PRIVACY POLICY

Latest Update: May 29, 2023

Effective Date: May 29, 2023

Introduction

This privacy policy informs you of your choices and our practices regarding any personal information you provide to us, and tells you about your privacy rights and how the law protects you. Your use of this website or membership platform ("NetEase Games Account") and any related services provided by EXPTIONAL PTE. LTD. ("EXPTIONAL", "we", "us" or "our") (together, the "Platform") involves the collection and use of your personal information. We are the controller and responsible for your personal information described in this privacy policy. Please note that the provider of any third party's or our affiliate's and/or our own gaming website(s) or application(s) (including but not limited to Loading Bay, an online game storefront) (collectively, "Third-Party Application") may also be a controller of your personal information and please see their privacy policy for further information. For this privacy policy, "affiliate(s)" include our parent company and any other subsidiaries, joint venture partners or other related group companies that we control or that are under common control with us from time to time.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal information about you so that you are fully aware of how and why we are using your information. This privacy policy supplements other notices and privacy policies and is not intended to override them. If you do not agree with this privacy policy, you must not use the Platform. Further, if you access or log into the Platform using any third-party social media or similar account (e.g., Epic or Steam, collectively "Social Media Account"), you should review the privacy policy of the applicable Social Media Account provider as their privacy policy applies in relation to your use of the Social Media Account.

In addition, there are certain non-UK/European Economic Area ("EEA") jurisdiction-specific terms that may apply to you depending on where you reside. Please see the section "Jurisdiction-Specific Terms for Jurisdictions Outside the UK/EEA" below. Please note that nothing in this privacy policy shall confer, and nor shall it be interpreted to confer, any additional rights or obligations that go beyond what is mandated by the relevant applicable data protection laws in a non-UK/EEA jurisdiction.

If you provide us with personal information of other persons, please make sure the respective persons are aware of this privacy policy and only provide us with their data if you are allowed to do so and such personal information is correct.

If you have any comments, questions or complaints regarding the processing of your personal information, you can contact us at support@global.netease.com. Please also see the section "Contact & Complaints" below.

The Types of Personal Information We Use and Collect

Personal information, or personal data, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

This section describes the different types of personal information we collect about you and how we collect it. We will collect and use the following information about you:

Information you give us. You give us information about you (either directly or through a third party):

(i)
when you register for the Platform using your details in order to set up and secure a Platform account (including your email address, account name/nickname, country/region, date of birth, password and security questions) or when you choose to bind your Platform account with your Social Media Account (we import from your connected Social Media Account your personal information which may include your name/nickname/username as it appears on your Social Media Account profile and your account ID);
(ii)
when you submit your name, date of birth, domestic citizenship or foreign status information for age verification or compliance with applicable laws and regulations;
(iii)
when you submit your contact details and other information about you to us, such as your name, age, phone number, email address, mailing address and purchase activities, as part of our promotional activities or when you give us feedback in customer support or participate in a survey; and
(iv)
when you subscribe to our new releases, updates or alerts and/or request marketing to be sent to you (via emails or push notifications).

Information we collect about you. We collect certain data from you when you use the Platform, including your IP address, MAC address, device information (such as device type/model, unique identifier, network data and operating system), information regarding your use of and interaction with the Platform such as date and time stamps of actions (such as installing or using the Platform), and the status of the Third-Party Application you have logged in using the Platform account. We also collect and store your data each time you interact or communicate with us, for example, when you raise support tickets or any requests or enquiries to us.
Information you generate and/or display in the course of using the Platform.You may provide additional information as part of your account profile, including your gender and profile avatar. You may also provide or generate information when you communicate or interact with other users (e.g., chat logs) in the Third-Party Applications. You acknowledge that information generated via your Platform account should not be considered private and communications within Third-Party Applications may be viewed/heard by other users. Please avoid revealing any personally identifiable or sensitive information during such communications.

