Privacy Policy


Effective Date: December 3, 2020

Hong Kong Bao Chuan Software Technology Limited and its affiliates (collectively “ Boltrend” or “ we”) is the data controller for the processing of your personal data. We have always solemnly promised to protect the privacy of users who use the Boltrend Game Service (the “ User” or “ you”). When you use Boltrend Games Service, we may collect and use your information. We hope to explain relative matters such as our processing rules in collecting and using your personal information in this Privacy Policy in order to better protect your rights and interests.

This Privacy Policy applies to the Boltrend Game Service (the “Services”) provided by us. When you use the Service, you agree to accept this Privacy Policy.

Please make sure you have carefully read and fully understood this Privacy Policy before you begin to use the Services, especially for the highlighted terms with bold and underlining which requires your special attention. If you do not agree with the content of this Privacy Policy, it may cause Services to be unable to operate normally, or unable to achieve the service effect we intend to achieve, then you should immediately stop accessing/using the Services.

After reading this Privacy Policy, if you have any questions about this Privacy Policy or matters regarding this Privacy Policy, please contact us via the channels in Section IX “How to contact us”, and we will respond to you as soon as possible.


I. How will we collect and use the information and our legal basis for processing it

II. How will we use cookies and similar technologies

III. How we share and store the information

IV. How will we keep, save and protect the information

V. How to manage your information

VI. Service provided by third parties

VII. Protection of Minors

VIII. Notice and amendment

IX. How to contact us

I. How will We Collect, Use the Information and Our Legal Basis for Processing It

We collect your information primarily to make it easier and more satisfying for you and other Users to use the Services. Our goal is to provide all internet users with safe, exciting, funny and instructive internet experience and this information helps us achieve this goal.

(I) We will collect and obtain your information through the following ways:

1. Information provided by you. For example:

(1) information provided by you when you register an account for the Services or use the Services;

(2) sharing information provided by you to other parties through the Services, and information saved when you use the Services.

Please note, if you post or upload any information in the public areas of the Services where other Users can see your information, or you publicly disclose your information in your response to other Users, such information may be collected and used by other Users. If you found your information has been improperly collected or used by a third party, you can contact us via the channels in Section IX “How to contact us”.

2. Your information shared by other parties. Referring to the information about you provided by other parties when they use the Services.

3. Your information obtained by us. The information collected, aggregated and recorded by us when you use the Services, such as log information, location information and device information.

(II) We will collect and use your information for the following purposes and legal basis:

1. Help you to complete the registration and log in: necessary for the performance of our contract with Users

In order for us to provide services for you, you need to provide basic registration or login information, such as mobile phone number, email address, etc., and create your account name, username and password.

In some Services, if you provide or supplement additional information (such as your nickname, gender, hometown, date of birth, icon, hobbies, professions, education background, language preferences) in the registration, log in process or during your subsequent use, it helps us to provide you with personalized recommendations and better service experience; but if you failed to do so, it shall not affect your use of the basic functions of such Services.

2. Conduct identity authentication: fulfil your and our legitimate interests

According to applicable laws and regulations and as required by regulatory authorities, in order to do user identity verification, to ensure system and service security, or as required by certain functions or specific services, you may be required to provide information about your authentic identity (such as name, ID card, passport, driver’s license, household register, facial features, figure prints and other identity information) to complete identity authentication. If you do not provide above information, we will not be able to provide such functions or services.

3. Maintain the normal operation of basic functions: necessary for the performance of our contract with Users

During your use of the Services, in order to identify account abnormal status, learn about product suitability, provide you with basic functions such as browse and search, maintain the normal operation of basic functions, we may collect and store information about your use of the Services and how you use the services by automatic means, and may correlate such information, which includes log information, device information, IP Address, etc.

4. Provide interactive and content release services to you: fulfil your and our legitimate interests

When you are using the Services, we will collect the information that is received as a result of your behavioural actions when using the Services (including your game actions and achievements, badges), and we will use this information in order to manage and administer the Services, including providing the Services to you;

5. Help you to place orders, make payments and facilitate delivery of products and services to you: necessary for the performance of our contract with Users

We use this information in order to manage and administer the Services, we will collect the Information of your use of the payment features of Services (for example, the first and last four digits of your bank card), information about payments (date, amount, payment type, payment status), information about Services purchased (name, amount), information about the activation status Services purchased. We may also use such information in order to investigate any complaints on your behalf and to provide you with a more efficient service.

