Tencent Game Privacy Protection Guidelines
Updated on: May 12, 2020
Became effective on: May 12, 2020
Summary
Thank you for your choice of Tencent game provided by Tencent (hereafter referred to as “we” or “us”; in the Guidelines, “Tencent” refers to Tencent Game and its service provider - Shenzhen Tencent Computer System Co., Ltd. registered at the location of Floor 35, Tencent Building, Ke Ji Zhong 1 Road, Maling Community, Yuehai Sub-district, Nanshan District, Shenzhen; the contact information regarding personal data protection is: Dataprivacy@tencent.com)! In addition to “Tencent Privacy Policy” and “Tencent Game License and Service Agreement”, through the Tencent Game Privacy Protection Guidelines ("Guidelines"), we will further elaborate on how we collect, use, store and share your personal information when you are playing Tencent Game, as well as the relevant rights you are entitled to. The Guidelines are part of the “Tencent Game License and Service Agreement”. The highlights are as follows:
• In order to provide you with game entertainment and to support the related player interaction, consumption and other services, we need to collect information such as your game history, device information, login data and others.
• In order to better protect both the physical and the mental health of minors and facilitate a healthy access to the internet by minors, we may implement more stringent anti-addiction measures in addition to the national regulations on anti-addiction policies of online games. At the same time, we have been constantly developing and testing various new technologies to better protect the minors. For instance, in order to further improve the accuracy of real-name verification and to try best to prevent minors from impersonating the identity of others, we may enable face-recognition verifications in some games or for some users (subject to specific game strategies).
The above-mentioned face-recognition verification mainly compares the user's real face information with the data sourced from the authoritative data platform of the police department. If the comparison results match, the verification is successfully passed, and a proper game time limit would be designated according to the actual category of the user’s age. If the comparison results do not match or the user refuses to go through the verification process, we will deem the user as a minor under 12 years old and enforce the corresponding anti-addiction supervision. The relevant verification data of face-recognition, upon encryption, is only used for comparison with the data from the authoritative data platform of the police department and will not be stored by us.
• You can manage your personal information and the relevant authorizations according to the provisions of the Guidelines.
• We adopt a wide range of security measures to ensure that your personal information is protected under a reasonably safe manner.
By reading the full version of “Tencent Game Privacy Protection Guidelines”, you may learn more about the processing rules of personal information such as the correspondence between the types and the uses of personal information.
1. Information We Collect
While you are using Tencent Game Service, Tencent Game will collect through the following ways the information that you voluntarily provide when using the service or the information generated by your use of the service, in order provide and optimize our services to you and to ensure your account in safe security:
1.1 When you register or use Tencent Game Service, we will collect the information of your network identity and the personal device that you frequently use, in order to mark you as our users. If you use a WeChat, QQ and (or) other account recognized by us (hereafter referred to as “Third-Party Account”) as the game account to login to Tencent Game, we will collect your unique ID, avatar and user name of the WeChat, QQ and Third-Party Account to store your login information so that you can login on different devices.
If you use a WeChat, QQ and (or) Third-Party Account as the game account to login to Tencent Games, in order to provide you with better services and improve your game experiences, we will collect and use your information such as unique identification, nicknames, avatars, friend relationships and other information authorized by you that are involved in your QQ number, WeChat account and Third-party Account, and the related operation information, game information and other information in Tencent Game (including but not limited to, your log-in status, battle information/status, achievement information, etc.) and Tencent may present it to you or other users or your friends. Depending on the specific situations of a game product, we may provide you with the relevant permissions enabling you to adjust the settings as to whether or not to display Such Information.
1.2 In order to comply with the relevant laws, regulations and policies and the requirements of competent authorities, Tencent Game users need to complete the real-name verification before using and enjoying Tencent Game. Upon your consent or by your voluntary provision, we will collect your real-name ID information (including name, ID number, photo, etc.), which is a type of sensitive information. Your refusal to provide your real-name ID information may result in a failure to log into Tencent Game or the corresponding restrictions to your use of Tencent Game.