We do not request any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Further, we do not request any information about criminal convictions and offences.

Cookies and Other Tracking Technologies

We may use cookies and other similar technologies to provide you the Platform and services you requested, as well as enhancing your experience on the Platform. Selected third parties may also use cookies when you access your account using Social Media Accounts, in which case you should review their cookie policy and/or privacy policy as applicable. Cookies are small files which, when placed on your device, enable us to provide certain features and functionality.

You may accept or refuse to accept all or some optional cookies we use, if any, by clicking on the "Cookies Setting" page accessible via the cookie banner displayed on our websites. However, in the event of your refusal to install all or some of our optional cookies, the Platform may be unable to operate as designed.

Your browser settings may allow you to transmit a "Do Not Track" signal when you visit various websites. Like many websites, our websites are not designed to respond to "Do Not Track" signals received from browsers. To learn more about “Do Not Track” signals, you can visit https://www.allaboutdnt.com/.

For more information about the cookies and other similar technologies we use, please see our Cookie Policy.

Please note we do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.

Children

We do not knowingly collect personal information from an individual under the age of 13 or under such higher minimum age (below which parent or guardian consent is needed to collect personal information about that individual) applying in your jurisdiction ("Child") without a parental or legal guardian consent. If you believe that we have unintentionally collected your Child's personal information without appropriate authorization, you may request the deletion of the information by contacting us at support@global.netease.com. In some cases, we may ask the user to provide us with their date of birth for age verification. If such information indicates the user is deemed a Child under the applicable law, we will not collect further personal information from the Child until a parent/guardian's verifiable consent is obtained.

How We Use Your Personal Information and Our Legal Bases of Processing

We will only use your personal information when the applicable law allows us to. Most commonly, we will use your personal information in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.
Where we have obtained your consent to the processing for one or more specific purposes (where applicable).

We have set out below how we will use your personal information and which of the legal bases we rely on to do so:

Registration Information (such as: name/nickname/username and account ID on Social Media Account, email address, account name/nickname, country/region, password, security questions, date of birth, domestic citizenship/foreign status information, and other information): We use Registration Information to set up user accounts, allow users to log-in to the Platform (and related Third-Party Applications) by using the Registration Information, maintain and secure the user accounts with us, and provide services to users. Use of Registration Information is necessary to perform our contract with you and for our legitimate interests (i.e. to keep our records updated, provide services to users and ensure the security and effective operation of the Platform).
Device Information (such as: device information including device type/model, unique identifier, network data and operating system, regional and language settings, MAC address and IP address): We use this information to provide and improve the Platform such as: (i) to record and keep track of requests from users of the Platform; (ii) to detect the user network and device status when the user is using the Platform; and (iii) to correct bugs or errors that occur when the user is using the Platform. Use of Device Information is necessary to perform our contract with you and for our legitimate interests (i.e. to keep our records updated, ensure network security and provide quality or customised services).
Contact Information (such as: name, email address, phone number and mailing address): We use this information to manage our relationship with users, send rewards, send notifications (via emails or push notifications) to users to inform them of new releases, updates and alerts, as well as our promotional activities or surveys. Use of such Contact Information is necessary for our legitimate interests (i.e. to study and understand how our users use the Platform, develop or improve the Platform and grow our business, send you rewards and details of our surveys or promotional activities, and keep you informed of latest releases and updates).
Customised User Profile (such as: gender and profile avatar): We use this information to provide customised services to users such as personal information page and allow users to customise their account profiles. Use of Customised User Profile is necessary for our legitimate interests (i.e. to provide quality or customised services and allow users to create customised profiles and interact with other users).
Usage Information (such as: saved preferences and status of Third-Party Applications logged in): We use this information to allow users to customize their preferences of settings and view the status of Third-Party Applications they have logged in using the Platform account. Please note that users' chat logs will be stored by Third-Party Applications to enable users to interact or communicate with other users in Third-Party Applications logged in via the Platform account. Use of Usage Information is necessary for our legitimate interests (i.e. to provide quality services and allow users to keep track of the history of Third-Party Applications logged in).

