Privacy Policy

1. Introduction

NEON ACTIVE LIMITED, along with its affiliates, including Grande Games Ltd. and Beijing Bole Technology Co., Ltd., (collectively referred to as the “Company,” “we,” or “us”) creates, publishes, promotes, and sells various games for different platforms, including mobile devices. These games (referred to as our “Applications”) offer gameplay and social gaming experiences, including in-app purchase options. We also manage the following websites: https://spinxgames.com, (collectively known as the “Services”).

NEON ACTIVE LIMITED decides how and why your personal data is processed as described in this Privacy Policy, making it the “data controller” of that information.

2. Notice

We encourage you to read this Privacy Policy thoroughly to understand how we handle your personal data. However, if you wish to go directly to a specific section, you can click on the relevant link above.

This Privacy Policy explains our information practices, including the types of personal data we collect, how we use and protect that data, and your options for managing and sharing your personal information. It covers personal data collected through our Services and applies to all users worldwide.

3. Information We Collect About You

We gather information about you in three main ways: (1) directly from you, (2) automatically as you use our Services, and (3) from third parties. The type of information we collect depends on the Service you’re using, the third-party partners involved, and your privacy settings.

Information You Provide Directly

We collect personal information when you choose to share it with us, whether through online interactions or other ways you engage with us (like social media, surveys, customer support, contests, or promotional events). You may be asked to provide personal information when you use certain features of our Services, such as creating an account, contacting customer support, or making purchases.

Information We Collect Indirectly

We also gather information indirectly through automated methods when you use our Services. This includes data collected from your device using cookies and other tracking technologies. More details about this can be found in the "Mobile IDs, Cookies, and Other Tracking Technologies" section below.

Information from Third Parties

We also obtain your personal information from third-party sources, including:

-Social Media and Third-Party Partners: We gather information from third-party applications, such as social networks, that you choose to link or interact with through our Services. For instance, if you connect to our apps using Facebook, we receive your username, profile picture, profile details, and your friends list.

-Co-branding and Marketing Partners: We collect information from partners with whom we collaborate on co-branded services or joint marketing campaigns.

-Service Providers: Third parties working on our behalf may collect or share information as part of the services they provide. For example, vendors who handle customer service in our apps may collect communication content, your name, username, contact details, and other information you provide.

-Publicly Available Sources: We may also obtain information from public sources, such as publicly accessible websites and open government databases.

Before using information from third parties, we verify that they have obtained your consent or have the legal right to share your personal information with us.

Description of Personal Information Collected

We collect various types of personal information from different sources, including:

-Name and Contact Information: This includes your first and last name, username or alias, and contact details like email address, mailing address, and phone number. We may also receive your social media handles, social media ID, and contact list.

Source: Directly from you and third parties.

-Demographic Information: In certain situations, such as when you fill out a survey, we may gather details like your age, gender, marital status, occupation, household income, and other demographic information.

Source: Directly from you and third parties.

-Payment Information: When you make a purchase or conduct a financial transaction, payment processors working on our Sites and in our apps collect payment details, including card numbers and financial account information.

Source: Directly from you.

-Purchase Information: We collect details about your purchases on our Sites and apps, such as order ID and order amount.

Source: Automatically.

-Content and Files: This includes photos (like social media profile pictures or their URLs), screenshots of gameplay, documents, or other files you upload to our Services. We also collect and retain any emails or messages you send us.

Source: Directly from you and third parties.

-Communications Information (a type of “sensitive personal information” under the California Consumer Privacy Act): We collect the content of your communications when you use our Services to send messages to others.

Source: Directly from you and third parties.

-Identifiers and Device Information: When you use our Services, we automatically collect your IP address and device details, including device identifiers (like MAC address, advertising IDs, IMEI, and other unique identifiers), device type, operating system, browser type, version, language, settings, storage information, network provider, battery status, and configuration. We also store and retrieve cookie identifiers and mobile IDs, as described in the “Mobile IDs, Cookies, and Other Tracking Technologies” section.

Source: Automatically.

-Geolocation Information: Depending on your device and app settings, we may collect location data when you use our Services.

Source: Automatically.

-Usage Data: We automatically log your activity on our Sites, apps, and connected products, including the URL you came from, pages viewed, time spent on each page, access times, and other usage details. We also gather information about your activities on third-party sites and services.