1.3 In order to ensure your use of our service under normal conditions, to maintain the normal operation of basic functions of the game, to optimize the performance of the game product, to improve your gaming experience and protect the security of your game account, we will collect the information such as your device ID as well as the name, type and version of your device, the version of the system, IP address, MAC address, application ID, network type and other information.
1.4 When you use Tencent Game Service, we will collect your game log information, such as log-in data, item logs, game battle information, friends relation records, etc., so that you can view the records of your game history on your terminal and we can use the above information for analyzing game operation statistics, handling customer service complaints and other game security analyses. Also, to improve the game experience for you, we may synchronize the afore-mentioned information with the later versions of the game or with other products you are using that are provided by us.
1.5 If you use mobile phones of Xiaomi, Meizu, Huawei and other brands, the afore-mentioned mobile phone manufacturers’ Push SKD that Tencent Game is connected to requires collecting the unique identifying information (e.g. IMEI) of the mobile phone, and may collect your mobile phone’s model, system type, system version, screen dimensions of the device and other parameters to enable the pushing of information of Tencent Game products and activities, etc. Please refer to the privacy policies or relevant statements of the SDK’s operators for more detailed information.
1.6 When you use the consumption function of Tencent Game products, we will collect your recharge history, purchase records and other information, so that you can check your transaction records, and at the same time to protect your virtual items to the greatest extent possible. Recharge history and purchase records are sensitive information. It is necessary to collect the above information in order to enable the consumption function of Tencent Game products, otherwise the transaction could not be completed.
1.7 To protect the security of your game account and to create a fair, healthy and safe gaming environment, we will collect information such as your game identity information, hardware and operating system information, processes and breakdown records and other information, for the purposes of fighting against the behaviors that destroy the fair gaming environment or that interfere and disrupt normal game services (such as detecting counterfeits, scanning plug-ins, preventing cheating, etc.).
1.8 When you interact with other players through text, images, voice, video and other means in the game, we may collect and store the above information sent by you, for the purpose of filtering out pornographic, violent, political and abusive contents, malicious advertisements and other improper contents to purify the game environment and maintain a healthy Internet environment.
1.9 If you wish to interact with other game players through voice and video, and to participate in live broadcasting, upon your authorization, Tencent Game will access your microphone and camera to accommodate you with voice chatting, interaction during live broadcasting and other functions.
1.10 If you wish to interact with nearby game players, upon your authorization we will collect the information of your geographic location to search for nearby game players, so that you can match with them or team up with them, etc. Geographic location information is a type of sensitive information. Your refusal to provide this information will only result in your incapability to interact with nearby game players, and will not affect your normal use of other functions provided by Tencent Games. You can also withdraw your authorization for the geographic location information at any time.
1.11 We have enabled a reminder function for moderate time length of playing games. If you use a wearable device, we will, with your consent, collect information such as your heartbeat when you are playing the game, so as to issue a system reminder when you have spent excessive time on the game.
1.12 We may analyze your game data to understand your preference, and we may share your such preference and relevant necessary information to other products and services within the Tencent Group, in order to better show you what you may be of interest within Tencent Games and other products and services within Tencent Group.
1.13 In accordance with relevant laws, regulations and national standards, we may collect and use your personal information in the following situations without obtaining your authorization:
1) where it is directly related to national interests such as national security and national defense security; and directly related to major public interests such as public security, public health, and public knowledge;
2) where it is directly related to criminal investigations, prosecutions, trials and enforcement of judgments, etc.;
3) where it is for protecting the fundamental legal rights of you or other individuals, such as life, property and reputation, but it is also difficult to obtain consent from you or the related individual;
4) where the personal information we collected is disclosed to the public by yourself;
5) where the personal information is collected through legitimate and public channels, such as legitimate news reports, government information disclosure, etc.;
6) where it is necessary to sign and perform the contract according to your requests;
7) where it is necessary to maintain a safe and stable operation of the products or services provided by us, such as the discovering and treating of the malfunctions of such product or service;
8) where it is necessary for legitimate news reporting;
9) where it is necessary to conduct statistical or academic research for public interests; and when externally providing the results of academic research or description, applying de-identification method to the personal information contained in the results; or
10) other circumstances as stipulated by the laws and regulations.
