Last Updated: 20 August, 2024
This Privacy Policy explains the when, how and why when it comes to processing of your personal information in connection with service offerings of Tencent CES (Cloud-Enabled Studios) (the "Service"), and sets out your choices and rights in relation to that information. This Privacy Policy only applies to the Service. If you use any other products or services please refer to the privacy policy for that particular product or service.
If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Service. By providing your information or otherwise using the Service, you are acknowledging how we process your personal information as described in this Privacy Policy.
This Service has been developed by Tencent America LLC ( "we", "us", "our" ), located at 2747 Park Blvd, Palo Alto, CA, 94306. For the purpose of data protection laws, we are the data controller of your personal information in relation to the Service.
For data protection purposes, our representatives in the following jurisdictions are as follows:
Jurisdiction/Area | Representative | Address |
|---|---|---|
European Union | Tencent International Service Europe B.V | Buitenveldertselaan 1-5, 1082 VA, Amsterdam OIT_DPO@global.tencent.com |
United Kingdom | Image Frame Investment (UK) Limited | 4th Floor 80 Strand, London, United Kingdom WC2R 0RL OIT_DPO@global.tencent.com |
If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, please contact us or our representatives at OIT_DPO@global.tencent.com.
We use cookies and other similar technologies ("Cookies") to enhance your experience using the Service. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities. For more information about our Cookies policy, click here.
Children must not use the Service for any purpose. By children, we mean users under the age of 18 years old; or in the case of a region where the minimum age for processing personal information differs, such different age. You should refer to the laws in your jurisdiction to ensure you are above the relevant legal minimum age.
This section provides more detail on the types of personal information we collect from you, and why. For users in jurisdictions that require a legal basis for processing your data, we also identify the legal basis.
Personal Information | Use | Legal Basis (where applicable) |
|---|---|---|
Information you provide to us (either directly or through a third party) | ||
Name, email address, organization name, and any personal data provided in the message on the "Contact Us" page | We use this information to send you marketing information and newsletters about the Service, and to contact you about offerings relating to the Service. | We only collect this information with your consent. |
Location, Name, Email Address, IP Address, User Agent (or website browser), Device ID, Cloud account ID and access credentials such as Cloud AK, Address (including city, province and post code), Username and other login security credentials | We use this information to:
| Necessary to perform our contract with you to provide the Service. |
Email Addresses of the Test Users/Players invited by you to participate in Speed Test (one of the Services made available to you) | We use this information to perform the Speed Test and to provide the SpeedTest report to you. | Necessary to perform our contract with you to provide the Service. |
Mobile Number, Email Address, Address | We use this information:
| It is in our legitimate interests to verify your identity and communicate with you about the Services. |
Log Data, Metadata, IP Address, User Tickets, User Agent, Date and Time of Access, whether each unique visit within the website is direct or referred from third party website | We use this information for Service improvement and for website analytics | It is in our legitimate interests to use this information to monitor the performance of the website, and for service improvement |
Customer Service Ticket/ Chat Content, IP Address, Cloud ID, incident details and response steps; (if you choose to enquire via Telegram: Telegram user’s account number) | We use this information to:
| It is in our legitimate interests to improve our Services and provide support in connection with the Services supplied to you. |
Log and Metadata in relation to incidents. | We use this information in order to improve our Service and responses. | It is in our legitimate interests to improve our Services and provide support in connection with the Services supplied to you. |
Enquiry Data (data provided when you submit an enquiry via our website contact form or as part of a sales enquiry), including: your name, email, phone number, priority of query or ticket, reminder settings, company name, business service, location, and details of your query or any additional information provided by you. | We use this information to respond to your enquiry or request for customer support. | It is in our legitimate interests to process this information as it is needed to respond to your request. |
Technical support enquiry data (data provided when you submit a technical support request), including your name, email, phone number, the type of your question, and details of your query. | We use this information to respond to your technical support or troubleshooting request with respect to our Service. | It is in our legitimate interests to process this information as it is needed to respond to your request. |
Promotional Contact Data: Name, Email, Phone Number, Company Name, Business Service, Location and details of your query. | We use this information to: promote our products and services to you; and to send you direct marketing communications through us or our third party partners. | We process this information with your consent. You can withdraw this consent at any time |
Marketing Data: Name, Business Email, Phone Number, Company Name, Country/Region and Industry | We use this information:
| We process this information with your consent. You can withdraw this consent at any time. |
Name, Email Address, Country Code, Phone Number and Company Name. | We use this information to communicate (whether through us or our third party partners) with you, in order to understand products and services that may interest you, and to explore potential business opportunities with you. | We process this information with your consent. You can withdraw this consent at any time. |
Cookies information (collected via Google Analytics) including the following:
| We use this information to maintain and monitor the performance of the Service and to improve the website and the services it offers to our visitors. Please refer to our Cookies Policy for more details: https://www.cloudstudio.games/cookie-policy | We only collect this information with your consent. |
We may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy. We have servers for the Service in the United States and Germany. For EEA/UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses or taking into account adequacy assessments. Only where necessary will we share your personal information with third parties. Situations where this occur are:
Third parties that provide services in conjunction with the Service, such as cloud services and event or webinar organisers such as Eventbrite. Where third party service providers providing services for us are processing personal information data on our behalf, they are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Service. Where they are processing personal information for their own purposes, they will do so in accordance with their terms and privacy policies. We use a third-party service, Google Analytics, to collect the information and we share your information with them. You may find more information on how Google Analytics processes and safeguards data here: https://support.google.com/analytics/answer/6004245
Companies within our corporate group who process your personal information solely for the purpose of providing the Service to you, strictly in accordance with this Privacy Policy.
