Privacy Policy

Last Update: December 2, 2022

Effective Date: December 2, 2022

Email of Data Protection Officer: contact@vrsuplife.com

Developer: SUPLIFE GAMES

SUPLIFE GAMES (hereinafter referred to as "we") deeply understands the importance of personal information to users (hereinafter referred to as "you") and especially provides this "Privacy Policy" to explain to you how we and our affiliated companies (hereinafter referred to as "we") collect, use, share, and disclose your information in the course of your using our services.

We may update this privacy policy from time to time and shall notify you in a reasonable manner if any change has been made. Your continued use of services from the effective date indicates your consent to be bound by this new privacy policy. If you do not agree with this "Privacy Policy", you should stop to access and/or use our products.

Please contact us at contact@vrsuplife.com if you have any questions about this privacy policy or how you might exercise your rights. We shall review your request and contact you within the period required by laws or regulations.

I.Personal Information We Collect and Use

We will do our best to protect your personal data when you use our games and/or services. If you are a user located in the European Union, we will protect your personal information in accordance with the European General Data Protection Regulation (GDPR). If you are a user located in the U.S., we will protect your personal information in accordance with California Consumer Privacy Act (CCPA) and Children's Online Privacy Protection Act (COPPA). If you are a user located in other regions, we will collect and process your personal information in accordance with the principles required by applicable local laws.

1.1 Data collected via games

We will not collect any personal information from you when you play our games and/or use our services.

1.2 We might request device and app permissions

1.2.1 We might request your permission to access network so that you can use our products normally.

1.2.2 We might request your permission to use your microphone so that we may offer you better better experience in the course of your using our products and/or services.

1.2.3 We might request your permission to allow the application to modify the global sound settings in order to bring you a better experience when you use our products and/or services.

1.2.4 We might request your permission to check your network status to ensure that you can use our products normally.

1.2.5 We might request your permission to Wifi status to ensure that you can use our products normally.

1.2.6 We might request Vibration permission in order to bring you a better experience when you use our products and/or services.

1.2.7 We might request to read the external storage and read the personal data stored in the external storage with the purpose of enabling you to open local files and use our products normally when you use our products and/or services.

1.3 Information we collect from other sources

When you contact us for purchase or use problems, or you have questions for this "Privacy Policy", we might need you to provide certain personal information, including your IP address, E-mail address, name, address, and telephone number, to ascertain the cause of your trouble. Your act of providing us with such information indicates your consent to our collecting, using, managing, and storing your information in accordance with this privacy policy. Such information you provide will be protected in accordance with this "Privacy Policy". All information we collect will be anonymized and de-identified to ensure the security of your personal information.

II. The Use of Cookies and Similar Technologies

We use Cookies and similar technologies for the purpose of providing you with better products and/or services. With the help of these advanced technologies, we are able to track your game progress and learn about your game info so as to provide you with a smooth and high-quality user experience. We shall not apply the above-said technology for any other purpose that is not listed in this policy. Please understand that certain services can only be achieved with these above-said technologies. If your device or related program permits, you can turn off or delete the above-said technologies by changing settings or visiting those technology providers' websites. But this might affect your experience with our products/services.

III. Third Parties

3.1 Third party payment service providers collect relevant personal information

You can acquire virtual products related to products and services, including games, game items, game currency, and game equipment. The above said payment service is provided by third parties. We only receive result verification information confirming that you have completed the payment process from the third party payment service providers so as to provide corresponding vitual products and services to you. If you wish to learn the specific rules as to how third party service providers collect personal information, please read their privacy policies.

3.2 Third Party SDK List

We will integrate third-party SDKs to provide you with better services. The personal information collected by these third party providers in accordance with their own privacy policy. You can refer to the list below to learn about the personal information collected by SDK providers. If you want to know more details, please refer to the their own privacy policy.

