Privacy Policy | MakeGame

Jun 12, 2026

Release Date: June 12, 2026

Effective Date: June 12, 2026

Welcome to MakeGame! This Privacy Policy describes the privacy practices of CENTURY NETWORK (HONG KONG) LIMITED (hereinafter referred to as "we" or "MakeGame") regarding any personal information that you provide to us, that we obtain from you, or that we otherwise become aware of. We respect your privacy rights and attach great importance to the protection of your personal data. This Privacy Policy will explain how we collect, process, disclose and protect your personal data when you use the services, as well as how you can exercise your rights related to personal data protection. By using the services, you indicate your agreement with the practices described in this Privacy Policy. If you do not agree with this Privacy Policy, please cease accessing or using any of our services. This Privacy Policy is incorporated into and forms part of our Terms of Service. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy shall have the same meanings as in our Terms of Service.

MakeGame has a diverse community consisting of users of different age groups. However, for US users, MakeGame is not intended for minors under the age of 13. If we discover that we have collected personal data from users under the age of 13, we will delete such personal data and terminate the user's account. If you believe that we have collected personal data from a minor under the age of 13, please contact us using the methods provided under "How to Contact Us" below. For users in other regions, to protect the privacy and personal data of minors, if required by local laws in your country or region, we will obtain the consent of parents or legal guardians before processing the personal data of minors. Please note that we will limit the types and scope of personal data collected from minors as much as possible, and restrict the functions available to minors.

1. Types and Purposes of Personal Data We Collect

The scope of personal data we collect depends on the service functions you use and how you use them. The following summarizes the purposes and types of personal data we collect:

A. Personal Data You Provide Directly to Us

Registration and Login: Users may register and log in to platform accounts via email or third-party platform accounts (such as Google). In this case, we may collect your nickname, avatar, email address, and location information; logging in through such third-party accounts indicates your consent for the third party to provide relevant personal data to us.
User-Generated Content (UGC) Creation and Sharing: When you publish any User-Generated Content ("UGC") (such as entering keywords in MakeGame to create your artificial intelligence games), depending on the specific functions you use, we may need to collect the user-generated content you publish, publication time, location data, etc. Only when you choose to publish such content will we provide the resulting output content and/or other user-generated content to other users for their browsing, playing or other uses expressly permitted by the services. You have the right to manage or revoke this authorization at any time in accordance with applicable laws. However, such revocation will not affect any use of the content by other users before the revocation takes effect, or user-generated content created based on such content.
Contact Information: We may use the contact information you provide (such as email address) to conduct user surveys or send you information about products and services that may be of interest to you. If you are not interested in such information, you may decline in your reply.

B. Personal Data Provided or Generated During Your Use of MakeGame

Content Browsing: Any user may view publicly available user-generated content within MakeGame, and may view such content through our website without registering for a MakeGame account or logging in. Whether you browse after logging in or as a guest, we may collect your browsing history so that you can record and further browse the content you have viewed.
Input Information: When you use the game creation function, depending on the specific method you use, we may collect the text data you input. This data will be processed according to your instructions to generate the corresponding game output. In addition, we will process your input data for security purposes, such as automatic screening of illegal information involving pornography, violence, fraud, infringement or scams.
Game Behavior Information: When you play public games, we may record the game content you create and play, playing periods, duration, and in-game operational behaviors.
Payment and Transactions: When you use our recharge or payment functions (via Apple Pay, Google Pay, Stripe, etc.) and initiate payment requests, we need to collect your user ID, country/region, payment currency, payment amount, payment time, payment method, order number and other information to complete the payment and transaction process through the application programming interface (API) supported by third-party payment service providers.
Improving User Experience: To enhance your user experience, we may automatically collect information such as your language, clicks and operations, program progress (including login status, interaction information/status, etc.), application tokens, operating system, network information (such as IP address), device data (such as International Mobile Equipment Identity and other device identifiers), country/region, device model, screen resolution, geographic location, anonymous user identifiers, and analyze such data.
Maintaining Stability and Security: To maintain the stability and security of MakeGame and your account, when you use MakeGame, we will automatically collect data related to service operation and your online operations, such as login status, clicks and operations, user device data (such as International Mobile Equipment Identity and other device identifiers), operating system data, network information (such as IP address), etc. In addition, when you use our website, we may also collect information related to how the services are accessed and used ("Usage Data"). Specifically, usage information includes the following content automatically created and recorded by our systems: (1) Log Data: Information automatically sent by your browser when you access the website ("Log Data"), including Internet Protocol address, browser type and settings, request date and time, interaction methods with the website, unique device identifiers and other diagnostic data; (2) Cookie Files: Cookies and similar tracking technologies allow MakeGame to access or store information about you, your settings or your device, mainly used to ensure the expected functionality of MakeGame. Generally, cookies do not contain any information that can directly identify you, but can provide you with a more personalized user experience. If you do not accept such cookies, you may not be able to use all functions of MakeGame. For example, we use first-party cookies to save your login information for your subsequent login to our services, and such cookies are essential for the normal operation of MakeGame.