6. Provide customer support services and other responses to you: fulfil your and our legitimate interests

When you contact our customer support or use other response functions we may need you to provide necessary personal information to match and verify your user identity, so as to protect the security of your account and the system. We may also store your contact information, your communication/call history and conversation or other necessary information relating to your needs, in order to contact you or help you solve problems, or to document the solutions and results of the related issues.

7. Your information collected indirectly by us: necessary for the performance of our contract with Users

We may collect your information from our affiliates and third-party partners which you have authorized to share your information. Such as, we may collect your account information (including but not limited to user ID, icon and nickname) that you shared with third parties, and combine your third-party account with your Service account so that you could login the Services using your third-party account. We will collect and use such information according to applicable laws and regulations and agreements between us and our affiliates/third party partners, and also on the precondition that we believe that such information is collected from legitimate source.

8. Provide information about the products/services or push notifications to you

(1) Show and push products or services for you: your consent

Based on the information that you provided to us, We may use emails, text messages or other methods to send marketing information, provide or promote our or third parties’ following goods and services to you based on feature tags:

Our goods and services: carefully selected news, event information and special offers about Boltrend products and services; and

Third party goods and services: carefully selected news, event information and special offers about third-party products and services .

(2) Send notices to you: fulfil your and our legitimate interests

We may send you notices related to the Services when necessary (for example when we suspend partial service, change, or stop providing partial service due to system maintenance). If you do not wish to continue to receive messages we have pushed, you may request us to stop the push, except those we send according to applicable laws or the service agreement.

9. Legal Obligation

We may use or process your information due to a legal obligation or right, including using information for legal compliance, litigation or pre-litigation, and security monitoring and investigations.

10. You understand and agree that, some Services may require your consent for specific access authorization to us in order to collect and use the information relating to such access. You can withdraw your consent to any access authorization above at any time. However, your withdrawal of any access authorization will not impact our collection and use of your information based on your previous authorization.

II. How We use COOKIES and Similar Technologies

We may obtain and use your information through COOKIES and other similar technologies and save the information as log information.

By using COOKIES, we provide Users with a simple and easy-to-use personalized web experience. A COOKIES is a small amount of data that is sent from a web server to your browser and stored on your computer's hard drive. We use COOKIES to allow Users to benefit. For example, to make the login process of the virtual community faster, you can choose to save the username in a COOKIES. This will make it easier and faster to login into the Services next time. COOKIES can help us to determine the webpages and content you are connected to, time you spend on certain Services you have chosen.

COOKIES enable us to serve you better and faster, and to make your experience on the Services more personal. However, you should be able to control whether and how COOKIES is accepted by your browser. Please check the documentation attached to your browser for more information on this.

The Services may have COOKIES and other similar technologies placed by advertisers and other partners. These COOKIES and similar technologies may collect non-personally identifiable information related to you for analyzing how users use such services, sending you advertisements that may be of interest to you, or evaluating the effectiveness of advertising services. The collection and use of such information by these third parties’ COOKIES and similar technologies are not governed by this Privacy Policy, but are governed by its own personal information protection statement, and we are not responsible for the third party's COOKIES or similar technologies.

You can reject or manage COOKIES or similar technologies through the browser or user selection mechanism. However, please note that if you disable COOKIES or similar technologies, we may not be able to provide you with the best service experience, and some services may not work properly. At the same time, you will still receive ads, but the relevance of these ads to you will decrease.

III. How We Share and Store the Information

(I) Share

Except for the following circumstances, without your consent, we will not share your information with any third party:

1. to provide you with our services. We may share your information with our partners and other third parties in order to provide relevant information to payment service provider, merchants on the Service platforms, or connect with other third party SDK or other similar applications, and share some of your personal information collected based on this Privacy Policy so as to provide better customer services and user experiences as follows:

We may also share your information with our partners and other third parties in order to provide data services (including online advertising monitoring, data statistics and data analytics), such as third party logistics service providers and other service providers, in order to provide the services you need. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard it.

