PAPILLON Privacy Protection Guidelines

Updated Date: June 5, 2020
Effective Date: June 5, 2020

Summary

  Welcome to choosing PAPILLON ENTERTAINMENT LIMITED (hereinafter referred to as "we"). In this guide, PAPILLON refers to PAPILLON ENTERTAINMENT LIMITED as the provider of PAPILLON services. In addition to the "PAPILLON Privacy Policy" and "PAPILLON License and Service Agreement", we will further elaborate on how we collect, use, store, and share personal information when you use PAPILLON and your related rights in this "PAPILLON Privacy Protection Guidelines" ("this guide"). This guide is an integral part of the "PAPILLON License and Service Agreement", and the key points are as follows:
  • In order to provide you with gaming entertainment and related player interactions, consumption, and other services, we need to collect your game history, device information, login logs, etc.
  • In order to better protect the physical and mental health of minors, promote healthy internet use for minors, we may implement stricter anti-addiction measures based on the national regulations on anti-addiction for online games. At the same time, we continue to research and test new technologies to protect minors. For further improving the accuracy of real-name authentication and preventing minors from using others' identity information, we may enable facial recognition verification for some games or specific users (subject to specific game strategies).
  The facial recognition verification mainly compares the user's real facial information with the data source from the public security authority. If the two match, the authentication is successful, and the corresponding game time limit matches the user's actual age group. If the comparison results do not match or the user refuses verification, we will uniformly consider them as minors aged 12 and below and subject to corresponding anti-addiction management. The related verification data of facial recognition is only used for comparison with the public security authority data platform and will not be retained by us.
  • You can manage your personal information and related authorizations as described in this guide.
  • We employ various security measures to ensure the reasonable security of your personal information.

You can understand the corresponding rules of personal information types and uses in more detail by reading the complete "PAPILLON Privacy Protection Guidelines".
  1. Information We Collect
  2. Information Storage
  3. Information Security
  4. How We Use Information
  5. Providing to Third Parties
  6. Your Rights
  7. Changes
  8. Protection of Minors
  9. Others
  10. Contact Us

