Privacy Policy

Version effective date: July 10, 2023 BULE POINT LIMITED and its affiliates (collectively, " BULEPOINT ", "we" or "our") develop, publish and operate Coin Of Clans game for the mobile environments (the "Game") as well as mobile applications (each, an "App", Game and Apps collectively referred to as "Services") )for playing our Games across multiple devices and platforms. BUlEPOINT respects the privacy of you (referred to as "you", "user" or "player") and is committed to making our practices regarding your data more transparent and fair. This Privacy Policy describes how we collect, store, use and share your Personal Data, and it applies to when you install our Apps and play the game, interact with us or otherwise access or use our Services. Please pay special attention: This Privacy Policy applies to the Services provided by BUlEPOINT, and does not apply to other products or services provided by third parties ( "third-party services"). Before using third-party services, you should fully understand the product functions and privacy policies of third-party services. By using BUlEPOINT's Services, you agree to this Privacy Policy. If you do not agree to this Privacy Policy, please do not use our Services.

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE YOU USE OUR SERVICES.

This Privacy Policy may change from time to time, so please check regularly to ensure you are aware of any changes. If we make material changes to this Privacy Policy, we will notify you by posting an update to the game or this Privacy Policy and, if necessary, provide you with additional choices regarding such changes prior to the changes become effective. Your continued use of BUlEPOINT's Services will constitute your acceptance of these changes. You have the right to cease using our Services, pursuant to this Privacy Policy at any time. Please kindly be noted that you are free to decide whether to provide your Personal Data to us or not, but disagreement on your side, to some degree, may adversely affect your user experience of our Services.

1. How do we collect and use your Personal Data

2. How do we share and disclose your Personal Data

3. How do we protect your Personal Data

4. How do we store, retain and delete your Personal Data

5. How do we use tracking technologies such as cookies

6. Advertising and Communications

7. Protection of Children's Personal Data

8. Revision and version control

9. Data Subject Rights

10. Contact us

1. How we collect and use your Personal Data

1.1 Data collection The ultimate purpose of our collection of your data is to provide you with better Services, optimize and enrich your user experience. We collect four main categories of data:

1.1.1 Data automatically Collected or Generated We may collect or generate technical data about people when they visit, interact with or use our Services, including any e-mail or text messages sent to them by us or via our Services. We collect or generate this data either independently or with the help of third-party services, including through the use of "cookies" and other tracking technologies (as further detailed below). Such data includes connectivity, technical or aggregated usage data such as IP addresses, in-game identifiers, game statistics, game preferences, unique advertising ID (e.g. IDFA; you may reset such IDs based on the operating system instructions), non- Identify data regarding a device, operating system, browser or App version, mobile operator, locale and language settings, user activity on our Services, in-App or game activity (such as game play content/product interactions and advertising data) ; diagnostic data (i.e. crash data and game performance data). We do not use such data to learn a person's true identity or contact details, but mostly to have a better understanding on how our users typically use and engage with our Services. The use of such technical and device data also helps us and our partners deliver interest-based or otherwise more effective advertisement and content, optimize our ad management and users' viewing experience, and improve the overall performance and your user experience of our Services . For more information about our advertising purposes, please see "VI. Advertising and Communications" in this Privacy Policy.

1.1.2 Data received from you You may voluntarily provide us with Personal Data, such as when you set up an account with us, contact us (via Facebook, Messenger, e-mail, in-game chat or any other channel, including any support services), when you post on our public forums or groups, when you provide us with your e-mail address, when you enter contests, tournaments and other promotions, when you place any purchases in our game, when you interact with other users via the in-game chat, or When you choose to connect your Facebook, Google, Apple or similar account to the Game.

1.1.3 Data received from Facebook and other channels Once you connect the game to your Facebook, Google, Apple or similar account, we will receive access to your public profile, including (to the extent you define it as "public"), as applicable, your Full name, e-mail address(es) provided to Facebook, Google or Apple, gender, profile picture or similar photo, location, time zone, and a list of your friends playing the game(along with their photos and other public profile information). This will also allow us to present your and your friends’public profile pictures inside the Game and create your in-game friends list. In addition, we or our advertising partners may receive general information from Facebook and our other marketing channels about the performance of our advertising campaigns, such as targeted age groups or interests, and we or our partners may be able to associate such general data with link such general data to any other data in our possession. To learn more about our advertising practices, please see "VI. Advertising and Communications" in this Privacy Policy. If you access our Services through a third party such as Facebook, Google or Apple, or connect our Services to any third party account, you should also read their terms and conditions and privacy policy. If you are unclear about what information a third-party applications has shared with us, please visit the third-party applications's website to learn more about their privacy practices.

