Privacy Policy

Last updated: {{EFFECTIVE_DATE e.g. 2026-11-01}}

DRAFT TEMPLATE — to be reviewed by a Hong Kong lawyer before launch. Text in {{…}} must be filled in by the operator; do not treat placeholders as confirmed facts.

{{COMPANY_LEGAL_NAME}} ("we") respects your privacy. This policy explains what we collect and how we use it, in line with the Hong Kong Personal Data (Privacy) Ordinance (PDPO), the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and the Malaysian Personal Data Protection Act 2010 (Act 709).

What we collect

• Account data: email address and hashed password.
• Order data: game user ID (UID), server / zone / region, nickname (if verified), items purchased, amounts, payment method type, delivery status.
• Technical data: IP address, device and browser information, essential cookies (language, currency, session, referral).

We do not collect or store your full card number or e-wallet PIN; card and wallet payments are handled by our payment service providers ({{PSP_NAMES e.g. Stripe / PayMongo / Xendit}}).

Why we use it

• To create and manage your account, deliver your order and send receipts.
• Fraud prevention, risk checks and chargeback defence.
• Customer support and legal / accounting obligations.

Who we share it with

• Payment service providers ({{PSP_NAMES e.g. Stripe / PayMongo / Xendit}}).
• Authorised product suppliers / distributors ({{SUPPLIER_NAMES e.g. UniPin}}) — only the game ID, server and SKU needed to deliver.
• Fraud-prevention and email service providers.
• Authorities where required by law.

We do not sell your personal data.

Cookies

We use essential cookies for login sessions and preferences (language, currency, referral). {{ANALYTICS_COOKIES_IF_ANY e.g. We use Google Analytics. / leave empty if none}}

International transfers

Our company is based in Hong Kong. Data may be processed by service providers in other jurisdictions (for example payment or email providers). We take reasonable steps to protect data in transit and at rest.

Retention and your rights

Order records are kept for {{RETENTION_YEARS e.g. 7}} years for accounting and dispute purposes. Under the PDPO / Philippine DPA / Malaysia PDPA you may request access to or correction of your personal data, and (where applicable) object to certain processing, by emailing {{SUPPORT_EMAIL}}. We will respond within a reasonable time.

Children

Our services are not directed at children under 13. Users under 18 need parental consent.

Contact

Data protection enquiries: {{SUPPORT_EMAIL}}. Registered address: {{REGISTERED_ADDRESS_HK}}.