Privacy Policy

Scope of Application

This Privacy Policy applies to the measures taken by Kingily Technology Co., Ltd. (hereinafter referred to as "the Company" or "we") regarding the collection, processing, utilization, disclosure, preservation, and protection of personal data in relation to "Jolly Wins" and its associated websites, applications, customer service systems, social interactions, activities, cash flow processes, operational analysis, and other related services (collectively referred to as "the Services").

This Privacy Policy also applies to the processing of personal data involved when you contact us, participate in marketing or operational activities, apply for customer service, use official social community functions, conduct transactions, or participate in surveys.

This Policy does not apply to third-party independently operated websites, platforms, cash flow services, application stores, advertising networks, social platforms, or other external services. The processing of your personal data by such third parties shall be handled in accordance with their respective privacy policies and terms.

Who We Are

Kingily Technology Co., Ltd. is the operator of "Jolly Wins" and is responsible for determining the purposes and methods of collecting and processing the personal data described in this Privacy Policy.

If you have any questions regarding this Privacy Policy, our data processing methods, the exercise of account rights, or privacy issues, please email us at service@jollywins.com.tw

Types of Data We Collect

We collect personal data based on actual service scenarios and the principle of minimum necessity. The scope of collection may vary depending on the functions you use, payment methods, customer service processes, event types, device settings, and your location. Common data types are as follows:

Account and Identification Data: Member account, nickname, character name, player ID, login credentials, and email address; used for establishing and managing accounts, verifying identity, maintaining game records, and corresponding with customer service.
Transaction and Payment Data: Transaction ID, order amount, payment result, invoice information, refund information, and payment/accounting data required by law or practice; used to complete top-ups, payments, refunds, reconciliation, taxation, and fraud prevention.
Device and Technical Data: IP address, device ID, operating system, browser, language setting, App version, crash records, and network environment; used for operations, security, anti-cheating, troubleshooting, and performance optimization.
Usage and Interaction Data: Login time, game progress, click/stay duration records, function usage, event participation records, and customer service tickets; used for providing services, analyzing usage, balancing game experiences, and improving functions.
Marketing and Preference Data: Subscription status, event responses, push notification preferences, questionnaire responses, and promotion redemption records; used for event notifications, member relationship management, audience segmentation, and effectiveness measurement.
Content and Communication Data: Messages, attachments, screenshots, complaint content, and community interaction content you submit to customer service; used for processing complaints, reporting anomalies, handling disputes, content moderation, and community management.
Compliance and Identity Verification Data: Real name, contact information, supporting documents, bank account, or other necessary information required during refunds, reward distribution, tax declaration, dispute resolution, or legal requests; used to fulfill legal obligations, verify identity, prevent fraud, and process specific applications.

Unless necessary for specific events, legal compliance, refund/reward issuance, account security, or dispute resolution, we will not generally or by default request that you provide data disproportionate to the service purposes.

How We Obtain Your Data

We may obtain your data in the following ways:

Provided directly by you, such as registering an account, binding an email address, submitting a customer service application, participating in events, filling out questionnaires, applying for a refund, or providing compliance documents.
Automatically generated when you use the Services, such as login records, device information, game behavior records, transaction results, error logs, and security detection data.
Provided by partners or third-party platforms, such as application stores, payment processing institutions, identity verification services, social login services, and advertising and analytics service providers; however, this is strictly limited to the scope necessary for fulfilling services, controlling risks, or complying with the law.

How We Use Your Data

We may use your personal data for the following purposes:

To provide, maintain, deliver, and optimize the Services, including account activation, login verification, game saves, customer service processing, and transaction fulfillment.
To maintain service security and integrity, including cybersecurity monitoring, anti-cheating, anti-abuse, fraud prevention, dispute resolution, anomaly detection, and auditing.
To process payments, top-ups, refunds, invoices, reward distribution, taxation, and accounting workflows.
To respond to your inquiries, complaints, rights exercise applications, or other customer support needs.
To conduct product analysis, service improvement, research, testing, quality management, and operational decision-making.
Provided that it is permitted by applicable laws or necessary consent has been obtained, to send you event notifications, member messages, push notifications, emails, SMS, or other marketing information.
To fulfill legal obligations, respond to lawful requests from government or judicial authorities, or protect the rights, property, and safety of the Company, other users, and the public.

Where required by applicable laws, we will use consent, contract performance, legitimate interests, legal obligations, or other applicable legal grounds as the basis for processing. If certain processing is premised on your consent, you may withdraw your consent at any time as described in this Policy, but this will not affect the lawfulness of processing based on consent before its withdrawal.

