Effective Date: November 14, 2025
Last Updated: July 28, 2022 (Based on original policy)
This Privacy Policy (the "Policy") is formulated by Cloud Clipper (Hong Kong) Digital Technology Co., Limited (hereinafter referred to as "Cloud Clipper," "We," "Us," or "Our") regarding the products and services (including cloud gaming services and other network services, collectively, the "Products and Services") provided through the HyFun cloud gaming platform on its website platforms and/or the website platforms and mobile applications of its affiliates.
Cloud Clipper is committed to protecting your privacy. This Policy is designed to comply with applicable data protection laws, including, where relevant, the European Union's General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA) / California Privacy Rights Act (CPRA).
This Policy will help you understand:
We commit to maintaining your trust by upholding principles such as accountability, purpose limitation, data minimization, accuracy, security, transparency, and data subject participation.
Personal Information (PI) means any information relating to an identified or identifiable natural person. We collect and use your Personal Information for the purposes listed below. If we intend to use your information for any purpose not covered by this Policy, we will seek your separate consent.
| Category of PI | Purpose of Collection | Examples of PI Collected |
|---|---|---|
| A. Account & Registration Data | To perform the contract for service provision, including account creation and user authentication. | Username, Email Address, Mobile Phone Number. (We generally avoid collecting sensitive identifiers like national ID numbers unless required by local law and we have a strong legal basis.) |
| B. Financial & Transaction Data | To process payments, manage orders, assess transaction risks, and prevent fraud. | Virtual property information (transaction history, virtual currency balances, virtual items, game redemption codes). We do not store full credit card details. |
| C. Service Security & Logging Data | To ensure service security, prevent fraud, abuse, and system malfunction, and perform backups. | Unique Device Identifiers (UDID), IP Address, Login/Logout Records, Personal Internet Access Records, System Failure Logs, Communication/Call Records (for customer service). |
| D. Service Optimization & Analytics | To improve our Products and Services, fix system bugs, and develop new features. | Aggregated or Pseudonymized usage data, performance metrics, system error reports. |
| E. Personalized Content & Marketing Data | To display and recommend content (including personalized advertisements) that may be of interest to you. | Browsing/Search Preferences, Behavioral Habits, User Profiles (created via recommendation algorithms), Geolocation Data (approximate). |
| F. Customer Support Data | To respond to your inquiries, address service issues, and maintain communication records. | Your contact information, content of communication (chat logs, emails). |
| G. Device & Permission Data | To enable specific service features requested by the user and ensure compatibility. | MAC Address, Device Serial Number, AndroidID, WiFi Status (SSID, BSSID), Camera/Album access (with user consent), Application Installation List (for ad effectiveness). |
For users in the European Economic Area (EEA) and the UK, we rely on the following legal bases for processing your Personal Information:
We use Cookies, pixels, and other similar technologies (collectively, "Cookies") to collect information, including to recognize your device, maintain your login status, customize your experience, and analyze service usage.
You have the right to accept or reject Cookies. Most web browsers automatically accept Cookies, but you can usually modify your browser setting to decline Cookies if you prefer. However, this may prevent you from taking full advantage of the service.
We may share your Personal Information with the following parties:
The use of certain third-party advertising or analytics services may be considered "Selling" or "Sharing" of Personal Information for cross-context behavioral advertising under the CCPA/CPRA.
California Residents have the right to opt-out of the Sale or Sharing of their Personal Information. Please see Section VI for details.
We will only publicly disclose your Personal Information with your explicit consent or as required by law (e.g., responding to a legal summons or court order).
We have implemented technical and organizational security measures designed to protect your Personal Information from unauthorized access, use, modification, damage, or loss. These measures include data encryption (e.g., SSL/TLS), access controls, and regular security audits. While we strive to protect your Personal Information, no security system is impenetrable, and we cannot guarantee the absolute security of your data.
Subject to applicable laws, you have the following rights regarding your Personal Information:
| Right | Description (Applicable Jurisdictions) |
|---|---|
| Right to Know/Access | The right to know what PI we have collected about you and to obtain a copy of that PI. (All) |
| Right to Rectification/Correction | The right to have inaccurate or incomplete PI corrected. (GDPR, CCPA) |
| Right to Erasure/Deletion | The right to request the deletion of your PI under certain conditions. (GDPR, CCPA) |
| Right to Object | The right to object to the processing of your PI based on legitimate interests, including for direct marketing. (GDPR) |
| Right to Data Portability | The right to receive your PI in a structured, machine-readable format and to transmit that data to another controller. (GDPR) |
| Right to Opt-Out of Sale/Sharing | The right to direct us not to Sell or Share your PI for cross-context behavioral advertising. (CCPA/CPRA) |
| Right to Limit Use of SPI | The right to limit the use of Sensitive Personal Information. (CCPA/CPRA) |
| Right to Non-Discrimination | The right not to be discriminated against for exercising your privacy rights. (CCPA) |
To exercise any of these rights, please submit a request to us via:
We will respond to verifiable consumer requests in accordance with applicable law.
The HyFun Products and Services are not intended for children under the age of 13. We do not knowingly collect Personal Information from children under 13 without verifiable parental consent. If we learn that we have collected PI from a child under 13 without consent, we will take steps to promptly delete the information.
For residents of the EEA/UK, the age of digital consent may be higher or lower depending on the member state (generally 13 to 16).
If you believe we may have collected information from a child without parental consent, please contact us immediately.
As we operate globally, your Personal Information may be transferred to and processed in countries outside of your jurisdiction, including Hong Kong and other jurisdictions, which may have different data protection laws than your country.
For transfers of EEA/UK user data outside of the EEA/UK, we rely on appropriate safeguards, such as Standard Contractual Clauses (SCCs) approved by the European Commission or other legal mechanisms, to ensure your data receives an adequate level of protection.
We retain your Personal Information only for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements (e.g., maintaining your account while it is active, and for a period thereafter for backup and audit purposes).
We reserve the right to modify or update this Policy from time to time. We will notify you of any material changes by posting the new Policy on this page and updating the "Last Updated" date. We encourage you to review this Policy periodically.
If you have questions, concerns, or requests regarding this Privacy Policy or your Personal Information, please contact our Data Protection Officer (DPO) or Privacy Team at:
Cloud Clipper (Hong Kong) Digital Technology Co., Limited
Attention: Privacy Team / Data Protection Officer
Email: [Insert Dedicated Privacy Email Address]
Address: [Insert Company Address in Hong Kong or primary processing location]
[End of Policy]