Regulators, judicial authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you, such as to comply with legal obligations or processes. In complying with the terms of valid legal processes, such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in advance of such disclosure.
Third parties to ensure safety, security, or compliance with laws. We may disclose your information to enforce our terms and conditions and other agreements; address security, fraud or technical issues; or protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law.
A third party that acquires, or may acquire, all or substantially all of us or our business, or that forms, or may form, a business with us or part of our business.
We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption. Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Service or otherwise via the Internet; any transmission is at your own risk.
We do not keep your data for longer than is necessary to fulfil the relevant purpose described above unless we are required or permitted to do so under law. For further details on how long we keep your data, please refer to the time periods set out below.
Personal Information | Retention Policy |
|---|---|
Name, email address, organization name, and any personal data provided in the message on the "Contact Us" page | Stored for a period of 2 years from collection unless you request deletion at an earlier time, after which it will be deleted within 30 days. |
Location, Name, Email Address, IP Address, User Agent (or website browser), Device ID，Cloud account ID and access credentials such as Cloud AK, Address (including city, province and post code), Username and other login security credentials | Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then for 30 days, except to the extent such information is required to be retained in accordance with regulatory or legal obligations. |
Email Addresses of the Test Users/Players invited by you to participate in Speed Test (one of the Services made available to you) | Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then for 30 days, except to the extent such information is required to be retained in accordance with regulatory or legal obligations. |
Mobile Number, Email Address, Address | Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then for 30 days, except to the extent such information is required to be retained in accordance with regulatory or legal obligations. |
Log Data, Metadata, IP Address, User Tickets, User Agent, Date and Time of Access, whether each unique visit within the website is direct or referred from third party website | Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then for 30 days, except to the extent such information is required to be retained in accordance with regulatory or legal obligations. |
Customer Service Ticket/ Chat Content, IP Address, Cloud ID, incident details and response steps; (if you choose to enquire via Telegram: Telegram user’s account number) | Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then for 30 days, except to the extent such information is required to be retained in accordance with regulatory or legal obligations. |
Log and Metadata in relation to incidents. | Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then for 30 days, except to the extent such information is required to be retained in accordance with regulatory or legal obligations. |
Enquiry Data (data provided when you submit an enquiry via our website contact form or as part of a sales enquiry), including: your name, email, phone number, priority of query or ticket, reminder settings, company name, business service, location, and details of your query or any additional information provided by you. | Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then for 30 days, except to the extent such information is required to be retained in accordance with regulatory or legal obligations. |
Technical support enquiry data (data provided when you submit a technical support request), including your name, email, phone number, the type of your question, and details of your query. | Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then for 30 days, except to the extent such information is required to be retained in accordance with regulatory or legal obligations. |
Promotional Contact Data: Name, Email, Phone Number, Company Name, Business Service, Location and details of your query | Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then for 30 days, except to the extent such information is required to be retained in accordance with regulatory or legal obligations. |
Marketing Data: Name, Business Email, Phone Number, Company Name, Country/Region and Industry | Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then for 30 days, except to the extent such information is required to be retained in accordance with regulatory or legal obligations. |
Name, Email Address, Country Code, Phone Number and Company Name | Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then for 30 days, except to the extent such information is required to be retained in accordance with regulatory or legal obligations. |
Cookies information (collected via Google Analytics) | 1 year. Please refer to our Cookies Policy for more details: https://support.google.com/analytics/answer/6004245 |
Some jurisdictions’ laws grant specific rights to users of the Service. Please refer to the Supplemental Jurisdiction-Specific Terms, or the applicable laws in your jurisdiction, for an overview of specific rights that apply to persons subject to data protection laws in those jurisdictions and how these can be exercised.
