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Privacy Policy

August 13, 2018 [GMT]

The effective date of this Privacy Policy (the "Policy") is August 13, 2018.


1. Introduction

Better Gem Limited and its subsidiaries, including but not limited to Better Gem Limited (collectively, "BETTER GEM” or “we”, or "us”) respect the privacy of its online visitors and users of its products and services. BETTER GEM recognizes the importance of personal information collected from users and has adopted this privacy policy to inform users about how BETTER GEM gathers, stores, and uses information derived from their use of BETTER GEM products, services and online sites. We may share this personal information with third parties and use it consistent with this Privacy Policy to provide and improve our products, services,contents, and advertising. . In order to ensure fair processing, we would also like to inform you about your rights under the European General Data Protection Regulation (GDPR). We will only process the data as permitted by law and with the prior consent of our user.

This policy is current as of its last revision date. However, please note that this policy may be amended from time to time to reflect changes and additions to the privacy policy. Please check back for the most current version before relying on any of the provisions in this privacy policy.


2. What Information Is Collected

Personal data: BETTER GEM’s primary objective in collecting user information is to provide and enhance the Service and to enable users to easily navigate and enjoy the Service.

When you install any of the BETTER GEM games or applications, we may collect and record the information you provide us voluntarily through the social networking website in accordance with their policies and terms.

The term “personal data” under the GDPR refers to all information relating to a specific or identifiable person. The types of personal information collected in accordance with the activities listed above may vary depending on the activity. Personal information may include:

i. Your name;

ii. Your Device number and Browser information

iii. Email address;

iv. Home address;

v. Phone number.

vi. Instant message account

vii. IP address

viii. IDFA and IDFV

ix. App store ID and gamecenter ID

x. Android_ID or Google advertising ID

xi. Google ID or Facebook ID

xii. Game Play Information

xiii. Third Party Cookies

xiv. Web Beacons

Additionally, we may acquire information from you through:

i.Your access and participation in message boards on the Service;

ii.Your email of a question to our customer support;

iii.Your purchase of a virtual product of any type.

When you play a BETTER GEM game, on BETTER GEM's website at (the "Site") or on your social network page or on someone else's page or through your mobile device, we may record information regarding the use of that game, and we may collect other information that is visible on your social network page in accordance with the relevant terms of use associated with that page.

Game Play Information : The Service will also record game play information such as your high scores or game session duration, trading records of the game, etc. When you invite new members into your network or send messages through BETTER GEM's applications, we collect and maintain the information associated with those messages, including email address and content.

Financial information: When you pay for products offered for purchase though the Service, our payment service providers will collect your billing address and complete credit card information that enables us to receive your payment. Our payment processing service provider may also retain this information to enable you to purchase additional items through our Service without having to re-enter it each time. BETTER GEM do not directly access, store or collect your credit card information and we will not use your payment information we collect except as needed to fulfill your purchase and/or communicate with you regarding your transaction.

BETTER GEM will never at any time ask you for your credit card or bank account information, your login or password, or national identification numbers via any unsolicited means, including email and telephone calls.

Third Party Cookies: We may use third-party advertising companies to serve ads on our behalf across the site. With your prior consent, these companies may collect and use information about your visits to this and other websites and your interaction with our products and services in order to provide advertisements about goods and services of interest to you. However, no personally identifiable information (such as your name, address, email address or telephone number) will be connected with such information. They may use information about your visits to this and other websites to target advertisements for goods and services and may be used to keep track of user response to each advertisement. These targeted advertisements may appear on the site or on other sites that you visit. The anonymous information is collected through the use of a pixel tag or cookies, which are industry standard technologies used by most major websites. If you do not want such companies to collect this information, you are not required to provide the this information requested, but, if you chose not to do so, in many cases these companies we will not be able to provide you with their products or services or respond to any queries you may have.

Web Beacons: The Websites may contain electronic images (called a "single-pixel GIF" or a "web beacon") that allow a website to track the effectiveness of marketing campaigns. No personally identifiable information will be transmitted via web beacons.

All the information we collect from the user will be saved permanently. Users can access, correct, delete relevant information and exercise other rights in accordance with GDPR rules.


3. What We Do With Your Personal Information

BETTER GEM uses your Personal Information to operate, for the improvement of the Services, and to assist you. We assign every player a User ID that contains no Personal Information, which is shared with the Third Party relevant to the Services.

We use your Personal Information, and Log File Information related to you, in a variety of ways including, but not limited to, customer service, account management, enforcement of our Terms of Service, marketing, promotions, and site improvement. We may also use your Personal Information to prevent cheating, crime, or fraud. We may also need to pass your Personal Information to fraud prevention agencies and other organizations involved in crime and fraud prevention and as otherwise required by applicable law. Additionally, in the event of a merger, acquisition, reorganization, bankruptcy of BETTER GEM, or other similar events, customer information may be transferred to BETTER GEM' successor or assignee, if permitted by and done in accordance with applicable law.

As our servers are in countries outside the European Union, and our payment service providers are incorporated outside the European Union, Therefore, all user data that may be collected or made available in this agreement are required to be transmitted outside the European Union. The user should clearly know that the operation of transmitting user data or information to the country outside the European Union is necessary for the user to use the game and to achieve the termination of the game.


4. Information Sharing With Third Parties

We partner with Third Parties to obtain marketing feedback, process payments, analyze metrics, and improve our systems. We will not share your Personal Information with Third Parties unless express consent is given by you. The purpose of our sharing your information with Third Parties is to provide a better service to you and we take necessary measures to protect your identity when dealing with Third Parties.

BETTER GEM is not liable for losses or damages resulting from or associated with the Privacy Policy of any Third Party. We ask all of our players to carefully read the relevant Third Party's Privacy Policy to stay informed and protected.


5. Security of Your Personal Information

Personally identifiable information is used internally by BETTER GEM to deliver, develop and improve products, content and services, to which users have subscribed, and to answer users’ requests. In addition, BETTER GEM may allow third parties performing services under contract with BETTER GEM, such as order or payment processors or merchandise warehouse and fulfillment services, to access and use personally identifiable information, but only to the extent necessary to provide those services.

BETTER GEM may use personally identifiable information provided by users to send them information about BETTER GEM, including news about product updates, contests, events, and other promotional materials, but only if the users agree to receive such communications. BETTER GEM will not share any personally identifiable information with third parties for marketing purposes without your consent.

When you create an account in BETTER GEM online websites, we collects a user's email address and username, and at the user's option, first and last name. Depending on their settings, users agree that some of this information may be searchable and available to other users within BETTER GEM. We has no obligation to keep private personally identifiable information that a user makes available to other users via BETTER GEM online websites or other BETTER GEM software, such as in multiplayer chat or other public functions.

External websites and companies with links to and from BETTER GEM's online sites and products may collect personally identifiable information about users when users visit their websites. Third party publishers may also collect personally identifiable information as a requirement of accessing their games or content. BETTER GEM's privacy policy does not extend to those websites and companies or third party publishers with links to or from BETTER GEM's products and online websites or who collect personally identifiable information through their game available on BETTER GEM online websites. Please refer directly to these companies and websites regarding their privacy policies.

BETTER GEM may release personally identifiable information to comply with court orders or laws that require us to disclose such information. In the event of a reorganization, sale or merger we may transfer personally identifiable information to the relevant third party with the user’s consent if required by law.


6. Policy Regarding Children Under the Age of 16

BETTER GEM does not collect or request personal information from anyone under the age of 16, including name, address, telephone number, email address, etc., except with the consent of the parent or guardian of a minor under the age of 16. If we find that we have collected personal information from anyone under the age of 16, we will delete it as soon as possible. We recommend that minors under the age of 16 send any information of their own online to anyone after they obtain permission from their parents or guardians. We emphasize that only people over the age of 13 can use the game services we offer.


7. Cookies and Other Information on a User's Machine

BETTER GEM’s products, services and sites may employ cookies and other technologies such as web beacons and pixel tags. Cookies are bits of electronic information that can be transferred to a user's hard drive to customize a person's use of a product or online site, keep records of a user's access to an online site or product, or store information needed by the user on a regular basis. Use of cookies is typically associated with websites. For example, when you sign in to BETTER GEM online websites , we stores your user id and a combination of your IP address and time of login as a cookie on your hard drive. This cookie allows you to move from page to page without having to sign in again on each page. Similarly, if you enter information during your session, such as age verification data, this will be stored as a cookie and you will not have to re-enter such information during that session. We may also use third party web site analytic tools that employ cookies to collect certain non-personally identifiable information concerning use of our websites, such as referring web site addresses, page views and browser types.

However, users can disable cookies by changing their browser settings. BETTER GEM also stores on a user’s hard drive a unique authorization key or CD-Key that is either entered by the user or downloaded automatically during product registration. This authorization key is used to identify a user as valid and allow access to BETTER GEM's products, services and third party games. This key is necessary for BETTER GEM to supply any products and services subscribed by users.

