Privacy Policy

Last updated: March 11, 2026

This Privacy Policy (the "Policy") applies to the website (https://mjtmllc.com/) and all mobile games, applications, and related services (collectively referred to as the "Services") operated, owned, or published by Ganggu Commercial Limited ("we", "us", "our", "Ganggu Commercial"). Ganggu Commercial Limited is a company registered in Hong Kong, with its registered address at Room 12C, 21/F, Victor Commercial Building, 1A-1L Tung Choi Street, Mong Kok, Kowloon, Hong Kong; contact email: ganggdoart@outlook.com; contact telephone: 68031893. By accessing, downloading, installing, or using any part of our Services, you acknowledge that you have read, fully understood, and unconditionally agreed to be bound by the terms of this Policy, as well as our Terms of Service and any additional rules, guidelines, or notices we may issue from time to time. If you do not agree to any of these terms, you must immediately cease accessing or using our Services.

This Policy is formulated to fully comply with the Apple App Store Review Guidelines (especially Guidelines 5.1.1 and 5.1.2), the Personal Data (Privacy) Ordinance (PDPO) of Hong Kong, the General Data Protection Regulation (GDPR) of the European Union, the Children's Online Privacy Protection Act (COPPA), and other applicable global data protection laws and regulations. It explains in detail how we collect, use, store, protect, and share your information when you access or use our Services, as well as your rights, choices, and the measures we take to protect your privacy. This Policy is closely linked to our Terms of Service, and any terms not explicitly stated herein shall be governed by our Terms of Service.

1. Scope of Application

1.1 Applicable Scope

This Policy applies to all Services provided by Ganggu Commercial, including but not limited to: (1) all mobile games developed, published, or operated by us (available on the Apple App Store and other authorized platforms); (2) our official website (https://mjtmllc.com/); (3) all functions, features, and content provided through the above Services; (4) any user support, feedback, or inquiry services related to the Services; (5) any promotional activities, surveys, or user interaction activities organized by us. This Policy also applies to any information you provide to us when interacting with our customer service team, participating in our promotional activities, or using any paid functions of the Services (as specified in our Terms of Service).

1.2 Exclusion Scope

This Policy does not apply to: (1) third-party products, services, websites, or applications that may be linked from our Services (including but not limited to third-party advertising platforms, social media links, app store platforms, and third-party payment services); (2) information collected by third parties through their own services or channels, regardless of whether such services are linked from our Services; (3) information provided by you to third parties independently, without our involvement or supervision; (4) anonymous data that cannot identify you personally under any circumstances. We are not responsible for the privacy practices, data security, content, or legal compliance of any third parties, and we strongly encourage you to review the privacy policies and terms of service of those third parties before accessing their services or providing them with any information. Your use of third-party services is at your own risk, and we shall not be liable for any losses or damages arising therefrom, as further specified in our Terms of Service.

2. Information We Collect

We adhere to the principle of "data minimization" and "necessity", and only collect information that is directly related to the operation, optimization, security, and user experience of our Services. We do not require user registration, login, or provision of personal information to use the basic functions of our Services (e.g., playing casual games without in-app purchases or personalized features), which is consistent with the non-mandatory registration requirement specified in our Terms of Service. The information we collect is divided into the following categories, all of which comply with Apple's requirements for data collection transparency and legitimacy, and are strictly limited to the scope necessary for the provision of Services.

2.1 Information You Voluntarily Provide

We only collect information that you voluntarily provide to us, and we will not actively request or force you to provide any unnecessary personal information. You have the right to choose whether to provide such information, and refusing to provide it will not affect your use of the basic functions of the Services (except for paid functions or promotional activities that require specific information). The voluntarily provided information includes but is not limited to:

