Privacy Policy
This Privacy Policy outlines how shygame and its affiliates (“we,” “our,” or “us”) collect, use, and disclose your personal data. It applies to the shygame platform (“the Game”) and all related services (collectively referred to as “Services”). This policy is designed to inform you about our practices regarding the collection, use, and disclosure of your personal data when accessing or using our Services, as well as the options available to you concerning your data.
Acceptance of Privacy Policy
By downloading,accessing,using,or interacting with our Services, you acknowledge and agree to the collection, use, and disclosure of your personal data as outlined in this Privacy Policy. This Privacy Policy is incorporated by reference into our End User License Agreement (“EULA”) available in the Terms of Service and is subject to the provisions outlined therein. Any capitalized terms not explicitly defined in this Privacy Policy shall carry the meanings assigned to them in the EULA.
Privacy Policy Overview
This Privacy Policy is designed to help you understand the following:
We offer a variety of online H5 games developed by independent creators, and you can access our services without the need for registration or login. Some of the games on our platform are operated by third parties, including those located outside the EU/EEA, each of which has its own privacy policy. For games hosted by us, we collect and process only the minimum amount of personal data necessary for the following purposes, based on the appropriate legal grounds:
1.1 Location-Based Services: To provide location-based features, such as team formation with nearby players, we may collect your IP address, GPS location, RFID data, and home address. The processing of this data is based on your consent. We will request your consent when activating these features, and you may withdraw your consent at any time.
1.2 Service Improvement and Bug Fixing: To enhance our services and address bugs or errors encountered during gameplay, we may collect data such as your in-game behavior, device information, and network status. The processing of this data is based on our legitimate interests, and we ensure that it does not override your legal rights.
1.3 Legal Compliance: In order to comply with applicable laws (e.g., anti-money laundering regulations), we may collect your device and network information.
The processing of this data is necessary for compliance with the legal obligations to which we are subject.
We use cookies and similar technologies (such as web beacons, log files, scripts, and eTags) ("Cookies") to improve your experience with our services. Cookies are small files placed on your device that enable us to provide specific features and functionality.
You have the option to allow the installation of Cookies or disable them at any time. You may choose to accept all cookies, configure your device or web browser to notify you when cookies are being installed, or refuse all cookies by adjusting the relevant settings on your device. Please note that refusing to accept cookies may impact the functionality of the Game, and certain features may not work as intended.
We may share your personal data with the following categories of third parties in order to provide our services:
3.1 Affiliates：As a global company with affiliates worldwide, we may share your personal data with our affiliates in order to provide our services. This sharing will occur based on the relevant legal grounds and the data processing agreements in place between us.
3.2 Advertising
This service allows user data to be used for advertising purposes, such as displaying banners and other advertisements on this website, potentially tailored to users’ interests. Please note that not all personal data is used for this purpose. Further information and conditions of use are outlined below.
Some of the services listed may use cookies to identify users or employ behavioral retargeting techniques, which involve displaying ads based on a user’s interests and behavior, including activities outside of this website. For more details, please review the privacy policies of the relevant services.
(1) AdSense:
https://www.google.com/settings/ads/onweb/optout
3.3 Data Analytics
To enhance our services and gain a deeper understanding of user behavior, we may conduct research and analysis on the personal data we collect, such as your game statistics. This data may be analyzed, profiled, and segmented, with findings often compiled and analyzed on an aggregate basis.
We may also engage third-party service providers to monitor and analyze the use of our services. These third parties will have access to your personal data solely to perform these tasks on our behalf and are contractually obligated not to disclose or use the data for any other purpose. For further details, please review the privacy policies of our partners, available below:
(1) Google Analytics:
(2) Google Tag Manager:
3.4 Remarketing and Behavioral Targeting
This service enables this website and its partners to inform, optimize, and serve advertisements based on the user's past interactions with the website. This is achieved by tracking usage data and utilizing trackers to collect information, which is then shared with partners managing remarketing and behavioral targeting activities.
Some services may offer remarketing options based on email address lists.
In addition to any opt-out features provided by the services listed below, users may opt out by visiting https://optout.networkadvertising.org/?c=1. Users can also opt out of certain advertising features through their device settings, such as the advertising settings for mobile phones or general ad settings.
