Privacy Policy

Last Updated: June 28, 2022

JollyMax, operated by Cybershell Technology Limited (hereafter referred to as “JollyMax”, “we”, “us” and “our”) attaches great importance to your privacy. We create JollyMax Privacy Policy (hereinafter referred to as “this Policy”) in accordance with applicable laws and regulations to sets out why, how and what personal data we collect, use, store, entrust processing, share, transfer and publicly disclose about you when we provide you with our services (the “Service”); the data security protection measures we take; and the rights and methods we make available to you for your access, update, deletion and control of your personal data.

We process your personal data to enable you use our Service through (the “Site”) and other methods which related to our Service. Please read this Policy in combination with JollyMax Terms of Use carefully. If you have any question about this Policy, please contact us through, we will respond you in time.

In order to facilitate your better understanding of our Service and this Policy, we highlight the following content for you.

- As to how to exercise your rights regarding the personal data, subject to applicable laws and regulations, we provide you with methods to exercise your rights to access, correct or modify, and delete your personal data; to withdraw your consent; and exercise any other rights provided by applicable laws and regulations. We will respond to your request timely to ensure that you have control over your personal data.

- Please note that we only provide the Service to those who are at or above the age of majority. You are not allowed to use the Service if you are a minor in your location.

- Please note that this Policy does not apply to data collected by any third party, including through any application or content that may link to or be accessible from or on our Site.

- We will process the personal data about you in accordance with this Policy and the scope of your consent. By accessing or using our Service, you signify that you have read, understand, and agree to our collection, storage, use, and disclosure of your personal data as described in this Policy and our Terms of Use.

- We may organize marketing activities from time to time. We may collect certain personal data from you with your prior consent if you participate in such activity.

1 Personal data we collect

Personal data is information, or a combination of pieces of information that could reasonably allow you to be identified. We collect personal data from a variety of sources, including from you directly, information we generate about you in the course of our relationship with you, and information we collect about you from other sources, including commercially available sources, such as public databases, and third-party services.

We collect the following information about you:

Your Profile Information. If you choose to register or use our Service by using a third-party social network account (e.g., Facebook, Google, Shareit), you will provide us or allow to provide us with your nickname, avatar, and other possible information related to such account. If you are using the Service only as a visitor, you are not required to provide the information described in this paragraph.

The account/character information you want to recharge. You need to provide the information about your account/character which you want to recharge, such as your account number, your character id and so on. The specific type of information you need to provide is subject to the content actually displayed on the corresponding webpage.

Contact information. You need to provide your e-mail address to us in order to receive our feedback. When you contact us, if necessary, you may need to provide corresponding information as evidence to prove the problem you encountered and we will also collect chatting records between you and us.

Transaction information. We will collect transaction information, such as order number, purchase amount, purchase history, date of purchase, the content of the goods and/or services that you are purchasing and so on, in order to pursue our legitimate interests and to abide by our contractual obligation to help you use the Service.

Technical information. We collect certain information when you use the Service, such as your IP address, GAID, network type, carrier, operating system, system language and region.

User activity information. We collect your activity information during your use of the Service, such as your log in history, sharing history, browsing history.

Please note that: If you have provided us with personal data of third-party individuals, you are required to obtain the individual's prior consent and you represent and warrant that you had or have their consent or are otherwise entitled to provide their personal data to us. By providing us with personal data of third-party individual(s), you also warrant that the individual(s) is informed of and consents to the terms of this Policy.

2 How we use your personal data and the legal basis on which we use it

We may use your personal data for the following purposes:

Identification and authentication. We use your personal data to verify your identity, create a profile for you when you register, access and use our Service, and to ensure the security of your personal data;

Contractual obligations. We use your personal data to meet our contractual obligations to you under our Terms of Use or to take steps at your request prior to entering into such contract;

Service operations. We process your personal data to provide the Service (Including our marketing activities) that you request, such as complete your recharge request; process and verify your online transactions and payments on JollyMax;

Service improvements. We analyse usage information, including site analytics, to continually improve the user experience; to carry out data analysis for advertising, and to protect you from fraud, phishing or other misconduct.

Communications. Communications may include providing information about changes to the terms and conditions, updates regarding our Service, or responses to questions you pose;

Advertising and marketing. We may use your personal data to build a profile about you, to understand your preferences, and to help determine which marketing materials (for example, region- or sector-focused) would be of interest to you. Where required by law, we will obtain your consent before sending such marketing materials;

Exercising our rights. We may use your personal data to exercise our legal rights where it is necessary to do so, for example to detect, prevent, and respond to intellectual property infringement claims or violations of law;

Complying with our obligations. We may process your personal data to carry out fraud prevention checks or comply with other legal or regulatory requirements, when required by law;

Keep security. We may use your personal data for risk management and operation detection purposes, so as to ensure the security of your use of the Service.

We may process your personal data in connection with any of the purposes set out above on one or more of the following legal grounds:

- To perform our obligations under a contract with you;

- To comply with our legal obligations, as well as to keep records of our compliance processes or tax records;

- To pursue our legitimate interests, or those of a third-party recipient of your personal data, provided that those interests are not overridden by your interests or fundamental rights and freedoms. Specifically, we have legitimate interests in promoting and marketing our services to existing and potential customers, in maintaining customer accounts for efficient operation of our business, in keeping our information, trade secrets and confidential data safe and secure, in handling complaints and claims to protect our business; or

- Based on your consent to process your personal data in that manner.

3 Information we share

We will only share your personal data with third parties in the following circumstances:

- Merchant of Digital Product. When you purchase any gift codes, app/game credits, or vouchers (“Digital product”) on the Site, we will share your personal data with the merchant who provides the Digital Product. This is necessary to help you complete the transaction.

