Effective Date: March 31, 2023

This Privacy Policy (“Policy”) describes the manner in which Zaidengdeng Holdings HK Limited (“MageCosmos”, “we,” or “us”) collect, use, and disclose Personal Information about you through our website at https://www.magecosmos.live/ (our “Site”), along with our related websites, networks, VR headset applications (each, a “VR Client” and together with any Desktop Clients, “Clients”), software development kits for use in connection with any technology or services made available by or on behalf of MageCosmos (each, an “SDK”), and other services provided by us and on which a link to this Policy is displayed (collectively, including any Clients and SDKs, the “Platform”). This Policy is incorporated into and is subject to the MageCosmos Terms of Service. By using the Platform, you consent to the collection, use, and disclosure of your Personal Information as described in this Policy. “Personal Information” means any information relating to an identified or identifiable individual.

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1. Personal Information We Process

We may collect a variety of Personal Information from or about you or your devices from various sources, as described below. Where required by applicable law, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so.

Personal Information You Provide to Us

When you use the Platform, we may collect or you may provide Personal Information about you and we may link this Personal Information with other Personal Information about you. You may provide us with Personal Information in various ways on the Platform:

Registration and Account Information. If you sign up for an account on our Platform, we collect Personal Information related to its creation and the usage of our Platform via this account. We will ask you to provide your email address and birthday, and allow you to create a username and password.

Payment and Billing Information. If you choose to access or use parts of the Platform that require payments or fees, we may require you to provide Personal Information to use for the purposes of processing those payments. We may provide your Personal Information to third-party payment processors who process transactions on our behalf. We may also collect and retain Personal Information relating to the transactions you conduct on the Platform.

Communications. If you contact us directly, we may receive additional information about you. For example, when you contact us with an inquiry or to receive customer support, we will receive your name, email address, and the contents of the message you send to us, and other information you choose to provide.

Newsletters. If you sign up to receive emails or information about our Platform, then we will collect Personal Information from you, such as your first and last name, email address, and your areas of interest. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Platform.

Careers. If you apply for a job with us directly, you may provide us with your resume, name and contact details, and any other information that you provide to us. If you apply for a job with us through a third-party platform (such as LinkedIn or Lever), we will collect the information you make available to us through such a third-party platform.

Personal Information We Collect When You Use Our Platform

Usage Information. When using the Platform, including participation in different “rooms” made available to users of our Platform, you may disclose Personal Information to us and to other users of the Platform. This may occur when you engage in conversations, chats, or other user-to-user interactions. We may collect and use this information to the extent permitted by law.

Information Collected via Automated Means

Information from Cookies and Similar Technologies. When you use the Platform, we may send one or more cookies – small text files containing a string of alphanumeric characters – to your device. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Platform. We may also automatically record certain information from your device by using various types of technology, including “tracking pixels" or “web beacons.”

The information we collect via such cookies and similar technologies (“Cookies”) may include your IP address or other device address or ID, web browser and/or device type, the web pages or sites that you visit just before or just after you use the Platform, the pages or other content you view or otherwise interact with on the Platform, your mouse movements on the Platform (for security purposes), the dates and times that you visit, access, or use the Platform, and the duration of such visits, access, or use. We also may use these technologies to collect information regarding your interaction with email messages, such as whether you opened, clicked on, or forwarded a message. This information may be gathered from all users and may be connected with other information about you.

We may also display third-party content on the Platform. Third-party content may use cookies, web beacons, or other mechanisms for obtaining data in connection with your viewing of the third-party content on the Platform. Additionally, we may implement third-party buttons (such as Facebook “like” or “share” buttons) that may function as web beacons even when you do not interact with the button. Information collected through third-party web beacons and buttons is collected directly by these third parties, not by MageCosmos. Information collected by a third party in this manner is subject to that third party’s own data collection, use, and disclosure policies. Below is an overview of the types of Cookies we may use:

• Functional Cookies. These Cookies are necessary for the Platform to operate. Without these Cookies, we may not be able to provide you with certain website functionalities.

