My Dog Town Privacy Policy

Last updated: December 5, 2025
Effective date: December 5, 2025

clubGames Co., Ltd. and its affiliated entities (collectively referred to as "clubGames", "we", or "us") attach great importance to the privacy of users, including parents and children (hereinafter referred to as "you" or "user"). We believe you have the right to make informed decisions when using our applications ("Apps"). This Privacy Policy details how we collect, use, store and protect your information when you use our services. Please read it carefully to understand our privacy practices.
If you are a minor under the legal age of consent (especially children under 14 years old as defined by Chinese law), please read this Privacy Policy with your parent or guardian. You must obtain explicit parental/guardian consent before using our Apps.
clubGames is committed to safeguarding the privacy of children using our Apps. This Privacy Policy complies with international and regional regulations including the U.S. Children's Online Privacy Protection Act ("COPPA"), the EU General Data Protection Regulation ("GDPR"), the California Consumer Privacy Act ("CCPA"), Japan's Act on Protection of Personal Information ("APPI"), and China's Measures for the Protection of Children's Personal Information Online. We reserve the right to revise this Privacy Policy as needed.
This Policy may be translated into multiple languages. In case of inconsistencies between the English version and other language versions, the English version shall prevail to the extent permitted by applicable laws and regulations.

1. Information Collection and Usage
We adhere to the principles of legality, necessity and transparency in collecting information, and will not require children to provide more personal information than is reasonably necessary for service provision.
1.1 Directly Collected Information
  The types of information we collect, their purposes of use, and legal bases are as follows: Email addresses are used to create and manage user accounts at your request, based on user consent; Parent/Guardian contact information is used to verify parental consent and communicate important service updates, in compliance with legal requirements for children's information protection.
1.2 Passively Collected Information
  We automatically collect certain non-identifiable information through your use of the Apps. Such data may be deemed personal information under certain regulations:
  - Internet Protocol (IP) address
  - Broad geographic location (e.g., country or city-level) derived from IP address
  - Usage data including game progress, playtime, achievements, and error/crash reports
  - Device information such as device type, model, manufacturer, operating system and language
  We use this information for:
  1. Enabling connection to our servers and ensuring basic service operation
  2. Maintaining, protecting and optimizing the Apps to enhance user experience
  3. Detecting and addressing security risks, technical issues and fraud
1.3 Third-Party Collected Information
  Please refer to Section 2 (Advertising) and Section 3 (Information Sharing) for details on information collected by authorized third parties.

2. Advertising-Related Information Usage
2.1 Ad Partner Collaboration
  To provide free or low-cost access to our Apps, we integrate technologies from authorized ad partners to display advertisements.
2.2 Targeted Ads and Opt-Out Options
  Some ad partners may collect device identifiers (e.g., IDFA on iOS) for ad tracking and targeted advertising. We have disabled such collection functions by default in line with privacy best practices.
  To opt out of targeted ads:
  1. Decline related authorization requests when using the Apps for the first time
  2. Adjust device privacy settings to disable ad tracking (e.g., "Limit Ad Tracking" on iOS or "Opt out of Ads Personalization" on Android)
  3. Follow the opt-out instructions provided by individual ad partners in their privacy policies

3. Information Sharing and Disclosure
We will never sell your personal information to independent third parties for commercial purposes. We may share or disclose information only in the following circumstances:
3.1 Affiliated Companies
  We may share information with companies within the clubGames group (including globally registered subsidiaries). These entities will process your information in accordance with this Privacy Policy and applicable laws.
3.2 Business Transfers
  In the event of merger, acquisition, reorganization, bankruptcy or similar transactions, we may transfer personal information to the succeeding entity. We will issue a prior announcement, disclose transaction details and successor information, and obtain re-consent from you or your parent/guardian if required by law.
3.3 Legal and Regulatory Requirements
  We may disclose information if required by law to:
  - Prevent or investigate illegal activities, potential threats to physical safety, or suspected fraud
  - Comply with legal processes, court orders or subpoenas
  - Protect the legitimate rights, property or safety of users, clubGames or the public
3.4 Third-Party Service Providers
  We may engage third-party service providers to assist with service operations (e.g., server maintenance, technical support). These providers are bound by confidentiality agreements and may only process information as authorized.

