Privacy Policy

Privacy Policy

PLEASE NOTE THAT THIS PRIVACY POLICY APPLIES ONLY TO THOSE USERS OF THE SERVICES WHO ARE AGE 13 AND OLDER. SPECIAL PROCEDURES ARE USED WHEN COLLECTING INFORMATION FROM USERS UNDER THE AGE OF 13, WHICH ARE DISCUSSED IN THE “POLICIES REGARDING CHILDREN” SECTION BELOW.

Privacy Policy

CHORDHERO Limited develops and publishes many social games for smartphones and mobile devices. CHORDHERO Limited, its subsidiaries, parent companies, affiliates, joint ventures and other corporate entities under common ownership (collectively, “we”, “our”, or “us”) respect our users’ (“users” or “you”) privacy rights. We adopt this Privacy Policy to explain how we collect, use, store, disclose and manage the personal information (“Personal Information”) you provide to us when using, or about to using, any of our applications, games or software (collectively, the “Services”).

You agree to our collection, use, storage, disclosure and management of your Personal Information as explained in this Privacy Policy when you access or use our website and domain name, and any of the Services, and accept this Privacy Policy in registration or game installation.

We have the right to amend this Privacy Policy from time to time. Use of your information we collect now is subject to the Privacy Policy in effect at the time such information is used. Please check this Privacy Policy every time you use our sites or the Services to make sure that you are aware of any changes in our privacy practices. Our Privacy Policy will display the date it was last updated. If we choose to make any material revisions to this Privacy Policy, we will post a revised policy on our sites and/or mobile products to inform you and other users. You understand that you accept the amendments to our Privacy Policy by continuously using our sites or the Services.

Except otherwise as mentioned herein, this Privacy Policy does not apply to information collected and stored by (1) web-based applications that are built from our mobile applications but published by other third parties, (2) or through websites and services provided by other third party companies or entities to which our Services may link, or (3) mobile applications that we distribute on behalf of other third parties which mobile applications are hosted by such third parties.

IF YOU CHOOSE NOT TO ACCEPT THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT USE ANY OF OUR SITES, MOBILE PRODUCTS OR SERVICES.

Personal and Non-Personal Information

We collect both Personal Information and Non-Personal Information.

“Personal Information” is information about you that can be used to contact or identify you on-line or off-line, such as your name, birth date, home address, email address, credit card information and phone number. “Personal information” may also include your unique device or user identifier when the identifier is combined with your personal information.

“Non-Personal Information" is information that, by itself, cannot be used to identify or contact you personally and can include gender, age or interests and cannot be used to connect with you. This Privacy Policy does not restrict or limit our collection of aggregate information or Non-Personal Information.

Personal information also does not include “aggregate information”. Aggregate information is data we collect about the characteristics and activities of the users and visitors of the Services and enhance our Services and our sites, from which any Personal Information has been removed. Such information may include demographic information, such as your unique user or user identifier (when not matched with or tie to your Personal Information), city of residence, information about your computer, software, platform and Internet IP address. We collect aggregate information about the use of the Services to provide the best possible service and allow us to make certain recommendations and internal reports and share such information with our partners about how our customers use the Services so that our partners also understand how people use the Services and they can provide you with an optimal user experience.

We may combine Personal Information and Non-Personal Information to be used to improve your experience with or to aggregate it with information collected from other users to improve or analyze the Services.

How Personal Information is Collected

To assist us in personalizing and improving the Services, and allow our users to set up a user account and profile that can be used to personalize their experience in using the Services, Personal Information are collected from you.

We may collect your Personal Information in a number of ways such as, during your (1) registration or log-in for games, games subscriptions or our websites, (2) creation of a personal profile, (3) download and use of our mobile applications and web-based applications, (4) purchase of a licence to use in-game virtual money or virtual items directly from us, any relevant billing and financial information necessary to process your charges will be collected by us, which may include your email address, (5) request for services from third party service providers on our websites or the Services (such as, your response to advertisements therein), (6) customer support or technical service requests, (7) communications with other registered users on our websites or through the Services, and (8) participations in promotional or marketing activities, surveys, and other alerts. Depending on the activity in which you are involved, information that we collect from you will vary.

Cookies and other technical information - We collect certain technical information when you use the Services in order to (i) manage advertising; (ii) analyze the usage of our sites and services; and (iii) provide a more personalized experience. We and our service providers use tracking technologies to collect and analyze certain types of technical information, including cookies (cookies are small files applied to your browser to track movements within websites), platform type, device and identifiers, domain names, IP addresses, landing pages, the number of clicks, pages viewed and the order of those pages, referring and exit pages, URLs, the amount of time spent on particular pages, browser types and language, game state and the date and time of activity on our sites or games, and other similar information. For our internal use, we may also associate this information with your user ID number. However, please note that we do not combine the general information collected through cookies with your other Personal Information to inform us your identity or what your email address or screen name is.