1. Information We Collect
In the process of using PAPILLON services, PAPILLON will collect the information you actively provide when using the service or the information generated due to the use of the service, to provide you with, optimize our services, and ensure the security of your account:
  1.1 When you register or use PAPILLON services, we will collect your online identity information and personal commonly used device information to identify you as a PAPILLON user. If you use a phone number, WeChat, QQ, and (or) other accounts recognized by us (hereinafter referred to as "third-party accounts") to associate with your game account for logging into PAPILLON, we will collect your phone number, WeChat, QQ, and the unique identifiers, avatars, nicknames of the third-party account, for saving your login information for use on different devices.
If you use a phone number, WeChat, QQ, and (or) a third-party account as your game account to log into PAPILLON, for better providing you with game services, improving the gaming experience, we may collect your phone number, QQ number, WeChat account, and other information related to the third-party account, including unique identifiers, nicknames, avatars, friend relationships, and other authorized information. Additionally, we may collect your in-game operation information, game information, and other information (including but not limited to your login status, battle information/status, achievement information, etc.) in PAPILLON. We may provide relevant permissions depending on the specific game, allowing you to adjust whether to display the aforementioned information.
  1.2 To meet relevant legal regulations and requirements from the competent authorities, PAPILLON users are required to undergo real-name authentication to continue using and enjoying PAPILLON. We will collect your real-name identity information (including name, ID card number, photos, etc.), which is sensitive information. Refusing to provide real-name identity information may lead to you not being able to log in to PAPILLON or experiencing certain limitations while using PAPILLON.
  1.3 To ensure your normal use of our services, maintain the normal operation of game basic functions, optimize game product performance, enhance your gaming experience, and safeguard your account's security, we may collect your device ID, device name, device type, version, system version, IP address, MAC address, application ID, network type, and other information.
  1.4 When you use PAPILLON game services, we will collect your game log information, such as login logs, item logs, game match information, friend records, etc. This allows you to view your game history on the client and is also used for game operation statistical analysis, customer service complaint handling, and other game security analysis. We may also synchronize the aforementioned information to subsequent versions of the game or other products provided by us.
  1.5 If you use phones from brands such as Xiaomi, Meizu, and Huawei, the third-party SDKs integrated by PAPILLON games may need to collect phone unique identifier information (such as IMEI). These SDKs may also collect information like your phone model, system type, system version, device screen size, etc., to enable the normal use of PAPILLON game products. For specific details, please refer to the "Third-party SDK Directory".
Please note that when you use our products, we do not collect or use any of your information while the product is in a silent or background state. Third-party SDKs may collect device information and location information when the product is in a silent state or in the background, including IMEI, MEID, IMSI, AndroidID, OAID, GAID, ICCID, MAC address, IP address, software installation list, WI-FI MAC, running processes, current running processes, and have permissions to read phone state and identity and allow writing to external storage. The collection of such information is governed by the privacy policy of the SDK itself, but we will supervise it to the best of our ability. If third-party SDKs collect information more than 5 times per second while in a silent or background state, we will coordinate with the third-party SDKs as much as possible.
  1.6 When you use the consumption function of PAPILLON game products, we will collect your recharge records, consumption records, and other information. This allows you to check your transaction records and ensures the maximum protection of your virtual items. Recharge records and consumption records are sensitive information and are necessary for the operation of PAPILLON game products. Otherwise, transactions cannot be completed.
  1.7 To ensure the security of your game account, create a fair, healthy, and safe gaming environment, we will collect your game recognition information, hardware and operating system information, process and game crash records, and other information. This is used to combat behaviors that disrupt the fair gaming environment or interfere with the normal operation of game services (e.g., to detect piracy, scan for cheats, prevent cheating, etc.).
  1.8 When you interact with other players in the game through text, images, voice, video, and other methods, we may collect and save the content of the information you send for filtering inappropriate content such as pornography, violence, politics, insults, malicious advertisements, etc. This helps purify the gaming environment and maintain a healthy online environment.
  1.9 If you wish to interact with other game players through voice, video, or participate in live broadcasting, upon your authorized consent, the game will access your microphone and camera to provide you with voice chat, interactive live streaming, and other functions.
  1.10 If you wish to interact with nearby game players, upon your authorized consent, we will collect your geographic location information to find nearby game players for matching and teaming up. Geographic location information is sensitive information, and refusing to provide this information will only prevent you from interacting with nearby game players. It will not affect your normal use of other features in PAPILLON games. You can revoke your authorization for geographic location information at any time.
  1.11 We have enabled the feature of moderate gaming reminders. If you use wearable devices, with your consent, we will collect your in-game online heartbeat and other information to send system reminders when you excessively play games.
  1.12 If you contact our customer service, we may need you to provide necessary personal information for identity verification to ensure the security of your account. For providing services based on your requests, and with your authorization, our customer service staff may need to access your relevant information within the scope of your authorization. We will take technical and managerial measures to safeguard the security and confidentiality of your information and use it within the necessary range. We may also retain your contact information (phone number, WeChat ID, QQ ID, or other contact information you use or provide), your communication records and content with us, and other necessary information to provide services to you and record customer service interactions.
  1.13 If you contact our customer service, we may need you to provide necessary personal information for identity verification to ensure the security of your account. To provide services based on your requests, with your authorization, our customer service representatives may need to query or verify your relevant information within the scope of your authorization. We will take technical and management measures to ensure the security and confidentiality of your information and use it within the necessary scope. We may also store your contact information (such as the phone number, WeChat ID, QQ ID, or other contact information you use or voluntarily provide), your communication records and content with us, and other necessary information to provide and record customer service for you.
  1.14 We may analyze your game data to understand your preferences better, in order to show you content that may interest you in other PAPILLON games, products, or services. You can manage the displayed content through the settings or other instructions provided within those products or services. For details, please refer to the instructions within the product.
  1.15 We may collect your information through Cookies, identifiers, and related technologies to provide you with a better user experience and ensure service security. For information on how we use Cookies and related technologies, and how you can manage our use of Cookies and related technologies, please refer to the "Cookie Policy." Some of our products may provide you with advertising push services. We may use your device identifiers such as IMEI, MEID, IDFA, OAID, advertising data such as exposure and click data, device information such as system language, screen size, and screen orientation, in these products to provide you with advertisements that you may be interested in, evaluate and improve the effectiveness of our advertising, promotions, and other marketing activities, and business analysis. If you do not wish to receive personalized advertising services, you can go to "Settings" - "Privacy" - "Personalized Advertising" in products that provide advertising push services to disable it. If you choose to disable it, the number of ads you see will not decrease, but the products will no longer show you personalized ads, and the relevance of ads you see may decrease. You can also go to "Settings" - "Apps & Permissions" - "App Management" on your mobile phone, click on the app that provides push services, click on "Notifications," and disable "Allow Notifications," so you will no longer receive push notifications.
  1.16 We may analyze the operation of our products based on factors such as the frequency and situation of users using our game products, fault information, and performance information, to ensure service security, optimize our products, and improve the quality of our services. However, we will anonymize or de-identify the information for analysis, and we will not combine the information stored in the analysis software with the personal information you provide.
  1.17 According to relevant laws, regulations, and national standards, there are situations where we may collect and use your personal information without seeking your authorization:
    1) It is directly related to national security, national defense, and other national interests; it is directly related to major public interests such as public safety, public health, and public knowledge;
    2) It is directly related to criminal investigation, prosecution, trial, and execution of judgments;
    3) It is for the purpose of protecting the life, property, reputation, and other major legitimate rights and interests of you or other individuals, but it is difficult to obtain your consent;
    4) The personal information collected is disclosed by yourself to the public;
    5) Personal information is collected from information that is legally disclosed to the public, such as legal news reports and government information disclosure channels;
    6) It is necessary for signing and performing a contract at your request;
    7) It is necessary to maintain the safe and stable operation of the product or service provided, such as discovering and dealing with product or service failures;
    8) It is necessary for conducting lawful news reporting;
    9) It is necessary for carrying out statistics or academic research for public interests, and when providing academic research or describing the results to the outside, personal information contained in the results is de-identified;
    10) Other situations as stipulated by laws and regulations.   1.18 Please understand that the functions and services we provide to you are constantly being updated and developed. If a certain function or service is not covered in the previous explanation and collects your information, we will explain the content, scope, and purpose of information collection to you through page prompts, interaction processes, website announcements, and other means to obtain your consent. Currently, apart from collecting game research information from third-party research institutions to help us improve our game products and provide better services, and the situation where you use third-party account login to PAPILLON as specified in Section 1.1 of this guideline, we will not actively obtain your personal information from third parties outside the PAPILLON Group. If it is necessary to indirectly obtain your personal information from third parties outside the PAPILLON Group for business development in the future, we will clearly inform you of the source, type, and scope of your personal information before obtaining it. If the personal information processing activities required by PAPILLON's business exceed the scope of authorization consent you originally provided to third parties outside the PAPILLON Group, we will obtain your explicit consent before processing such personal information. In addition, we will strictly comply with relevant laws and regulations and require the third party to ensure the legality of the information provided.

2. Storage of Information
  2.1 Methods and Period of Information Storage

We will securely store your information using various methods, including local storage (such as data caching using the app), databases, and server logs. Generally, we will only store your personal information for the time required to achieve the service purpose or as required by laws and regulations. 2.2 Geographical Location of Information Storage
In accordance with laws and regulations, we will store user personal information collected within the country in China. 2.3 Notification of Product or Service Shutdown
When our product or service is shut down, we will provide notification in accordance with relevant laws and regulations and protect your legal rights.

3. Information Security
3.1 Security Measures
We strive to provide protection for the security of user information to prevent information leakage, loss, unauthorized access, and disclosure. We use multiple security protection measures to ensure that personal information protection reaches a reasonable security level, including technical protection measures, management system controls, security system guarantees, and more. In addition, the related systems of our games have also passed the filing and evaluation of national network security level protection (Level 3). We employ industry-leading technology protection measures, including but not limited to firewalls, encryption (such as SSL), de-identification or anonymization, and access control measures. Furthermore, we continuously enhance the security capabilities of software installed on your devices. For instance, we complete part of the information encryption work on your device to strengthen secure transmission. We learn about the applications installed on your device and the processes running on it to prevent viruses, Trojans, and other malicious programs. We have established a dedicated management system, processes, and organization for the security of personal information. For instance, we strictly limit the scope of personnel who can access information, require them to comply with confidentiality obligations, and conduct audits. Violators of these obligations will be subject to penalties. We also review this management system, processes, and organization to prevent unauthorized access, use, or disclosure of user information. We recommend that you pay full attention to the protection of personal information when using our products and services, and we will also provide various security features to assist you in protecting your personal information security. 3.2 Security Incident Response Measures
In the event of a security incident such as personal information leakage, we will activate an emergency response plan to prevent the incident from expanding. After a security incident occurs, we will inform you of the basic situation of the security incident, the measures we are about to take or have taken, and the remedial measures in the form of announcements, push notifications, or emails, and provide you with response advice. If it is difficult to notify individually, we will issue warnings through public announcements.

4. How We Use Information
We strictly adhere to legal requirements and agreements with users and use the information collected in accordance with this guideline and the "PAPILLON License and Service Agreement." to provide you with better services. 4.1 Information Usage Rules
We will use the information collected according to the following rules:
1) We will provide you with various features and services, including basic game features, player interaction features, live streaming features, and consumption features based on the information we collect. 2) We will analyze the operation of our products based on the frequency and situation of your usage of PAPILLON products, fault information, performance information, etc., to ensure service security, optimize our products, and improve the quality of our services. We will not combine the information stored in the analysis software with your personal identity information. 4.2 Obtaining Consent After Informing of Changes in Purpose
We will use the information collected within the scope covered by this guideline. If we use your personal information beyond the purpose and scope declared at the time of collection, and if it is not directly related to the original purpose, we will inform you again and obtain your explicit consent before using your personal information.

5. External Sharing Currently, except as specified in this guideline and the "PAPILLON License and Service Agreement," we will not proactively share, provide, or transfer your personal information to third parties outside of PAPILLON. If there are other situations in which we need to share, provide, or transfer your personal information to third parties outside of PAPILLON, we will directly obtain your express consent for such actions or confirm it with the third party involved. Even with the above provisions, if you use overseas games that we act as agents for, we may provide the logs and related information generated by you in the game (such as login logs, item logs, etc.) to overseas developers or relevant third parties for game security analysis, helping improve game services, and further optimizing the user's gaming experience. Additionally, after suspecting underage consumption, we will attempt to contact their guardians, inform them of relevant consumption records and information, and provide reminders, confirmation, and handling. Except as otherwise provided in this guideline and the "PAPILLON License and Service Agreement," we will not publicly disclose the personal information we collect. If it is necessary to disclose it publicly, we will inform you of the purpose of such disclosure, the type of information to be disclosed, and any sensitive information involved, and obtain your express consent. As our business continues to develop, we may engage in mergers, acquisitions, asset transfers, and other transactions. We will inform you of relevant circumstances and continue to protect your personal information in accordance with legal regulations and standards no less than those required in this guideline. In addition, according to relevant laws, regulations, and national standards, the following situations may involve sharing, transferring, or publicly disclosing personal information without obtaining your prior consent: 1) Directly related to national security and national defense security; 2) Directly related to public safety, public health, and major public interests; 3) Directly related to criminal investigation, prosecution, trial, and execution of judgments; 4) Necessary to protect the life, property, and other major legitimate rights and interests of the personal information subject, but it is difficult to obtain the person's consent; 5) The personal information subject voluntarily discloses personal information to the public; 6) Collecting personal information from information legally disclosed, such as lawful news reports, government information disclosure, and other channels.

6. Your Rights During your use of PAPILLON services, we may provide you with specific operational settings, depending on the game product, allowing you to inquire, delete, correct, or withdraw your relevant personal information. You can refer to the specific guidance for the respective game product to perform these operations. Additionally, we have established a channel for complaints and reports, and your feedback will be handled promptly.

7. Changes We may revise this guideline as needed. When the terms of this guideline change, we will prompt you with the updated version in an appropriate manner. Please carefully read the updated privacy protection guideline or guideline content. Your continued use of PAPILLON indicates your agreement for us to collect, process, or use your personal information in accordance with the updated privacy protection guideline.

