PRIVACY POLICY

YOUR PRIVACY MATTERS TO US!

"HEYBOX" is the official website labeled as "HEYBOX" that is legally owned and operated by SAPPHIRE ENTERTAINMENT (HK) CO., LIMITED and its affiliates ("we"), and the software development kits (SDKs) and application programming interfaces (APIs) for use by third party websites and applications.

As the operator of HEYBOX, we are aware of the importance of your personal information and we will protect your personal information and privacy in accordance with the laws and regulations. We specifically advise you to read and understand this privacy policy carefully before using HEYBOX and the related services in order to make appropriate choices.

ABOUT US AND THIS POLICY

Our registered users (“Users”) can choose to share their gaming profiles, engage with the Community network, exchange knowledge and gaming achievements, post and view relevant content. Also, content on some of our services is available to non-members (“Visitors”).

Please understand you consent to the use or collection of your data in accordance with this Privacy Policy when you browse, register, log in to this website or further use the services on this website.

SAPPHIRE ENTERTAINMENT (HK) CO., LIMITED, will be the controller of your personal data provided to, or collected by or for, our Services.

This Privacy Policy explains when we collect data about you, what we collect, why we collect it, who we share it with, where it is processed, how we handle it and what your choices and legal rights are.

SAPPHIRE ENTERTAINMENT (HK) CO., LIMITED is registered at ROOM 09, 27/F, HO KING COMMERCIAL CENTRE, 2-16 FA YUEN STREET, MONGKOK, KOWLOON, HONGKONG.

DATA COLLECTION

This section explains what data we collect about you and the sources of this information. We may combine data we receive from any of these sources. For example, we may process singularly or collectively information we have collected from you, your visits to our website, or your Steam if you have shared it with us, etc., for the purposes explained in this Privacy Policy.

Data You Provide

You may provide us with certain information directly, including:

1. Account information: In order to create an account for HEYBOX, you need to provide information such as your username, email address and password to create the account. It will help us provide better service and experience if you would like to provide your telephone number, date of birth, a profile picture and other details of the account profile. If you choose not to share more information with us, you can still access the basic function. The information you provide above will be licensed to us on an ongoing basis for the duration of your use of the Service.

2. Payment information: If you wish to purchase games or credit for your account wallet or make any other payments via HEYBOX using a payment method, we will ask you to provide certain data such as your billing address and payment details

3. User Content: Some HEYBOX products and services will allow you to upload to our servers: messages, comments, forum posts, game levels, videos, images and other information

4. Customer Services: If you contact us for assistance we may ask you to provide information about you (such as your name and contact details) and the nature of your query, and you may choose to send further communications about your query

5. Other: We may ask you to provide information if you participate in market research surveys, feedback requests, beta and other user testing research, competitions, promotions or events or agree to receive marketing information from us

Please make sure that any personal details which you provide are accurate and current as we will send important information relating to your account using the contact information you provide (including account security and data protection notices). Let us know if there are any changes. You can check and update the information you have provided to us any time via HEYBOX Account Profile Settings. Always obtain consent first before giving us anyone else's personal information (for example, for refer-a-friend promotions).

HEYBOX Website

Each time you sign in to HEYBOX and access our online services, we may automatically:

1. access and store information about your use of HEYBOX features and services on your device; and

2. log your activity on our HEYBOX servers.

For example, we may receive device and account identifiers, such as HEYBOX Account and details of what content, promotions and other information your devices request and receive from our servers (such as store content, gameplay activity and want lists) and when you receive and interact with them, what content and games you add to your 'basket' and what you purchase.

Accessing HEYBOX on your devices

Each time you use a HEYBOX app or sign in to your HEYBOX account on your devices (such as a mobile or PC), we may automatically access and store information about your use of that device and app.

The data that we access from and store on your devices may include:

1. Device identifiers such as your laptop/desktop ID, mobile device IDs, cookie IDs

2. Network identifiers such as your IP and MAC address

3. Account authentication tokens that avoid you having to log in repeatedly

4. Content and client downloaded to your device for the online services that you access

5. Account creation IP address and store that against a country.

6. Achievements, scores and rankings achieved online and offline

7. Some device type and setting details and error reporting

8. Information about which features and services you are accessing from your HEYBOX device or app and when (such as Steam or Twitch if applicable)

9. Information about the device(s) you are using and how you have configured them.

Websites, Marketing and Advertising

Each time you visit our website or receive and interact with our marketing communications and advertise on our or third party websites and services, we may automatically log your activity on web, advertising and marketing servers managed by us or by third parties on our behalf.

For example, we may receive:

1. Online identifiers stored in cookies on your device

2. Other tracking data, such as tracking pixels and browser configuration details (e.g. browser type, list of installed plugins and list of installed fonts)

3. If you sign into your account, account identifiers such as HEYBOX Online Account

4. Information about the content, marketing communications and advertisements you view and interact with

Please see the HEYBOX Cookie Policy for more details on our use of cookies and how to control them when accessing our websites.

Third Party Partners

We may receive limited information about you from third party partners, including from:

1. Our financial and anti-fraud service providers processing your account sign in and purchase transactions, including fraud risk scores

2. Other online service providers, our security service providers, government agencies, law enforcement and public security sources, including IP addresses and details of suspected unlawful or fraudulent activity and security risk scores

3. Third party partners providing games and apps via HEYBOX, including information about accounts, IP addresses and devices reasonably suspected of breaching our or our third party partners terms of service or of being involved in fraudulent or malicious activity

4. Other third parties where permitted under notices and choices that they or we have provided to you (for example, we may receive information from a HEYBOX partner that you visit if you've agreed that the provider of that service can send us information about your activity, such as Facebook)

Other Situations

We will ask for your consent (pop-outs, page notification, etc) when we want to use information for purposes other than those set out in this policy. We will seek your prior consent when we use information collected for other purposes and inform you of the usage of such data. After your consent, these notifications act as the same power as this privacy policy.

Your Consent

1. According to the Foundamental Law of Hong Kong Special Administrative Region, Personal Data (Privacy) Ordinance and other appliable laws, we will request your consent for the following subjects and you are able to remove your consent at any time by changing your preferences.:

1) pop-outs

2) page notification

3) email newsletter.

4) other purposes that require your separate consent due to business changes, etc.

2. We have a contractual obligation

In certain circumstances, we need your personal data to comply with our contractual obligations, i.e. if you order a game from us, we’ll collect your name email address/ phone number and payment details to deliver your purchase.

3. We have a legal obligation

If the law requires us to, we may need to collect and process your data and we can pass on details of people involved in fraud or other criminal activity affecting HEYBOX to law enforcement.

4. We have a legitimate interest.

In specific situations, we require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business, and which does not materially impact your rights, freedom, or interests. For example, we will use your purchase history to send you or make available personalised offers. We will also send you direct marketing emails when you shop with us and do not choose to opt out - this is often called a 'soft opt in'. We also combine the shopping history of many customers to identify trends and ensure we can keep up with demand. We may contact you regarding market research.

With your consent, or when you shop with us and do not choose to opt out from receiving our emails ('soft opt in') we will use your personal data, preferences, and details of your transactions to keep you informed by email, web, text, about relevant products and services including tailored special offers, discounts, promotions, events, competitions and so on.

Exempted Agreement

According to the Foundamental Law of Hong Kong Special Administrative Region, Personal Data (Privacy) Ordinance and other appliable laws, we do not need to request your consent for the following subjects:

1.Make or execute a contract based on your needs and requests.

2.Required for the performance of statutory duties or legal obligations, such as those directly related to national security, national defense security, criminal investigation, prosecution, trial and execution of judgments, etc.

3.To respond to public health emergencies, or emergency situations necessary to protect the life, health and property of natural persons

4.The implementation of news reporting, public opinion monitoring and other acts in the public interest, we will deal with your information in a reasonable range.

5.Handle personal information that you disclose on your own, or other personal information that has been legally disclosed (such as personal information that has been legally disclosed through legitimate news reports, government information disclosure, etc.) within a reasonable range.

6.Other circumstances as stipulated by laws and regulations.

Special Note: According to the law, if the information cannot be identified to a specific individual alone or in combination with other information, it is not personal information. When your information can be identified to you alone or in combination with other information, or when we use data that is not linked to any specific individual in combination with your personal information, we will treat it as your personal information and process and protect it in accordance with this privacy policy.

DATA USE

This section explains how we may use the data we collect about you. We may use data combined from any of the sources explained in the 'Data Collection' section of this Privacy Policy. For example, we may process together information we have collected from you, your visits to our website, your Steam etc., for the purposes explained in this Privacy Policy.

Services

We (and affiliates and third parties operating on our behalf in accordance with our instructions) may use your information to operate HEYBOX and to provide the services you have requested - for example, in order to maintain your account, process your purchases and/or complete anti-fraud checks.

Personalized Recommendation

To display and recommend the most relevant information and provide services matching your needs, we will collect and use your personal information for our algorithms to analysis and predict your preferences to match your interested information or services:

1.Our personal recommendation service includes but does not limit to information display, search results, merch recommendations, services and ads

2.We may collect and use your device information, location information, and the actions while you use HEYBOX like browse, post, interactions, search, click, follow, subscribe, download, share, trade, etc. This also includes the information you chose to share with us like your gender, birthday, location, etc.

