Privacy and Cookie Policy

Note：Our Privacy and Cookie Policy is updated on March [ ],2025，if You have any queries You can get in touch with us at privacy@mars.games.

Privacy and Cookie Policy

MARS ERA (HK) LIMITED ("MARS "or “We”), is dedicated to protecting the privacy rights of its online Users ("You" or "Users"). This Privacy and Cookie Policy has been crafted to inform You as to the ways MARS collects, stores, uses, and manages the information You provide during the use of any MARS’ games or application (" “Services”). This Privacy and Cookie Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy and Cookie Policy on the site. You are advised to consult this Privacy and Cookie Policy regularly for any changes.

What Personal Information do we collect?

MARS’ primary objective in collecting your information is to operate and improve our Services and software and to enable You to easily navigate and enjoy the Services. The information we collect depends on what Services You use and how You use them.

Personal Information that You Give Us Directly

The personal data provided by You is necessary for the performance of the agreement and for validation purposes and to complete your transactions, enforce licensing terms, and administer your inquiries. We will collect your personal data when You interact with our Services such as when You register with us through the Services and create an account; or make a purchase via the Services; or submit and/or sell assets, content or games via the Services; or submit a request for technical support; or download, register, and/or install any software; or post any content via the Services. Such personal data includes: • Your User name, your email address, your country, and a password; • Your MARS account information; • Security questions and answers; • Information You provide when seeking help from us such as your name and records of the issues You experience; • Information You provide to enter a contest or sweepstakes held outside of the games on the platforms such as facebook or games’ official website. If You win, we may need to collect your postal address and/or national identification for eligibility, prizes delivery and tax purposes. Please note that because a third party manages the purchases of virtual goods offered by the Services, MARS does not have access to your payment details and billing information.

Other Information We Collect When You Use Our Services

We collect other information automatically when You use our products, including: • IP address; • Mobile and other hardware or device identifiers; • Browser information, including your browser type and the language You prefer; • Referring and exit pages, including landing pages and pages viewed; • Platform type; • Details about what Services You use and your use of them; • Device event information, including crash reports, request and referral URL's and system activity details; • Your purchase of a virtual product of any type or other business events; • Progression events that are used to mark your progress or movement in the game; • Resource events such as the acquisition or spend of game virtual currencies by You; • Design events used to track your behavior in the game, which can refer to any aspect of the game’s design, including, but not limited to, level or character design, bonuses, social interactions, etc.; • Error events such as any errors encountered by You while using the game; • Custom fields that can contain any game parameter defined by You.

Information Provided to Us by Third Parties

By signing up to play our products on the third parties platforms, You may agree to give us your third parties platforms accounts information so we can establish a MARS Account for You. You need a MARS Account to play MARS' products on these platforms. From such third parties, we may receive your personal information as You give to the third parties, such as your name, email address, online ID, your country, etc. We do not receive your credit card number or other financial information. Such third parties/platforms include but are not limited to: • Mobile Platforms • Facebook • Google Play • APP Store • X • TikTokMARS may combine and/or analyze your in-game information in an attempt to overall enhance the Services. For your clarification, we will never make any decisions based on this, which produces legal effects concerning You or similarly significantly affect You, and our purpose hereunder is only to provide You with better User experience, thus enhancing our Services. If You prefer that we do not collect or process your personal data, You can at any time request us to cease the collection and processing of your personal data, see Section 3 below on how to do this.

How your personal information is used?

Our use of your personal information will strictly comply with the requirements of relevant laws and regulations, and will be used only within the scope described in this privacy policy.

We may use the information we collect for a number of business and commercial purposes, including to:

Perform internal operations necessary to develop, provide, maintain, and improve our Services, including troubleshooting, providing customer and technical support, and conducting data analysis, testing, and research;

Understand how you interact with our Services and personalize the product experience and content (including advertising and messaging campaigns), as well as offer discounts or personalized pricing in accordance with applicable law;

Maintain the safety, security, and integrity of our Services, for example by authenticating players and providing account security and fraud detection;

Send you news and/or marketing communications (by email, phone, or text) subject to your marketing preferences and choices, including information about Mars or third-party offerings we think may be of interest to you;

Administer contests, surveys, and sweepstakes you enter, notify contest winners, and award prizes;

Fulfill a purchase or send you order confirmations or other requested product or Service information;

Facilitate your communication with friends and other players, and enable features that allow you to share information with other people (for example, if you choose to use friend invite features); and/or

Comply with legal requirements and/or investigate or address claims or disputes relating to your use of the Services.