1.14 Please understand that the functions and services we provide to you are constantly updated and developed. If a certain function or service is not included in the above descriptions herein but your information is collected there, we will separately explain to you the content, scope and purpose of such collection through prompts, interaction process, website announcement and other ways in order to obtain your consent.
At present, aside from collecting game research information from third-party research organizations to help us upgrade our game products and provide personalized services, and aside from your use of Third-Party Account to login in Tencent Games prescribed in Section 1.1 herein, we do not take the initiative to obtain your personal information from any third party outside of Tencent Group. In the future, if Tencent needs to obtain your personal information indirectly from a third party outside of Tencent Group and process such personal information, we will strictly comply with the relevant laws and regulations, and we will require the said third party to obtain your consent and to guarantee the legality of the information it provides.
2.Storage of Information
2.1 Manner and Term of Storing Information
We will store your information in a secure manner, including storing it locally (such as data caching via APP), using database and server logs.
In general, we will only store your information for a necessary period for achieving the purpose of providing our services or as required by laws and regulations.
2.2 Territory of Storing Information
Personal information collected within China would be stored within China pursuant to the laws and regulations.
2.3 Termination Notice of the Product or Service
In the event the operation of a product or service is terminated, we will make an announcement in accordance with the relevant laws and regulations, and will protect your legitimate rights and interests.
3.Information Security
3.1 Security Measurements
We strive to protect information security of the users to avoid any information leakage, loss, improper usage, unauthorized access and disclosure, etc. We employ multiple security measures, including technical protection solutions, management system controlling, security system guarantee and others to make sure the user’s personal information is protected in a reasonably secured manner. In addition, the relevant system of our games has passed the examination and made a recordation at the national network security level protection (Level 3).
We adopt leading technical protection measures in the industry. The measures we take include but not limited to firewall, encryption (such as SSL), de-identification or anonymization, access controlling, etc. Further, we will constantly strengthen the security capacity of the software installed in your devices. For example, we will implement part of the encryption work in your devices locally to consolidate a secured transmission; we will collect the information of the applications installed in your devices and its processing information during operation to avoid malicious programs such as virus and Trojan.
We have established special management regulations, procedures and organizations to safeguard the security of the personal information we collected. For example, we will apply strict limitation on the scope of people authorized to access the information, requiring them to obey confidential obligations and conducting audits. Those who violates such obligations will be punished in accordance with the regulations. We will also review the management regulations, procedures and organizations to prevent unauthorized access, use or disclosure of the users’ information by those people that are without authorization.
We suggest you give full attention to the protection of personal information when using the products and services, and we will also provide multiple security methods to assist you to protect the security of your personal information.
3.2 Dealing with Security Incident
If any security incident such as the leak of personal information occurs, we will initiate the emergency plan to prevent it from expanding. Upon the occurrence of such incident, we will inform you the basic situation of the security incident, the treatment measures and remedies we will take or have taken as well as our advices for you, via announcements, push notifications or emails, etc. If it is difficult to inform every user, we will issue the warning through public announcements.
4.How We Use the Information
We will strictly obey the laws, regulations and the agreement with our users, and we will make use of the collected information in accordance with the Guidelines, "Tencent Game License and Service Agreement" and "Tencent Privacy Policy"so as to provide you with better service.
4.1 Rules for Using Information
We will use the collected information in accordance with the following rules:
1) based on the information we collected, we will provide you with multiple functions and services, including the general gaming functions, interactive functions between players, live broadcasting functions as well as consumption functions;
2) we will analyze the operation of our products based on the frequency and situations of your use of Tencent Game, malfunction information and performance information, etc., so as to ensure a safe provision of our services, and to optimize our products and improve the quality of our services. We will not combine your personal information with the information we stored in the analysis software.
