Sun Ground Co., LTD Privacy Policy

Sun Ground Co., Ltd ("Sun Ground"), its parent and its subsidiaries respect the privacy rights of our users and are committed to protect users' information collected through our online products, online services and websites (together "Services"). Sun Ground has adopted this privacy policy ("Privacy Policy") to explain how Sun Ground collects, stores, and uses the information collected in connection with Sun Ground's Services. Should you have any questions relating to this Privacy Policy, please contact us at android[a] or alternatively at Sun Ground Co., LTD, Legal Department, Room 809, 8F, Haidian Science Plaza, Building No.3, Zhongguancun SouthStreet, Haidian District, Beijing, 100081.



PROCESSING, USE AND DISCLOSURE OF YOUR PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO ANY TERM PROVIDED HEREIN, PLEASE DO NOT INSTALL, USE, REGISTER TO OR OTHERWISE ACCESS THE SERVICES. Sun Ground reserves the right to modify this Privacy Policy at reasonable times, so please review it frequently. If Sun Ground makes material or significant changes to this Privacy Policy, Sun Ground may post a notice on Sun Ground's website along with the updated Privacy Policy. Your continued use of Services will signify your acceptance of the changes to this Privacy Policy.

Non-personal data

For purposes of this Privacy Policy, "non-personal data" means information that does not directly identify you. Additionally, non-personal data means "aggregate" and "de-personalized" information, which is data Sun Ground collects about the use of Sun Ground Services, from which any personally identifiable data has been removed.

Sun Ground may use tools or third party analytical software to automatically collect and use certain non-personal data that does not directly enable Sun Ground to identify you. The types of non-personal data Sun Ground may collect and use include, but are not limited to: (i) device properties, including, but not limited to IP address, device identifier like International Mobile Equipment Identity ("IMEI"); (ii) device software platform and firmware; (iii) mobile phone carrier; (iv) game progress, score and achievements; (v) other non-personal data as reasonably required by Sun Ground to enhance the Services and other Sun Ground products and services.

Sun Ground uses analytics tool such as Umeng in order to develop and analyze use of the Services.

Sun Ground may use and disclose to Sun Ground's partners and contractors the collected non-personal data for purposes of analyzing usage of the Services, advertisement serving, managing and providing the Services and to further develop the Services and other Sun Ground services and products.

You recognize and agree that the analytics companies utilized by Sun Ground may combine the information collected with other information they have independently collected from other services or products relating to your activities.

Ad Serving Technology

Sun Ground may employ third party ad serving technologies that use certain methods to collect information as a result of ad serving through Services.

You recognize and agree that the advertising companies who deliver ads for Sun Ground may combine the information collected with other information they have independently collected from other services or products. These companies collect and use information under their own privacy policies. These ad serving technologies are integrated into Services; if you do not want to be subject to this technology, do not use or access Services.

Below is a full list of Third Parties, as well as links to their privacy policies:

Admob  Admob's privacy policy

Personal Data

For purposes of this Privacy Policy, "personal data" complies with the definition of "Children's Online Privacy Protection Act" (COPPA), which includes:

a) First and last name;

b) A home or other physical address including street name and name of a city or town;

c) Online contact information;

d) A screen or user name that functions as online contact information;

e) A telephone number;

f) A social security number;

g) A persistent identifier that can be used to recognize a user over time and across different websites or online services;

h) A photograph, video, or audio file, where such file contains a child’s image or voice;

i) Geolocation information sufficient to identify street name and name of a city or town; or

j) Information concerning the child or the parents of that child that the operator collects online from the child and combines with an identifier described above.

When purchasing products or services online, your purchasing orders might have personal data. Such personal data is only collected for purpose of billing calculation.

Disclosure and Transfer of Personal Data

Sun Ground collects and processes personal data on a voluntary basis and it is not in the business of sellinng your personal data to third parties. Personal data may, however, occasionally be disclosed in accordance with applicable legislation and this Privacy Policy. Additionally, Sun Ground may disclose personal data to its parent companies and its subsidiaries in accordance with this Privacy Policy.

Sun Ground may hire agents and contractors to collect and process personal data on Sun Ground's behalf and in such cases such agents and contractors will be instructed to comply with our Privacy Policy and to use personal data only for the purposes for which the third party has been engaged by Sun Ground. These agents and contractors may not use your personal data for their own marketing purposes. Sun Ground may use third party service providers such as credit card processors, e-mail service providers, shipping agents, data analyzers and business intelligence providers. Sun Ground has the right to share your personal data as necessary for the aforementioned third parties to provide their services for Sun Ground. Sun Ground is not liable for the acts and omissions of these third parties, except as provided by mandatory law.

