Privacy Policy

Last Updated: 2023.05.19

Welcome to JungoJam (the “Game”). The Game is provided, operated and controlled by JungoJam Pte. Ltd., whose registered address is 77 ROBINSON ROAD #06-03 ROBINSON 77 SINGAPORE 068896. (“JungoJam”, “we”, “us” or “our”).


You are reading the Privacy Policy, which explains how we collect, use and disclose your personal data when you download the Game from Apple App Store or Google Play, access the Game, and the rights you may have under applicable privacy laws. If you do not agree with this policy, you should not play the Game.


If you have any questions about how we use your personal data, please contact us at support@jungojam.com.


PLEASE READ THIS PRIVACY POLICY CAREFULLY. This Privacy Policy consists of the summary of the key points in our Privacy Policy, the main body, and a jurisdiction-specific section. The jurisdiction-specific section might include additional information required under your local data protection laws, render certain aspects of the Privacy Policy to be inapplicable, or amend them to ensure compliance with local data protection laws. As such, please be sure you review this Privacy Policy in its entirety.


PRIVACY POLICY SUMMARY
What data do we collect about you?
We collect and process your data when you create an account and play the Game, including your contact details and other data you provide when you register for an account or play the Game. We also collect data you share with us from third parties (such as Facebook, Apple, Google, etc.) if you choose to log in to the Game via your account with such third party networks, and technical and behavioral data about your use of the Game. We may also collect data about you automatically through your use of the Game.
1.How and for what purpose will we use the data about you?
We use your data to provide the Game to you and to improve, develop and administer it. We may also use your data to, among other things, ensure your safety. We may also use your personal data to serve you targeted advertising and promote the Game and other products and services (in each case, if required under applicable law, where we have your consent).
2.Who else will access and collect your personal data and who do we share your data with?
The third party developer of the Game will have access to your data. Your data may also be collected by and shared with other companies in the same group as JungoJam. Where required or permitted by law, we will share your data with law enforcement agencies or regulators and with third parties pursuant to a legally binding court order.
3.Your rights.
In certain circumstances, you have rights in relation to your data such as the right to access and the right to correction. Depending on your jurisdiction, you may have additional rights - please see the jurisdiction-specific section at the end of this Privacy Policy.
4.How long do we keep hold of your data?
We retain your data for as long as it is necessary to provide you with the Game service so that we can fulfill our contractual obligations and rights in relation to the data involved. Where we do not need your data in order to provide the Game to you, we retain it only as long as we have a legitimate business purpose in keeping such data or where we are subject to a legal obligation to retain the data. We will also retain your data if necessary for the establishment, exercise or defense of legal claims.
5.How will we notify you of any changes to this Privacy Policy?
We will generally notify all users of any material changes to this policy through a notice within the Game when you log in. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. By accessing the Game, you acknowledge that you have read this policy and that you understand your rights in relation to your personal data and how we will collect, use and process it.


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1.The types of personal data we collect
Unless otherwise stated in this policy, the personal data we collect from you or about you is required so that we can perform our contract with you to provide the Game to you as detailed in our Terms of Service. The provision of certain data is mandatory for the purposes of your access to the Game, and if you do not provide certain types of data, we may not be able to grant you access to the Game, provide certain aspects of the Game or certain functionalities may be lost. However, you have control over certain kinds of personal data that you can choose to share or to withhold from us, and will still be able to access the Game, as detailed in this policy.


We collect and use the following data about you:


Data You Provide to Us, Including Your Profile Data. You give us data when you register an account to play the Game via the application directly or if you choose to register using your social network account details (e.g. Facebook etc.), including your name, username, password, age, language, email address, shipping address, phone number, country, data you disclose in your user profile, character name or nickname, and data you voluntarily elect to provide in order to customize game play, such as gender. We link your data with your activity on our Game across all your devices, using your email or other log-in or device data.


We also collect data in correspondence you send to us.


Behavioral and Use Data.


Gameplay


We collect and process data regarding your use of the Game including login history, how you engage with the Game, the preferences you set, the amount of time spent in the Game, your gameplay and activity, your Game progress, your interactions with other players in the Game, and other pieces of data in connection with your various activities within or through the Game or otherwise (including when you capture a screenshot in the Game) that are sent by your device or computer system when you access the Game, which are automatically tracked and recorded by our servers. We also link your subscriber data with your activity on our Game across all your devices using your email address, phone number, or similar data that you have provided.

User content
We process the content you generate on the Game, including videos you upload to create AI motion, and the associated metadata, such as when, where, and by whom the content was created (“User Content”). Even if you are not a user, information about you may appear in User Content created or published by users on the Game.


Surveys


We collect data through surveys, challenges and competitions in which you may participate including gender, likeness, age and preferences. We will also process your personal data in order to tell you about services and opportunities.


Messages


Where local laws allow us to, we collect and process, which includes scanning and analyzing, data you provide in the context of composing, sending, or receiving direct messages to and from other players, either directly on our websites and apps or to third party social media account and whether by words, audio, video or photos and your communications with us e.g.in the context of customer support including audio messages. That data includes the content of the message and data about when the message has been sent, received and/or read, as well as the participants of the communication.


We do this to prevent and block spam, prevent and detect crime, safeguard children (where this is in the substantial public interest) or to protect the interests of our users and other people.


Please also be aware that messages sent to other players will be accessible by those players and that we are not responsible for how those players use or disclose them.


Message Boards and Chat Rooms


We may also collect additional data you share about yourself such as on the Game's message boards, chat rooms and in the Game, including comments, images, photos, links, stickers and emojis. Any actions you perform with other players are considered public and are solely at your discretion, and therefore you should have no expectation of privacy or confidentiality. You may choose to disclose data about yourself in the course of contributing user generated content to the Game or in its chat rooms, blogs, message boards, user "profiles" for public view, or in similar forums on its sites through mobile services and/or through third party sites or services. You should be aware that any personally identifiable data you submit in the course of these public activities can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages.


Feedback


We also collect data and content of messages you provide to us through your feedback such as product reviews you write, or questions and data you provide for customer support. In this case, we may collect and store your contact data that you give them (i.e. your name and email address), your social network or service user ID number. When you contact us, such as for customer support, phone conversations or chat sessions with our representatives may be monitored and recorded.


Data from Third Parties. You may choose to share certain data with us from third parties or through your use of the Game. We have set out further details on the data we receive from third parties below:


Social Networks
If you choose to register to use the Game using your social network account details (e.g. Facebook, etc.), you will provide us or allow your social network to provide us with your username and public profile (including your name, profile picture, gender, networks, user IDs, list of friends, followers and accounts you follow, date of birth, email address, and any other data you have set to public on your account).


Technical Data we collect about you. We automatically collect certain data from you when you use the Game. Such data includes your IP address, time zone settings, language, data regarding the device or hardware you are using to access the Game such as the model of your device, mobile device’s unique identifier (UDID) or serial number, cellular information, WiFi network, identifier for vendor (IDFV), source of user (where you use your account on a third party platform to log in), device screen resolution, mobile carrier, network type, device ID, operating system, Android ID as well as other types of data sent by your device when you access the Game. Where you log-in from multiple devices, we will be able to use your profile data to identify your activity across devices.


Location. We use the 'Region' you select in Settings to customize your Game experience. When you play the Game on a mobile device, we will collect data about your location, including your country, zip code, area code and geolocation. In certain jurisdictions, with your permission, we will collect Global Positioning System (GPS) data and mobile device location data based on your SIM card. If you do not wish to share your precise location with us, you can switch off location services via the settings on your mobile device.


Invite your friends. If you play through a social network or register through a social network, you can invite your social network friends to join you in playing the Game. We will use the contact data you have for that person, from Facebook friends (or other similar social network) list and give you the option to send them either an SMS, email or third party message (such as WhatsApp, Facebook (including Facebook Messenger), Instagram, Google, Twitter, Kakao or Line) inviting them to play the Game.


Other. JungoJam may also receive either non-personal or public data from third parties in connection with market and demographic studies and/or data that JungoJam may use to supplement personal data provided directly by you. JungoJam may ask some third-party service providers to supplement the personal data that you provide to JungoJam for its own marketing and demographic studies, so that JungoJam can consistently improve its services and related advertising to better meet its visitors' needs and preferences. To enrich its understanding of individual customers, JungoJam may tie this data to the data you provide to us.


2.Cookies
We, our vendors and service providers use cookies and other similar technologies (e.g. pixels, web beacons etc.) (collectively, “Cookies”) to enhance your experience using the Game. We will obtain your consent to the use of Cookies where required under applicable law.


a) What is a Cookie?
Cookies are used to collect data, including personal data, from you. Cookies are small files which, when placed on your device, enable the Game to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar data from your computer or device.


Cookies are stored on your browser by website or apps that you visit. When you return to that website or app (or visit websites or apps that use the same cookies) these platforms recognize the Cookies and your browsing device.


b) Categories of Cookies
Cookies do many different jobs, like letting you navigate between pages efficiently, remembering your preferences, and generally improving the user experience. Cookies can tell us, for example, whether you have visited the Game before or whether you are a new player.


There are different categories of Cookies, including:

• First-party Cookies: First-party Cookies are small amounts of text which are served by us directly to your device.
• Third-party Cookies: Third-party Cookies, which are served by a third party on our behalf. We use third party Cookies for essential, functionality, analytics and performance, targeting and social media purposes.

Cookies can remain on your computer or mobile device for different periods of time. Some Cookies are 'session cookies', meaning that they exist only while your browser is open and are deleted automatically once you close your browser. Other Cookies are 'permanent cookies', meaning that they survive after your browser is closed. They can be used by the platform to recognize your computer when you open your browser and browse the Internet again.


c) What types of Cookies do we use and how do we use them?
The types of Cookies and similar technologies used by us and our partners in connection with the Game can be classified into one of five categories, namely 'essential Game Cookies', 'functionality Cookies', 'analytics and performance Cookies', and 'social media Cookies'. Cookies do a lot of different tasks to ensure you enjoy your use of the Game, for example, they are used to remember your preferences on sites you visit, to help you navigate between pages more efficiently. We have set out some further information about each category, and the purposes of the Cookies we and third parties set in the following table.


Cookies that are necessary for essential purposes
These Cookies are essential to provide you with the Game and to use some of its features, such as to enable you to log in. Without these Cookies, we would not be able to provide you with a secure log in account. We use Cookies to uniquely identify you. Each time you log in to the Game, a Cookie containing a unique identifier that is tied to your account is placed on your browser. These Cookies allow us to uniquely identify you when you are logged into the Game and to process your online transactions and requests.


Functionality Cookies
Functionality Cookies record information you have entered or choices you have made. These Cookies also enable you to optimize your use of the Game after logging in so that we can personalize our content for you, greet you by name and remember your preference. These Cookies can also be used to remember settings you have applied. These Cookies mean that when you continue to use or come back to the Game, we can enable you to start the Game from where you left off.


Analytics and Performance Cookies
We use analytics/performance Cookies to analyze how you use the Game, including your level in the Game, measure any errors that occur and test different design ideas. The information is used to report and evaluate your activities and patterns as a user of the Game to provide services in accordance with these activities. These Cookies do not collect information that individually identifies you and all information these Cookies collect is aggregated and anonymous. We also use third-party analytics tools to help us measure traffic and usage trends for the Game (with your consent if required under applicable law).


Social Media Cookies
Third parties whose applications are connected to the Game by you will set their own Cookies in order to customize their applications for you. Because of how Cookies work, we cannot access these Cookies, nor can the third parties access the data in Cookies used by us. If you are logged in to your account with the third party, the third party will be able to link information about you with your actions via Cookies.

1. How and for what purpose we use your personal data

We may use the data we collect about you in the following ways:
In accordance with, and to perform our contract with you, we may use your data to:

• enable you to play the Game;
• notify you about changes to the Game and send Game-related communications to you including information regarding other games under JungoJam;
• personalise the content you receive and provide you with tailored content that will be of interest to you;
• provide you with user support;
• enforce and notify you of changes to our terms of service, conditions and policies;
• administer the Game including troubleshooting;
• enable you to participate in the virtual items program or make other payment related transactions;
• deliver game-related products to the shipping address designated by you; and
• communicate relevant information (such as updates and security alerts) and provide support to you.

In order to comply with our legal obligations, we may use your data to:

• help us detect abuse, fraud and illegal activity in the Game;

In accordance with our legitimate interests to provide an enjoyable and safe Game experience, we may use your data to:

• ensure your safety and security ;
• ensure the Game is presented in the most effective manner for you and your device;
• improve, promote, update and develop the Game and your experience, and protect the Game from any cyber-attacks;
• better understand customer behavior and improve our products and services through analytics;
• carry out data analysis and test the Game to ensure its stability and security and data about installed packages and running apps or processes in order to ensure the security of the Game network and prevent the spread of viruses and malware;
• allow you to participate in social and interactive features of the Game; and
• provide you with personalized advertising and promotional emails (with your consent, if this is required by law), namely by sending messages regarding new products, features, enhancements, special offers, upgrade opportunities, contests and events of interest;
• We may also take measures to ensure that you are old enough to play the Game, as required by law.

4.Who else will access your personal data and how will we share your data
Third Party Game Developer
We work with third party game developers, and the third party developer of the Game will have access to your technical data and other data.


Social Networks
If you choose to register to use the Game using your social network account details (e.g. Facebook etc.), you will provide us or allow your social network to provide us with your user name and public profile (including your name, profile picture, gender, networks, user IDs, list of friends, date of birth, email address, and any other data you have set to public on your account).


If you access third-party services, such as Facebook, to log in to the Game, these third-party services may be able to collect data about you, including data about your activity on the Game, and they may notify your connections on the third-party services about your use of the Game in accordance with their privacy policies.


To manage the data JungoJam receives about you from a third-party application, such as Facebook, you will need to follow the instructions for the third-party application for updating your data and changing your privacy settings. You can also manage some aspects of data collection and use by visiting the “settings” page of your mobile device and reviewing the permissions of each application or “app.” Once JungoJam receives your data from a third-party application or your mobile device, that data is stored and used by JungoJam in accordance with this Privacy Policy. You may access and update that data as described herein.


Our Corporate Group
We may also share and/or other members, subsidiaries, or affiliates of our corporate group may collect your data to provide the Game including improving and optimizing the Game, preventing illegal use, and supporting users.


Law Enforcement
We may share your data with law enforcement agencies, public authorities or other organizations if legally required or permitted to do so, or based on our legitimate business interests if such use is reasonably necessary to:

• comply with a legal obligation, process or request JungoJam is not required to question or contest the validity of any legal process, search warrant, subpoena or other similar governmental request that it may receive;
• enforce our Terms of Service and other agreements, policies, and standards, including investigation of any potential violation thereof;
• detect, prevent or otherwise address security, fraud or technical issues; or
• protect and defend the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging data with other companies and organizations for the purposes of fraud protection and credit risk reduction).

Sale or Merger
We will also disclose your data to third parties:

• in the event that we sell or buy any business or assets (whether a result of liquidation, bankruptcy or otherwise), in which case we will disclose your data to the prospective seller or buyer of such business or assets; or
• if we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets. In such transactions, user data may be among the transferred assets.

5.International data transfers
For the purpose of performance of our contract with you, the personal data that we collect from you may be transferred to, and stored at, or otherwise accessed from or processed in a destination outside of your jurisdiction of residence (including Singapore and the United States of America) that has laws and regulations that may not guarantee the same level of security and protection of personal data as your jurisdiction. We will take reasonable and necessary steps to ensure that we handle personal data in accordance with this Privacy Policy and provide a standard of protection that it is comparable with the protection under the laws of your jurisdiction, regardless of where your personal data is transferred to or accessed from.


We will separately obtain your consent for international data transfer if this is required under applicable law.


6.Your rights
You may have the following rights under applicable laws:

• The right to request free of charge (i) confirmation of whether we process your personal data and (ii) access to a copy of the personal data retained;
• The right to request proper rectification or deletion of your personal data or restriction of the processing of your personal data; and
• The right to object to processing your personal data for the purposes of sending you promotional messages.

Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.


Depending on your jurisdiction, you may have additional rights. Please see the jurisdiction-specific section at the end of this Privacy Policy.


Please send an e-mail to support@jungojam.com if you would like to exercise any of your rights. We will respond to your request consistent with applicable law and subject to proper verification.


In addition:

• You can change your preferences by using the toggle features in the Game's cookie settings or by adjusting your browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of Cookies.
• You may opt out of marketing communications by following the instructions in such communications or by using options provided in the game settings.
• Some browsers transmit “do-not-track” signals to websites. Because of differences in how browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.
• If you have registered for an account, you may access, review, and update certain personal data that you have provided to us by logging into your account and using available features and functionalities.
• If you want to remove your contacts stored by us, follow the instructions provided in the game to request that we remove them from our systems. If you need to enter a password to allow us to access your address book, we will not store that password.

7.The security of your personal data
We take steps to ensure that your data is treated securely and in accordance with this policy. We understand the importance of keeping your personal data safe and private, and we are committed to protecting your personal data from being lost, stolen or misused.


You are also responsible for keeping your personal data safe. Also, you are responsible for keeping your account details (if any) confidential.


We will, from time to time, include links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Because JungoJam cannot control the activities of third parties, it cannot accept responsibility for any use of your personal data by such third parties, and it cannot guarantee that they will adhere to the same privacy and security practices as JungoJam. Please check these policies before you submit any data to these websites.


8.How long do we keep your personal data
We retain your data for as long as it is necessary to provide you with the service so that we can fulfill our contractual obligations and rights in relation to the data involved. However, there are occasions where we are likely to keep this data for longer in accordance with our legal obligations or where it is necessary for the establishment, exercise or defense of legal claims.


9.Data relating to children
The Game is not directed at children under the age of 13 and we do not knowingly collect or solicit personal data from children under 13. If you believe that we have personal data about or collected from a child under the relevant age, please contact us at support@jungojam.com and we will ensure that it is.


10.Complaints
In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at support@jungojam.com and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to lodge a claim with the relevant data protection authority.


11.Changes
We will generally notify all users of any material changes to this Privacy Policy, through a notice provided via the Game and providing any other notice required by applicable law. We will also update the “Last Updated” date at the top of this Privacy Policy, which reflects the effective date of such Privacy Policy. By accessing the Game, you acknowledge that you have read this Privacy Policy and that you understand your rights in relation to your personal data and how we will collect, use and process it. If you do not agree to the updated Privacy Policy, you must stop accessing or using the Game.


12.Contact
Questions, comments and requests regarding this Privacy Policy should be addressed to support@jungojam.com.


Supplemental Terms – Jurisdiction-Specific
If you are using the Game in the following jurisdictions, the respective jurisdiction-specific terms below would apply. In the event of a conflict between the provisions of the Supplemental Terms –Jurisdiction-Specific that are relevant to your jurisdiction from which you access or use the Game, and the rest of this Privacy Policy, the relevant jurisdictions’ Supplemental Terms – Jurisdiction-Specific will supersede and control.

Australia
The following definition shall apply to the Privacy Policy:

• “Personal data” means "personal information" as defined in the Privacy Act 1988 (Cth), i.e., information or an opinion, whether true or not, and whether recorded in a material form or not, about an identified individual, or an individual who is reasonably identifiable.

The following shall be added to Section 5 (International data transfers):

• The personal data that we collect from you will be transferred to, and stored at, a destination outside of Australia, in particular in Singapore and the United States of America.

The following shall replace Section 12 (Contact):

• If you have any questions about the Privacy Policy, or would like to complain about a breach of the Australian Privacy Principles, or are concerned about the handling of your personal data, please contact the privacy officer support@jungojam.com. You have the right to access your personal data and seek correction of it. Please contact the privacy officer on the details provided in this Privacy Policy if you wish to access your personal data and/or seek correction of your personal data. If you are not satisfied with the response or do not receive a response within a reasonable time frame, you may have the right to take your complaint to the Office of the Australian Information Commissioner (OAIC). Current contact details for the OAIC are available on the OAIC's website at www.oaic.gov.au.

Philippines
The following is added to the "Summary":

• If you are a resident of the Philippines, the applicable privacy laws shall include the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and issuance of the National Privacy Commission.

The following is added to Section 6 (Your rights):

• Right to complaint: You have the right to lodge complaints before the National Privacy Commission.

The following shall replace Section 12 (Contact):

• If you have any questions about the Privacy Policy, or would like to complain about a violation of the Data Privacy Act of 2012, or are concerned about the handling of your personal data, please contact the data protection officer (DPO) at support@jungojam.com. You have the right to access your personal data and seek correction of it. Please contact the DPO on the details provided in this Privacy Policy if you wish to access your personal data and/or seek correction of your personal data. If you are not satisfied with the response or do not receive a response within a reasonable time frame, you have the file a complaint with the National Privacy Commission (NPC). Current contact details for the NPC are available on the NPC's website at www.privacy.gov.ph.

New Zealand
The following sentence should be added to the end of Section 5 (International data transfers):

• Where we send your personal data to a jurisdiction outside of New Zealand, we will ensure that your personal data will be protected by security safeguards comparable to New Zealand law while in that foreign jurisdiction. If your personal data will not be protected by security safeguards comparable to New Zealand law while in that foreign jurisdiction, we will inform you that this is the case, and only transfer your personal data with your consent.