Source: Automatically and from third parties.

-Inferences: We analyze other data we collect to generate insights about your likely preferences or other characteristics. This includes inferences based on survey responses or data received from third-party advertisers. For instance, we may determine your general geographic location (e.g., city, state, and country) from your IP address.

Source: Directly from you, automatically, and from third parties.

We don’t gather any special categories of personal information as defined by the GDPR, such as health details, racial or ethnic background, or sexual orientation. However, under certain U.S. state privacy laws, we do receive what’s considered “sensitive personal information,” specifically the content of your communications when you use our Services to message others.

You have the option to refuse to provide personal information when asked. Additionally, you can use your web browser or device settings to block certain types of automatic data collection. However, if you choose not to share or allow information required for certain services or features, those services or features may not be accessible or may not function properly.

4. Mobile IDs, Cookies, and Other Tracking Technologies

We use a variety of tracking technologies, such as cookies (including Flash cookies), transparent GIFs (also known as “web beacons”), mobile analytics and advertising IDs, server log analysis, and other tools (collectively referred to as "Cookies"). These technologies, whether they exist now or are developed in the future, help us run our Services, improve your user experience, and collect data about how you interact with our Services, including identifiers and device details.

Mobile analytics and advertising IDs are created by mobile operating systems (like Android) and function similarly to cookies on websites. Our apps include software that allows third-party analytics and advertising partners to access these mobile IDs.

We do not share mobile information with third parties or affiliates for marketing or promotional purposes. Additionally, all other data usage excludes text messaging originator opt-in data and consent, which will not be shared with any third parties.

5. How Your Information Is Used

The personal information we collect will be used for the purposes described in this Privacy Policy or otherwise as we make clear to you at the time we collect the information. For processing personal information of users in the EU and UK, we rely on one of the following lawful bases, depending on the purpose for which we collect your personal information:

Contract — We need certain personal information in order to provide and support the services you have purchased or requested;

Consent — In some cases, we may ask for your consent before collecting, using or disclosing your personal information (not related to any contract between us), in which case you can choose to consent or withhold consent voluntarily and there will be no negative impact on you;

Legitimate Interests — We will use or disclose your personal information for our or a third party’s legitimate business interests, provided your privacy rights are appropriately protected. Where we rely on our (or a third party’s) legitimate interests, these interests will typically be: operating, providing and improving our business (including our services); communicating with you and responding to your questions; improving our services or using insights to improve or develop marketing campaigns and promote our products and services; detecting or preventing illegal activity (such as fraud); and/or managing the security of our IT infrastructure and protecting the safety of our employees, customers and suppliers. Where we need your data to pursue our legitimate interests or those of a third party, the use will be in a way you would reasonably expect and will not materially impact on your rights and freedoms. We have set out our legitimate interests below;

Legal obligations – In some cases we must process and hold your personal information to comply with the law or to meet certain legal obligations.

The table below provides further details on the personal information we process and the relevant lawful bases. The lawful basis for processing your personal information will depend on the data in question and the specific context in which we use it.

To access the virtual items you've purchased and fulfill our contract with you, NEON ACTIVE LIMITED requires your purchase information. Without this information, we won't be able to complete our contract or provide you with the services. Additionally, providing your email is necessary for receiving payment receipts or logging into a Service via email. If you choose not to provide your email, you may not be able to make purchases or log in through email.

We combine the data we gather from various sources to enhance your experience, making it smoother, more consistent, and tailored to your preferences.

6. How We Share Your Information

We may share deidentified information, meaning details that can’t reasonably be linked back to an individual, as permitted by law.

Personal information may also be shared with your consent, or when necessary to complete your transactions or provide the services you’ve requested. Additionally, we disclose the categories of personal information listed earlier with the types of recipients and for the business purposes outlined below:

-Public Information: Some of your profile details, such as your profile name, image, game level, and virtual items, can be viewed by other players. You can update your name, profile picture, and other details.

-Third-Party Social Media Platforms: If you choose, we may share your profile name, player ID, profile picture, and in-game content (like game level, screenshots, and virtual items) with third-party social media platforms.

-Service Providers: We share personal information with third-party vendors, contractors, or service providers who help us operate our business. This includes customer support teams, game analysts, hosting services, and marketing partners.

