Super Zero Co., LTD Privacy Policy

Super Zero Co., Ltd ("Super Zero"), its parent and its subsidiaries respect the privacy rights of our users and are committed to protect users' information collected through our online products, online services and websites (together "Services"). Super Zero has adopted this privacy policy ("Privacy Policy") to explain how Super Zero collects, stores, and uses the information collected in connection with Super Zero's Services. Should you have any questions relating to this Privacy Policy, please contact us at game[a] or alternatively at Super Zero Co., LTD, Legal Department, Room 401,Wan lin Bd,88,Nong Da South Rd,Hai Dian Dist,Beijing,China, 100081.

BY INSTALLING, USING, REGISTERING TO OR OTHERWISE ACCESSING THE SERVICES, YOU AGREE TO THIS PRIVACY POLICY AND GIVE AN EXPLICIT AND INFORMED CONSENT TO THE PROCESSING, USE AND DISCLOSURE OF YOUR PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO ANY TERM PROVIDED HEREIN, PLEASE DO NOT INSTALL, USE, REGISTER TO OR OTHERWISE ACCESS THE SERVICES. Super Zero reserves the right to modify this Privacy Policy at reasonable times, so please review it frequently. If Super Zero makes material or significant changes to this Privacy Policy, Super Zero may post a notice on Super Zero's website along with the updated Privacy Policy. Your continued use of Services will signify your acceptance of the changes to this Privacy Policy.

Non-personal data

For purposes of this Privacy Policy, "non-personal data" means information that does not directly identify you. Additionally, non-personal data means "aggregate" and "de-personalized" information, which is data Super Zero collects about the use of Super Zero Services, from which any personally identifiable data has been removed.

Super Zero may use tools or third party analytical software to automatically collect and use certain non-personal data that does not directly enable Super Zero to identify you. The types of non-personal data Super Zero may collect and use include, but are not limited to: (i) device properties, including, but not limited to IP address, device identifier like International Mobile Equipment Identity ("IMEI"); (ii) device software platform and firmware; (iii) mobile phone carrier; (iv) game progress, score and achievements; (v) other non-personal data as reasonably required by Super Zero to enhance the Services and other Super Zero products and services.

Super Zero uses analytics tool such as Umeng in order to develop and analyze use of the Services.

Super Zero may use and disclose to Super Zero's partners and contractors the collected non-personal data for purposes of analyzing usage of the Services, advertisement serving, managing and providing the Services and to further develop the Services and other Super Zero services and products.

You recognize and agree that the analytics companies utilized by Super Zero may combine the information collected with other information they have independently collected from other services or products relating to your activities.

Ad Serving Technology

Super Zero may employ third party ad serving technologies that use certain methods to collect information as a result of ad serving through Services.

You recognize and agree that the advertising companies who deliver ads for Super Zero 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. These ad serving technologies are integrated into Services; if you do not want to be subject to this technology, do not use or access Services.

Below is a full list of Third Parties, as well as links to their privacy policies:

Admob  Admob's privacy policy

Personal Data

For purposes of this Privacy Policy,"personal data" complies with the definition of "Children's Online Privacy Protection Act" (COPPA), which includes:

a) First and last name;

b) A home or other physical address including street name and name of a city or town;

c) Online contact information;

d) A screen or user name that functions as online contact information;

e) A telephone number;

f) A social security number;

g) A persistent identifier that can be used to recognize a user over time and across different websites or online services;

h) A photograph, video, or audio file, where such file contains a child’s image or voice;

i) Geolocation information sufficient to identify street name and name of a city or town; or

j) Information concerning the child or the parents of that child that the operator collects online from the child and combines with an identifier described above.

When purchasing products or services online, your purchasing orders might have personal data. Such personal data is only collected for purpose of billing calculation.

Disclosure and Transfer of Personal Data

Super Zero collects and processes personal data on a voluntary basis and it is not in the business of sellinng your personal data to third parties. Personal data may, however, occasionally be disclosed in accordance with applicable legislation and this Privacy Policy. Additionally, Super Zero may disclose personal data to its parent companies and its subsidiaries in accordance with this Privacy Policy.

