Welcome to Fate Trigger!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with the closed beta test of the game Fate Trigger (the “Game”) and its official website (the “Website”) (the Game and the Website together, the “Service”), 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 Service. 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 Service. By using the Service 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 Service is Proxima Beta Pte. Limited. (“we”, “us”, “our”).

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

We use cookies and other similar technologies (“Cookies”) to enhance your experience using the Websites for Fate Trigger. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities.

For more information about our Cookies policy, click here.

1. Children

Children must not use the Service 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
Argentina	13
Brazil	18
Canada	13
Hong Kong	18
Indonesia	18
Japan	18
Malaysia	18
Philippines	18
Republic of Korea (PC version)	19
Singapore	13
Thailand	20
United States	13

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 Indonesia and Thailand, it also identifies the legal basis under which we process your data.

Personal Information	Use	Legal Basis (where applicable)
WEBSITE
Information you provide to us (either directly or through a third party)
CBT Registration Data: Email and other information you decide to disclose during the registration process.	We use this information to allow you to register to the Game in accordance with your request. If you are selected for the closed beta test, we will send the activation code to your email. We also use this information to send you news and communication about the Game with your consent.	For registering you for the CBT, we process this information as it is necessary to perform our contract with you to provide the Service. We send you news and communications about the Game with your consent.
Customer Support Data: name, OpenID, device information, login information, steam ID, email address (if contacted via email), details of ticket, complaint and handling, content of correspondence, game data and details of gameplay under review, IP address, and any other personal information you provide to us.	We use this information to: improve our services; and provide troubleshooting, such as addressing and remediating technical issues and bugs.	Necessary to perform our contract with you to provide and support the Service.
Webpage optimization information IP address, visited domain name, device information (device type, screen information, operating system, browser type, browser version, system language, etc.) Page operation logs (page visit records, referrer or exit pages, date or timestamps, clickstream data and similar data)	We use this information to better understand our pageviews and to optimize our webpage performance.	It is in our legitimate interest to use this information to optimize and improve our services.
GAME
Information you provide to us (either directly or through a third party)
Social Media and Platform Information (if you choose to log in via your social media or platform account with these networks) that such social media and platform companies provide: Nickname, avatar, open ID, device name, device model (e.g. see here for Steam Privacy Policy)	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.
Information generated as part of the Game
Game optimization and improvement information: 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, game match data).	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; upload game data; 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. Please note that your real time voice chat content is not retained by our servers. The voice chat function is OFF by default unless specifically enabled.	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 on our Game.
Text Chat Data: Account information (user ID, gameid), message data	We use this information to facilitate the posting of your communications with other users. We also process text chat data to identify, for example, harmful communication, exploits, bullying, harassment, threats of violence or conduct which is hateful, harassing, abusive, racially or ethnically offensive, defamatory, humiliating, threatening, profane or similarly objectionable.	Necessary to perform our contract with you to facilitate the posting of your communications with other users. It is in our legitimate interest to ensure the security and integrity of our service and the safety of our users.
Diagnostic and crash reporting information: Diagnostic logs such as user ID, device identifiers, CPU, storage, network status.	We use this information to perform troubleshooting and locate and resolve crashes, latency issues and other errors.	It is in our legitimate interest to fix issues and improve the operation of the Game.
Bug-fixing data: User Identifier: OpenID; Device Information: Operating system, Device ID, CPU, GPU, model of the device, and memory; Logs that include device ID, player ID and other device information; Network Information: Network type, IP address and other similar information	We use this information to identify and fix bugs.	It is in our legitimate interest to fix bugs and improve the operation of the Game.
Advertising Information (AppsFlyer): Technical information: technical information related to your device Technical identifiers: unique identifiers that generally only identify your device, browser, vendor or application such as IP address, advertising ID, Open ID and user agent Network data such as IP address Engagement information: your interactions with our advertisement campaigns	We use this information for ad attribution purposes.	It is in our legitimate interest to carry out data analytics for ad attribution purposes to understand how our users interact with advertisements.
Survey information : Game experience feedback, gender, age range, game username, employment status, your device information (such as device model and components), gaming habits and preferences (such as games played), steam id, email, 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 Service, we may 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. If you choose to participate in a survey hosted on third parties’ platforms or otherwise conducted by third-party service providers, their terms of use and privacy policy also apply to the data processed.	We use this information to better understand our users and to improve the Service with your consent.	We collect this information with your consent.