• Analytical Cookies. We use Cookies for analytics purposes in order to operate, maintain and improve our Platform.

Please note that if you delete, or choose not to accept, Cookies from the Platform, you may not be able to utilize the features of the Platform to their fullest potential. As there is no accepted standard on how to respond to “do not track” signals, MageCosmos does not process or respond to web browsers’ “do not track” signals or other similar transmissions that indicate a request to disable online tracking of users who use our Platform.

Location Information. We may use your IP address to obtain general information about the physical location from which you are connecting to the Internet.

Personal Information We Receive From Third Parties.

Our partners. We may receive additional Personal Information about you from third parties such as analytics partners, vendors providing additional information on your IP address (i.e., approximate location), gaming infrastructure and platform providers, social networks and advertisers. Such additional information includes additional IP address information, additional information about your device and connected social media account details. We may combine this information with other Personal Information we have about you.

Fraud Prevention & Anti-Cheat Information

We aim to provide users with a positive user experience on the Platform by minimizing abuse of MageCosmos or other users on the Platform. We strictly enforce prohibitions against cheating, hacking, account stealing and any other unauthorized or fraudulent activity on the Platform. We use a variety of anti-cheat and fraud prevention technologies to help us identify and prevent malicious activity. These services may collect and analyze data about your computer and the software on your computer to detect cheating and misuse of the Platform. For example, these services may monitor your gameplay and device’s RAM, processes, communications, and file storage and otherwise detect the use of “modified clients.”

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2. How We Use the Information We Collect

We collect, use and disclose Personal Information for the following purposes:

• Providing the Platform. We may use your Personal Information to operate, maintain and provide our Platform, including to facilitate transactions and payments, and ensure content moderation on the Platform.

• Customer support. We may use your Personal Information to provide support to users.

• Analytics and product development. We may use your Personal Information to assess the effectiveness of the Platform, analyze usage trends and preferences, to improve our Platform, as well as to develop new products, services, features, and functionalities.

• Marketing. We may use your Personal Information for marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you.

• Personalization. We may use your Personal Information to personalize our Platform, such as remembering information about you so that you will not have to re-enter it during your visit or the next time you visit the Platform and providing customized content.

• Communicating with you. We may use your contact details to contact you for administrative purposes (e.g., to provide services and information that you request or to respond to comments and questions).

• Jobs. We may use your Personal Information to process your job application.

• Legal. We may use your Personal Information for compliance purposes, including to enforce this Policy or our Terms of Service, to defend our legal rights, to comply with our legal obligations and internal policies, and as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

• Safety and security. We may use your Personal Information to find and prevent fraud, abuse, and cheating on the Platform, to secure the Platform, and to respond to trust and safety issues that may arise.

• Other purposes. We may also use Personal Information for other purposes for which we provide specific notice at the time the Personal Information is collected.

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3. Legal Bases for Processing European Personal Information

If you are located in the European Economic Area (“EEA”) or the United Kingdom (together, “Europe”), we only process your Personal Information when we have a valid “legal basis,” including as set forth below.

• Consent. You have consented to the use of your Personal Information, for example when you consent to receive electronic marketing communications or when you consent to the use of Cookies.

• Contract. We need your Personal Information to provide you with our Platform. For example, we may need to process your Personal Information to respond to your inquiries or requests.

• Compliance with a Legal Obligation. We have a legal obligation to use your Personal Information, for example to comply with tax and accounting obligations.

• Legitimate Interests. We or a third party have a legitimate interest in using your Personal Information. Specifically, we have a legitimate interest in using your Personal Information for product development and internal analytics purposes, and to improve the safety, security, and performance of our Platform. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.

