JIMI Privacy Policy
Latest Update: August 19, 2024
This JIMI Privacy Policy (the “Privacy Policy”) is fully committed to implementing and complying with applicable privacy laws and regulations, including but not limited to the Personal Data Protection Act 2012 of Singapore (“PDPA”) in order to inform you of your choices and our practices regarding any personal information you provide to JIMI PTE. LTD. and its relative companies (collectively referred to herein as “JIMI”, “we” or “us”). This Privacy Policy is an integral part of the JIMI Terms of Service and, unless otherwise agreed, the terms used in this Privacy Policy are the same as in the JIMI Terms of Service.
Your use of or access to products and services provided by JIMI, including but not limited to game(s) and/or applications for mobile devices and PC platforms, web applications accessible on third-party social networking services, online sites, web forums or messaging boards in applications and sites provided by JIMI (collectively the “JIMI Services” or “our Services”) involves the collection, disclosure and use of your personal information. It is important for you to understand how this happens and how you may control it. This Privacy Policy explains the types of information that we may collect, disclose and hold, how that information is used and with whom the data is shared. It also sets out how you can contact us if you have any queries or concerns about this Privacy Policy.
IF YOU AGREE WITH THIS PRIVACY POLICY THROUGH CLICKING ON THE AND/OR ACTUALLY ACCESS OR USE JIMI SERVICES BY DOWNLOADING OR POSTING ANY CONTENT ON OR THROUGH JIMI SERVICES, IT WILL BE DEEMED YOU HAVE READ, FULLY UNDERSTOOD AND AGREED TO ACCEPT ALL THE TERMS OF THIS PRIVACY POLICY AND OTHER SERVICE REGULATIONS PROVIDED BY JIMI AND YOU EXPRESSLY CONSENT TO US COLLECTING, PROCESSING, USING, DISCLOSING AND STORING YOUR PERSONAL INFORMATION, AS DESCRIBED IN THIS PRIVACY POLICY. You have the right to withdraw your consent at any time, and upon such withdrawal, we will cease to collect, process, store, disclose and use your personal information.
IF YOU DO NOT AGREE TO THE TERMS AND CONDITIONS IN THIS PRIVACY POLICY, OR IF YOU DO NOT WANT US TO COLLECT, USE OR DISCLOSE YOUR PERSONAL INFORMATION AS DESCRIBED HEREIN, PLEASE DO NOT USE THE SERVICE.
SPECIAL NOTE FOR MINORS, PARENTS AND GUARDIANS: YOU AGREE THAT IF YOU ARE UNDER THE AGE OF 18 OR OTHER AGE OF LEGAL MAJORITY WHERE YOU ACCESS JIMI SERVICES, YOU REPRESENT THAT YOUR LEGAL GUARDIAN HAS READ, UNDERSTOOD, AND AGREED TO THIS PRIVACY POLICE. FOR PARENTS AND GUARDIANS: YOU SHOULD NEVER LET MINORS IN YOUR CUSTODY TO USE ANY OF JIMI SERVICES WHILE UNSUPERVISED. PLEASE ENSURE THAT THE MINORS UNDER YOUR CUSTODY DO NOT GIVE OUT TOO MUCH PERSONAL INFORMATION, AND THAT THEY UNDERSTAND HOW TO USE THE SERVICES SAFELY. IN REGISTERING FOR AN ACCOUNT (DEFINED AS BELOW), YOU AGREE TO MONITOR THE ACCOUNT TO RESTRICT ANY USE BY MINORS. YOU ACCEPT FULL RESPONSIBILITY FOR ANY USE OF OUR SERVICES BY MINORS, AND THIS INCLUDES ANY USE OF YOUR CREDIT CARDS OR OTHER PAYMENT OR SETTLEMENT INSTRUMENTS OR DEVICES BY MINORS.
THIS AGREEMENT CONTAINS A BINDING INDIVIDUAL ARBITRATION AGREEMENT AND CLASS ACTION WAIVER IN THE SECTION TITLED “DISPUTE RESOLUTION.” THIS AFFECTS YOUR RIGHTS WITH RESPECT TO ANY “DISPUTE” BETWEEN YOU AND JIMI AND MAY REQUIRE YOU TO RESOLVE DISPUTES IN BINDING, INDIVIDUAL ARBITRATION, AND NOT IN COURT. PLEASE READ THIS ENTIRE AGREEMENT, INCLUDING THAT PROVISION, CAREFULLY.
