Privacy Policy

CAPSL Entertainment. and its Affiliates (“CE” or “we”) are dedicated to protecting the privacy rights of our online users (“users” or “you”). Affiliates shall mean subsidiaries, parent companies, joint ventures and other corporate entities under common ownership. This Online Privacy Policy (“Privacy Policy”) has been crafted to inform you as to the ways we collect, store, use, manage, and, in certain circumstances, share the information you provide in connection with any CE developed or published application (“Service”). Please note that the scope of this Privacy Policy is limited to only information collected from CE through use of the Service.

By using the Service, you agree to the collection and use of your personal information as outlined in this Privacy Policy. We may amend the Privacy Policy from time to time, and we encourage you to consult the Privacy Policy regularly for changes.  If you do not agree with this policy, do not access or use our Service or interact with any other aspect of our business.

 Information Collected and Used

CE’s primary objective in collecting user information is to provide and enhance the Service and to enable users to easily navigate and enjoy the Service. 

When you install any of CE  applications or register for an Account, we may collect and record the information you provide us directly or voluntarily and such collection and use of the information shall be governed by the Personal Data (Privacy) Ordinance, Cap. 486 of the laws of Hong Kong

The types of personal information collected in accordance with the activities listed above may vary depending on the activity. This “personal information” is defined as information about you that can be used to contact or identify you. Personal information may include: 

(1) Contact information (such as your first, last name, mobile number and email address), (2) profile information that you volunteer (such as profile photo, gender, age or birthday, links to profiles on other social networking websites), (3) your user identification number or username of the pertinent social network, which is linked to publicly available information such as name and profile picture, (4) the login email you provided to the pertinent social network upon registration, (5) username and password for our CE’s login account system.  

Additionally, we may acquire information from you through (1) your access and participation on the Service (2) your question to our customer support (3) your purchase of a virtual product of any type (4) other sources, including, but not limited to newspapers and internet sources such as blogs, instant messaging services, other users of the Service to supplement your profile. Please note that because a third party site manages the purchases of virtual goods offered by the Service, we do not have access to your credit card details and billing information.

 CE may also invite you to share non-personal information about yourself which may include, but is not limited to: (1) your age or date of birth; (2) your gender; (3) information about the hardware you may own; (4) your favorite websites; (5) friend information from your mobile phone contact list (such as friends of yours that are also connected to our Service) and fan pages; (5) your physical location and your access device (collectively referred to as “non-personal information”). If non-personal information is collected for an activity that also requires personal information, CE may combine your non-personal information with your personal information in an attempt to provide you with a better user experience, to improve the quality and value of the Services and to analyze how our Service is used.

The Service will also record game data (such as your player identification number, interactions with the game and with other players inside the game via server log files).

In addition to the information collected as described above, you may choose to share additional information about yourself throughout the Service, such as in games or on message boards. Any actions you perform with other players are considered done in public domain and is free of any obligation of confidence subsequent to the time of performance of the actions, and are at your sole discretion and risks.

We may use your name, profile picture, email address, mobile number and other information to notify you of new feature releases, notifications, and to solicit your feedback and input. Those emails will contain links for preference management and where appropriate, unsubscribe links should you decide you do not want to receive further emails.

Finally, at any time you access the Service, we may collect aggregate information including but not limited to automatically collected data (such as IP Address, your device’s operating system, browser type and language, referring / exit pages and URLs, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, and the date and time of this activity; and mobile device identifiers (such as your unique device identification number (persistent/non-persistent, hardware type, media access control (“MAC”) address, international mobile equipment identity (“IMEI”), and your device name (“aggregate information”).  We use this aggregate information to better tailor the Service to your interests, to provide you more efficient customer support, and overall enhance the Service.

We may use your name, profile picture and game play information to communicate with your friends that are also connected to the Service, which you can opt out by contacting us at the email found at the bottom of this webpage. We may also disclose information about you to our partners in order to provide the Service, resolve service problems and correct errors in the Service, to communicate with you about the Service, to provide you with advertising and promotional information in connection with the Service, and to enhance your experience on the Service.  However, we do not give our partners an independent right to share this information. Due to our contractual obligations with these third parties and the need to share information to deliver and support the Service, we cannot provide you with the opportunity to opt-out of sharing information (whether personal information or non-personal information) with these third parties. CE, certain of its partners, and each of their contractors and employees may view the information that you transmit to the Service to provide the Service and otherwise perform the tasks set forth in this Privacy Policy. 

