Privacy Policy

Effective Date of Privacy Policy: July 1st, 2025

Preamble

This SILOT Privacy Policy is designed to assist you in understanding our practices regarding the collection, use, sharing, and protection of personal data. Within this privacy statement, "SILOT" refers to SILOT (HONG KONG LIMITED). We may also refer to SILOT as "we". This privacy statement applies when you visit our website, play games linked to this declaration, or otherwise access any of our other products and/or services, mobile applications, or any other applicable platforms and/or devices ("Services").

1. Personal Information

We Collect SILOT may collect personal information in accordance with this privacy statement to fulfill one or more specific functions or activities.

A. Personal Data You Provide Directly to Us

You may directly provide information to us in the following ways when you use our Services (including through social networks):

  • Establishing your personal account;
  • Participating in social media;
  • Engaging in group discussions or chat;
  • Communicating with customer service agents and account managers;
  • Participating in conferences, conventions, and other events.

The information you share with us may include:

  • Your age or birthday;
  • Your name and/or surname;
  • Your email address;
  • A password to access our Services;
  • Information about your account, the games you are playing with us, and/or the device you are using to access our Services and/or other information about your requests or inquiries;
  • Additional information to help us ensure it is you accessing your account, including the information we need to provide you with requested support or information you provide to help us improve our services (such as questionnaires from online surveys or feedback forms).

While using our Services, you may also choose to create a player profile visible to other SILOT players. You may include the following information in your player profile:

  • A photo;
  • A gaming username;
  • Personal details (such as age and/or gender);
  • Approximate location information;
  • Links to your personal profiles on one or more social networks;
  • Detailed information about your gaming settings (such as your game progress or rewards obtained).

B. Personal Information We Obtain from Third Parties

We may collect information about you from third parties, including app stores, third-party login services, and third-party applications where you play games through social networks. This information, along with information you provide directly to us, is used for the purposes described in this privacy statement, such as helping you connect with friends or pushing personalized advertisements based on your interests.

When you play SILOT's games through third-party applications (including social networks like Facebook) or access our other services or associate our services with third-party applications, SILOT may receive certain information from these third-party application providers. The type of information we receive depends on the SILOT game you play, the third-party application used, and your and your friends' privacy settings (where applicable).

For example, SILOT may collect and store all or part of the following information shared by third-party applications:

  • Your name;
  • Your photo in the personal profile or its link;
  • User identity number (such as a Facebook user ID), which may be associated with your name, personal profile photo, and information that identifies your friends;
  • Your friends list, which may include user IDs, names, and personal profile photos, among other information;
  • The email address used to log into the third-party application;
  • Exact location data for you and the device accessing the service;
  • Gender;
  • Date of birth and/or age range;
  • Information about your activities within the third-party application or information obtained through it;
  • Other information you share within the third-party application;
  • Other information you or the third-party application provider share with SILOT.

If you access our services through a third-party application or link our services with a third-party application, you should also review and understand the terms of service and privacy policy of that third-party application.

If you have questions about the information shared with us by third-party applications, please visit these third-party applications directly to learn more about their privacy practices.

C. Cookies

Like most websites, cookies may be sent to your device when you visit or browse our Services. Cookies are small data files stored on your device to record information. The information in cookies may be associated with your personal information. We use cookies to improve the quality of SILOT services and enhance user experience.

For more information on how to opt out or disable cookies, please refer to the “4. Your Rights and Choices” section below.

D. Payment Information Processing

When you make purchases using SILOT's services, basic transaction information may be processed through third-party platforms or stores (such as Facebook, Apple, or Google), including purchases you make within social network games or games downloaded to your mobile device. Our terms of service provide detailed explanations about policies and regulations regarding charges, billing methods, third-party credits, and virtual currencies.

When you purchase virtual currency or items within our SILOT gaming platform, our third-party payment processors will collect and process the billing and payment information necessary for the transaction. This may include your mailing address, email address, and/or details of your payment method. SILOT's payment processors will collect, process, store, and share information related to your purchase in accordance with the appropriate level of PCI-DSS standards.