Third-Party SDK	Usage	Information they collect	Scope of usgae	Privacy Policy	Owner and its official website
Bugly（AKA, Tencent Bugly SDK）	Data Analysis	Device information, including IMEI, IMSI, AndroidID, IDFA, OpenUDID, GUID, OAID, GAID, ICCID, MAC address, and IP.	All channels and packages	https://privacy.qq.com/ document/preview/ fc748b3d96224fdb825ea79e132c1a56	Tencent Technology Shenzhen Co Ltd（https://www.tencent.com/en-us）
		Access to network connection which might consume GPRS data; obtain network information status; obtain information of installed applications.
		Allow programs to write to external storage.
Umeng SDK	Data Analysis	Device information, including IMEI, IMSI, AndroidID, IDFA, OpenUDID, GUID, OAID, GAID, ICCID, MAC address, and IP.	All channels and packages	https://www.umeng.com/page/policy	"Youmeng Tongxin (Beijing) Technology Co., Ltd. https://www.umeng.com/page/about"
		Access to network connection which might consume GPRS data; obtain network information status; obtain information of installed applications.
		Allow programs to write to external storage.
PICO Unity Integration SDK (v2.1.2)	Necessary for application publishing and Pico platform service usage	Players' account information on platform	Pico	https://www.picoxr.com/cn/terms/privacy.html	Beijing Xiaoniao Kankan Technology Co., Ltd. https://www.picoxr.com/
		Players' friend information on platform
		Leaderboard data
		Achievement data
		Challenge data
Oculus Platform	Receive, statisticize, Use and Transfer data	Avatar	Oculus Platform	https://developer.oculus.com/policy/data-use/	Facebook Technologies, LLC. (https://about.facebook.com/meta/)
		Challenge data information
		Deep link information
		Information about in-app & out-app purchases.
		Information about bringing users together in a virtual space.
		Information about users, relationships between friends, and recently met people.
		Access information about Matchmaking platform services.
		Access information related to the user's platform services.
		Access subscribed information.
		Access user ID, Oculus username, and avatar.
Qiyu_Platform_SDK_v1.1.0	1. Support developers to implement account, social, income and other functions related to Qiyu platform in Unity.	Obtain the account status and information of Qiyu users in the application.	Qiyu Channel	https://app.iqiyi.com/tvguo/iprivacy.html	"Beijing Mengxiangzhanfang Technology Co., Ltd. https://www.iqiyismart.com/"
Qiyu_UnityXR_SDK_v1.4.1	Support developers to develop Qiyu VR content in Unity.	Obtain device manufacturer, name, unique code and other information
		Frame Refresh Rate
GSXR Unity SDK V_1.0.10 / XR V_1.0.4	Support developers to develop in the Unity engine.		Nolo Channel	https://api.nolovr.com:9080/agreements/privacyagreements.html	"Beijing Lingyu Intelligent Control Technology Co., Ltd. https://www.nolovr.com/"

IV.With whom will we share your personal data?

We will share your personal data with our affiliates and shall put all necessary protection mechanisms in place. All recipients are under obligation to comply with GDPR and other laws and regulations that they should abide by. Excepting that, we will not share or sell your personal data with 3rd parties.

We will strictly abide by relevant laws and regulations and keep your personal data confidential. We will not share your personal data with others, except for the following circumstances:

(1) Your explicit consent or authorization has been obtained in advance;

(2) We are under a legal obligation or this is a mandatory requirement from relevant departments;

(3) We need to protect the legal rights and interests of you or other users or other individuals' lives, property, and other legal rights within the confines of laws and regulations;

(4) We have received a legal request from your guardian;

(5) This is in accordance with relevant agreements signed with you (including electronic agreements signed online and corresponding platform rules) or other legal documents;

We may disclose your personal data within the confines of laws to investigate, prevent or take measures against illegal activities, suspected fraud, infringement of our intellectual properties, situations involving potential threats to the personal safety of any person, and violation of our terms and conditions or other agreements, or other legal obligation and/or requirements.

V. Personal Data Retention

We will store your personal information in accordance with applicable local laws and regulations, depending on the jurisdiction.

We will only process your personal data within the necessary confines of the collection purpose related to the provision of services to you. Your personal data will not be retained by us for longer than necessary unless we have the legal right or obligation to retain the data for a longer period of time, or the data is necessary for the establishment, exercise, or defense of legal requirements.

VI.Transfer of Personal Data

All personal data we collect from you will be stored in accordance with the requirements of local applicable laws and regulations in the territory where we and our affiliates are located. When it is necessary to transfer the collected personal data across regions due to business needs, we will obtain your separate consent and ensure that such transfer is in compliance with relevant laws and regulations.