You may have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). If you wish to exercise your rights, please contact us at OIT_DPO@global.tencent.com.
Access: You may have the right to access personal information we hold about you, how we use it, and who we share it with.
Portability: You may have the right to receive a copy of certain personal information we process about you.
Correction: You may have the right to correct personal information we hold that is inaccurate.
Erasure: You may be able to delete or remove your personal information, unless there is a valid ground under data protection laws for us to retain such information.
Restriction of Processing to Storage Only: You may have a right to require that we stop processing the personal information we hold about you (other than for storage purposes in certain circumstances). However, if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so.
Objection: You may have the right to object to our processing of your personal information.
Consent Withdrawal: To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities. Where consent is required to process your personal information, if you withdraw your consent we may not be able to deliver the expected service.
Advertising: You may choose to stop receiving personalised advertising or marketing promotions from us by sending an opt-out request to OIT_DPO@global.tencent.com.
Please get in touch with us if you have any questions. You can reach out to our data protection officer in the first instance at OIT_DPO@global.tencent.com.
If we make any changes to this Privacy Policy we will post the updated Privacy Policy here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy.
Some jurisdictions’ laws contain additional terms for users of the Service, which are set out in this section. If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.
If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us as specified in Section 8 (Contact). Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.
If you are under the age of 18, you must not use the Service.
By clicking “accept”, you consent to the transfer of your personal information to third parties (if any), which may include the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information).
The categories of personal information specified in to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information) may include “special care-required personal information” (i.e., sensitive information as detailed under applicable law), and you consent to the collection of such information.
You may request us to notify you about the purposes of use of, to disclose, to make any correction to, to discontinue the use or provision of, and/or to delete any and all of your personal information which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contact us as set out in Section 8 (Contact).
For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”), and respectively include the terms “personal data” and “sensitive data” as defined in the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”), (collectively, “US State Laws”). The terms do not include information excluded from the scope of US State Laws.
Over the past 12 months, we have collected and disclosed for a business purpose the following category(ies) of personal information, from or about you or your device:
Identifiers, such as your name, email address, and organization name, and any personal data provided in the message on the “Contact Us” page. This information is collected directly from you.
We collect and disclose your personal information for the following purpose(s):
We use this information to send you marketing information and newsletters about the Service, and to contact you about offerings relating to the Service.
We disclose each of the categories of personal information that we collect as described in Section 4 (How We Store and Share Your Personal Information).
In the past 12 months, we have not sold or shared personal information of California residents within the meaning of “sold” and “share” in the CCPA. And we have no knowledge of any sale or sharing of personal information of users under 16 years of age.
In addition, we do not use or disclose sensitive personal information for purposes other than to perform the services reasonably expected by an average consumer who requests those services or as otherwise permitted by US State Laws.
For detailed information about the retention period, please see the main portion of the Privacy Policy.
Depending on where you live, you may have some or all of the rights listed below in relation to information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
Right to Access/Know.Request we confirm whether we process information about you and give you access to that information. You may also request to receive that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment. If you are a California resident, you may request the following information about our collection, use and disclosure of your information:
the categories of personal information about you that we collected;
the categories of sources from which the personal information was collected;
the business or commercial purposes for collecting personal information about you;
the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you;
the specific pieces of personal information we collected about you;
Request to Delete.Request we delete personal information we collected about you;
Request to Correct.Request we correct inaccurate personal information that we maintain about you;
Right to Non-Discrimination.Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the US State Laws.
You may exercise your rights, if any, by contacting us as specified inSection 8 (Contact). We may take steps to verify your identity before complying with your request to protect your privacy and security, and may decline your request if we are unable to verify your identity. To verify your identity, we may need your name and email address.
Depending on where you live, you may exercise these rights yourself or you may also designate an authorized agent to make these requests on your behalf. In order for us to process the request, you must provide the authorized agent with signed written permission. We reserve the request to require the agent to verify their own identity and to confirm directly with you that you have provided the authorized agent permission to submit the request.
In addition, where applicable, we will provide you with more information about our appeal process. When you submit a request or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfil your request or process your appeal. We will not require you or your authorized agent to pay a fee for the verification of your request or appeal.
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