Privacy Policy

Last Updated: December 1, 2025

1. Introduction

Beijing Ningdom Technology Co., Ltd. (hereinafter referred to as "Ningdom," "we," "us," or "our") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard information when you use our products, applications, games, and services (collectively, "Products").

This is a general Privacy Policy for Products developed and published by Ningdom. The exact data practices may vary by Product, platform, device, feature, and user choice. We collect only the categories of information needed for the Product or feature you use, and any Product-specific notice or in-app disclosure will supplement this Privacy Policy.

Our Products may be available across:

  • Operating Systems: Including but not limited to iOS, Android, Windows, macOS, Linux, and other operating systems
  • Devices: Including but not limited to smartphones, tablets, personal computers, VR/MR headsets, handheld gaming consoles, home gaming consoles, smartwatches, smart glasses, and other connected devices
  • Distribution Platforms: Including but not limited to App Store, Google Play, Steam, Epic Games Store, Meta Quest Store, PlayStation Store, Xbox Store, Nintendo eShop, and other digital distribution platforms

By using our Products, you acknowledge the data practices described in this Privacy Policy. Where consent is required by applicable law or platform rules, we will request it separately. If you do not agree with this policy, please do not use our Products.

2. Information We Do NOT Collect

We want to be transparent about what our Products generally do not collect or store. Except where a Product, feature, permission prompt, or user action clearly provides otherwise, our Products do not collect or store the following sensitive personal information:

  • Personal identification information (name, address, phone number, email address) unless you voluntarily provide it
  • Financial information (credit card numbers, bank account details)
  • Biometric data used to identify or authenticate a person
  • Precise location data (GPS coordinates)
  • Contacts, messages, or call logs
  • Photos, videos, or other media files from your device unless you choose to save, export, upload, share, back up, or sync them through a Product feature
  • Microphone recordings or camera recordings unless you choose to create, save, export, upload, share, back up, or sync them through a Product feature

3. Information We Collect

We only collect information that is necessary to provide, maintain, secure, and improve our Products. The specific categories depend on the Product and features you use. The information we may collect includes:

3.1 Usage Data

We may collect usage, diagnostic, and performance data to understand how our Products are used and to identify and fix issues. Where practical, this data is aggregated, de-identified, or otherwise limited. This may include:

  • App launch events and session duration
  • Feature usage and interaction patterns
  • Performance metrics (crash reports, error logs, loading times)
  • Device information (device type, operating system version, screen resolution)
  • General location data (country/region level, not precise GPS)

3.2 Technical Data

We may collect technical information necessary for Product functionality, analytics, security, fraud prevention, advertising, or platform services:

  • Device identifiers (such as advertising ID or device ID) where used for analytics, advertising, security, or platform functionality
  • IP address (anonymized when possible)
  • Platform-specific identifiers (such as Apple, Google Play Services, Steam, or other platform identifiers) where needed for platform functionality, purchases, accounts, or support
  • Product version and build information

3.3 User-Generated Content

If you choose to create, upload, or share content within our Products, we may collect and store that content to provide the service. This content is stored securely and is only used for the intended purpose.

3.4 Camera, Face, and Facial Feature Processing

Some Products may use the device camera to provide camera-based visual effects, previews, editing, augmented reality, or similar user-facing features. When these features are used, the Product may process camera frames on your device to detect faces, facial areas, facial landmarks, facial contours, facial position, or similar geometry needed to render the feature.

This processing is used only to provide the requested in-app feature, such as positioning an effect, preview, overlay, filter, or edit on your face or facial area. We do not use this data to identify users, verify identity, authenticate users, track users across apps or websites, create biometric templates, or perform face recognition.

Unless a specific Product clearly states otherwise, camera frames and face or facial-feature data are processed locally on your device. They are not uploaded to our servers, sold, or shared with third parties. They are not used for advertising, marketing, analytics, or data mining.

Face and facial-feature data processed for live camera features is retained only temporarily in device memory while the feature is being used. It is overwritten or discarded as new frames are processed, when the camera session ends, or when the Product is closed.

If a Product allows you to save or export an image or video, the resulting file is saved only when you choose to do so. Saved or exported media is stored in the location you select or in the location provided by the operating system, such as your photo library. We do not receive or store a copy unless the Product separately and clearly offers an upload, backup, sync, or sharing feature and you choose to use it.

4. How We Use Information

We use the collected information for the following purposes:

  • Product Improvement: To analyze usage patterns, identify bugs, and improve Product performance and user experience
  • Technical Support: To diagnose and resolve technical issues
  • Analytics: To understand how our Products are used and to make data-driven decisions
  • Legal Compliance: To comply with applicable laws and regulations
  • Security: To detect and prevent fraud, abuse, and security threats

5. Third-Party Services and Data Collection

Our Products may integrate with third-party services that have their own data collection practices. The services used vary by Product and platform. These services may include:

5.1 Advertising Services

We may use third-party advertising networks to display ads in our free or ad-supported Products. These services may collect and use data for advertising purposes, including:

  • Device identifiers for personalized advertising
  • Advertising interaction data
  • Demographic information (age, gender, interests) inferred from usage patterns

Advertising partners may include Google AdMob, Unity Ads, Meta Audience Network, and other advertising platforms where they are integrated into a particular Product. Each service has its own privacy policy governing data collection and use.

5.2 Analytics Services

We use analytics services to understand Product usage and performance. These services may collect:

  • Usage statistics and events
  • Crash reports and error logs
  • Performance metrics

Analytics providers may include Google Analytics, Firebase Analytics, Unity Analytics, and similar services where they are integrated into a particular Product.

