Privacy Policy
                                                                                                                                                                                                                                                Last Updated: 2022/09/23

Thank you for choosing the products or services as offered by Pathea Co., Ltd. and its affiliates (including but not limited to Chongqing Zheergen Co., Ltd. and Logoi Co., Ltd., and hereinafter collectively referred to as “the Company” together with “Pathea“).

You are reading this Privacy Policy, made under and shall be governed by and construed in all respects in accordance with the laws of the People’s Republic of China, which explains how we collect, use and disclose your personal data when you download the Game from Apple App Store, Google Play, Steam, WeGame, or other channels, access the Game, and the rights you may have under applicable privacy laws. We may modify this Privacy Policy from time to time. In case of modification, we will change the Last Update shown at the top of this Privacy Policy to inform you, or provide additional notice in certain circumstances (such as adding a statement to our service home page or sending you a separate notice). If you do not agree with this Privacy Policy, you should not play the Game.

If the personal information protection statement of a particular service is inconsistent with this Privacy Policy, the personal Information Protection Statement of that particular service shall prevail.

If you have any questions about how we use your personal data, please contact

Please note that this Privacy Agreement does not apply when:

(1) Information collected by third-party services (including any third-party websites) accessed through our services;

(2) Information collected by other companies or organizations that advertise on our services.

By playing or continuing to play the Game, you consent to our collection, use, storage and sharing of your information in accordance with this Privacy Policy.

1.The Types of personal data we collect

Unless otherwise stated in this Privacy Policy, the personal data we collect from you or about you is required so that we can perform our contract with you to provide our support for your access to and use of the Game as detailed in our Terms of service for online services for Pathea’s Games.)

1) Information You Provide to Us

We collect information you provide directly to us. For example, we collect information when you create an account, interact with other users, upload images to our servers, request customer support, participate in surveys or otherwise communicate with us. You have the right to choose not to provide the information, but if you refuse to provide the relevant information, you may not be able to login to the Games, accept or use some or all of the specific products or services provided by us, or the services you accept or use may not achieve the intended effect.

2) Information We Collect Automatically When You Use the Services

When you access or use our Services, we automatically collect information about you, including:

• Usage Information: We collect information about your use of our Services, including gaming service ID, levels completed, game scores, time spent using our Services, and other game play information.

• Log Information: We log information about your use of our Services, including your browser type and language, access times, pages viewed, your IP address and the website you visited before navigating to our Services.

• Hardware Information: We collect information about the computer or device you use to access our Services, including the hardware model, operating system and version, browser mobile network information, list of other Pathea mobile applications installed on the device, MAC address, IP address International Mobile Equipment Identity (“IMEI”) number and other unique device identifiers made available by the operating system of your device.

• Location Information: We may collect information regarding the geographic location of your device each time you use the Services provided on iOS or Android platforms, or otherwise consent to the collection of this information. You may opt-out of the collection of platform provided location data using the settings on your device. Your location is stored for the period specified in the Services before collection.

 Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your computer hard drive or in device memory that help us to improve our Services and your experience, see which areas and features of our Services are popular and count visits.

Information We Collect From Other Sources

We may also obtain information from other sources as far as it is necessary to perform our Services, and combine that with information we collect through our Services. For instance, we may collect game ranking and achievement status from your PC, console or mobile operating system game center application. Additionally, when you complete in-app purchases, we may collect information about you from the provider of your device operating system when they process the purchases on our behalf. Please note that we do not receive your payment method information from the operating system providers. In all other cases we will ask you to authorize us to collect, store, and use personal information from third parties.

Please notice: the individual device information and service log information are information that cannot identify the identity of a specific natural person and do not belong to your personal information (hereinafter referred to as “non-personal information”). We have the right to use non-personal information for lawful purposes. If we combine this kind of non-personal information with other information to identify a specific natural person identity, or combined with other personal information, such non-personal information will be treated as personal information during the period of using. In addition to obtain your authorization or otherwise prescribed by laws and regulations, we will anonymize and de-identify this information.