2. How We Use Personal Data

SILOT uses personal data for a variety of business purposes, as indicated in this privacy statement, including but not limited to fulfilling contractual obligations, processing your transaction requests, complying with legal requirements, and other legitimate business uses, as follows:

  • Creating gaming accounts to enable your participation in our games;
  • Managing and optimizing our services, as well as enhancing player experience, which includes assessing engagement and interest in our services;
  • Processing payment card and/or other financial information to complete your in-game purchases;
  • Personalizing our services, including recommending connections between players and converting social media contacts into in-game connections;
  • Facilitating communication among players;
  • Providing technical support and responding to player inquiries;
  • Confirming and/or verifying identity information;
  • Ensuring the safety and well-being of players;
  • Protecting the rights and property related to SILOT and its services;
  • Resolving technical issues, maintaining and/or improving network and information security;
  • Conducting audits, ensuring internal quality control and taking safety precautions;
  • Preventing, investigating, and/or prosecuting fraud or potential illegal activities, and strictly enforcing our terms of service;
  • Informing players about game updates, new products, content, or promotional activities;
  • Complying with legal obligations, resolving disputes with players, collecting debts, and strictly enforcing our agreements;
  • Conducting research, including using personal data to create DE-identified and/or aggregated data. DE-identified and/or aggregated data is not considered personal data, and we may use and share such data for legally permissible purposes.
  • In addition to the purposes mentioned above, if you have provided SILOT with your email address, we may communicate with you and other players in various ways, including but not limited to responding to customer service inquiries, informing you and others about your gaming settings, friend comments, in-game statuses and promotional activities, and notifying you about gifts and neighbor requests. Some information (such as invitations from friends to join a game) may include your name and personal profile photo. We may also send promotional communications (hereafter referred to as "Promotional Communications") directly or through partners. For details on how to opt-out of receiving Promotional Communications, please refer to the "Your Rights" section below.

We may use technology for automated decision-making and/or profiling, including the use of artificial intelligence, to assess the personal data we collect (such as gaming activities and communications) to improve our services (such as prioritizing customer support inquiries, shortening response times, personalizing gaming experiences, and understanding trends in response to certain features in our services) and other legitimate business purposes.

Unless we have obtained your consent or the law permits, we will not use automated technologies that may have a significant legal impact on you.

We may also use personal data for any other purpose declared to you at the time of collecting your personal data or when we obtain your consent.

3. How We Share Personal Information

Under no circumstances do we share information (which may include personal information) with third parties (parties that are not SILOT) or allow third parties to collect information from our services.

We value our players' privacy and the security of personal information. We are firmly committed to not sharing your personal information with any third party. We understand the importance of this information to you and the necessity of protecting it. We adhere to strict privacy policies and security measures to ensure that your personal data is used solely to enhance your gaming experience and that it will not be disclosed, sold, or transferred to external entities without your explicit consent. Your trust is paramount to us, and we are dedicated to maintaining that trust by responsibly managing your information.

4.Data Retention

4.1 Common Data Storage

We are committed to protecting your personal information while ensuring a consistent and efficient gaming experience. We will retain your information within the bounds of the law, solely to provide and enhance our gaming services, to fulfill our legal obligations, and to maintain, exercise, or safeguard our rights.

Information Retained Until You Remove It:

In many of our services, you can correct or delete the data stored under your account. For example, you can:

  • Modify your personal information;
  • Permanently delete your game account;

We will keep such data under your account until you choose to remove it.

Data That Expires After a Set Time:

In certain cases, we store data for preset retention periods and do not offer a way to delete it. The retention period for each type of data depends on the reasons for which we collected it. Sometimes, we might extend the retention period of certain data for specific purposes, in line with business and legal requirements. For instance, when SILOT processes and disburses payments to you or when you make payments to SILOT, we may extend the retention period of such data in compliance with tax or accounting procedures.

4.2 Player Data Storage (Mexico Region)

We attach great importance to the protection of user data and strictly comply with Mexico's Ley Federal de Protección de Datos Personales en Posesión de los Particulares (LFPDPPP). The personal data generated by you during the game will be stored in accordance with the following policies:

Storage Location: We will store your personal data on servers that meet the requirements of the LFPDPPP to ensure the security and compliance of the data. The data storage location may be within or outside Mexico. If stored outside Mexico, the recipient will also assume the same data protection obligations as we do to ensure that your data rights and interests are not compromised.

