Privacy Policy for ZomTube

Last updated: 21 April 2025

ZomTube is published on Google Play by Shanghai Chengyu Information Technology Co., Ltd. (“Chengyu”, “we”, “our”, “us”).
This Policy explains how and why we process personal information when you play ZomTube, visit our websites, or interact with our support channels.


Table of Contents

  1. Who We Are
  2. Applicability
  3. Definitions
  4. Information We Collect
  5. How We Use Information
  6. Legal Bases
  7. Sharing & Disclosure
  8. Advertising, Analytics & Cookies
  9. International Transfers
  10. Security
  11. Data Retention
  12. Your Rights & Controls
  13. Account & Data Deletion Procedure
  14. Children's Privacy
  15. Changes to This Policy
  16. Governing Law & Dispute Resolution
  17. Contact Us
  18. Final Provisions

Who We Are

Item Details
Legal name Shanghai Chengyu Information Technology Co., Ltd.
Contact (global) zomtube.en@hotmail.com
Data Protection Officer gp@chengyuinfo.net
EU/UK representative ¹ EuroPrivacy OÜ – gp@chengyuinfo.net

¹ Appointed pursuant to Art 27 GDPR/UK GDPR for users located in the EEA or UK.


Applicability

This Policy applies to:

By installing or playing the Game you acknowledge that you have read and agree to the practices described herein. If you do not agree, please uninstall the Game and cease use of our services.


Definitions

Term Meaning
Personal data / personal information Any information that identifies or can reasonably identify you («data subject») either alone or in combination with other data.
Processing Any operation performed on personal data (collection, storage, use, disclosure, etc.).
SDK A software development kit integrated in the Game, provided by a third party (e.g., Facebook).
Legal basis The justification we rely on to process data under GDPR, LGPD, CCPA, and similar laws.

Information We Collect

Category Examples Source Purpose(s)
Account info In‑game UID, display name, e‑mail (if you contact us) You Account creation, customer service
Gameplay data Levels, achievements, inventory, purchase history You / generated by gameplay Core functionality, cloud save, balancing
Device & log Device model, OS version, IP, language, crash reports Automatically from device Debugging, anti‑fraud, analytics
Identifiers Google AAID, AppsFlyer ID, Firebase Install ID, Facebook Login ID Device/SDKs Attribution, personalized ads (if consented)
Usage analytics Session length, feature clicks, A/B‑test cohort Automatically via SDKs Feature improvement, product decisions
UGC Chat messages, screenshots, player support attachments You Social features, moderation, support

Sensitive categories: We do not collect or request sensitive personal data (e.g., political opinions, biometric identifiers).


How We Use Information


Legal Bases

Processing purpose Primary legal basis Alternative bases (region‑specific)
Game delivery, account management Contract (Art 6(1)(b) GDPR) Legitimate interest
Analytics & crash reporting Legitimate interest (Art 6(1)(f)) — improving product stability Consent (Opt‑in regions)
Personalized ads & attribution Consent (Art 6(1)(a)) acquired via Google Play consent SDK Legitimate interest (non‑EEA)
Push notifications for service updates Legitimate interest Consent (opt‑out via system settings)
Legal compliance & fraud prevention Legal obligation (Art 6(1)(c)) Legitimate interest

If you reside in California, we rely on "business purpose" exemptions under the CCPA and do not sell personal information as defined therein.


Sharing & Disclosure

We never sell personal data. We share it only:

  1. With service providers listed below, bound by data‑processing agreements (DPAs);
  2. Within our corporate group for internal administration;
  3. For legal reasons, such as court orders or to defend legal claims;
  4. In a business transaction (merger, acquisition) — you will receive advance notice.

Core Third‑Party SDKs

Partner Role Opt‑out
Meta (Facebook) Login, social sharing Remove linked account in‑game
AppsFlyer Attribution & ad‑campaign analytics AppsFlyer Opt‑Out
Firebase Analytics, crash logs, push Disable analytics in settings (where available)

Each partner processes data under its own policy and may transfer data globally under Standard Contractual Clauses (SCCs) or other approved safeguards.


Advertising, Analytics & Cookies

We (and our partners) place SDK‑level cookies or mobile identifiers to:

You can reset or limit the Google Advertising ID in Android Settings › Privacy › Ads, and revoke consent in the in‑game Privacy Settings panel.


International Transfers


Security


Data Retention

Data type Standard retention Deletion trigger
Active account data Life of account Account deletion request
Crash logs & analytics 24 months rolling Opt‑out or account deletion
Purchase records (tax) 7 years Statutory expiry
Support tickets 3 years Ticket closure + 90 days

Your Rights & Controls

Region Rights & mechanisms
EEA/UK Access • Rectify • Erase • Restrict • Port • Object • Withdraw consent
Brazil (LGPD) Confirm • Access • Correct • Anonymize • Delete • Port • Information • Refuse
California (CCPA/CPRA) Know • Delete • Correct • Opt‑out of sale/share (not applicable)

How to exercise:
E‑mail zomtube.en@hotmail.com with subject "Privacy Request" and include your in‑game UID. We respond within 30 days (10 business days for CCPA acknowledgment).


Account & Data Deletion Procedure

  1. Send an e‑mail titled "Delete My ZomTube Account" to zomtube.en@hotmail.com.
  2. Attach a screenshot showing your in‑game UID and character name.
  3. We verify ownership and confirm within 72 hours.
  4. Deletion (live servers + backups) is completed within 30 days — irreversible.
  5. You will receive a final confirmation e‑mail once the process is finished.

Warning: Deletion is permanent; purchases and progress cannot be restored.


Children's Privacy

ZomTube is not directed to children under 16. We do not knowingly collect such data. If you believe we have unintentionally collected data from a minor, please contact us immediately for deletion.


Changes to This Policy

Continued use of the Game after the effective date constitutes acceptance of the revised Policy.


Governing Law & Dispute Resolution

If informal resolution fails, any dispute arising out of or in connection with this Policy or the Game shall be submitted to the Shanghai International Arbitration Center (SHIAC) for arbitration in Shanghai under its then‑effective rules.
Language: English / Chinese (bilingual award).
Award: Final and binding.


Contact Us

Purpose Channel
General privacy enquiries zomtube.en@hotmail.com
Data Protection Officer gp@chengyuinfo.net

Final Provisions


Thank you for playing ZomTube — see you in‑game!