PRIVACY POLICY FOR NETEASE SERVICES

1. INTRODUCTION

This Privacy Policy informs you of your choices and our practices regarding and use of any personal information you provide to us or collected through the product(s), service(s) and related websites (collectively, the “Services”) distributed by NetEase Interactive Entertainment Pte. Ltd. and its affiliates and subsidiaries (“NetEase”, the “Company”, “we”, “us” or “our”). It is important for you to understand how this happens and how you may control the collection and use of your personal information. This Privacy Policy applies to any Service that links directly to it.

When you access, use or register for the Services, you accept our rules and policies regarding your personal information and you expressly consent to us collecting, processing, using and storing your personal information, as described in this policy.

This Privacy Policy does not apply to third party websites, online properties, or systems to which the Services may link or through which the Services may be accessed, and you accept NetEase is not responsible for the security or privacy practices of any such third party websites, properties, or systems. Sometimes, we may direct you to a site, product, or service operated by a vendor or partner. Even though the page where you provide information may have the look and feel of the Services, a different privacy policy may govern that information collection and use by our vendor or partner.

You acknowledge that you have read and understood this privacy policy. If you do not agree with this Privacy Policy, you must not access, use or register for the Services. If you change your mind in the future, you may withdraw your consent to use of your personal information in accordance with this policy.

If you have any comments, questions or complaints regarding the processing of your personal information, you can contact us at privacy.glo@list.nie.netease.com or at 11400 West Olympic Blvd. Suite 200, Los Angeles, California 90064, USA.

2. THE TYPES OF PERSONAL INFORMATION WE USE

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

2.1 Information You Give Us

(i) When you register for the Services using an email address (including your email address and your name/nickname/username);

(ii) When you register for the Services using a third-party social media or similar account (e.g. Facebook, Twitter, Google or Apple, each a “Social Media Account”) in order to set up your profile (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 profile, your profile picture, your friend list, and your account ID);

(iii) When you set up your profile for the Services (including information you voluntarily elect to provide, including but not limited to your name/nickname/username, your gender, your age, etc.) and secure your account for the Services (including information you provide to help secure the account, including but not limited to your phone number, email address, security questions, etc.);

(iv) When you submit your name, date of birth, domestic citizenship or foreign status information for age verification or compliance with applicable laws and regulations;

(v) When you submit your contact and other details to us (e.g. your name, age, email address and physical address) as part of promotional activities for the Services;

(vi) When you submit your contact details and/or resume to us (including your name, email address, physical address, employment history, etc.) as part of applying for a job opportunity; and

(vii) When you use location-based functions in the Services (“Location Services”) (including GPS location information, cell-ID, Wi-Fi connection location).

2.2 Information We Collect About You

We automatically collect certain data from you when you use the Services, including your IP address and device information (such as device type, network data, operating system) and information regarding your use of and interaction with the Services, such as date and time stamps of actions. We also collect and store your data each time you interact with us, for example, when you use in-app support to communicate with us.

2.3 Information You Generate and Display in the Course of Using the Services

You may provide additional information as part of your profile. You may also provide or generate information when you communicate with other users in the Services (e.g., community forum). You acknowledge and agree that information generated within the Services should not be considered private and communications within the Services may be viewed/heard by other users. Please avoid revealing any personally identifiable or sensitive information during such communications.

2.4 Cookies and Other Tracking Technologies

We may use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to understand and enhance your experience with the Services. NetEase and certain third parties, such as marketing partners and analytics providers may use tracking technologies such as cookies and/or similar technologies on the Services. For more information about NetEase's use of cookies, and how you can withhold or withdraw your consent to using your data for targeted advertising purposes, please see our Cookie Policy, which is also incorporated by reference into this privacy policy and made part of this privacy policy.

3. CHILDREN'S PRIVACY

We do not knowingly collect or store any personal information from children under 13 in the United States or under the relevant age threshold in other jurisdictions where the child is located. In some cases, we may ask the user to provide us with their date of birth date for age verification. If such information indicates the user is under the age stipulated by the applicable laws and deemed as child under such laws, we will not collect further personal information from the child until a parent/guardian's verifiable consent is obtained. If you believe that we have unintentionally collected your child's personal information or otherwise used your child's personal information for another purpose, you may contact us at privacy.glo@list.nie.netease.com or at 11400 West Olympic Blvd. Suite 200, Los Angeles, California 90064, USA.