1. The Types of Personal Information We Use
We generally do not collect your personal data unless (i) it is provided to us voluntarily by you directly or via a third party who has been duly authorized by you to disclose your personal data to us (your “Authorized Representative”) after we notify you of the purposes for collecting the information or obtain your (or your Authorized Representative's) written consent; or (ii) the collection and use of personal data without consent is permitted or required by the PRIVACY LAWS or other laws. We shall seek your consent before collecting any additional personal information and before using your personal information for a purpose which has not been notified to you (except where permitted or authorized by law).
This section describes the different types of personal information we collect and how we collect it. We will collect and use the following information about you:
1) Information you provide:
a. when you register for JIMI Services using third-party social media or similar accounts (e.g. Facebook, Twitter, Google or Apple etc., collectively “Social Media Accounts”) in order to set up your profile (we import from your connected Social Media Accounts your personal information which may include your name/nickname/username as it appears on your social media profile, your profile picture, your friend list, and your account ID);
b. when you register for JIMI Services using email addresses (including your email address and your name/nickname/username);
c. when you log-in as a ‘guest’ in order to use JIMI Services (including your nickname);
d. when you set up your profile for JIMI Services (including information you voluntarily elect to provide in order to customize gameplay, including but not limited to your name/nickname/username, your gender, your age, etc.) and set up your account for JIMI Services (including information you provide to help set up the account, including but not limited to your phone number, email address, security questions, etc.);
e. when you submit your name, date of birth, domestic citizenship or foreign information for age verification or compliance with applicable laws and regulations;
f. when you submit your contact details to us (including your name, email address, phone number and physical address) as part of promotional activities for JIMI Services;
g. when you use location-based functions in JIMI Services (if any, “Location Services”) (including GPS location information, device ID, Wi-Fi connection location); and
h. when you make purchases using your account (in which case we will process the information you provide to us to facilitate the payment which could include your name, bank/debit/credit card number, card expiration date, billing address, CVV), etc.
i. when you use our Services, or interact with other users and/or us through our Services. This includes, but is not limited to, the cookies that may be generated when you interact with us.
2) Information we collect about you:
a. We may automatically collect certain data from you when you use JIMI Services, including your IP address and device information (such as device type, network data, operating system, device ID, device name, device type/model, MAC address, IMEI data, CPU data, graphics card model, OS version and language, time zone, screen DPI, device resolution, memory data, and graphics card model, etc.) and information regarding your use of and interaction with JIMI Services, such as date and time stamps of actions. Additionally, we gather information related to bugs, errors, crashes, and diagnostics, including registration/login time, game version, stack trace, crash reports, and abnormal process data to better understand your device, usage patterns, and location.
b. We collect information about your in-game experience points, game progress, your level, score, and user statistics, and other similar data generated while using our Services. This information helps us understand your gaming preferences, provide personalized feedback, and enhance your overall experience with our Services.
c. We store the Advertising ID and select device information for each advertisement, along with your profile, to monitor the effectiveness of our advertising and marketing campaigns. Furthermore, we may use your de-identified email address, including those collected from third-party social media providers when you log in via your social media account(s), to track the success of our advertising and marketing campaigns after implementing appropriate technical security measures.
d. You have the option to create personalized profiles (where applicable) in our Services by selecting a nickname, crafting a personal signature, uploading an avatar, and providing other relevant details based on our service setup.
e. If you participate in our surveys, we will gather your survey responses.
f. If you choose to take part in any events or promotions organized by us (such as campaigns), we may collect information related to your participation, including your name, your user id, email address, mobile phone number, nickname, and country/region. In case you win any prizes, you may also need to provide us with your mailing address so that we can send you the prize. Your participant information may be added to your Account.
g. We collect information about your preferences for receiving marketing materials, your communication preferences, and your communication history with us and our service providers, to tailor our communications with you and enhance your user experience.
h. We collect, and process data related to the security of your account and our Services, such as password changes and login history, to ensure the safety and integrity of our Services.
i. We may collect certain data and utilize various methods to detect and analyse instances of cheating or fraud within the Services. These methods include but are not limited to monitoring the presence of external programs that may affect the Services, identifying attempts by external programs or plugins to access the Services, and other similar techniques aimed at ensuring the integrity of gameplay. The collected data is used solely for the purpose of detecting and preventing cheating and fraud, with the objective of providing a fair gaming experience for all users.
j. We also collect and store your data each time you interact with us, for example, when you use in-app support to communicate with us.
k. We may collect additional information as required by specific Services or features within our platform. In such cases, we will provide separate privacy notices detailing the collection and usage of this information.