In all cases of data access and collection, the information you provide will not be disclosed, rented, leased, loaned, sold, or otherwise voluntarily distributed to unaffiliated third parties and will be used solely for the purpose of providing you with and improving the Service.

 Other Disclosure of Your Personal Information

You understand and agree that we may be required to disclose any personal information if required to do so by law or in good faith believe that such disclosure is reasonably necessary to avoid liability, to comply with legal process, including but not limited to a search warrant, subpoena, statute, or court order, or to protect our rights and property, or that of the public. Note that CE is not required to question or contest the validity of any search warrant, subpoena or other similar governmental request that CE may receive.

Additionally, in the event of a merger, acquisition, reorganization, bankruptcy, or other similar event, customer information may be transferred to CE’s successor or assignee, if permitted by and done in accordance with applicable law.

Others’ Information

You may decide to provide us with another person’s personal information including but not limited to email address or phone number or user identification number of another web service so that the person may be invited to join the Service.  We use this information to contact and, if necessary, remind that person that he or she has been invited to join the Service or receive content from the Service. We may disclose such information if required to do so in order to comply with the legal process, as described above.


A cookie is a small data file that we transfer to your computer’s hard disk, mobile, and/or tablet (“Devices”), generally to quickly identify a user’s Device and to “remember” things about the user’s visit, such as your preferences or a user name and password. The Service sends cookies to your Devices when you access or view any CE content. Information contained in a cookie may be linked to your personal information for purposes such as improving the quality of our service, tailoring recommendations to your interests, and making the Service easier to use. You can disable cookies at any time, although you may not be able to access or use features of the Service.


The Service may contain links to other websites. The fact that the Service links to a website or presents a banner ad or other type of advertisement does not mean that CE endorses or authorizes that third party, nor is it a representation of our affiliation with that third party. CE is in no way responsible for the privacy policies of these other websites to which you chose to access from the Service. Please be sure to read the privacy policies of those websites when exiting the Service.

Third-Party Advertising Companies 

We may use third-party advertising companies to serve advertisements on the Service.  We do not provide any personal information to third-party advertising companies on a non-aggregate basis. Our system and the third-party advertising technology may use aggregate information, non-personal information, CE’s cookies on your hard drive and your use of the Service to target advertisements. In addition, advertisers may use other third-party advertising technology to target advertising on other sites. If advertisements are served to you, a unique third-party cookie or cookies may be placed on your Devices.  Similarly, third-party advertising companies may provide us with pixel tags (also called ”clear gifs” or ”beacons”) to help manage and optimize online advertising. Beacons enable us to recognize a browser’s cookie when a browser visits the site on which is beacon is located, and to learn which banner advertisements bring users to a given site.

Changing or Deleting Your Information

You may review, update, correct or delete any personal information by changing the applicable information in your profile page on Facebook and/or other social network(s) and/or other mobile platforms. If you completely delete all this information, your account may become deactivated. If you would like us to delete your record in our system, please contact us and we will attempt to accommodate your request if we are not legally obligated to retain the record. 


We have 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, we cannot guarantee that unauthorized third parties will never be able to overcome those measures or use your personal information for improper purposes. Also please note that email and messaging systems are not considered secure, so we discourage you from sending us personal information through these mediums. Although in compliance with the Personal Data (Privacy) Ordinance, Cap 486 of the laws of Hong Kong, we will adopt appropriate security procedures to help prevent unauthorized access to your Personal Information, we shall not be liable for any attempt to hack or crack or otherwise gain access to any part of the Service including any of your Personal Information.

Policy Regarding Children

The Service is not geared toward children under the age of 13 and we do not knowingly collect personal information from children under the age of 13. If we learn that a child under 13 has provided us with personal information, we will delete such information from our files as quickly as possible.