Please note that we may associate all of the foregoing information with your account, the device you use to access the Platform, or the email address that you use to engage with us.

In addition to the specific uses of information described above, we may use any or all of the above information to:

provide, improve and develop the Platform, including troubleshooting, data analysis, testing, system maintenance, reporting and hosting of data. Such use is necessary to perform our contract with you and for our legitimate interests (i.e. for running and developing our business, keeping the Platform updated and relevant, the provision of administration and IT services, and ensuring network security);
provide customer service to users, including to support and resolve any support tickets, requests or enquiries raised by users. Such use is necessary to perform our contract with you and for our legitimate interests (i.e. to support and resolve users' requests or enquiries, provide high quality services and enhance users' experience of using the Platform);
comply with any applicable legal obligations, including for age verification purposes where legally required; and/or
enforce any applicable terms of service, including our Terms of Use, protect or defend the Platform, our rights, the rights of our users, or others, for the purpose of combatting fraud, or to otherwise operate our business. Such use is necessary for our legitimate interests (i.e., to enforce our rights and rights of users, protect our Platform, systems and users, ensure network security and effective operation of the Platform, and prevent fraud).

If You Fail to Provide Personal Information

Where we need to collect personal information by law, or under the terms of a contract we have with you, and you fail to provide that information when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

How We Store and Share Your Personal Information

In order to perform our contract with you, your personal information will be accessible from and processed on our servers. Our servers are hosted on Amazon Web Services. Your information may be transferred to and processed in countries outside the jurisdiction you are located – for further information, please see the section "International Transfers" below.

We share your personal information with selected third parties in and outside your jurisdiction, including:

third-party vendors and service providers that provide services in support of or in connection with the Platform, such as: (i) Amazon Web Services for the purpose of hosting our servers and (ii) the providers of Third-Party Applications, for the purpose of allowing you to use your Platform account to access or log into their websites or applications;
our affiliates, with whom we share your information to provide and operate the Platform and administer our relationship with you;
law enforcement agencies, public authorities, regulators or other judicial bodies and organisations. We disclose information if we are legally required to do so, or if we have a good faith belief that such use is reasonably necessary to: (i) comply with a legal obligation, process or request; (ii) enforce our Terms of Use and other agreements, policies, and standards, including investigation of any potential violation thereof; (iii) detect, prevent or otherwise address security, fraud or technical issues; or (iv) protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (including exchanging information with other companies and organisations for the purposes of fraud protection);
professional advisers such as lawyers, bankers, auditors or insurers, with whom we may share your information to establish or protect our legal rights, property, or safety, or the rights, property, or safety of others, or to defend against legal claims; and
third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owner may use your personal information in the same way as set out in this privacy policy.

We require all third parties to respect the security of your personal information and to treat it in accordance with the applicable law.

International Transfers

We share your personal information within our affiliates and other third parties as described above, which means personal information may be stored and processed in a jurisdiction outside of the UK or EEA.

As applicable, whenever we transfer your personal information out of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information. For further details, see ICO: International data transfers (for the UK) or European Commission: Adequacy decisions (for the EEA); and/or
Where we transfer your personal information to countries that are not deemed to provide an adequate level of protection for personal information, we will use specific standard contractual clauses approved for use in the UK / EEA in accordance with the UK / EEA data protection regime which give personal information the same protection it has in the UK / EEA.

As applicable, please contact us using the contact details listed below under "Contact & Complaints" if you want further information on the specific mechanism used by us when transferring your personal information out of the UK / EEA, including obtaining a copy of the documents (such as standard contractual clauses) used to protect your information.

The Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We have information security and access policies that limit access to our systems and technology. We have also put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed, including deploying a firewall and other security measures (such as encryption) commensurate to industry standards to prevent unauthorised access to your personal information. Your personal information will remain subject to our technical and organisational controls and our policies and procedures (including this privacy policy).

