Infold Official Website Personal Information and Privacy Protection Policy

Updated on May 15, 2024

Effective on May 15, 2024

Preamble

This Infold Official Website Personal Information and Privacy Protection Policy (hereinafter referred to as ‘Privacy Policy’) is a contract between you (hereinafter also referred to as ‘user’) and INFOLD PTE. LTD. (hereinafter also referred to as ‘Infold’ or ‘we/us’, with our registered address at 6 Raffles Quay, #14-06, Singapore). This Privacy Policy is specifically designed for use on the Infold official website and shall constitute an independent contract.

You are welcome to use the services provided by the Infold official website, including your interactions with the official website and your registration and use of the services thereon (hereinafter collectively referred to as ‘services’). Infold attaches great importance to the protection of users’ personal information and privacy. We have formulated this Privacy Policy to clarify how we collect, use, store, share, and transfer such information when you use our products or services, as well as to provide information on the channels we have made available for you to access, update, control, and protect such information.

Special notes on the official website functions:

If you are under the age of 18 or the statutory age for employment in your country or region, please refrain from providing us with any information in the recruitment section of the Infold official website. This is to comply with the requirements of applicable laws and protect your personal information. If you are considered a child, the age of which depends on the definition of ‘child’ under the laws of your country/region of residence (for example, under the age of 13 in some countries/regions), it is not advisable for you to use our services. If you are over the age of a child under the laws of your country or region of residence but are still considered a minor, the age of which depends on the definition of ‘minor’ under the laws of your country/region of residence (for example, under the age of 18 in some countries/regions), or if you do not meet the foregoing eligibility requirements, you must read this Privacy Policy while accompanied by your parent (or guardian).

In particular, we need to remind you of the following:

We may amend the terms of this Privacy Policy from time to time. The amended terms, once publicly posted, shall replace the original terms. You can check for the latest version of this Privacy Policy on our website. Please carefully review the amended Privacy Policy. If you disagree with the amendments, please discontinue logging in or browsing and close our website immediately. If you choose to continue using our services, you will be considered to have accepted the amended Privacy Policy and will be bound by it. In the event of any adjustments to these terms that may significantly affect your rights, we will notify you in advance through an announcement.

This Privacy Policy will help you understand the following:

I. How We Collect and Use Your Information

II. How We Use Cookies and Similar Technologies

III. How We Commission Processing of, Share, Transfer, and Disclose Your Personal Information

IV. How We Store and Protect Your Personal Information

V. Your Rights to Manage Personal Information

VI. Protection of Minors’ Information

VII. Miscellaneous

VIII. Contact Us

I. How We Collect and Use Your Information

In accordance with applicable laws and regulations, or as required for the provision of specific functions and services, we may collect, store, and use the following information about you while offering our products or services. The collection, storage, and lawful use of this information are essential for us to provide or enhance the relevant products, services, or customer experience to your benefit, as well as to maintain the security of your account. If we intend to use your information for purposes beyond those outlined below, we will clarify such use and seek your consent.

1. Information Provided by You

(1) When you use the services on the Infold official website and log in using a third-party account, we may collect the unique identifier and account name of your relevant account to save your login information. If you do not agree to authorize the collection of such information, you will not be able to use a third-party account to log in to our products/services. Please note that only by providing accurate and truthful information, as mentioned above, can you registered as our user and access our services. Failure to provide the information as mentioned above will restrict your ability to log in or use some or all of Infold’s products or services.

(2) You may submit information through our customer service or when participating in activities/questionnaires organized by us. Such information may include your name, gender, telephone number, address, education, occupation, and personal income range statistics. We would like to remind you that the submission and modification of the above information may be subject to the specific rules of the relevant interface. If such rules are inconsistent with those outlined in this Privacy Policy, we will seek your consent separately. Your decision not to participate in the above activities/questionnaires or not to provide the above information to customer service will not affect your access to other services.

(3) In the recruitment section, if you are interested in one of our positions and wish to join us, upon your voluntary application, we will collect your mobile phone number and generate a recruitment-specific account for you. When you fill out the form, we will collect your basic information (name, mobile phone number, email address, location), educational background (school name, academic degree, major, start and end time), work experience (company name, job title, start and end time), and resume attachments. We will assess your suitability for the position you applied for based on the above information. Some information is optional, such as internship experience (company name, job title, start and end time), project experience (project name, project role, start and end time, project link, description), works (work link, work attachment, description), awards (title, time, description), and language skills (language and proficiency), etc. You can choose not to fill in such optional items, but it may affect your overall assessment results or prevent us from reaching out to you for further communication about the position in question. When choosing to apply for a position on the Infold official website, you are aware and understand that the system may generate other information related to you, such as application submission records, interview evaluations, recommendation records, etc., while using the recruitment module.