4.2 The Way to Seek Consent after Informing the Purpose of Changing
We will use the collected information within the scope included in the Guidelines. If we use your personal information beyond the scope and a direct or reasonably relevant scope, of purpose we claimed when collecting the information we will again inform you and seek your express consent before using your personal information.
5.Provide to Other Entities
Currently, except for the conditions provided in the Guidelines and “Tencent Game License and Service Agreement”, we will not actively share, provide or transfer your personal information to any other third party outside of Tencent Group. In the event we share, provide or transfer your personal information or you need us to share, provide or transfer your personal information to a third party outside of Tencent Group, we will directly ask for your express approval or confirm that the third party has obtained your express approval.
Notwithstanding the above paragraph, if you use overseas games which are licensed to us, we might provide your log-in information and relevant information (such as log-in data, item logs, etc.) generated in the game to the overseas developer entities or relevant third parties for the purpose of conducting security analysis, and helping to improve game services and further optimize users’ experience in game. In addition, we will try to contact the guardian after a person that is suspected to be a minor has made consumption, and inform the guardian of the consumption records and other information to remind the guardian to confirm and handle this issue.
Except as otherwise provided in the Guidelines, “Tencent Game License and Service Agreement” and “Tencent Privacy Policy”, we will not publicly disclose the information we collect. If a disclosure is necessary, we will inform you about the purpose of the disclosure, the type of the disclosed information and the sensitive information that may be involved, and we will also obtain your express approval.
As our business continuously develops, we are likely to conduct transactions such as mergers, acquisitions and asset transfers, etc. We will inform you of the information and continue or require the new controllers to continue to protect your personal information in accordance with the laws and regulations and the standards no lower than the requirements of the Guidelines.
In addition, in accordance with relevant laws, regulations and national standards, we may share, transfer, or publicly disclose personal information without your prior authorization and approval in the following situations:
1) where it is directly related to the national security and national defense security;
2) where it is directly related to public security, public health or major public interests;
3) where it is directly related to criminal investigation, prosecution, trial and enforcement of judgments;
4) where it is for protecting the material legal rights and interests such as life, property and others of the personal information holder or other individuals but it is also difficult to obtain consent from the involved person;
5) where the personal information holder publicly discloses personal information by himself/herself; or
6) where the personal information is collected through legitimate and publicly channels, such as legitimate news reports, government information disclosure, etc.
6.Your Rights
During the time you use Tencent Game Service, we may provide you with the corresponding operation settings based on the specific situation of the game products, so that you can search, delete, change or withdraw your relevant personal information. You can refer to the specific instructions of the corresponding game products to guide your operation. In addition, we have set up the channel to receive complaints and reports, and your opinion will be dealt with in a timely manner.
7.Amendments
We may amend the Guidelines as appropriate. When the provisions of the Guidelines have been amended, we will inform you of the amended Guidelines in a proper way at the time of version update. Please read the amended Guidelines or the content carefully. Your continuous use of Tencent Game would be deemed as your approval for us to collect, deal with or use your personal information in accordance with the updated Guidelines.
8.Protection of Minors
We attach great importance to the protection of minors’ personal information, and we will keep exploring new ways to protect minors’ personal information.
We will protect the legitimate rights and interests of minors by initiating anti-addiction system in accordance with national regulations on online game anti-addiction policies. We will make a judgment on whether the real name information of an account belongs to a minor via the identification result of information such as real-name identity, based on which we decide whether the account shall be included in the anti-addiction system. In addition, we will collect information such as your login time, length of playing games, etc., and guide the minors to play games rationally through ways such as automatically intervening and limiting the game duration of the minors in our system, enabling the function of mandatorily exiting the game, etc. When the consumption is conducted by a person suspected to be a minor, we will then try to contact his or her guardian for reminders, confirmations and deposition, so as to help the minors have a healthy access to the Internet.