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of the information transmitted from, to or via our Platform. We are not responsible for the security of information transmitted via the Internet; any transmission of your information via the Internet is at your own risk.

Data Retention

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

Your Rights

You have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay and at least within one month (though this may be extended by a further two months in certain circumstances). You will not have to pay a fee to exercise any of your rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

To exercise any of your rights, please contact us at support@global.netease.com. Please note that further information may be required to verify your identity when exercising your rights.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. If you believe we hold any other personal information about you, please contact us and complete the corresponding request form.

Portability

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process by automated means and on the basis of your consent or pursuant to our contract with you, as described in the section "How We Use Your Personal Information and Our Legal Bases of Processing" above. 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.

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 another'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).

Correction

You have the right to correct any personal information held about you that is inaccurate or incomplete. If you believe we hold any other personal information about you and that information is inaccurate or incomplete, please contact us and complete the request form, although we may need to verify the accuracy of the new data you provide to us.

Erasure

You can delete your account, or remove certain personal information. If there is any other personal information you believe we process that you would like us to erase, please contact us and complete the request form.

You may request that we erase the personal information we hold about you in the following circumstances:

you believe that it is no longer necessary for us to hold such personal information;
you believe the personal information we hold about you is being unlawfully processed by us;
where you have successfully exercised your right to object to processing (see "Objection" below); or
where we are required to erase your personal information to comply with applicable laws.

You can also exercise your right to restrict our processing of your personal information (as described below) 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 Platform and there are grounds for erasure, we will use reasonable steps to try to tell others that are processing or displaying the personal information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only

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 defence of legal claims or for another'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.

You may request we stop processing and just store the personal information we hold about you where:

you believe the personal information is not accurate for the period it takes for us to verify whether it is accurate;
the processing we are doing is unlawful but you oppose the erasure of the personal information and request restriction of their use instead; or
it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims; or
you have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use it.

Objection

You have the right to object to our processing of personal information about you where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Withdrawal of consent

You have the right to withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (such as when we temporarily suspend the Platform 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.

Contact & Complaints

The Data Controller for the Platform is EXPTIONAL PTE. LTD.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance. This is without prejudice to your right to lodge a claim or complaint with the relevant data protection authority in the jurisdiction in which you live or work where you think we have breached data protection laws.

Our Contact Information

Name: EXPTIONAL PTE. LTD.
E-mail: support@global.netease.com
Postal address: Level 35, The Gateway West, 150 Beach Road, Singapore

For EEA data subjects, please note that we have appointed Prighter as our representative in the EEA to act as a point of contact for any enquiries, concerns or requests regarding this privacy policy or the processing of your personal information. You can contact Prighter via the contact details set out below:

Art 27 GDPR representative

PrighterGDPR-Rep by Maetzler Rechtsanwalts GmbH & Co KG

c/o EXPTIONAL PTE. LTD.

Address: Schellinggasse 3/10, 1010 Vienna, Austria

Website: https://prighter.com

Please add the following subject to all correspondence: ID-14363821546

For UK data subjects, please note that we have appointed Prighter as our representative in the UK to act as a point of contact for any enquiries, concerns or requests regarding this privacy policy or the processing of your personal information. You can contact Prighter via the contact details set out below:

Art 27 UK-GDPR representative

PrighterUK-Rep by Prighter Ltd

c/o EXPTIONAL PTE. LTD.

Address: 20 Mortlake Mortlake High Street, London, SW14 8JN, UNITED KINGDOM

Website: https://prighter.com

Please add the following subject to all correspondence: ID-14363821546

Changes to This Privacy Policy

We keep our privacy policy under regular review and may update the policy from time to time as the Platform or our privacy practices change, or as required by law or regulation. This version was last updated and is effective as of May 29, 2023 – please refer to "Latest Update / Effective Date" at the top of this page.