3. Choices

You have certain choices about whether to provide us with your personal information and whether it is shared. Generally, we only ask your personal information that is necessary to provide the Service you requested. You may consent to our collection or withdraw your Consent, if You choose to withdraw your consent, You may contact privacy@mars.games to exercise your choice. However, any withdrawal of consent will not impact our processing of your information occurs before. In some circumstances, your withdrawal of consent or not sharing your information with us will impair our Services.

4. Changing or Deleting Your Information

You have certain data subject rights including the right to: (i) request access to and rectification of your personal data; (ii) obtain restriction of processing or to object to processing of your personal data; and (iii) ask for a copy of your personal data to be provided to You, or a third party, in a digital format; and (iv) ask us how your personal data is used by us; (v) erasure of your personal data if MARS is not legally obligated to retain the record; and/or any other rights as permitted by applicable data protection laws.

If You would like to exercise any above-mentioned rights, please contact MARS at privacy@mars.games. For your clarification, if your personal data are erased/deleted or completely transferred to a third party, your account may become deactivated.

5. Information Sharing or Disclosure

We do not share personal information that directly identifies You with unaffiliated third parties except to provide products or Services You have requested, or when MARS has your permission, or under the following circumstances: • For legal reasons; • Enforce applicable Terms of Service, including investigation of potential violations; • Detect, prevent, or otherwise address fraud, security or technical issues; • Protect against harm to the rights, property or safety of MARS, You or the public as required or permitted by law; • Necessary to provide the Services You need. In the event that we contract with a third party to provide some part of the Services that You have requested or to assist us in analyzing our Services or information collected about You (as You consent), MARS may provide your information to such third party, or such third party may collect information from You. Our Services might be linked with other websites or mobile applications. Please note that the third-party service providers our products and/or Services integrate might have their own privacy policies and are not bound by this privacy policy. The third-party platforms we work with and their privacy policy links are shown below. Please read their privacy policies carefully. We encourage you to review their privacy policies to learn more about their data processing practices.But please note we cannot control the behavior, content or privacy policy of any third-party website or services, nor do we assume any responsibility.

Third Party	Purposes of Use	Privacy Policies
Google	Advertising	https://policies.google.com/privacy
Facebook	Advertising	https://www.facebook.com/about/privacy
X	Advertising	https://x.com/en/privacy
TikTok	Advertising	https://www.tiktok.com/legal/page/global/partner-privacy-policy/en
UnityAds	Advertising	https://unity.com/legal/privacy-policy
IronSource	Advertising	https://www.is.com/privacy-policy/
Moloco	Advertising	https://www.moloco.com/privacy-policy
Mintegral	Advertising	https://www.mintegral.com/en/privacy
Adjust	Analytics	https://www.adjust.com/terms/privacy-policy/
AWS	Cloud Service	https://aws.amazon.com/privacy/?nc1=f_pr
Paymentwall	Payment Processing	https://www.paymentwall.com/privacypolicy
Xsolla	Payment Processing	https://xsolla.com/privacypolicy
Stripe	Payment Processing	https://stripe.com/zh-hk/privacy
Paypal	Payment Processing	https://www.paypal.com/myaccount/privacy/privacyhub/principles
Pagseguro	Payment Processing	https://international.pagseguro.com/legal-compliance/for-users/terms-of-use?hsLang=en
CM	Payment Processing	https://www.cm.com/app/legal/miscellaneous/privacy-statement/
Infobip	Payment Processing	https://www.infobip.com/privacy-documents

The aforementioned third parties include all entities with which we collaborate in relation to MARS games or applications within our Services. Consequently, the Services we provide to you may involve one or more of these third parties, depending on the specific circumstances. Please note that we may update this list periodically. In addition, we may disclose information about You to third parties in connection with a corporate reorganization, merger or amalgamation, or the sale of all or substantially all of our assets and will obtain your consent to do so if required by law. Finally, we may encrypt, aggregate and/or anonymize information collected from You or via other means so that the information does not identify You. Our use and disclosure of aggregated, anonymized, and otherwise non-identifiable information is not subject to any restrictions under this Privacy and Cookie Policy, and we may disclose it to others without limitation for any purpose, including with game developers, advertisers, publishers, business partners, sponsors, and other third parties.

6. International Transfer

For the purposes as described in this policy, your information may be transferred or transmitted to, or stored and processed in other countries outside of the jurisdiction where You are located. These data transfers are necessary to provide the Services set forth herein. If your personal data is transferred to a country where do not provide a similar or adequate level of protection compared to the laws in your country, however, we will treat your personal information as subject to the protections described in this policy. We will rely on standard contractual clauses, binding corporate rules, and other legal measures to help establish adequate safeguards to ensure your personal data protected by this Privacy and Cookie Policy.

7. Security and Retention

MARS has put in place reasonable technical and organizational measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration or disclosure. However, MARS cannot guarantee that the current security measures are 100% perfect. Besides, we do not assume any responsibility for your discloser of your personal information to the public and/or your inappropriate use of our Services, resulting in the disclosure of your personal information. We will retain your information and data for no longer than is necessary and for the duration of the agreement with You unless we are legally obliged to retain your information such as to resolve disputes, enforce our Terms of Service or other user agreements, or comply with legal requirements; in such case, your personal information will be blocked from use for any other purpose.

8. Cookies and Similar Technologies

Some of the Services use cookies and similar tracking technologies, such as pixel tags, mobile analytics and advertising IDs, and similar technologies to automatically collect information from and about your device(s) and your use of the Services.

A cookie is a small data file that MARS transfers to your computer’s hard disk for record-keeping purposes, generally to quickly identify a User's computer and to "remember" things about the User's visit. The server sends cookies to your computers when You access or view content of MARS Games. Information contained in a cookie may be linked to your personal information for purposes such as improving the quality of our Services, tailoring recommendations to your interests and making the Services easier to use. You can disable cookies at any time, although you may not be able to use all portions or functionalities of the Services.

Tracking technologies such as "pixel tags," "web beacons," "clear GIFs" or similar means (individually or collectively "Pixel Tags") in connection with our Services are used to collect usage, demographic and geographical location data. A Pixel Tag is an electronic image, often a single pixel that is ordinarily not visible to users and may be associated with cookies on a user’s hard drive. Pixel Tags allow us to count users who have visited certain pages of the Sites, to deliver branded services and to help determine the effectiveness of promotional or advertising campaigns.

MARS partners with third parties who provide us with analytic and marketing services. To optimize the Users experience provided by our Services, we may allow these third parties to place cookies on your browser that information about your use of the Services. We neither have access to, nor does our cookie policy govern, the use of cookies or other technologies that may be placed on your electronic device by non-affiliated, third-party ad technology, ad servers or ad networks. Session cookies are deleted from your computer when You close your browser. In the options menu of your browser, You can instruct it to stop accepting cookies or to notify You before accepting a cookie from the websites You visit.

9. Policy Regarding Children

We recognize a special obligation to protect personal information obtained from children. The Services are intended for general audiences and MARS does not knowingly collect any Personal Data from children. When users identify themselves as being children (i.e. under the age of 16 or under the minimum age in the relevant territory), consistent with applicable law we will obtain consent from parents for the collection, use, and sharing of their children's personal information.Information collected is secured in a manner consistent with this Privacy and Cookie Policy. If we make material changes to how we use, collect, or share your child's personal information, we will notify parents by email in order to obtain verifiable parental consent for the new uses of your child's personal information. If You are a parent or guardian who becomes aware that your child has provided us with information without your consent or You wish to revoke your previously provided consent, review information collected from your child or have that information deleted, please contact us at privacy@mars.games. MARS recognizes the importance of safeguarding the privacy of children and encourages parents to check and monitor their children's use of online activities regularly.

