Privacy Policy

1) Service operation and Functionality

In order to provide you with the core functionalities of the Service, we will process your information only to the extent necessary, including but not limited to:

• Software Delivery and Execution: To provide you with application download, installation, and operational support, including version updates and compatibility adjustments.
• Personalized Service: To provide customized content presentation or feature recommendations based on your account settings, usage preferences or device information.
• Social Interaction Support: To enable content sharing between you and other users.
• Service Notification: To send you service-related usage tips, policy updates, or security alerts via email, in-app messages, or mobile push notifications.

2) Service Optimization and Error Handling

In order to ensure the stability of the Service and to continuously improve the user experience, we may process your data for the following purposes:

• System Diagnosis: To identify and resolve system errors through log analysis, error detection and other technical methods.
• Functionality Optimization: To evaluate server load, response speed, and other performance indicators to improve service efficiency.
• Functionality Iteration: To test new features in a controlled environment and verify their effectiveness through data analysis.
• Technical Support: To provide troubleshooting and solutions based on feedback or error reports submitted by you.

3) Security and Compliance Measures

We take technical and organizational measures to maintain service security and fulfill our legal obligations, including:

• Risk Control: To detect and prevent fraud, cyber-attacks or data misuse.
• Content Audit: To review user-generated content for compliance (e.g., removal of illegal or infringing material) based on community guidelines.
• User Protection Mechanism: To handle reports and complaints submitted by you or other users and take appropriate actions.

4) Compliance with Legal Obligations

To the extent required by laws and regulations, we may process your data in accordance with the law to fulfill the following purposes:

• Identity Verification: To complete real-name or age verification in specific service scenarios (e.g., financial transactions or age-restricted content access).
• Regulatory Cooperation: To respond to lawful data requests made by judicial or other authorized authorities in accordance with the law.
• Record Retention: To keep necessary business logs and transaction records in accordance with the E-Commerce Law, Cybersecurity Law, and other regulations.

5) Routine Business Operations

In order to ensure lawful and compliant business operations, we may process your data in the following situations:

• Internal Audit: To conduct regular reviews of data security and financial processes to ensure compliance with internal control standards.
• Organizational Changes: To handle user data migration in the event of mergers, acquisitions, or restructuring, in compliance with applicable laws and regulations.

1) Information you voluntarily provide

When you create a RushBuy.gg account, purchase a product, participate in promotions offered by RushBuy.gg, contact us, submit feedback, or participate in surveys, you may provide personal information directly to us, including but not limited to:

• Accessing or Browsing the Site: To collect device information (e.g., IP address, browser type) and browsing behavior data (e.g., pages visited, duration of your visit) when you use our site.
• Registration and Use of Services: To collect information such as your name, email address, phone number, username, and password when you create an account or use certain features.
• Recorded Communications: To record and retain the content of communications and your contact information when you contact us via online customer service, telephone, or email, as needed for support and troubleshooting purposes.
• Transaction Information: To collect transaction information, such as order number, purchase amount, purchase history, date of purchase, and details of the goods or services purchased, in order to pursue our legitimate interests and fulfill contractual obligations related to the provision of the services.
• User Activity Information: To collect information you provide when participating in surveys, contests, or marketing activities, including your name, contact information, and feedback. We also collect information about your activities while using the services, such as login history, sharing history, and browsing history.
• Account Association: To collect information from third-party social network accounts (e.g., Google, Facebook) when you register for or use our services through such accounts. The profile information obtained may vary by provider, but typically includes your name, email address, friends list, avatar, and other information you choose to make public on that platform. If you use the services as a guest, providing this information is not required.
• Complaints or Feedback: To collect your name, contact information, and the content of complaints, feedback, or suggestions you provide.