-Financial Services & Payment Processing: When you provide payment details, we share necessary information with banks and payment processors for fraud prevention, credit checks, transaction processing, and other financial services.

-Affiliates: We may share personal data across our subsidiaries and affiliates to provide services and run our business.

-Corporate Transactions: Personal information may be disclosed during a corporate transaction like a merger, acquisition, or sale of business assets.

-Legal & Law Enforcement: If required by law or legal proceedings, we may disclose personal information to comply with legal obligations, court orders, or to assist law enforcement.

-Security, Safety, and Protecting Rights: We may disclose your information to safeguard users and others, such as preventing fraud, protecting life or safety, securing our systems, or investigating illegal activities or fraud.

-Third-Party Analytics & Advertising: Companies like Google Analytics may collect personal data such as device identifiers, geolocation, and usage patterns to analyze interactions with our Services. Some of these disclosures may qualify as a “sale” or “sharing” of personal data under California and other U.S. laws. For more information, please refer to the “What Choices Do You Have” and “California Privacy Rights” sections.

Additionally, some services may link to third-party services with their own privacy practices. If you provide personal information to those services or allow us to share it with them, their privacy policies will govern that data.

7. Your Choices Regarding Our Use of Your Personal Information

We offer you several options to control how we use and manage the personal information we hold about you. In some regions, these options may be enforceable as legal rights. If you're located in the UK, EEA, or Switzerland, please refer to the "UK, EEA, and Swiss Data Protection Rights" section below for more details.

-Access, Portability, Correction, and Deletion: Depending on where you live, you may have the right to access, request a copy of, correct, or delete your personal information. If you want to exercise any of these rights, please email us at grandjpgame@outlook.com. We might need you to verify your identity so we can process your request and find the information we hold about you.

-Keep in mind that certain records, such as payment or customer service information, might be retained for legal or accounting reasons. If you've previously allowed us to access your precise geolocation or receive push notifications, you can stop sharing this data or turn off notifications via your device settings or through the app itself.

-Communication Preferences: You can choose whether to receive promotional messages from us via email, SMS, mail, or phone. To opt-out of promotional emails or SMS, just follow the unsubscribe instructions in those messages, or contact us through the "Contact Us" section below. Please note that processing your opt-out requests might take a little time. Even if you opt-out of promotional emails, we may still send you important account-related emails or messages regarding the services you've requested or received.

Targeted Advertising

If you'd like to opt out or control targeted advertising, there are a number of options available to you. For example, you can use the Global Privacy Control (GPC) setting on your web browser or browser extension. Many of our partners also belong to associations that offer simple ways to opt out of cookies, analytics, and ad targeting. Here’s where you can do that:

-United States: NAI (optout.networkadvertising.org) and DAA (optout.aboutads.info)

-Canada: Digital Advertising Alliance of Canada (youradchoices.ca)

-Europe: European Digital Advertising Alliance (youronlinechoices.com)

Additionally, you can use other cookie or mobile ID controls as outlined below.

These choices are specific to the device or browser you're using, so if you access our services from multiple devices or browsers, be sure to apply these preferences on each one to ensure they’re honored across your usage.

Data Sales

Some privacy laws define “sale” broadly, which may include certain disclosures described in our "Disclosure of Personal Information" section. To opt-out from such data “sales,” you can visit our “Do Not Sell or Share My Personal Information” section, use the Global Privacy Control (as mentioned above), or email your request to grandjpgame@outlook.com.

Browser or Platform Controls

-Cookie Controls: Most browsers are set to accept cookies by default. You can change these settings in your browser to reject or delete cookies. However, deleting or rejecting cookies may affect the functionality of certain services or features on our sites. If you delete cookies, preferences set by those cookies (such as advertising preferences) might also be removed.

-Global Privacy Control (GPC): Some browsers or extensions allow you to send a signal indicating your preference to opt out of certain data processing practices, including data sales and targeted advertising. When we detect this signal, we'll do our best to honor your preferences as per applicable laws.

-Do Not Track (DNT): While some browsers allow you to enable DNT features to stop tracking, we don't currently respond to DNT signals due to varying interpretations of what the DNT signal means. However, you can still control data collection using the other tools mentioned here, such as cookie controls.

