Nebula Games Pte. Ltd. (the "Company", "we" or "us") values the protection of personal information and privacy. This Privacy Policy applies to the Joypot Club game, official website, mobile pages, customer service channels, activity pages and other related services operated by the Company (collectively, the "Service"). It explains how we collect, use, retain, disclose, share, transfer and protect personal information, and how users may exercise rights such as access, correction, withdrawal of consent, restriction of direct marketing, deletion and complaint according to applicable law. This Policy is a legal document and is not a store interface, advertising page or promotional statement.
We process personal information in accordance with applicable data protection laws, platform rules and this Policy. If you do not agree to this Policy, please stop registering, logging in or using the Service. If you continue to use the Service, you are deemed to have read, understood and accepted this Policy.
Article 1 Scope and Data Controller
This Policy applies to all scenarios in which we process personal information while providing Joypot Club related services, including account registration and login, game operation, top-ups and refunds, activity participation, customer service complaints, risk control, prize delivery, website access, marketing communications, data analytics, security audit and lawful compliance handling.
The data controller for personal information under this Policy is Nebula Games Pte. Ltd. If you have any questions, requests or complaints about the processing of personal information, you may contact us through the contact details listed at the end of this Policy.
Article 2 18+ Service and Accidental Collection of Minors' Information
The Service is available only to users who are at least eighteen years old. We do not proactively provide registration, login, top-up, activity participation, marketing promotion or other game services to minors, and we do not design personal information collection activities targeting minors.
If we discover or have reasonable grounds to believe that we have accidentally collected a minor's personal information, or that an account is registered, controlled or used by a minor, we will take measures including service restriction, cessation of processing, deletion, anonymization or other necessary measures in accordance with applicable laws and platform rules. Guardians or other lawful rights holders may submit supporting materials through the contact details published in this Policy and apply to access, correct, delete or restrict processing of the relevant personal information.
Article 3 Categories of Information We Collect
We process the following information within a lawful, proper and necessary scope depending on the service scenario:
- Account and identity information: account ID, nickname, avatar, login credentials, bound email address, mobile number, third-party account unique identifiers, and necessary identity or age verification materials.
- Device and network information: device model, operating system and version, language and region settings, IP address, network status, unique device identifiers, advertising identifiers, mobile device identifiers, device fingerprints and security verification data.
- Game and service records: login time, online status, gameplay behavior, activity participation, virtual item changes, leaderboard or task records, abnormal operation records, system logs, error logs and crash information.
- Transaction and payment information: order number, product type, payment channel, payment status, amount, time, transaction flow, refund records, risk control conclusions and related vouchers. Sensitive payment information such as bank card numbers and payment accounts is generally processed by third-party payment institutions, and we receive only transaction results, billing status or risk control information within the necessary scope.
- Customer service and communication information: inquiry content, complaint records, contact details, account verification materials, handling results, voice or text communication records and dispute evidence materials.
- Delivery and activity information: if the Service involves souvenirs, physical prizes or other deliverable items, we may process recipient name, contact telephone number, detailed address, postal code, logistics tracking number, customs clearance or delivery information.
- Marketing and preference information: notification subscription status, activity preferences, advertising interaction records, Cookie or similar technology records, marketing communication and opt-out records.
Article 4 Sources of Information
The information we process may come from the following sources:
- Information you actively provide when registering, logging in, topping up, participating in activities, contacting customer service, submitting applications, requesting refunds or completing delivery information.
- Information automatically generated or recorded by systems when you use the Service.
- Information provided to us by third-party login, payment, advertising, analytics, cloud service, customer service, security, logistics and other partners within lawful authorization or necessary service scope.
- Information obtained according to applicable laws, regulatory requirements, judicial or administrative authority requirements, or for dispute handling, risk control security and rights protection.
Article 5 Purposes and Legal Bases of Processing
We process personal information for the following purposes:
- Creating, logging in to, verifying, maintaining and protecting your account.
- Providing games, top-ups, virtual item delivery, activity participation, reward issuance, customer service, complaints, refunds, notices and other related services.
- Conducting age, identity, transaction, account security and risk control verification.
- Preventing cheating, fraud, money laundering, illegal transactions, service abuse, plug-in attacks, account theft and other unlawful or non-compliant acts.
- Maintaining system security, troubleshooting, repairing vulnerabilities, optimizing performance and improving product experience.
- Conducting statistics, operational analysis, advertising effectiveness evaluation and service quality evaluation.
- Sending service notices, activity information, marketing content or personalized recommendations within the scope of consent or as permitted by law.
- Complying with applicable laws, platform rules, regulatory requirements, judicial or administrative authority requirements, and protecting the lawful rights and interests of users, the Company, partners or the public.
Our legal bases for processing personal information include necessity for performing the user agreement or providing the Service, your consent, compliance with legal obligations, protection of lawful rights and interests, necessity for dispute handling and security risk control, and other bases permitted by applicable law. Where sensitive personal information or explicit consent is required by law, we will obtain the corresponding consent according to law.
Article 6 Sensitive Personal Information and Data Minimization
We will not proactively request sensitive personal information unrelated to the Service. If identity documents, payment vouchers, health information or other sensitive information must be processed for age verification, transaction risk control, dispute handling, legal compliance or account security, we will process it only for clear purposes, within the necessary scope and for the shortest reasonable period, and apply stricter access control and security measures.
You may refuse to provide non-essential information. However, if certain information is necessary for registration, login, payment, refund, delivery, customer service verification or security risk control, refusal to provide it may prevent us from providing the corresponding service or completing the relevant request.
Article 7 Cookies, SDKs and Similar Technologies
We may use Cookies, local storage, device identifiers, SDKs, pixel tags or similar technologies to identify login status, save preferences, maintain account security, measure service usage, analyze crashes and performance, conduct advertising attribution and improve service experience.