At the same time, in order to better protect both the physical and mental health of minors and facilitate a healthy access to the Internet for them, we may employ stricter anti-addiction measures on the basis of national anti-addiction policies related to online games. Further, we will keep conducting researches and testing various technologies to protect the minors. For example, in order to further improve the accuracy of real-name verification on identities and to try best to prevent minors from impersonating the identity of others, we may enable face-recognition verifications (if face-recognition verifications are enabled, we will use the face-recognition function provided by WeChat or QQ to provide your relevant real-name ID information to WeChat or QQ for face-recognition) in some games or for some users (subject to specific game strategies) under specific situations (for example, when you log into a game, or when you top up, purchase or make transactions during the game).
The above-mentioned face-recognition verification mainly compares the user's real face information with the data sourced from the authoritative data platform of the police department. If the comparison results match, the verification is successfully passed, and a proper game time limit would be designated according to the actual category of the user’s age. If the comparison results do not match or the user refuses to go through the verification process, we will deem the user as a minor under 12 years old and enforce the corresponding anti-addiction supervision. The relevant verification data of face recognition, upon encryption, is only used for comparison with the data from the authoritative data platform of the police department and will not be stored by us.
Besides, we may also collect your game behavior data generated during the game (for example, the data such as the click pressure and radius, the relative position of the click, the acceleration direction, and the direction of gravity formed when you operate the game on the terminal device, and the voice data generated when you interact with other players through online voice in the game) to preliminarily determine whether the user is a minor (regarding the voice data, the system will only randomly use some of your online voice to judge whether it is from a child or an adult). If the preliminary determination shows you are a minor, we may enable the face-recognition verification in accordance with the foregoing prescriptions.
In addition, we have also established a platform for child growth and guardian. The platform can help parents or guardians keep track of their children's gaming activities, set up consumption limits and the duration and the time of playing games each day to assist parents or guardians of minors to protect minors from unhealthy game habits. You can click here to learn more about the introduction of Tencent Game’s anti-addiction system and the Platform for Child Growth and Guardian. At the same time, we have also established an active service platform for the minors. When the consumption is conducted by a person suspected to be a minor, we will then try to contact his or her guardian for reminders, confirmations and deposition. You can contact us through the minor education advisory hotline 0755-83761852.
If you are the legal guardian of a minor, please pay attention to whether the minor uses Tencent Game Service or provides his or her personal information after obtaining your authorization and approval. If you have questions about the personal information of the minor under your guardian, please contact us through the contact details provided in Section 10 herein.
Particularly, if you are a minor under 14 years old, we also published “Tencent Game Privacy Protection Guidelines for Children” on October 1, 2019 to protect children’s personal information. Before using Tencent Game Service, both the minor and his/her legal guardian shall read “Tencent Game Privacy Protection Guidelines for Children” carefully. Only with your legal guardian’s consent to “Tencent Game Privacy Protection Guidelines for Children”, shall you be able to use Tencent Game Service.
9.Others
“Tencent Privacy Policy”is a general privacy policy uniformly applied by Tencent. The contents specified in it, including but not limited to user rights and information security measures, etc., are all applicable to the users of Tencent Game. If there is any inconsistency or contradiction between Tencent Privacy Policy and the Guidelines, the Guidelines shall prevail.
“Tencent Game Privacy Policy Guidelines for Children” are personal information protection specifications that shall be applied to the users who are minors under 14 years old. Within the range of “Tencent Game Privacy Policy Guidelines for Children”, if there is any inconsistency or contradiction with Tencent Privacy Policy and the Guidelines, “Tencent Game Privacy Policy Guidelines for Children” shall prevail.