Third-party advertising companies may be used by us to serve advertisements on our sites. This Privacy Policy covers only the use of our cookies and the use of cookies by any other advertisers are subject to their respective privacy policies. Our advertising partners, who may set cookies, may deliver advertisements appearing in the Services to users, and may also use other third-party advertising technology to target advertising in the Services. When we serve advertisements to you, an unique third-party cookie or cookies may be placed on your computer. The advertisements server uses these cookies to identify your computer or other device each time they serve you an advertisement in order to gather information about you or others users who use your computer or device. Based on such information, advertisement networks will deliver targeted advertisements that will be of interest to you.

Other technologies may also be used by us, which include: (i) flash cookies (which help us in preventing fraud, remembering your in-game preferences and speeding up load times); (ii) tracking pixels (which permit us to advertise more efficiently by (a) not serving certain promotional messages to our current users, (b) identifying the source of a new installation or (c) delivering advertisements to you on other websites); and (iii) web beacons (which assist us in determining if a certain page was visited or whether an e-mail was opened).

Most browsers have an option to alert you on attempts to place cookies on your computer or other devices or disable the cookie feature, which will not permit your browser to accept new cookies, or allow you to decide to accept each new cookie in a variety of ways. If you disable cookies, you may run the risk of losing some of the features and functionality of playing our games or using the Services, as you may need our cookies to track and enhance your game activities. We strongly advise you not to disable the cookies feature so that you can enjoy some of the Services’ most attractive features.

When you download and use any of our games on your mobile device or on a personal computer, we also collect information regarding your in-game actions, your unique device or user identifier and country in which the mobile phone or device is registered or located, and may collect your mobile phone number, and other information you decide to provide, such as user name, or e-mail address. When our mobile or web-based applications are used, we also collect information about your mobile device type, operating system, browser type and IP address. We use such information in relation to providing our mobile and web-based applications, such as to authenticate you and to communicate with you regarding the Services by push notification, SMS, e-mail, text message or other electronic means to your mobile device. By using the Services, you agree to letting us retain all the above information in any form as we see fit. We only collect information to the extent that is reasonably necessary to comply with your requests and our legitimate business objectives.

How and Where Personal Information is Stored, International Transfer and Personal Information Security

We are an international organisation and the Personal Information, Non-Personal Information or aggregate information we collect or receive are stored in data storage facilities in different locations. For example, if you are located outside Hong Kong and choose to provide information to us, we may transfer your Personal Information to Hong Kong and processes it there and your submission of such information represents your agreement to that transfer. Such information may be used, transferred to, processed or held by computers in other countries, including countries outside your country of residence or governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction, and used for the purposes set out in this Privacy Policy.

We may use third parties service providers to collect, process and store your Personal Information, Non-Personal Information or aggregate information in the data storage servers and/or equipment owned and operated by such third parties, and such third parties will be instructed to comply with our Privacy Policy and to use your Personal Information only for the purposes for which they have been engaged by us. We are not responsible for these third parties’ acts and omissions, except as provided by the applicable laws. Please note that the data protection laws of other countries may not be the same as those of your country of residence. You consent to the transfer, storage and processing of your Personal Information as mentioned in this section.

We also understand the importance of keeping your information safe and secure. We have implemented commercially reasonable security measures to safeguard and secure your information and to prevent the destruction, loss, misuse and alteration of information under our control. There is no transmission method over website or Internet that is completely flawless, even though we have our commercially reasonable security measures in place against possible breaches of our sites’ security and our user records and databases, and we are not liable for data loss, hacking, unauthorized access or other breaches in relation to our servers and systems or guarantee the security of user account information. Any transmission of your information to our sites is done at your own risk. After we receive your information, we have procedures and security measures in place to attempt to prevent any unauthorised access. You should also limit access to your computer (or other device) and browser by logging out after you have finished accessing your account to ensure that there is no unauthorized access to your account and Personal Information.