3) Information you generate and display in the course of using JIMI Services:
You may provide additional information as part of your profile. You may also provide or generate information when you communicate with other users in JIMI Services (e.g., chat log). You acknowledge and agree that information generated within our Services should not be considered private and communications within our Services may be viewed/heard by other users. Please avoid revealing any personally identifiable or sensitive information during such communications.
4) Representations and Warranties
You represent and warrant that:
a. any information you provide when registering an account or when using JIMI Services is true, accurate, current and complete; and
b. if you provide the personal information of another individual to us: (i) you have obtained the consent of such individual(s) to provide us with his or her personal information for the relevant purposes and are otherwise permitted to do so under applicable law, without us taking any further steps; (ii) we may collect, use, disclose and store such information as described in this Privacy Policy, (iii) the individual concerned is aware of the terms and conditions in this Privacy Policy, (iv) the information you provide to us about such individual are true, accurate, current and complete.
2. Purposes of Data Collection and Use
Your personal information collected and stored by us may be used to:
1) Provision of product and services
a. provide you with a product or service you have requested (including any product or service updates) and checking that a payment is not made fraudulently, and delivering your purchase to you or ensuring that you benefit from any relevant special offer or promotion (and fulfil its obligations under any other agreement it may have with you);
b. provide customer service (whether in-person, online, by phone, email, social media or otherwise)
c. provide customer service and support, installation, warranty, repair, returns and other after sales services;
d. conduct and host our events, competitions, roadshows, seminars, workshops and engaging in our redemption activities;
e. establish and maintain your account with us;
f. provide our checkout assistance service;
g. facilitate your use of services provided by us.
2) Product and service development
a. work constantly to improve our Services to better meet customer requirements, to ensure data quality, to develop identity management, and to strengthen network and information security;
b. conduct prize draws, contests and other promotional offers;
c. post messages to our social media, internet platform or any other means or answer a survey;
d. tailor our Services to your needs - information on service use may be used to compile aggregate statistics and carry out analysis in order to help us create content and navigation that is the most relevant and user friendly to users;
e. conduct analytic to target and provide better personalized contents, recommendations or advertisements within any service, or application used by you;
f. achieve other purposes directly relating to any of the above.
3) Preventing unauthorized use of JIMI Services
detect, investigate, and respond to security incidents and protect against illegal or objectionable activities, including the unauthorized use of JIMI Services.
3. Share and Transfer of Personal Information
You acknowledge and authorize your personal information will be retained by us and stored in one or more of our databases. We will maintain full control over and safeguard, according to strict standards of security and confidentiality, but may share your personal information with the following individuals and/or entities whether within or outside of Singapore, for any of the purposes set out above:
a. any agent, contractor or third party service provider who provides services to us including analytic and processing, administrative, accounting, customer service, data hosting, logistics distribution, delivery and fulfillment, installation, fraud detection, telecommunications, computer, payment gateway, marketing, insurance, financing, legal, and other professional services to us;
b. any branch, subsidiary, holding company, associated company or affiliate of ours;
c. credit reference or debt collection agency or similar provider of debt collection or credit information services to us for purpose of credit reporting, verification and risk management;
d. third party advertising partners so that they can better target and/or personalize advertisements displayed within any application used by you;
e. third party purchaser or seller, and its and our professional advisors, in connection with a corporate event such as a merger, business acquisition or insolvency situation;
f. any person or authority to whom we are under an obligation to make disclosure under the requirement of any law, regulations, rules, codes of practice or guidelines binding on or applicable to us;
g. any other entity under a duty of confidentiality to us which has undertaken to keep such information confidential;
h. persons whom you transact with through our Services such as online merchants, or any banking, financial or other institutions.
Where there is a transfer of your personal information out of Singapore, we will take steps to ensure that your personal information continues to receive a standard of protection comparable to that provided under the PDPA.
THIRD-PARTY SERVICE PROVIDERS LIST:
Provider: NXCLOUD ASIA PTE. LTD.
Acquired Permission/Information: email address
Function/Purpose: send email (advertising or general notification)
Provider Privacy Policy: https://www.nxcloud.com/privacy-policy
Provider:
United Kingdom, Switzerland, and other jurisdictions in Europe but outside the European Economic Area：Alibaba.com (Europe) Limited
European Economic Area：Alibaba (Netherlands) B.V.