2. How and for what purpose we use your personal data

In accordance with, and to perform our contract with you, we may use your data to provide you with user support. We may also use your data to improve our products and services where it is in our legitimate interests to do so.

We (or a third party data processor on our behalf) may collect, store and use information about you for the following purposes for the periods necessary to achieve such purposes:

• Provide, maintain and improve our Services;

• Provide and deliver the products and services you request, process transactions and send you related information;

• Register you for an account on our Services and assist in the management of your account

• Respond to your comments, questions and requests and provide customer service;

• Send you technical notices, updates, security alerts and support and administrative messages;

• Communicate with you about products, services, offers, promotions, rewards, and events offered by Pathea and others, and provide news, information and other marketing materials that we think will be of interest to you;

• Monitor and analyze trends, usage and activities in connection with our Services;

• Process and deliver contest entries and rewards promoted by Pathea;

• Personalize and improve the Services and provide in-Service advertisements, content or features that match user profiles or interests;

• Link or combine with information we get from others to help understand your needs and provide you with better service;

• Detect, investigate and/or prevent fraudulent, unauthorized or illegal activity;

• For any other purpose required or authorized for us to comply with our legal and regulatory obligations; and

• For any other purpose for which you provided the information.

If we use your information for other purposes not specified in this Privacy Policy or collected it for other specific purposes, we will ask your consent.

If you are based in the European Economic Area, Switzerland or the United Kingdom (the “European Region”), the applicable legal bases for the processing set out above are that the processing is required for the performance of our contract with you and for the performance of our legitimate interests, namely to improve our products and services based on your feedback.

3.How do you access and control your personal information

We will take appropriate technical measures to ensure that you can access, update and correct your account information or other personal information provided when using our Services.

4.Who else will access your personal data and how we share your data

We will not share your personal information with, transfer or otherwise exchange your personal information to, third parties unless our products or services provide, or are required by law, in accordance with this Privacy Policy, or you have expressly agreed to do so to us. We do not sell your personal information to third parties. To comply with the foregoing, the Company may share information about you with other parties under the following circumstances or other circumstances described in this Privacy Policy:

(1) If you choose to participate in the interactive area of our service, such as multi-player game, chat or sharing function, the Company may share information about you with other users (but our service prohibits users from using personally identifiable data (such as your full name) as their user name);

(2) and are working on behalf of our company, and need to access the information of our employees, subsidiaries, affiliates, consultants and other third parties, the seller service providers to share information about you (including: for example, developers and payment service providers, web hosting services, or information storage and processing service providers)

(3) To respond to legal proceedings or requests for information (including, for example, government or regulatory agencies, law enforcement agencies or courts) in accordance with or where disclosure is required under applicable laws, rules or regulations;

(4) where we have reasonable grounds to believe that your actions are in conflict with our user agreements or policies, or to protect the rights, property and safety of Pathea, its users or others;

(5) Your personal information may be transferred as part of mergers, acquisitions, asset transfers or similar transactions that we and our affiliates may undertake as our business continues to grow. We will inform you before the transfer; and

(6) With your consent or direction.

(7) In addition, in accordance with relevant laws, regulations and national standards, we may share, transfer or publicly disclose personal information without your prior authorization under the following circumstances:

    • those directly related to national security and national defense security;

    • those directly related to public safety, public health or major public interest;

    • directly related to criminal investigation, prosecution, trial and execution of judgment;

    • For the maintenance of personal information subject or other personal life, property and other significant legitimate rights and interests but it is difficult to get my consent;

    • the subject of personal information voluntarily discloses personal information to the public;

    • Collecting personal information from legally disclosed information, such as legal news reports, government information disclosure and other channels.

5. Advertising and analysis services provided by others

The Company may accept others to provide analytical services on behalf of the Company and provide advertising within the scope of our services. These companies can use technology to automatically collect information about your devices and use of our services, including IP addresses, device identifiers, and the length of time you have visited and the links you have clicked on our services. This information can be used by the Company and others to, among other things, maintain, improve and analyze the functionality of our services and to serve ads that are relevant or targeted to the Web content that may be of interest to you. The use of your information by these third parties is governed by their respective privacy policies, and we do not control and are not responsible for the privacy practices of third parties.