Super Zero may hire agents and contractors to collect and process personal data on Super Zero's behalf and in such cases such agents and contractors will be instructed to comply with our Privacy Policy and to use personal data only for the purposes for which the third party has been engaged by Super Zero. These agents and contractors may not use your personal data for their own marketing purposes. Super Zero may use third party service providers such as credit card processors, e-mail service providers, shipping agents, data analyzers and business intelligence providers. Super Zero has the right to share your personal data as necessary for the aforementioned third parties to provide their services for Super Zero. Super Zero is not liable for the acts and omissions of these third parties, except as provided by mandatory law.

Super Zero may disclose your personal data to third parties as required by law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or Super Zero to legal liability. Super Zero may also disclose your personal data to third parties when Super Zero has a reason to believe that a disclosure is necessary to address potential or actual injury or interference with Super Zero's rights, property, operations, users or others who may be harmed or may suffer loss or damage, or Super Zero believes that such disclosure is necessary to protect Super Zero's rights, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on Super Zero. To the extent permitted by applicable law, Super Zero will make reasonable efforts to notify you of such disclosure through Super Zero's website or in another reasonable manner.

Data Retention and Correctness

Super Zero retains the data collected pursuant to this Privacy Policy for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Thereafter if the collected data is no longer needed for purposes specified in this Privacy Policy, Super Zero deletes all aforementioned data in its possession within a reasonable timeframe. Super Zero does not verify the correctness of personal data.

Super Zero may still retain some of the data to the extent such retention is necessary to resolve disputes, enforce Super Zero user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of Services.

Third Party Terms and Conditions

Please note that your access to and use of the Services may be subject to certain third party terms and conditions and privacy policies, including but not limited to application stores, mobile software platforms, on-line gaming platforms, social networking services and payment providers. You recognize and agree that Super Zero is not liable for any such third party terms and conditions and their use of your personal data.

Super Zero may in its discretion make available links through advertisements or otherwise enable you to access third party products or services. Please note that, while using such products or services, you are using products or services developed and administered by people or companies not affiliated with or controlled by Super Zero. Super Zero is not responsible for the actions of those people or companies, the content of their products or services, the use of information you provide to them, or any products or services they may offer. The fact that Super Zero is linking to those products or services does not constitute our sponsorship of, or affiliation with, those people or companies.


Super Zero follows generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity and privacy of the information in Super Zero's possession. Only those persons with a need to process your personal data in connection with the fulfillment of their tasks in accordance with the purposes of this Privacy Policy and for the purposes of performing technical maintenance, have access to your personal data in Super Zero's possession. Personal data collected by Super Zero is stored in secure operating environments that are not available to the public. To prevent unauthorized on-line access to personal data, Super Zero maintains personal data behind a firewall-protected server. However, no system can be 100% secure and there is the possibility that despite Super Zero's reasonable efforts, there could be unauthorized access to your personal data. By using the Services, you assume this risk.


Please be aware of the open nature of certain social networking and other open features of the Services Super Zero may make available to you. You may choose to disclose data about yourself in the course of contributing user generated content to the Services. Any data that you disclose in any of these forums, blogs, chats or the like is public information, and there is no expectation of privacy or confidentiality. Super Zero is not responsible for any personal data you choose to make public in any of these forums.

If you are under 13 years of age or a minor in your country of residence, please ask your legal guardian's permission to use or access the Services. Super Zero takes children's privacy seriously, and encourages parents and/or guardians to play an active role in their children's online experience at all times. Super Zero does not knowingly collect any personal information from children below the aforementioned age and if Super Zero learns that Super Zero has inadvertently gathered personal data from children under the aforementioned age, Super Zero will take reasonable measures to promptly erase such personal data from Super Zero's records.

Super Zero may disclose your personal data to third parties in connection with a corporate merger, consolidation, restructuring.

Further information

Pursuant to Law of the People's Republic of China on the Protection of Minors, any and all use of your personal data by Super Zero is governed by Chinese law and not the laws where you may be located.

Super Zero regularly reviews its compliance with this Privacy Policy. If Super Zero receives a formal written complaint from you, it is Super Zero's policy to attempt to contact you directly to address any of your concerns. Super Zero will cooperate with the appropriate governmental authorities, including data protection authorities, to resolve any complaints regarding the collection, use, transfer or disclosure of personal data that cannot be amicably resolved between you and Super Zero. TO THE EXTENT YOU AND Super Zero ARE NOT ABLE TO AMICABLY RESOLVE ANY DISPUTE THAT MAY ARISE, YOU AGREE THAT YOU MAY BRING CLAIMS AGAINST Super Zero ONLY IN YOUR INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING.