Privacy Policy

DATE: Oct 29, 2025

This Privacy Policy explains how ThanhLe Van (hereinafter referred to as "we") collects and processes your personal data when you use our mobile game Rookie Legend on the iOS platform. We collect and process your relevant information solely to provide you with high-quality game products and the best possible user experience.

1. How We Collect Your Personal Data

We acquire, utilize, and process your personal data through various means, and are committed to protecting the security of your personal data in all cases. The following details the categories of personal data we collect and how we process them.

1.1 Categories of Personal Data

When you access or use Rookie Legend, we may collect the following general information about you:

1.2 Other Data Sources

If you log in to the game via third-party platforms such as Apple Game Center, we will obtain relevant information about you from that platform (including display name and profile information) in accordance with the authorization procedures specified by the platform, provided that you have agreed to the relevant authorizations of the third-party platform.

You can learn about how third-party platforms process your personal data by reviewing their privacy policies:

Apple Game Center: https://www.apple.com/legal/internet-services/itunes/gamecenter/

If you log in to the game via a third-party platform, you represent and warrant that:

2. How We Use the Collected Information

We use your information for the following purposes, and the use of each type of personal data complies with the corresponding legal basis:

The legal basis for the above data processing is Article 6(1)(b) of the General Data Protection Regulation (GDPR) (also known as the "balancing of interests principle"). This processing is necessary for performing the contract you are part of, supporting game operations, providing the products and services you request, and ensuring the maintenance and update of the game.

The legal basis for the above data processing is Article 6(1)(f) of the GDPR. We conduct such data processing based on our legitimate interest in providing you with advertisements and content that interest you and improving service quality.

3. Data Retention Period

We will retain your information for the period necessary to provide you with game services, fulfill legal obligations, and/or exercise, defend, or establish our rights. To resolve disputes, enforce our terms and policies, manage game services, comply with technical and legal requirements, or due to constraints related to service security, integrity, and operation, we may retain part of your personal information in our files for a reasonable period.

We also retain Usage Data for internal analysis purposes. Generally, Usage Data is retained for a relatively short period, except in the following cases: the data is used to enhance service security, improve service functionality, or laws require us to extend the retention period.

4. How Information Is Shared

Subject to your legal rights, in accordance with Article 6(1)(b), 6(1)(c), and 6(1)(f) of the GDPR, we may disclose or allow you to share the information we collect about you with various third parties in the following ways:

4.1 Sharing with Ad Network Partners

When you agree to share information in accordance with the relevant provisions of Article 6(1) of the GDPR, we will share your device identification information with ad network companies to help provide you with personalized advertisements. The ad networks we currently use or may use are as follows:

The use of the disclosed information by third-party recipients is not governed by this Privacy Policy. If you have questions about the data processing practices of such third parties, please review their privacy policies.

4.2 Cooperation with Data Processors

In the process of data processing, we cooperate with the following data processors, including server hosting providers, technical service providers supporting internal operations, user login service providers, and analytics service providers:

5. Protection of Children's Information

Rookie Legend is not directed at individuals under the age of 13. We do not knowingly collect personally identifiable information from children under the age of 13. If we discover that we have collected personal information from a child under the age of 13, we will immediately delete such information from our servers. If you are a parent or guardian and are aware that your child has provided us with personal information, please contact us to take the necessary measures.

6. Information Security Measures

We value your trust in us and strive to protect the personal information you provide using commercially acceptable methods. However, please note that no method of transmission over the Internet or electronic storage is 100% secure and reliable, and we cannot guarantee the absolute security of information.

7. Push Notification Services

If you have agreed to receive push notifications, we will send game-related information, service updates, promotional content, and other relevant messages to your iOS device. You can disable such push notifications by adjusting the notification settings on your device.

8. Your Rights

8.1 Rights of Residents in the European Economic Area (EEA)

We will process and respond to your requests in a timely manner, and will respond no later than one month after receiving your request; if the processing time needs to be extended due to the complexity of the request, in accordance with Article 12 of the GDPR, the maximum extension period is three months, and we will inform you of the reason for the extension and the extended period at that time.