United States of America：Alibaba Cloud US LLC
India：Alibaba Cloud (India) LLP
Malaysia：Alibaba Cloud (Malaysia) Sdn. Bhd
Outside of Europe, the United States of America, India or Malaysia：Alibaba Cloud (Singapore) Private Limited
Acquired Permission/Information: email address
Function/Purpose: send email (advertising or general notification)
Provider Privacy Policy:
https://www.alibabacloud.com/help/en/legal/latest/alibaba-cloud-international-website-privacy-policy
4. Direct Marketing
1) In accordance with the requirements of the PDPA, we intend to use and transfer your personal information for the purposes of conducting direct marketing and may not do so unless we have received your consent or written consent (in the case of transfer).
2) With your consent or written consent (in the case of transfer) (which includes an indication of no objection), we may:
a. use personal information, including your name, contact details including email, phone number and address for direct marketing purposes such as sending advertising texts or emails;
b. conduct direct marketing in relation to the products and services that we, our affiliates, our co-branding partners and our business partners may offer;
c. provide the personal information described in the section entitled “The Types of Personal Information We Use” to any agent or contractor for the purpose of carrying out direct marketing of the above products and/or services on our behalf ; and
d. in addition to marketing the above products and services, share the personal information described in the section entitled “The Types of Personal Information We Use”, with any third party provider of any of the classes of products and/or services as described in the section entitled “Transfer of Personal Information” for direct marketing purposes in relation to such classes of products and/or services, and we require your written consent (which includes an indication of no objection) for the purposes and will not do so without your written consent.
3) If you do not consent to us using and/or sharing your personal information for any of those purposes, we may not conduct direct marketing to you and provide your personal information to others for direct marketing purposes. You may also subsequently withdraw your consent by writing to our Data Protection Officer at the address as mentioned in this Privacy Policy. If you exercise your right to opt out of the use/sharing of your personal information for any of the above purposes, it will mean that we, our group companies and/or third party service providers will not be able to send you any direct marketing, targeted or special offers in the future. When you exercise your right to opt out of direct marketing, we shall cease to use and transfer your personal information for direct marketing purposes, without charge.
5. Cookies and Other Tracking Technologies
We may use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience when using JIMI Services. Selected third parties may also use Cookies when you access your account using Social Media Accounts. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality. The data collected from cookies is currently used to improve the functionality of our Service.
6. Security
We are concerned with the security of your personal data collected and has put in place measures to prevent unauthorized access to that data. Our systems safeguard electronic communications by utilizing appropriate security protocols for authentication and authorization, including SSL, encryption and firewalls.
7. DISCLAIMER REGARDING SECURITY AND THIRD PARTY SITES
1) WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY SITES. We do implement a variety of security measures to maintain the safety of your personal data that is in our possession or under our control. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the personal data confidential. When you place orders or access your personal data, we offer the use of a secure server. All personal data or sensitive information you supply is encrypted into our databases to be only accessed as stated above.
2) In an attempt to provide you with increased value, we may choose various third party websites to link to, and frame within, the Site or Games. We may also participate in co-branding and other relationships to offer e-commerce and other services and features to our visitors. These linked sites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with us, we have no control over these linked sites, each of which has separate privacy and data collection practices independent of us. Data collected by our co-brand partners or third party web sites (even if offered on or through our Site or Games) may not be received by us.
3) We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. These linked sites are only for your convenience and you therefore access them at your own risk. To the maximum extent permitted by applicable laws, we shall not be liable and do not accept any liability for any damage or loss of any kind which arises, whether directly or indirectly, from your access and use of such linked sites. Nonetheless, we seek to protect the integrity of our Site and Games and the links placed upon each of them and therefore welcome any feedback about these linked sites (including, without limitation, if a specific link does not work).
8. INFORMATION ON CHILDREN
JIMI Services are not intended for children under the age of 13 (or other age threshold required by local laws). We do not knowingly collect or maintain any personal data or non-personally-identifiable information from anyone under the age of 13 nor is any part of our Site, Games or other Services intended for them. As a parent or legal guardian, please do not allow such children under your care to submit personal data to JIMI and please also consult us for more information. In the event that personal data of a child under the age of 13 in your care is disclosed to us, you hereby consent to the processing of the child’s personal data and you accept and agree to be bound by the terms of this Privacy Policy on behalf of such child. In the event you do not in fact consent to the processing of the personal data of a child under the age of 13 in your care, please contact our Data Protection Officer. We will close any accounts used exclusively by such children and remove and/or delete any personal data that was submitted without parental consent by such child or as otherwise required by applicable law.
9. Period of Retention
We retain your personal information for as long as necessary for the purposes set out in this Privacy Policy, or as agreed between you and us, unless otherwise required or permitted under applicable law. Where we no longer require your personal information for the purposes under this Privacy Policy, or otherwise required under applicable law, we will take appropriate steps to securely delete or destroy your personal information.