2. to share with our affiliates as necessary. In order to provide consistent services from our unified account system, to enable your unified management of your use of the Services, to provide you with personalized recommendation, to ensure system and account security, your information may be shared among us and our affiliates as necessary;

3. to achieve the purposes and subject to the legal basis described in Section I “How will we collect and use the information and our legal basis for processing it” of this Privacy Policy;

4. to the extent permitted by laws and regulations, in order to comply with the law, protect the interest, property or safety of us and our affiliates or partners, you or other Users, or the public interest, property or safety from harm, such as to prevent fraud and other illegal activities and reduce credit risk, we may exchange information with other companies and organizations (e.g., to law enforcement agencies, Courts, our third-party legal advisors). However, this does not include information sold, rented, shared, or otherwise disclosed for profit making in violation of the commitments made in this Privacy Policy.

5. provide your information in response to the legitimate requests of your guardian;

We will only share your information for legitimate, justifiable, necessary, specific, and explicit purposes. For companies, organizations, and individuals with whom we share the information, we will sign strict confidentiality agreements with them and ask them to process information in accordance with our instructions, this Privacy Policy, and any other relevant confidentiality and security measures.

(II) Store

In order to perform our contract with you, your personal information will be accessible from and will be processed on our servers (depending upon your location and the game server you select), which locate including but not limited to:

IV. How Will We Keep, Save and Protect the Information

We retain your information only during the period required by the purposes described in this Privacy Policy (i.e. until deletion in accordance with your request) and within the shortest time limits required by applicable laws and regulations. If we terminate our services or operations, we will timely stop collecting your personal information, give you prior notice according to applicable laws and regulations, and delete or anonymize your personal information after termination of services and operations unless otherwise provided by applicable laws or regulatory bodies’ requirements.

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 also protect data through the use of technological protection measures such as encryption. Your personal information will remain subject to our technical and organisational controls and our policies and procedures (including this Privacy Policy). In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of your information. Please understand that due to technical limitations and risk prevention limits, even if we have strengthened our security measures as much as possible, we cannot always guarantee 100% security of the information. You need to understand that the system and communication network used by you to access to the Services may have problems due to circumstances beyond our control.

Please do ensure your account, password and other identity elements are well kept. When you are using the Services, we will identify you using your account, password and other identity elements. Once you leaked the foregoing information, you may suffer from loss and other adverse impacts. If you found your account, password and/or other identity element has been leaked, please contact us immediately so that we could timely take relevant measures to avoid or reduce the losses.

V. How to Manage Your Information

(I) Access, Rectification, Delete and Portability

We encourage you to update and modify your information to make it more accurate and effective. You can access your information through the Services, and complete by yourself or request us to modify, supplement or delete according to the ways of managing corresponding information. You can also object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your information.

When you exercising the rights hereinabove, please contact us via the channels in Section IX “How to contact us” , we may ask you to do identity verification to keep your information secure. For your information collected through COOKIES and similar technologies, we also explain the selection mechanism provided to you in Section II “How We Use COOKIES and Similar Technologies”of this Privacy Policy. . We may retain personal information necessary to: (a) protect our business, systems, and users from fraudulent activity, (b) to address technical issues that impair existing functionality, (c) necessary for us, or others, to exercise their free speech or other rights, (d) comply with law enforcement requests pursuant to lawful process, (e) for scientific or historical research, (f) for our own internal purposes reasonably related to your relationship with us, or to comply with legal obligations.

(II) Californian Residents’ Rights

The California Consumer Privacy Act of 2018 (CCPA), may afford rights to the Users who are California residents:

(1) Right to Know:

If you are a California resident, you may submit, free of charge, but no more than twice in a 12-month period, a verifiable request for the following information:

(a) The specific pieces of personal information we have about you;

(b) The categories of personal information we collected, sold, or disclosed for a business purpose about you within the last 12 months;

(c) The categories of sources from which the personal information was collected;

(d) The purposes for which the information was collected or sold; and

(e) The categories of third parties to whom the information was sold, disclosed for a business purpose, or otherwise shared.

Following any request, we will verify your identity using at least two data points. You may also authorize an agent to submit a request on your behalf, so long as you provide the authorized agent written permission to request on your behalf, and your authorized agent is able to verify their identity with us.

(2) Right to Opt-Out:

California residents may opt out of the “sale” of their personal information, as defined by the CCPA. This does not include when:

(a) You direct us to disclose your personal information or use us to interact with a third party and the third party does not sell the personal information;

(b) We use or share an identifier solely to alert a third party you have opted out of the sale of your personal information;

(c) Your personal information is transferred as an asset as part of a transaction in which the third party assumes control of all or part of our business, in which case the third party would have to tell you in writing if it materially changes how the information is used or shared; and

(d) We use or share your personal information under a written contract with a service provider necessary to perform a business purpose. Here, the service provider performs is on our behalf, and our written contract prohibits it from keeping, using or disclosing your personal information for any purpose other than for the specific purpose identified in the contract.

In these cases, the disclosure of your personal information would not be considered a “sale” under CCPA. We use and share your information as described in this Privacy Policy and do not believe this use and sharing is a sale as defined by the CCPA. We have not sold personal information about you in the last 12 months and currently have no plans to do so in the future.

Any requests may be made as described in Section IX below. And of course, we do not discriminate against our users on the basis of their exercising any of their rights afforded by the CCPA, which is further in accordance with California residents’ rights under that title.

Following any request, we will verify your identity using at least two data points. You may also authorize an agent to submit a request on your behalf, so long as you provide the authorized agent written permission to request on your behalf, and your authorized agent is able to verify their identity with us.

(III) Change the Scope of your Authorization

You can always select whether to disclose the information. Some information is required to use the Services, but the provision of most other information is on your decision. You can change the scope of your authorization to us to continue to collect the information or withdraw your authorization by means of deleting information, turning off device functions and so on.

After you withdraw your authorization, we are unable to continue to provide you with the Service corresponding to the withdrawal of the authorization, and will not process your corresponding information. However, your decision to withdraw your authorization will not affect the information processed previously based on your authorization.

VI. Service Provided by Third Parties

The Services may link to the social media or other services provided or operated by third parties (including websites or other forms of services).Your use of the social media services or other services of such third parties (including the provision of your information by you to such third parties) must be subject to the terms of service and information protection statement of such third parties (but not this Privacy Policy) and you must read carefully their terms. This Privacy Policy only applies to any information collected by us, but does not apply to services provided by third parties or information use rules of third parties. If you found any risks with these third-party social media and other services, we recommend you to stop relevant usages in order to protect your legitimate interests.

VII. Protection of Minors

We do not knowingly collect any personal information from children under 16 years old, and we recommend that anyone under the age of 16 read this Privacy Policy together with your Guardian and seek your Guardian’s consent and guidance before submitting information and using the Services. However, if the parent or the guardian of a child under 16 (“Guardian”) believes that the child has provided us with personal information, the parent or guardian of that child should contact us at the channel provided in Section IX, if they want this information deleted from our files. We may require that the Guardian provide identity authentication to prove his/her guardianship.

VIII. Notice and Amendment

In order to provide you with better services, we may revise the terms of this Privacy Policy as appropriate according to updates of products and services and requirements of applicable laws, and such modifications form part of this Privacy Policy. For major changes that may cause substantial decreases or changes of your rights under the Privacy Policy, we will provide notices by website announcement, push notification, pop-up prompts and other means before such changes come into effect, and if you do not agree to such changes, you may choose to stop using the Services; if you continue to use the Services, you are deemed to have carefully read, understood and agreed to be bound by this Privacy Policy as revised.

Any amendment will put your satisfaction in the first place. We encourage you to review our Privacy Policy each time you use the Services.

We may post service-related announcements when necessary (for example, when we suspend certain service due to system maintenance). You may not be able to cancel these announcements that are related to the service and that are not in the nature of promotion.

IX. How to Contact Us

We have established dedicated departments for protecting personal information, and will protect your personal information according to this Privacy Policy. If you have any complaints or reports about the security of online information, or if you have any questions, comments or suggestions about this Privacy Policy and matters regarding your information, and any questions regarding this statement or our privacy practices, please contact us by writing emails to the email address at: , or for the purpose of European Data Protection Law, contact our EU representative according to Art 27 GDPR with an easy way to submit us privacy related request by visiting Designated EU representative and contact information:

Designated EU representative and contact information:

Maetzler Rechtsanwalts GmbH & Co KG

Attorneys at Law


Schellinggasse 3/10, 1010 Vienna, Austria

Please add the following subject to all correspondence:

GDPR-REP ID: 13474351

In normal circumstances, we will reply to you within a reasonable time, which may be required by applicable laws and regulations, upon receipt of your questions, advices or comments and verification of your User identity.