Privacy Policy

Last updated: 2022/09/30

The Data Controller under this Privacy Policy is BILIBILI HK LIMITED (“bilibili”, “we”, “our”, or “us”) .

We greatly recognizes and values the privacy of people (“you” or “User”).,who visit our websites, use or access our games, whether played on mobile devices, PCs, our websites or other approved platforms (“bilibili Game(s)”), and/or otherwise use or access any of our provided services (“bilibili Services” or “our services”).

The Policy describes why and how we collect, store, and use your personal data, and the choices and rights you have about the personal data you provide or we collect in connection with the Game. By accessing our websites or otherwise using the Game, you acknowledge that you have read, understood and accepted the following terms. In the case you do not agree to any of the terms, some basic functions in the Game may not be able to run normally, which may prevent you from using them.

bilibili may periodically amend the Policy. We will announce to you by revising the date at the top of this Privacy Policy and obtain your consent (and/or the consent of your parent/guardian, if applicable) again if we make any material changes to the Policy.. You acknowledge and agree to check the updated terms regularly. If you do not agree to the processing of your personal data in the way that this Policy describes, please do not provide your information (when we request) and stop using our Services.

1. What Data We Collect and Process

           We collect or receive Data in three ways:

• you directly provide Data to us, such as by creating an account by email .
• we collect Data on an ongoing basis, such as through cookies and related technologies.
• we receive Data from third party with your consent, such as social media platforms. 

       A. Data You Directly Provide to Us

1. Data of Account:  including email address, password (if you choose to use our services by email) username, nickname and profile picture. We collect such information on the legal basis of performing our contract with you to provide our services , and use this information to create the account for your usage of our services as you request, and enable you to enjoy certain game feature.
2. Customer Support Information. We use AIHelp customer supporting system to provide the customer service. We will collect your purchase information (including purchase time, product, currency, cost) , device information , user ID, your chat data or game data regarding to customer service with it. We use such information to help identify your account to enable us to troubleshoot problems with your account or games, communicate with you and respond to your specific requests or questions. It is necessary for our performance of a contract with you.
3. The Other data you provide to us
   • When you participate in online discussions or otherwise interact with us;
   • When you voluntarily complete a customer survey or provide feedback / requests on any of our message boards or via email;
   • When you choose to share the live video content in game, we will collect the same.
   • If you get the prize(s) for participating in our game-based events, we may collect your name, ID number or passport ID, delivery address, postal code, telephone number, in-game account ID and zone ID, to deliver the physical prize(s) to you, we may collect your email address to send the digital prize(s) to you. We collect such data with your consent.

        B. Data We Collect on an ongoing Basis

We may also collect Data and other information through technologies, from you when you use our services. We use these  information for purposes such as modifying or improving features, managing advertising, addressing technical issues, preventing fraud, and conducting data analytics and it is necessary for provision of services. The type of information that we collect includes:

1. Guest log in information. A new OpenID will be generated every time you log into our services as a “guest”. It is necessary to perform our contract with you to provide our services.
2. Internet Protocol (IP) address. We will collect it to determine the country or religions you are in and lock the Services region to that, to allow you to connect to the services and we may use your IP address to help to solve disputes concerning your account. The legal basis is legitimate interests pursued by us.
3. Transaction information. Our services enable in-app purchases and we collect your purchase or transaction record. However, we do not process payments for in-app purchases nor have access to your credit card information. Payment transactions for in-app purchases are mostly completed through the app store via your App Store account or Google Play account, or platforms such as Sony Play Station, or through the payment method you choose . Any post-purchase processes are controlled by the payment providers. If you make any payments in using services, we will collect transaction information of payment platform, such as Google Play or iOS App Store ( including purchase time, order number, in-game product purchased, cost.) We also collect Purchase history in-game, (including order number, User ID, purchase method, purchase amount, currency, product ID, purchase quantity, order creation time, purchase time, transaction completion time, username, role ID, role name, game server ID, game server name, SDK version number, application store version number, client IP, device Id, IDFA, device model, network operator,, network type, system version number, root or jailbreak, resolution, platform, language, excluding financial information) .
4. Data of Use of the Service.