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 Service in Ireland, Singapore and the United States. We also have support, engineering and other teams who may support the Service, 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 Service, including providers of services that process information identified in this policy for the purpose of providing the Service, including to enable you to login via a social media account, and for the purpose of providing marketing and advertisements and monitor the success of our marketing and advertising programs. 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 Service 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 Service 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
WEBSITE
CBT Registration Data Customer support data Webpage optimization information	30 days after CBT for CBT Registration. Others: 30 days since completion of the purpose for which the data is collected
GAME
Social Media and platforms Information Game optimization and improvement information Security and anti-cheating-related information Customer Support Data News and Communications	Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then deleted within 30 days.
Real time voice chat	The realtime voice data will not be saved. Other data such will be stored for 30 days.
Survey Information	Stored for the duration of the Service, until account deletion in accordance with user's request, upon which it will be deleted within 30 days. Where user does not request for account deletion, such data will be retained for 30 days after the Game is shut down, before it is deleted
Diagnostic and crash reporting information Bug-fixing data Advertising Information (AppsFlyer) Text chat data	Stored for 30 days, after which it will be deleted.

6. Your Rights

Some jurisdictions’ laws grant specific rights to users of the Service. 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 Service 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 Service 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 via Section 7 (Contact) 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 via Section 7 (Contact). 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 Service 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

You can reach us using our online form HERE to submit Data Subject Rights requests and any questions or concerns related to data privacy. This DSR Form also allows you to contact our Data Protection Officer regarding your privacy-related inquiries.

If you are an agent or official of a regulatory authority and have a specific data and privacy regulatory inquiry, please use our Data and Privacy Regulatory Inquiry Form HERE.

We will make every effort to address your request as quickly as possible. This does not affect your right to file a complaint with a data protection authority in your region if you believe we have violated data protection laws.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S. based third-party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request.

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.

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

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

Argentina

If you are dissatisfied with our response to your request for access to, correction, or erasure of your personal information or your privacy complaint in respect of your personal information, you may contact the Agency for Access to Public Information at: Av. Pte. Gral. Julio A. Roca 710, Piso 2°, Ciudad de Buenos Aires (Telephone: +5411 3988-3968 or email: datospersonales@aaip.gob.ar). While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, by providing your personal information and by using the [Service], you consent to the transfer of your personal information to a jurisdiction where privacy laws may not offer the same level of protection as the laws that may apply in Argentina.

Brazil

Whenever we use your personal information based on your consent, you may revoke the consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account or you can contact us as set out in Section 7 (Contact). This may affect our provision of the Game to you.

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORISE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

Canada

If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us. Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.

Hong Kong

As a Hong Kong data subject you have legal rights in relation to the personal information we hold about you (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to receive a copy of the data we process about you, a data correction request as well as a right to reject to the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.

Indonesia

By accepting and consenting to this Privacy Policy, you agree that we may collect, use and share your personal information in accordance with this Privacy Policy, as revised from time to time. If you do not agree to this Privacy Policy, you must not access or use our services and we have the right to not provide you with access to our services.

If you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Service.

In the event we fail to maintain the confidentiality of your personal information in the Service, we will notify you through the contact information provided by you or via the Service, to the extent required by local laws and regulations.

You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

Japan

If you are under the age of 18, you must obtain your parent’s or legal guardian’s consent to register an account on and use the Service.

By accepting the Privacy Policy, you consent to the transfer of your personal information to third parties (if any), which may include the cross-border transfer of your information to any country or region where we have databases or affiliates and, in particular, to the jurisdictions specified in Section 3 (How We Store and Share Your Personal Information).

The categories of personal information specified in Section 2 (How We Process Your Personal Information) may include "special care-required personal information" (i.e., sensitive information as detailed under applicable law), and you consent to the collection of such information.

You may request us to notify you about the purposes of use of, to disclose, to make any correction to, to discontinue the use or provision of, and/or to delete any and all of your personal information which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contact us.

Malaysia

In the event you are agreeing to this Privacy Policy in order for a minor to access and use the Service, you hereby consent to the provision of personal information of the minor to be processed in accordance with this Privacy Policy and you personally accept and agree to be bound by the terms in this Privacy Policy. Further, you hereby agree to take responsibility for the actions of such minor, and that minor’s compliance with this Privacy Policy.

Right of access: You have the right to request access to and obtain a copy of your personal information that we have collected and is being processed by or on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law. When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

Right of correction: You may request for the correction of your personal information. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.

Right to limit processing of your personal information: You may request to limit the processing of your personal information by contacting us. However, this may affect our provision of the Service to you.