1.1.4 Transaction Data In-game purchases will typically be processed by the relevant platform provider (e.g. Apple, Google or Facebook) and we will not collect or store your financial data, such as your credit card number or bank account. However, we may still receive non-financial Personal Data related to your purchases, such as your name, billing address, e-mail address and items purchased, in order to fulfil your purchases and for our accounting purposes.

1.2 Data use Our legal basis for collecting and using your Personal Data will depend on the particular purpose for which your data is processed, however, we generally use the following:

1.2.1 Performance of the contract. On this basis, we will perform the necessary processing to make games, including social gameing when you choose to log in with Facebook, Google or Apple, and support services, available to you, and to send you service communications, gifts and rewards.

1.2.2 Consent. If you accept cookies on our sites, we will process your Personal Data based on your consent. You can withdraw your consent at any time by contacting us with the details in use.

1.2.3 Legitimate interests. We will process your Personal Data based on our legitimate interests in maintaining and improving our Services and offerings, understanding how our Services are used, serving effective advertisements within our Game and through other channels, matching users to create in-game friends lists, improving our customer service and support operations, fraud detection and protecting and securing our users, ourselves and our Services.

1.2.4 Compliance with legal obligations.In limited cases we may process your Personal Data where we need to do so to comply with a legal obligation e.g. which is set out in an applicable law, or if we receive an order from a court or regulatory body. The purposes for which we use Personal Data are described in more detail below:

2. How we share your Personal Data

2.1 We may share your data with certain third parties, including law enforcement agencies, our service providers and our affiliates. The circumstances in which we share data are summarized as follows:

2.1.1 Compliance with laws, legal orders and authorities: We may disclose or allow government and law enforcement officials to access certain Personal Data in response to subpoenas, search warrants or court orders (or similar requests), or to comply with applicable laws and regulations, Including for national security purposes. Such disclosure or access may occur with or without notice to you, provided we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with our efforts to investigate, prevent or take action regarding actual or suspicious illegal activities, fraud or other wrongdoing.

2.1.2 Service Providers: We may engage selected third-party companies, contractors and individuals to provide services complementary to our own Services (such as hosting services, data analysis services, marketing agencies and advertising services and tools, data and cyber security services, fraud detection and prevention services, payment processing services, customer support partners, external auditors and testers, user engagement services, e-mail distribution and monitoring services, session recording, and our business, legal, financial and Compliance Advisors) (collectively, "Service Providers"). These service providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and complementing our Services, and may process your Personal Data only for the purposes for which we instruct them. We may also share anonymously, statistical or aggregated information with our service providers for legitimate business purposes.

2.1.3 Third-party integrations: The Services allow you integrate with certain third party services, such as in order to connect your Facebook, Google or Apple account to a certain Game, Login with Google, Facebook or sign in with Apple or to place purchases, in which case you will be bound by the terms and conditions and privacy notices of said third parties (e.g., Apple, Google or Facebook) – so please make sure that you read and accept them in advance. We do not receive or store your passwords for any of these third party services.

2.1.4 Protection of rights and safety:We may share your Personal Data with others, with or without notice to you, if we believe in good faith that this will help protect the rights, property or personal safety of BUlEPOINT, any of our users or any members of the general public.

2.1.5 BUlEPOINT's subsidiaries and affiliates: We may share Personal Data internally within our company for the purposes described in this Privacy Policy. In addition, in the event of any change of control of BUlEPOINT or any of its affiliates, including through mergers, acquisitions or purchases of substantially all of its assets, your Personal Data may be shared with parties involved in such events. If we believe that such a change of control could have a material impact on the Personal Data you store with us, we will notify you of this event and the choices you may have by e-mail and/or a prominent notice on our Services. For the avoidance of doubt, BUlEPOINT may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obliged to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-Personal Data in our sole discretion without further approval.

2.2 Data transmission Your Personal Data may be maintained, processed, accessed and stored by BUlEPOINT and our authorized affiliates and service providers in other jurisdictions as necessary for the proper delivery of our Services or as may be required by law. We may transfer the Personal Data we collect about you outside the United States to perform our contract with you. To ensure an adequate level of protection of your Personal Data, we have taken the following measures to ensure that these third parties process your Personal Data protection in a manner that complies with and respects the relevant laws: Standard Contractual Clauses, etc.

3. How we protect your Personal Data To protect the Personal Data you hold with us and our service providers, we use appropriate physical, procedural and electronic security measures, including encryption as deemed appropriate, access controls for internal data, bastion mechanisms. However, please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties. If you discover any security or vulnerability issues related to the Services you should send an e-mail to: [service@bluepointgame.com] .

4. How do we store, retain and delete your Personal Data:

4.1 Personal Data storage YOUY PETSONAL DATA WILL BE STORED ON THE ALIBABA CLOUD SERVICES, WHOSE DATA CENTER IS IN THE UNITED STATE OF AMERICA. The reason we transfer your Personal Data to the United State of America is that it is where the Alibaba Cloud data center where we store the Personal Data of users is located.

4.2 Retention of Personal Data Although privacy laws may vary in different jurisdictions, BUlEPOINT has taken reasonable steps to require its affiliates and service providers to process your Personal Data in a secure and lawful manner and in accordance with industry practices. We retain your Personal Data in order to maintain our relationship and provide you with our Services. We will retain your Personal Data for only as long as reasonable and necessary to fulfil the purpose for which we collected it. In other words, we will retain your Personal Data as long as you are still our user and you have not notified us otherwise. If you delete your account, we will take reasonable steps to delete your Personal Data. We may also retain your Personal Data for legal and accounting purposes (i.e. as required by laws applicable to records and bookkeeping, and in order to obtain evidence about our relationship if any legal issues arise after you stop using it). If you have any questions about our data retention policy, please contact us via e-mail at: [service@bluepointgame.com]. Please note that we are not obligated to retain your data for any particular period of time, except as required by applicable law, and may securely delete it at any time for any reason, with or without notice to you. In certain circumstances, we may anonymize your Personal Data so that it can no longer be associated with you, in which case we may use such information without notice to you and no longer be regarded as Personal Data within the meaning of this Privacy Policy.

4.3 Deletion of Personal Data If you would like to prevent us from actively using your Personal Data, or delete your Personal Data, you can reach via e-mail at: [service@bluepointgame.com]. We will respond to your request within thirty days after successfully receipt of your email. We will comply with your request as soon as we receive it, but please allow some time to process it. We also reserve the right to keep copies of any Personal Data that we are required to keep by applicable law.

5. How we use tracking technologies such as cookies

5.1 Our Services and some of our service providers utilize "cookies", anonymous identifiers and other tracking technologies (collectively, "Tracking Technologies") to help us provide and improve our Services, personalize your experience and monitor the performance of our activities and campaigns, as well as the usage of our Apps, Games and Services as a whole.

5.2 You can accept or refuse cookies. If you choose to refuse cookies, you may not be able to log in or use the Services provided by BUlEPOINT, and some advertisements that rely on cookies may not be applied. If you choose to accept cookies, you can also delete cookies you have already accepted at a later date.

6. Advertising and Communications

6.1 Our game includes advertisements for third-party services and products. We and our advertising partners use certain data about you to improve our advertising practices and make the advertising we deliver more effective, relevant and enjoyable, including by deploying interest-based advertising, as well as targeting and ad measurement and attribution systems. Such data includes your device advertising identifier (such as IDFA or Advertising ID, to the extent available), data related to your connected Facebook, Google or Apple profile (if any, such as your gender, region or country), game content, and other demographic and interests-based information that we or our advertising partners may have received from or about you, based on your consent or another legal basis (i.e., as required in order to provide you with our respective services, or based on the legitimate interests that we described above). Advertisements served by us or our advertising partners may be shown within our games, our Services, or through other channels such as third-party websites and applications. This Privacy Policy does not apply to the practices of companies that we do not own or control, or to employees or service providers that we do not manage. Any information you provide to sites, applications or services advertised through our Services will be covered by the applicable privacy policies specified therein. Please be sure to read the privacy policies of any third-party applications, services and sites that you visit or provide permission to access your information. It is those third parties’ responsibility to protect any information you give them, so we will not be held liable for their use of your personally identifying information.

6.2 How to adjust your preferences regarding interest-based advertising If you wish to prevent the use of your device's advertising ID or other identifiers for interest-based advertising, you may change your device settings to reset such advertising IDs or opt-out of such advertising(typically, this is available under the “Privacy” or “Ads” section in your device settings). If you live in the USA, Canada or Europe, you can also opt-out from the collection of your data by our advertising partners who participate in the Digital Advertising Alliance, by visiting www.aboutads.info/choices (for US users), www.youradchoices.ca/choices (for Canadian users), www.youronlinechoices.eu (for European users). Please note that if you reset your advertising ID or opt out of interest-based advertising, you may still see advertisements in our games or any other channel, but these advertisements will not be targeted based on the above mentioned identifiers. For example, such advertisements may be based on context, such as your progress and actions in a game, or your language preference.Please note that such actions may result in an unpleasant user experience.

6.3 Aggregated and analytical information We use the standard analytics tools of Google Analytics and may use other analytics tools from time to time. The privacy practices of these tools are subject to their own privacy policies. Google uses technologies such as cookies in order to track and analyse the use of our Site and/or an SDK to serve ads within our Game. To learn more about how Google processes data, we recommend you review Google’s policies located at: https://policies.google.com/technologies/partner-sites. For additional information regarding the data which Google SDK processes and stores see: https://support.google.com/admob/answer/7665968.

6.4 Communication

6.4.1 Promotional communications and user service communications via a third-party customer service platform (Helpshift): We may notify you about new Services, events and special opportunities or any other information we consider valuable to you. We may provide such notices through any contact method available to us (such as telephone, mobile or e-mail), through the Services or through our marketing activities on any other website or platform. You have the right to withdraw your consent to receive such information at any time. You can contact us via e-mail at: [service@bluepointgame.com]. Please note that it may take up to 3 business days for your request to be processed in our systems, during which time you may continue to receive such information.

6.4.2 Other Service Communications: We may contact you to provide important information about our Services. For example, we may notify you (by any means available to us) of changes or updates to our Services, billing issues, etc. You will not be able to opt out of receiving such service communications.

7. Protection of Children's Personal Data We do not provide services for purchase by children, and we do not knowingly collect personal information from children. If you are under the age of thirteen (13), you may use and access the Services only with the permission of your parent or guardian. We respect the privacy of parents and children and are committed to complying with the Children's Online Privacy Protection Act. We reserve the right to request proof of age or parental consent at any stage. If we become aware that a child under the age of thirteen (13) is using the Services or playing our game, we may prohibit and prevent such use and will make every effort to promptly delete any Personal Data we store about them. If a parent believe that his or her child has submitted Personal Data to us, he or she may contact us via e-mail at: [service@bluepointgame.com]. We will promptly delete the information upon learning that it relates to a child under the age of thirteen（13）. We recognize the importance of safeguarding the privacy of children and encourage parents to check and monitor their children's use of online activities regularly.

8. Revision and controlling version We may revise this Privacy Policy from time to time by posting revised versions on our Services. The revised version is effective from the published effective date, and we will provide notice by any means of communication or service available. If you do not agree to be bound by the terms of the new or revised Privacy Policy, you must stop using the Services. The Privacy Policy was drafted in English language, which is the original and controlling version of this Privacy Policy. All translations of this Privacy Policy into other languages shall be for convenience only and shall not control the meaning or applications of this Privacy Policy. In the event of any discrepancy in the meaning of any translated version of the Privacy Policy and the English-language version, the English-language version shall prevail.

9. Data Subject Rights

9.1 If you are a resident of the European Economic Area (EEA), Switzerland or the United Kingdom (UK) about whom we process Personal Data, you have the right to:

9.1.1 Request access to your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check whether we are processing it lawfully.

9.1.2 Request correction of the Personal Data we hold about you. This enables you to correct any incomplete or inaccurate information we hold about you.

9.1.3 Request deletion of your Personal Data. This enables you to ask us to delete or remove Personal Data that we have no good reason to continue processing. You also have the right to ask us to delete or remove Personal Data for which you have exercised your right to object to processing.

9.1.4 Object to the processing of your Personal Data where we rely on a legitimate interest (or the interests of a third party) and your particular circumstances that make you object to the processing on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.

9.1.5 Request restriction of processing of your Personal Data. This allows you to ask us to suspend the processing of Personal Data about you, for example if you would like us to establish its accuracy or the reasons for processing it.

9.1.6 Request to transfer your Personal Data to another party. (1) Usually no fee is required. You can access your Personal Data (or exercise any other rights) without paying a fee. However, if your request for access is manifestly unfounded or excessive, we may charge a reasonable fee, in which case we may refuse to comply with the request. (2) What we may need from you. We may need to request specific information from you to help us confirm your identity and ensure your right to access that information (or to exercise any of your other rights). This is another security measure in place to ensure that Personal Data is not disclosed to anyone who is not authorized to receive it.