How Personal Information is Used

We may use your Personal Information, Non-Personal Information or aggregate information collected from you in any one or more of the following ways to:

• provide advertising and promotional information in connection with the Services
• prevent fraud or potentially illegal, unethical or legally actionable activities, and enforce the relevant terms of service
• provide to government or law enforcement officials to protect our rights and property as well as those of third party and protect the safety of the public or any person
• notify you of new game releases or updates
• communicate with you about the Services
• provide technical support and respond to user requests
• operate, maintain and manage the Services
• solicit feedback and input to improve the Services, including our websites, products and services and personalize your user experience, diagnose problems with our server and develop new product and services

How Personal Information is Shared

In general, we do not sell or rent your Personal Information to other third parties. Your Personal Information is only shared in the following circumstances:

With Your Consent – Except as mentioned in this Privacy Policy, we will notify you when your Personal Information may be shared with other third parties, and you may elect not to share such information.

Users’ profiles – We may display your user profile information including your username and other information entered by you (“User Submissions”) to other users to facilitate user interaction within the Services.

Offer wall – Our games may display a third party hosted “offer wall”. Such offer wall allows third party advertisers to provide virtual money to users and in return such user will respond to an advertisement or complete an advertisement offer. Such offer wall may appear in the games and be displayed to you based on certain information, such as your geographic area or demographic information. When you click on one of these offer walls, you will leave our or our partners’ site at the time. A unique identifier, such as your user ID number, will be shared with the offer wall provider in order to prevent fraud and properly credit user accounts.

Protection of our rights and those of others – If we believe in good faith that the release of your Personal Information is necessary to comply with the relevant law and regulation, enforce or apply our conditions of use and other agreements, or protect our rights, property, or safety, or those of our employees, users or others, we may do the same. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

Responses to User Submissions – We may send email and other communication to you relating to your User Submissions as part of the Services. You agree that by posting such User Submissions, you may be receiving email and other communication from us that we determine in our sole discretion relate to your User Submissions.

Advertisers – You agree that any of the information we have collected from you (including information you may have decided not to show to other users) may be used by us to choose or allow the advertisers to choose the appropriate audience for their advertisements.

Affiliated businesses that we do not control – A variety of businesses may become affiliated and work closely with us. Through the Services, items may be sold to you by such affiliated businesses, and services or products may also be provided or sold to you by us jointly with such affiliated businesses. You can recognize when an affiliated business is associated with your transaction, and we may share your Personal Information that is related to such transactions with that affiliated business.

Transfers of business – If we decide to dispose our assets, we may include user information as part of the business assets that are transferred to the buyer. At the same time, if we, or substantially all of our assets, were acquired, or in the unlikely event that we go out of business or enter bankruptcy, information of our users would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and your Personal Information may continue to be used by any of our purchasers or the purchasers of our assets as set forth in this Privacy Policy.

Agents – We also use other companies and third parties to perform tasks for us and we will share your information with them to provide you with the relevant products or services. When such third parties collect or possess any information other than non-personal, anonymous and/or aggregated data, they do not have any right to use such Personal Information we share with them beyond what is necessary to assist us, unless you are told otherwise. Such agents are required to use your Personal information consistently with our Privacy Policy and protect and maintain the collected information’s confidentiality during their engagement by us and refrain from using such information for any purpose other than to provide the Services for us without your express consent. You consent to our sharing of Personal Information for such purposes.

To improve our games or the Services to serve you better, we may also use your Personal Information for our own marketing and demographic research. This Privacy Policy does not restrict or limit our collection of aggregate information, and we may disclose this information to any third parties.

Policies Regarding Children

Please note that this “Policies Regarding Children” section only applies to procedures when collecting information from children under the age of 13.

We recognise the obligation to protect Personal Information obtained from young children. The Services are not geared toward children under the age of 13. When we collect any personal information (as defined in the Children’s Online Privacy Protection Act (“COPPA”), which was established by U.S. Congress to protect children’s online privacy) from children under the age of 13, we either (1) comply with the requirements of COPPA; or (2) take all reasonable steps to promptly remove from our files and records such information. For more information about COPPA and children’s rights to online privacy, please visit the Children’s Privacy section of the Federal Trade Commission’s website at http://www.business.ftc.gov/privacy-and-security/childrens-privacy.

In addition, we advise that children over the age of 13 shall ask their parents for permission before transmitting any of their information to anyone over the Internet, and we suggest parents to tell their children not to provide their personal information, without permission, when using the Internet.

What types of information do we collect from children?

We may collect persistent identifier (such as an IP address, mobile device id, or a unique device identifier) from the child. However, we do not use such information for any analytical purpose in relation to the child.

How do we use and share the personal information collected from children?

We may request a user enters a birthdate in order to establish the age of the user. This birthday is not used for any purpose other than to identify the user as a child. We provide a restricted version of our services to children under the age of 13.