3.You can choose to turn on or off our personalized recommendation system according to the xxx of this privacy policy. After you choose to turn off our personalized recommendation system, we will no longer analyse your information based on the purpose of personalizing your feed but push common information or ads without your personal preference.

Development

We use the data we collect to understand, improve and enhance our existing products and services and your experiences using them, and to help develop new ones. For example, we may use the data to optimise user interfaces, for bug and error fixing, apps and websites.

Moderation and Safety

We cannot monitor the whole of HEYBOX and make no commitment to do so. However, we reserve the right in our sole discretion to monitor and record your online activity and communication throughout HEYBOX and to remove and/or delete any content. We may use the combined data we collect, such as text communications, the time and location of your activities, and your HEYBOX Online Account, registered account details and IP address) to detect breaches and enforce our HEYBOX Terms and Conditions and any other terms of service you have agreed to and any rules or codes of conduct applying to your use of HEYBOX. Enforcement action that we may take can include suspending, banning communication, trade, accounts and/or devices.

Legal and Compliance

We may use the combined data we collect for auditing, compliance and legal purposes (for example, making or defending claims or activities that are required by law).

Marketing and Advertising

We might target and personalise our marketing communications, purchase recommendations and adverts that we display on our and third party websites and services based on the combined data we have collected about you (e.g. to avoid displaying content you've already purchased from our store).

You may notice this personalisation when you visit HEYBOX (via website), when we send you marketing communications or when you visit our and third party websites (such as social network sites) that show purchase recommendations or adverts from us (for example, you might see an advert for a game similar to one you have played recently or a product that you have recently viewed on HEYBOX).

You can choose if you would like to receive marketing communications from us relating to HEYBOX and our products and services. If you later decide not to receive marketing emails from us, you can turn off marketing communications:

1. Via Preference Centre Settings in your HEYBOX Account Settings area

2. By following the instructions and/or the link "unsubscribe" attached to our marketing emails

We will aim to process your request as soon as reasonably practicable and in any event, within 2 working days. Note that we will still send you non-marketing emails about your account even if you opt-out of marketing emails.

If you choose not to allow us to store and access cookies that are not strictly necessary for the provision of our websites, this will also limit when we can recognise your visits to our websites and target and personalise the advertising and commercial purchase recommendations displayed on those websites. Please see the HEYBOX Cookie Policy for more details on our use of cookies and how to control them when accessing our websites.

DATA SHARING AND TRANSFERS

This section explains how we may share the combined data we collect with third party vendors and partners that provide services to us or provide games and apps on HEYBOX that you use.

Services

We may share the combined data we collect with third party vendors and selected partners that provide services to us or provide games and apps on HEYBOX that you use. For example, we may share your payment details to banks and other financial and anti-fraud organisations in order to complete your purchase, obtain payment and carry out credit and anti-fraud checks.

Advertisements and Ad Serving Technology

We also use third party providers of adverts. Third party providers we may use from time to time include Adroll, Dotomi, Conversant, ESV Digital and all the other third party providers we may use in the future.

Third party ad providers may collect information as a result of ad serving through the Website and/or the App. These entities may collect and use data for this purpose including software, applications, hardware, browser information, internet and online usage information. This data may be used and disclosed in accordance with our and the privacy policy of the company providing the ad serving technologies. The advertising companies who deliver ads for us may combine the information collected with other information they have independently collected from other services or products. These companies collect and use information under their own privacy policies.

Third-Party Research Companies

We may share, on a commercial basis, anonymised customer data with third-party research companies when you browse/login/purchase on HEYBOX (for example, making a purchase on our store). In order to comply with various privacy laws (CCPA, Nevada Privacy laws, GDPR, etc), you have the right to withdraw permission for HEYBOX to share any data (even anonymised) with third-party research companies for commercial reasons. To opt-out of data sharing for commercial activities please click here and log-in to your account and send us a message with your details.

Other Users

When you create an account for HEYBOX, certain information will form part of your public profile and we will make it accessible to all accounts on HEYBOX.

This includes:

1. Your HEYBOX Username

2. "About Me" statement, avatar, gaming activity and statistics (if you choose to link your Steam account), online/offline status, game reviews you write and the games you own or have added to your Want List.

Please be aware that anyone who can see your information will be able to share it with others . For example, by sharing the information you posted on our website. Some devices allow users to record, stream and upload online activities such as gameplay and therefore may be distributed outside HEYBOX without your knowledge, which means that you and we have no control over it.

You are responsible for any content you share on forums, communities, chat and messaging features and this content will be accessible to others.

We recommend you consider carefully with whom you share your information. Avoid sharing your contact information with others.