9.1.7 Right to withdraw consent. In the limited circumstances in which you may have consented to the collection, processing and transfer of your Personal Data for a specific purpose, you have the right to withdraw your consent to that specific processing at any time. To withdraw your consent, please contact us via e-mail at: [service@bluepointgame.com]. Once we have received notice of your withdrawal of consent, we will no longer process your information for one or more of the purposes for which you originally consented, unless we have another legitimate basis in law. If you wish to exercise your rights under applicable law such as the General Data Protection Regulation ("GDPR") or the UK "GDPR", please contact us here. If you wish to manage the information we receive about you from a third-party applications or platform where you play our game (such as Facebook, Apple or Google), please follow the instructions for the third-party applications to update your information and change your privacy settings. You have the right to file a complaint with a data protection supervisory authority. For EEA residents, you can find details of your country's supervisory authority at: https://edpb.europa.eu/about-edpb/board/members_en . UK residents can contact the Information Commissioner's Office at: https://ico.org.uk/global/contact-us/ .

9.2 California Consumer Notice under the California Consumer Privacy Act (“CCPA”) In addition to our Privacy Policy, we provide the following notice in accordance with the CCPA.

9.2.1 The Categories of Personal Information We Collect You have the right to know the categories of personal information we are collecting. We provide this information in "How We Collect and Use Your Personal Data" in our Privacy Policy.

9.2.2 How We Use Your Personal Information You have the right to know how personal information is obtained, how it is used, and our business purposes for that use. We provide this information in "How We Collect and Use Your Personal Data" in our Privacy Policy.

9.2.3 How We Share Your Personal Information You have the right to know if your personal information is shared with any third parties. In most cases, we will not share your personal information we collected from you. But your prior approval will be obtained if we need to share your personal information to other third parties beyond the scope that you have consented to. We provide this information under "How we share your Personal Data" in our Privacy Policy.

9.2.4 We Do Not Sell Your Personal Information You have the right to know whether your personal information is being sold. Your personal information is sold when it is shared with a third party in exchange for valuable consideration for a purpose that is not a “business purpose” as set forth in the CCPA. We do not sell your personal information.

9.2.5 Right to Know, Right to Receive, Right to Delete You have the right to: （1）Know what personal information we collected and retained about you over the previous 12 months. （2）Receive a copy of your personal information we retain at the time of your request. （3）Delete your personal information we retain at the time of your request. If you want to exercise the above rights, you can contact us via e-mail at: [service@bluepointgame.com]. Before providing the required services, we may ask to verify your identity or the identity of your authorized agent.

9.2.6 Right to “Opt-out” of “Sale” You have the right to “opt-out” so that a business can no longer sell your personal information, if any. We not sell your personal information, so we do not offer an opt out.

9.2.7 Financial Incentives You have the right to know the financial incentives, if any, for sharing your personal information we collect. We do not provide any financial incentives to you for sharing your personal information.

9.2.8 Non-Discrimination You have the right to avoid any discrimination because your exercise of your rights under the CCPA. We will not deny your access to our service, or provide different prices or qualities of services because you exercise your rights under the CCPA.

9.3 Brazilian Consumer Notice under the Brazilian General Data Protection Law (“LGPD”) This Brazil Privacy Notice (“Notice”) applies to personal data processing activities under Brazilian law and supplements our Privacy Policy. Under the LGPD, you have the following rights.

9.3.1 confirmation of the existence of the processing;

9.3.2 access to the data;

9.3.4 correction of incomplete, inaccurate or out-of-date data;

9.3.5 anonymization, blocking or deletion of unnecessary or excessive data or data processed in noncompliance with the provisions of the LGPD;

9.3.6 portability of the data to another service provider or product provider, by the means of an express request, pursuant with the regulations of the national authority, and subject to commercial and industrial secrets;

9.3.7 deletion of personal data processed with the consent of the data subject, except in the situations provided in Art. 16 of the LGPD;

9.3.8 information about public and private entities with which we have shared data;

9.3.9 information about the possibility of denying consent and the consequences of such denial;

9.3.10 revocation of consent as provided in paragraph 5 of Art. 8 of the LGPD.

10. Contact us If you have any comments or questions about this Privacy Policy, or if you have any questions about your privacy, or to contact BUlEPOINT's data protection staff, please contact us via e-mail at: [bpgamecoc@gmail.com] and we will respond to yout within thirty (30) days after successfully receipt of your e-mail.

Coin of Clans Account Deletion:https://www.bluepointgame.com/from.html