  • 2.1.1 Contact Information: If you contact us for customer support, feedback, or inquiries (e.g., submitting a support ticket, sending an email, or making a phone call), you may provide your email address (ganggdoart@outlook.com is our dedicated contact email), phone number (optional), or other contact information to enable us to respond to your needs. This information is used solely to handle your inquiries and resolve your issues, and will not be used for other purposes without your consent.
  • 2.1.2 Feedback and Inquiry Content: Any messages, suggestions, complaints, or inquiries you submit to us (e.g., feedback on game bugs, suggestions for feature optimization, or questions about the Services, including paid services as specified in our Terms of Service), which we use to improve our Services, fix technical issues, and enhance user experience. We may retain this content for a reasonable period to track the effect of improvement and respond to follow-up questions.
  • 2.1.3 Promotional Activity Information: If you voluntarily participate in our promotional activities (e.g., game giveaways, surveys, discount activities), you may provide information such as your name (optional), email address, or game account information (if applicable) to participate in the activity and receive rewards. We will clearly inform you of the purpose of collecting such information when you participate in the activity, and will not use this information for other promotional purposes without your explicit consent.
  • 2.1.4 Paid Service Information: If you use the paid functions or services of our Services (as specified in our Terms of Service), you may need to provide information related to the payment (e.g., email address for receiving payment confirmation), but we do not directly collect or store your payment details (e.g., credit card information, bank account information), which are processed by authorized third-party payment service providers in accordance with their own privacy policies and security standards.
  • 2.1.5 Other Voluntary Information: Any other information you actively choose to share with us (e.g., game experience sharing, user-generated content, profile information for personalized display), which you confirm is appropriate to disclose and does not violate any third-party rights or applicable laws. You may modify or delete such information at any time, unless otherwise specified by applicable laws.

We will not collect any sensitive personal information (including but not limited to ID number, bank card information, health information, precise location information, or biometric information) without your explicit, written consent. If we need to collect sensitive personal information for specific purposes (e.g., identity verification for paid services), we will separately inform you of the purpose, scope, and usage of such information, and obtain your explicit consent before collection.

2.2 Automatically Collected Information

When you access or use our Services (including opening our mobile games, browsing our website, or using any function of the Services), we may automatically collect certain non-personal or device-related information through technical means (e.g., SDKs, server logs, cookies). This information does not directly identify you personally, but helps us ensure the normal operation of the Services, optimize user experience, detect and prevent fraud, and comply with Apple's App privacy requirements. The automatically collected information includes but is not limited to:

  • 2.2.1 Device Information: Device type, brand, model (e.g., iPhone 15, iPad Pro), operating system version (e.g., iOS 17.2), device manufacturer, device unique identifiers (including IDFA, IDFV, and Android ID), device storage capacity, screen resolution, and device settings (e.g., language, brightness, time zone). This information is used to ensure the compatibility of our games with your device, fix technical bugs, optimize game performance for different devices, and prevent unauthorized device access (as specified in our Terms of Service regarding anti-fraud measures).
  • 2.2.2 Network Information: IP address, network type (Wi-Fi, 4G, 5G), network connection status, network operator, and geographic location (only the city-level location derived from the IP address, not precise GPS location). This information is used to monitor the stability of our Services, resolve network-related errors, provide localized content (e.g., displaying game interfaces in the local language), and detect abnormal network activities to prevent fraud and unauthorized access.
  • 2.2.3 Usage and Gameplay Data: Game progress (e.g., levels completed, scores achieved), session duration (how long you use the game each time), interaction events (e.g., buttons clicked, features used, in-game purchases made), gameplay statistics (e.g., game completion rate, frequency of use), crash logs, error reports, and diagnostic data (e.g., system errors, game freezes). This information is used to detect and fix bugs, optimize game difficulty, improve user experience, develop new features that meet user needs, and verify compliance with our Terms of Service (e.g., preventing cheating behavior).
  • 2.2.4 Website Usage Data: If you browse our official website, we may collect information such as the pages you visit, the time you spend on each page, the links you click, the browser type and version you use, and the referral source (how you found our website). This information is used to analyze website usage trends, optimize website design, improve the user experience of the website, and ensure the normal operation of the website.
  • 2.2.5 Advertising-related Data: If you consent to personalized advertising (via the AppTrackingTransparency (ATT) framework in iOS 14.5 and above), we may collect IDFA (Identifier for Advertisers) to display contextual or personalized ads. We will not collect IDFA without your explicit consent, and we will not use IDFA to track you across other apps or websites. You may withdraw your consent to personalized advertising at any time through the settings of your device or the Services, which will not affect your use of the basic functions of the Services.

2.3 Information from Third-Party Services

To provide necessary functions and improve the quality of our Services, we may integrate third-party software development kits (SDKs) or other third-party services into our Services, as further specified in our Terms of Service. These third-party services may collect information in accordance with their own privacy policies, and we do not control their data practices. We only cooperate with third-party service providers that comply with Apple App Store Review Guidelines, global data protection laws, and our Terms of Service, and we will require them to take appropriate data security measures to protect your information. We will also conduct regular audits of third-party service providers to ensure their compliance with relevant requirements. The common third-party services we may use include:

  • 2.3.1 Advertising Services:Third-party advertising networks (e.g., Unity Ads, Google AdMob) that help us display non-intrusive casual game ads. These services may collect IDFA (only after obtaining your consent via ATT) or other non-personal information to display relevant ads. We will ensure that these advertising services comply with Apple's requirements and do not display inappropriate or intrusive ads (e.g., ads containing violent, pornographic, or illegal content).
  • 2.3.2 Analytics Services: Third-party analytics platforms (e.g., Firebase Analytics, AppsFlyer) that help us analyze user usage behavior, track service performance, and optimize our Services. These services collect non-personal usage data (e.g., session duration, gameplay statistics) and do not collect personal information. We use the data provided by these services to improve our Services and comply with the service optimization requirements specified in our Terms of Service.
  • 2.3.3 App Store Platforms: Official app store platforms (e.g., Apple App Store) that process in-app purchases, verify user device information, and provide download services. We do not directly collect or store your payment information (e.g., credit card details), which is processed by the app store platform in accordance with its own privacy policy and security standards. We only receive non-personal information related to the purchase (e.g., purchase completion status) to confirm the provision of paid services.
  • 2.3.4 Attribution and Anti-Fraud Services: Third-party attribution and anti-fraud tools that help us track the effect of promotional activities, prevent fraud, cheating, and unauthorized access, and protect the legitimate rights and interests of users and our Services. These services may collect device information and usage data to identify fraudulent behavior, which is consistent with the anti-fraud and security protection requirements specified in our Terms of Service.
  • 2.3.5 Payment Services: Authorized third-party payment service providers that process in-app purchases and other paid services. These providers collect payment-related information in accordance with their own privacy policies and security standards, and we do not have access to or store such information. We only receive confirmation of payment completion to provide the corresponding paid services.

We will disclose the list of third-party service providers, their privacy policy links, and the scope of information they may collect on our official website (https://mjtmllc.com/) from time to time, so that you can review their data practices. If you have any questions about the data collection of third-party service providers, you may contact us or the relevant third parties directly.

3. How We Use Your Information

We use the collected information only for the purposes specified in this Policy and our Terms of Service, and we will never use it for purposes not disclosed herein. We will not use your information beyond the scope necessary to fulfill the purposes of the Services, and we will take reasonable measures to ensure that the use of your information is legal, legitimate, and transparent. The specific uses of your information are as follows, all of which comply with Apple's requirements for data usage and applicable laws:

  • 3.1 To Operate and Maintain the Services: Use device information, network information, and technical data to ensure the normal operation of our games and website, resolve technical failures (e.g., crashes, freezes), maintain the stability and security of the Services, and ensure that the Services comply with the operational requirements specified in our Terms of Service. For example, we use crash logs and error reports to quickly identify and fix bugs, ensuring that you can use the Services smoothly; we use network information to monitor service stability and resolve network-related errors.
  • 3.2 To Optimize User Experience: Use usage data, gameplay statistics, and user feedback to analyze user behavior, adjust game difficulty, optimize interface design, provide personalized game recommendations (without collecting personal information), and improve the overall quality of the Services. For example, we may adjust the difficulty of game levels based on the average completion rate of users, or recommend game features that are popular among users with similar gameplay habits; we may optimize the website layout based on website usage data to improve browsing experience.
  • 3.3 To Provide Advertising Services: Display contextual or personalized ads only after obtaining your explicit consent (via the ATT framework). We will not display inappropriate or irrelevant ads (e.g., ads containing violent, pornographic, or illegal content), and we will not use your information for unauthorized advertising purposes. You may withdraw your consent to personalized advertising at any time through the settings of your device or the Services, which will not affect your use of the basic functions of the Services. We will also ensure that the advertising services comply with the relevant provisions of our Terms of Service.
  • 3.4 To Conduct Statistical Analysis: Conduct anonymous statistical analysis of user usage data to understand the overall usage of our Services (e.g., the number of active users, the average time spent on the Services, the most popular game features). This anonymous data is used to improve service quality, formulate business strategies, comply with platform and legal requirements, and evaluate the effectiveness of service optimization measures specified in our Terms of Service. Anonymous data cannot identify you personally under any circumstances.
  • 3.5 To Prevent Fraud and Protect Security: Use device information, network information, and usage data to prevent cheating, fraud, hacking, unauthorized access, and other harmful behaviors, protect the legitimate rights and interests of users (e.g., prevent account theft, in-game currency fraud) and our Services, and comply with legal obligations related to data security and anti-fraud. This is consistent with the security protection and anti-fraud requirements specified in our Terms of Service. For example, we may use device information to identify abnormal login behavior and prevent unauthorized access; we may use usage data to detect cheating behavior and take corresponding measures in accordance with our Terms of Service.
  • 3.6 To Respond to User Needs: Use the contact information and feedback content you provide to respond to your support requests, feedback, and inquiries in a timely manner, handle your complaints, implement your suggestions for service improvement, and provide after-sales support for paid services. For example, if you report a game bug via email, we will use the information you provide to investigate and fix the bug, and notify you of the progress; if you have questions about paid services, we will use your contact information to respond to your inquiries and resolve your issues.
  • 3.7 To Conduct Promotional Activities: If you voluntarily participate in our promotional activities, we use the information you provide to verify your eligibility for participation, distribute rewards, notify you of the results of the activities, and ensure the fair and orderly conduct of the activities. We will not use this information for other promotional purposes without your consent, and we will delete or anonymize the information promptly after the end of the activities (except as required by law).
  • 3.8 To Provide Paid Services: If you use the paid functions or services of our Services (as specified in our Terms of Service), we use the information you provide (e.g., email address) to confirm your payment status, deliver the paid content or services, and provide after-sales support. We will not use this information for other purposes without your consent.
  • 3.9 To Comply with Legal Obligations: Use and disclose your information when required by applicable laws, regulations, legal procedures, subpoenas, or government requests (e.g., requests from law enforcement agencies). We will only provide the minimum necessary information required by law, and will take reasonable measures to protect your privacy to the greatest extent possible. We will also comply with the legal compliance requirements specified in our Terms of Service.

4. Legal Bases for Data Processing

In accordance with applicable global data protection laws (including GDPR, Hong Kong PDPO, and COPPA), we process your information based on the following legal bases, ensuring that all data processing activities are legal and legitimate, and consistent with the provisions of our Terms of Service:

  • 4.1 Legitimate Interests: Processing your information to operate and improve our Services, protect user security, prevent fraud, conduct statistical analysis, and ensure the normal provision of Services. These legitimate interests do not violate your fundamental rights and interests, and we will balance our legitimate interests with your privacy rights. For example, processing usage data to optimize the Services is in our legitimate interest to improve service quality, and also in the interest of users to obtain a better experience.
  • 4.2 Compliance with Legal Obligations: Processing your information to comply with applicable laws, regulations, and platform requirements (e.g., Apple App Store Review Guidelines, Hong Kong PDPO). For example, we may retain certain information to comply with the data retention requirements of relevant laws; we may disclose information when required by law enforcement agencies. This is also consistent with the legal compliance obligations specified in our Terms of Service.
  • 4.3 Explicit Consent: Processing your information (e.g., accessing IDFA for personalized advertising, collecting sensitive personal information, using your information for promotional purposes) only after obtaining your explicit, voluntary consent. You may withdraw your consent at any time through the settings of your device or the Services, and we will stop processing the corresponding information immediately after you withdraw consent (without affecting the legality of previous processing based on consent). Withdrawing consent will not affect your use of the basic functions of the Services, except for functions that specifically require such consent.
  • 4.4 Performance of a Contract: If you use paid services or participate in promotional activities that require the provision of information, we process your information to perform the contract with you (e.g., providing paid game features, distributing rewards, delivering after-sales support). This is consistent with the contract performance obligations specified in our Terms of Service.

5. Disclosure and Sharing of Information

We attach great importance to the protection of your information and will never sell, rent, or lease your personal information to third parties for commercial purposes, which is also explicitly stated in our Terms of Service. We will only disclose or share your information in the following limited circumstances, and we will take reasonable measures to ensure that the third parties comply with this Policy, our Terms of Service, and relevant laws:

  • 5.1 With Authorized Third-Party Service Providers: We may share necessary information with third-party service providers that assist us in operating our Services (e.g., analytics, advertising, anti-fraud, customer support, payment processing). These third parties are only authorized to use the information for the specific purposes agreed with us, and are required to take appropriate data security measures (e.g., encryption, access control) to protect your information. We will supervise their data processing activities, conduct regular audits, and require them to delete or return the information after the purpose is achieved. We will also ensure that these third parties comply with the relevant provisions of our Terms of Service.
  • 5.2 When Required by Law: We may disclose your information if required by applicable laws, regulations, legal procedures, subpoenas, or government requests (e.g., requests from law enforcement agencies, courts, or regulatory authorities). We will only provide the minimum necessary information required by law, and will notify you of the disclosure if permitted by law. This is consistent with the legal compliance obligations specified in our Terms of Service.
  • 5.3 To Protect Legitimate Rights and Interests: We may disclose your information to protect the safety, rights, property, or interests of Ganggu Commercial, our users, or the public. For example, if you engage in fraudulent, illegal, or harmful behavior that endangers the safety of other users or our Services (as prohibited in our Terms of Service), we may disclose your relevant information to relevant authorities or affected parties to stop the harmful behavior, protect the legitimate rights and interests of other users, and maintain the normal order of the Services.
  • 5.4 In Connection with Corporate Transactions: In the event of a merger, acquisition, asset transfer, reorganization, or dissolution of our company, your information may be transferred to the successor entity or relevant third party. We will ensure that the successor entity or third party complies with this Policy and our Terms of Service, and continues to protect your information. We will notify you of the transfer if required by law, and you have the right to withdraw your consent to the processing of your information by the successor entity (if applicable).
  • 5.5 With Your Explicit Consent: We may disclose or share your information with other third parties only after obtaining your explicit consent. For example, if you agree to share your game progress with a social media platform, we will share the relevant information in accordance with your consent. You may revoke your consent at any time, and we will stop sharing your information immediately.

We will not disclose or share your personal information with any third party for purposes not specified in this Policy or our Terms of Service. Any unauthorized disclosure or sharing of your information by third-party service providers shall be the sole responsibility of the third parties, and we will take appropriate measures to assist you in safeguarding your rights.

6. Data Security

We take data security very seriously and implement industry-standard administrative, technical, and physical safeguards to protect your information from unauthorized access, use, disclosure, alteration, or destruction, in line with Apple's requirements for data security, industry best practices, and the security protection requirements specified in our Terms of Service. Our specific security measures include:

  • 6.1 Technical Safeguards: (1) Use encryption technologies (e.g., AES-256) to encrypt data during transmission and storage, ensuring that your information is not intercepted or tampered with during transmission; (2) Regularly update our systems, software, and SDKs to fix security vulnerabilities and prevent network attacks (e.g., hacking, phishing); (3) Restrict access to user information to only authorized personnel, and assign different access permissions based on job responsibilities, implementing the principle of "least privilege"; (4) Use firewalls, intrusion detection systems, and other security tools to protect our servers and data storage facilities, and monitor abnormal access behavior in real time; (5) Conduct regular security testing and vulnerability scanning to identify and fix potential security risks in a timely manner.
  • 6.2 Administrative Safeguards: (1) Establish strict data management systems and operating procedures, specifying the responsibilities and obligations of employees in data processing, and prohibiting unauthorized access, use, or disclosure of user information; (2) Conduct regular data security training for employees to enhance their awareness of data protection and prevent information leakage due to human error; (3) Sign confidentiality agreements with employees and third-party service providers, prohibiting them from disclosing or misusing user information, and clarifying the liability for breach of contract; (4) Conduct regular audits of data processing activities to ensure compliance with this Policy, our Terms of Service, and relevant laws; (5) Establish a data security incident response mechanism to handle security incidents in a timely manner
  • 6.3 Physical Safeguards: (1) Protect our servers and data storage facilities in a secure environment, with access control, monitoring, and anti-theft measures, ensuring that only authorized personnel can access the facilities; (2) Regularly back up user data to prevent data loss due to hardware failure, natural disasters, or other unexpected events, and establish a data recovery mechanism to quickly restore data in the event of data loss; (3) Take appropriate measures to protect the physical security of devices used to process user information, preventing loss or theft.

However, please note that no data transmission or storage system can be guaranteed to be 100% secure. If an information security incident occurs due to factors beyond our reasonable control (e.g., network attacks, natural disasters, third-party breaches, or force majeure), we will promptly take remedial measures (e.g., blocking the security vulnerability, restoring data, notifying affected users), and cooperate with relevant authorities to investigate and handle the incident. We will also notify you of the incident in accordance with applicable laws and regulations if it may affect your rights and interests, and provide necessary assistance to help you safeguard your rights. This is consistent with the security incident handling provisions specified in our Terms of Service.

7. Data Retention

We retain your information only for as long as necessary to fulfill the purposes described in this Policy and our Terms of Service, or as required by applicable laws and regulations. We will not retain your information for longer than necessary, and will securely delete or anonymize your information once it is no longer needed. The specific retention periods are as follows:

  • 7.1 Voluntarily Provided Information: (1) Contact information and feedback content: Retained for 6 months after we respond to your needs (e.g., resolve your complaint, answer your inquiry), then securely deleted or anonymized; (2) Promotional activity information: Retained for 3 months after the end of the promotional activity, then securely deleted or anonymized; (3) Paid service-related information: Retained for 12 months after the expiration of the paid service, then securely deleted or anonymized; (4) Other voluntarily provided information: Retained for as long as necessary to fulfill the purpose for which it was provided, then securely deleted or anonymized.
  • 7.2 Automatically Collected Information: (1) Device information, network information, and usage data: Retained for 12 months after you stop using our Services (i.e., no activity on your device for 12 consecutive months), then securely deleted or anonymized; (2) Crash logs, error reports, and diagnostic data: Retained for 24 months to facilitate technical optimization and bug fixing, then securely deleted or anonymized; (3) IDFA and advertising-related data: Retained only for as long as you consent to personalized advertising, and deleted immediately after you withdraw consent; (4) Website usage data: Retained for 12 months after your last visit to the website, then securely deleted or anonymized.
  • 7.3 Information Required by Law: Retained for the period required by applicable laws and regulations (e.g., Hong Kong PDPO requires the retention of certain business records for 7 years; COPPA requires the retention of certain children's privacy-related records for a reasonable period). After the retention period expires, the information will be securely deleted or anonymized.

Anonymized data (data that can no longer identify you personally under any circumstances) may be retained indefinitely for statistical analysis, service optimization, or other legitimate business purposes, without being subject to the above retention periods. Anonymized data will not be linked to any personal information, and will not be used to identify you personally.

8. Your Rights Regarding Your Information

Depending on your jurisdiction (e.g., Hong Kong, European Union, United States), you may have the following rights regarding your information in accordance with applicable data protection laws (including PDPO, GDPR, and COPPA). We will respond to your requests in a timely manner and provide necessary assistance to help you exercise your rights, in line with the user rights provisions specified in our Terms of Service:

  • 8.1 Right of Access: You have the right to request access to the information we hold about you, including the type, content, purpose, and processing method of the information, as well as the list of third parties with whom we have shared the information. We will provide you with a copy of the information we hold about you free of charge (unless the request is excessive or repetitive).
  • 8.2 Right of Correction: If the information we hold about you is incorrect, incomplete, or outdated, you have the right to request correction or supplementation. We will verify the information within a reasonable time and make corrections or supplements promptly. If we cannot verify the accuracy of the information, we will inform you of the reasons and take appropriate measures to protect your rights.
  • 8.3 Right of Deletion: You have the right to request deletion of your information (also known as the "right to be forgotten") in the following circumstances: (1) the information is no longer needed for the purposes for which it was collected; (2) you withdraw your consent and there is no other legal basis for processing; (3) the processing violates applicable laws or this Policy; (4) you object to the processing and there are no overriding legitimate interests for us to continue processing; (5) the information was collected in violation of the provisions of our Terms of Service. We will securely delete your information within a reasonable time, unless longer retention is required by law. After deletion, we will not retain any copies of your information (except for anonymized data).
  • 8.4 Right to Restrict Processing: You have the right to request restriction of the processing of your information in the following circumstances: (1) you dispute the accuracy of the information; (2) the processing is illegal but you do not want the information to be deleted; (3) we no longer need the information but you need it for legal claims; (4) you have objected to the processing and we are verifying whether our legitimate interests override your rights. During the restriction period, we will not process your information except for storage and verification, and will not share it with third parties.
  • 8.5 Right to Withdraw Consent: If you have previously given consent for us to process your information (e.g., accessing IDFA for personalized advertising, collecting sensitive personal information), you have the right to withdraw your consent at any time. Withdrawing consent will not affect the legality of processing based on consent before withdrawal. You can withdraw consent through the settings of your device (e.g., iOS settings) or by contacting us. After you withdraw consent, we will stop processing the corresponding information immediately (except for processing required by law or other legal bases).
  • 8.6 Right to Data Portability: You have the right to request us to provide the information we hold about you in a structured, commonly used, and machine-readable format (e.g., CSV, JSON), or to transmit it directly to another data controller (where applicable). This right applies only to information that you have provided to us and that is processed based on consent or a contract. We will provide the information within a reasonable time and free of charge.
  • 8.7 Right to Object: You have the right to object to the processing of your information if we process it based on our legitimate interests. We will review your objection within a reasonable time and stop processing the information if your rights override our legitimate interests. If we continue to process the information, we will inform you of the reasons for overriding your rights.

To exercise any of the above rights, please contact us through the contact information provided in Section 13 of this Policy. When you submit a request, we may ask you to provide necessary information to verify your identity (e.g., email address, phone number) to ensure that the request is made by you personally and to prevent unauthorized access to your information. We will verify your identity within 15 working days (Hong Kong time) and respond to your request within 45 working days (or within the time limit required by applicable laws). We will not charge any fees for your reasonable requests, unless the request is excessive, repetitive, or requires additional costs. If you are not satisfied with our response, you may file a complaint with the Office of the Privacy Commissioner for Personal Data of Hong Kong or other relevant regulatory authorities, as further specified in our Terms of Service.

9. Children’s Privacy

Our Services are intended for general audiences and are not specifically directed at children under the age of 13. We strictly comply with COPPA and other applicable laws regarding children's privacy, and we do not knowingly collect personal information from children under the age of 13. This is also consistent with the user eligibility requirements specified in our Terms of Service (which require users to be at least 13 years of age).

If you are a parent or legal guardian of a child under the age of 13 and you believe that the child has provided us with personal information without your consent, please contact us immediately. We will verify your identity and the relevant information, and delete the child's personal information immediately (within 7 working days) upon confirmation. We will also take measures to prevent such collection from happening again, such as adding age verification mechanisms to our Services, and will not use or disclose the child's information for any purpose.

If we become aware that we have collected personal information from a child under the age of 13 without proper parental/guardian consent, we will immediately stop collecting such information, delete the existing information, and notify the relevant authorities if required by law. We will also review our data collection processes to prevent similar incidents from occurring in the future.

