Privacy Policy

Our Privacy Policy was updated on May20, 2026.

Please take a moment to read this entire Privacy Policy and the Terms of Service to make sure you understand and agree to them before using our Services. Please contact us if you have any questions.

About us

HONGKONG TENGYANG CO.，Limited (hereinafter referred to as, " TENGYANG ", "we", "our", "us") take your privacy very seriously. This Privacy Policy is designed to provide you with a clear understanding of how we collect and use personal information when you visit or use our services, and to help you exercise control over the personal information you provide to us.

About this privacy policy

This Privacy Policy explains how TENGYANG collects, uses, discloses, processes, and protects any personal information that you provide us or that we collect from you. We will only process your personal information where we have a lawful basis for doing so. Should we ask you to provide certain information by which you can be identified when you use the TENGYANG services, it will only be used in accordance with this Privacy Policy and/or our terms and conditions for users.

Under this Privacy Policy, “personal information” means any information from or about an identified or identifiable person, including information that TENGYANG can associate with an individual person. We’re only describing our own practices—this Notice doesn’t cover the practices of third parties we don’t control.

When we say “TENGYANG Services,” we mean our games, websites, applications, entertainment content, partnerships, events, activities, and services that link to this Policy, regardless of how you access or use them or engage with us, including through mobile devices or offline such as by phone. Your use of the TENGYANG Services is also subject to the Terms of Service in your region (including its provisions regarding limitations on damages, resolution of disputes, and application of governing law).

Contact Us

Ultimately, what we want is the best for all our users. Should you have any concerns with our data handling practice as summarized in this Privacy Policy, please contact [email protected] to address your specific concerns. We will be happy to hear from you.

1. What information is collected and how can we use it?

1.1 What information is collected by us?

In order to provide our services, We collect personal info you choose to provide, either directly, automatically (like with cookies or scripts), or via third parties. We will only collect the information that is necessary for its specified, concrete, explicit, and legitimate purposes and not further processed in a manner that is incompatible with those purposes. You have the right to choose whether or not to provide the information we have requested, but in most cases, if you do not provide your personal information, we may not be able to provide you with our services or respond to your queries. If you disclose any personal info relating to other people in connection with the TENGYANG Services, you represent that you have the authority to do so and to permit us to use the personal info in accordance with this Notice. We do not collect sensitive personal info, as defined under comprehensive state privacy laws, including the California Consumer Privacy Act and the European Union’s GDPR.

Depending on the service you choose, we may collect the following types of information, along with their respective lawful bases for processing:

1.1.1 Information that you provide to us directly (Lawful Basis: Performance of a contract or Consent)

We may collect any personal information you provide to us, which is necessary for the service you choose. For example, you may provide your Google/Facebook Account information or your Apple ID information when you sign in; you may provide us your email address when you send feedback to us and/or wish to receive emails from us; Other data you choose to give us (such as name and phone number when you participate in certain services from us).

1.1.2 Information that we collect automatically in your use of services

• Device or SIM-related information. For example, Google Advertising ID (GAID), Android ID, Mac address, Android version, screen display information, device manufacturer details, network operator, connection type, and basic hardware information.. Lawful Basis: Consent (for advertising identifiers), Legitimate Interests (for strictly necessary operational purposes like security and service delivery).
• Information specific to you that may be assigned by third-party service providers and business partners. We may collect and use the information such as your advertising ID assigned by third-party service providers and business partners. Lawful Basis: Consent.
• Information related to your application usage, including application basic information, such as application version, application settings (region, language, and time zone), and application status record. Lawful Basis: Performance of a contract, Legitimate Interests (for service improvement and analytics).
• Information generated when you use a service, Including each interface’s dwell time, the game running, click settings, click on leaderboards, click to collect, click on honors, click on draw/unlock button and the number of gold coins at the time, the game is over, active click incentive ads after the game over, collect Active clicks on the interface to motivate ads, autoplay video ads, and duration, achievement activation, click on the ads button. Lawful Basis: Performance of a contract, Legitimate Interests (for service improvement and analytics)
• Log information: information related to your use of certain functions. For example, IP addresses, crash information, log information generated by using the services. Lawful Basis: Legitimate Interests (for diagnosing service failures, maintaining security, and providing user support).
• Purchases information: transaction ID, purchased time, cost, product purchased, and device details including OS version, a phone model. Lawful Basis: Performance of a contract, Legal Obligation.

1.1.3 Non-personally identifiable information

We may also collect other types of information that are not directly or indirectly linked to an individual and which may not be defined as personal information according to applicable local laws. Such information may include statistical data generated when you use a specific service (e.g. daily usage events, page access events, page access time events, and session events); network monitoring data (e.g. request time, number of requests or error request, etc.); application crash events. The purpose of such collecting is to improve the services we provide to you. The type and amount of information collected depend on how you use our services.

Such data is not personal information as it cannot be used to identify you. However, if we combine non-personal information with personal information, such information will be treated as personal information. and processed in accordance with this Privacy Policy, including adherence to all personal data protection principles.

1.2 How and Why we use the personal information that we collect

The purpose of collecting personal information is to provide you with our services and to ensure that we comply with applicable laws, regulations, and other regulatory requirements. Here are more detailed examples of how we use your information (which may include personal information), along with their respective lawful bases for processing:

• Operating basic features. We may use your information to run interactive features such as notify you about changes to our service and communicate with you. Lawful Basis: Performance of a contract, Legitimate Interests.
• Record game settings and progress: To make it easier for you to find and use previous game records, we provide you with records of the progress of the game, including but not limited to points, virtual currency, etc., as well as recording user’s game settings, including but not limited to sound, vibration, etc. When you log in to this Product, you can choose to skip the previously passed levels without starting over. We also record your game’s highest score and game achievements for leaderboard features. We provide the ability to delete history, you can delete the history as needed. Lawful Basis: Performance of a contract, Legitimate Interests
• Conducting relevant promotional activities, such as providing marketing and promotional activity and coupons. Lawful Basis: Consent (you can opt-out at any time).
• Conducting data analysis. Device related information and application related information may be used to analyze and develop statistical information on the use of our services to ensure the stability and security of the application. Lawful Basis: Legitimate Interests (to improve and secure our services, after a balancing test).
• Payment transactions: in order to maintain a record of your transaction history and provide restore purchase service for payments on Google Play or iOS App Store. Lawful Basis: Performance of a contract, Legal Obligation
• In-App Purchases: This Product enables in-app purchases. We do not process payments for in-app purchases nor have access to your credit card information. Lawful Basis: Performance of a contract.
• Improving user experience. To improve, promote, and develop the quality of our services of this Product and thus provide you with better services and new services. Lawful Basis: Legitimate Interests (to enhance user experience and service quality, after a balancing test)
• Diagnosing service failures. Logs information may be used to help diagnose service or technical problems, maintain security, and provide you with user support. Lawful Basis: Legitimate Interests (to ensure service stability and security).

1.3 Lawful Bases for Processing

We will only process your personal information when we have a lawful basis to do so under applicable data protection laws. The lawful bases we rely upon include:

Your Consent: Where you have given us explicit consent to process your information for a specific purpose, such as for sending you marketing communications or for placing cookies/advertising identifiers on your device for personalized advertising. You have the right to withdraw your consent at any time.

Performance of a Contract: Where the processing is necessary for the performance of a contract with you, such as providing you with the game services you have requested, processing your in-app purchases, or maintaining your game progress.

Legitimate Interests: Where the processing is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. This includes using your information for analytics, fraud prevention, security, and improving our services. We will always balance our interests against your rights.

Compliance with Legal Obligations: Where we are required to process your information to comply with a legal or regulatory obligation.

2. How we share, transfer and publicly disclose your personal information

2.1 Sharing

We do not sell your personal information in the traditional sense. However, we may share your personal information for cross-context behavioral advertising, which may be considered 'sharing' under certain privacy laws like the CCPA/CPRA. You have the right to opt-out of such sharing. We may sometimes share your personal information with third parties (as described below) in order to provide or improve the products or services based on your requirements.

2.1.1 Sharing that you actively choose or request

With your explicit consent or at your request, we will share your personal information within the scope of your consent/request with specific third parties designated by you. Lawful Basis: Consent.

2.1.2 Sharing information with our group

In order to successfully conduct business operations and to provide you with all the functions of our services, we may share your personal information from time to time with other TENGYANG affiliated parties. Lawful Basis: Legitimate Interests (for efficient business operations and comprehensive service provision).

2.1.3 Sharing with Third Party Service Providers and Business Partners

To help us provide you with services described in this Privacy Policy, we may where necessary, share your personal information with our third-party service providers and business partners. We will conduct due diligence and have contracts in place to ensure that third-party service providers comply with the applicable privacy laws in your jurisdiction and implement appropriate security measures. We may share your information with analytics providers to help us in the optimization and improvement of the application. These partners may access your data and operate under their own privacy policies. We encourage you to check their privacy policies to learn more about their data processing practices. Lawful Basis: Performance of a contract, Legitimate Interests.

2.1.4 Other

We may disclose your personal information in accordance with legal requirements, legal procedures, litigation, and/or requests from public agencies and government agencies. Such disclosure will only occur to the extent legally required or permitted. If the disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance, we may also disclose information about you. In order to enforce our terms or protect our business, rights, assets or services, or to protect users, or if the disclosure is reasonably necessary for the following purposes (detecting, preventing and resolving fraud, unauthorized use of the service, violations of our terms or policies, or other harmful or illegal activities), we may also disclose information about you. Lawful Basis: Legal Obligation, Legitimate Interests (for security, and protection of rights).

In addition, we may share your personal information with:

• our accountants, auditors, lawyers, or similar advisers when we ask them to provide us with professional advice; and
• investors and other relevant third parties in the event of an actual or potential sale or other corporate transaction related to an entity in the TENGYANG and its affiliated parties; and
• any other third parties, if authorized by you to do so in relation to a specific disclosure.

2.2 Transfer

TENGYANG will not transfer your information to any subject except in the following cases:

• Where we have obtained your explicit consent;
• If we are involved in the merger, acquisition, or sale of all or part of its assets, we will notify you of any changes in the ownership, use, and any choice of your personal information you possibly possess by email and/or by posting a prominent notice on our application.

International Data Transfers:

Our Service is global by nature, and your data can therefore be transferred outside of the jurisdiction in which you reside. Because different jurisdictions may have different data protection laws than your own, we take steps to ensure adequate safeguards are in place to protect your data as explained in this Privacy Policy.

When your personal information is transferred outside of your jurisdiction, particularly to countries outside the European Union/European Economic Area (EU/EEA), we ensure that such transfers comply with applicable data protection laws, including GDPR. We will rely on appropriate safeguards such as:

• Standard Contractual Clauses (SCCs) approved by the European Commission;
• Adequacy Decisions by the European Commission for certain countries;
• Binding Corporate Rules (BCRs) approved by competent supervisory authorities;
• Your explicit consent after being informed of the possible risks of such transfers for you due to the absence of an adequacy decision and appropriate safeguards.

We will take all necessary steps to ensure that your personal information receives an adequate level of protection in the jurisdictions to which it is transferred. For services operating in countries with data localization requirements, such as India and Russia, we will comply with local regulations by storing relevant personal information in local data centers.

2.3 Public Disclosure

TENGYANG will only publicly disclose your personal information under the following circumstances:

• Where we have obtained your explicit consent;
• Public disclosure based on law or reasonable grounds: including laws and regulations, legal procedures, litigation, or at the request of the competent government departments, or when it is reasonably necessary to protect our rights, property, or safety, or the rights, property, or safety of others. Lawful Basis: Legal Obligation, Legitimate Interests.

3. How we store and protect your personal information

3.1 TENGYANG 's security safeguards

We are committed to keeping your personal information secure. In order to prevent unauthorized access, disclosure, or other similar risks, we have put in place legally required physical, electronic, and managerial procedures to safeguard and secure the information we collect on your using our services. We will ensure that we safeguard your personal information in accordance with applicable law. All your personal information is stored on secure servers and protected in controlled facilities. We classify your information based on importance and sensitivity and ensure that your personal information has the required level of security. We regularly review our information collection, storage, and processing practices, including physical security measures, to guard against any unauthorized access and use. We implement specific technical and organizational measures such as data encryption, pseudonymization, access controls, data backup and recovery mechanisms, and regular security audits and penetration testing. We conduct due diligence on third-party service providers and business partners to make sure that they are able to protect your personal information. We also check those appropriate security standards are maintained by these third parties by putting in place appropriate contractual restrictions, and where necessary, carrying out audits and assessments. In addition, our employees and those of our business partners and third-party service providers who access your personal information are subject to enforceable contractual obligations of confidentiality. We conduct security and privacy protection training courses and tests to enhance our employees' awareness of the importance of protecting personal information. We will take all practicable steps to safeguard your personal information. However, while we strive to protect your personal information, the use of the Internet is not entirely secure, and for this reason, we cannot guarantee the absolute security or integrity of any personal information when transferred from you or to you via the Internet. We handle personal data breaches as required by applicable data protection law which includes, where required, notifying the breach to the relevant data protection supervisory authority and data subjects.

3.2 Retention Policy

We retain personal information for the period necessary for the purpose of the information collection described in this Privacy Policy, or as required by applicable laws. The retention period is determined based on the type of data, the purpose of collection, legal requirements. We will cease to retain and delete or anonymize personal information once the purpose of collection is fulfilled, or after we confirm your request for erasure, or after we terminate the operation of the corresponding service. An exception to this is personal information that we are processing for the public interest, scientific, historical research, or statistical purposes. TENGYANG will continue to retain this type of information for longer than its standard retention period, where permitted based on applicable laws or your request, even if further data processing is not related to the original purpose of collection.

4. Your Rights

4.1 Controlling Settings

TENGYANG recognizes that privacy concerns differ from person to person. Therefore, we provide examples of ways TENGYANG makes available to you on the collection, use, disclosure, or processing of your personal information and control your privacy settings.

If you have previously agreed to us using your personal information for the aforementioned purposes, you may change your mind at any time by clear your app data or emailing us [email protected]. Withdrawing consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

4.2 Your rights to your personal information

Depending on applicable laws and regulations, you have the right to access, rectification, and erasure of any other personal information that we hold about you (hereinafter referred to as the request).

You may also write to us or contact us at the email address below.

Email: [email protected]

This Privacy Policy requires that your request satisfy applicable laws and regulations and the following conditions:

• 1. Through TENGYANG 's exclusive access to request and for the protection of your information security, your request should be in writing (unless the local law explicitly recognizes the oral request);
• 2. Provide sufficient information to enable TENGYANG to verify your identity and ensure that the applicant is the subject or legally authorized person of the requested information.

Once we obtain sufficient information to confirm that your request can be processed, we shall proceed to respond to your request within any timeframe set out under your applicable data protection laws.

In detail:

• You have the right to be provided with clear, transparent, and easily understandable information about how we use your personal information and your rights. This is why we are providing you with the information in this Privacy Policy.
• If any information we are holding on you is incorrect or incomplete, you are entitled to have your personal information corrected or completed based on the purpose of use.
• Based on the requirements of applicable laws, you have the right to request the deletion or removal of your personal information where there is no compelling reason for us to keep using it. We shall consider the grounds regarding your erasure request and take reasonable steps, including technical measures. If the right is upheld, we may not be able to immediately remove the information from the backup system due to applicable legal and security technologies. If this is the case, we will securely store your personal information and isolate it from any further processing until the backup can be cleared or be made anonymous.
• We have the right to refuse to process requests that are not meaningful/entangled, requests that damage others' right of privacy, extremely unrealistic requests, requests that require disproportionate technical work, and requests not required under local law, information that have been made public, the information given under confidential conditions. If we believe that certain aspects of the request to delete or access the information may result in our inability to legally use the information for the aforementioned anti-fraud and security purposes, it may also be rejected.

4.3 Your right to delete account data

4.3.1. You have the right to delete your account data at any time.

When you decide to delete your account for this application or service, unless otherwise provided by laws, regulations or this agreement, your personal information under the account will be deleted or anonymized. Once the deletion of this account is completed, it cannot be restored. Please proceed with caution.

4.3.2. Account deletion steps

• 1. You log in to this application, click the avatar in the upper left corner, select "Settings", and click the "Account Deletion" option at the bottom.
• 2. You need to read the deletion conditions carefully. When you have read and understood them all, check the option you have read and click "Next Step".
• 3. You need to read the deletion agreement carefully. When you have read and understood them all, check the option you have read and click "Next Step".
• 4. You need to read the results after deletion carefully. If you are sure you want to delete your account, click the "Account Deletion" button; if you do not want to delete, you can click the "Cancel" button to end the deletion.
• 5. After you confirm the deletion, you will have the option to delete your account immediately or to have a 15-day grace period during which you may log in and cancel the deletion. If you do not cancel within that period, your account data will be anonymized and the account will become unusable. If you wish to proceed with immediate deletion without the consideration period, please contact us at [email protected], we will process your request without delay.

5. How your personal information is transferred globally

We process and backs up personal information through a globally operating and control infrastructure. Currently, we have data centers in the United States and Singapore. For the purposes described in the Privacy Policy, your information may be transferred to these data centers in accordance with applicable law.

If we need to transfer personal information outside of your jurisdiction, whether to our affiliates or third-party service providers, we will comply with related applicable laws. We ensure that all such transfers meet the requirements of applicable local data protection laws by implementing uniform safeguards. The jurisdiction in which these global facilities are located may or may not protect personal information to the same standards as in your jurisdiction. There are different risks under different data protection laws and that we may transfer and store your personal information to overseas facilities. However, this does not change our commitment to comply with this Privacy Policy and to protect your personal information.

6. Protection of minors

We consider it the responsibility of the parent or guardian to supervise the child's use of our services. However, we do not offer services directly to a child or use personal data of children for the purposes of marketing.

If you are a parent or guardian and you believe that the minor has provided TENGYANG with personal information, please contact us at [email protected] to ensure that the personal information is removed immediately and that the minor is unsubscribed from any of the applicable TENGYANG services.

7. Do I have to agree to any third party terms and conditions?

Our Privacy Policy does not apply to products or services offered by a third party that act as independent data controllers. Depending on the service you use, it may incorporate a third parties’ products or services. Some of these will be provided in the form of links to third parties’ websites, and some will be accessed in the form of SDKs, APIs, etc. Your information may also be collected when you use these services. For this reason, we strongly suggest that you take the time to read the third party’s privacy policy just like you read ours.

When we share your personal information with third-party service providers acting as our data processors, we enter into Data Processing Agreements (DPAs) with them, requiring them to comply with applicable data protection laws and implement appropriate security measures. However, for situations where third parties act as independent data controllers or where you directly provide information to them, we are not responsible for and cannot control how they use the personal information they collect from you. Our Privacy Policy does not apply to other sites linked from our services.

8. Children

Protecting children’s privacy online is very important to us. Generally, our Services are not marketed to, or intended for children under 13 (or other age as required by local law). We strive to follow the different minimum age guidelines set by the laws of individual regions when determining the age that children can access certain features of our service. Our Services do not knowingly collect personal data from children, except as described in the following paragraph.

Though our services are not intended for children as the primary audience, we may collect age information before allowing a user to proceed for certain services. If we learn that we have inadvertently gathered personal information about a child that is not subject to an exemption under applicable privacy law, we will take measures to promptly remove that information from our records.

9. How we update this privacy policy

We review the Privacy Policy periodically based on changes in business and technology, and we may update this Privacy Policy. If we make a material change to this Privacy Policy, particularly changes that affect your rights, introduce new data processing purposes, or change the legal basis for processing, we will notify you via your registered contact information such as email (sent to the email address specified in your account) or publish on the homepage of the services, or notify you via mobile devices For such material changes, we will seek your explicit consent before applying the changes to your personal information. Your continued use of the services on the website, mobile, and/or any other device after being notified of non-material changes will be deemed an acknowledgment of the updated Privacy Policy. We will ask for your explicit consent when we collect additional personal information from you or when we use or disclose your personal information for new purposes.

10. Contact us

If you have any comments or questions about this Privacy Policy or any questions relating to TENGYANG’s collection, use, or disclosure of your personal information, please contact us at the address below referencing “Privacy Policy”.

HONGKONG TENGYANG CO.，Limited Email: [email protected]

Thank you for taking the time to read our Privacy Policy!

11.【SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC】

11.1. Additional Information for US Residents

(1) General

Certain U.S. states* have enacted consumer privacy laws that grant their residents certain rights and require additional disclosures. If you are a resident of one of these states, this section applies to you.

*Including California, Colorado, Delaware, Iowa, Connecticut, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, and Virginia.

In order to provide our Services to you, we collect and process the categories of personal data described in more detail in Section 1, for one or multiple purposes described, and for any other purposes for which we provide specific notice at the time the information is collected.

We do not “sell” your personal information with third parties as most people would understand that term. However, we may share data about you collected via cookies, and advertising identifiers with our third-party partners in order to deliver interest-based and targeted advertisements, attribute installations and to optimize advertising campaign performance.

To the extent that this practice is considered a “sale” under applicable law, you may opt out by following the steps described in our Privacy Policy or Terms of Services.

(2) Data Collection and Processing for Children in US

For users in the United States identified as under age 13, we do not collect, use, or disclose personal information from such users without first obtaining verifiable parental consent in accordance with the Children’s Online Privacy Protection Act (COPPA).

If we have actual knowledge that a user is under 13 and verifiable parental consent is not obtained within 14 days of that knowledge, we will delete the child’s account and all related personal information. “Delete” means the information is removed so that it is not maintained in retrievable form and cannot be retrieved in the normal course of business

We may retain certain limited categories of personal information only as permitted by COPPA (such as persistent identifiers used solely for internal operations, or information required by law), solely for the purposes permitted. Any retained information will be deleted when no longer reasonably necessary.

11.2. Additional Information for the EEA and UK Residents

As a global company, we may transfer your personal data to our affiliates, third party service providers and partners that operate around the world, which are located in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.

Where we transfer your personal information to countries and territories outside of the European Economic Area and the UK, which have been formally recognized as providing an adequate level of protection for personal information, we rely on the relevant "adequacy decisions" from the European Commission, where applicable.

Where the transfer is not subject to an adequacy decision, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy. The safeguards we use are the European Commission's Standard Contractual Clauses as issued on 4 June 2021, including the UK Addendum, and/or the UK International Data Transfer Agreement permitted under Article 46 of the UK GDPR. This is how transfers of personal information between us and other companies will be safeguarded. All companies are required to protect personal information that they process from Europe in accordance with European Union data protection law. Transferred personal information includes basic information such as your name or contact information such as your email address.