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4. When We Disclose Personal Information

We may disclose Personal Information to third parties if you consent to us doing so, as well as in the following circumstances:

• Vendors and Service Providers. We work with third-party service providers who provide website, application development, hosting, payment, maintenance, marketing, advertising and other services in connection with the provision of our Platform. These third parties may have access to or process Personal Information about you as part of providing those services for us.

• Analytics Providers. We use analytics providers who help us understand how our Platform is used.

• Other Users. When using our Platform, you may disclose Personal Information to other users of the Platform via conversations, chats, or other user-to-user interactions.

• As Required By Law and Similar Disclosures. We may disclose Personal Information about you if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws, in response to a court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.

• To Enforce Legal Claims. We also reserve the right to disclose Personal Information about you that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Platform and any facilities or equipment used to make the Platform available, or (v) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.

• Merger, Sale, or Other Asset Transfers. Personal Information may be disclosed and otherwise transferred to an acquirer, successor, or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, or in the event of an insolvency, bankruptcy, or receivership in which Personal Information is transferred to one or more third parties as one of our business assets.

• Aggregate Data. We may make certain aggregate or otherwise anonymized information available to third parties for various purposes, including compliance with various reporting obligations, unless we are prohibited from doing so under applicable law

• Business Partners. We may share Personal Information with our business partners, including for the purposes of sales, marketing, recruiting and other related purposes.

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5. Your Rights and Choices

You may, of course, decline to share certain Personal Information with us, in which case we may not be able to provide to you some of the features and functionality of the Platform. You may update your profile information through the Platform. If you wish to access, update, delete or amend any other Personal Information we hold about you, you may contact us at bd@magecosmos.com. Please note that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain Personal Information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so, to the extent permitted under applicable law.

Marketing. If you receive commercial email from us, you may unsubscribe at any time by following the instructions contained within the email. You may also opt out from receiving commercial email from us by sending your request to us by email at bd@magecosmos.com. We may allow you to view and modify settings relating to the nature and frequency of promotional communications that you receive from us in user account functionality on the Platform.

Please be aware that if you opt out of receiving commercial email from us or otherwise modify the nature or frequency of promotional communications you receive from us, it may take up to ten business days for us to process your request, and you may continue receiving promotional communications from us during that period. Additionally, even after you opt out from receiving commercial messages from us, you will continue to receive administrative messages from us regarding the Platform.

Your European Privacy Rights. If you are located in Europe, you have the additional rights described below:

• You may request access to the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, restrict or object to the processing of your Personal Information, have your Personal Information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Information to another company. In addition, you also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work or where an incident took place.

• You may withdraw any consent you previously provided to us regarding the processing of your Personal Information at any time and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.

The above rights may be limited under applicable law. Before fulfilling your request, we may ask you to provide reasonable information to verify your identity.

Residents of California may have additional rights – please see the California Resident Privacy Notice at the end of this Policy for more information.

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6. Third-Party Services

The Platform may contain features or links to websites and services provided by third parties. Any Personal Information you provide on third-party sites or services is provided directly to the operators of such services and is subject to those operators’ policies, if any, governing privacy and security, even if accessed through the Platform. We are not responsible for the content or privacy and security practices and policies of third-party sites or services to which links or access are provided through the Platform. We encourage you to learn about third parties’ privacy and security policies before providing them with Personal Information.

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7. Children’s Privacy

Our Site is a general audience site not directed to children under the age of 13, and we do not knowingly collect Personal Information from children. If you become aware that your child or any child under your care has provided us with Personal Information without your consent, please contact us at the contact information listed below in the section “How to Contact Us” and we will delete any such account or profile and associated Personal Information.

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8. Data Security

We use certain physical, managerial, and technical safeguards that are designed to improve the integrity and security of Personal Information that we collect and maintain. Please be aware that no security measures are perfect or impenetrable. We cannot and do not guarantee that Personal Information about you will not be accessed, viewed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

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9. Retention

We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when your Personal Information is no longer necessary for the purposes for which we process it unless we are required by law to keep your Personal Information for a longer period. When determining the specific retention period, we consider various factors, such as the type of service provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and the statute of limitations.

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10. International Visitors

The Platform is hosted in HK. If you choose to use the Platform from Europe or other regions of the world with laws governing data collection and use that may differ from H.K. law, then please note that your Personal Information is processed and stored outside of those regions, in particular in HK. Also, we may transfer your data from HK to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Platform. By providing any information, including Personal Information, on or to the Platform, you agree with such transfer, storage, and processing.

If you are located in Europe, we will comply with applicable European data protection laws when transferring your Personal Information outside of Europe. We may transfer your Personal Information to countries which have been found to provide adequate protection by the EU Commission or the UK government, to recipients who use contractual protections for the transfer of Personal Information, or to recipients who have adopted Binding Corporate Rules. We may also rely on an appropriate legal derogation.

For more information about how we transfer outside of Europe, or to obtain a copy of the contractual safeguards we use for such transfers, you may contact us using the contact details as indicated in the “How to Contact Us” section below.

 

11. Changes and Updates to this Policy

Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify this Policy, we will make it available through the Platform, and indicate the effective date. In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access the Platform for the first time after such material changes are made. Your continued use of the Platform after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of this Policy.

 

12. How to Contact Us

Zaidengdeng Holdings HK Limited is the entity responsible for the processing of your Personal Information. Please contact us with any questions or comments about this Policy, Personal Information we have collected or otherwise obtained about you, our use and disclosure practices, or your consent choices by email at bd@magecosmos.com.

 

California Resident Privacy Notice

This California Resident Privacy Notice supplements the information and disclosures contained in our Privacy Policy. It applies to individuals residing in California from whom we collect Personal Information as a business under the CCPA (as defined below).

For the purposes of this California Resident Privacy Notice, Personal Information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the California Consumer Privacy Act of 2018 (California Civil Code §§ 1798.100 to 1798.199) and its implementing regulations, as amended or superseded from time to time (“CCPA”). Personal Information does not include information that is:

• Lawfully made available from government records.

• Deidentified or aggregated.

• Otherwise excluded from the scope of the CCPA.

• The chart below provides the categories of Personal Information (as defined by the CCPA) we have collected, disclosed for a business purpose, or sold in the preceding twelve months since this notice was last updated. The examples of Personal Information provided for each category reflect each category’s statutory definition and may not reflect all of the specific types of Personal Information associated with each category.

Category：

A. Identifiers

Examples: Name, unique personal identifier, online identifier, internet protocol address, email address.

B. Categories of Personal Information in Cal. Civ. Code Section 1798.80(e)

Examples: Name, telephone number, financial information.

C. Characteristics of Protected Classifications under California or Federal Law

D. Commercial Information

Examples: Records of services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

E. Biometric Information

F. Internet or Other Electronic Network Activity Information

Examples: Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application or advertisement.

G. Geolocation Data

H. Sensory Information

I. Professional or employment-related information

J. Non-Public Education Information (as defined in 20 U.S.C. 1232g; 34 C.F.R. Part 99)

K. Inferences Drawn from Personal Information

Examples: Consumer profiles reflecting a consumer’s preferences.

As listed above:

We Collect：A/B/D/F/K

We Disclose: A/B/D/F/K

We Sell: None

We have not sold any California resident’s Personal Information.

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Use of Personal Information

We collect, use, and disclose your Personal Information in accordance with the specific business and commercial purposes below:

1. Providing Services: Providing our services.

2. Communicating: Communicating with you, providing you with updates and other information relating to our services, providing information that you request, responding to comments and questions, and otherwise providing customer support.

3. Marketing: Marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable or otherwise of interest to you.

4. Personalization: Personalizing your experience on our services such as presenting tailored content.

5. Facilitating Payments: Facilitating transactions and payments.

6. De-identification and Aggregation: De-identifying and aggregating information collected through our services and using it for any lawful purpose.