10. Your Rights
1) In accordance with the applicable laws and regulations of relevant countries/regions (including but not limited to GDPR, CCPA and PDPA), you have the right to request access to, correction of and deletion of the personal data we hold about you. If you have such a request, please contact us through our customer support service. We will process your request as quickly as possible and provide you with the requested information or perform the necessary corrections or deletions, as required by law.
2) Access. You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your Account and by contacting us. If you believe we hold any other personal information about you, please email us at cs@jmjimi.com.
3) You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent (e.g., certain survey information) or pursuant to our contract with you. You have the right to receive this information in a structured, commonly used, and machine-readable format. You also have the right to request that we transfer that personal information to another party.
4) If you wish for us to transfer such personal information to a third party, please ensure you detail that party in your request. Note that we can only do so where it is technically feasible. Please note that we may not be able to provide you with personal information if providing it would interfere with other’s rights (e.g., where providing the personal information we hold about you would reveal information about another person or our trade secrets or intellectual property).
5) Correction. You have the right to correct any personal information held about you that is inaccurate. You can access the personal information you have made available as part of your account by logging into your Game account. If you believe we hold any other personal information about you and that information is inaccurate, please email us at cs@jmjimi.com.
6) Erasure. You can delete your account, or remove certain personal information, by logging into your Account or contact us. If there is any other personal information you believe we process that you would like us to erase, please email us at cs@jmjimi.com. You may request that we erase the personal information we hold about you in the following circumstances:
a. you believe that it is no longer necessary for us to hold such personal information;
b. you believe the personal information we hold about you is being unlawfully processed by us.
c. You can also exercise your right to restrict our processing of your personal information whilst we consider your request. We may need to retain personal information if there are valid grounds under data protection laws for us to do so (e.g., for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Game Services and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.
7) You have a right to require us to stop processing the personal information we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (e.g., for the defense of legal claims or for other’s protection). As above, where we agree to stop processing the personal information, we will try to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.
8) You may request we stop processing and just store the personal information we hold about you were:
a. you believe the personal information is not accurate for the period it takes for us to verify whether it is accurate
b. you wish to erase the personal information as the processing we are doing is unlawful, but you want us to retain the personal information;
c. you wish to erase the personal information as it is no longer necessary for our purposes, but you require it to be stored for the establishment, exercise or defense of legal claims.
9) Objection. You have the right to object to our processing of personal information about you. We will consider your request in other circumstances as detailed below by emailing us at cs@jmjimi.com.
10) Announcements. We may send you announcements from time to time when we consider it necessary to do so (such as when we temporarily suspend Game access for maintenance, or security, privacy, or administrative-related communications). You may not opt-out of these service-related announcements, which are not promotional in nature.
11) Notwithstanding the foregoing, if the applicable laws and regulation of your country/region of residence provide otherwise, the corresponding laws shall govern.
11. Updates to The Privacy Policy
We respect our users' privacy and recognize the need to update this Privacy Policy as and when new features and business services are offered by us. Users will be notified of any changes to the Privacy Policy before the changes become effective. If you do not agree to any updates or changes to the Privacy Policy, please do not use JIMI Services (or any part thereof). Your continued use of JIMI Services and submission of personal data and other information in connection with your use of JIMI Services shall be deemed as your acknowledgement and acceptance of the revised Privacy Policy.
12. Dispute Resolution
This Agreement and any action related thereto will be governed by the laws of Singapore without regard to its conflict of law’s provisions. Any dispute arising out of or in connection with this Agreement, including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre (“SIAC”) in accordance with the Arbitration Rules of the Singapore International Arbitration Centre (“SIAC Rules”) for the time being in force, which rules are deemed to be incorporated by reference in this clause. The seat of the arbitration shall be Singapore. The Tribunal shall consist of one arbitrator. The language of the arbitration shall be English.
13. Contact Us
1) For requests to access, correct or delete your personal data, please provide us with relevant information (which should include customer information, requested data, correction, deleted data, use of personal data) and post to: cs@jmjimi.com or the following address: 10 ANSON ROAD #33-17 INTERNATIONAL PLAZA SINGAPORE (079903).
2) Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your access requests.
3) Please note, in accordance with relevant laws, we will process your request as quickly as possible after receiving it, subject to payment of the relevant administrative fees (if any).
4) If we are unable to process your request or we have legitimate reasons to deny your request, we will notify you as soon as possible. To ensure that we can process your request in a timely and accurate manner, we may need to obtain more information about you.