Storage Period: We will only retain your personal data for the period necessary to achieve the purposes of data collection and within the period permitted by applicable laws. When the data storage period expires or is no longer needed for the original purpose, we will delete or anonymize your personal data in a secure manner in accordance with the provisions of the LFPDPPP.

Data Security Measures: To prevent your personal data from unauthorized access, disclosure, alteration or destruction, we have implemented a series of strict technical and organizational security measures that meet the requirements of the LFPDPPP for data security assurance. These include, but are not limited to: encrypting data, setting access permission controls, regularly backing up data, and continuously monitoring the security of data storage systems.

5. Your Rights and Choices

Depending on the legal jurisdiction in which you reside, you may have the right to request from SILOT regarding data related to you that we process, such as the right to:

  • Request information;
  • Access data;
  • Correct (or update) personal data that you believe is incorrect;
  • Delete (or erase) data;
  • Receive a copy (or portability) of the data;
  • You may also object to certain types of data processing, including opting out of targeted advertising. SILOT allows all players to make these requests through the SILOT privacy portal website or via accessible help pages within the game.

A. Managing Information Obtained from Platforms

To manage information that SILOT receives from third-party platforms you play on (such as Facebook, Apple, Amazon, etc.), you need to follow the guidelines of the relevant third-party applications to update your information and modify your privacy settings.

B. Opting Out of Promotional Communications

If you do not wish to receive promotional information from SILOT, you can click the "unsubscribe" link in any SILOT promotional email. If you wish to stop receiving our SMS or text messages, you can use the "unsubscribe" link or reply with "STOP" in any promotional message. Please note that it may take some time to process your opt-out request.

C. Opting Out of Receiving Information on Facebook

If you do not want to receive information through our gaming pages on Facebook, you can turn off all information through the "Settings" on your Facebook account.

D. Opting Out of Push Notifications

You can choose whether to receive push notifications when you install our applications, which are messages sent to your device even when the app is closed. You can go to the "Settings" page on your mobile device to turn off notifications.

E. Opting Out of Cookie Tracking

You can set your web browser to warn you before placing cookies on your computer or to restrict the types of cookies allowed. The way flash cookies work is different from browser cookies, and the tools provided by your browser to manage cookies will not remove flash cookies. To learn more about flash cookies and how to manage them, you can visit the Adobe website and change the Global Privacy Settings Panel. If you disable cookies, you may lose access to certain features and functionality of our services, as cookies are necessary to provide the service.

F. Do Not Track

Some browsers have incorporated "Do Not Track" (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Please be aware that SILOT currently does not respond to Do Not Track (DNT) signals, regardless of whether the signal is sent from a computer or mobile device.

6. Child Privacy Protection

According to our terms of service, users under the age of 18 are not permitted to use our services.

SILOT is committed to complying with laws related to the protection of children. If you suspect that your child has provided personal information to SILOT without your consent, please contact us at spincraze777@gmail.com. SILOT will take appropriate steps to remove such information promptly.

7. Updates

SILOT reserves the right to update this privacy policy at any time and recommends that you review it regularly for any changes.

Should we make significant changes to our privacy policy, we will notify you and other users before these changes take effect by posting a notice in the game or, as legally required, using the email address you have provided to send you notifications. We will also post these notices on our game blog, social media pages, and/or forums. You can regularly visit www.game-champion.com and our privacy policy page for the latest information.

Please note that the website www.game-champion.com is used as an example and may need to be replaced with the actual website used by SILOT for posting privacy policy updates.

8. U.S. State Law Supplements

The following information is a supplement to the Privacy Statement and applies to consumers in certain U.S. states (including California and Virginia) in accordance with applicable state laws.

California Privacy Rights Act (CPRA)

As a resident of California, you are entitled to certain privacy rights granted by the California Privacy Rights Act (CPRA). We are committed to explaining in a fully transparent manner how we collect, use, disclose, and protect your personal information and ensuring that you can fully exercise your privacy rights.