• Gameplay data : including game setting, level, heroes, scores, open ID、Game ID、operating system, region ID\game server ID, region ID, player nickname, character ID, character level, player balance, account status, account binding status, registration time, latest login time, player type.
• Game behavior data: including your match information in Games, your online time, click record (battle record, mall record, activity record, social category), your in-game interactions( such as friends list).
• Game log information and game statistics: including character ID, game account, user nickname, country code, device system version, device brand, IDFV, device model, device manufacturer, device name, screen resolution, screen orientation, CPU model, GPU information, RAM, client exported IP, phone memory, login channel ID, operator name, network type, signal strength.
• We collect such information for the purpose of analyzing the usage of Game feature, optimize and improve experience, recording your game behavior and providing the Services and provide troubleshooting such as addressing and remediating technical issues and bugs. We process such data on the legal basis of Service Provision.
• Device data: When you use our services on a mobile platform, we may collect your device data (including application version, unique device identifier, advertisement identifier, system language, device name and model, the version of your operating system, system and its version number, MAC address) every time you log in to the Services or make an in-game purchase or use customer service for the purpose of ensuring game security and verification , identify and address bugs and assess function for optimization, and monitor the success of our advertising and marketing programs (if any). It is necessary for us to provide the Services and to ensure the security.
• Security-Related Information: We will collect Security-Related Information (including your SDK log data, server IP, Open ID, system information (system version, brand, CPU architecture , country language) , root status, application version, device information (including device type, IDFA, network type, brand, language region), jailbreak status (iOS) for security purposes in order to detect offensive and sensitive wording to provide a fair and secure online environment. it is our legitimate interest to ensure the security of our services. You know and understand that since there are multiple versions of the game, the above information is collected for the purpose of adapting, developing and updating for devices of different versions.
• Advertising Information. Advertising ID and select device information (such as device ID, device name, device type, system and version, MAC address, IDFA) , registration time and login time. We store the Advertising ID for that advertisement and device information with your profile to track the success of our advertising and ensure security of our services on the legal basis that it is our legitimate interest to ensure service security and manage registrations.

       C. Data We Collect from the Third-party

• Connected Social Media Account Information. Most of our services support you to log in with your social media account(e.g. Google, Apple). We may collect personal information you authorized the third-party social media to share with us to pre-populate our sign up form. We will collect your information as follow:

Google: We will collect your authorization ID, nickname, profile picture(if any), email address, location, and whether the email address is authenticated from Google, only the authorization ID, nickname, profile picture(if any) will be saved。

Apple：We will collect your authorization ID, email address, whether the email address is authenticated, whether it is a private email, current timestamp, and expiration timestamp，only the authorization ID will be saved.

We use such data to enable you to link, connect, or login to your account with a third-party service. We process such data on the legal basis of Service Provision.

Exactly what information we receive from your social media will depend on your social media privacy settings. You should always review, and if necessary, adjust your privacy settings on the Third-Party Social Networks before linking or connecting them to our Service.

• Other information from third party sources. From time to time, we may receive personal information about you from third party sources. For example, if you click on an advertisement to direct you to one of our services or Games (such as an advert of one of our Games in other publisher’s game), we may receive the information that allows us to know which ad network and advertising campaign your installation was originated from.

2. Why We Collect and Process Your Personal Data

A. We collect, use, store, and process your personal data based on:

• The principle of lawfulness, fairness and transparency;
• Your consent that we may take from you time to time;
• Specified, explicit and legitimate purposes;
• The extent that is adequate, relevant and limited to what is necessary in relation to the purposes;
• The manner that ensures appropriate security of the personal data;
• Performing the obligations under Terms of Use and providing our Services;
• Your and our legitimate interests;
• Other legal reasons including if required under any law or required by governmental and regulatory bodies.

B. we collect and process your personal data to:

• allow you to access or restrict your access to our services;
• analyze and manage our services for system administration, user service, security, fraud-detection, checking the authenticity of an account owner, archival and/or backup purposes
• correct bugs or errors, improve our services and respond to customer desires and preferences, including language and location customization, personalized support and instructions, and other responses;
• develop new services or products that user(s) request and improve the user experience;
• verify and confirm payment;
• deliver advertising that may be relevant to your interests (you can choose to turn this feature on or off in the device settings as stated hereunder);
• communicate with other users and take action against violations;
• personalize your experience, keep you up to date with the latest product announcements, provide software verification, upgrades and administration, notify of special events, offer to participate in our surveys or activities, and provide other information pertaining to our services;
• protect the integrity, safety, and security of our services or users, comply with legal obligations, and enforce compliance with the Terms of Service or other restrictions placed on your use of our services;
• track your process across our websites and applications to verify that you are not a bot and to optimize our services.
• investigate claims and/or legal actions, violations of our policies and procedures, and compliance with relevant applicable laws and legal process;
• comply with applicable laws, regulations, or legal process as well as industry standards and our company policies; or
• prevent, investigate, identify, or take any other action with regard to suspected or actual fraudulent or illegal activity, or any activity that violates our policies.

3. Advertisements and Your Choices

For the purpose of providing personalized advertisements（if any）, you acknowledge and agree that based on your consent we may collect and process the data to:

(1)  deliver, target and improve our advertising; and/or

(2)  improve advertising and other marketing and promotional activities.

We may also use the data you provide to send you, or have our authorized contractors to deliver advertisements, market research or surveys.

Pertaining to the marketing or promotional communications, you may opt-out of

receiving such communications in accordance with the instructions therein, such as email, online communication channels, or other contact methods provided by us. For example, you may opt-out of the out-of-game push notifications on mobile applications by checking the settings and turning off the “allow notifications” (iOS/Android).

 Without your consent, we ensure that we will not use your data for marketing purposes, and after granting permission, you may also withdraw such consent at any time while without impact on the validity and lawfulness of data usage prior to such withdrawal. For the avoidance of doubt, if we know that you are a registered user under the age of majority in your jurisdiction, we will not target you with advertising.

4. Sharing Your Personal Data

A. We do not share personal data that directly identifies you (such as your name, e-mail) with independent third parties unless:

• your prior authorization or consent is obtained;
• if we are required to do so by law, legal process, or a reasonable request from law enforcement authorities or other government officials;
• when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity; or
• if necessary, to protect the vital interests of us and any of its users (such as to prevent death, bodily harm, or serious damage to property), public security and public interests; or
• if we sell part or all of our assets to the third parties, we may share your Data with the buyer. In the event of this circumstance, the buyer will comply with this privacy policy, the related laws and regulations.

B. We may share anonymous or aggregated data, or other data that does not directly identify you with other parties. You acknowledge that you have foreseen and agreed to the occurrence of such disclosure when you provide your personal data.

• Other In-Game Users. We support and often encourage you to interact with other players. In most games, other players will see your name, player profile, in-game activities and read messages you have posted depending on the setting adopted by you. Any data you post to any communication area is publicly viewable. We strongly recommend that all users avoid posting personal or sensitive data at any time on or through our services.
• Competent Authorities. We may provide a certain portion of your personal data to judicial or administrative authorities as so requested. Besides, we may disclose certain portion of your personal data within a strictly limited scope of recipients when we reasonably think it is necessary to protect us, our users or a portion of the public.
• Related group companies of us. We may share your information with our related entities, including our parent and sister companies. For example, we may share your information with our affiliates for customer support, marketing, or technical operations. Where we share your personal information with our affiliates, they handle your personal information in accordance with this Policy.
• A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.
• Providers of analytics services. They process information identified in this Privacy Policy on their servers for the purposes of assisting us with acquiring users for the Game and analytics purposes to improve your gameplay. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.

• logistics service providers. We may share your personal data such as your address, phone number with logistics service providers who provide shipping services such as delivering physical prizes to users.
• Other third-party service providers.

1. 1. Social networking portals who provide login and/or content-sharing service to and in our services;
   2. Payment service providers who provide payment services, such as assisting our services to run on, facilitating users’ payment, and maintaining a record of the users’ transaction history;
   3. AIhelp service provider. We will share your device information , your chat data or game data regarding to customer service with it.
   4. Our cloud service providers
   5. Other contractors if any for the purpose of providing our services to you.

Since those contractors may access, collect, or process your data as the data controller and operate under their own privacy policies, please refer directly to their privacy policies on their official websites and learn more about their data processing practices.

5. Cookies or Similar Technologies

By using the Service you agree that we may automatically collect certain information through the use of “ cookies” or other similar tracking technologies to analyze trends and administer the Service.

