Effective: [December 18, 2024 ]
Updated: [December 18, 2024 ]
This is Heroes of Jin Yong Website Privacy Policy (“Privacy Policy”).
Create AI (formerly Tusimple,including all parent, subsidiary and affiliated companies within the Create AI Group of Companies, collectively “we” or “us” or “our”) are concerned about privacy issues. This Privacy Policy explains how we collect, use, disclose, share, and safeguard your personal information when you visit our website (“Website”), engage with our marketing operations, or when you contact us, including through email or social media. Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, please do not access this Website. This Privacy Policy does not apply to personal information we obtain from individuals interacting with other our products and services such as vehicles or mobile applications.
Personal Information We Collect
Presently, the personal information we may collect includes:
1. Information You Provide (data directly from users or through third party)
(1) Account Registration Information: When you create the Website account, we may collect your [username, email address, mobile phone number], to help you create and manage the account for your use of our services provided on the Website.
(2) Connected Social Media Account Information: If you choose to log in to the Website via your social media account(s), we may receive your social media account information from third party social media providers. Such information obtained from third party social media providers will be added to your account information.
(3) Survey Information: If you participate in our surveys, we will collect your survey responses.
(4) Activity Participation Information: If you agree to participate in any activities organized by us (such as sweepstakes ), we may collect your participation information including your [name, UID, email address, mobile phone number, nickname, country/region]. Where you win any prizes, you may also need to provide us your mailing address for us to send you the prize. Your activity participation information may be added to your account.
(5) Marketing information If you participate in our game reservation activities, we may collect your participation information including your [name, UID, email address, mobile phone number, nickname, country/region].
2. Automatically Collected Information. When you visit our website, we may use automatic data collection technologies as described under section “Cookies and Similar Technologies” in this Privacy Policy to collect the following information to ensure security and stable operation, prevent cheating and improve the functionality and quality of Website services and other purposes as set forth in Section 2 of this Privacy Policy:
(1) Access times;
(2) The pages you have viewed directly before and after accessing the website.
(3) Internet Protocol (“IP”) addresses of the devices you are using to interact with us online;
(4) Tools such as cookies and other local storage used by websites and web browsers to maintain information regarding your previous activities on a site;
(5) Information regarding your internet connection including your Internet Service Provider, connection type, and approximate city level location of your internet connection based on IP address;
(6) Information about how the device is interacting with our Website and social media accounts;
(7) Type and version of your device’s operating system and web browser;
(8) Specific interactions with our Website (such as which pages you viewed, in what order, and how long you engaged with each page); and
(9) Error logs.
How We Use Your Personal Information
We may use the personal information you provide to us or that we collect about you to:
1. Respond to an email or other inquiry or request, including to fulfill your request to subscribe to a our newsletter;
2. Customize your experience on our Website;
3. Deliver advertisements ,game development updates, and launch notifications to you, including on other websites you visit;
4. Provide, maintain, analyze, and improve our Website;
5. Monitor and analyze usage and trends to improve the functionality of our Website;
6. Perform other business activities as needed;
7. Fulfill our obligations under applicable laws and regulations, respond to requests of government authorities;
8. Establish, exercise or defend legal claims;
9. Detect, prevent, and respond to fraud, abuse, and security issues;
10. Carry out any other purpose described to you at the time the information was collected.
Cookies and Similar Technologies
We use "cookies" and similar tracking technologies to gather information about your visit to our Website (see section “Automatically Collected Information” above). These technologies including:
1. Google Analytics: We use Google Analytics to help us understand your use of our Website and the popularity of certain content so we can improve your experience. You can learn about Google’s privacy practices at www.google.com/policies/privacy/partners/, and you can opt out of Google Analytics by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
2. LinkedIn Insights Tag: We use LinkedIn Insights Tag to retarget our Website visitors and learn insights about your interactions with our LinkedIn advertisements. You can learn about LinkedIn’s privacy practices at www.linkedin.com/legal/privacy-policy, and you can opt out of LinkedIn Insights Tag at www.linkedin.com/psettings/.
3. Google Ads: We use Google Ads to help us determine how effective our ad campaigns are. You can learn about Google’s privacy practices relating to Google Ads at policies.google.com/privacy, and you can prevent your participation in Google Ads conversion tracking by setting your browser to block cookies from the domain www.googleadservices.com.
Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. There is no final uniform technology standard for recognizing and implementing DNT signals. As a result, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.
How We Share Your Personal Information
We will share your personal information with:
1. Third-party service providers (but only as necessary to provide services to us) and our affiliates: We will require those third-party service providers and affiliates to keep such information confidential and use it only for the purposes for which we disclose it to them. Once we have selected specific service providers, we will update this policy to reflect the services we use and provide links to their privacy policies for your review.
2. Advertising service contractors: These third parties may use cookies or similar technologies to collect information about you when you use our Website. They may use such information to provide you with personalized ads or other targeted content. You can generally opt out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt out pages on the NAI website and DAA website.
3. Regulatory agencies or others as requested by laws: we might need to share your personal information with third parties where required by law or to comply with a valid legal process (such as a search warrant, subpoena, or court order), to investigate or remedy potential violations of our policies, to protect our rights or property, or during emergencies when personal safety is at risk.
4. Merger, acquisition, reorganization, bankruptcy or other similar events: we may share your personal information with a buyer or other successor company in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our website visitors is among the assets transferred.
Data Retention and Security
We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless longer retention is required by law or for auditing purposes.
We have affiliated companies that are located throughout the world. You acknowledge and agree that your data will be stored and processed on our servers which may not located in your country/region of residence. Please be aware that, in general, the information we collect will be stored in our servers located in the United States. But depending on the services you use and how you engage with us, your information may be processed in countries/regions other than the United States and can be accessed by our support, engineering and/or our affiliates around the world.
No matter where our servers are located, we will make great efforts to take the appropriate safeguards to guarantee your rights in conformity with this Privacy Policy and any applicable laws and regulations. We have implemented reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure.
However, the transmission of information via the Internet is not completely secure. While we strive to protect your personal data, we also remind you to be aware of hacking, cyber-attacks, and other risks on the Internet. Therefore, we strongly urge you to take every possible precaution to protect your personal information when using our Websites.
Links to External Websites
For your convenience and informational purposes, our Website may contain links to external websites that are not owned or controlled by us. We have no control over, and assumes no responsibility for, the content, privacy policies, or practices of any external websites. If you visit such sites, your activities and the collection, use, and disclosure of information will be subject to the privacy policies and terms of the external websites or services, and not this Privacy Policy.
Children’s Privacy
The Website is not directed to, or intended for children under 16. We do not knowingly collect personal information from children under the age of 16. If we find out that a child under 16 (or other age threshold required by local laws) has given us personal information, we will take steps to delete that information. If you have reason to believe that a child under 16 has provided personal information to us, please contact us through the means provided under the Contact section below.
If you are 16 above but are considered a minor in your country, you must have your parent or legal guardian read through this Privacy Policy with you and you represent that you have obtained the permission of your parent or guardian to use the Website and related services.
Your Rights and Choices
Subject to applicable laws and regulations, you may have the following data protection rights:
1. Request access to or a copy of your personal information;
2. Request deletion of your personal information;
3. Request correction or modification of your personal information;
4. Right to opt out of marketing communications;
5. Be informed about the personal information we collect and/or process about you, the sources of personal information, and the third parties with whom information was shared or sold and for what purposes;
6. Withdraw consent, if processing is based on consent;
7. Right to complain.
To exercise any applicable data protection rights, you may contact us through the means provided under the “Contact” section below.
To protect the security of your personal information, we may ask you to provide certain additional information to verify your identity before we respond to your requests. Under some circumstances, we may refuse to comply with your request as permitted by applicable laws and regulations. We may also charge a reasonable fee for complying with your request in accordance with applicable law, e.g. if your request is clearly repetitive or excessive.
Contact
If you have any questions as to how we collect and use your personal information, or would like to exercise your data protection rights, please contact us at 【 jinyongherosservice@gmail.com】 .
Updates
We reserve the right to make changes to this Privacy Policy from time to time and for any reason. You should check this Privacy Policy regularly to see if there have been any changes. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted changes in any revised Privacy Policy by your continued use of the Website after the date the revised Privacy Policy is posted.
California Privacy Rights and Additional Information
This privacy notice for California Residents supplements the information contained in this Privacy Policy and applies to visitors, users, and others who reside in the State of California. If you are a California resident, the California Consumer Privacy Act (“CCPA”) provides you with certain rights with respect to your personal information.
1. Collection and Use of Personal Information
In the preceding 12 months, we have collected the following categories of personal information: identifiers, personal information categories listed in the California Civil Code Section 1798.80. (e), commercial information, internet or other similar network activity. For examples of more specific information we collect and the sources of such collection, please see “Personal Information We Collect” section in the Privacy Policy. We collect your Data for the business and commercial purposes described in “How We Use Your Personal Information” Section.
2. Disclosure of Personal Information
We may share your personal information with third parties as described in the “How We Share Your Personal Information” above. In the preceding 12 months, we have disclosed the following categories of your personal information for business or commercial purposes: identifiers, personal information categories listed in the California Civil Code Section 1798.80. (e), commercial information, and internet or other similar network activity. All categories of personal information listed here may be shared with categories of third parties as listed in “How We Use Your Personal Information” section above.
3. Sale of Personal Information
California law requires that we provide transparency about your personal information we “sell”, which for the purposes of the CCPA, means scenarios in which personal information is shared with third parties/partners in exchange for valuable consideration. In the preceding 12 months, we have not sold any of your personal information.
4. Your Rights
you have the following rights under CCPA:
(1) Right to Know: You have the right to request more information about the categories and specific pieces of personal information we have collected, sold, and disclosed for a business purpose in the last 12 months;
(2) Right to Delete: You have the right to request deletion of your personal information;
(3) Right to Non-Discrimination: You have the right to be free from discrimination for exercising your rights under the CCPA;
(4) Right to Opt-Out: You have the right to opt-out of the sale or sharing of your personal information;
(5) Right to Correct: You have the right to correct inaccurate personal information we may have;
(6) Right to Limit Use and Disclosure of Sensitive Personal Information: You have the right to limit the use and disclosure of sensitive personal information we may have.
To exercise any one of these rights, please contact through the means provided under the “Contact” section. You are also permitted under the CCPA to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.
5. California “Shine the Light” Disclosure
California Civil Code Section 1798.83 permits users of services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please submit a verifiable consumer request to us by: [jinyongherosservice@gmail.com]
6. California Rights for Minor Users
California Business and Professions Code Section 22581 permits you, if you are a California resident under the age of 18, to view, correct, or remove information provided by you or publicly posted by you. To make such a request, please submit a verifiable consumer request to us by: [jinyongherosservice@gmail.com]
EEA and UK Residents Notice
If you are in the European Economic Area (EEA) or the United Kingdom (UK), the following additional information applies to you in addition to the Privacy Policy set out above.
1. Data Subject Rights
In addition to the information set out in the "Your rights and choices" section in the Privacy Policy above, you have the right to:
(1) ask us to restrict the processing of your personal data;
(2) data portability;
(3) to object to the processing of personal data.
2. Legal basis for processing your personal information
Our legal basis for collecting and using the personal information for the purposes as described in the Privacy Policy above is:
(1) To establish and perform our contract with you (i.e. our Terms of Service) and to provide our services;
(2) For our legitimate interests, where those interests are not overridden by your data protection interests of fundamental rights and freedoms, e.g. to improve our services;
(3) Consent, where obtained separately;
(4) For compliance with our legal obligations under applicable laws and regulations;
(5) To protect our or your vital interests or those of another person, e.g. against fraud and violations of our terms;
While we typically do not collect sensitive or special category personal information, where we do this, it will be on the grounds of consent or other applicable lawful basis. If you have questions, need further information about the legal bases for processing your personal information, or want to withdraw your consent, please see section “Contact” in the Privacy Policy above.
3. International data transfer
As a global company, we may transfer your personal information to our affiliates, third party service providers that operate around the world, which are located in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country.
Where we transfer your personal information to countries and territories outside of the EEA and the UK, which have been formally recognised as providing an adequate level of protection for personal information, we rely on the relevant “adequacy decisions” from the European Commission, where applicable.
Where the transfer is not subject to an adequacy decision, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy. All companies are required to protect personal information that they process from Europe in accordance with European Union data protection law.
4. Data Protection Supervisory Authority
If you’re in the EEA or UK, you may lodge a complaint with an EEA or UK data protection authority for your country or region where an alleged infringement of applicable data protection law occurs.
China Residents Notice
This section applies solely to users who access or use our services from the People's Republic of China (excluding Hong Kong, Macau, and Taiwan). We are committed to protecting your personal data in compliance with the Personal Information Protection Law (PIPL) and other applicable laws and regulations in China.
1. Categories and Use of Personal Information
We collect and process your personal information as described in this Privacy Policy. If we need to collect sensitive personal information (e.g., biometric data, health information, or precise location data) from you, we will obtain your explicit and separate consent prior to collection and processing.
2. Data Storage and Cross-Border Transfers
We collect personal information from you, which may be transferred and stored on servers located in the United States. This transfer is necessary to provide and improve our services.By using our services, you explicitly consent to the transfer of your personal data to our servers located in the United States, and we take appropriate security measures to protect your data.
3. Your Rights
Under the PIPL, you have the following rights regarding your personal information:
Access: You can request access to the personal data we hold about you.
Correction: You can request corrections if your data is inaccurate or incomplete.
Deletion: You may request the deletion of your personal data under specific circumstances, such as when the purpose of processing has been achieved or consent has been withdrawn.
Data Portability: You can request to transfer your personal data to another service provider, subject to technical feasibility.
Withdrawal of Consent: You may withdraw your consent for processing your personal data at any time.
4. Protection of Minors
If you are under the age of 14, we will only collect and process your personal information with the consent of your legal guardian. Parents or guardians may contact us to review, update, or delete their child s personal data.
5. Security Measures and Incident Notifications
We implement technical and organizational measures to protect your personal data from unauthorized access, loss, misuse, or disclosure. In the event of a data breach, we will promptly notify affected users and the relevant authorities as required by Chinese law.
6. Contact Information
If you have any questions, concerns, or complaints about how your personal data is handled under this policy, or if you wish to exercise your rights under the PIPL, please contact us at [business@jinyongheros.com].