information for these purposes.

(2)    California

The following is only addressed to residents of California.

Notice of Collection: Please see Article 1 above for information about the types of personal information we collect and the purposes for which we use personal information. We may collect, use and disclose California residents’ device information as illustrated in Article 1, which the CCPA qualifies as personal information. Further below is a copy of our CCPA Privacy Policy, which includes our Notice of Right to Opt-Out of Sharing of Personal Information.

We retain personal information only as necessary for the purposes for which the personal information is processed or for legal requirements. The length of time for which we retain personal information depends on the purposes for which we collect and use it and how long we need to retain it to comply with applicable laws (including for the purpose of satisfying any legal, regulatory, tax, accounting or reporting requirements). Once personal information is no longer necessary for the purposes for which we collected it, we will delete it.

CCPA Privacy Policy:

A. Right to Know About Personal Information Collected, Disclosed, or Sold

We describe here the personal information we collect, use, and disclose about California residents. You have the right to request that we disclose what personal information we collect, use, disclose and sell about you specifically (“right to know”). To submit a request to exercise the right to know, please email 【customerservice@cd-ophiuchus.com】and include “California Request to Know” in the subject line. Please specify in your request the details you would like to know, including any specific pieces of personal information you would like to access.

B. Our Personal Information Handling Practices over the Preceding 12 Months

We have set out below the categories of personal information we have collected about California residents in the preceding 12 months, as enumerated in the CCPA’s definition of “personal information”.

- email address

- device model, operating system version, unique device identifier, browser type and version, network type and other device information

We collected all of these types of personal information from California residents directly and used all of these types of personal information as described in Article 1 above, which describes how we use each type of personal information. We disclosed this information as described in Article 3 above.

C. Right to Request Deletion of Personal Information

You have a right to request the deletion of personal information that we collect or maintain about you. To submit a request to delete personal information, please contact us by mail or submit an email request to 【customerservice@cd-ophiuchus.com】 and include “California Request to Delete” in the subject line. Please specify in your request the personal information about you that you would like to have deleted, which can be all of your personal information as required by the CCPA.

D. Notice of Right to Opt-Out of Sharing of Personal Information / Do Not Share My Personal Information

You have the right to opt-out of the sharing of your personal information. We disclose personal information to third-parties and partners. You may opt out of such sharing in our products and services by emailing us at【customerservice@cd-ophiuchus.com】. Please note that we may need to verify your identity before acting on a request.

E. Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

You may not be discriminated against because you exercise any of your rights under the CCPA.

F. Verification Process and Authorized Agents

Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information. In your request or in response to us seeking additional information, you, or your authorized agent, must provide sufficient information to allow us to reasonably verify that you are, in fact, the person whose personal information was collected, which will depend on your prior interactions with us and the sensitivity of the personal information being requested. We may ask you for information to verify your identity and, if you do not provide enough information for us to reasonably verify your identity, we will not be able to fulfil your request. We will only use this information for the purposes of verifying your identity and to fulfill your request.

G. Contact Information

If you have any questions about this Privacy Policy or if you want to exercise your privacy rights, please contact us at 【customerservice@cd-ophiuchus.com】 or by sending us postal mail at 【No. 22-31, 5th Floor, Building 2, No.1366 Middle Tianfu Avenue, Chengdu Gaoxin District, Sichuan Province, China】.