-Mobile Advertising ID Controls: Android allow you to limit tracking by adjusting or resetting your advertising IDs.

-Email Web Beacons: Many email clients let you prevent the automatic downloading of images, including web beacons, which stops your email client from automatically connecting to the servers hosting those images.

Requesting Your Rights

While we aim to honor your privacy choices, please note that in some cases, we might decline requests to exercise your rights. For instance, we might deny a request if fulfilling it would be prohibited by law, affect the privacy of others, disclose confidential information, or conflict with business obligations. We may also decline requests if we cannot verify your identity, if the request is unreasonable or excessive, or if we're otherwise permitted to do so by law. If your request is denied in whole or part, you can appeal the decision by contacting us using the details at the end of this Privacy Policy.

8. UK, EEA, and Swiss Data Protection Rights

If your personal information is processed under the data protection laws of the UK, the European Economic Area (EEA), or Switzerland, you have specific rights regarding that data:

-Access, Rectification, and Erasure: You can request access to, correction, or deletion of your personal information.

-Data Portability: If any automated processing of your data is based on your consent or a contract with you, you have the right to obtain or transfer your personal information in a portable, usable format.

-Withdrawal of Consent: If we process your data based on your consent, you can withdraw that consent at any time. This can be done by contacting us using the details provided in the “Contact Us” section below. Keep in mind that withdrawing your consent won't affect the lawfulness of any processing carried out before the withdrawal, nor will it affect processing based on other lawful grounds.

-Objection and Restriction: You can object to or request a restriction on the processing of your personal information in certain situations.

-Opt-out of Marketing: You have the right to opt out of marketing communications from us at any time. You can do this by clicking the "unsubscribe" or "opt-out" link in marketing emails. To opt-out of other marketing methods, such as postal mail or phone calls, please reach out to us using the contact details under "Contact Us." Please note that even if you opt out of marketing communications, we may still send you essential, non-promotional emails related to your account or business relationship with us.

-Complaints: If you believe that our handling of your personal data violates the law, you have the right to file a complaint with a supervisory authority. You can contact your local supervisory authority for more information. For the UK, the contact information is available here. In some cases, the supervisory authority may ask you to first exhaust our internal complaint process before investigating the issue.

-France-specific Right: For residents of France, you can give us instructions on how you would like your personal information to be handled after your death.

If you wish to exercise any of your rights or contact our Data Protection Officer, please email us at grandjpgame@outlook.com.

We make sure to respond to all requests regarding your data protection rights in line with the applicable data protection laws.

9. California Privacy Rights

If you are a resident of California and your personal information is subject to the California Consumer Privacy Act (CCPA), you have specific rights regarding your data.

-Notice at Collection: When we collect your personal information, you have the right to be informed about our practices, including the types of personal information and sensitive information we collect, the reasons for collecting or using it, whether the information will be sold or shared, and how long we will retain it. You can find this information in our Privacy Policy.

-Right to Know: You have the right to ask us for the personal information we’ve collected about you. You can also request further details about how we collect, use, disclose, or share your personal information. A lot of this information is provided in this Privacy Policy. To request access to this data, email us at grandjpgame@outlook.com or write to us at #A13, RM19, 2/F, SINO IND PLAZA, 9 KAI CHEUNG RD KLN BAY, HONG KONG.

-Right to Request Deletion: You have the right to ask us to delete your personal information in certain cases, although there are exceptions. To request deletion, you can email us at grandjpgame@outlook.com or write to us at #A13, RM19, 2/F, SINO IND PLAZA, 9 KAI CHEUNG RD KLN BAY, HONG KONG.

-Right to Opt-Out/Do Not Sell or Share My Personal Information: You can opt out of the "sale" or "sharing" of your personal information, as defined by the CCPA. The CCPA broadly defines "sale" and "personal information," so some of our data sharing activities might be considered a "sale" under these definitions. In the past year, we have shared or sold all categories of personal information listed above. To opt out, you can use the Global Privacy Control or email us at grandjpgame@outlook.com. We do not knowingly sell personal information of minors under 16 years old.

-Right to Limit Use and Disclosure of Sensitive Personal Information: You can limit how we use sensitive personal information, such as communication content, for purposes other than providing services you request or as allowed by law. We use the content of your communications to facilitate services, customer support, and address complaints about violations of our Terms of Service. If you have questions about how we use sensitive personal information, please contact us using the details provided in this Privacy Policy.