7. Safety Issues: Responding to trust and safety issues that may arise.

8. Compliance: For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency.

9. Fraud and Incident Prevention: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.

10. Debugging: Debugging to identify and repair errors that impair existing intended functionality.

11. Transient Use: Short-term, transient use.

12. Contracting Vendors: Contracting with service providers to perform services on our behalf or on their behalf, including maintaining or servicing accounts, providing customer service, processing or fulfilling transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.

13. Research: Undertaking internal research for technological development and demonstration.

14. Improving Our Services: Undertaking activities to verify or maintain the quality or safety of our services, and to improve, upgrade, or enhance our services.

15. Enabling Transactions: Otherwise enabling or effecting, directly or indirectly, a commercial transaction.

16. Notified Purpose: For other purposes for which we provide specific notice at the time the information is collected.

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Collection of Personal Information

Since this notice was last updated, we have collected Personal Information from the following categories of sources:

1. You/Your Devices: You or your devices directly.

2. Analytics Providers.

3. Social Networks.

4. Vendors providing additional information on your IP address.

5. Gaming Infrastructure and Platform Providers.

6. Advertisers.

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Disclosure of Personal Information

Pursuant to our Privacy Policy, we share your Personal Information with the following categories of third parties:

1. Analytics Providers.

   1. Personal Information we share: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Commercial Information, Internet or Other Electronic Network Activity Information.

2. Government: Government entities.

   1. Personal Information we share: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Commercial Information, Internet or Other Electronic Network Activity Information, Inferences Drawn from Personal Information.

3. Social Networks.

   1. Personal Information we share: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Commercial Information, Internet or Other Electronic Network Activity Information.

4. Vendors: Vendors and service providers.

   1. Personal Information we share: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Commercial Information, Internet or Other Electronic Network Activity Information, Sensory Information, Inferences Drawn from Personal Information.

5. Third Parties as Legally Required: Third parties as required by law and similar disclosures.

   1. Personal Information we share: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Commercial Information, Internet or Other Electronic Network Activity Information, Inferences Drawn from Personal Information.

6. Third Parties in Merger/Acquisition: Third parties in connection with a merger, sale, or asset transfer.

   1. Personal Information we share: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Commercial Information, Internet or Other Electronic Network Activity Information, Inferences Drawn from Personal Information.

7. Third Parties with Consent: Other third parties for whom we have obtained your permission to disclose your Personal Information.

   1. Personal Information we share: Identifiers, Categories of Personal Information in Cal. Civ. Code Section 1798.80(e), Commercial Information, Internet or Other Electronic Network Activity Information, Inferences Drawn from Personal Information.

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Your California Privacy Rights

If you are a California resident, you may exercise the following rights.

Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of Personal Information collected, sold, or disclosed by us; (2) purposes for which categories of Personal Information are collected or sold by us; (3) categories of sources from which we collect Personal Information; (4) categories of third parties with whom we disclosed or sold Personal Information; and (5) specific pieces of Personal Information we have collected about you.

Right to Delete. Subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected from you.

Verification. Requests for access to or deletion of Personal Information are subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations. We may seek to verify your identity by asking you to log in to your password-protected account. If we are unable to verify your identity in this way, we may ask for additional information.

Right to Equal Service and Price. You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.

Shine the Light. We do not rent, sell, or share Personal Information with nonaffiliated companies for their direct marketing uses as contemplated by California’s “Shine the Light '' law (Civil Code § 1798.83), unless we have your permission.

Submit Requests. To exercise your rights under the CCPA, please send an email to bd@magecosmos.com.

Authorizing an Agent. To authorize an agent to make a request to know or delete on your behalf, please send a written authorization signed by you and the authorized agent to us via the contact information listed in the “How to Contact Us” section above.

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Do Not Track

There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

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Contact Information

If you have any questions, comments, or concerns about this notice or our processing activities, or you would like to exercise your privacy rights, please email us at bd@magecosmos.com.