Project N

Privacy Policy

Last Updated: [●] 2024

Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Please note that this privacy policy (“Privacy Policy”) only applies to Project N (“Game”). If you use any other products or services, please refer to the privacy policy for that particular product or service.

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here.

For the purpose of data protection laws, the data controller of your personal information in relation to the Game is Proxima Beta Pte. Limited.

SUMMARY

Here is a summary of the information contained in this Privacy Policy. You can find more detail by clicking ‘More Information’.

What information do we need to be able to provide the Game?	If you choose to set up your profile using a social media account, we collect information provided by your social media account service provider to automatically generate your profile, including nickname, avatar. To maintain the smooth operation of the Game (which includes activities such from addressing bugs or malicious activity through to improving functionality), we will process customary device and network information (such as IP address, device specifications, as well as gameplay data). If you choose to answer a survey, we collect survey response content that you choose to provide in the survey, such as email, country or region of residency, and gaming habits and preferences. If you need to get in touch with us, we will retain some information (such as your email and any screenshots you send us) so that we can review and respond to your concerns.	More Information.
How will we use your information?	We use your information to set up your account, enable you to use the Game, localise the Game experience, enable interaction between users of the Game, save your progress, ensure the safe and secure operation of the Game, address bugs, optimise and improve the Game, protect users, monitor our marketing initiatives, resolve user queries, and to comply with our legal obligations and enforce our legal rights.	More Information.
Who do we share your information with?	We may from time to time use third parties and work with our affiliates to help us deliver the best possible experience. All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Game (i.e., to fulfil the purpose(s) described above). In some cases we may be required by a court or be under a legal obligation (such as a valid search warrant or subpoena) to disclose certain information.	More Information.
Where do we process your information?	Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy. We have servers for the Game in Singapore. We also have support, engineering and other teams who may support the Game, including from Singapore and the People’s Republic of China.	More Information.
How long do we keep your information?	Unless otherwise required or permissible by applicable laws, we retain your information for the period during which you maintain an account for the Game, or for so long as the information is needed to fulfil the purpose for which it was collected (as further described in this Privacy Policy). We then delete or anonymise such data, in accordance with applicable laws.	More Information.
How can I exercise my rights over my information?	Certain jurisdictions offer users specific rights with respect to their information, so you may have a right to access or receive a copy of your data, or to delete your data or restrict or object to our processing of your data.	More Information.
How will we notify you of changes?	Changes to this Privacy Policy will be posted here. We will also notify you of changes in accordance with relevant legal requirements.	More Information.

Welcome to Project N!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with the Project N (the “Game”), and sets out your choices and rights in relation to that information. Please read it carefully – it will allow you to understand how we collect and use your information, and how you can control it.

Please note that this Privacy Policy only applies to the Game. If you use any other products or services please refer to the privacy policy for that particular product or service.

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Game. By using the Game you are acknowledging how we process your personal information as described in this Privacy Policy.

 

For the purpose of data protection laws, the data controller of your personal information in relation to the Game is  Proxima Beta Pte. Limited. (“we”, “us”, “our”).

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here. You can also reach out to our data protection officer at dpo@levelinfinite.com. We have representatives for data protection purposes listed here.

1.                Children

Children must not use the Game for any purpose, except where their parent or guardian has provided lawful consent (to the extent this option is available in your jurisdiction).

By children, we mean users under the age of 18 years old; or in the case of a region where the minimum age for processing personal information differs, such different age. For users located in certain regions we have listed the relevant minimum age as of the date of this policy in the table below. You should in any case refer to the laws in your jurisdiction to ensure you are above the relevant legal minimum age.

Other than as provided above, we do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without lawful consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us.

Region in which the user is located	Minimum age of the user
Philippines	18
Thailand	20

 

2.                How We Process Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why.

For users who live in Thailand, it also identifies the legal basis under which we process your data. 