Notice at Collection At or before the point of collecting personal information, you have the right to be informed about our practices, including the categories of personal and sensitive personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared, and the retention period for such information. You can find these details within this Privacy Policy by clicking on the link above.

Right to Know You have the right to request disclosure of the personal information we collect about you. You also have the right to request additional information about our collection, use, disclosure, or sale of such personal information. Please note that many such details have already been provided in this Privacy Policy. You can make such "right to know" requests by contacting spincraze777@gmail.com.

Right to Delete In certain circumstances, you also have the right to request the deletion of your personal information, subject to many exceptions. To make a deletion request, you can email us at spincraze777@gmail.com.

Right to Opt-Out/Do Not Sell or Share My Personal Information You have the right to opt-out of future "sales" or "sharing" of your personal information, as those terms are defined by the CCPA.

Right to Limit Use and Disclosure of Sensitive Personal Information You have the right to limit our use of your sensitive personal information for purposes other than providing the goods or services you requested or other purposes permitted by law. We collect and process the content of your communications on our services to facilitate such communications, to provide customer service, and to respond to complaints of violations of our terms of service. If you have any questions about our use of such sensitive personal information, please contact us using the contact information provided at the bottom of this policy.

Authorized Agent You may designate an authorized agent to act on your behalf to exercise your CCPA rights by written permission or power of attorney. Before accepting a request from an agent, we will require proof that you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

Verification of Identity Additionally, to provide, correct, or delete specific personal information, we need to verify your identity to the extent required by law. We will verify your request by asking you to send the request from the email address associated with your account or to confirm the request or by requiring you to provide information necessary to verify your account.

Virginia Consumer Data Protection Act (VCDPA)

As a resident of Virginia, you are entitled to certain privacy rights granted by the Virginia Consumer Data Protection Act (VCDPA). We are always committed to articulating in a clear and transparent manner how we collect, use, disclose, and protect your personal information, ensuring that you can fully exercise your privacy rights.

Notice at Collection At or before the point of collecting personal information, you have the right to be notified about our practices, including the categories of personal information and specific types of sensitive personal information to be collected, the purposes for collecting or using such information, whether such information will be disclosed, and the retention period for the information. You can review these details within this Privacy Policy.

Right to Know You have the right to request disclosure of the personal information we collect about you, and you also have the right to request further information about our collection, use, disclosure, or sale of such personal information. Please note that much of this information is already provided in this Privacy Policy. You can make "right to know" requests by sending an email to spincraze777@gmail.com.

Right to Delete In certain circumstances, you have the right to request that we delete your personal information, but be aware of some exceptions. To make a deletion request, you can email us at spincraze777@gmail.com.

Right to Limit Disclosure You have the right to limit our disclosure of your personal information to third parties unless required by law. We only disclose personal information to the extent necessary to provide services or fulfill legal obligations.

Right to Data Portability You have the right to request a copy of your personal information in a portable, structured format to enable you to transfer this information to another service provider.

Special Protection for Sensitive Personal Information We take extra precautions in protecting sensitive personal information. We only use sensitive personal information to provide the services or goods you requested or for other purposes permitted by law. If you have any questions about our use of sensitive personal information, please contact us using the contact information provided in this policy at spincraze777@gmail.com.

Authorized Agent You may designate an authorized agent to exercise your VCDPA rights on your behalf by written permission or power of attorney. Before accepting a request from an agent, we will require proof that you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

Verification of Identity To provide, correct, or delete specific personal information, we need to verify your identity to the extent required by law. We will verify your request by asking you to send the request from the email address associated with your account or to confirm the request or by requiring you to provide information necessary to verify your account.

In the past 12 months, we have not sold or shared any of the categories of personal information mentioned above. To opt-out of the "sale" or "sharing" of personal information, please use the global privacy control features described in this document, or send your request via email to spincraze777@gmail.com. We do not knowingly sell the personal information of minors under the age of 16.

9. Contact Us

If you have any questions, comments, or concerns regarding our Privacy Policy or any other privacy-related matters, please contact us via email at spincraze777@gmail.com, or write to us at UNIT 225-22, 2/F, MEGA CUBE, 8 WANG KWONG ROAD, KOWLOON BAY, KL, Hong Kong.