Security and Fraud

We may share limited information about you with third party partners through encrypted transmission , including:

1. Our financial and anti-fraud service providers processing your account sign in and purchase transactions, including fraud risk scores

2. Other online service providers, our security service providers, government agencies, law enforcement and public security sources, including IP addresses and details of suspected unlawful or fraudulent activity and security risk scores

Legal and Corporate

We may share the combined data we collect:

1. To defend legal claims or exercise legal rights

2. With our service providers processing data on our behalf

3. With our professional advisors dealing with, for example, legal, tax, audit or accounting matters

4. During negotiations for and following conclusion of a sale of all or part of our business

Government Authorities

We may share your information with police and other government authorities if we believe that it is reasonably necessary to comply with a law, regulation, or legal process, to detect, protect and enforce the safety of any person, their property or their rights, to address fraud and security and report criminal activity.

International Transfers

Data generated by HEYBOX will be stored in the mainland of the People's Republic of China， not in Hong Kong.

Your information may be processed, stored and transferred outside your country of residence for the purposes set out in this Privacy Policy. Data protection laws in these countries may not offer the same level of protection as in Hong Kong and you may have fewer legal rights in relation to your information. In such cases, we will take necessary action to ensure that the level of protection is not less than that required by Hong Kong regulations, such as implementing security initiatives like data de-identification prior to international data transfers.

DATA HANDLING AND YOUR CHOICES

Storage

We may retain some of your data (including but not limited to account information, transaction records, etc.) until such retention is no longer necessary or the basis for such retention is lost, in accordance with relevant laws and regulations.

When you close your account, we will stop using the data we collected from you, except for information like transaction information that is required to be kept by law or regulation.

Security

Access to your HEYBOX account is restricted through the password that you set. Please keep the password for your account safe and do not disclose it to anyone else. Consider ensuring automatic account log in setting is disabled and the setting requiring a password to be entered before completing purchases is enabled, particularly if your HEYBOX device is shared with others. You should contact HEYBOX Help and Support immediately if you become aware of any unauthorised use of your account or other security breach.

Juvenile's Data

Our products, websites and services are primarily intended for adults. Juveniles are not allowed to create their own user accounts without the consent of their parents or guardians.

For personal information collected from juveniles with parental consent, we will only use or publicly disclose this information as permitted by law, with the consent of the parent or guardian, or as necessary to protect the juvenile.

We consider anyone under the age of 18 to be a juvenile.

If we find that we have collected personal information from a juvenile without prior parental consent, we will seek to delete the relevant data as soon as possible.

Your Choices and Rights

If you are a user of our services, you can access, correct, and modify some of the personal information that you have provided to us via HEYBOX Account Settings.

You also have the right to request a copy, rectification, erasure or blocking of your personal information and to object to our processing of your personal information in certain situations. You can exercise these rights by contacting us via the information in the About Us and Complaints section of this Privacy Policy.

Each business function requires some basic personal information in order to be completed (refer to "Data You Provide"). You may give or withdraw your consent to the collection and use of additional personal information at any time.

Once you have withdrawn your consent, we will no longer process the corresponding personal information. However, your decision to withdraw your consent will not affect the processing of personal data that was previously carried out on the basis of your authorisation.

If you do not want to receive commercial advertising from us, you can cancel it at any time.

You can turn off push notifications in the website settings or click unsubscribe within the email.

Some of our functions may make decisions based solely on non-human automated decision-making mechanisms, including information systems, algorithms, etc. If these decisions significantly affect your legal rights, you are entitled to an explanation and we will provide appropriate remedies.

You can close your account for HEYBOX by contacting HEYBOX Help & Support. Please be advised that account changes can take up to 28 days.

Note that this will not affect any alternative accounts that you might have; you will need to close those accounts separately.

Complaints

If you have a concern about our information rights practises, please get in contact with us first so we can try to resolve your query using the details in the 'About Us and this Policy' section of this Privacy Policy.

If however you feel we have not dealt with your concern and that we are failing to meet our legal obligations, you can report this to your local data protection regulator.

UPDATES AND CHANGES TO THIS PRIVACY POLICY

We may make alterations to this Privacy Policy from time to time and these variations shall become effective immediately upon being accessible from here or on the Effective Date.

We will use our reasonable efforts to notify you of any such changes, which will not apply to any earlier use of the Service or purchases of Games through the Service.

Your continued use of the our Services will be deemed acceptance of the updated or amended Privacy Policy and these variations shall become effective immediately upon being accessible. If you do not agree to the changes, you should cease using the Service. If there is any conflict between this Privacy Policy and any terms or specific local terms appearing elsewhere on the Service then this policy shall prevail.

Version 1.0 ( 2022)

Effective Date on August 9th, 2022