8. Protection of Minors We attach great importance to the protection of personal information of minors and continue to explore updated ways of protecting personal information of minors. We will actively follow the requirements of national anti-addiction policies to protect the legitimate rights and interests of minors. We will determine whether an account belongs to a minor by verifying their real-name identity information and use information, such as login time and game duration, to guide minors to play games reasonably. After suspecting underage consumption, we will attempt to contact their guardians to provide reminders, confirmation, and handling and help minors to have a healthy online experience. Additionally, to further protect the physical and mental health of minors and encourage healthy internet use by minors, we may implement more stringent anti-addiction measures based on the relevant national policies for online games' anti-addiction. We also continuously research and test various new technologies for protecting minors. To enhance the accuracy of real-name verification and prevent minors from using other people's identity information, we may enable facial recognition verification in specific situations, such as when you log in to the game or during in-game activities involving game recharge, consumption, or trading (if facial recognition is enabled, we will use facial recognition functionality provided by WeChat or QQ to verify your real-name identity information for facial recognition). The facial recognition verification mainly compares the user's real face information with data from public security authorities' data sources. If the two match, the verification is successful, and the user's actual age group determines the corresponding game time limit. If the comparison result does not match or the user refuses verification, we will uniformly treat the user as a minor aged 12 or below and include them in the relevant anti-addiction supervision. The related verification data for facial recognition is encrypted and used only for comparison with public security authorities' data sources; we do not retain it. Furthermore, we may preliminarily determine whether you are a minor by collecting game behavior data generated during your gameplay (such as click pressure and radius, relative click position, acceleration direction, gravity direction, and other data generated when operating the game on terminal devices, as well as voice data generated when interacting with other players through online voice and other means during the game). Regarding voice data, it is only a random sampling of some of your online voice to determine whether it is a child's voice or an adult's voice. If it is preliminarily determined that you are a minor, we may enable facial recognition verification as described above. If you are the legal guardian of a minor, please pay attention to whether the minor under your guardianship uses PAPILLON services or provides their personal information after obtaining your authorization. If you have any questions about the personal information of the minor you are guardian to, please contact us using the contact information provided in section 10. In particular, if you are a child under 14 years of age, to protect the personal information of children, we issued the "PAPILLON Children's Privacy Protection Guideline" on June 5, 2020. Before using PAPILLON services, children and their guardians should carefully read the "PAPILLON Children's Privacy Protection Guideline" and obtain the guardian's consent. Only after obtaining the guardian's consent for the "PAPILLON Children's Privacy Protection Guideline" can you use PAPILLON services.

9. Other The "PAPILLON Children's Privacy Protection Guideline" applies to personal information protection rules for child users under 14 years of age. Within the scope of the "PAPILLON Children's Privacy Protection Guideline," in cases of inconsistency or contradictions with this guideline or the "PAPILLON Privacy Protection Guideline," please follow the "PAPILLON Children's Privacy Protection Guideline."

10. Contact Us If you have any other complaints, suggestions, or issues related to personal information of minors, please send them to us through the customer service feedback system or contact us by email at outlook@papillonx.com.

PAPILLON ENTERTAINMENT LIMITED





PAPILLON Children's Privacy Policy

Update Date: June 5, 2020
Effective Date: June 5, 2020
  Welcome to the selection by PAPILLON ENTERTAINMENT LIMITED (hereinafter referred to as "we"). In this policy, PAPILLON refers specifically to the services provided by PAPILLON ENTERTAINMENT LIMITED as the provider of PAPILLON! In addition to the "PAPILLON Privacy Policy", we will also help you and your children (referred to as "children" in this policy, meaning individuals under the age of fourteen) understand further the collection, use, storage, and sharing of your child's personal information, as well as the related rights that you and your child have.
[Important Note]:
This policy applies to the processing of personal information of minors under the age of fourteen. For the processing of personal information related to you and users over the age of fourteen, please refer to "PAPILLON Privacy Policy" for relevant information.
We will explain the collection of children's personal information and obtain your consent through page prompts, interactive processes, website announcements, and other means. Please read and fully understand "PAPILLON Privacy Policy" and this policy carefully, and choose whether to agree to the above privacy policy.

1. Personal Information of Children We Collect
In the process of your child using PAPILLON services, PAPILLON will only collect personal information about your child that you have agreed to collect or that your child has actively provided in order to provide your child with optimized services and ensure the security of your child's account. For details of the personal information we may collect from your child, please refer to "PAPILLON Privacy Policy". In addition, to verify your guardianship with your child, we may also collect your contact information (including phone number, email) and other information that helps us determine the guardianship relationship.
Currently, apart from collecting game research information from third-party research organizations to help us improve game products and provide better services, we will not actively obtain your child's personal information from third parties outside the PAPILLON group. If, in the future, it is necessary to indirectly obtain your child's personal information from third parties outside the PAPILLON group for business development, we will explicitly inform you of the source, type, and scope of personal information before obtaining it. If the personal information processing activities carried out by PAPILLON for your child exceed the scope of authorization and consent you originally provided to third parties outside the PAPILLON group, we will obtain your explicit consent before processing your child's personal information; in addition, we will strictly comply with relevant laws and regulations and require the third party to ensure the legality of the information it provides.

2. How We Use Children's Personal Information
We strictly comply with laws and regulations and the agreements with users and use the information collected in accordance with this policy and "PAPILLON License and Service Agreement" and "PAPILLON Privacy Policy" to provide your child with better services. For details of how we use children's personal information, please refer to "PAPILLON Privacy Policy". If we use your child's personal information beyond the stated purposes and the scope directly or reasonably related to the collection at the time of collection, we will inform you again and obtain your consent before using your child's personal information.

3. Storage of Children's Personal Information
  3.1 In accordance with the laws and regulations, we will store the personal information of your child collected within the People's Republic of China in the People's Republic of China and protect this information strictly in accordance with the law. If there is a need to transfer the personal information collected domestically to overseas institutions, we will also provide protection for your child's personal information in accordance with domestic laws, administrative regulations, and relevant regulatory authorities.
  3.2 In general, we will only store your child's personal information for the time necessary to achieve the service's objectives or as required by laws and regulations. Beyond the time limit set by laws and regulations or regulations, we will delete or anonymize your child's personal information in accordance with the requirements of laws and regulations.

4. Security of Children's Personal Information
  4.1 To ensure the security of your child's information, we will take reasonable and necessary measures to protect your child's information at the existing technical level, including physical protection, security technology, and management systems, to reduce the risk of loss, misuse, unauthorized access, disclosure, and alteration, including but not limited to data encryption transmission, firewall and encrypted storage, physical access control, and information access authorization control. For this purpose, we have established security procedures to protect your child's information from unauthorized access, and all personal information is stored in encrypted form and placed in an internally protected system behind a firewall.
  4.2 To ensure the security of your child's information, we have established a dedicated management system, processes, and organization to safeguard the security of information. For example, we strictly limit the scope of personnel accessing information, require them to observe confidentiality obligations, and conduct audits.
  4.3 In the event of a security incident involving the disclosure of children's personal information, we will initiate an emergency plan to prevent the incident from spreading, and promptly inform you and your child of the basic information of the security incident, the measures we have taken or will take to deal with it, and our recommendations for your response, through announcements, push notifications, or emails, and, if it is difficult to inform you one by one, we will issue warnings through announcements and other means.

5. Correction of Children's Personal Information
If you and your child find that there are errors in the personal information of your child, you can contact us to correct it.

6. Deletion of Children's Personal Information
  6.1 If you and your child find that we have violated laws, regulations, or the agreement between the two parties in processing children's personal information, or have processed children's personal information beyond the scope or necessary period, you can contact us to delete the relevant personal information.
  6.2 If you withdraw your consent, you can contact us, and we will process it in accordance with the relevant national laws and regulations.
  6.3 If you and your child actively cancel the PAPILLON account and stop using PAPILLON, we will stop using your child's personal information, except as required by laws and regulations or regulatory authorities. If our products or services cease operation, we will notify in accordance with relevant laws and regulations and promptly stop using children's personal information and delete or anonymize stored children's personal information.

7. Transfer and Delegation of Children's Personal Information
Generally, we do not transfer or delegate the processing of children's personal information to third parties. If it is necessary to transfer to or delegate processing to a third party, we will take compliance measures in accordance with the laws, regulations, and administrative regulations, including but not limited to conducting security assessments on third parties.

8. Disclosure of Children's Personal Information
Unless laws and regulations require disclosure or your agreement allows the disclosure of your child's personal information, we will not disclose your child's personal information.

9. Changes
We may revise this policy from time to time. When the terms of this policy change, we will inform you of the changes in an appropriate manner when the version is updated. Please read the revised privacy policy or policy content carefully, and your child's continued use of PAPILLON indicates that you agree to our collection, processing, or use of your child's personal information in accordance with the updated privacy policy.

10. Others
"PAPILLON Privacy Policy" is a general privacy clause applicable to PAPILLON, which includes but is not limited to user rights and information security measures. This policy is a specific privacy policy for children, including special protection for children's personal information. In case of any inconsistency or contradiction between "PAPILLON Privacy Policy" and this policy, this policy shall prevail.

11. Contact Us
If you and your child have any questions about this policy or any related complaints, opinions, or requests, please send your questions to the following address:


We will review the issues as soon as possible, and respond within a maximum of fifteen days or the time limit prescribed by laws and regulations after verifying your identity.

PAPILLON ENTERTAINMENT LIMITED