6. International data transfers

In order to provide support services to you, the personal data that we collect from you may be transferred to, and stored at, or otherwise accessed from or processed in a destination outside of your jurisdiction of residence that has laws and regulations that may not guarantee the same level of security and protection of personal data as your jurisdiction.

However, we will take reasonable and necessary steps to ensure that we and our third party service providers handle personal data in accordance with this Privacy Policy and provide a standard of protection that it is comparable with the protection under the laws of your jurisdiction, regardless of where your personal data is transferred to or accessed from.

We will separately obtain your consent for international data transfer if this is required under applicable law.

7. Your rights  

You may have the following rights under applicable laws:

– The right to request free of charge (i) confirmation of whether we process your personal data and (ii) access to a copy of the personal data retained; and

– The right to request proper rectification or removal of your personal data or restriction of the processing of your personal data.

In addition to the above, if you are based in the European Region, you have the following rights:

– Object: The right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal data, and we will assess and inform you if that is the case.  You can object to marketing activities for any reason.

– Portability: You can ask for a copy of personal data you provided in a machine readable form.

– Withdraw Consent: If you have provided consent for the processing of your personal data, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal data before your withdrawal.

Before we can respond to a request to exercise one or more of the rights listed above, you may be required to verify your identity or your account details.

Please send an e-mail to if you would like to exercise any of your rights. We will respond to your request consistent with applicable law and subject to proper verification.

8. The security of your personal data

We take steps to ensure that your data is treated securely and in accordance with this policy. We understand the importance of keeping your personal data safe and private, and we are committed to protecting your personal data from being lost, stolen or misused. Due to the limitations of technology and the potential for malicious means, even with the best security measures we can take, information cannot always be completely safe. The systems and communication networks you use to access our services may fail due to factors beyond our control.

Remember, whenever you voluntarily disclose personal information (e.g., in the message board, via email or in chat), collection and use of such information may be others, therefore cause your personal information, the company is not liable, if your personal information will be released in the channel, it may cause your personal information. Therefore, we remind and ask you to carefully consider whether it is necessary to disclose your personal information through the above channels.

9. How long do we keep your personal data  

We retain your data for as long as it is necessary to provide you with the service so that we can fulfill our contractual obligations and rights in relation to the data involved. However, there are occasions where we are likely to keep this data for longer in accordance with our legal obligations or where it is necessary for the establishment, exercise or defense of legal claims.

To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and the applicable legal requirements.

10.Third-party websites or services

Our services may contain links to websites or services operated by other third parties. Please note that this Privacy Policy only applies to our services, and we are in no way responsible for the collection, storage and use of personal information by third parties through our website. You must read carefully the privacy policy of each third party operator’s website or service.

11. Tips for Minors Users

We attach great importance to the protection of minors’ personal information and continue to explore new ways to protect minors’ personal information. We will actively protect the legitimate rights and interests of minors by using the anti-addiction system in accordance with the requirements of the national anti-addiction policy. We will verify the relevant information to determine whether the real name information of the relevant account is a minor, and then decide whether to include the account into the anti-addiction system.

If you are a minor under the age stipulated by the applicable laws and deemed as child under such laws, you shall carefully read this Privacy Policy and our Privacy Protection Guidelines for Children with your guardian, and use our products, services or provide us with information with your guardian’s consent.

If you are the guardian of a minor user, please carefully read and choose whether to agree with this Privacy Policy. We hope that you can join us to protect minors’ personal information, educate and guide minors to enhance their awareness and ability of personal information protection, and guide, remind and require them not to provide any personal information to any network product or service provider without your consent. If you have any questions about the personal information of your child and hope to inquire, access, modify, correct or delete it, please contact us through the Contact term set forth in this Privacy Policy.

Please choose whether to consent your child using our products or services after carefully and fully reading this Privacy Policy. If you do not agree with this Privacy Policy or do not agree to provide the necessary information for our service, it may cause our products or services to fail to operate normally, or fail to achieve the intended service effect, and your child may not be able to use our products, services or related specific business functions normally.

By clicking “Agree”, it means that you agree to our collection, use and processing of minors’ information in accordance with the provisions of this Privacy Policy and Privacy Protection Guidelines for Children.


In the event that you wish to make a complaint about how we process your personal data, please contact us in the first instance at and we will endeavor to deal with your request as soon as possible. This is without prejudice to your right to lodge a claim with the relevant data protection authority.

13. Changes

We will generally notify all users of any material changes to this policy, through a notice provided via the Game or Service provided by Pathea and providing any other notice required by applicable law. We will also update the “Last Updated” date at the top of this policy, which reflects the effective date of such policy. In such event, by continuing to use our Services, you agree to be bound by this Privacy Agreement, as amended.

14. Contact

Questions, comments and requests regarding this policy should be addressed to


Privacy Protection Guidelines for Children

Thank you for choosing the products or services as offered by Pathea Co., Ltd. and its affiliates (including but not limited to Chongqing Zheergen Co., Ltd. and Logoi Co., Ltd., and  hereinafter collectively referred to as “the Company” together with “Pathea“).

In addition to “Pathea Games Privacy Policy”, through this Pathea Games Privacy Protection Guidelines for Children (“Children’s Guidelines”), we will further help you and your child (“child” or “Children” shall be under the age stipulated by the applicable laws and deemed as child under such laws) understand how we collect, use, store and share your child’s personal information, as well as the relevant rights you and your child are entitled to. We will explain to you the collection of children’s personal information through prompts, interaction processes, website announcements and other ways and obtain your consent. Please carefully read and fully understand “Pathea Games Privacy Policy” and the Children’s Guidelines, before choosing to agree the afore-mentioned privacy policies.

1. Children’s Personal Information We Collect


While your child is using Pathea Games and Service, we will only collect your child’s information upon your consent or by you and your child’s voluntary provision, in order to provide and optimize our services to your child and to ensure your child’s account in safe security. We may collect you and your child’s personal information through third party service providers, as detailed in the Pathea Games Privacy Policy. We will collect information such as your login time, length of playing games, etc., and guide the minors to play games rationally through ways such as automatically intervening and limiting the game duration of the minors in our system, enabling the function of mandatorily exiting the game, etc. Besides, we may also collect the game behavior data generated during the game (for example, the data such as the click pressure and radius, the relative position of the click, the acceleration direction, and the direction of gravity formed when you operate the game on the terminal device, and the voice data generated when you interact with other players through online voice in the game) to preliminarily determine whether the user is a minor.

Also, in order to verify your custody relationship with your child, we might collect your contact information (including phone number, email address) and other information to help us judge the existence of custody relationship. When the consumption is conducted by a person suspected to be a minor, we will then try to contact his or her guardian for reminders, confirmations and deposition, so as to help the minors have a healthy access to the Internet.

At present, aside from collecting game research information from third-party research organizations to help us upgrade our game products and provide personalized services, we do not take the initiative to obtain your child’s personal information from any third party outside of Pathea. In the future, if Pathea needs to obtain your child’s personal information indirectly from a third party outside of Pathea, we will strictly comply with the relevant laws and regulations and require the said third party to guarantee the legality of the information it provides.

2. How We Use Children’s Personal Information


We will strictly obey the laws, regulations and the agreement with our users, and we will make use of the collected information in accordance with the Children’s Guidelines, and Pathea Games Privacy Policy to provide your child with better service.

We use children’s personal information as mentioned above in Section 1. We will protect the legitimate rights and interests of minors by initiating anti-addiction system in accordance with national regulations on online game anti-addiction policies. We will make a judgment on whether the real name information of an account belongs to a minor via the identification result of information such as real-name identity, based on which we decide whether the account shall be included in the anti-addiction system. If we use your child’s personal information beyond the scope, or a direct or reasonably relevant scope, of the purpose we claimed when collecting that information, we will inform you once again and seek your express consent before using your child’s personal information.

3. Storage of Children’s Personal Information


3.1 In accordance with laws and regulations, we will store your child’s personal information within the information collection territory and strictly keep that information confidential. If we need to transmit personal information collected within the information collection territory to overseas institutions for the sake of cross-border business, we will protect your child’s personal information pursuant to domestic laws, administrative regulations and competent authorities’ specifications.

3.2 In general, we will only store your child’s information for a necessary period for achieving the purpose of providing our services or as required by laws and regulations. After the period specified by laws or competent authorities has expired, we will delete or anonymize your child’s personal information in accordance with the requirements of laws and regulations.

4. Security of Children’s Personal Information


4.1 In order to ensure the safety of your child’s personal information, we will take reasonable and necessary measures under the current level of technology to protect children’s information, and adopt measures of physical protection, security technology, management systems and so forth to reduce the risk of information loss, improper usage, unauthorized access, disclosure and alteration, including but not limited to, encrypted data transmission, firewalls and encrypted storage, physical access control, and information access authorization control.

4.2 We have established special management regulations, procedures and organizations to safeguard the security of your child’s personal information. For example, we will strictly limit the scope of people that are authorized to access the information, requiring them to comply with confidential obligations and conducting audits.

4.3 If any security incident such as the leak of children’s personal information occurs, we will initiate the emergency plan to prevent it from expanding and inform you the basic situation of the security incident, the treatment measures and remedies we will take or have taken as well as our advice for you via announcements, push notifications or emails, etc. in a timely manner. If it is difficult to inform every user, we will issue the warning through public announcements and other methods.

5. Rectification of Children’s Personal Information


If you and your child find there is any mistake regarding the child’s personal information, you may contact us for rectification.

6. Deletion of Children’s Personal Information


6.1 If you and your child find we process children’s personal information against the requirements of laws, administrative regulations or our agreement, or beyond the purpose scope or the necessary period, you may contact us to delete relevant personal information.

6.2 If you withdraw your consent, you may contact us and we will deal with it pursuant to relevant laws and regulations.

6.3 If you and your child take the initiative to terminate the use of Pathea Games and Service, we will stop using relevant child’s personal information, except as otherwise required by laws, regulations or competent authorities. If we plan to cease any operation of products or services, we will notify you in accordance with relevant laws and regulations.; in the meantime, we will stop using children’s personal information in a timely manner and delete or anonymize the stored information.

7. Transfer and Delegation of Children’s Personal Information


Generally, we will not transfer to or delegate any third party to process children’s personal information. In the case where we have to do so, we will take compliance measures according to laws and regulations, including but not limited to conduct a security assessment on the third party.

8. Disclosure of Children’s Personal Information


Unless otherwise required by laws, administrative regulations or pursuant to our agreement, or protect you, your child and other users personal property security, we will not disclose children’s personal information.

9. Others


9.1 “Pathea Games Privacy Policy” is general privacy policy uniformly applied in Pathea Games and Service, and is made under and shall be governed by and construed in all respects in accordance with the laws of the People’s Republic of China. The contents specified therein, including but not limited to user rights and information security protection measures, etc., are all applicable to the users of Pathea Games and Service. The Children’s Guidelines are privacy protection guidelines designed for children, which include special protection of children’s personal information. If there is any inconsistency or contradiction between the Children’s Guidelines and “Pathea Games Privacy Policy”, the Children’s Guidelines shall prevail.

9.2 We will generally notify all users of any material changes to this Children’s Guidelines, through a notice provided via the Game or Service provided by Pathea and providing any other notice required by applicable law. We will also update the “Last Updated” date at the top of this Children’s Guidelines, which reflects the effective date of such policy. In such event, by continuing to use our Services, you agree to be bound by this Children’s Guidelines, as amended.

10. Contact Us


When you and your child have any questions to the Children’s Guidelines, or any relevant complaints, suggestions, or requests, you and your child are encouraged to contact us via We will review the issues involved as soon as possible, and handle them promptly after verifying your identity, and reply within a maximum of fifteen days or within the period prescribed by laws and regulations.

Pathea Co., Ltd.


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