4. Information Security Protection
We implement comprehensive physical, technical and administrative safeguards to protect your information from unauthorized access, disclosure, alteration or destruction:
- Encryption of data during transmission (SSL) and storage
- Strict access control for information systems and data centers
- Regular security assessments and technical vulnerability scans
- Staff training on data protection and minimum authorization principles
Please note that no internet transmission is completely secure. While we strive to protect your information, we advise you to remain vigilant against cyber risks such as hacking and phishing.
In the event of a data security incident, we will immediately activate emergency response plans, take remedial measures, and notify affected users and relevant authorities as required by law.

5. Parental/Guardian Rights
Parents or guardians have the following rights regarding their child's personal information:
1. Refuse further collection of their child's information at any time
2. Request access to, correction or deletion of their child's personal information
3. Withdraw consent for information processing through convenient channels
To exercise these rights:
- Access the child's account directly to manage information
- Contact us via the email provided in Section 9 with relevant verification materials
Please note that deleting personal information may result in account termination and loss of associated service access.

6. User Rights
Your specific rights may vary by jurisdiction. We comply with all applicable data protection laws.
6.1 General Rights
  - Right to Know**: Request a copy of your personal information held by us (provided free of charge in electronic format after verification)
  - Right to Rectify**: Request correction of inaccurate or incomplete personal information
  - Right to Delete**: Request deletion of your personal information (subject to legal exceptions)
  - Right to Withdraw Consent**: Withdraw consent for information processing at any time without affecting prior processing activities
6.2 Rights for EEA Residents (GDPR)
  In addition to general rights, EEA residents have the right to:
  - Object to processing based on legitimate interests
  - Restrict processing of personal information
  - Request data portability in a structured, machine-readable format
  - Lodge complaints with the relevant supervisory authority
6.3 Rights for California Residents (CCPA)
  California residents have the right to:
  - Request details of personal information collected, disclosed or sold in the past 12 months
  - Opt out of the sale of personal information (if applicable)
  - Not receive discriminatory treatment for exercising privacy rights
  - Authorize an agent to make requests on your behalf (with proper verification)
6.4 Regional Representatives
  - UK Representative**: Rickert Services Ltd UK, PO Box 1487, Peterborough PE1 9XX, United Kingdom; Email: art-27-rep-ghnvg@rickert-services.uk
  - EU Representative**: Rickert Rechtsanwaltsgesellschaft mbH, Colmantstraße 15, 53115 Bonn, Germany; Email: art-27-rep-ghnvg@rickert.law
6.5 Rights for Japanese Residents (APPI)
  Japanese residents may exercise rights under Japan's Act on Protection of Personal Information by contacting our privacy team. We ensure cross-border data transfers comply with APPI requirements.

7. International Data Transfer
We store data on servers closest to users to ensure service efficiency and security. Server locations include:
- United States (for users subject to COPPA/CCPA)
- Hong Kong, China (for users in the Asia-Pacific region)
- Germany (for EEA users, subject to GDPR)
We use EU Commission-approved standard contractual clauses and other appropriate safeguards for cross-border data transfers, ensuring compliance with GDPR Article 46 and other regional regulations.

8. Data Retention Period
We retain your personal information only for the period necessary to fulfill the purposes stated in this Policy or as required by law. After the retention period expires, we will delete or anonymize your information in accordance with regulatory requirements.
Account-related information will be retained until you request deletion or your account is terminated. Usage data and device information may be retained in anonymized form for service optimization purposes.

9. Contact Us
For questions, complaints or requests related to this Privacy Policy or personal information processing, please contact us at: Email: kunpingxu2@gmail.com
We will respond to valid requests within the timeframes required by applicable law.

10. Policy Updates
We may update this Privacy Policy periodically to reflect regulatory changes or service adjustments. When we make updates:
- We will revise the "Last updated" date at the top of the Policy
- Material changes will be notified via prominent in-App notices or direct communication
- The updated Policy will take effect immediately upon publication
We encourage you to review this Policy regularly to stay informed about our privacy practices. Your continued use of our Apps after updates constitutes acceptance of the revised Policy.