- Payment aggregator. We may share your personal data, such as order information, profile Information, with payment aggregator, in order to verify and facilitate the transaction. We will not collect your bank account, swift code, IFSC code, etc.

- Our affiliate companies, joint venture partners, and other partners or collaborators. We will share your personal data with them for the purposes of processing, analysing, or storing your information or otherwise as needed to provide the Service to you or achieve other purposes for which we collect information, in each case, consistent with the terms of this Policy.

- Courts, law enforcement authorities, regulators, government officials or other competent authorities. We will share with them where it is reasonably necessary for the establishment, exercise or defence of a legal or equitable claim, including in order to protect the legitimate rights and interests of you and others.

- Service providers which we engage to process personal data for any of the purposes listed above on our behalf and in accordance with our instructions only, such as licensed payment service providers, cloud storage providers; and/or

- Prospective sellers or buyers of any of our business or assets to which we might assign or novate any of our rights and obligations; in such case we may disclose your personal data to the prospective seller or buyer of such business or assets.

You can visit or use other third-party services through our website. Please note that any information you provide directly to third-party providers is not covered by this Policy. We are not responsible for the privacy or security practices of other third parties with whom you choose to share your personal data directly. We encourage you to review the privacy policies of any third party to whom you choose to share your personal data directly.

4 Where and how long do we keep your personal data

The personal data we collect may be transferred to and stored outside of the country you use our Service for the purposes specified in this Policy. For example, we store all of our data, including personal data on a server located in Singapore.

Any international transfers of your personal data will be made according to appropriate safeguards under the applicable laws and regulations. If you wish to enquire further about these safeguards used, please contact us using the details set out in section 8 of this Policy.

Your personal data will be retained only for as long as necessary for the purposes for which the information was collected, except where necessary to meet our legal obligations or to establish, exercise or defend potential legal claims or to pursue our legitimate interests.

5 Your rights

You have certain rights regarding the personal data we hold about you, subject to local law. These may include the following rights:

(a) access – confirm whether your personal data is processed by us, and if it is, to request a copy of your personal data and information relating to how it is processed;

(b) rectify – request any inaccuracies in the personal data we hold about you be corrected or any incomplete personal data we hold about you to be completed;

(c) erase – in certain circumstances, request that we erase your personal data from our records;

(d) restrict – in certain circumstances, request that your personal data is no longer processed by us;

(e) object – where we process your personal data on the basis of our legitimate interests, you have the right to object to this. However, we may continue to process your personal data if you have objected where we have compelling legitimate grounds to continue such processing or for the establishment, exercise or defence of legal claims;

(f)  direct marketing - you have the right to ask us to stop processing your personal data for direct marketing purposes;

(g) portability / transfer – in certain circumstances, request to receive personal data concerning you, which you have provided to us, in a structured, commonly used and machine-readable format and you may have the right to transmit that data to you or another third party you have chosen;

(h) withdraw your consent – where we are relying on your consent to process your data, then you can withdraw your consent at any time;

(i) automated decision making - in certain circumstances you have the right to request that you are not subject to automated processing of personal data, which produces a legal effect or similarly significantly affects you; and

(j)  lodge a complaint – you have the right to lodge a complaint with your local data protection authority.

If you would like to discuss or exercise any rights you may have under law, please contact us at the contact details below.

To withdraw your consent or to exercise any of the rights above, if they are applicable, you should use our contact details set out in section 8 below.

6 Security

We are concerned about safeguarding the confidentiality of your personal data. We employ administrative, physical and electronic measures designed to protect your personal data from unauthorized access and use. Please be aware that no security measures that we take to protect your personal data are absolutely guaranteed to avoid unauthorized access or use of your personal data which is impenetrable.

7 Sensitive Information

We ask that you not send us, and you not disclose, any sensitive personal data (e.g., information related to your e-wallet password, credit or debit card password, racial or ethnic origin, political opinions, religion or other beliefs, health, sexual orientation, criminal background or membership in past organizations, including trade union memberships) through JollyMax to us, unless such information is required by us for legal compliance checks.

8 Contacting Us

If you have any questions, complaints or comments about this Policy or our privacy practices, or to report any violations of this Policy, please contact us at:

9 Changes to This Privacy Policy

We reserve the right to amend this Policy from time to time to reflect any changes to the way how we process your personal data or changing legal requirements without any prior notice to you. Any amendments will be made available and published on and will indicate the effective date. You may determine if any revision has taken place by referring to the date that this Policy was last updated. We recommend that you check this Policy periodically to review the latest version. Your continued use of the our Service after an amendment constitutes your acknowledgement and acceptance of such changes. The most current version of this Policy will govern our use of your information. Please check back frequently to see any updates or changes. This Policy was last effective on the date provided at the top of this page.

Supplemental Terms

The following additional or amended terms shall apply to you if you are a user in the relevant jurisdiction specified below.


If the Services are used or accessed from within Republic of Indonesia, then the following supplemental terms shall apply and override any conflicting provisions in this Policy:

Data sharing. We will not share your personal data with third parties for any purposes other than the provision of the Service specified herein, without your consent.

Governing Language. These Policy are made in English and Indonesian language versions. In the event of any discrepancy between the English and Indonesian language versions, the English language version shall prevail.

Parental or Guardian Consent. If you are under the age of 21, you hereby represent that you had the consent of your parent or legal guardian to use the Service.

Waiver. For the purpose of termination and/or dissolution and/or rescission of this Policy, we and you hereby waive the applicability of the provisions under Article 1266 of the Indonesian Civil Code, to the extent that the court order and/or decision would otherwise be required to validly terminate and/or dissolve and/or rescind this Policy.


Access Logs. We keep your website access logs, under confidentiality, in a controlled and safe environment, for, at least, 12 months, in order to comply with legal obligations.