If you provide personal data of any other data subjects to us, please inform them of this Privacy Policy. You hereby confirm that before providing such personal data to us, you have obtained their consent or completed other procedures required by other legal data processing bases other than consent.

By submitting such information to us, you represent that you have the right to provide such information and that we have the right to process the relevant personal data for the purposes described in the Privacy Policy.

Generally, we will only use your personal data for the purposes described in the Privacy Policy or for purposes explained to you at the time of collecting the relevant personal data. However, where permitted by applicable laws and regulations, we may also process personal data for other purposes that are not incompatible with the disclosed purposes. If we do so, we will notify you separately through other means to ensure transparency.

2. How We Process Personal Data of Minors

For US users, MakeGame is not intended for minors under the age of 13. If we discover that we have collected personal data from users under the age of 13, we will delete such personal data and terminate the user's account. If you believe that we have collected personal data from a minor under the age of 13, please contact us using the methods provided under "How to Contact Us" below.
For users in other regions, to protect the privacy and personal data of minors, if required by local laws in your country or region, we will obtain the consent of parents or legal guardians before processing the personal data of minors. We will limit the types and scope of personal data collected from minors as much as possible, and restrict the functions available to minors. If we discover that we have collected personal data from minors below the corresponding age limit in your country or region without obtaining parental or legal guardian permission, we will delete such personal data as soon as possible.

We recognize that we have special obligations regarding the collection and processing of personal data of minors. We also strongly recommend that parents and guardians educate their children not to disclose or provide any personal data about themselves without your prior permission when using our services.

To provide you with better services, we may entrust third parties (such as service providers assisting us in providing MakeGame-related services) to process your personal data on our behalf. We will enter into strict confidentiality contract terms with such third parties, requiring them to process personal data in accordance with our requirements, this Privacy Policy and the confidentiality and security measures required by applicable laws and regulations.

Under the following circumstances, we may share your personal data with third parties:

To provide you with a better user experience, we may share your personal data with our partners, such as sharing your Google user identifier to facilitate login to the services through third-party platform accounts.
We provide information and content to service providers supporting our business (such as cloud service providers, payment service providers, analytics service providers) to ensure that MakeGame becomes a safe and satisfactory platform; we will also provide relevant information to service providers assisting us in platform marketing. We may use Google Analytics to collect and share with them information related to service usage (such as the frequency of user access to services, operations during access, location during login) for marketing activities and to provide tailored services for users in specific regions.
We may share your information with advertisers and third-party companies to display personalized advertisements to you (if any).
We may also share your information with other members, subsidiaries or affiliates of our corporate group, including for providing, improving and optimizing MakeGame services, preventing illegal use and providing user support.
To detect, prevent or address security or fraud issues, during transactions and payment processes, we may provide your registration information, your selected country/region and your last login IP address to relevant third-party payment service providers.
If we use information such as user-generated content on the platform in advertising and marketing activities to promote the platform, your personal data contained in such information may be disclosed to recipients of such advertising or marketing content.
In the event of any change, merger, acquisition, reorganization or liquidation involving the transfer of personal data, we will require the new company or organization processing your personal data to continue processing your personal data in accordance with this Privacy Policy. If the new company or organization processing your personal data needs to use your personal data for purposes not specified in this Privacy Policy, unless otherwise provided by applicable laws and regulations, the new company or organization will obtain your consent.
Disclosure to relevant competent law enforcement agencies, regulatory authorities, government departments, courts or other third parties, provided that we believe such disclosure is necessary to: (1) comply with applicable laws and regulations; (2) exercise, establish or defend our legal rights; or (3) protect the vital interests of you or any other person.