You may manage, reject or delete certain Cookies or identifiers through browser or device settings. After disabling relevant functions, you may still use part of the Service, but login persistence, security verification, payment, activities, personalized display or statistical analysis functions may be affected.
When third-party SDKs or services are integrated, such third parties may process information according to their privacy policies. We will require partners to process information within the agreed purposes and necessary scope and to adopt reasonable security measures.
Article 8 Sharing, Entrusted Processing and Disclosure
We do not sell personal information. To achieve the purposes described in this Policy, we may share, disclose or entrust the processing of personal information to the following recipients within the necessary scope:
- Service providers for payment, cloud services, SMS, email, customer service, advertising, data analytics, crash analysis, security protection, risk control review, logistics delivery and similar services.
- Affiliates, consultants, partners or entrusted processors that provide operational, technical, legal, audit, compliance, financial, customer service or business support to the Company.
- Third-party login providers, app stores, payment platforms, advertising platforms, data analytics platforms or logistics service providers, for completion of functions you choose to use.
- Judicial authorities, administrative authorities, regulators, law enforcement authorities or other statutory entities legally entitled to request information.
- Recipients involved in mergers, divisions, acquisitions, asset transfers, restructurings, bankruptcy liquidation or similar transactions; we will require the recipient to remain bound by this Policy or rules providing no lower protection level.
We require recipients to process personal information only for agreed purposes and to assume confidentiality, security and compliance obligations. Without your consent or a lawful basis, recipients may not use personal information for other purposes.
Article 9 Cross-Border Transfers
Because the Service involves cross-border network transmission, cloud services, payment processing, customer service support, security review, data backup or operational collaboration, your personal information may be transferred, stored or processed in regions related to service operation.
We will take reasonable measures in accordance with applicable laws, including necessity assessment, contractual safeguards, access control, encrypted transmission, permission isolation and security audits, and require recipients to provide a level of protection no lower than that required by this Policy.
Article 10 Retention and Deletion
We retain personal information only for the period necessary to achieve the purposes described in this Policy, during the term of the user agreement, for periods required by laws, regulations or platform rules, during dispute handling, and for audit, security and risk control needs.
When the retention period expires, or when there is no longer a lawful, proper and necessary reason for continued retention, we will delete or anonymize the relevant personal information. Where continued retention is required for legal, regulatory, dispute handling, transaction record, anti-fraud, security audit or lawful rights protection purposes, such requirements shall apply.
Article 11 Information Security
We adopt reasonable technical and management measures to protect personal information security, including access control, permission grading, least privilege, encrypted transmission, log records, backup and recovery, security audits, employee confidentiality requirements and supplier security management.
The Internet environment is not absolutely secure. If a personal information leak, alteration, loss, unauthorized access or other security incident occurs or may occur, we will activate an emergency plan, take remedial measures, prevent expansion of harm, and notify affected users within the period required by law through service pop-ups, in-site messages, registered email, SMS or other conspicuous methods. Where necessary, we will report to regulators and cooperate with investigation and handling.
Article 12 Your Rights
To the extent permitted by applicable law, you may exercise the following rights regarding personal information:
- Query whether we are processing your personal information and request access or a copy.
- Request correction of inaccurate, incomplete or outdated personal information.
- Request deletion, anonymization or cessation of processing where permitted by law and where there is no legitimate reason for continued processing.
- Withdraw consent previously given; withdrawal does not affect processing already conducted based on consent before withdrawal.
- Object to or restrict processing of personal information for direct marketing purposes, including profiling related to direct marketing.
- Request restriction or object to processing that may cause damage or distress.
- Complain to us about personal information processing matters, or lodge a complaint with a competent authority according to law.
To protect account security, we may require you to provide necessary materials to complete identity verification. For requests meeting legal requirements, we will handle them within a reasonable period. If a request cannot be fulfilled according to law, we will explain the reason.
Article 13 Marketing Notices and Opt-Out
We may send you service notices, activity information, marketing content or personalized recommendations within the scope of consent or as permitted by law. You may request to stop receiving marketing information through the unsubscribe method in relevant messages, device settings, account settings or the contact details published in this Policy.
Even if you opt out of marketing information, we may still send non-marketing information relating to account security, transactions, service changes, agreement updates, legal compliance or important operational notices.
Article 14 Automated Decision-Making and Personalized Recommendations
We may conduct security risk control, abnormality identification, anti-cheating, advertising attribution, content ranking or personalized recommendations based on account status, device information, transaction records, gameplay behavior, risk signals or activity participation records.
If automated processing has a significant impact on your rights and interests, you may request an explanation, raise an objection or request human review through the contact details listed in this Policy. We will not make decisions solely based on automated processing that violate applicable law or unreasonably harm your lawful rights and interests.
Article 15 External Links and Third-Party Platforms
When using the Service, you may open or be redirected to other websites, applications, app stores, payment platforms, social platforms or third-party services. For third-party products or services not operated or controlled by the Company, we cannot guarantee their privacy protection level. Please read their privacy policies, terms of service and permission descriptions before use.
Article 16 Policy Changes
We may update this Policy according to laws and regulations, platform rules, service content, technical solutions or operational needs. The revised Policy will be published on the official website, game client or related pages. For material changes affecting user rights, we will provide a conspicuous notice. Where separate consent is required by law, we will obtain such consent according to law.
Article 17 Contact Information
If you need to access, correct or delete personal information, withdraw consent, object to direct marketing, restrict processing, submit a complaint or ask about this Policy, you may contact the Company through the following methods:
Email: support@nebulagamesg.com
Telephone: +65 80282813
Address: 81 Aljunied Road #05-01, YHWH Building, Singapore 389823
Official Website: https://www.nebulagamesg.com/