Personal Information		Use	Legal Basis (where applicable)
Information you provide to us (either directly or through a third party)
Social Media Information (if you choose to log in via your social media account with these networks) that such social media companies provide: Steam: nickname, avatar (see https://store.steampowered.com/privacy_agreement/).		We use this information to allow you to log in to the Game in accordance with your request.	Necessary to perform our contract with you to provide the Game.
Survey information (via IMUR) (aggregated data): game experience feedback, gender, age range, game username, employment status, and any other personal information you provide in your survey responses.   To the extent you choose to participate in an in-game survey regarding the Game Service, we will redirect you to IMUR Survey to take the survey and the IMUR Survey privacy policy will apply to certain data processed in connection with your participation in the survey.   We only receive aggregated survey data from IMUR.		We use this information to better understand our users and to improve the Service with your consent.	We collect this information with your consent.
Information generated as part of the Game
Information in relation to Game optimization and improvement:  Account information (OpenID, user ID, gameid);  Device and operating system information (including device name, device model, OS information, IP Address, uuid); Location information (fuzzy location information); and gameplay data (including log data, SMS data, avatar data, nickname data, friend list data, Gender information, User personalized signature information, Steam account).	We use this information to operate and provide the Game, including to: review and analyze Game performance for optimization (including network connection and connection and access to server); fix bugs in the Game and resolve crashes and other issues; manage Game resources and version updates; locate and resolve crash issues; and improve our services including the functionality of the Game.			It is in our legitimate interest to use this information to ensure the security of our services, and to optimize and improve our services.
Security and anti-cheating-related information: Account information (including User ID, Game ID), device information, device identifiers (including UUID); location information (including IP address, country/zone); gameplay data (including log data); and screenshots.	We use this information to provide a fair environment, and ensure the security and safety of the services of the Game (through anti-cheat functions like cheating countermeasure and detection based on game replay).			It is in our legitimate interest to use this information to detect and prevent cheating in the Game.
Real time voice chat data: Open ID, device model, device brand, system time, SDK version, Network Type, RegionID.	We facilitate your real time voice chat with other users.			Necessary to perform our contract with you to facilitate communication between users where you seek to use chat services.

3.                How We Store and Share Your Personal Information

Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy.

We have servers for the Game in Singapore. We also have support, engineering and other teams who may support the Game, including from Singapore and the People’s Republic of China.

 

Only where necessary will we share your personal information with third parties. Situations where this occur are:

• Third parties that provide services in support of the Game, including providers of services that process information identified in this policy for the purpose of providing the Game. All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Game (i.e., for the purpose(s) described above).
• Companies within our corporate group who process your personal information solely for the purpose of providing the Game to you.  All such group companies may only use your personal information in accordance with this Privacy Policy.

• Regulators, judicial authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you, such as to comply with legal obligations or processes. In complying  with the terms of valid legal processes, such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in advance of such disclosure.
• Third parties to ensure safety, security, or compliance with laws. We may disclose your information to:
  • enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
  • detect, prevent or otherwise address security, fraud or technical issues; or
  • protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (such as exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
• 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.

4.                The Security of Your Personal Information

We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Game or otherwise via the Internet; any transmission is at your own risk.

 

5.                Data Retention

We do not keep your data for longer than is necessary to fulfil the relevant purpose described above unless we are required or permitted to do so under law. If we retain your information beyond the retention periods set out below, for example to comply with applicable laws, we will store it separately from other types of personal information.

For further details on how long we keep your data, please refer to the time periods set out below.

Personal Information	Retention Policy
Social Media Information Account information Device and operating system information Location information Gameplay data Screenshots	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days.
Real time voice chat data	The realtime voice data will not be saved.
Survey Information	Stored for a year from collection, after which it will be deleted.

 

6.                Your Rights

Some jurisdictions’ laws grant specific rights to users of the Game. Please refer to the Supplemental Jurisdiction-Specific Terms, or the applicable laws in your jurisdiction, for an overview of specific rights that apply to persons subject to data protection laws in the listed jurisdictions and how these can be exercised.