Cookies, Device IDs, and Analytics Technologies

We may use Cookies, SDK, pixel tags, device IDs, server logs, and other similar technologies to identify devices, maintain login status, record preferences, measure event effectiveness, conduct analysis, improve stability, and enhance security.

You can manage Cookie, tracking, advertising ID, notification, or location permissions through your browser, operating system, device permissions, app store settings, or control functions provided by third-party platforms. If you disable some of these technologies, certain functions of the Services may not operate properly.

How We Disclose or Share Data

We do not arbitrarily sell your personal data to third parties for monetary consideration. However, we may disclose, provide, or allow access to your data to the extent necessary under the following circumstances:

Service Providers: For example, cloud hosting, customer service platforms, payment processing, risk control, analytics, push notifications, email, cybersecurity, compliance, and auditing service providers.
Transaction and Co-op Partners: For example, application stores, cash flow institutions, refund processors, and event partners; strictly limited to the scope necessary for fulfilling the transaction or event.
Statutory or Lawful Requests: For example, courts, investigative agencies, competent authorities, judicial or administrative procedural requests, or as necessary to comply with the law.
Protection of Rights and Safety: To prevent fraud, cheating, money laundering, infringement of others' rights, cybersecurity incidents, or other major risks.
Corporate Transactions: In the event of a merger, acquisition, asset transfer, investment, reorganization, or other corporate transactions, necessary disclosure may be made under the premise of confidentiality.

We require third parties entrusted with processing data to take appropriate security measures in accordance with the contract, and they may not use the data for purposes unrelated to the delegated tasks without authorization.

International Transfers

As the Services may utilize cross-border cloud infrastructure, international customer service tools, global analysis tools, or cross-regional technical support, your personal data may be transferred to, stored in, or processed in countries or regions outside of your current location.

We will take appropriate protective measures as required by applicable laws and regulations, such as contractual controls, the principle of least privilege, access restrictions, encryption, or other reasonable security mechanisms. If specific jurisdictions have additional mandatory requirements for international transfers, we will comply with such requirements accordingly.

Retention Period

We will only retain personal data for the period necessary to achieve the purposes set out in this Policy, fulfill contracts, process disputes, comply with laws, handle accounting and taxation, conduct cybersecurity audits, investigate fraud, or establish necessary legal claims.

The retention period may differ for different data types. For example, data related to transactions, invoices, disputes, and audits are generally kept longer; marketing preferences, location permissions, or certain analytics data may cease processing, be anonymized, or be deleted earlier based on business needs or your settings.

Your Rights and Choices

Depending on the applicable laws in your jurisdiction, you may enjoy some or all of the following rights:

To inquire about, review, or obtain a copy of your personal data.
To request supplementation, correction, updating, or restriction of processing.
To request deletion, or to request the cessation of collection, processing, or use when legal conditions are met.
To withdraw consent, or to opt-out of specific marketing, push notifications, Cookies, or advertising tracking.
To request data portability, or to object to specific automated decision-making, profiling, or marketing uses.
To submit applications through an authorized agent in accordance with applicable laws.

To protect the security of accounts and others' data, we may ask you to provide reasonable and necessary identity verification information before processing rights applications. If we are legally permitted to refuse, restrict, or delay our response to certain applications, we will explain the reasons within the applicable scope.

Minors

If, under applicable laws, you do not yet possess the legal capacity to independently consent to data processing or enter into relevant contracts, please have your parents, guardians, or other legal representatives read this Privacy Policy, and use the Services under their consent and supervision.

If we become aware that a minor has provided personal data without lawful authorization or consent, we may take measures in accordance with the law, such as deleting the data, restricting its use, suspending the account, or requesting the rectification of the consent process.

Data Security

We adopt reasonable technical, administrative, and procedural security measures commensurate with business risks to prevent unauthorized access, alteration, disclosure, loss, or destruction of personal data. These measures may include access controls, encryption, log monitoring, backups, vulnerability patching, vendor management, and personnel training.

No system can guarantee 100% security. You should also properly safeguard your account, password, verification codes, and login devices, avoiding weak passwords or sharing account information with others.

Third-Party Services and External Links

The Services may integrate third-party logins, social sharing, payments, advertising, analytics, or links to external websites. Once you leave the Services or authorize third parties to interact with the Services, the processing of personal data by that third party shall be handled according to its own terms and policies.

We recommend that you read their privacy policies and permission descriptions before using any third-party services.

Amendments to this Policy

We may amend this Privacy Policy from time to time based on business, product features, legal, or practical needs. In the event of material changes, we will notify you through official website announcements, in-game notifications, emails, push notifications, or other reasonable means as appropriate.

The revised version shall apply from the date of announcement or the specified effective date. Your continued use of the Services after the new version takes effect shall be deemed as your acknowledgment and acceptance of the revised content; if you do not agree to the amendments, you should stop using the related services.