In case of any discrepancy or dispute between the Chinese version and the English version of the Guidelines, the Chinese version shall prevail. You may find the Chinese version via: http://game.qq.com/privacy_guide.shtml
10.Contact Us
When you have other complaints, suggestions, or questions regarding personal information of minors, please contact us via http://kf.qq.com/ . You can also send your questions to Dataprivacy@tencent.com or mail to the following address:
Data and Privacy Center, Legal Department, Tencent Binhai Building, No. 33, Haitian 2 Road, Nanshan District, Shenzhen, Guangdong Province, P. R. China
Zip Code: 518054
We will review the relevant questions as soon as possible, and will respond within 15 days upon verifying your user identity.
Tencent Game Privacy Protection Guidelines for Children
Updated on: May 12, 2020
Became effective on: May 12, 2020
Thank you for choosing Tencent game provided by Tencent (hereafter referred to as “we” or “us”. In the Guidelines, Tencent specifically refers to Tencent Game and its service provider - Shenzhen Tencent Computer System Co., Ltd. registered at the location of Floor 35, Tencent Building, Ke Ji Zhong 1 Road, Maling Community, Yuehai Sub-district, Nanshan District, Shenzhen; the contact information regarding personal information protection is: dataprivacy-kids@tencent.com)! In addition to “Tencent Privacy Policy”, “Tencent Game License and Service Agreement” and “Tencent Game Privacy Protection Guidelines”, through this Tencent Privacy Protection Guidelines for Children (“Children’s Guidelines”), we will further help you and your child (“child” or “Children” shall refer to minors under 14 years old in the Children’s Guidelines) understand how we collect, use, store and share your child’s personal information, as well as the relevant rights you and your child are entitled to.
[Important Note]:
The Children’s Guidelines shall be applied to the processing of personal information of minors under 14 years old. As for you and users above 14 years old, please refer to “Tencent Privacy Policy” and “Tencent Game Privacy Protection Guidelines” for more information. We will explain to you the collection of children’s personal information through prompts, interaction processes, website announcements and other ways and obtain your consent. Please carefully read and fully understand “Tencent Privacy Policy”, “Tencent Game Privacy Protection Guidelines” and the Children’s Guidelines, before choosing to agree the afore-mentioned privacy policies.
1. Children’s Personal Information We Collect
While your child is using Tencent Game Service, Tencent game will only collect your child’s information upon your consent or by you and your child’s voluntary provision, in order to provide and optimize our services to your child and to ensure your child’s account in safe security. For the details of your child’s personal information we might collect, please refer to “Tencent Game Privacy Protection Guidelines”.
Also, in order to verify your custody relationship with your child, we might collect your contact information (including phone number, email address) and other information to help us judge the existence of custody relationship. At present, aside from collecting game research information from third-party research organizations to help us upgrade our game products and provide personalized services, we do not take the initiative to obtain your child’s personal information from any third party outside of Tencent Group. In the future, if Tencent needs to obtain your child’s personal information indirectly from a third party outside of Tencent Group, we will strictly comply with the relevant laws and regulations and require the said third party to guarantee the legality of the information it provides.
2. How We Use Children’s Personal Information
We will strictly obey the laws, regulations and the agreement with our users, and we will make use of the collected information in accordance with the Children's Guidelines, "Tencent Game License and Service Agreement", "Tencent Privacy Policy" and “Tencent Game Privacy Protection Guidelines” so as to provide your child with better service.
Please refer to “Tencent Game Privacy Protection Guidelines” for more details about how we use children’s personal information. If we use your child’s personal information beyond the scope, or a direct or reasonably relevant scope, of the purpose we claimed when collecting that information, we will inform you once again and seek your express consent before using your child’s personal information.
3. Storage of Children’s Personal Information
3.1 In accordance with laws and regulations, we will store your child’s personal information collected from China within the territory and strictly keep that information confidential. If we need to transmit personal information collected within China to overseas institutions for the sake of cross-border business, we will protect your child’s personal information pursuant to domestic laws, administrative regulations and competent authorities’ specifications.
3.2 In general, we will only store your child’s information for a necessary period for achieving the purpose of providing our services or as required by laws and regulations. After the period specified by laws or competent authorities has expired, we will delete or anonymize your child's personal information in accordance with the requirements of laws and regulations.