(4) You may share information with other parties through our products and services, and you may provide and store information with us when using our products or services.

2. Your Information Shared by Other Parties

(1) Information about you shared by other parties while using our products or services.

(2) We may have access to information generated or shared during your use of products or services provided by third-party partners. Please carefully review the user agreements or privacy policies related to the products or services of these third-party partners.

3. Your Information Obtained by Us

When you use the Infold official website, we may collect the following information for the purposes outlined below:

(1) In order to ensure the normal functionality of our services, maintain the proper operation of the website, optimize product performance, enhance your user experience, and ensure the security of your account, we may collect information about your device or software. This includes various details related to your mobile devices, web browsers, or other applications used to access our products or services. Such information encompasses IP addresses, device types, device model and version, operating system type and version, and network type.

(2) When you contact us or our customer service, we may collect your communication or call records and details, as well as any contact information you provide for us to reach out to you or assist you in resolving issues. We may also document the solutions and outcomes related to the issue you raise.

(3) When you use our services, we may contact you by phone or send you emails, text messages, information or push notifications.

4. Where necessary for entering a contract, or as required by the relevant laws and regulations of your residence, as well as any administrative or judicial authorities’ writs of execution, we may collect and use your relevant personal information without requiring your authorization and consent:

(1) Where it is directly related to national security, national defense security, and other national interests of the country or region where the products and services are offered; where it is directly related to significant public interests, such as public security, public health, and the right to access public information;

(2) Where it is directly related to the investigation, prosecution, trial, enforcement of judgment, and related matters for criminal offenses in the country or region where the products and services are offered;

(3) Where it is for the purpose of safeguarding the life, property, reputation, and other significant legitimate rights and interests of you or other individuals, but it is difficult to obtain the personal consent of each information subject;

(4) Where the personal information we collect is made available to the public at your initiative;

(5) Where the personal information is collected from lawful public sources, such as lawful news reports, government information publicity, and other channels;

(6) Where it is necessary for the conclusion and performance of the contract at your request;

(7) Where it is necessary for maintaining the safe and stable operation of the products or services provided, such as detecting and disposing of malfunctions in the products or services;

(8) Where it is necessary for lawful news reporting;

(9) Where it is necessary for statistics or academic research in the public interests and when the results of academic research and descriptions are made available to the public, the personal information contained therein has been de-identified;

(10) Other circumstances stipulated by laws and regulations.

5. Guidelines for disclosure and sharing of your information

Please carefully consider the information you disclose, upload, post, and communicate through our services. In some cases, you may be able to control the range of users who can access the information you share in the privacy settings of some of our services. If you wish to request the deletion of your information from our services, please contact us to confirm the procedure, and note that such deletion will require you to verify your identity.

II. How We Use Cookies and Similar Technologies

We or our third-party partners may collect and use your information through cookies, web beacons, and other similar technologies and will store this information. We use our own cookies, web beacons, and similar technologies to:

1. Remember your identity: For example, cookies and web beacons help us identify you as a registered user or store other information about you that you have provided to us.

2. Analyze your use of our products or services: We can use cookies and web beacons to understand the activities you engage in when using our services.

3. Our products and services may contain cookies, web beacons, and other similar technologies placed by our third-party partners. These technologies may be used to collect your non-personally identifiable information for analyzing how you use such services or evaluating the effectiveness of advertising services. We require our third-party partners to strictly adhere to the relevant provisions of this Privacy Policy. You can opt out of or manage cookies, web beacons, and other similar technologies in your browser settings. However, please note that disabling cookies, web beacons, or other similar technologies may impact your experience of relevant services, and some services may not work as intended.

III. How We Share, Transfer, and Disclose Your Personal Information

1. Sharing: We, as well as our affiliates, will not share your personal information with any third party without your consent, except in the following cases. In the recruitment section, in particular, you are deemed to have expressly agreed to authorize the provision of the information for our use when you voluntarily fill in/send the information:

(1) Providing you with our products or services;

(2) Achieving the purposes outlined in the ‘How We Collect and Use Your Information’ section;

(3) Performing our obligations and exercising our rights under this Privacy Policy or other agreements between Infold and you;

(4) Understanding, maintaining, and improving our products or services;

(5) Complying with lawful requests from you or your guardian;

(6) Meeting legal requirements and responding to requests from competent authorities in the country or region where the products or services are offered.