Contact Us

If you have any questions about this Privacy Policy, our data processing methods, your marketing preferences, account rights, or data protection matters, please contact:

Company Name: Kingily Technology Co., Ltd.
Company Address: 2F., No. 120, Qiaohe Rd., Zhonghe Dist., New Taipei City, Taiwan
Product Name: Jolly Wins
Contact Email: service@jollywins.com.tw

Appendix

Supplemental Terms for the Taiwan Region

This Appendix only applies to users located in Taiwan, or data subjects whose personal data processing is protected by Taiwan's personal data protection laws under specific circumstances. In the event of a conflict between this Appendix and the main text of the Global Privacy Policy, this Appendix shall prevail within the scope of application of Taiwanese law.

Collector and Contact Information

Name of Non-Government Agency: Kingily Technology Co., Ltd.

Contact Email: service@jollywins.com.tw

The Company is the operator of "Jolly Wins" and is responsible for the collection, processing, and use of personal data within the Services.

Purposes of Collection

The specific purposes for which the Company collects, processes, and uses personal data include, but are not limited to: membership management, account verification, contract performance, customer service, transaction processing, payments and refunds, event management, marketing, statistical analysis, product optimization, information and database management, cybersecurity maintenance, fraud and abuse prevention, legal compliance, and dispute resolution.

Categories of Personal Data

Depending on the actual service workflow, the categories of personal data that the Company may collect include:

Identifying individuals: Name, member account, nickname, email address, contact phone number, and mailing address.
Government or compliance identification information: Identification document information provided when necessary for legal requirements, refunds, taxation, identity verification, or dispute resolution.
Characteristic and descriptive information: Birthday, age range, language preference, game preferences, or questionnaire responses.
Transaction information: Order number, payment result, invoice information, refund information, and reward distribution information.
Technical and network information: IP address, device information, browser, operating system, and login and usage records.
Customer service and communication information: Tickets, complaints, attachments, chat records, and processing results.

Period, Region, Recipients, and Methods of Use

Period of Use: From the date of collection until the purpose of collection ceases to exist, the contract or membership relationship is terminated, the statutory retention period expires, or until you request the cessation of use or deletion in accordance with the law and there is no legal ground for retention.

Region of Use: Taiwan, and other countries or regions necessary for the provision of the Services.

Recipients of Use: The Company, service providers entrusted by the Company to process data, payment/refund processing institutions, cloud and information technology providers, customer service and marketing service providers, legally authorized authorities, and partners within the scope necessary for authorization or transaction fulfillment.

Methods of Use: Collection, recording, input, storage, editing, correction, retrieval, analysis, transmission, disclosure, deletion, or other methods of processing and use permitted by law, through automated or non-automated means.

Impact of Not Providing Data

If you refuse to provide personal data necessary for account creation, transaction completion, refund processing, customer support, security verification, or legal compliance, the Company may be unable to provide all or part of the Services, complete specific transactions, issue rewards, process complaints, or respond to your rights applications.

Rights Under Taiwan Law

You may exercise the following rights regarding your personal data toward the Company in accordance with the law:

To inquire or request to view.
To request the issuance of a duplicate copy.
To request supplementation or correction.
To request the cessation of collection, processing, or use.
To request deletion.

The Company may perform reasonable identity verification before processing your request. If the Company is legally permitted to collect necessary costs, restrict the exercise of rights, or retain specific data, such matters will be handled in accordance with legal provisions.

Marketing and Right to Opt-out

If the Company uses your personal data for marketing purposes within the scope permitted by applicable laws, you may notify the Company to cease such marketing use at any time. Once you express your refusal, the Company will stop using your personal data for marketing within a reasonable period and provide feasible methods for unsubscription, deactivation, or preference management.

International Transfers

For reasons such as cloud architecture, international technical support, analysis tools, payment processes, or other operational necessities, the Company may transfer personal data to countries or regions outside of Taiwan. The Company will take appropriate protective measures in accordance with Taiwan's laws and regulations and the degree of risk; if the competent authority imposes restrictions on specific countries, regions, industries, or scenarios according to the law, such restrictions shall be followed accordingly.

Contact Point in Taiwan

If you wish to exercise your rights or have questions, complaints, or suggestions regarding personal data protection matters in Taiwan, please email to: service@jollywins.com.tw

Please provide identifiable account information and contact details to facilitate the Company's verification and response.

Jurisdiction

The interpretation and application of these Terms, as well as any disputes related to the Services, shall be handled in accordance with the laws of the Republic of China (Taiwan), and the Taiwan Taipei District Court shall be the court of first instance jurisdiction.