4. Security of Children’s Personal Information
4.1 In order to ensure the safety of your child’s personal information, we will take reasonable and necessary measures under the current level of technology to protect children’s information, and adopt measures of physical protection, security technology, management systems and so forth to reduce the risk of information loss, improper usage, unauthorized access, disclosure and alteration, including but not limited to, encrypted data transmission, firewalls and encrypted storage, physical access control, and information access authorization control. For this purpose, we have set up security procedures to protect your child's information from being stolen via unauthorized access. All personal information is encrypted and stored , and placed in an internal system strictly protected by the firewall.
4.2 We have established special management regulations, procedures and organizations to safeguard the security of your child’s personal information. For example, we will strictly limit the scope of people that are authorized to access the information, requiring them to comply with confidential obligations and conducting audits.
4.3 If any security incident such as the leak of children’s personal information occurs, we will initiate the emergency plan to prevent it from expanding and inform you the basic situation of the security incident, the treatment measures and remedies we will take or have taken as well as our advices for you via announcements, push notifications or emails, etc. in a timely manner. If it is difficult to inform every user, we will issue the warning through public announcements and other methods.
5. Rectification of Children’s Personal Information
If you and your child find there is any mistake regarding the child’s personal information, you may contact us for rectification.
6. Deletion of Children’s Personal Information
6.1 If you and your child find we process children’s personal information against the requirements of laws, administrative regulations or our agreement, or beyond the purpose scope or the necessary period, you may contact us to delete relevant personal information.
6.2 If you withdraw your consent, you may contact us and we will deal with it pursuant to relevant laws and regulations.
6.3 If you and your child take the initiative to cancel the Tencent game account and terminate the use of Tencent game, we will stop using relevant child's personal information, except as otherwise required by laws, regulations or competent authorities. If we plan to cease any operation of products or services, we will notify you in accordance with relevant laws and regulations.; in the meantime, we will stop using children's personal information in a timely manner and delete or anonymize the stored information.
7. Transfer and Delegation of Children’s Personal Information
Generally, we will not transfer to or delegate any third party to process children’s personal information. In the case where we have to do so, we will take compliance measures according to laws and regulations, including but not limited to conduct a security assessment on the third party.
8. Disclosure of Children’s Personal Information
Unless otherwise required by laws, administrative regulations or pursuant to our agreement, we will not disclose children’s personal information.
9. Amendments
We may amend the Guidelines as appropriate. When the provisions of the Guidelines have been amended, we will inform you of the amended Guidelines in a proper way at the time of version update. Please read the amended Guidelines or the content of it carefully. Your child’s continuous use of Tencent Game would be deemed as your approval for us to collect, deal with or use your child’s personal information in accordance with the updated Guidelines.
10. Others
“Tencent Privacy Policy” and “Tencent Game Privacy Protection Guidelines” are general privacy policies uniformly applied in Tencent Game. The contents specified therein, including but not limited to user rights and information security protection measures, etc., are all applicable to the users of Tencent Game. The Children’s Guidelines are privacy protection guidelines designed for children, which include special protection of children’s personal information. If there is any inconsistency or contradiction between the Children’s Guidelines and “Tencent Privacy Policy” or “Tencent Game Privacy Protection Guidelines”, the Children’s Guidelines shall prevail.
11. Contact Us
When you and your child have any questions to the Children’s Guidelines, or any relevant complaints, suggestions, or requests, please contact us via http://kf.qq.com/. You and your child can also send your questions to dataprivacy-kids@tencent.com or mail to the following address: Data and Privacy Center, Legal Department, Tencent Binhai Building, No. 33 Haitian 2 Road, Nanshan District, Shenzhen, Guangdong Province, P. R. China Zip Code: 518054. We will review the issues involved as soon as possible, and handle them promptly after verifying your identity, and reply within a maximum of fifteen days or within the period prescribed by laws and regulations.