We use the collected persistent identifier for the sole purpose of providing support for internal operations of the Services, including activities necessary for us to maintain or analyze the functioning of the Services, authenticate users or personalize content, protect the security or integrity of the user or the Services, or ensure legal or regulatory compliance.

The collected persistent identifier is not shared with other third parties. However, we may, from time to time contract with certain third party service providers to provide support for the internal operations of the Services. Your personal information is not used or disclosed by these contracted third party service providers except for the limited service for which they have been contracted.

We collect a child’s email address in connection with a question emailed to us by the child for the sole purpose of communicating with the child on a one-time-only basis (e.g. responding to a question from the child). We will not use or disclose such information to re-contact the child or for any other purpose, and such information will be deleted from our records promptly after responding to the child’s request. If we choose not to respond to the child’s request, we will immediately delete the child’s information.

How can parents review or delete personal information about their child?

At any time, parents of children under the age of 13 may review or delete personal information about their children from our records, or refuse to permit our further collection or use of such personal information. Please contact us at support@chordhero.com if you would like to review or delete your child’s personal information, or to inform us about your refusal to permit our further collection of such personal information.

Whenever a parent requests a deletion of his or her child’s personal information, we will use reasonable efforts to delete the child’s information from our records as much as possible and will not collect any other personal information from such child. Please note that there may be residual information that will remain in our records that may or may not contain the personal information that was requested to be deleted. Such residual information will not be disclosed or shared with any other third party or used for any commercial purpose.

Changes in our Privacy Policy Regarding Children

We may amend our Privacy Policy Regarding Children at any time. We will provide parents notice by e-mail of any material changes in the way we intend to collect, use, and/or share a child’s personal information. Please note that, at all times, parents should update their personal information to provide us current e-mail addresses. We will apply material changes in our Privacy Policy Regarding Children only in conformance with applicable law, including any applicable provisions of COPPA that require parental consent.

Contact us

If you have any other questions about our Privacy Policy for Children, including our practices in relation to children’s personal information, in particular collecting or maintaining such personal information, please contact us at:

Chord Hero Limited
Room 8, 6/F, Core C, Cyberport 3, 100 Cyberport Road, Pok Fu Lam, Hong Kong

or send us an email at: support@chordhero.com
Or call us at: (852) 5982 4202

Linked Third Party Sites’ Privacy Policies

Our sites and the Services may contain links to websites of other third parties that we do not own or control. It does not mean that we authorise, sponsor or endorse those third parties, nor is it a representation of our association with them, when we provide such links to other websites. If you click on such links, including clicking on a banner ad or other type of advertisement, you will leave our site and will be directed to those third parties’ sites. As we have no control on such third parties’ activities, we are not responsible for their websites’ content or privacy practices, the collection or use of information you provide to them or any of their products or services. We cannot provide assurance that such third parties employ the same or similar privacy and security practices as us. We advise you to review such other websites’ privacy policies, as their privacy policy governs any information you provide to these third parties. Only information collected on or through the Services is subject to this Privacy Policy.

The Services may also contain other third party service providers’ tracking tools. We may use such third parties’ APIs/SDKs in providing the Services to you, which may allow these third parties to analyze user information. Although these third parties may have access to your Personal Information when services are performed for us, they may not use such information for any purposes other than to provide their services.

Your Options

You may decide not to disclose any of your information, even though such information may be necessary to take advantage of or register for certain features of the Services. Please let us know at support@chordhero.com if you do not want to receive email or other mail from us in the future. If you do not wish to receive any legal notices from us, including this Privacy Policy, such legal notices will continue to govern your use of the Services, and you are responsible for reviewing such legal notices for any changes.

How Personal Information Are Accessed or Amended

You may access or amend any Personal Information collected and held by us by changing the relevant information through our sites. You may contact us at support@chordhero.com if you would like to stop using your account(s). We will review, update, correct or delete the relevant information as appropriate and your information may still be retained in our systems for enforcing our user agreement, maintaining the security, integrity and operation of our sites and the Services and resolving any disputes.

Question About Our Privacy Policy

Please get in touch with us at support@chordhero.com if you have any questions, comments or concerns regarding our Privacy Policy on the Services.

Updates & Effective Date

From time to time, we may update this Privacy Policy. We will notify you about material changes in the way we treat Personal Information by placing a notice on the site. We encourage you to check back periodically and review this Privacy Policy so that you will always know what information we collect, how we use it and to whom we disclose it.

The Privacy Policy was last updated and posted on this site on 01 January, 2024.