(1) Google Ads Remarketing (Google Ireland Limited):
(2) Remarketing with Google Analytics (Google Ireland Limited):
3.5 Traffic Optimization and Distribution
This service enables this website to distribute its content through servers located in various countries and to optimize its performance. The personal data processed depends on the characteristics of the service and how it is implemented. The primary function of this service is to filter communications between the website and the user's browser.
Due to the global nature of this system, it is difficult to determine the specific locations to which content—possibly containing the user's personal data—may be transferred.
3.6 Law Enforcement / Legal Obligation
(1) Anti-Cheat and Anti-Fraud Companies:
We may
share the necessary information with anti-cheat and anti-fraud companies
to support the detection, investigation, and prevention of cheating and
violations of the End User License Agreement (EULA) within the game. This
information will only be shared for the specific purpose of addressing
these issues.
(2) Public Authorities and Auditors:
Certain
personal data may be disclosed to public authorities, such as tax and
customs authorities, auditors, and other competent parties, as required by
applicable laws and regulations.
3.7 Sale or Merger
In the event that we sell, buy, merge, or partner with another company, or undergo a business transaction such as the sale of some or all of our assets, personal data may be transferred as part of the assets involved in such transactions. If a third party acquires all or a substantial portion of our business, we may disclose your data to the prospective buyer. You will be notified of any change in ownership or the handling of your personal data via email, in-app notifications, or notices on our website.
4.1 Determining Retention Period
The retention
period for your personal data is determined based on the following
factors:
4.2 Retention Duration
We may retain your personal
data for as long as necessary to provide our services or products to you,
or as required or permitted by applicable laws.
When personal data is no longer required, we will ensure its destruction using appropriate measures to render the data irrecoverable or irreproducible. Electronic files containing personal data will be permanently deleted using a technical method that makes the files irreproducible.
If the processing and retention period has ended but retention is required for other purposes, such as compliance with applicable laws, the relevant data will be stored separately from other types of personal data.
If you request the destruction of your personal data before the end of its retention period (as outlined in our retention policy), we will comply with this request in accordance with local laws.
We are dedicated to safeguarding the privacy and integrity of your personal data, regardless of where it is stored. Our group companies implement information security and access policies to limit unauthorized access to our systems and technology. We also protect your data using technological security measures such as encryption. Your personal data remains subject to our technical and organizational controls, as well as our policies and procedures, including this Privacy Policy.
However, please note that transmitting information over the internet is not entirely secure. While we make commercially reasonable efforts to protect your personal data, we cannot guarantee the security of the information transmitted to our services. Any transmission of your information is done at your own risk.
In the event of a personal data breach, we will notify the competent supervisory authority within 72 hours of becoming aware of it, unless the breach is unlikely to result in a risk to your rights and freedoms.
If the breach is likely to result in a high risk to your rights and freedoms, we will inform you without undue delay.
By accessing and/or using our Services, you confirm that you are an “adult” as defined by the laws of your jurisdiction and possess the necessary authority to do so. If you are not considered an adult, you must obtain consent from your parent or legal guardian before using our Services. Generally, our Services are not intended for children under the age of 16 (this age requirement may differ depending on your country, as outlined in the table below), and we do not knowingly collect personal data from children of that age.
Children under the age of 16 are prohibited from using or attempting to use our Services. If you are under 16, please refrain from using our Services.
If we discover that we have inadvertently collected personal data from a child under the age of 16, we will take reasonable steps to delete such data from our records. Parents or guardians who believe that we may have collected personal information from a child under 16 can contact us at the email address provided in the "Contact Us" section below.
7.1 The Right to Be Informed
You have the right to
be provided with clear, transparent, and easily understandable information
about how we use your personal data and your rights. This Policy aims to
provide that information.
7.2 The Right of Access
You have the right to obtain
access to your personal data. This allows you to verify that we are using
your personal data in accordance with applicable data protection laws.
Please
contact us and submit a request to the email address provided in the
"Contact Us" section below.
7.3 The Right to Rectification
You are entitled to
have your personal data corrected if it is inaccurate or incomplete. For
information that you can modify within your game settings, you can update
it yourself. For other information you cannot change, please contact us
via email.