2) Information Collected Automatically

In order to ensure the proper functioning and security of the Service, we may automatically collect data through cookies, log files, and other technical means, including but not limited to:

• Location Information: To collect your IP address, cell ID, and city, country, or region when connected via Wi-Fi.
• Device, Network, and Technical Information: To collect your IP/MAC address and other device identifiers; device model, operating system, regional/language settings, and Internet Service Provider (ISP); screen resolution, frame rate, and ping values; stack information (such as crash reports and core dumps); server health metrics (such as CPU and memory utilization, I/O utilization, and load average); date and time stamps of operations and events within the Service; and other network and technical information.

3) Information Obtained from Third-Party Platforms

Subject to applicable laws, we may collect information about you indirectly from the following sources, including but not limited to:

• Affiliates or Partners: To obtain necessary information (such as account verification data) shared by partners when you use our services through their platforms.
• Publicly Available Channels: To collect information from publicly available sources, including social media (if you publicly mention our services) or legally accessible databases (such as business registration information).
• Provided by Other Users: To obtain information, such as your contact details, when other users invite you to join or use our services.
• Payment Information: To obtain payment-related information, such as payment identifiers, source country/region, and transaction details, when you use a third-party payment processing service.

1. Identity Verification: To verify your identity and create a profile when you register, access, or use our services, for identification, due diligence, or know-your-customer purposes.
2. Fulfillment of Contractual Obligations: To fulfill contractual obligations agreed with you in the Terms of Use or to act on your request prior to entering into a contract.
3. Operation of the Service: To operate the Service and provide the services you request (including marketing activities), such as fulfilling top-up requests and processing or verifying online transactions and payments on RushBuy.gg.
4. Service Improvement: To analyze usage information (including web analytics, statistics, and product or service development) to understand how you use our services, recommend relevant products and services, continually improve the user experience, conduct advertising data analysis, and protect against fraud, phishing, or other inappropriate behavior.
5. Communication: To communicate with you, including providing information about changes to the Terms, updates to the Services, or responses to your inquiries.
6. Advertising and Marketing: To create a profile to understand your preferences and determine which marketing materials (e.g., targeted by region or industry) may be of interest to you. Where required by law, we will obtain your consent before sending such materials.
7. Exercising our Rights: To exercise our legal rights, such as detecting, preventing, or responding to claims of intellectual property infringement or other legal violations.
8. To fulfill our obligations: To fulfill legal obligations, including fraud prevention checks, compliance with legal proceedings, or responding to lawful governmental or regulatory requests. This includes, but is not limited to, responding to subpoenas and other legal requests, or disclosing information when necessary to identify, contact, or take legal action against an individual who may endanger public safety or interfere with the Services.
9. For Security: To ensure security, including risk management and operational testing, to protect your use of the Services.
10. Other Purposes: For any other purposes that we notify you of and obtain your consent for at the time of data collection.

You may opt out of receiving future communications from RushBuy.gg at any time.

1. To share information with social media and gaming platforms: When you link, connect, or sign in using a third-party social media or gaming platform account, that third party may receive information about your interactions with us in accordance with our Privacy Policy (e.g., signing in to a game using your Xbox account may result in Microsoft receiving information about your sign-in). We have no control over the privacy practices of third parties; you should review the privacy policies of any third-party services you use.
2. To share information with service providers: We share your personal data with service providers who operate on our behalf to fulfill the purposes described in this Privacy Policy. Service providers act according to our instructions and are required to process information securely. Examples include cloud services, payment processors, user researchers, and marketing or advertising networks.
3. To share information with affiliates and subsidiaries: We may share your personal data with company affiliates and subsidiaries for purposes consistent with this Privacy Policy.
4. To transfer information in business transactions: In the event of a merger, acquisition, reorganization, or bankruptcy, your personal data may be transferred as an asset to the relevant party, provided that the recipient continues to comply with this Privacy Policy.
5. To disclose information for legal compliance and security: We may disclose your personal data if reasonably necessary to comply with applicable laws, regulations, or legal processes, respond to requests from courts or government authorities, or protect our users, the public, or our legitimate interests from harm.
6. Data sharing for specific scenarios:
   • Digital Goods Transaction: To provide necessary transaction data to merchants when purchasing gift codes or point coupons.
   • Payment processing: To share order information (excluding sensitive information such as bank accounts) with payment aggregators.
   • Partners: To share information with business partners for joint offerings or promotions, subject to compliance with this Privacy Policy.
   • Regulatory Requirements: To disclose information to regulators or law enforcement as required by law.
7. To transfer information internationally: Your personal data may be transferred to, and processed in, countries where our services, affiliates, subsidiaries, or partners are located. These countries may have data protection laws that differ from your jurisdiction and, in some cases, may provide a lower level of protection. We require these entities to process information in accordance with applicable data protection laws and implement appropriate security measures to protect your personal data.

   For transfers of personal information from the EEA or the UK, we implement the following safeguards:

   • To transfer data based on adequacy decisions: We rely on adequacy decisions to transfer personal data to countries deemed adequate, such as Canada, Japan, and the UK. The full list of adequate countries is published by the relevant authorities for the EEA and the UK, respectively.
   • To transfer data using standard contractual clauses: We use the standard contractual clauses issued by the European Commission and the UK Information Commissioner's Office (ICO) for transfers to countries that are not deemed adequate, such as Singapore and Hong Kong.

1) Data transmission security

We use encryption technologies such as TLS/SSL (Transport Layer Security) and transmit data via secure HTTPS channels to protect the confidentiality of information during transmission.

2) Data storage security

• We encrypt stored personal information and restrict access by using isolation technologies.
• Data is stored in facilities with robust physical security measures, and access is limited to authorized personnel only.
• Some data may be routed through extended networks, but appropriate safeguards are in place to ensure compliance.

3) Security of data use

• When displaying or processing personal information, we use data masking techniques (e.g., content substitution, SHA-256 hashing) to reduce the risk of exposure of sensitive information.
• We implement strict access controls and multi-factor authentication (MFA) to prevent unauthorized use of data.

4) Security Auditing and Monitoring

Regular security audits are conducted through automated code security checks and data access log analysis to detect and mitigate risks in a timely manner.

5) Data Retention and Deletion

• Personal information is retained only for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable law.
• When you close your account, your data will be deleted unless retention is required by applicable law or regulation.

We continuously update and optimize our security measures to respond to evolving risks. If you have any questions about data security, please contact us.

1) Emergency Response Mechanism for Security Incidents

RushBuy.gg has established a number of security systems to address potential risks such as leakage, destruction, or loss of personal information, including:

• Developing an Information Security Incident Grading and Handling System, which defines the criteria for categorizing security breaches and incidents and the corresponding response processes.
• Establishing a dedicated security emergency response team and implementing 24/7 monitoring.
• Implementing a standardized incident handling process, covering event assessment, loss prevention, root cause analysis, remedial measures, and traceability.

2) Security incident notification obligations

In the unfortunate event of a personal information security incident, we will notify you promptly and take the following measures in accordance with applicable laws and regulations:

• Timely Notification: We will inform you of the details and potential impact of the incident through our website, email, SMS or phone call.
• Transparency in Handling: We will explain the countermeasures taken or to be taken, provide recommendations on how you can independently prevent and mitigate risks, and inform you of remedial measures available to you.
• Centralized Announcement: If individual notification is not feasible, we will issue a notification through platform announcements or other effective means.
• Regulatory Reporting: We will proactively report the handling and progress of the incident to the competent authorities in accordance with applicable regulatory requirements.

3) User Response Suggestions

If you have any questions about our personal information protection, you can contact us through the contact information agreed in this privacy policy. If you find that your personal information has been leaked, especially your account and password, please contact us immediately through the contact information agreed in this Privacy Policy so that we can take appropriate measures.

1) Scope of Rights

• Access and Correction: You have the right to access and request corrections to your personal information to ensure it is accurate and up to date.
• Deletion: You have the right to request the deletion of your personal information.
• Objection and Restriction: You have the right to object to our processing of your personal information and request that we restrict certain types of processing.
• Withdrawal of Consent: Where applicable, you have the right to withdraw the consent you previously provided to us.
• Complaint: You have the right to lodge a complaint with the relevant data protection authority regarding our processing of your personal information. You can file a complaint with the Information Commissioner's Office where you live or work.

2) Limitations on the exercise of authority

We may not be able to respond to your request in the following circumstances, as permitted or required by applicable laws or regulations:

• Where responding is expressly prohibited by law.
• Where the request relates to national security, defense security, public safety, public health, or other significant public interests.
• Where the request is connected with the investigation, prosecution, or trial of a crime.
• Where there is sufficient evidence that the request is made with malicious intent or constitutes an abuse of rights.
• Where fulfilling the request would cause serious harm to your lawful rights and interests, or those of other individuals or organizations.
• Where the request involves trade secrets or confidential business information of partners.
• Where it is not technically feasible to fulfill the request, such as where it involves archived or backup data.

1) Principles of protection of minors

• Minors under 18 must obtain their guardian's consent before using our products or services. RushBuy.gg will strictly follow national laws and regulations to protect the personal information of minors.
• RushBuy.gg does not knowingly collect personal information from minors. We only use, share, or disclose such information when permitted by law, with the guardian's consent, or when necessary to protect the minor.
• If we discover that a minor has registered to use our services without guardian consent, we will contact the guardian and delete the relevant personal information as soon as possible.

2) Special Protection for Child Users (under 14 years old)

• Such information will only be processed when permitted by law, expressly authorized by the guardian, or necessary to protect the child.
• If we discover that we have inadvertently collected information from a child under 14 without verifiable guardian consent, we will delete the data immediately.
• When a guardian chooses to enable a service for a child, we may need to collect necessary information, but we will clearly state the purpose and obtain prior authorization.

3) Guardian's Rights and Safeguards

• Children and guardians have the right to access, correct or delete personal information, and may make requests or contact us support@rushbuy.gg at any time for feedback.
• For services that may be attractive to younger users, we implement additional safeguards:
  • Provide the guardian with a privacy notice describing the scope of information processing;
  • Require verifiable guardian consent (when required by law);
  • Strictly limiting the scope of information processing to what is necessary for the service;
  • Providing privacy setting controls to allow guardians to manage children's account permissions;
  • Customizing privacy instructions for younger users.

• We may process your personal information based on your consent for specific purposes. You may withdraw your consent at any time without affecting the lawfulness of processing prior to withdrawal.
• Where the processing of your personal information is necessary for the performance of a contract, failure to provide such information may result in our inability to provide you with the requested services.
• In certain circumstances, we may act as a data processor on behalf of third-party partners. In such cases, we will process your personal information solely for the purposes specified in this policy and in accordance with the data processing agreements entered into with those partners.
• We may process your information when we believe that processing is necessary for the legitimate interests pursued by us and such interests are not overridden by your interests, fundamental rights, and freedoms. We may process your personal information in the following circumstances:
  1. To send users information about our products and services, as well as related activities and discounts.
  2. To develop and display personalized content for our users.
  3. To analyze user behavior data and service usage in order to improve our services, and to attract and retain users.
  4. To understand how users interact with our products so that we can improve the user experience.
  5. To diagnose problems and prevent fraud.
  6. To support our marketing and promotional activities.
• We may process your information when we believe it is necessary to comply with our legal obligations. For example, if law enforcement or regulatory authorities require us to disclose relevant information, we will provide such information to cooperate with regulatory investigations.
• When we believe it is necessary to protect your vital interests or the vital interests of a third party, we may process your information to protect the interests of the relevant parties.

Your Rights

If you require a copy of your personal information, wish to update or correct your personal information, request its deletion, or ask us to transfer your personal information to another data controller, please contact us via the email address provided at the bottom of our website and include a detailed description of your request.