You may have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). You can exercise some of these rights directly by accessing and updating the information in your account. If you believe we hold any other personal information about you, please contact us.

Access

You may have the right to access personal information we hold about you, how we use it, and who we share it with.

Portability

You may have the right to receive a copy of certain personal information we process about you. For example, in certain jurisdictions this can comprise personal information we process on the basis of your consent (e.g., survey information) or pursuant to our contract with you (e.g., account name), as described above in the section “How We Use Your Personal Information”. We will provide further information to you about transferring this data if you make such a request.

Correction

You may have the right to correct personal information we hold that is inaccurate.

Erasure

You may be able to delete your account, or remove certain personal information, by logging into your Game account. 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 defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Game and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only

You may have a right to require that we stop processing the personal information we hold about you (other than for storage purposes in certain circumstances). Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). Where we agree to stop processing the personal information, we will take steps to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You may have the right to object to our processing of your personal information. If you wish to do so, please contact us at dpo@levelinfinite.com or using the contact details set out below, and we will consider your request.

Consent Withdrawal

To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us at dpo@levelinfinite.com. 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. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.

Announcements

We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the Game for maintenance, or security, privacy or administrative-related communications). These are essential system and service-related announcements and you are not able to opt-out of these notifications, which are not promotional in nature.

7.                Contact

Please get in touch with us if you have any questions. You can reach us in the first instance at:

Email: dpo@levelinfinite.com

Mailing Address:

Tencent International Privacy & Data Protection Centre

79 Robinson Rd #07-01

Singapore 068897

We will endeavour to deal with your request as soon as possible. This is without prejudice to any right you may have to launch a claim with a data protection authority in the region in which you live or work where you think we have infringed data protection laws.

8.                Changes

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here and notify you in accordance with relevant legal requirements.

9.                Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this Privacy Policy, the English version shall prevail.

Our Representatives in Certain Jurisdictions

Jurisdiction	Representative	Address	Contact details
Thailand	Tencent (Thailand) Company Limited	8 T-One Building, Floor 10th, 11th & 12th (Unit 3-5), Soi Sukhumvit 40, Sukhumvit Road,  Khwaeng Phra Khanong, Khet Khlong Toei, Bangkok 10110, Thailand	dpo@levelinfinite.com

 

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Game, 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.

Philippines

You are entitled to the following rights:

• Right to be informed. You may in certain circumstances have the right to be informed whether personal data pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.
• Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for direct marketing, automated processing or profiling.
• Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.
• Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.
• Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw or seek the blocking, removal or destruction of your personal information.

 

By consenting to this Privacy Policy, you consent to us:

• collecting and processing your personal information as described in Section 3 (How We Process Your Personal Information);
• sharing your personal information with third parties, companies within our corporate group, and a third party that acquires substantially all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and
• transferring or storing your personal information in destinations outside the Philippines as described in Section 4 (How We Store and Share Your Personal Information)

Thailand

By clicking "accept", you acknowledge that you have read, understood, and agree to the Privacy Policy. If you do not agree with the Privacy Policy, you must not use the Game.

 

If you are under the age of 20, you undertake that you have obtained your parent or legal guardian’s consent to register an account on and use the Game.

 

To the extent provided for by the Thai Personal Data Protection Act (PDPA), you may:

• withdraw your consent to the processing of your personal data (only where the legal basis for our processing is consent); however, please note that where consent is required to process your personal data, we may not be able to deliver the expected service without it;
• request us to provide you access to, make any correction to, cease any automated processing or profiling (if applicable), discontinue, restrict the use or provision of and/or erase your personal data;
• request us to provide you or a third party with your personal data which is stored by us in a machine readable format; and/or
• lodge a complaint to a relevant authority.

 

Where you wish to make such requests, please contact us as set out in Section 8 (Contact).

 

The contact details of our designated local representative in Thailand for the purposes of compliance with the PDPA is as set out in Section 8 (Contact) and can be contacted via email. Please include the word “Thailand” in the subject line of your email.