7.4 The Right to Erasure
Also known as the
"right to be forgotten," this allows you to request the deletion
or removal of your personal data when there is no compelling reason for us
to continue using it. Please note that this is not an absolute right, and
exceptions may apply.
You may request that we erase your personal
data in the following circumstances:
• You believe it is no longer
necessary for us to hold such personal data.
• You believe the
personal data we hold about you is being unlawfully processed.
We may need to retain certain personal data if there are valid legal
grounds under data protection laws, such as for the defense of legal
claims or the exercise of freedom of expression. If this is the case, we
will inform you. If you request the erasure of personal data made publicly
available on our Services and there are grounds for erasure, we will take
reasonable steps to inform others displaying or linking to your personal
data to delete it as well.
While we consider your request, you may
also exercise your right to restrict the processing of your personal data
(as described below).
7.5 The Right to Restrict Processing
You have the
right to request that we stop processing your personal data, except for
storage purposes, in specific circumstances. However, if we cease
processing, we may still use your data if there are valid legal grounds
under data protection laws (e.g., for the defense of legal claims or to
protect another person).
If we agree to stop processing your personal
data, we will attempt to inform any third party to whom we disclosed the
data so they can cease processing it as well.
You may request
restricted processing in the following cases:
7.6 The Right to Data Portability
You have the right
to obtain and reuse your personal data for your purposes across different
services. This allows you to move, copy, or transfer your data safely and
securely between IT systems without affecting its usability.
7.7 The Right to Object to Processing
You have the
right to object to specific types of processing, including processing for
direct marketing purposes (which we perform only with your consent).
7.8 The Right to Lodge a Complaint
You have the
right to lodge a complaint regarding our handling or processing of your
personal data with your national data protection authority.
7.9 The Right to Withdraw Consent
If you have given
your consent for us to process your personal data, you can withdraw it at
any time. Withdrawing your consent will not affect the legality of any
processing conducted before your withdrawal. This includes withdrawing
consent for marketing purposes.
7.10 The Right Not to Be Subject to Automated Decision-Making
You have the right not to be subjected to decisions made solely
through automated processing (including profiling) that produce legal or
similarly significant effects on you.
Additional Information
We typically act on requests
and provide information free of charge. However, we may charge a
reasonable fee for:
Alternatively, we may refuse to act on your request if it is unreasonable.
Please consider your request responsibly before submitting it. We strive to respond within one month of receiving your request. If we need more time, we will inform you of the delay.
Additionally, we will cooperate with third parties who interact with your data to ensure your rights under applicable laws and regulations.
If we make any material changes to this Privacy Policy, we will update the revised version on this page and notify our users through appropriate channels, such as in-app notifications, emails, or website announcements.
We encourage you to review this page periodically to stay informed about how we protect your personal data and any updates to this policy.
9.1 Brazil Addendum
If you are located in Brazil,
you acknowledge that we comply with Brazil’s General Data Protection Law
(Lei Geral de Proteção de Dados Pessoais, LGPD). For any questions,
concerns, or complaints regarding this Privacy Policy or the handling of
your personal data, please contact us at the address provided in the
“Contact Us” section below.
9.2 Colombia Addendum
If you are located in
Colombia, you acknowledge that we comply with Statutory Law 1581 of 2012
(Law 1581). For any questions, concerns, or complaints regarding this
Privacy Policy or the handling of your personal data, please contact us at
the address provided in the “Contact Us” section below.
9.3 Turkey Addendum
If you are located in Turkey,
you acknowledge that we comply with the Law on Protection of Personal
Data, Law No. 6698 (LPPD). For any questions, concerns, or complaints
regarding this Privacy Policy or the handling of your personal data,
please contact us at the address provided in the “Contact Us” section
below.
9.4 Peru Addendum
If you are located in Peru, you
acknowledge that we comply with The Personal Data Protection Law N° 29733
(PDPL) and Supreme Decree N° 003-2013-JUS (Regulation). For any questions,
concerns, or complaints regarding this Privacy Policy or the handling of
your personal data, please contact us at the address provided in the
“Contact Us” section below.
If you wish to lodge a complaint regarding our handling of your personal data or need to contact us for any other reason (including exercising your rights related to personal data), please send your request to: