Privacy Policy for SyFu

Welcome to SyFu. Unlock Lab Limited (hereinafter referred to as “Company”, “we”, “us”, or “our"), as the operator of SyFu, recognizes the importance of protecting personal information and has established and complies with this privacy policy ("Privacy Policy") to ensure that users can use the Company's site and services with confidence through appropriate use and management. The Company is a company created under the laws of the British Virgin Islands ("BVI").

This Privacy Policy details how we collect, use, and protect your data in accordance with the BVI Data Protection Act (as amended) (the "Data Protection Act") and the Hong Kong Personal Data (Privacy) Ordinance (the "PDPO") when you use our Web3-based services, which may include game wallet systems where users enter payment data in exchange for loyalty tokens or NFTs, either directly or through third parties. This section details how we collect, use and protect your data when you use our Web3-based services, which may include a game wallet system where you enter payment data directly or through a third party. By using our services, you consent to the practices described in this Privacy Policy.

Your personal information will be processed by the Company, and by persons engaged by the Company. Under the Data Protection Act, you have rights, and the Company has obligations, with respect to your personal data. The purpose of this notice is to explain how and why the Company, and persons engaged by the Company, will use, store, share and otherwise process your personal data. This notice also sets out your rights under the Data Protection Act and the PDPO, and how you may exercise them.

If you are an individual customer, this will affect you directly. If you have any questions that are not answered within the policy, please refer to the end of this Privacy Policy for information on how to contact us.




１. Personal Information We Collect

By virtue of being a customer of the Company and by using of SyFu or by virtue of you otherwise providing us with personal information on individuals connected with you as a customer, you will provide us with certain personal information which constitutes personal data within the meaning of the Data Protection Act and the PDPO.

The personal information that we collect depends on your interaction with us and our services including the choices you make and features you use within the service. You may choose not to provide some types of personal information when using our services. Please note, however, that some of our services require certain personal information to operate, so if you choose not to provide the personal information that is necessary in order for us to provide you with a particular service or feature of that service, you may not be able to use that service or feature. We collect various types of personal information to enhance our services:

１.１ Personal Information which we collect from you directly:

Identification Information: We may collect your name, username, birthday, gender, email address, personal photo and contact details including phone numbers and address.
Financial Information: If you participate in our game-wallet system, we may collect payment information, which could include payment methods (including credit/debit/prepaid cards, QR code payment and other electronic payment method), transaction details, bank account information, cryptocurrency wallet addresses, and other relevant financial data.
Social Media Information: We may collect your social media account information including account IDs.

We may also obtain personal data on you from other publicly accessible directories and sources. These may include websites; bankruptcy registers; tax authorities; governmental agencies and departments, and regulatory authorities, to whom we have regulatory obligations; credit reference agencies; sanctions screening databases; and fraud prevention and detection agencies and organisations, including law enforcement.

Personal Information which we collect from you indirectly:

１.２ Identity Verification:

To ensure compliance with applicable regulations, we may collect documents and information to verify your identity and eligibility to use our services.

１.３ Usage of Personal Information:

Device and Browser Information: We collect information about the devices and browsers you use to access our services, including your IP address, device type, browser type, and operating system.
Website and Application Usage Data: We gather data related to your interactions with our platform, such as the pages visited, actions taken, geo-location data and session duration.

１.４ Transaction Information:

If you participate in our game-wallet system, we collect data related to your transactions, including transaction amounts, timestamps, merchant information, payment method and types.

１.５ Third-Party Information:

If you choose to use third-party payment processors to provide payment data, we may collect data from these third parties, in accordance with this Privacy Policy and where applicable, their privacy policies.

To do this we may use cookies (pieces of data sent by a website to your computer and stored on its hard drive). See the section 10 on Cookies below for more information about how we use cookies.

２. How We Use Your Personal Information

We will only use your personal information when we have a legal basis for doing so. We only collect personal information for a lawful purpose directly related to a function or activity of the Company, and the collection of the personal information is necessary for or directly related to that purpose. Our collection of personal information is adequate but not excessive in relation to that purpose.

Your personal information may be used partially or fully for the following:

２.１ Service Provision:

To provide, maintain, and improve our services, including the game-wallet system, digital assets distribution, and web3-based features.
To verify your identity and eligibility to use our services.

２.２ Communication:

To send important updates, notifications, and account-related information.
To respond to your inquiries and requests.

２.３ Marketing:

We intend to use your personal information for direct marketing. We may not so use your personal information unless we have received your consent. We shall use your name, your residential address, your mobile phone number, your residential phone number, your email address for marketing our services. Your personal data will be used for marketing our SyFu services. Please tick the box provided to indicate your consent.

To send promotional materials and offers if you have provided your consent as described above. You can withdraw your consent and opt out of marketing communications at any time.

２.４ Legal and Regulatory Compliance:

To comply with legal and regulatory obligations, including tax and anti-money laundering regulations which will cover applicable due diligence checks and sanctions screening.
To carry out audit checks and instruct auditors.
To maintain statutory registers.
To prevent and detect fraud.
To facilitate the continuation or termination of the contractual relationship with you.
To facilitate the transfer of funds, and administering and facilitating any other transaction with you.
To respond to legal and regulatory requests and protect our rights and interests.

２.５ Research and Analytics:

To analyze user behavior and preferences to enhance our services.
To develop new features and conduct research and data analysis.

３. Use of your Location Data

SyFu requires the use of location data for some service features (such as location based "check-in" features) that benefit the user. Users can update or change their permissions for location data collection at any time through their device settings. Location data collection settings will vary by device, but most devices allow options to the followings:
(1) Never share location data
(2) Only share location data when permission is given when the app opens
(3) Only share location data while using the service
(4) Always share location data while using the service
We encourage users to review their settings and choose the options that are best for them.

４. Sharing Your Personal Information

We may share your personal information in the following ways:

４.１ Third-Party Service Providers:

We may share your personal information with third party service providers that provide services for us or on our behalf for business purposes including but not limited to data hosting and storage service providers, cloud computing services, data analytics services, marketing services, payment processors, IT services. We may also share your personal information with third parties if you have provided consent.

The Company's services providers are generally data processors acting on the instructions of the Company. Additionally, a service provider may use your personal data where this is necessary for compliance with a legal obligation to which it is directly subject (for example, to comply with applicable law in the area of anti-money laundering and counter terrorist financing or where mandated by a court order or regulatory sanction). The service provider, in respect of this specific use of personal data, may be deemed to be acting as a data controller.

Please also note that we may share your personal information with Google Maps Platform APIs (for example, Google Maps API and Google Places API). To learn more about Google's Privacy Policy, please see here: https://policies.google.com/privacy?hl=en-US

４.２ Advertisement Partners:

We may share personal data with advertising partners including but not limited to ad networks, ad-serving companies, social media companies, and affiliates. This data may allow these services to recognize you across different services and provide interest or location based content and advertisements.

４.３ Business Partners:

We may share or transfer your personal information with trusted business partners and consultants, enterprise and business customers, business partners for joint marketing activities or to enhance our service or in connection with any merger, sale, financing, or acquisition of all or a portion of our company. We will obtain your consent when required by applicable laws.

４.４ Government authorities and law enforces:

We may share your personal information to comply with legal and regulatory requirements or in response to legal or regulatory requests from relevant governmental or regulatory authorities.

４.５ Sale or Merger:

In the event of a sale, merger, or acquisition of all or part of our company, your personal information may be transferred to a third party provided that such transfer is necessary and not excessive.

４.６ Affiliates and Delegates:

We may share your personal information with our affiliates and delegates. The Company's affiliates and delegates may process your personal information on the Company's behalf, including with our banks, accountants, auditors and lawyers which may be data controllers in their own right.

５. Retention and Deletion of Personal Information

We will keep your personal information for as long as it is required by us. For example, we may require it for our legitimate business purposes, to perform our contractual obligations, or where law or regulation obliges us to. We will generally retain your personal data throughout the business engagement you are involved in with us. Some personal data will be retained after your relationship with us ends. We expect to delete your personal data (at the latest) once there is no longer any legal or regulatory requirement or legitimate business purpose for retaining your personal data.

６. Your Rights

You have rights regarding your personal information, including the right to:
· Be informed about the purposes for which your personal information are processed.
· Access and obtain a copy of your data.
· Correct inaccuracies in your data.
· Delete your data (subject to legal requirements).
· Object to certain data processing activities.
· Withdraw consent for marketing communications.
To exercise your rights or make data-related inquiries, please contact Legal Director in Keyway Chambers, 3rd Floor, Quastisky Building, Road Town, Tortola, British Virgin Islands or by email at privacy@syfu.io.

７. International Transfer of Personal Information

Your personal information may be transferred, stored, or processed in countries other than your country of residence. Our services are located in BVI. If you are using our services from outside of BVI or in Hong Kong, please understand that your personal information may be transferred, stored, and processed by us or by third parties in BVI or other countries. In such cases, we will process personal data or procure that it be processed in accordance with the requirements of the Data Protection Act and the PDPO.

８. Security

We employ advanced security measures to protect your data, including encryption, access controls, and regular security assessments. However, please be aware that no method of data transmission or storage is entirely secure. You are responsible for maintaining the confidentiality of your account credentials.

９. Cookies

We, and third parties with whom we partner, may use cookies, pixels, web beacons, local storage, advertising identifiers (including identifiers such as Apple's IDFA or Google's Advertising ID) and similar technology ("Cookies") in our mobile application, website, and emails. These Cookies may transmit information about you and your use of our service, including but not limited to your browser type, search preferences, IP address, advertisements shown and advertisement activity, and the time of your use of our Service. These Cookies may be persistent or may be stored only during an individual session using our service.

SyFu uses a variety of cookies for various purposes, included but not limited to the following:

Strictly Necessary Cookies: SyFu uses cookies for some basic functions of the service. This includes settings such as your privacy preferences or login information. Please note some parts of the service may not work if these cookies are blocked or not permitted.

Performance & Analytics Cookies: SyFu uses cookies to track and measure data to help us further understand how users use the service and to help us improve the service. These cookies help us see what features are most used or where users have trouble with the service. For example, SyFu may collect and store information on what pages and features are used, how much time is spent with these pages and features, type of operating system of users, and more. If you do not allow these cookies we will not know when you have used our service and will not be able to monitor it for improvement.

Functional Cookies: SyFu uses cookies to provide enhanced functionality and personalization. Please note some parts of the service may not work if these cookies are blocked or not permitted.

Targeting Cookies: SyFu uses cookies to build a profile of your interests and show you or other users relevant advertisements on other sites and services. SyFu may work with other outside advertising companies to display ads based on location or interests. These cookies may allow you to be identified across multiple services and websites.

Social Media Cookies: SyFu may use cookies from social media services to allow users to easily link their social media accounts or share content with their friends in these other services. These cookies may allow you to be identified across multiple services and websites. Please note some parts of the service, such as social media service sharing, may not work if these cookies are blocked or not permitted.

１０. Age Limitations and Eligibility of Children

Our service is intended for general adult audiences and is not directed to children
under 18 years of age. You must be at least 18 years of age to access or use our service. We do not knowingly collect personal information from children under 18
years of age.
If you become aware that a child under 18 years of age is using our service, or suspect that a child under 18 years of age is using our service, we request you please contact us at privacy@syfu.io immediately. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records.

１１. Residents of the EEA and the United Kingdom

SyFu is available for use to users from many different countries. We are primarily bound by the BVI Data Protection Act and manage the personal information of users in accordance with legislation and any applicable governmental guidance. Since our users are based in Hong Kong, we also comply with PDPO as a matter of best practice.

The following data protection information is a guide to provide users with transparent, concise, and easy to understand information on how their personal information will be processed in accordance with the Data Protection Act and the PDPO. Users with any questions or who wish to exercise their rights can contact privacy@syfu.io.
You have the following rights regarding their personal information:

Right to be informed: You have the right to be informed about the collection and use
of your personal data. This information is available in this Privacy Policy.

Right of access: You have the right at any time to confirm if we have your personal
data stored and which personal data is stored. We are required to provide this
information to you free of charge.

Right to rectification: You have the right to request your personal information be corrected at any time if the personal information stored is inaccurate or incomplete.

Right to erasure: You have the right to request your personal information be erased if the purpose for which it was collected is no longer needed or if the personal information was stored based on your consent and you revoke your consent. In this case we must cease the processing and storage of your personal data and remove that data from our service.
However, please note that you do not have the right to have your personal information erased under the following circumstances:
- The data is needed due to a statutory obligation
- The data is needed for the establishment, exercise, or defense of legal claims

Right to restriction of processing: You have the right to request that we restrict the processing of your personal information.

Right to object to processing: You have the right to object to the processing of your personal information. You may contact the SyFu Privacy Team at privacy@syfu.io to assert right to lodge a complaint with a data protection supervisory authority. You have the right to lodge a complaint with a data protection supervisory authority if you believe that the processing of your personal data infringes the law.



１２. Updates to this Privacy Policy

When necessary we may occasionally update this Privacy Policy. The most current version of the Privacy Policy will be posted on our website and inside our mobile app service.

When we post changes to this Privacy Policy, we will revise the "last revised" date at the bottom of this Privacy Policy and it will be considered in effect from that date onwards. By continuing to access or use our service after those changes become effective, you acknowledge that you have reviewed the revised Privacy Policy. We recommend that you periodically check for the latest version of the Privacy Policy and the Terms of Service so you are aware of any changes and how your information may be used.

However, if there is any material change to how we use or disclose your personal data which constitutes a new purpose of use under PDPO, we will inform you of such changes and obtain your consent in accordance with the PDPO.

１３. Note Regarding Translation

The above Privacy Policy may be translated into other languages for user convenience. Nevertheless, the English version governs user relationships with the Company and the SyFu service. Any inconsistencies among the different versions will be resolved in favor of the English version of the Privacy Policy.


１４. Contact Us

If you have questions or concerns about this Privacy Policy or our data practices, please contact us at privacy@syfu.io