Tencent Game Privacy Protection Guidelines
Updated on：May 20, 2019
Became effective on：May 20, 2019
• 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 using 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 this Guideline.
• 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 or QQ account to log into Tencent Game, we will collect your unique ID, avatar and user name of the WeChat or QQ account to store your login information so that you can login on different devices.
In order to provide you with better services and improve your game experiences, we may use your information such as nicknames and avatars of your QQ account, WeChat account or game account, and the related operation information, game information and other information in Tencent Game (hereinafter referred to as "Such Information”, including but not limited to, your log-in status, battle information/status, achievement information, etc.) and Tencent may present Such Information 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. 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 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 require 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 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 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 those personal information we collected is disclosed to the public by yourself;
5) where those 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.
1.13 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 therethrough, we will 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, 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, we will expressly inform you the source, type and scope of use of your personal information prior to our obtaining of it. If the activities of processing personal information carried out by Tencent Game for the need of operating its businesses exceed the original scope of your authorization to the third party outside of Tencent Group when you provide your personal information, we will obtain your express consent before any further process of your personal information. In addition, 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.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.
3.1 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
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 provide you with personalized service based on your features such as game level, preference, habits and consumption, etc., including creating indirect crowd portraits based on your feature tags and recommending to you some “may-be-interested” contents such as activities, competition, promotion, etc.;
3) 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 Rules for Directed Promotions
We will send out personalized promoting contents based on your features such as your game level, preference, habits and consumption, etc., for example, recommending you the skin you might like in a game. Depending on the specific situations of the game product, we will provide you with relevant permissions enabling you to reduce the relevance between you and the recommended contents or quit such personalized promotions.
4.3 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 of purpose we claimed when collecting those information or a direct or reasonably relevant scope, we will again inform you and seek your express consent before using your personal information.
5.Provide to other Entities
Notwithstanding the above paragraph, if the developer of the Tencent Game you use is an overseas entity, we might provide your records or log information (such as log-in logs, item logs, etc.) generated in the game to the overseas game developers for the purpose of conducting game operation statistics and analysis, handling the complaint about customer service and other game security analysis to help developers 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.
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 those personal information is collected through legitimate and publicly channels, such as legitimate news reports, government information disclosure, etc.
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.
Note: Currently there is no independent account in the games that we provide; instead, those games require using related QQ account or WeChat account to log in as the game account. If you want to cancel the game account, you need to cancel the related QQ account or WeChat account. Please follow the references on WeChat and QQ for cancelling the QQ account and WeChat account.
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 identity 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 maintain a healthy Internet environment for the minors.
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 focusing on conducting researches and tests 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 using 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.
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 limits for 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.
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
When you have other complaints, suggestions, or questions regarding personal information of minors, please contact us viahttp://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 Building, Kejizhongyi Avenue, Nanshan District, Shenzhen, Guangdong Province, P. R. China
Zip Code: 518057
We will review the relevant questions as soon as possible, and will respond within 15 days upon verifying your user identity.