If we make any material changes to this policy, we will post the updated policy here and we may notify our users through their account. Please check this page frequently to see any updates or changes to this policy.

Language

This privacy policy may be translated into the local language in the relevant territory. In the event of a conflict between this privacy policy in the English language version and the localised version, the English language version shall prevail.

Jurisdiction-Specific Terms for Jurisdictions Outside the UK/EEA

If you reside outside the UK/EEA, you may have specific privacy rights in your jurisdiction. If you are a citizen or habitual resident of the applicable jurisdiction described below, the following jurisdiction-specific terms will supplement, and should be read together with, this privacy policy. In the event of a conflict between the Jurisdiction-Specific Terms that are relevant to your jurisdiction and the rest of the privacy policy, the relevant Jurisdiction-Specific Terms shall prevail.

Please note that nothing in this privacy policy shall confer, and nor shall it be interpreted to confer, any additional rights or obligations that go beyond what is mandated by the relevant applicable data protection laws in a non-UK/EEA jurisdiction.

Australia

1.

International Transfers

(a)

Add the following paragraph:

We may disclose your personal information to overseas recipients including in the following countries/regions: Singapore, Japan, Canada, and the United States.

2.

Your Rights

(a)

The section "Your Rights" is replaced in its entirety as follows:

You have certain rights to make requests to us in relation to the personal information we hold about you. Some of these rights only apply in certain circumstances (as set out in more detail below). We must respond to a request by you to exercise those rights without undue delay. We will endeavour to respond to you within 30 days of request of a request. In some circumstances we may be entitled to or required to refuse your request.

To exercise any of your rights, please contact us at support@global.netease.com. Please note that further information may be required to verify your identity when exercising your rights.

Access

You have the right to request access to personal information we hold about you.

Correction

You have the right to request that we correct any personal information held about you that is inaccurate, out-of-date, incomplete, irrelevant or misleading.

Withdrawal of consent

You have the right to withdraw consent at any time where we are relying on consent to process your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

3.

Contact & Complaints

(a)

Add the following paragraph:

We will investigate any complaint you make to us regarding our handling of your personal information and will use reasonable endeavours to respond to you in writing within 30 days of receiving the written complaint. If you are dissatisfied with our response to your complaint, you have the right to make a complaint to the Office of the Australian Information Commissioner.

Brazil

1.

Your Rights

(a)

The section "Your Rights" is replaced in its entirety as follows:

Brazilian users are entitled the following rights under Brazilian Data Protection Law (Law No. 13,709/2018 or "LGPD"):

Right to Confirmation of data processing activities performed by Platform in connection with their personal data;

Right to Access to the data Platform has available about them;

Right to Rectify data that Platform has available about them;

Right to Anonymization, Restriction to the processing or Elimination of personal data, to the extent that they believe that such data is no longer necessary or is excessive for the purpose for which Platform informed, or, additionally, when Platform believe that the data processing activities in connection with such data are not in accordance with data protection laws;

Right to Erase personal data that Platform process based on consent, except in those cases where the law provides for exceptions to this right;

Right to Information on third parties with whom their personal data has been shared;

Right to Information on the possibility of not giving consent and the consequences thereof;

Right to Review decisions made based solely on automated data processing;

Right to Portability of personal data;

Right to Withdraw consent at any time, where consent has been provided;

Right to Object to the processing, where the processing is not based on consent, and the processing is unlawful;

Right to Bring a claim before the Data Protection Authority ("ANPD") against Platform (https://www.gov.br/anpd/pt-br).

2.

Contact & Complaints

(a)

Add the following paragraph:

For data subjects in Brazil, please note that we have appointed a Person in Charge to act as a point of contact for any enquiries, concerns or requests regarding this privacy policy or the processing of your personal information. You can contact Lei Jiang, Legal Department at support@global.netease.com.

Canada

1.