Sun Ground may disclose your personal data to third parties as required by law enforcement or other government officials in connection with an investigation of fraud, intellectual property infringements, or other activity that is illegal or may expose you or Sun Ground to legal liability. Sun Ground may also disclose your personal data to third parties when Sun Ground has a reason to believe that a disclosure is necessary to address potential or actual injury or interference with Sun Ground's rights, property, operations, users or others who may be harmed or may suffer loss or damage, or Sun Ground believes that such disclosure is necessary to protect Sun Ground's rights, combat fraud and/or comply with a judicial proceeding, court order, or legal process served on Sun Ground. To the extent permitted by applicable law, Sun Ground will make reasonable efforts to notify you of such disclosure through Sun Ground's website or in another reasonable manner.

Data Retention and Correctness

Sun Ground retains the data collected pursuant to this Privacy Policy for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law. Thereafter if the collected data is no longer needed for purposes specified in this Privacy Policy, Sun Ground  deletes all aforementioned data in its possession within a reasonable timeframe. Sun Ground does not verify the correctness of personal data.

Sun Ground may still retain some of the data to the extent such retention is necessary to resolve disputes, enforce Sun Ground user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of Services.

Third Party Terms and Conditions

Please note that your access to and use of the Services may be subject to certain third party terms and conditions and privacy policies, including but not limited to application stores, mobile software platforms, on-line gaming platforms, social networking services and payment providers. You recognize and agree that Sun Ground is not liable for any such third party terms and conditions and their use of your personal data.

Sun Ground may in its discretion make available links through advertisements or otherwise enable you to access third party products or services. Please note that, while using such products or services, you are using products or services developed and administered by people or companies not affiliated with or controlled by Sun Ground. Sun Ground is not responsible for the actions of those people or companies, the content of their products or services, the use of information you provide to them, or any products or services they may offer. The fact that Sun Ground is linking to those products or services does not constitute our sponsorship of, or affiliation with, those people or companies.


Sun Ground follows generally accepted industry standards and maintains reasonable safeguards to attempt to ensure the security, integrity and privacy of the information in Sun Ground's possession. Only those persons with a need to process your personal data in connection with the fulfillment of their tasks in accordance with the purposes of this Privacy Policy and for the purposes of performing technical maintenance, have access to your personal data in Sun Ground's possession. Personal data collected by Sun Ground is stored in secure operating environments that are not available to the public. To prevent unauthorized on-line access to personal data, Sun Ground maintains personal data behind a firewall-protected server. However, no system can be 100% secure and there is the possibility that despite Sun Ground's reasonable efforts, there could be unauthorized access to your personal data. By using the Services, you assume this risk.


Please be aware of the open nature of certain social networking and other open features of the Services Sun Ground may make available to you. You may choose to disclose data about yourself in the course of contributing user generated content to the Services. Any data that you disclose in any of these forums, blogs, chats or the like is public information, and there is no expectation of privacy or confidentiality. Sun Ground is not responsible for any personal data you choose to make public in any of these forums.

If you are under 13 years of age or a minor in your country of residence, please ask your legal guardian's permission to use or access the Services. Sun Ground takes children's privacy seriously, and encourages parents and/or guardians to play an active role in their children's online experience at all times. Sun Ground does not knowingly collect any personal information from children below the aforementioned age and if Sun Ground  learns that Sun Ground has inadvertently gathered personal data from children under the aforementioned age, Sun Ground will take reasonable measures to promptly erase such personal data from Sun Ground's records.

Sun Ground may disclose your personal data to third parties in connection with a corporate merger, consolidation, restructuring.

Further information

Pursuant to Law of the People's Republic of China on the Protection of Minors, any and all use of your personal data by Sun Ground is governed by Chinese law and not the laws where you may be located.

Sun Ground regularly reviews its compliance with this Privacy Policy. If Sun Ground receives a formal written complaint from you, it is Sun Ground's policy to attempt to contact you directly to address any of your concerns. Sun Ground will cooperate with the appropriate governmental authorities, including data protection authorities, to resolve any complaints regarding the collection, use, transfer or disclosure of personal data that cannot be amicably resolved between you and Sun Ground. TO THE EXTENT YOU AND Sun Ground ARE NOT ABLE TO AMICABLY RESOLVE ANY DISPUTE THAT MAY ARISE, YOU AGREE THAT YOU MAY BRING CLAIMS AGAINST Sun Ground ONLY IN YOUR INDIVIDUAL CAPACITY AND NOT AS A PLAINTIFF OR CLASS MEMBER IN ANY PURPORTED CLASS OR REPRESENTATIVE PROCEEDING.

Copyright 2014 南京光辉互动网络科技股份有限公司 NJ. Brilliance I.E. PLC. All rights reserved
苏ICP备 13059777号-2   苏网文许字【2014】1418-044号