We will share your information only for legal, legitimate, necessary, specific, and transparent purposes. If we or our affiliates share your personal information with the aforementioned third parties, we will make every effort to ensure that these third parties comply with this Privacy Policy and adhere to the appropriate confidentiality and security measures required by us when using your information. Alternatively, we will require such third parties to obtain your authorization and consent once again.

When you use the products or services provided by us, we may access Software Development Kits (SDKs) or Application Program Interfaces (APIs) provided by third parties or share your personal information with third parties through other collaborative means to fulfill the aforementioned purposes. The third parties collect and process information in accordance with their privacy policies or related statements, and we recommend that you review their privacy policy before using their services. To protect your legitimate rights and interests, if you identify any risks associated with the third-party services, we recommend that you discontinue the relevant operations immediately and promptly contact us. Our current information sharing with third parties is outlined below:

2. Transfer: We will transfer your personal information only:

(1) With your explicit consent;

(2) As required by applicable laws and regulations or as requested by competent authorities;

(3) With the ongoing development of our business, we and our affiliates may engage in mergers, acquisitions, asset deals, or similar transactions. In such cases, your personal information may be transferred as part of these transactions. We will notify you of such events through push notifications, announcements, and other means. Additionally, we will also ensure that your personal information remains protected, either by us or by the new managers, in accordance with applicable laws, regulations, and standards that are no less stringent than those required by this Privacy Policy.

3. Disclosure: We will disclose your personal information only:

(1) With your explicit consent (In the recruitment section, you are deemed to have expressly agreed to authorize the provision of information for our use when you voluntarily fill in the information);

(2) As required by applicable laws and regulations or as requested by competent authorities;

4. Exceptions to the Requirement for Prior Consent

In accordance with the relevant laws of your residence, as well as any administrative or judicial authorities’ writs of execution, we may share, transfer, and disclose your personal information in compliance with the law, without requiring your consent:

(1) Where it is directly related to national security and national defense security of the country or region where the products and services are offered;

(2) Where it is directly related to public security, public health, and significant public interests of the country or region where the products and services are offered;

(3) Where it is directly related to the investigation, prosecution, trial, enforcement of judgment, and related matters for criminal offenses in the country or region where the products and services are offered;

(4) Where it is for the purpose of safeguarding the life, property, reputation, and other significant legitimate rights and interests of you or other individuals, but it is difficult to obtain the personal consent of each information subject;

(5) Where the personal information is made available to the public on your initiative;

(6) Where the personal information is collected from lawful public sources, such as legal news reports, government information publicity, and other channels.

You acknowledge and agree that we may use the collected information, which has been de-identified, for conducting big data analytics. We may publicly share with our partners the de-identified information after statistical processing to understand how users use our products or services or to allow the public to understand the general usage trend of our products or services. Pursuant to applicable laws and regulations, the sharing and transfer of de-identified information, ensuring that the recipient of the data is unable to recover and re-identify the information subject, is not considered an act of external sharing, transfer, or public disclosure. Such data will be stored and processed with no separate notification to you and without obtaining your consent.

IV. How We Store and Protect Your Personal Information

1. Unless otherwise mandated by laws, regulations, or regulatory authorities in the jurisdiction where you use our services, and unless it is reasonably required to safeguard public interests or protect the personal safety, property security, or legitimate rights and interests of our customers, us, our group companies, other users, or employees, we will retain your personal information only for the shortest period necessary to fulfill the purposes outlined herein.

2. Our group companies are represented all over the world. As per the service contract between you and us, your personal information may be processed on servers located outside your place of residence when necessary. Regardless of the server’s location, we will take appropriate measures to protect your rights in accordance with this Privacy Policy. The servers for these services may be located in Singapore, the United States, Japan and Germany.

3. Your data collected by us or shared with third-party partners may also be stored and processed on the servers of our third-party located in the United States, Japan, Singapore and Germany. In addition, our support team, engineering team, and other teams located around the world (including in Singapore) may have access to your information from a location other than your place of residence.

4. When it is necessary to carry out a cross-border transfer of the information we collect within our group companies, we will ensure that such transfer is carried out in compliance with the laws, regulations, and requirements of the competent regulatory authorities in the country from which the data originates, thereby ensuring adequate protection for your personal information. We will transmit your personal information in a de-identified and anonymized manner to ensure its security and confidentiality. We will also ensure that the data-receiving region applies the same level of data protection as the region of your residence.

5. If we terminate our services or operations, we will promptly discontinue any further collection of your personal information, while giving you advance notice as required by relevant laws and regulations. We shall delete or anonymize your personal information following such termination unless otherwise mandated by the relevant laws and regulations or regulatory authorities.

6. In the recruitment section, we will assess your suitability for the position you applied for based on the name, phone number, location, background information of your education, career, and skills that you voluntarily provide to us. You acknowledge and agree that the above information will remain in our talent pool if a job offer is not made, and we may contact you for future job openings.

7. We will implement reasonable and necessary security measures in accordance with established industry standards to minimize the risk of information loss, misuse, and unauthorized access or disclosure. For example, some products or services may utilize encryption technologies (such as SSL) to protect the personal information you provide. Nevertheless, it is important to understand that despite our best efforts to enhance security measures, we cannot guarantee the absolute security of your information due to technical limitations and the potential for malicious attacks. Please be aware that issues may arise with the systems and communication networks you use to access our services, which may be beyond our control.

8. In the event of a personal information security incident, we will promptly notify you, as required by relevant laws and regulations, of the following: the basic information about the incident and its possible impact, the measures we have taken or will take to address it, recommendations for preventing and mitigating risks on your end, remedies available to you, and more. We will notify you of incident-related information through emails, letters, phone calls, push notifications, or other means. If it is challenging to notify each personal information subject affected individually, we will issue announcements reasonably and effectively. Furthermore, we will report information on the handling of such personal information security incidents as requested by regulatory authorities.

V. Your Rights to Manage Personal Information

1. Right to Access Your Personal Information

You can access the relevant personal information you have provided to us by following the instructions or settings related to the products and services we provide. If you encounter any issues while accessing this information and require additional personal information not available through the above methods, you can contact us using the methods provided herein.

2. Right to Correct/Change Your Personal Information

(1) If you discover that the personal information you have provided to us is incorrect, incomplete, or requires an update, you can make corrections or changes to your personal information in our products and/or services.

(2) If you encounter any difficulties while exercising the aforementioned rights, or if online correction/change services are temporarily unavailable for any reason, unless otherwise specified by relevant laws and regulations, you have the right to correct or change incorrect or incomplete information upon verification of your identity, provided that such correction/change will not compromise the objectivity and accuracy of your information. In exceptional cases, particularly when your data is inaccurate, you may submit a correction/change request to us through our published feedback, error reporting, customer service, and other channels. However, for security and identification purposes, some of the initial registration information you provided when registering with us may not be modifiable.

3. Right to Delete Your Personal Information

In any of the following circumstances, you may request us to delete your personal information directly, unless it has been anonymized or unless otherwise provided by relevant laws and regulations:

(1) When the purpose for processing your personal information has expired or no longer exists, or when there is some other legal basis for doing so;

(2) When our processing of your personal information violates any laws or regulations;

(3) When we collect or use your personal information without your consent;

(4) When our processing of your personal information breaches our agreement with you;

(5) When you have terminated your account;

(6) When we terminate our services and operations.

Where we decide to respond to your deletion request, we will also inform the entities that have received your personal information from us and request them to promptly delete such information, unless otherwise specified by the laws and regulations or unless these entities have obtained separate authorization from you. After you delete any information from our services, we may not immediately delete the corresponding information in the backup system. Instead, it will be deleted during the next backup update. For more information about the process, conditions, and other details regarding exercising your right to delete your personal information, please contact our customer service.

4. Right to Withdraw All or Part of Your Authorization in Relation to Your Personal Information

As mentioned above, you can withdraw (or discontinue) further authorization on your personal information at any time after such authorization has been granted. When we update our official website, we will not change the status of your previous authorization without your express consent. You may also permanently withdraw all your authorizations granted to us to further collect your personal information by terminating your account. Please be aware that following such withdrawal, we may no longer be able to provide you with specific functions and/or services corresponding to the part of authorization that you have withdrawn. However, your decision to withdraw your authorization will not affect our prior processing of your personal information, based on your previous authorization.