-Authorized Agents: You can appoint an authorized agent (in writing or through a power of attorney) to make requests on your behalf to exercise your CCPA rights. Before we accept such a request, we’ll need the agent to provide proof of authorization and may require you to verify your identity directly with us.

Additionally, to respond to requests for specific information or actions regarding your data, we may need to verify your identity to the extent required by law. This could involve confirming your request from the email address associated with your account or providing necessary information to verify your identity.

Finally, you have the right to exercise these CCPA rights without fear of discrimination.

In the past calendar year, we received and processed the following types of California privacy rights requests:

-Requests to know: 0 received, for compliance and denial, N/A for response time

-Requests to delete: 0 received, N/A for compliance and denial, N/A for response time

-Requests to opt-out: 0 received, N/A for compliance and denial, N/A for response time

In accordance with California Civil Code section 1798.83, also referred to as the “Shine the Light” law, California residents who have shared personal information with a business for personal, family, or household purposes (referred to as “California Customers”) have the right to inquire whether the business has shared their personal information with third parties for the third parties' direct marketing. If the business has disclosed such information, upon request, it must provide a list of those third parties and the types of personal information disclosed in the previous calendar year. California Customers can contact us via email at grandjpgame@outlook.com for further information about how we comply with this law. Please note that businesses are only required to respond to one request per California Customer annually and may not be obligated to respond to requests made through any means other than the designated email address.

Additionally, California residents under 18 who are registered users of online services have the right, as per California Business and Professions Code Section 22581, to request the removal of content or information they’ve publicly posted. To make such a request, they can email us at grandjpgame@outlook.com. However, please note that submitting a request does not guarantee the complete removal of content, and the law may not require removal in certain situations.

10.Retention of Personal Information

We keep personal information for as long as necessary to fulfill the services and transactions you've requested, meet our legal requirements, resolve disputes, enforce agreements, and for other valid business reasons. The retention period for different types of information can vary depending on factors such as user consent, the sensitivity of the data, and the availability of tools for users to manage or delete their data, as well as our legal obligations.

If you need more details about how long we retain certain types of personal information, feel free to reach out to us using the contact details provided under the “Contact Us” section.

11.Location of Personal Information

We may store and process the personal information we collect either in your country or region or in other countries where we, our affiliates, subsidiaries, or service providers operate. The locations are chosen to ensure efficiency and improve performance, while we take appropriate steps to process and protect your data as outlined in this Privacy Policy, no matter where it’s stored.

European Personal Information Processing

When transferring personal data outside of the European Economic Area, Switzerland, and the UK, we ensure that it is transferred to countries deemed by the European Commission or the UK’s Secretary of State to provide adequate protection for personal data. If the transfer is not subject to such an adequacy decision or regulations, we implement appropriate safeguards to protect your data, such as the European Commission’s Standard Contractual Clauses, including an Addendum for transfers from the UK.

You can request the Standard Contractual Clauses we’ve entered into with our group companies or third-party partners. However, please note that certain sensitive business information may be redacted.

12.Security of Your Personal Information

We have put in place reasonable precautions to safeguard the personal information we collect from loss, misuse, unauthorized access, and other risks. However, please be aware that no security measures can provide 100% protection.

To further protect your account, we recommend using a strong, unique password and keeping it private. Avoid sharing your password with anyone, and refrain from using the same password across multiple accounts.

13.Effective Date and Changes to the Policy

Every time you use our Services, the latest version of the Privacy Policy will apply. So, we recommend checking the date of the Privacy Policy (located at the top) and reviewing any updates since the last time you visited. This policy can change from time to time, and unless we specify otherwise, the most recent version applies to all the data we hold about you. If we make significant changes, we will notify you or ask for your consent if required by law.

14.Contact Us

If you have any questions or comments about this Privacy Policy, or about how we handle information through our Services, feel free to email us at grandjpgame@outlook.com.

Alternatively, if you prefer to send a letter, our mailing address is #A13, RM19, 2/F, SINO IND PLAZA, 9 KAI CHEUNG RD KLN BAY, HONG KONG. You may also contact our representatives in the EU or the UK if applicable.