Upon receiving your request, we may require sufficient information to verify your identity and the nature of your request. We will endeavor to respond within one calendar month of receipt. If we are unable to respond within that timeframe, we will notify you of the earliest date by which we can provide a response.

Please note that, under European data privacy laws, these rights are subject to certain exemptions and limitations. In some cases, your personal information may be retained, processed, or restricted from access. Where applicable, we will inform you of any such exemptions or limitations.

International Data Transfer

Due to the global nature of our operations, your personal information may be stored and processed in countries outside the European Economic Area (EEA) where we, our suppliers, or our data processing partners operate. Accordingly, you understand and agree that we may transfer your personal information to recipients outside the EEA in order to provide you with RushBuy services, process and complete transactions you initiate on our platform, or fulfill any other purposes specified in this policy.

In such cases, we will take appropriate measures to ensure that these recipients outside the EEA provide a level of protection for your personal data that is equivalent to the requirements of the EU General Data Protection Regulation (GDPR) and the applicable local data protection laws in your jurisdiction. We will take all reasonable and necessary steps to ensure your personal data is protected, including relying on recognized legal adequacy mechanisms, using standard contractual clauses where applicable, and ensuring that your information is processed securely and in accordance with this policy.

1) Policy Updates

To provide you with better service and as RushBuy.gg's business grows, this Privacy Policy will be updated. However, we will not reduce your rights under this Privacy Policy without your explicit consent. We will post the updated version on the RushBuy.gg website and will notify you of such updates by means of a web posting or other appropriate channels prior to the effective date. You are also encouraged to visit RushBuy.gg regularly to stay informed about the latest version of this Privacy Policy.

2) Material Changes

We may also provide more prominent notice of material changes to our Privacy Policy (including, but not limited to, email, text message, or a special notification on the page you are visiting). Material changes, within the meaning of this Privacy Policy, include but are not limited to:

• A material change in our service model. For example, a change in the purpose of processing personal information, the type of personal information processed, or how personal information is used.
• Significant changes in our ownership or organizational structure. For example, a change of ownership due to business restructuring, bankruptcy, merger, or acquisition.
• A change in the primary recipients of personal information that RushBuy shares, transfers, or publicly discloses.
• Significant changes to your rights regarding the handling of personal information or to the methods by which you can exercise those rights.
• A change in the department responsible for handling the security of your personal information, including updates to contact information or complaint channels.
• Situations where a personal information security impact assessment report indicates a high level of risk.

1) Types of Technology and Uses

• Cookies: Used to recognize your device, record preferences, and enable basic functionality (e.g., maintaining login status). Disabling essential cookies may cause parts of the website to malfunction.
• Pixel Tags / Web Beacons: Monitor email open rates and link clicks to minimize unnecessary communications.
• Log Files: Automatically record IP addresses, device information, operating systems, and other data for trend analysis and service optimization.

2) Advertising and Privacy Control

• We and our partners use cookies to deliver relevant advertisements (e.g., controlling display frequency and enabling targeted placement).
• You can refuse interest-based ads through your device settings (e.g., Settings > Privacy > Ad Restrictions). Note that this only affects RushBuy.gg ad serving and may reduce the relevance of ads displayed to you.
• Enabling "Restrict Ad Tracking" will prevent third-party targeting via ad identifiers.

3) User Options

• Manage Cookies: Major browsers (e.g., Chrome, Safari) support deleting or disabling cookies through privacy settings. Disabling cookies may limit some website features.
• Exit Email Tracking: You can prevent click tracking by not clicking on links in emails. Pixel tags will only register whether an email has been opened.

4) Nature of Data and Legal Compliance

• By default, cookie data is treated as non-personal information. However, we comply with local laws that classify certain data, such as IP addresses, as personal information.
• If cookie or tracking information is combined with personal information, the combined data will be treated as personal information in its entirety.