International Transfers

(a)

Add the following paragraph:

Your personal information may be stored and processed in jurisdictions in which we have affiliates and/or in which we engage the third-party vendors and service providers, such as Singapore, Japan, Canada, and the United States.

2.

Your Rights

(a)

The section "Your Rights" is replaced in its entirety as follows:

You have certain rights in relation to the personal information we hold about you.

Access

You have the right to access personal information we hold about you.

Withdrawal of consent

You have the right to withdraw consent at any time where we are relying on consent to process or disclose your personal information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

Correction

You have the right to correct any personal information held about you that is inaccurate or incomplete. If you believe we hold any other personal information about you and that information is inaccurate or incomplete, please contact us at support@global.netease.com and complete the request form, although we may need to verify the accuracy of the new data you provide to us.

3.

Contact & Complaints

(a)

Add the following paragraph:

To contact us or make a complaint if you are in Canada, please contact us as follows:

Attn: Lei Jiang, Legal Department

E-mail: support@global.netease.com

Postal address: Level 35, The Gateway West, 150 Beach Road, Singapore

Hong Kong

1.

Direct Marketing

(a)

We intend to use your name and contact information to provide direct marketing to you in relation to games and other related goods and services, and we require your consent for that purpose. We also intend to provide your name and contact information to our affiliates in order to enable them to direct market to you the same types of goods and services, and we require your written consent for that purpose.

2.

If You Fail to Provide Personal Information

(a)

Add the following sentence at the beginning of the section:

Your provision of personal information is voluntary.

3.

Your Rights

(a)

The section "Your Rights" is replaced in its entirety as follows:

You have the right to ascertain whether we hold personal information about you and request access to such personal information. You also have the right to correct any personal information held about you that is inaccurate or incomplete.

To exercise any of your rights, please contact Lei Jiang, Legal Department at support@global.netease.com. Please note that further information may be required to verify your identity when exercising your rights.

4.

Changes to This Privacy Policy

(a)

The section "Changes to This Privacy Policy" is replaced in its entirety as follows:

We keep our privacy policy under regular review and may update the policy from time to time as the Platform or our privacy practices change, or as required by law or regulation. This version was last updated and is effective as of May 29, 2023 – please refer to "Latest Update / Effective Date" at the top of this page.

If we make any material changes to this policy, we will post the updated policy here and we may notify our users through their account and/or obtain their consent if required by applicable law. Please check this page frequently to see any updates or changes to this policy.

New Zealand

1.

Your Rights

(a)

The section "Your Rights" is replaced in its entirety as follows:

You have the right to request access to, and correction of, your personal information by contacting us at the contact details notified above.

Philippines

1.

Introduction

(a)

Add the following paragraph:

To the extent that the processing of your personal information is subject to Philippines law, please note that the applicable data privacy laws shall include the Philippine Data Privacy Act of 2012, its Implementing Rules and Regulations, and the issuances of the Philippine National Privacy Commission.

2.

How We Use Your Personal Information and Our Legal Bases of Processing

(a)

Add "We also rely on your consent, if required by applicable law." at the end of each of the two bullet points regarding Registration Information and Customised User Profile.

3.

Your Rights

(a)

The section "Your Rights" is replaced in its entirety as follows:

Under Philippine law, you have certain rights in relation to the personal information that we hold about you, including the right to obtain information regarding the processing of your personal information, request access to the personal information that we hold about you, request rectification of your personal information, request erasure of your personal information, request data portability, and object to the processing of your personal information. Please note that these rights may be limited under the applicable law.

If you would like to exercise the above rights, you may contact us using the information indicated above in "Contact & Complaints". You also have the right to lodge a complaint with the Philippine National Privacy Commission and seek indemnification if you think any of your rights have been infringed by us.

Singapore

1.

Your Rights

(a)

Add the following sentence to this section:

We will respond to the exercise of your specific privacy rights in accordance with applicable data protection laws.

Switzerland

1.