10. Cookies and Similar Technologies

Our website may use cookies and similar technologies (e.g., web beacons, pixel tags, local storage) to improve user experience, analyze website usage, and deliver relevant content. Cookies are small text files stored on your device that help us remember your preferences (e.g., language settings, browsing history) and track website usage data. Similar technologies (e.g., web beacons) are small images embedded in web pages that help us track user behavior and measure the effectiveness of advertising. We will not use cookies or similar technologies to collect personal information without your consent, and will comply with the relevant provisions of our Terms of Service.

We use two types of cookies: (1) Essential Cookies: Necessary for the normal operation of our website (e.g., cookies that enable you to browse the website and use its basic functions). You cannot disable these cookies, as they are essential for the website to work properly; (2) Non-Essential Cookies: Used to analyze website usage, deliver personalized content, and display relevant ads. You can disable these cookies through your browser settings.

You may adjust your browser settings to refuse cookies or delete existing cookies. However, disabling non-essential cookies may affect the normal use of some functions of our website (e.g., personalized content display, advertising optimization). For more information on how to manage cookies, please refer to the help documentation of your browser. We will clearly inform you of the use of cookies when you first visit our website, and obtain your consent for the use of non-essential cookies.

We will not use cookies or similar technologies to collect personal information without your consent, and we will not share cookie data with third parties for unauthorized purposes. Third-party service providers (e.g., advertising networks, analytics platforms) may also use cookies on our website, and their use of cookies is governed by their own privacy policies.

11. Third-Party Links

Our Services may contain links to third-party websites or services (e.g., links to app stores, third-party advertising platforms, social media platforms, third-party payment services). These third-party websites or services have their own privacy policies and terms of service, and we are not responsible for their privacy practices, data security, content, or legal compliance. We do not control the information collected by third parties, and we cannot guarantee the security of your information when you access these third-party services.

We encourage you to review the privacy policies and terms of service of these third parties before accessing their websites or using their services. Your use of third-party services is at your own risk, and we shall not be liable for any losses or damages arising from your use of third-party services or your provision of information to third parties, as further specified in our Terms of Service. We do not endorse any third-party services or their content, and the inclusion of links to third-party services does not constitute our approval of their privacy practices or content.

12. Changes to This Policy

We may update this Policy periodically to adapt to changes in applicable laws, regulations, Apple App Store Review Guidelines, industry practices, or our data processing practices. When we make material changes to this Policy (including but not limited to changes to the scope of information collection, the purpose of use, the method of sharing, or user rights), we will post the revised version on our official website (https://mjtmllc.com/) with an updated effective date. We may also notify you of such changes through appropriate channels (e.g., in-game pop-up notifications, email) if necessary, as further specified in our Terms of Service.

Your continued access to or use of our Services after the revised Policy is posted constitutes your acceptance of the updated Policy. If you do not agree to the revised Policy, you must immediately stop using our Services. We encourage you to review this Policy regularly to stay informed of any updates. The revised Policy will take effect on the posted effective date, and will replace the previous version of the Policy.

We will retain the historical versions of this Policy on our official website for at least 12 months, so that you can review the changes made to the Policy and understand the evolution of our privacy protection measures.

13. Contact Us

If you have any questions, requests, or concerns regarding this Policy, or if you wish to exercise your rights regarding your information, report a data security incident, provide feedback on our privacy protection measures, or inquire about the compliance of our Services with Apple App Store Review Guidelines, please contact us through the following channels:

Ganggu Commercial Limited

Email: ganggdoart@outlook.com (dedicated to privacy-related inquiries, response time: 15 working days)

Tel: 68031893 (Monday to Friday, 9:00 AM - 6:00 PM, Hong Kong time; excluding public holidays)

Registered Address: Room 12C, 21/F, Victor Commercial Building, 1A-1L Tung Choi Street, Mong Kok, Kowloon, Hong Kong

Website: https://mjtmllc.com/ (where you can find the latest version of this Policy and our Terms of Service)

We will respond to your inquiries and requests within 15 working days (Hong Kong time) and work with you to resolve any issues related to privacy protection. If you are not satisfied with our response, you may file a complaint with the Office of the Privacy Commissioner for Personal Data of Hong Kong (website: https://www.pcpd.org.hk/) or other relevant regulatory authorities, in accordance with applicable laws and regulations.