When third parties acting as data controllers process your personal data, please directly refer to their privacy policies on their official websites or other platforms to understand their data processing practices.

4. How We Protect Your Personal Data

We adopt appropriate technical and organizational measures to protect your personal data that we collect and process. The measures adopted are designed to provide a level of security appropriate to the risks associated with the processing of your personal data. In addition, we regularly test applications and systems for vulnerabilities and security issues, and adopt access control measures such as access tokens and multi-factor authentication to ensure information security.

Please note that we cannot guarantee absolute security on the Internet. If you discover that your personal data has been leaked, please contact us through our contact information so that we can take corresponding measures.

In the event of any accident, force majeure event or other situation leading to the leakage of your personal data, we will do our best to control the situation and promptly inform you of the cause of the leakage, the security measures we have taken, the measures you can take and other relevant information. In the event of a security incident related to personal data, we will report the incident to the competent authorities in accordance with the requirements of applicable laws and regulations, promptly investigate the problem and take emergency measures.

5. How We Store Your Personal Data

A. Cross-Border Transfer

To meet the needs of global operation and security management, your personal data may be transferred to and processed in multiple jurisdictions where our affiliated entities are located (which may be different from your jurisdiction). In such cases, we will take necessary and appropriate safeguard measures to ensure the security of your personal data during transmission, and require recipients of your personal data to provide a sufficient level of protection and security safeguards in accordance with this Privacy Policy and the requirements of applicable laws and regulations.

B. Storage Period

Unless otherwise provided by applicable laws and regulations, we will store your personal data within the scope of the company's legitimate business needs (such as to provide you with services and comply with legal, tax and accounting requirements). When your personal data is no longer needed, or when the storage period expires in accordance with applicable laws and regulations, we will delete or anonymize your personal data.

6. Your Rights

We value the protection of your personal data. If you wish to access, correct or delete your personal data, or file a complaint, withdraw consent, or exercise other rights provided by applicable laws and regulations, please contact us through our contact information. You have the right to access the personal data we collect about you. We will implement appropriate measures to do our best to ensure that your personal data is accurate and up-to-date. If we terminate the services or operations, we will notify you at least thirty (30) days in advance, and delete or anonymize your personal data after the termination of services or operations.

If we process your personal data based on your consent, you may withdraw such consent at any time. Please note that withdrawal of consent will not affect the legality of any processing we have conducted before your withdrawal of consent, nor will it affect the legality of our processing of your personal data based on legal grounds other than consent.

If you wish to exercise other statutory data subject rights provided by applicable laws and regulations (such as requesting us to transfer your personal data to a third party designated by you, restricting our processing of your personal data, or, under statutory conditions, objecting to our processing of your personal data based on legitimate interests), you may contact us using the methods provided under "How to Contact Us" below.

To protect the security of your information, before responding to your request to exercise rights, we may need to verify your identity, such as requiring you to provide certain identity-related certification materials. We will respond to your request to exercise data subject rights in a timely manner in accordance with the requirements of applicable laws and regulations.

7. How We Update This Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical or business developments. When we update the Privacy Policy, we will take appropriate measures to notify you according to the importance of the changes. You can learn when this Privacy Policy takes effect by checking the "Effective Date" displayed at the top of this Privacy Policy. If you continue to use any functions of MakeGame, you are deemed to have read and understood the updated Privacy Policy.

8. How to Contact Us

If you have any questions or concerns about this Privacy Policy or our processing of your personal data, especially if you believe that our processing of your personal data has harmed your legitimate rights and interests, please contact us at support@makegame.io. We will immediately review your questions and respond in a timely manner in accordance with applicable laws and regulations.

9. Governing Law and Dispute Resolution

This Privacy Policy shall be governed by the substantive laws of Hong Kong, without regard to its conflict of law provisions. Any dispute arising out of or in connection with this Privacy Policy (including any question regarding the existence, validity or termination of this Privacy Policy) shall be submitted to and finally resolved by arbitration administered by the Hong Kong International Arbitration Centre (HKIAC) pursuant to the HKIAC Arbitration Rules in effect at the time of application, which rules are deemed incorporated by reference in this section. The place of arbitration shall be Singapore.