5. Right to Terminate Your Account

You can request to terminate your account through our customer service or via other methods we have publicized. Once your account is terminated, you will no longer be able to log in to or use our products and services with that account. The content, information, data, records, and other data associated with that account will be deleted or anonymized (unless otherwise required by the laws and regulations or requested by regulatory authorities). Please note that a terminated account cannot be recovered. For more information about the termination process, conditions, and other details regarding an Infold account, please contact our customer service.

6. Right to Obtain Copies of Your Personal Information

You have the right to obtain copies of your personal information. You can contact us through the methods provided herein to request these copies at any time, and we will respond within fifteen (15) working days.

7. Restrictions on Automated Decision-Making by Information System

In certain business functions, we may make decisions solely based on automated decision-making mechanisms, which may include information systems and algorithms. If these decisions have a significant impact on your legitimate rights and interests, you have the right to request clarification from us, and we will also provide appropriate relief.

8. How We Respond to Your Requests for Exercising the Above Rights

We will respond to your requests as promptly as possible, typically within fifteen (15) working days, after receiving your request and verifying your identity as a user. If you have any questions or concerns about the disposal of your personal information, you can contact us using the methods provided in Section 8 (Contact Us).

We will not be able to respond to your request under the following circumstances:

(1) Where it is related to the personal information controller’s performance of its obligations under laws and regulations;

(2) Where it is directly related to national security and national defense security;

(3) Where it is directly related to public security, public health, and significant public interests;

(4) Where it is directly related to criminal investigation, prosecution, trial, enforcement of judgment and related matters;

(5) Where the personal information controller has sufficient evidence to indicate that the personal information subject is subjectively malicious or abuses his/her rights;

(6) Where it is for the purpose of safeguarding the life, property and other significant legitimate rights and interests of the personal information subject or other individuals but it is difficult to obtain the personal consent of each information subject;

(7) Where responding to the request of the personal information subject will result in serious damage to the legitimate rights and interests of the personal information subject or other individuals or organizations;

(8) Where trade secrets are involved.

9. If You Are a Resident of the State of California

If you are a California resident, you may have the following rights under the California Consumer Privacy Act (CCPA)

(1) Right to request the details of the categories and specifics of the personal information we collect, use, and disclose;

(2) Right to delete your personal information;

(3) Right to opt out of the sale of your personal information;

(4) Right to non-discrimination for exercising these rights.

You may contact us to exercise the above rights. Before completing your request, we shall review your specific request and arrange for its processing. To avoid your rights being fraudulently used by wrongdoers, we may request you provide additional information or materials to assist us in verifying your identity.

We will endeavor to respond to your request as promptly as possible. The processing time for such a request is around fifteen (15) working days since it requires dedicated staff in our data protection department.

We will not discriminate against you for exercising these rights. However, to ensure that you receive as much help as possible during the request processing period, we will identify and deal with any malicious requests. This may have an impact on your account privileges. If you face any issues as a result, you can always contact us to synchronize the information and resolve the issue.

VI．Protection of Minors’ Information

Please be informed that we will not collect the information of minors or individuals who do not meet the age requirements for using our services in your country/region of residence. If you are the guardian of such an individual and discover that they have been our services and providing personal information, please discontinue their use of our services immediately and promptly inform us so that we can take appropriate measures. If you need to inquire about or delete the information, please refer to section V (Your Rights to Manage Personal Information). Our customer service may verify and confirm your relationship with the minor as necessary, and we will assist you in deleting the information and terminating the corresponding account upon such confirmation.

VII. Miscellaneous

1. Except for certain services expressly excluded herein, this Privacy Policy applies to all our services. Specific personal information protection statements or rules for certain services will provide more detailed information on how we use your information in those services. These specific statements or rules are considered part of this Privacy Policy. In case of any inconsistency between these specific statements or rules and this Privacy Policy, the former shall prevail.

2. Unless otherwise defined in this Privacy Policy, the terms used herein will have the same meanings as those defined in the other terms we have prepared and made available to the public.

3. The headings in this Privacy Policy are included for convenience only and do not affect the meaning or interpretation of any provisions contained herein.

VIII. Contact Us

1. We have established a dedicated department for the protection of personal information, responsible for safeguarding your personal information in compliance with this Privacy Policy. If you have any queries, comments, or suggestions regarding this Privacy Policy, our privacy protection measures, or any issues related to your information, you can contact us through the following methods or via email at dpo@infoldgames.com.

2. Generally, we will respond to your queries, comments, or suggestions within fifteen (15) working days after verifying your identity as a user, unless otherwise required by the laws and regulations in the jurisdiction where you use our services.