10. Additional Information for residents in California, USA

For residents within California, USA information regulations are governed by the California Consumer Privacy Act of 2018 (CCPA) and CCPA as amended in 2020. Under the CCPA, you have the following rights concerning your personal information:

10.1 Your Rights

a. Right to Know You may request a copy of your personal data that we hold, including information about the purposes of processing, categories of data, and recipients of your data.

b. Right to delete You may request the deletion of your personal data when:

It is no longer necessary for the purpose for which it was collected;

You withdraw your consent (and no other legal basis applies);

The data was unlawfully processed.

Please be informed that if you choose to delete your personal information, certain features that require such information may no longer be available. If we have legitimate reasons to retain your personal information, such as legal obligations, public interest, or legal claims we are not required to delete your information.

c. Right to Correct You may update or correct any inaccurate or incomplete personal data we hold about you.

d. Right to Limit Processing You may request a temporary restriction of processing if:

You contest the accuracy of the data;

The processing is unlawful, but you oppose erasure;

We no longer need the data, but you require it for legal claims.

e. Right to opt-out of sale or sharing

You may request that MARS stop selling or sharing your personal information (“opt-out”), including via a user-enabled global privacy control. MARS cannot sell or share your personal information after we receive your opt-out request unless you later authorize us to do so again. If you wish to opt-out of promotional or marketing communications from MARS you can do so by:

● Clicking "unsubscribe" in any promotional email from a specific MARS Service to change and update your contact preferences for emails from us (please note that we may still contact you via email in relation to your account, for example for password resets or other account management);

If you wish to opt-out of push notifications from MARS you can do so by:

● Changing the settings within your social media platforms to turn off notifications from MARS via these platforms. For example, by turning off notifications from Mars on Facebook; and

● Changing the settings on your device and/or browser to turn off push notifications from our Service. In some of our apps we also have the option to disable push notifications in the in-game settings.

If you would prefer to opt out of having information about your mobile app usage used for interest-based advertising, you may also do so through your device settings such as (“Allow Apps to Request to Track” on iOS and “Opt Out of Ads Personalization” on Android). Please note that even if you disable personalized advertising, you may continue to receive ads that are not based on your preferences.

10.2. How to Exercise Your Rights

To exercise any of your rights, please contact us at privacy@mars.games. We will respond to your request without undue delay and within one month of receipt.

10.3 Information Share

We do not “sell” your personal data with third parties as most people would understand that term. However, we may share your cookie information and advertising identifiers with our third-party advertising platforms to deliver interest-based advertisements, attribute installs and optimize campaign performance.

In the past 12 months, we have disclosed (or have enabled you to disclose) the following categories of personal information to third parties for business or commercial purposes:

Category of Personal Data Collected	Categories of Parties to whom Personal Data is Shared	Category of Purposes of Use of Received Third Parties
Identifiers such as username or handle, third party service ID, IP address, unique device identifier, advertising identifier, device serial number.	Venders such as cloud service providers, Google Firebase, platforms	Analytics; Advertising; Service Support
Internet or other electronic network activity information, such as hardware model, device software platform/OS and firmware, mobile carrier, preferred languages, device motion information, and mobile network information, and browsing history.	Vendors, such as Analytics providers and advertising partners.	Analytics; Advertising;
Commercial information, such as information regarding in-game purchase payment method.	Vendors, such as payment processors and business partners.	Payment, Service Support
Demographic information, such as your gender, age, date of birth, and language.	Vendors, such as cloud service providers	Storage, Service Support
Inferences derived from personal information such as profile reflecting a consumer's preferences, characteristics and behavior.	Vendors, such as Analytics providers and advertising partners.	Advertising; Service Support

10.4. Complaints

If you believe that your rights have been violated, you have the right to lodge a complaint with the supervisory authority such as the California Privacy Protection Agency or you may contact us at the following address. We would like to resolve your complaint and provide you with suitable solutions.