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

Our data protection officer, responsible for the management and safety of your personal information
- Telephone: +603-22872388
- Email: as set out in Section 7 (Contact)

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 2 (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 3 (How We Store and Share Your Personal Information)

Singapore

By accepting this Privacy Policy, you consent to the collection, use and disclosure of personal data as set out in this Privacy Policy, including cross-border transfer of your information to any country or region where we have databases or affiliates and, in particular, the locations specified in Section 3 (How We Store and Share Your Personal Information). In situations where consent is not obtained, Proxima Beta collects, uses, or discloses personal data in accordance with an exception under the Personal Data Protection Act 2012 or as required or authorized by any other applicable law.

You have the right to access your personal information, how we use it, and who we share it with. You have the right to correct any of your personal information that is inaccurate.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted here.

Republic of Korea

Collection and Use of Personal Information

We collect your personal information for the purposes described in this Privacy Policy. Personal information that we collect from Republic of Korea is stored in and processed on our server located in Singapore.

With regards to the legal basis of processing personal information included in Section 2 “How We Process Your Personal Information,” the following legal provisions under the PIPA applies:

- (for consent): we use this information pursuant with your consent, pursuant to Article 15(1)(1) of the PIPA.

- (for complying with legal obligations): we use this information where necessary to comply with a legal obligation pursuant to Article 15(1)(2) of the PIPA.

- (for contractual necessity): we use this information where necessary to perform our contract with you to provide our Services, pursuant to Article 15(1)(4) of PIPA.

Third-Party Provision of Personal Information

We provide your personal information to third parties as described below:

Legal Grounds

Name of Recipient (and contact information)

Types of Personal Information provided

Purpose of Use by Recipient

Period of Retention and Use by Recipient

Consent – PIPA Art. 17(1)(1)

Valve, Facebook, Google, Apple, X

Relevant login information

To allow you to log in to the Game in accordance with your request

In accordance with the Steam Privacy Policy.

Legitimate interest – PIPA Art. 17(1)(2), 15(1)(6)

Appsflyer

(https://www.appsflyer.com/services-privacy-policy/)

(United States unless otherwise described in the service provider’s privacy policy)

Advertising information

Ad attribution and to understand how our users interact with advertisements

In accordance with the Appsflyer privacy policy

Delegation of Personal Information

For the performance of the services detailed in this Privacy Policy, we delegate the processing of your personal information to the following professional service providers in accordance with Article 26 PIPA:

Delegatee	Description of Delegated Services
Aceville Pte. Ltd.	Storage of personal information

Overseas Transfer of Personal Information

We transfer personal information to third parties overseas as follows:

Legal Grounds	Recipient (Contact Information of Information Manager)	Country or Region to which Your Personal Information is to be Transferred	Date and Method of Transfer	Types of Your Personal Information to be Transferred	Purposes of Use by Recipients	Period of Retention of Use by Recipient
Delegation and Retention for Contractual Performance - PIPA Art. 28-8(1)(3)	Aceville Pte. Ltd. (cloudlegalnotices@tencent.com)	Singapore, United States, Ireland	Transferred via information and communications network at the time of service use	All personal information collected	Storage of personal information	For the data retention period specified under “Data Retention”
Legitimate interest – PIPA Art. 17(1)(2), 15(1)(6)	Appsflyer (https://www.appsflyer.com/legal/privacy-policy/)	Belgium and Ireland or otherwise provided in Appsflyer’s privacy policy	Transferred via information and communications network at the time of service use	Advertising information	Perform data analytics and app attribution analysis.	In accordance with the Appsflyer privacy policy
Consent – PIPA Art. 17(1)(1)	Valve, Facebook, Google, Apple, X	United States or otherwise provided in platforms’s privacy policy	Transferred via information and communications network at the time of service use	Platform login information	To allow you to log in to the Game in accordance with your request	In accordance with the platform privacy policy

You may refuse the overseas transfer of your personal information by contacting our Data Protection Department. If you refuse the overseas transfer of your personal information, your personal information will not be transferred overseas. However, you may not be able to use our services for which overseas transfer of personal information is necessary.

Data Destruction

Personal information is retained in accordance with the data retention periods as detailed in section “Data Retention”. With the exception of the personal information set out below, personal information, which has fulfilled the purpose for which it was collected or used, and has reached the period of time during which personal information was to be possessed, will be destroyed in an irreversible way. Personal information stored in electronic files will be deleted safely in an irreversible way by using technical methods, and printed information will be destroyed by shredding or incinerating such information.