Many browsers enable you to control the use of cookies at the individual browser level. Cookies are small data files that are stored on a user’s hard drive at the request of a Website or the Service to enable the Website or the Service to recognize users who have previously visited them and retain certain information such as customer preferences and history. If we combine cookies with or link them to any personally identifying information, we would treat this information as personal information. If you wish to block, erase, or be warned of cookies, please refer to your browser or mobile device’s instructions or help screen to learn about these functions. You may not be able to delete or disable cookies on certain mobile devices and/or certain browsers.

Remember, if a browser or mobile device is set not to accept cookies or if a user rejects a cookie, some portions of the Website or Service may not function properly. For example, you may not be able to sign in and may not be able to access certain Website or Service features or services.

6. International data transfers

Our corporate group operates around the world. Pursuant to our contract with you to allow you to participate in our Games, your personal information may be transferred to, and processed in, countries other than the country in which you are resident, and can be accessed by our support, engineering and/or our affiliates around the world (including but not limited to Singapore, Korea, Japan). These countries may have data protection laws that are different from the laws of your country. We have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Policy. Internally, we also require these affiliates of bilibili group and our services providers or business partners to protect your personal information when processing your personal information to provide Services to you.

7. Data Retention

We will only store your personal information for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the information was collected, or as may be required or permitted under applicable law. Upon the expiration of such period, your personal data will be deleted, blocked or anonymized, as provided by applicable law.

In the case you request to remove or delete your personal data, we will assess whether such data is necessary for our legitimate business interests, such as to comply with our legal obligations, resolve disputes, and/or enforce the agreements between you and us. If so, we will retain your data until it is not necessary. Please note that the removal or deletion of any of your data may result in the termination of some of our applicable services.

8. Your Rights

You may exercise any of the rights described in this section by using any functionality available while using our services and/or sending an email to starseed_help@bilibili.com. We will respond within 30 days though this may be extended by a further two months in certain circumstances. Please note that we may ask you to verify your identity before taking further action on your request.

• Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to access your personal data that we hold about you. In some jurisdictions, applicable law may entitle you to request copies of your Data held by us. You may also be entitled to request copies of Data that you have provided to us in a structured, commonly used, and machine-readable format, should you have such requirement, please contact us. According to our reasonable and unilateral judgement, if your verifiable request affects or will affect the rights or freedom of other users or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs arising therefrom) or refuse to act on the request.

• Right to Rectify

If we process your personal data, we shall endeavor to ensure by implementing suitable measures that your personal data is accurate and up-to-date for the purposes for which it was collected. If your personal data is inaccurate or incomplete, you have the right to obtain rectification of your inaccurate personal data without undue delay.

• Right to Request Deletion of Personal Information

You have the right to obtain deletion of your personal data, if the reason as stated in Article 2 of this Privacy Policy does not exist anymore, or if there is another legal ground for its deletion, subject to submitting a verifiable request in the form of sending an email.

We provide you with the service of account cancellation. You can delete your account by clicking 【Settings】-【User Center】-【Delete your account】in most of our Games or you can contact us to exercise your right. Please read the instructions of the cancellation page carefully. Should you choose to cancel the Game account, we will delete or anonymize all relevant personal data generated by you in the Game in a timely manner in accordance with relevant laws and regulations, unless otherwise required by laws and regulations.

We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defense of legal claims or freedom of expression) but we will let you know if that is the case.

• Right to withdraw consent

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service. Should you withdraw your consent or authorization, we may no longer continue to provide you with the services related to the withdrawal of the consent or authorization, and will no longer process your related personal data. However, your decision to withdraw your consent or authorization will not affect the processing of personal data previously carried out based on your authorization.

• Right to Object

When our processing of your personal data is based on legitimate interests according to Article 6(1)(f) of the GDPR or any other applicable laws in your country of residence, you have the right to object to our processing. If you object, we will no longer process your personal data unless there are compelling and prevailing legitimate grounds of processing as described in Article 21 of the GDPR or any other applicable laws in your country of residence; in particular, if the data is necessary for the establishment, exercise or defense of legal claims. You also have the right to lodge a complaint at a supervisory authority.

Where your personal information is processed for direct marketing purposes, you may, at any time ask us to cease processing your data for these direct marketing purposes

• Right to Restrict Processing

You have the right to restrict the processing of your personal data under the conditions set out in Article 18 of the GDPR or any other applicable laws in your country of residence. in particular where:

you contest the accuracy of your Data;

the processing is unlawful and you oppose the erasure of your Data;

we no longer need your Data for the purposes of the processing, but you require the Data for the establishment, exercise or defense of legal claims; or

Should you have any above requirements, please contact us

• Right to complain to a data protection authority.

If you think we have infringed data protection laws, you can lodge a complaint with or report to a supervisory authority within your jurisdiction, or file a lawsuit to a judicial authority within your jurisdiction.

9. Securing Your Data

Security of our users' Data is a priority at us, and we are continuously implementing and updating administrative, technical, and physical security measures such as access control, compressed encryption to help protect your Data against unauthorized access, loss, destruction, or alteration.

Unfortunately, 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.

We strongly urge you to take every possible precaution to protect your personal data when using our services, including but not limited to changing your passwords from time to time, not reflecting your real name or other personal data in registration, using a combination of letters and numbers when creating passwords, using a secure browser and/or taking other possible security measures.

If we learn of a security systems breach, we may attempt to notify you electronically so that you can take appropriate protective steps. If there is a security breach occurs, we may also post a notice on the Website. We will send an emergency report to authorities in case that the security breach is serious and assist authorities to take steps to prevent further harm.

10. Age Limits and Children Protection

You represent that you are at least the age of majority in your jurisdiction when using our services. If you are under the age of majority in your jurisdiction,, you shall not play our Game without the consents of your parent or guardian.

We do not and will not knowingly collect personal data from children without consent from their parents or guardians. We strongly urge parents and guardians to instruct their children never to disclose or give out their personal data when using our services without the prior permission of their parent/guardian. If we learn that we have collected personal data about a child, we will delete that data as quickly as possible. Also, if you believe that we might have any data from or about a child, please contact us.

11. Contact and Complaints

If you have any questions about this Privacy Policy or have any requests for resolving issues with your personal data while using our services, please contact us as soon as possible by emailing our Data Protection Office at starseed_help@bilibili.com.

                                                               BILIBILI HK Limited

SUPPLEMENTAL JURISDICTION-SPECIFIC TERMS

Some jurisdictions’ laws contain additional terms for users of the Game Services, which are set out in this section.

If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our privacy policy above.

Indonesia

Consent

By accepting and consenting to this privacy policy, you agree that we may collect, use and share your personal information in accordance with this privacy policy, as revised from time to time. If you do not agree to this privacy policy, you must not access or use our services and we have the right to not provide you with access to our services.

Parental and Guardian Consent

If you are under the age of 21, you undertake that you have the consent of your parent or legal guardian to register an account on the Game and use the Game Services.

Data Subject Rights

You have the right to access your personal information stored in our Game from time to time in accordance with applicable data privacy laws and regulations in Indonesia.

Data Breach

In the event we fail to maintain the confidentiality of your personal information in the Game, we will notify you through the contact information provided by you or via the Game, to the extent required by local laws and regulations.

Notification to Amendment of this Privacy Policy

If you fail to explicitly express your objection to any amended version of this privacy policy within fourteen (14) days of the date the relevant amended version of this privacy policy is made available , you will be considered as having accepted the changes and agreed to the new privacy policy. However, you may stop using or accessing our Service by unsubscribing or ceasing your use of the Game Services at any time, if you cease to agree with the amended privacy policy.

Data Accuracy and Third Party Consent

You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

Malaysia

Parental and Guardian Consent

If you are under the age of 18, please do not use our services except where your parent or guardian has provided consent

In the event you are agreeing to this privacy policy in order for a minor to access and use the Game Services, you hereby consent to the provision of personal information of the minor to be processed in accordance with this privacy policy and you personally accept and agree to be bound by the terms in this privacy policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor’s compliance with this privacy policy.

Your Rights

Right of access: You have the right to request access to and obtain a copy of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law.

When handling a data access request, we are permitted to request for certain information to verify the identity of the requestor to ensure that he/she is the person legally entitled to make the data access request.

Right of correction: You may request for the correction of your personal information. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requestor to ensure that he/she is the person legally entitled to make the data correction request.

Right to limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details provided above. However this may affect our provision of the Game Services to you.

Singapore

By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, the People’s Republic of China and Japan.

Thailand

By accepting this privacy policy, you acknowledge that you have read, understood, and agree to this privacy policy. If you do not agree with this privacy policy, you must not use our services.

If you are under the age of 20, please do not use our services except where your parent or guardian has provided consent