5.3 Payment Processors

When you make in-app purchases or subscriptions, payment processing is handled by platform providers (including but not limited to Apple, Google, Valve/Steam, Epic Games, Meta, Sony, Microsoft, Nintendo) or third-party payment processors. We do not collect or store your payment information. Payment data is subject to the privacy policies of the respective platform or payment processor.

5.4 Other Third-Party Services

Depending on the Product and feature, our Products may also integrate with:

  • Cloud storage services (for data backup and sync)
  • Social media platforms (for sharing features)
  • Authentication services (for account management)

We encourage you to review the privacy policies of all third-party services used in our Products.

6. Data Sharing and Disclosure

We do not sell your personal information. We may share data in the following circumstances:

  • Service Providers: With trusted third-party service providers who assist in operating our Products, subject to confidentiality agreements
  • Legal Requirements: When required by law, court order, or government regulation
  • Business Transfers: In connection with a merger, acquisition, or sale of assets, with notice to users
  • Protection of Rights: To protect our rights, property, or safety, or that of our users

7. Data Security

We implement appropriate technical and organizational measures to protect your information against unauthorized access, alteration, disclosure, or destruction. However, no method of transmission over the internet or electronic storage is 100% secure, and we cannot guarantee absolute security.

8. Data Retention

We retain collected information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law. When data is no longer needed, we securely delete or anonymize it.

9. Children's Privacy

Unless a specific Product clearly states otherwise, our Products are not directed to children under the age of 13 (or the applicable age of consent in your jurisdiction). We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately.

If a Product is directed to children or is made available in a way that requires child-specific privacy protections, we will provide any required Product-specific notice and obtain verifiable parental consent where required by law before collecting personal information from children.

10. Your Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding your personal information:

10.1 General Rights

  • Access: Request access to your personal information
  • Correction: Request correction of inaccurate information
  • Deletion: Request deletion of your personal information
  • Portability: Request a copy of your data in a portable format
  • Opt-Out: Opt out of certain data collection practices

10.2 GDPR Rights (European Users)

If you are located in the European Economic Area (EEA), you have additional rights under the General Data Protection Regulation (GDPR):

  • Right to access your personal data
  • Right to rectification of inaccurate data
  • Right to erasure ("right to be forgotten")
  • Right to restrict processing
  • Right to data portability
  • Right to object to processing
  • Right to withdraw consent
  • Right to lodge a complaint with a supervisory authority

10.3 CCPA Rights (California Users)

If you are a California resident, you may have rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (CCPA):

  • Right to know what personal information is collected
  • Right to know if personal information is sold, shared, or disclosed
  • Right to opt out of the sale or sharing of personal information, including certain cross-context behavioral advertising where applicable
  • Right to access your personal information
  • Right to request deletion of personal information
  • Right to request correction of inaccurate personal information
  • Right to limit the use and disclosure of sensitive personal information where applicable
  • Right to non-discrimination for exercising your rights

10.4 Mainland China Privacy Rights

If you are located in mainland China, you may have rights under applicable personal information protection laws, including the right to know, decide on, restrict, or refuse certain processing of your personal information; access, copy, correct, supplement, or delete your personal information; withdraw consent where processing is based on consent; request account cancellation where applicable; and request an explanation of our personal information processing rules.

We act as the personal information handler for the personal information we process. This Privacy Policy describes our contact details, processing purposes and methods, categories of personal information, retention approach, sharing or entrusted processing, cross-border transfer circumstances where applicable, and how you may exercise your rights.

10.5 Exercising Your Rights

To exercise any of these rights, please contact us at contact@ningdom.com. We will respond to your request within the timeframes required by applicable law.

11. Platform-Specific Privacy

Our Products are distributed through various distribution platforms, each with their own privacy policies and data practices. These platforms include but are not limited to:

  • Apple App Store: Subject to Apple's Privacy Policy and App Store Review Guidelines
  • Google Play: Subject to Google Play's Privacy Policy and Developer Policy
  • Steam: Subject to Steam's Privacy Policy and Steam Subscriber Agreement
  • Epic Games Store: Subject to Epic Games' Privacy Policy and Terms of Service
  • Meta Quest Store: Subject to Meta's Privacy Policy and Platform Terms
  • PlayStation Store: Subject to Sony's Privacy Policy and Terms of Service
  • Xbox Store: Subject to Microsoft's Privacy Policy and Terms of Service
  • Nintendo eShop: Subject to Nintendo's Privacy Policy and Terms of Use
  • Other Distribution Platforms: Subject to respective platform policies

Please review the privacy policies of the platforms through which you access our Products.

12. International Data Transfers

Where applicable, your information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that differ from those in your country. When required, we take appropriate safeguards to ensure your information receives adequate protection, including:

  • Using standard contractual clauses approved by data protection authorities
  • Relying on adequacy decisions by relevant authorities
  • Implementing appropriate technical and organizational safeguards

13. Cookies and Tracking Technologies

Our Products may use cookies, web beacons, and similar tracking technologies to collect information. You can control cookies through your device or browser settings, though this may affect Product functionality.

14. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable laws. We will notify you of material changes by:

  • Posting the updated Privacy Policy on our website
  • Providing notice within our Products
  • Sending an email notification (if we have your email address)

Your continued use of our Products after such changes constitutes acceptance of the updated Privacy Policy.

15. Do Not Track Signals

Some browsers and devices support "Do Not Track" (DNT) signals. We currently do not respond to DNT signals, as there is no industry standard for how to respond to such signals. We continue to monitor developments in this area.

16. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Email: contact@ningdom.com

We will make every effort to respond to your inquiry in a timely manner.

17. Data Protection Contact

For users in the European Economic Area or other regions with specific privacy contact requirements, if you have questions or concerns about our data processing activities, you may contact our privacy contact at contact@ningdom.com. If a Data Protection Officer or representative is legally required for a specific Product or processing activity, we will provide the relevant contact information where required.