Cygnet Limited (“Cygnet” or “we”) provides this privacy policy (“Privacy Policy”) to inform you of our policies and procedures regarding the collection, use and disclosure of personal information we receive from users of certain electronic game software, application software offered by Cygnet and its partners that are owned, operated licensed or controlled by Cygnet (the “Cygnet Products”) and any other services provided by Cygnet and its partners including any support Cygnet may provide to your inquiries regarding Cygnet Products, repair services of Cygnet Products, announcements in regards to Cygnet Products and related events and marketing for the purpose of development and enhancement of Cygnet Products along with any Cygnet offered website and forums (with Cygnet Products, collectively, the “Service”). This Privacy Policy applies only to information that you provide to us through the Service. This Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on the Service. You are advised to consult this Privacy Policy regularly for any changes. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in the relevant terms of use for the Service.
As used in this Privacy Policy, the terms “using” and “processing” information include using cookies on a computer or other device, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organisation or among our affiliates within Hong Kong and Taiwan, and/or any other countries internationally.
This Privacy Policy shall be interpreted under and governed by the law of Hong Kong as administered by the courts of Hong Kong.
Our primary goals in collecting information are to provide and improve our Service, to administer your membership, and to enable users to enjoy and easily navigate them. For the purposes of providing you our Services we may provide your personal information internationally to our affiliated companies. By submitting your personal information to us, you understand and agree that we may transfer your personal information to those affiliated companies. We may additionally transfer your data in similar fashion to third party sub-contractors in which case we will ensure that such sub-contractors abide by the terms of this Privacy Policy.
When you download Cygnet Products and/or register with us, either through the Cygnet Products or the Service (“Cygnet Subscriber”), we may ask you for personally identifiable information. This refers to information about you that can be used to contact or identify you (“Personal Information”). Personal Information includes, but is not limited to, your name, phone number, credit card or other billing information, email address and home and business postal addresses. We also collect the other information that you provide as part of registration and the administration and personalization of your account (e.g., without limitation, zip/postal code (on its own) and individual preferences) which are not your personally identifiable information (“Non-Identifying Information”). We use your Personal Information (in some cases, in conjunction with Non-Identifying Information) mainly to provide the Service, complete your transactions for the Services, and administer your inquiries.
We may also use your email addresses and, if applicable, your phone number and addresses to contact you with Cygnet’s and its marketing partners’ newsletters, marketing or promotional materials and other information that may be of interest to you. Such marketing subjects include but not limited to the availability of content, special offers in relation to Cygnet and content, joint promotional deals with our content providers or advertisers. Cygnet will honor an individual’s request not to use his or her personal information for the purposes of direct marketing. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications or send us an email request to bfb.cs@cygnetify.com or update your “user preferences” information as applicable. (See the section called Changing or Deleting Information, below).
In principle, when the purposes of collecting and using your Personal Information are achieved, such information will be destroyed without unreasonable delay. However, if any of your Personal Information is required to be retained under applicable laws and regulations, such Personal Information will be retained and used for the period and purpose as prescribed under such laws and regulations.
When destroying your Personal Information, Cygnet will take commercially reasonable and technically possible measures to make the Personal Information irrecoverable or irreproducible as follows: (i) Electronic files which contain personal Information will permanently be deleted using a technical method which makes the files irrecoverable; and (ii) Any other records, print-outs, documents or any other recording media will be shredded or incinerated.
When you use or visit the Service, whether as a Cygnet Subscriber or a non-registered user just browsing (in either case we deem you a “Cygnet User”), our servers automatically record information that your browser or device sends whenever you visit a Service (“Log Data”). This Log Data may include information such as your computer or other device’s Internet Protocol address, MAC address, device specifications, browser type, or the webpage you were visiting before you came to the Service, pages of the Service that you visit, the time spent on those pages, information you search for on the SEGA Products, access times and dates, and other statistics or information regularly collected in the standard course of on-line activity. We use this information to monitor and analyze use of the Service, for their technical administration, to increase their functionality and user-friendliness, and to better tailor them to our visitors’ needs. For example, some of this information is collected so that when you visit the Service again, it will recognize you and serve advertisements and other information appropriate to your interests. We also use this information to verify that visitors to the Service meet the criteria required to process their requests. We do not treat Log Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.
Like many websites and applications, we use “cookies” to collect information. A cookie is a small data file that we transfer to your computer or other device’s hard disk for record-keeping purposes. We use cookies for two purposes. First, we utilize persistent cookies to save your registration ID and login password for future logins to the Service. Second, we utilize session ID cookies to enable certain features of the Service, to better understand how you interact with the Service and to monitor aggregate usage by you and web traffic routing on the Service. Third party advertisers on the Service may also place or read cookies on your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions or functionalities of the Service.