The personal information detailed in section “Data Retention” are required to be retained pursuant to the following laws:

Act on the Consumer Protection in Electronic Commerce, Etc.

Article 6 of the Act on the Consumer Protection in Electronic Commerce

In an electronic commerce or a mail-order sale:

Records regarding labelling and advertising (6 months)
Records regarding execution or withdrawal of a contract (5 years)
Records regarding the payment of a price and the supply of goods and services (5 years)
Records regarding customer services or dispute resolution (3 years)

Protection of Communications Secrets Act

Article 41 of the Decree of the Act, Article 15-2 of the Protection of Communications Secrets Act

Log records, IP address (3 months)
The date of telecommunications by users, the time that the telecommunications start and end, the frequency of use (12 months)

Your Rights

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, or objecting to or requesting an explanation on an automated decision concerning your personal information, etc. pursuant to applicable laws such as the Personal Information Protection Act (“PIPA”). You may also exercise these rights through your legal guardian or someone who has been authorized by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Enforcement Regulations of the PIPA. You can also withdraw your consent or demand a suspension of the personal information processing at any time.

Additional Use and Provision of Personal Information

In accordance with the PIPA, we may use or provide personal information within the scope of reasonably related to the initial purpose of the collection, in consideration of whether disadvantages have been caused to data subjects and whether necessary measures have been taken to secure such as encryption, etc. We will determine with due care whether to use or provide personal information in consideration of general circumstances including relevant laws and regulations such as the PIPA, purpose of use or provision of personal information, how personal information will be used or provided, items of personal information to be used or provided, matters to which data subjects provided consent or which were notified/disclosed to data subjects, impact on data subjects upon the use or provision, and measures taken to protect subject information. Pursuant to Articles 15(3) and 17(4) of the PIPA, we consider the following factors set forth in Article 14-2 of the Enforcement Decree of the PIPA when using or providing to a third party additional personal information without your consent:

whether the additional use/provision is related to the initial purpose of the collection;
whether the additional use/provision is foreseeable in light of the circumstances under which personal information was collected and practices regarding processing;
whether the additional use/provision unfairly infringe on the interests of the data subject; and
whether the necessary security measures such as pseudonymization or encryption were taken.

Measures to Ensure Safety of Personal Information

We implement the following measures to ensure safety of your personal information:

1. Managerial measures: establishment and implementation of internal management plan, operation of dedicated organization, regular employee training

2. Technical measures: management of access rights to the personal information processing system, installation of an access control system, encryption of personal information, and installation and renewal of security programs

3. Physical measures: access control of computer rooms, data storage rooms, etc.

Domestic Privacy Representative

Pursuant to the Article 32-5 of Network Act and Article 31-2 of the amended PIPA, the information regarding the domestic agent is as follows:

Name: Kite Bird Korea Yuhan Hoesa
Address: 25F, 55, Sejong-daero, Jung-gu, Seoul (Taepyeongro 2-ga), Republic of Korea
Telephone: +82-2-2185-0926
Email: See Section 7 (Contact)

Contact

Data Protection Department, responsible for the management and safety of your personal information
Telephone: +82-2-2185-0926
Email: See Section 7 (Contact)

Remedies for Infringement of Rights and Interests

In order to seek remedies for personal information infringement, you may file an application for dispute resolution or consultation with the Personal Information Dispute Mediation Committee, the Korea Internet & Security Agency's Personal Information Infringement Reporting Center, etc. In addition, you may contact the following institutions for other reports and consultations on personal information infringement:

Personal Information Dispute Mediation Committee: (no area code required) 1833-6972 (www.kopico.go.kr)
Personal Information Infringement Report Center: (no area code required) 118 (privacy.kisa.or.kr)
Supreme Prosecutors’ Office: (no area code required) 1301 (www.spo.go.kr)
National Police Agency: (no area code required) 182 (ecrm.cyber.go.kr)

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 Service.

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 Service.

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 7 (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 7 (Contact) and can be contacted via email. Please include the word “Thailand” in the subject line of your email.

United States

For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”), and respectively include the terms “personal data” and “sensitive data” as defined in the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”), (collectively, “US State Laws”). The terms do not include information excluded from the scope of US State Laws.

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed for a business purpose the following categories of personal information, including sensitive personal information (denoted by *), from or about you or your device:

Identifiers, such as your nickname as it appears on your social media profile, Open ID / user ID, IP address, device ID, email address, and nickname. This information is collected directly from you and your device and from social media platforms if you choose to sign up using a social media account.
Characteristics of protected classifications under California or federal law such as national origin, gender, or age. This information is collected directly from you in the context of being our consumer or, if you choose to set up your profile using a social media account, your gender may be provided by your social media account provider, or otherwise if you choose to provide us such information when you respond to our surveys.
Internet or other electronic network activity information, such as your information regarding your use of the Service, including gameplay data and other Device Information as described in the main Privacy Policy. This information is collected directly from you and your device.
Geolocation information such as your region location when you set up your profile and choose to provide this information for the Service. This information is collected directly from you.
Audio and visual information such as your social media profile picture or avatar, and audio messages. This information is collected directly from you and from social media platforms if you choose to sign up using a social media account, or when you use our in-Game chat features.
Professional or employment-related information such as your profession if you choose to provide it in a survey. This information is collected directly from you.
Account log-in information, including the username and password used to access your Service account.*
Contents of your chat messages sent on Service*. This information is collected from your device, and stored for security related matters and automatically deleted after 30 adys.

We collect and disclose your personal information, including sensitive personal information, for the following purposes:

To provide you with the Service, maintain your account, provide customer service, and deliver audio and text messages.
To process surveys.
To improve our services, including the functionality of the Service.
For security and verification purposes, including to prevent and detect fraudulent activity.
To address and remediate technical issues and bugs.

For additional information about what each type of personal information is used for, see Section 2 (How We Process Your Personal Information).

We disclose each of the categories of personal information that we collect as described in Section 3 (How We Store and Share Your Personal Information).

In the past 12 months, we have not sold or shared personal information of California residents within the meaning of “sold” and “share” in the CCPA. And we have no knowledge of any sale or sharing of personal information of users under 16 years of age.

In addition, we do not use or disclose sensitive personal information for purposes other than to perform the services reasonably expected by an average consumer who requests those services or as otherwise permitted by US State Laws.

Retention of Your Personal Information

The retention period varies among the different categories of data collected. For detailed information about the retention period for any specific category of data, see this chart in the main portion of the Privacy Policy.

Rights under US State Laws:

Depending on where you live, you may have some or all of the rights listed below in relation to information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.

Right to Access/Know. Request we confirm whether we process information about you and give you access to that information. You may also request to receive that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment. If you are a California resident, you may request the following information about our collection, use and disclosure of your information:
- the categories of personal information about you that we collected;
- the categories of sources from which the personal information was collected;
- the business or commercial purposes for collecting personal information about you;
- the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
- the specific pieces of personal information we collected about you;
Request to Delete. Request we delete personal information we collected about you;
Request to Correct. Request we correct inaccurate personal information that we maintain about you; and
Right to Non-Discrimination. Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the US State Laws.

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. Depending on where you live, you may also exercise your rights, if any, regarding other data by contacting us. We may take steps to verify your identity before complying with your request to protect your privacy and security, and may decline your request if we are unable to verify your identity. To verify your identity, we may need the following information from you: your first name, last name, address, phone number, date of birth and email address.

Depending on where you live, you may exercise these rights yourself or you may also designate an authorized agent to make these requests on your behalf. In order for us to process the request, you must provide the authorized agent with signed written permission. We reserve the request to require the agent to verify their own identity and to confirm directly with you that you have provided the authorized agent permission to submit the request.

In addition, where applicable, we will provide you with more information about our appeal process. When you submit a request or launch an appeal, we will limit our collection of your information to only what is necessary to securely fulfil your request or process your appeal. We will not require you or your authorized agent to pay a fee for the verification of your request or appeal.

Questions

If you have questions or concerns regarding this Privacy Policy, please contact us.

What information do we need to be able to provide the Service?	If you use the Website to register for the Game, we will collect your email. 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 and device information. We will also generate an Open ID, which is an internal ID for your account. 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. The Game also allows players to communicate directly with each other via the text chat and audio chat functions. Player communication is a key part of players’ experience on the Game. Note that the audio chat function is OFF by default unless specifically enabled. The Game might allows players to have the option of sharing their leaderboard rankings, screenshots of their gameplay, chat conversations and other gameplay information in-game with friends and/or on social media platforms of their choice, and/or other related services and such information may reveal personal information such as their usernames and chat conversations with other players (if applicable). Your profile information and user content may be visible to other users, for example when you participate in events or activities (e.g. in-game challenges), or when other users want to see your level and stats (if applicable). Some of these functions can be managed in the settings. 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 Service, 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 Service (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 Service in Singapore, Ireland and the United States. We also have support, engineering and other teams who may support the Service, 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 Service, 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.