Disclaimer of Warranty and Limitation of Liability

You agree that your use of the Service shall be at your sole risk. To the fullest extent permitted by law, CE, its Affiliates, officers, directors, employees, and agents disclaim all warranties, express or implied, in connection with the website and your use thereof including implied warranties of title, merchantability, fitness for a particular purpose or non-infringement, accuracy, authority, completeness, usefulness, and timeliness. CE makes no warranties or representations about the accuracy or completeness of the content of the Service and of the content of any sites linked to the Service; CE assumes no liability or responsibility for any (i) errors, mistakes, or inaccuracies of content, (ii) personal injury or property damage, of any nature whatsoever, resulting from your access to and use of the Service, (iii) any unauthorized access to or use of our secure servers and/or any and all personal information and/or financial information stored therein, (iv) any interruption or cessation of transmission to or from the Service, (v) any bugs, viruses, trojan horses, or the like which may be transmitted to or through the Service by any third party, and/or (vi) any errors or omissions in any content or for any loss or damage of any kind incurred as a result of the use of any content posted, emailed, transmitted, or otherwise made available via the Service.

In no event will CE, its Affiliates, directors, officers, agents, contractors, partners and employees, be liable to you or any third person for any special, direct, indirect, incidental, special, punitive, or consequential damages whatsoever including any lost profits or lost data arising from your use of the Service or other materials on, accessed through or downloaded from the Service, whether based on warranty, contract, tort, or any other legal theory, and whether or not has been advised of the possibility of these damages. The foregoing limitation of liability shall apply to the fullest extent permitted by applicable law in the applicable jurisdiction. You specifically acknowledge and agree that CE shall not be liable for user submissions or the defamatory, offensive, or illegal conduct of any third party and that the risk of loss or damage from the foregoing rests entirely with you.

You agree to indemnify and hold CE, and each of its Affiliates, directors, officers, agents, contractors, partners and employees, harmless from and against any loss, liability, claim, demand, damages, costs and expenses, including reasonable attorney’s fees, arising out of or in connection with (i) your use of and access to the Service; (ii) your violation of any term of these Terms of Service; (iii) your violation of any third party right, including without limitation any copyright, property, or privacy right; (iv) any claim that one of your User Submissions caused damage to a third party; or (v) any Content you post or share on or through the Service.


These Terms of Service, and any rights and licences granted hereunder, may not be transferred or assigned by you, but may be transferred or assigned by CE without any restriction.


 By visiting or using the Service, you agree that the laws of Hong Kong, without regard to principles of conflict of laws and regardless of your location, will govern these Terms of Service and Privacy Policy and any dispute of any sort that might arise between you and CE. Any claim or dispute between you and CE that arises in whole or in part from your use of the Service shall be decided exclusively by a court of competent jurisdiction located in Hong Kong, and you hereby consent to, and waive all defenses of lack of personal jurisdiction and forum non conveniens with respect to venue and jurisdiction in Hong Kong. However, nothing aforesaid shall preclude CE from pursuing all available remedies, including relief from a court of competent jurisdiction, in the case of a dispute in which CE seeks injunctive relief, or where CE must file suit in order to avoid the expiration of the applicable statute of limitations or to enforce the judgment of the courts of Hong Kong. 

CE reserves the right to amend these Terms of Service at any time and without notice, and it is your responsibility to review these Terms of Service for any changes. Your use of CE following any amendment of these Terms of Service will signify your consent to and acceptance of its revised terms. YOU AND CE AGREE THAT ANY CAUSE OF ACTION ARISING OUT OF OR RELATED TO THE SERVICE MUST COMMENCE WITHIN ONE (1) YEAR AFTER THE CAUSE OF ACTION ACCRUES. OTHERWISE, SUCH CAUSE OF ACTION IS PERMANENTLY TIME BARRED. 

Contacting Us

If you have any questions about these Terms of Service,Privacy Policy, and your personal information including what we hold and how it is used, please contact us at you can contact us at You are entitled to request for a copy of the Personal Information we hold about you (for which we may charge a small fee) and to have any inaccuracies in your information corrected. 

Last updated on: Jan 8, 2020