We recognize a special need to protect the personal information of children. We urge parents to instruct their children to never give out their real names, addresses, phone numbers, or other personal information without parental permission, when online. We also recommend that parents familiarize themselves with parental controls available on consoles, mobile telephones, tablets and other devices they provide to their child and accompany their child when online. Parents should contact NetEase immediately at privacy.glo@list.nie.netease.com or at 11400 West Olympic Blvd. Suite 200, Los Angeles, California 90064, USA if they have any concerns.

4. HOW WE USE YOUR PERSONAL INFORMATION

We use and share your information (i) to provide the services under the Terms of Use, (ii) with your consent, (iii) in our or others' legitimate interests (such as safety, security, and providing a tailor service), and (iv) for other legal reasons.

We rely on a number of legal bases to collect, use, share and otherwise process the information we have about you for the purposes described in this Privacy Policy. These legal bases include:

  • Registration Information (such as: ID on Social Media Accounts, email address, nickname, avatar, username, password, phone number, security questions, date of birth and other information): We use Registration Information to set-up user accounts, allow users to log-in to the Services by using the Registration Information, maintain and secure the user accounts with us, and provide the Services to users. We use this information with your consent to this Privacy Policy.
  • Device Information (such as: device ID, device type, operating system, CPU, RAM, IP address, MAC address): We use this information to provide and improve the Services such as: to allow users to download and install the software on their devices; to record and keep track of requests from users of the Services; to detect the user network and device status when the user is using the Services; and to correct bugs or errors that occur when the user is using the Services. Use of Device Information is necessary to perform our contract with you to provide the Services.
  • Contact Information (such as: name, email address, physical address, phone number): We use this information to send notifications to users to inform them of any company updates or promotional activities. We use this information with your consent to this Privacy Policy.
  • User Profile (such as: age, gender, photo, etc.): We use this information to provide customized services to users such as personal information page. We use this information with your consent to this Privacy Policy.
  • Applicant Information (such as: name, email address, mailing address, phone number, employment-related information, education information, etc.): We use this information when you apply for a job opportunity with the Company, accepting and evaluating applicant submissions for job postings, and making hiring decisions. We use this information with your consent.
  • Location Data (such as: GPS location information, cell-ID, Wi-Fi connection location). With your consent, we use this information to provide Location Services to users and to record and keep track of requests from users of the Services. Use of Location Data is limited to the context of location-based services. You can disable Location Services by turning off the relevant switch in the settings of the Services or your device.

We may associate all of the foregoing information with your account, the device you use to access the Services, or email that you use to engage with us. We use this information with your consent to this Privacy Policy.

In addition to the specific uses of information described above, we may use all of the above information to provide, improve and develop the Services, including as we describe in our User Agreement, to comply with any applicable legal obligations, to enforce any applicable terms of service, to protect or defend the Services, our rights, the rights of our users, or others, for the purpose of combatting fraud, or to otherwise operate our business.

5. HOW WE STORE AND SHARE YOUR PERSONAL INFORMATION

In order to perform our contract with you, your personal information will be accessible from and will be processed on our servers. Our servers are hosted on cloud servers such as Amazon Web Services. Your information may be transferred to and processed in countries outside the country you are located. We will take steps necessary to comply with applicable legal requirements, such as using European Commission approved Standard Contractual Clauses to protect your information. In particular, your information will be transferred to and processed in Japan where our central database is based.

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

  • Third-party vendors that provide services in support of the Services, such as WorkDay for the purpose of job postings and job application submission. Such third-party vendors have limited access to your personal information and are contractually bound not use it for other purposes.
  • Related group companies, with whom we share your information to operate the Services. The transfers contemplated above are made pursuant to our contract with you; and
  • Law enforcement agencies, public authorities or other judicial bodies and organizations. 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 service 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 organizations for the purposes of fraud protection).
  • Business partners and third parties (e.g., other companies, retailers, research organizations, advertisers, ad agencies, advertising networks and platforms, participatory databases, publishers, and non-profit organizations) that provide advertising or may want to market products or services to you. If we share personal information with such unaffiliated third parties for their own marketing purposes, we will provide you with an opportunity to opt out of such uses either at the point of collection or through the choice mechanisms set forth in this Privacy Policy.
  • In the event of a business transaction, such as if we or one of our business units or our relevant assets are acquired by, sold to, or merged with another company or as part of a bankruptcy proceeding or a business reorganization.