(1) Right to Request Access

Pursuant to Article 15 of the GDPR, you have the right to request access to the data we are processing about you, including the following information:

In addition, you have the right to obtain a copy of the personal data being processed. Please note that your access rights may be restricted based on the protection of intellectual property or trade secrets.

(2) Right to Object

Pursuant to Article 21 of the GDPR, when we process your personal data based on the "balancing of interests principle" under Article 6(1)(f) of the GDPR, you have the right to object to such data processing based on your specific circumstances. In such cases, we will cease the relevant data processing unless we have legitimate grounds that outweigh your interests, rights, and freedoms, or the data processing is necessary for the establishment, exercise, or defense of legal claims.

You have the right to object at any time to our use of your personal data for direct marketing purposes. After you raise an objection, we will cease processing your personal data for this purpose.

(3) Right to Rectification

Pursuant to Article 16 of the GDPR, you have the right to request the rectification of inaccurate personal data.

(4) Right to Restrict Processing

Pursuant to Article 18 of the GDPR, in certain circumstances, you have the right to request the restriction of data processing. If you have this right, we will only process your data with your consent, for the establishment/exercise/defense of legal claims, to protect the interests of others, or based on important grounds of public interest.

(5) Right to Withdraw Consent

Pursuant to Article 7 of the GDPR, if our data processing is based on your consent, you have the right to withdraw such consent at any time.

After you withdraw your consent, we will cease processing the data related to the consent you withdrew, unless the law requires us to retain part of the data.

Your withdrawal of consent does not affect the legality of the data processing conducted based on your consent prior to the withdrawal.

(6) Right to Data Portability

Pursuant to Article 20 of the GDPR, if data processing is based on your consent or the performance of a contract, you have the right to request us to provide the personal data you have provided to us (which we are processing) in a structured, commonly used, and machine-readable format, and have the right to transmit such data to another data controller.

8.2 Rights of Residents of California

(1) Request Response Period

We will make every effort to respond to a verifiable consumer request within 45 days of receipt; if the processing time needs to be extended (up to a maximum of 90 days), we will inform you of the reason for the extension and the extended period in writing, and deliver the written response to you by mail.

(2) Scope of Disclosed Information

Any information disclosure we provide will only cover the data within 12 months prior to the receipt of the verifiable consumer request. If we are unable to fulfill your request, we will also explain the reason in the response. For data portability requests, we will select a format that is convenient for you to use to provide personal data, ensuring that you can transmit the information from one entity to another without obstacles.

(3) Right to Opt-Out

Pursuant to the California Consumer Privacy Act (CCPA), each resident of California has the right to request any business to stop selling their personal information to third parties.

(4) Right to Know

You have the right to know the categories of personal data we collect and the purposes of collection, and relevant information can be accessed at any time in this Privacy Policy. We will update this Privacy Policy at least once every 12 months.

(5) Right to Request Disclosure

You have the right to request us to disclose the personal data collected about you within the past 12 months.

You can find information about the categories of personal data we collected about you within the past 12 months and plan to collect in the future, data sources, and usage methods in this Privacy Policy.

You have the right to obtain a free copy of your personal information (i.e., the right of access), and you can make such a request for free twice a year.

When providing information pursuant to the right of access, we will provide you with the following content: the categories of personal data we collect about you, the categories of data sources, the purposes of data collection, the categories of third parties with whom we share data, and the specific personal data collected about you.

(6) Right to Request Deletion

You have the right to request us to delete the personal data collected about you within the past 12 months.

We fully recognize your right to deletion, but it should be noted that in some cases, we are required by law to retain your personal data, such as to provide you with services, detect or resolve security and functional issues, comply with legal regulations, conduct public interest research, protect freedom of speech, or perform internal operations that you can reasonably expect. If there are no circumstances requiring data retention as mentioned above, we will delete your personal information in accordance with your request.

9. Data Deletion Request

When your personal data is no longer necessary for us to retain, you may request us to delete such data immediately. If you need to delete data, you can contact us by sending a request to the email address [email protected].

10. Contact Us

If you have any questions about this Privacy Policy, please contact us via the following method:

Contact Email: [email protected]

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