International Transfers

(a)

The section "International Transfers" is replaced in its entirety as follows:

We share your personal information within our affiliates and other third parties as described above, which means personal information may be stored and processed in a jurisdiction outside the UK, EEA or Switzerland.

Whenever we transfer your personal information out of the UK, EEA or Switzerland, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will transfer your personal information to countries that have been deemed to provide an adequate level of protection for personal information. For further details, see ICO: International data transfers (for the UK) or European Commission: Adequacy decisions (for the EEA) or EDöB: Adequacy decisions (for Switzerland); and/or
Where we transfer your personal information to countries that are not deemed to provide an adequate level of protection for personal information, we will use specific standard contractual clauses approved for use in the UK / EEA / Switzerland in accordance with the UK / EEA / Switzerland data protection regime which give personal information the same protection it has in the UK / EEA / Switzerland. For transfers out of Switzerland we use the standard contractual clauses issued by the EU Commission with the Swiss local law amendments.

Please contact us using the contact details listed below under "Contact & Complaints" if you want further information on the specific mechanism used by us when transferring your personal information out of the UK / EEA / Switzerland, including obtaining a copy of the documents (such as standard contractual clauses) used to protect your information.

United States

1.

Cookies and Other Tracking Technologies

(a)

The third paragraph shall be amended as follows:

Your browser settings may allow you to transmit a "Do Not Track" signal when you visit various websites. Except where required by law or where we voluntarily decide to do otherwise, our websites are not designed to respond to "Do Not Track" signals received from browsers. To learn more about "Do Not Track" signals, you can visit https://www.allaboutdnt.com/.

2.

Information for California Residents

(a)

Please see the main body of our privacy policy above for our Notice at Collection. We may collect the following categories of personal information and sensitive personal information, as these terms are defined in the California Consumer Privacy Act:

Category Examples
Identifiers A name, account name, nickname, username, profile avatar, account ID, device ID, device type/model, network data and operating system, IP address, MAC address, email address, IP address, mailing address, password, security question.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) A name, mailing address, and telephone number. Some personal information included in this category may overlap with other categories.
Protected classification characteristics under California or federal law Age (date of birth) or national origin.
Geolocation data Approximate location derived from IP address, cell-ID, and Wi-Fi connection location.
Electronic information Information you provide directly or through your interactions with our Platform (device type/model, network data and operating system, date and time stamp of actions, saved preferences and status of Third-Party Applications logged in).
Category of sensitive personal information Examples
Racial or ethnic origin, gender (gender expression or gender identity) or other sensitive Personal Information, where a user voluntarily makes such information available to us, even if we do not expressly request such information Gender (gender expression or gender identity), racial or ethnic origin
Log-in credentials Email address, account name/nickname, password and security questions
(b)

If you reside in California, please see our California Privacy Policy and Notice of Right to Opt-out of Sale/Sharing here.

3.

Information for Colorado Residents

(a)

As of July 1, 2023, Colorado residents acting as consumers have the following rights under the Colorado Privacy Act, subject to the conditions therein:

(i)
Confirm whether or not EXPTIONAL is processing the consumer's personal data and to access such data;
(ii)
Correct inaccuracies in the consumer's personal data, taking into account the nature of the personal data and the purposes of the processing of the consumer's personal data;
(iii)
Delete personal data concerning the consumer;
(iv)
Obtain a copy of the consumer's personal data that the consumer previously provided to EXPTIONAL in a portable, and to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another entity without hindrance; and
(v)
Opt-out of the processing of the consumer's personal data for the purposes of: (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
(b)

If you are a resident of Colorado, you may exercise these rights by contacting us at support@global.netease.com. We may request information from you to verify your identity; for example, we may ask you to login to your account with us or ask you to provide information that we have on file and which we can use to authenticate you. You may also designate an authorized agent to submit a request to exercise your rights on your behalf; in this case, we may ask you for information to verify your identity and that you have authorized the agent to act on your behalf.