For marketing purposes, Cygnet uses the Google Analytics Demographics and Interest Reporting feature to collect certain visitor information, including, without limitation, age, gender, and interests.
Information collected and reported through this feature never includes personally identifiable information.
If you would like to opt-out of this reporting feature, please change your personal settings on your Ad Settings page and/or download and install Google’s Opt-out Browser Add-on for your web browser.
You can also customize advertisements displayed through the Google Display Network by changing your personal settings in your Ad Settings page. Your Ad Settings page can be accessed through your personal Google account.
As part of the Service, Cygnet Subscribers may be offered the ability to communicate with Cygnet Subscribers and non-registered users through use of their accounts. Where Cygnet Subscribers have selected the option of adding one or more email addresses to an online form, the message they create in the corresponding template will be sent from Cygnet to those email addresses on their behalf. These email addresses will be stored in the address book the Cygnet Subscriber creates and will be used only for the purpose of sending the email communication to the addressee.
Identity theft and the practice currently known as “phishing” are of great concern to Cygnet. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your account ID, login password, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication.
When you download a Cygnet Product and/or register through the Service and submit your Personal Information to create a profile webpage or join the Service, Cygnet Users may see your username and the other information about you (“Required Subscriber Identifiers”). We may display your Personal Information in your profile page and elsewhere on the Service according to the preferences you set in your account. Any information you choose to provide should reflect how much you want other Cygnet Users to know about you. We recommend that you guard your anonymity and sensitive information and we encourage you, as a Cygnet Subscriber, to think carefully about what information you disclose in your profile pages. You can review and revise your profile information at any time. We recommend that you guard your anonymity and sensitive information and that you do not use your real name as your username, since that would allow others to identify you.
Please note that whenever you give out Personal Information in public areas such as on a message board, forum or chat, that information can be collected and used by people you don’t know. While we strive to protect those who wish to participate in these activities, we cannot guarantee the security and privacy of any information that you post in public areas.
We may share aggregated information that includes your Personal Information, Non-Identifying Information and Log Data with third parties for industry analysis and demographic profiling and to deliver targeted advertising to you. We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform tasks, (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Service) or to assist us in analyzing how our Service are used. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. We may also provide Personal Information to our business partners or other trusted entities for the purpose of providing you with information on goods or services we believe will be of interest to you. You can, at any time, submit a request to the issuing party to opt out of receiving such communications.
We may be required to disclose any information about you to government or law enforcement officials or private parties and, if we reasonably believe that it is necessary or appropriate to respond to such claims and legal process (including but not limited to subpoenas), or to protect the property and rights of Cygnet or a third party, or to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity, we may comply with such requirements to disclose.
In the event that we sell or buy any business or assets, we may disclose your Personal Information to the prospective seller or buyer of such business or assets. If Cygnet or substantially all of its assets are acquired by a third party, your Personal Information held by Cygnet will be one of the transferred assets.
You may review, update, correct or delete the Personal Information in your Cygnet Subscriber registration profile by changing the applicable information in your profile page. If you completely delete all such information, then your account may become deactivated. If you would like us to delete your record in our system, please contact us and we will attempt to accommodate your request if we do not have any legal obligation to retain the record. See below for privacy contact information. If you are the legal guardian of a minor, you have the right to request the change or deletion of your ward under your local law but Cygnet may ask for proof that you are, in fact, such legal guardian. To that end, Cygnet may request you to show proof (such as your passport or any other governmental ID) to confirm your identify matches the Personal Information to be changed or deleted. Cygnet may ask you to bear any actual expenses, such as postal fees, incurred by Cygnet for processing your request to disclose, change or delete your Personal Information in its possession. In such case Cygnet will separately inform you in writing.
In accordance with the requirements of the Ordinance, you are also entitled to request access to your personal information held by Cygnet and to correct such information. In this connection, you may direct your request by email to bfb.cs@cygnetify.com
Cygnet is very concerned with safeguarding your Personal information. We employ administrative, physical and electronic measures designed to protect your Personal Information from unauthorized access. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on the Service in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Our Service contains links to other websites. If you choose to visit an advertiser by clicking on a banner ad or other type of advertisement, or click on another third party link, you will be directed to that third party’s website. The fact that we link to a website or present a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer or other device, collect data or solicit Personal Information from you. Other sites follow different rules regarding the use or disclosure of the Personal Information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
The Service is not directed to children under 18. We do not knowingly collect personally identifiable information from children under that age. If we become aware that a child under that age has provided us with Personal Information, we will delete such information from our files.
If you have any questions about this Privacy Policy, please contact us through the following customer inquiries website https://www.cygnetify.com/