Soft Source Pte Ltd (together with its affiliates, otherwise known as “Soft Source”) has concerns
about the privacy of individuals who visit our websites (“Sites”) and otherwise do business
safeguards information we obtain from and about our customers, visitors to our Sites, and business
prospects and partners (collectively, “You”), including information we collect when you visit our
websites, or other services offered by Soft Source, or purchase our products and services
(collectively, our “Services”). It also provides you about your rights and choices with respect to your
information, and how you can contact us if you have any questions or concerns. Your use of the
INFORMATION TYPES WE COLLECT
identified or identifiable individual. We obtain Personal Information relating to you, from various
sources described below.
Where applicable, we indicate whether and why you must provide us with Personal Information, as
well as the consequences of failing to do so. If you do not provide Personal Information when
requested, you may not be able to benefit from our Soft Source Sites and Services if that
information is necessary to provide you with the service or if we are legally required to collect it.
In order to provide the Soft Source Sites and Services, we must process information about you. The
types of information we collect depend on how you use our Sites and Services. You may access, edit
and delete information we collect for any account profiles where applicable in our Sites and Services.
PERSONAL INFORMATION YOU PROVIDE
Information and content you provide – We may collect content, communications and other
information you provide when you use Soft Source Sites and Services, including when you sign up
for an account, access our games and content, and message or communicate with others. This can
include information in or about the content you provide, such as the images used in your account
profiles. We may process content and communications you and others provide to analyse context
and what is in them for the purposes described below.
Your usage – We may collect information about how you use Soft Source Sites and Services, such as
the types of content or services you access; the features you use; the actions you take; the people or
accounts you interact with; and the time, frequency and duration of your activities. For example, we
may log when you are using and have last used our Sites and Services.
Information about transactions made on our Sites and Services – If you use Soft Source Sites and
Services for purchases or other financial transactions (such as when you make a purchase in a game),
we may collect information about the purchase or transaction, including payment information, such
as credit or debit card number and other card information; other account and authentication
Information we collect – When you use Soft Source Services described below, we may collect
information from and about the computers, phones, and other web-connected devices you use that
integrate with our Sites and Services, and we combine this information across different devices you
use. For example, we may use information collected about your use of our Sites and Services on your
phone to better personalize the content or features you see when you use our Sites and Services on
another device, such as your laptop or tablet.
Information we obtain from these devices includes:
Device attributes – Information such as the operating system, hardware and software versions,
battery level, signal strength, available storage space, browser type, app and file names and types,
Identifiers – Unique identifiers, device IDs, and other identifiers, such as from games, apps or
accounts you use.
Data from device settings – Information you allow us to receive through device settings you turn on,
such as access to your GPS location, camera or photos.
Cookie data – Data from cookies stored on your device, including cookie IDs and settings.
HOW WE MAY USE YOUR INFORMATION
We may use the information we have (subject to choices you make) as described below and to
provide and support the Soft Source Sites and Services and related services, as described below:
Provide, personalize and improve our Sites and Services – We may use the information we collect to
improve delivery of Soft Source Sites and Services and make suggestions for you regarding our Sites
Information across our Sites and Services – We may connect information about your activities on
different Soft Source Sites and Services to provide a more tailored and consistent experience on all
our Sites and Services you use, wherever you use them. For example, we may suggest that you try a
new Service. We may also make your experience more seamless, for example, by automatically
filling in your registration information (such as your account ID) from one Service to another when
you access our Sites.
Location-related information – We may use location information, such as your current location or
detected IP, to provide, personalize and improve Soft Source Sites and Services, for you and others.
Location-related information may be based on IP addresses, and information from your use of our
Sites and Services.
Product research and development – We may use the information we collect to develop, test and
improve Soft Source Sites and Services, including via conducting surveys and research.
Facilitating transactions – We may use your payment information to facilitate your transactions,
promote data safety, integrity and security.
Information security – We may use the information we collect to verify accounts and activity;
combat harmful conduct; detect, prevent spam and other bad experiences; maintain the integrity of
our Sites and Services; or promote safety and security of Soft Source Sites and Services. For example,
we may use data we collect to investigate suspicious activity or violations of our terms or policies.
Communications with you – We may use the information we collect to share with you marketing
communications; communicate with you about Soft Source Sites and Services; or let you know about
our terms and policies. We may also use your information to respond to you when you contact us.