(c)

If we decline to take an action regarding your request, we will inform you of such, including the justification for declining to take action and instructions on how to appeal the decision. We will inform you of any action or inaction taken in response to such appeal. If the appeal is denied, you may contact the Colorado Attorney General to submit a complaint.

4.

Information for Connecticut Residents

(a)

As of July 1, 2023, Connecticut residents acting as consumers have the following rights under Connecticut law, subject to the conditions therein:

(i)
Confirm whether or not EXPTIONAL is processing the consumer's personal data and to access such data;
(ii)
Correct inaccuracies in the consumer's personal data, taking into account the nature of the personal data and the purposes of the processing of the consumer's personal data;
(iii)
Delete personal data provided by, or obtained about, the consumer;
(iv)
Obtain a copy of the consumer's personal data processed by EXPTIONAL in a portable, and to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another controller without hindrance, where the processing is carried out by automated means; and
(v)
Opt-out of the processing of the consumer's personal data for the purposes of: (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of solely automated decisions that produce legal or similarly significant effects concerning the consumer.
(b)

If you are a resident of Connecticut, you may exercise these rights by contacting us at support@global.netease.com. We may request information from you to verify your identity. If we decline to take an action regarding your request, we will inform you of such, including the justification for declining to take action and instructions on how to appeal the decision. We will inform you of any action or inaction taken in response to such appeal. If the appeal is denied, you may contact the Connecticut Attorney General to submit a complaint.

5.

Information for Nevada Residents

(a)

Nevada law gives Nevada residents the right to direct a company to not sell certain of their personal information. This right applies even if their personal information is not currently being sold. If you are a Nevada resident and wish to exercise this right, please submit a "Do not sell your personal information request" by contacting us at support@global.netease.com.

6.

Information for Utah Residents

(a)

As of December 31, 2023, Utah residents acting as consumers have the following rights under the Utah Consumer Privacy Act, subject to the conditions therein:

(i)
Confirm whether or not EXPTIONAL is processing the consumer's personal data and to access such data;
(ii)
Delete personal data that the consumer provided to EXPTIONAL;
(iii)
Obtain a copy of the consumer's personal data that the consumer previously provided to EXPTIONAL in a format that: (1) to the extent technically feasible, is portable; (2) to the extent practicable, is readily usable; and (3) allows the consumer to transmit the data to another controller without impediment, where the processing is carried out by automated means.
(iv)
Opt-out of the processing of the consumer's personal data for the purposes of: (i) targeted advertising, or (ii) the sale of personal data.
(b)

If you are a resident of Utah, you may exercise these rights by contacting us at support@global.netease.com. We may request information from you to verify your identity. If we decline to take an action regarding your request, we will inform you of such, including the justification for declining to take action and instructions.

7.

Information for Virginia Residents

(a)

Virginia residents acting as consumers have the following rights under the Virginia Consumer Data Protection Act, subject to the conditions therein:

(i)
Confirm whether or not EXPTIONAL is processing the consumer's personal data and to access such data;
(ii)
Correct inaccuracies in the consumer's personal data, taking into account the nature of the personal data and the purposes of the processing of the consumer's personal data;
(iii)
Delete personal data provided by or obtained about the consumer;
(iv)
Obtain a copy of the consumer's personal data that the consumer previously provided to EXPTIONAL in a portable, and to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another controller without hindrance, where the processing is carried out by automated means; and
(v)
Opt-out of the processing of the consumer's personal data for the purposes of: (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.
(b)

If you are a resident of Virginia, you may exercise these rights by contacting us at support@global.netease.com. We may request information from you to verify your identity. If we decline to take an action regarding your request, we will inform you of such, including the justification for declining to take action and instructions on how to appeal the decision. We will inform you of any action or inaction taken in response to such appeal. If the appeal is denied, you may contact the Virginia Attorney General to submit a complaint.