VII.Your Rights

We fully respect and guarantee your rights to your personal data, and you have the following rights to your personal data:

7.1 Right to Access

Except as otherwise provided by laws and regulations, you have the right to exercise your data access rights. You can send an email to contact@vrsuplife.com to contact us to exercise your rights. We will accept and process it within the time specified by the laws and regulations of your location, which will not exceed 15 working days.

7.2 Right to Correct and Delete

You have the right to correct inaccurate personal data about you. You have the right to delete your personal data in the following cases:

a. The personal data is no longer necessary for the purposes for which it was collected or otherwise processed;

b. If you have withdrawn your consent and there is no other legal basis for processing;

c. If you object to its processing and there are no reasonable grounds for its processing;

d. Personal data must be deleted in order to comply with legal obligations under relevant laws;

e. Personal data has been unlawfully processed or;

f. Personal data collected are in connection with the provision of information society services.

Please note that your Right to Delete may be restricted if the data is necessary to comply with legal obligations or to establish, formalize or defend legal claims.

You may request deletion of personal information collected about you by contacting our Data Protection Officer via the contact details we provide, i.e. by sending an email to contact@vrsuplife.com. After receiving your request to delete personal information, we will accept and process it within the time specified by the laws and regulations of your locality, which shall not exceed 15 working days. We will take measures such as checking the deletion of your personal information to protect your personal information.

7.3 Right to Restrict

You have the right to restrict data processing in certain circumstances. We will only process your personal data with your consent if you have the right to restrict it, or for important reasons for establishing, exercising or defending legal claims or protecting personal or public interest.

7.4 Right to Withdraw Consent

If you consent to our use of your data, you can withdraw your consent at any time. If you withdraw your consent, we will stop processing the personal data for which you have withdrawn consent unless we are legally obliged to retain some or parts of your data. Please note that withdrawing your consent does not affect the lawfulness of processing based on your consent prior to its withdrawal.

7.5 Change or Delete Account Information

There are no account and other related functions in our products. You may be required to use suitable accounts of other service providers to access and download our products. Please note that the correction, deletion and cancellation of the account information should follow the privacy policy of the service provider. Please read the privacy policy of the platform carefully. If you want to exercise the above-said rights or have any questions about your exercise of the above rights, please contact us at contact@vrsuplife.com. We will review and process them within the time stipulated by the laws and regulations of your locality which shall not exceed 15 working days.

VIII. Personal Information Security

We use a variety of security technologies and procedures to prevent loss, misuse, unauthorized access or disclosure of information. For example, in some of our services, we use encryption technology to protect certain sensitive information you provide to us. Please note that it is impossible to ensure that information is 100% secure in the internet industry no matter what measures we take. You shall understand that the systems and communication networks used by the services you access may have problems due to factors beyond the controllable field.

IX. Minor Protection

Minors under the age of 13 should read this privacy policy in the company of parents or legal guardians. Under no circumstances are minors allowed to use our services without parents' or legal guardians' consent to this privacy policy.

We will not intentionally collect or solicit personal data about minors under the age of 13, direct them to interest-based advertisements, or intentionally allow such people to use our services unless laws and regulations permit us to collect and process such information without parents' consent. If you are a minor under the age of 13, please do not send us any personal data about you, including your name, address, phone number, or email address. If we learn that we have collected any personal data about minors under the age of 13, we will apply every reasonable method to delete that data. Please contact us if you believe that we might have data from or related to minors under the age of 13. We shall apply every reasonable means to delete that from our system.

This policy follows the definition of minors of the marjority of countries/regions and defines minors in this policy as children under the age of 13. If the definition of minors in your jurisdiction is different from this policy, please refer to the regulations in your jurisdiction. We will still protect children's personal information as described in this article.

X. Updates of Privacy Policy

We reserve the right to change this Privacy Policy at any time. We will notify users on this page and possibly in this application and/or by any available means where technically and legally feasible. It is strongly recommended that you check this page frequently and refer to the last modification date listed in this privacy policy to make sure you know how we collect, use, and share information.

XI. Contact Us

If you have any questions, complaints or suggestions about this Privacy Policy, you can contact us by sending an email to contact@vrsuplife.com.