Information regarding BETTER GEM billing, a user’s BETTER GEM account, a user's Internet connection and the BETTER GEM software installed on a user's computer is uploaded to the server in connection with the user's use of Steam and BETTER GEM software. BETTER GEM software automatically generates and submits to BETTER GEM bug reports upon a crash or other fault in the BETTER GEM software, services or Steam games. This automatically generated bug report information may include information about other software or hardware on a user's system. BETTER GEM does not associate and store the automatically generated bug report information with users’ personally identifiable information. Any bug reporting information manually submitted by users (e.g. through BETTER GEM's Bug Reporter form) is associated and stored with personally identifiable information sent voluntarily by the user through a bug report.


8. Facebook Connect

We also offer you the option of easier registration for our games and services through Facebook. You can use your existing Facebook user account for this purpose. By clicking the “Log in with Facebook” link, you can use this registration method via our online portal. To do this, you need to already have a Facebook account or have access to Facebook.

If you would like to register for one of our services using your Facebook account, the first step in the registration process will immediately redirect you to Facebook. Facebook will then ask you to log in or to register. Under no circumstances will we receive your personal access data (user name and password).

In a second step, you will connect your Facebook profile with the service for which you would like to register. At this point, you will be told what data from your Facebook profile will be transmitted to us. This information is usually your “public information” on Facebook and information which you have made available to the public or authorized for the application in question. Information of this type generally includes your name, profile picture and cover photo, your gender, your networks, your username (Facebook URL), and your user ID number (Facebook ID). We will also use the email address you have saved with Facebook in order to contact you outside of Facebook. You can see an overview of information in your profile that is available to the public via the General Account Settings menu of your Facebook profile (

The legal basis for data collection and storage is your consent. If you would like to remove the connection between Facebook Connect and our service, please log in to Facebook and make the required changes to your profile. We will then no longer have the right to use information from your Facebook profile.


9. Google Analytics

We use the Google Analytics service from Google LLC (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”) to analyze our website visitors. Google uses cookies. The information generated by the cookie about the use of the online product or service by users is generally transferred to a Google server in the USA and stored there. Google will use this information on our behalf to evaluate the use of our online products and services by users, to compile reports on the activities within these online products and services and to provide us with further services associated with the use of these online products and services and the use of the internet. Pseudonymous user profiles can be created from the processed data.

We use Google Analytics only with IP anonymization enabled. This means that Google will truncate the IP address of users within Member States of the European Union or in other states that are party to the Agreement on the European Economic Area. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and truncated there.

The IP address transmitted by the user’s browser is not merged with other Google data. Users can prevent cookies from being stored by adjusting the settings to their browser software accordingly.

Users can prevent the collection of data generated by cookies by downloading and installing the browser plug-in that is available at the following link:

If you visit our website using a mobile device, you can deactivate Google Analytics by clicking on the following link: Click here.

Facebook is certified under the Privacy Shield Agreement and thus guarantees compliance with European data protection legislation (


10. Your Rights

As the person concerned, you are entitled to exercise your rights against us. In particular, you have the following rights:

◇In accordance with Article 15 GDPR, you have the right to request information as to whether or not, and to what extent, we process personal data about you. Also You have the right to lodge a complaint with the regulator.

◇You have the right to have us correct your data in accordance with Article 16 GDPR.

◇You have the right to have us delete your personal data in accordance with Article 17 GDPR .

◇You have the right to have the processing of your personal data restricted in accordance with Article 18 GDPR.

◇You have the right, in accordance with Article 20 GDPR, to receive the personal data concerning you that you have provided to us, in a structured, commonly used and machine-readable format and to transmit this data to another controller.

◇You habe the right to withdraw your agreement at any time in accordance with Article 7 GDPR.


11.Changes to Privacy Policy

BETTER GEM may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used. If we make changes in the way we use personal information, we will notify you by posting an announcement on our Service or sending you an email. You are bound by any changes to the Privacy Policy when you use the Service after such changes have been first posted. If you object to any change, your sole recourse shall be to immediately terminate your account and cease using the Site and Service.


12. Contact Us

&The Policy and your use of the Services shall be governed by and construed and take effect in accordance with the laws of Hong Kong. With respect to any questions, disputes, suits, action or proceedings arising out of or in connection with the Policy, you irrevocably submit to the Hong Kong International Arbitration Center. If you have any questions about the Policy, or the practices mentioned within, please send an email to support@BETTER

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