6. 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 deploy a firewall and other security measures (such as encryption) commensurate to industry standards to prevent unauthorized access to your personal information. Your personal information will remain subject to our technical and organizational 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 to the Services; any transmission of your information is at your own risk.

7. DATA RETENTION

We will retain most of your personal information for the lifetime of your use of the Services (i.e. until account deletion in accordance with your request) except that Contact Information obtained from promotional activities will be retained during the lifetime of such activities.

In the event that the processing and retention period have terminated, but personal information is required to be retained continuously for other reasons including for the purposes as prescribed under applicable laws, the relevant personal information will be stored and maintained separately from other types of personal information. If you require us to destroy your personal information before the end of its life cycle, we will destroy your personal information in accordance with local laws.

8. YOUR RIGHTS

8.1 International Transfer

We operate internationally, and many of our computer systems are currently based in the United States, which means Information we collect will be processed by us in the U.S. where data protection and privacy regulations may not offer the same level of protection as in other parts of the world, such as the European Union. If you access, use or register for the Services from outside the United States, you consent to the collection and/or processing in the United States of Information we collect from you.

8.2 California Collection Notice

This section addresses legal obligations and rights laid out in the California Consumer Privacy Act (“CCPA”) and other laws that apply only to California residents. These obligations and rights apply to businesses doing business in California and to California residents and information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with California consumers or households (“California Information”). It does not apply to information that has been de-identified or aggregated as provided by CCPA.

Depending on how you interact with us, we may collect about you the categories of information summarized below. We also describe below how we collect and use such categories of information. These categories of personal information are shared with third parties as described in detail in Section 5 above.

Categories of Information Collected

  • Identifiers and Contact or Registration Information, e.g., name, email address, mailing address, phone number, account username, and third party account names;
  • Device Information and Device Identifiers, e.g., IP address; browser type and language; operating system; platform type; device type; software and hardware attributes; and unique device, advertising, and app identifiers;
  • Geolocation, e.g., city, state and ZIP code associated with your IP address;
  • Job applicant Information, e.g., name, email address, mailing address, phone number, employment-related information, education information, etc.);
  • User-generated content, e.g., photos, videos, audio, any information you submit in forums, chat or message boards;
  • Customer service information, e.g., questions and other messages you address to us directly through online forms, chat, by email, or by mail;
  • Other Information, e.g., any other information you choose to directly provide to us in connection with your use or access of the Service.

Purposes of Use

  • Perform the services, and personalizing your experience on the Services;
  • Commercial purposes, such as operating our business, or sending newsletters or marketing, and to provide you with targeted advertising;
  • Detect security incidents and secure our website;
  • Undertaking activities to verify and maintain the quality of the Services.

Sources of Personal Information

  • You, both directly and through your use of the Services
  • Our vendors and business partners (for example, data analytics providers, advertisers, media partners or platform providers)
  • NetEase group companies
  • Social Media and other third party accounts

We may share information falling into the categories of information described above with NetEase group companies and third parties for the specified purposes as follows:

  • with the various NetEase group companies, including for the group companies' own marketing purposes;
  • with NetEase vendors, partners and licensees to provide you with services you have requested, or create applications and websites that benefit our community;
  • if required to do so by applicable law, regulation or legal process;
  • if necessary to exercise, establish or defend our legal rights;
  • if necessary to protect the vital interests of any person; and
  • in connection with the sale of our business or assets.

8.3 Your California Privacy Rights

Without being discriminated against for exercising these rights, California residents have the right to request that we disclose what personal information we collect from you, to delete that information, and to opt-out of the sale of your personal information, subject to certain restrictions. You also have the right to designate an agent to exercise these rights on your behalf. This section describes how to exercise those rights and our process for handling those requests.

8.4 Privacy Information for Nevada Residents

Under Nevada law, Nevada residents who have purchased goods or services from us may opt out of the “sale” of “covered information” (as such terms are defined under Nevada law) for monetary consideration to a person for that person to license or sell such information to additional persons. “Covered information” includes first and last name, address, email address, and phone number, or an identifier that allows a specific person to be contacted either physically or online. As discussed above, we share your information with certain third parties that we believe can provide you with offers and promotions for products and service of interest to you and in the other ways described above. We do not believe that our sharing in this regard would qualify as a sale under Nevada law. Nonetheless, if you are a Nevada resident who has purchased goods or services from us, you may submit a request to record your preference to opt out by emailing us at privacy.glo@list.nie.netease.com. Please note we may take reasonable steps to verify your identity and the authenticity of the request.

8.5 Privacy Information for Users in the EEA and the UK

We only process or transfer your personal information where we can rely on legal grounds and appropriate safeguards to do so. We process your information for the purposes set out below.

Performance of the Services

We process your personal information for the performance of the Services, to provide or support of our products, or for any other feature you request or enable. This includes, for example, using your personal information to:

  • administer your account;
  • support game functionality;
  • provide global customer service; or

Consent

We process your personal information based on your consent. This includes, for example, providing:

  • newsletters and direct e-mails about the Services that may be of interest to you;
  • targeted ads; and
  • certain other marketing features.

Legitimate Interest

We process your personal information where we have a legitimate interest to do so. This includes, for example, processing:

  • to provide you with requested customer service or technical support;
  • to debug and improve our current and future Services;
  • in order to give you personalize your online experience with us and contact you in accordance with applicable marketing preferences;
  • to allow third party partners and licensees to create applications and websites that benefit our users; and
  • for the establishment, exercise or defense of legal claims or whenever courts are acting in their judicial capacity.

Legal Obligation

We process your personal information for compliance with a legal obligation to which we are subject.

8.6 Disclosure to Users Outside the US, the EEA and the UK

In addition, if you are a visitor to our websites or other online products and services from outside the U.S., the personal information you provide will be collected, processed and stored directly on, or transferred to, servers in the United States or other countries where NetEase group companies or our other partners or vendors maintain facilities or business operations.

No matter where the Information is located, NetEase takes commercially reasonable measures to safeguard your privacy rights in accordance with this Privacy Policy. If you do not agree to the collection, processing, storage and transfer of your Information, please do not provide your Information when requested and stop using our websites and other online products and services.

9. 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 personal information about you, please contact us at privacy.glo@list.nie.netease.com or at 11400 West Olympic Blvd. Suite 200, Los Angeles, California 90064, USA.

10. PORTABILITY

You have the right to receive a copy of certain personal information we process about you. This comprises any personal information we process on the basis of your consent or pursuant to our contract with you, as described in the section “How We Use Your Personal Information”. 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).

11. CORRECTION

You have the right to correct any personal information held about you that is inaccurate. If you believe we hold any personal information about you and that information is inaccurate, please contact us at privacy.glo@list.nie.netease.com or at 11400 West Olympic Blvd. Suite 200, Los Angeles, California 90064, USA.

12. ERASURE

You can delete your account, or remove certain personal information. If there is any personal information you believe we process that you would like us to erase, please contact us at privacy.glo@list.nie.netease.com or at 11400 West Olympic Blvd. Suite 200, Los Angeles, California 90064, USA.

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; or
  • You believe the personal information we hold about you is being unlawfully processed by us.

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 defense 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 Services and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.

13. 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 defense 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;
  • You wish to erase the personal information as the processing we are doing is unlawful but you want us to retain the personal information but just store it instead; or
  • You wish to erase the personal information as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defense of legal claims.

14. OBJECTION

You have the right to object to our processing of personal information about you. We will consider your request in other circumstances as detailed below by contact us at privacy.glo@list.nie.netease.com or at 11400 West Olympic Blvd. Suite 200, Los Angeles, California 90064, USA.

15. ANNOUNCEMENTS

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

16. CONTACT & COMPLAINTS

For the purposes of European Data Protection Law, the Data Controller is NetEase Interactive Entertainment Pte. Ltd.

If you wish to make a complaint about how we process your personal information, please contact us at:

NetEase Interactive Entertainment Pte. Ltd.

11400 West Olympic Blvd. Suite 200

Los Angeles, California 90064

USA

Attn: Privacy / Legal Department

Email: privacy.glo@list.nie.netease.com

This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws.

17. CHANGES

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.

18. LANGUAGE

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

Effective: September 26, 2022

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