HOW WE DISCLOSE INFORMATION
Your information may be shared with other parties in the following ways:
Sharing on our Sites and Services – When you share and communicate using Soft Source Sites and
Services, you may select the audience for your posts, such as on social media. Similarly, when you
use an app service to communicate with other users, those users may see the content you send.
Apps, third-party integrations and websites on our Sites and Services – When you choose to use
third-party apps, websites, or other services that use, or are integrated with Soft Source Sites and
Services, they may receive information about you. For example, when you play a game integrated
with other platforms, information regarding your activities in the game may be received by another
party. Some games you play may receive your list of social media contacts if you choose to share it.
Ownership transfer – If the ownership or control of all or part of Soft Source Sites and Services, or
assets changes, we may transfer your information to the new owner without any prior notice.
Sharing with third-party partners – We may work with third-party partners who help us to provide
and improve Soft Source Sites and Services in the course of business operations. We do not and
never will sell any of your information to other parties. We impose strict restrictions on how
partners may use and disclose data we collect. Below are types of third-party partners we may share
Data analytic partners – We may share information about you with companies that aggregate it to
provide data analytic reports to our partners.
Vendors and service providers – We may provide information and content to vendors and service
providers who support our business operations, such as by providing technical infrastructure
services; analysing how Soft Source Sites and Services are used; providing customer service;
facilitating payments; or conducting surveys.
Law enforcement and legal requests – We may share information with law enforcement agencies or
in response to legal requests.
Soft Source and its affiliates – We may share infrastructure, systems and technology with Soft
Source affiliate and subsidiary companies. We may also process information about you across our
companies for these purposes, as permitted by applicable law and in accordance with their terms
YOUR RIGHTS & CHOICES
We may provide you with the ability to access, rectify, and port your data in your account profiles.
Soft Source may store data until it is no longer necessary to provide our Sites and Services, or until
your account is deleted – whichever comes first. This is a case-by-case determination that depends
on things like the nature of the data, why it is collected and processed, and relevant legal or
operational retention needs. For example, if you submit a copy of your government-issued ID for
account verification purposes, Soft Source will delete that copy 60 days after submission.
LEGAL & SIMILAR DISCLOSURE REQUIREMENTS
Soft Source may be required to access, preserve and share your information with regulators, law
enforcement agencies or others upon their request, examples of which are outlined below.
In response to a legal request (Eg. Court order, search warrant, subpoena) that compels us by law
to do so – This may include responding to legal requests from jurisdictions of the regions covered by
any of Soft Source Sites and Services when we have a good-faith belief that the response is required
by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally
recognized response standards; when we have a good-faith belief that it is necessary to detect,
prevent and address fraud, unauthorized use of the Sites and Services, violations of our terms and
conditions policies, or other harmful or illegal activity; to protect ourselves (including our rights,
property or Sites and Services), you or others, including as part of investigations or regulatory
inquiries; or to prevent death or imminent bodily harm. For example, if relevant, we provide
information to and receive information from third-party partners about the reliability of your
account to prevent fraud, abuse and other harmful activity on our Sites and Services.
Information we receive about you (including financial transaction data related to purchases made
with Soft Source) may be accessed and preserved for an extended period when it is the subject of a
legal request or obligation, governmental investigation, or investigations of possible violations of our
terms or policies, or otherwise to prevent harm. We may also retain information from accounts
disabled for terms violations for at least a year to prevent repeat abuse or other term violations.
TRANSFER TO OTHER COUNTRIES
Soft Source may share information, both internally within affiliate companies, and externally with
transferred or transmitted to, or stored and processed in the regions covered by any of our Services
be necessary to operate and provide our Sites and Services to you. We may utilize standard contract
clauses, as applicable, and obtain your consent for these data transfers.
DATA SECURITY COMMITMENT
Soft Source may undertake necessary protection measures and procedures required to prevent
unauthorized disclosure of, access to and use of information that we collect and receive. However,
Soft Source cannot guarantee the absolute security of your information.
We may notify you of any changes to this policy and give you the opportunity to review the revised
policy before you choose to continue using Soft Source Sites and Services prior to the effective date.
Soft Source Pte Ltd
190 Middle Road
#11-05 Fortune Centre