ACGL: Privacy Policy


Our Privacy Policy was updated on December 29th, 2022.

ABOUT US

Aqua Creative (hereinafter refer to as “Aqua Creative” “we”, “our” or “us”) take your privacy very seriously. This Privacy Policy is designed with your needs in mind, and it is important that you have a comprehensive understanding of our personal information collection and usage practices, while ensures that ultimately, you have control of your personal information provided to Aqua Creative.

ABOUT THIS PRIVACY POLICY

This Privacy Policy explains how Aqua Creative collects, uses, discloses, processes and protects any personal information that you give us or that we collect from you. Should we ask you to provide certain information by which you can be identified when you use the services on our platform, it will only be used in accordance with this Privacy Policy and/or our terms and conditions for users. Under this Privacy Policy, “personal information” means information that can be used to directly or indirectly identify an individual, either from that information alone or from that information combined with other information Aqua Creative has access to about that individual, except as otherwise specifically provided by applicable laws in your region. We will use your personal information strictly in accordance with this Privacy Policy.

HOW WE CAN HELP YOU

Ultimately, what we want is the best for all our users. Should you have any questions with our data handling practices as summarized in this Privacy Policy, please contact us at info@aqua-creative.co to address your specific concerns. We will be happy to hear from you.

1. What information is collected by us and how do we use it?

1.1 What information is collected by us

In order to provide our services to you, we will ask you to provide personal information that is necessary to provide those services to you. We will only collect the information that is necessary for its specified, concrete, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes. You have the right to choose whether or not to provide the information we have requested, but in most cases, if you do not provide your personal information, we may not be able to provide you with our services or respond to your queries.

1.1.1 Information you provide to us

We may collect any personal information you provide to us, which is necessary for the service you choose. For example, you may provide us your game user account if you use our payment service, and you may provide us your credit card number and expiry date if you use credit card to pay.

1.1.2 Information from third-party sources

When permitted by law, we will collect information about you from third-party sources. For example,
information about you that others provided to us (e.g. your email address that other users may provide to us when they buy products for you).

1.1.3 Non-personally identifiable information

We may also collect other types of information which are not directly or indirectly linked to an individual and which may not be defined as personal information according to applicable local laws. Such information may include statistical data generated when you use a specific service (e.g. daily usage events, page access events, page access time events and session events); network monitoring data (e.g. request time, number of request or error request etc.);service crash events. The purpose for such collecting is to improve the services we provide to you. The type and amount of information collected depends on how you use our services.

Such data is not personal information as it cannot be used to identify you. However, if we combine non-personal information with personal information, such information will be treated as personal information.

1.2 How we use the personal information that we collect

The purpose of collecting personal information is to provide you with our services, and to ensure that we comply with applicable laws, regulations and other regulatory requirements. This involves:

  • Providing, processing, maintaining, improving and developing our services to you, such as delivery, after-sales, customer support.
  • Handling your questions or requests about our services, such as answering customer inquiries.
  • Storing and maintaining information related to you for our business operations (such as business statistics) or for fulfilling our legal obligations.
  • Other purposes with your consent

Here are more detailed examples on how we use your information (which may include personal information):

  • Processing your purchase order. Information related to e-commerce orders is used for processing the purchase order and related after-sales services, including customer support and re-delivery. In addition, the order number will be used to cross-check the order with the delivery partner as well as to record delivery of the product. Recipient information, including user gaming id and email address will be used for delivery purposes.

2. How we share, transfer, and publicly disclose your personal information

2.1 Sharing

We do not sell any personal information to third parties. We may sometimes share your personal information with third parties (as described below) in order to provide or improve our services, including offering services based on your requirements. If you no longer wish to allow us sharing this information, please contact us at Info@aqua-creative.co

2.1.1 Sharing that you actively choose or request

With your explicit consent or at your request, we will share your personal information within the scope of your consent/request with specific third parties designated by you.

2.1.2 Sharing with third party service providers and business partners

To help us provide you with services described in this Privacy Policy, we may, where necessary, share your personal information with our third party service providers and business partners. This includes our game providers, payment service providers, data centers, data storage facilities, customer service providers and marketing service providers and other business partners. These third parties may process your personal information on Aqua Creative's behalf or for one or more of the purposes of this Privacy Policy. We guarantee that the sharing of personal information necessary for providing services to you is solely for legitimate, legal, necessary, specific, and explicit purposes. Aqua Creative will conduct due diligence and have contracts in place to ensure that third-party service providers comply with the applicable privacy laws in your jurisdiction. There may be occasions that third-party service providers have their sub-processors.

To provide performance measurement, analysis, and other business services, we may also share information (non-personal information) with third parties in aggregated form. We use the information we have to help our business partners evaluate the effectiveness and coverage of their services, and understand the types of people who use their services and how people interact with their websites, apps, and services. We may also share general usage trends of our services with them, such as the number of customers in a particular group of people who purchase certain products or engage in certain transactions.

2.1.3 Other

In accordance with legal requirements, legal procedures, litigation and/or requests from public agencies and government agencies, Aqua Creative may need to disclose your personal information. If the disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance, we may also disclose information about you.

In order to enforce our terms or protect our business, rights, assets or services, or to protect users, or if the disclosure is reasonably necessary for the following purposes (detecting, preventing and resolving fraud, unauthorized use of the service, violations of our terms or policies, or other harmful or illegal activities), we may also disclose information about you. (There may be occasions when Aqua Creative may collect, use or disclose your personal information without your consent if it is and only to the extent it is permitted under applicable data protection laws). This may include providing your personal information to public or government agencies; communicating with third-party partners about the reliability of your account to prevent fraud, violations, and other harmful behaviors.

In addition, we may share your personal information with:

  • our accountants, auditors, lawyers, or similar advisers when we ask them to provide us with professional advice; and
  • investors and other relevant third parties in the event of an actual or potential sale or other corporate transaction related to Aqua Creative; and
  • any other third parties, if authorized by you to do so in relation to a specific disclosure.

2.2 Transfer

Aqua Creative will not transfer your information to any subject except in the following cases:

  • Where we have obtained your explicit consent;
  • If Aqua Creative is involved in the merger, acquisition, or sale of all or part of its assets, we will notify you of any changes in the ownership, use, and any choice of your personal information you possibly possess by email and/or by posting a prominent notice on our websites.

2.3 Public disclosure

Aqua Creative will only publicly disclose your personal information under the following circumstances:

  • Where we have obtained your explicit consent;
  • Public disclosure based on law or reasonable grounds: including laws and regulations, legal procedures, litigation, or at the request of the competent government departments.

3 How we store and protect your personal information

3.1 Aqua Creative's security safeguards

We are committed to keeping your personal information secure. In order to prevent unauthorized access, disclosure or other similar risks, we have put in place all legally required physical, electronic and managerial procedures to safeguard and secure the information we collect on your device and on websites. We will ensure that we safeguard your personal information in accordance with applicable law.

When you send or receive data from your device to our servers, we make sure they are encrypted using Transport Layer Security (“TLS”) and other algorithms.

All your personal information is stored on secure servers, and protected in controlled facilities.

We classify your information based on importance and sensitivity, and ensure that your personal information has the required level of security. We have special access controls for cloud-based data storage, and we regularly review our information collection, storage and processing practices, including physical security measures, to guard against any unauthorized access and use.

We conduct due diligence on business partners and third party service providers to make sure that they are able to protect your personal information. We also check that appropriate security standards are maintained by these third parties by putting in place appropriate contractual restrictions, and where necessary, carrying out audits and assessments. In addition, our employees and those of our business partners and third party service providers who access your personal information are subject to enforceable contractual obligations of confidentiality.

We conduct security and privacy protection training courses and tests to enhance our employees' awareness of the importance of protecting personal information. We will take all practicable and legally required steps to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure, and for this reason we cannot guarantee the security or integrity of any personal information when transferred from you or to you via the Internet.

We handle personal data breaches as required by applicable data protection law which includes, where required, notifying the breach to the relevant data protection supervisory authority and data subjects.

3.2 Retention policy

We retain personal information for the period necessary for the purpose of the information collection described in this Privacy Policy, or as required by applicable laws. We will cease to retain and delete or anonymize personal information once the purpose of collection is fulfilled, or after we confirm your request for erasure, or after we terminate the operation of the corresponding service. An exception to this is personal information that we are processing for public interest, scientific, historical research, or statistical purposes. Aqua Creative will continue to retain this type of information for longer than its standard retention period, where permitted based on applicable laws or your request, even if further data processing is not related to the original purpose of collection.

4 Your rights

Controlling your personal information

4.1 Controlling settings

Aqua Creative recognizes that privacy concerns differ from person to person. Therefore, we provide ways Aqua Creative makes available to you to restrict the collection, use, disclosure or processing of your personal information and control your privacy settings, such as contacting our privacy customer service address. You may contact us at Info@aqua-creative.co for your rights.

If you have previously agreed to us using your personal information for the aforementioned purposes, you may change your mind at any time by contacting us at Info@aqua-creative.co

4.2 Your rights to your personal information

Depending on applicable laws and regulations, you may have the right to access, rectification, erasure (and certain other rights) in relation to personal information that we hold about you (hereinafter referred to as the request). These rights will be subject to specific exclusions and exceptions under applicable laws. You can contact us at Info@aqua-creative.co to exercise your rights to your personal information. You should provide sufficient information to enable us to verify your identity and ensure that you are the data subject or legally authorised to act on the data subject's behalf. Once we obtain sufficient information to confirm that your request can be processed, we shall proceed to respond to your request within any timeframe set out under your applicable data protection laws.

4.3 Withdrawal of consent

You may withdraw your consent previously provided to us for a particular purpose by submitting a request, including collecting, using, and/or disclosing your personal information in our possession or control. Based on the specific service you are using, you can contact us at Info@aqua-creative.co. We will process your request within a reasonable time from when the request was made, and thereafter not collect, use and/or disclose your personal information as per your request. Depending on the extent of your withdrawal of consent, please note that you may not be able to continue receiving the full benefit of Aqua Creative’s products and services. The withdrawal of your consent or authorization will not affect the validity of our processing carried out on the basis of the consent up until the point of withdrawal.

5 Protection of minors

We consider it the responsibility of the parent or guardian to supervise the child's use of our services. However, we do not offer services directly to a child or use personal data of children for the purposes of marketing. If you are a parent or guardian and you believe that the minor has provided Aqua Creative with personal information, please contact us at Info@aqua-creative.co to ensure that the personal information is removed immediately and that the minor is unsubscribed from any of the applicable Aqua Creative services.

6 Do I have to agree to any third party terms and conditions?

Our Privacy Policy does not apply to products or services offered by a third party. Depending on the service you use, it may incorporate a third parties’ products or services such as payment processing etc. Some of these will be provided in the form of links to third parties’ websites, and some will be accessed in the form of SDKs, APIs, etc. Your information may also be collected when you use these services. For this reason, we strongly suggest that you take the time to read the third party’s privacy policy just like you read ours. We are not responsible for and cannot control how third parties use personal information which they collect from you. Our Privacy Policy does not apply to other sites linked from our services.

7 How we update this Privacy Policy

We review the Privacy Policy periodically based on changes in business and technology, and we may update this Privacy Policy. If we make a material change to this Privacy Policy, we will notify you by publishing on Aqua Creative websites so that you can learn about the information we collect and how we use it. Such changes to Privacy Policy will apply from the effective date specified in the notice or website. We encourage you to check this page regularly for the latest information on our privacy practices. Your continued use of the services on the website, mobile and/or any other device will be deemed acknowledgement of the updated Privacy Policy. We will ask for your explicit consent when we collect additional personal information from you or when we use or disclose your personal information for new purposes.

8 Contact us

If you have any comments or questions about this Privacy Policy or any questions relating to Aqua Creative’s collection, use, or disclosure of your personal information, please contact us at the address below referencing “Privacy Policy”. When we receive privacy or personal information questions about access/download requests, we have a professional team to solve your problems. If your question itself involves a significant issue, we may ask you for more information. If you are not satisfied with the response you received, you can hand over the complaint to the relevant regulatory authority in your jurisdiction. If you consult us, we will provide information on the relevant complaint channels that may be applicable based on your actual situation.

Aqua Creative

ROOM 1605, HO KING COMMERCIAL CENTRE, 2-16 FA YUEN STREET, MONGKOK, KOWLOON, HONG KONG.

Contact us: Info@aqua-creative.co

Thank you for taking the time to read our Privacy Policy!