We are High Morale Developments Limited, a Hong Kong-incorporated company. Together with our group companies, we operate globally to provide you services and products and a lot of fun!

What does this policy apply to?

This Privacy Policy describes how we handle, collect, use, share and process your personal information when you use our Services.
By “Services”, we mean any of our products or services – including games available on PC, mobile and/or website and relevant eSports, events and activities – that link to this Privacy Policy.
Only Services that link to this Privacy Policy are covered by it. Some other High Morale products and services have their own specific privacy policies and will not link to this Privacy Policy – in those cases, please read the product or service-specific policy.

How to read this policy.

We want to make this Privacy Policy easy to understand and concise, so you know where to find the relevant information:

For our general principles and practices for handling personal information across our Services, please read this Privacy Policy.
For other details about our privacy practices, please scroll down to the Privacy Portal’s Additional Information section where you can find information such as our Children’s Privacy Policy, our contact information, etc.
If you have further questions or need more information, please refer to the Contact Us section below. Our team is ready to assist you with any privacy-related inquiries.

2. Data controller and how to contact us

In this Privacy Policy, we will call the entity that is responsible for your information “High Morale” (and terms like “we”, “us”, etc.).

However, you can find information about the name of the specific data controller for your Service, as well as their contact details and local representatives (if applicable), in the Privacy Portal’s Additional Information section below.

3. Children

Our Service is not intended for children. Children must not use the Service for any purpose. By children, we mean users under the age of 16 years old; or in the case of users located in a country where the minimum age for processing personal data differs, the minimum age specified under law. We do not knowingly process personal information from children for any purpose. If you believe that we have personal information concerning a child under the age set out above without lawful basis, or if you are the parent, guardian or other person with parental responsibility of the child user and wish to withdraw consent, please contact us (see Contact Us section).

4. What information do we process?

We process information in the following ways:

when you directly provide it to us;
when you interact with us;
when you use our Services; and
when we receive information from third parties.

The following is a summary and provides relevant examples of the types of personal information we process:

A. Information you directly provide to us

ⓘ We will process personal information that you directly provide to us, such as:

If you create an account with us, we will process basic registration information that you provide such as your nickname, the country you live in, your email address, mobile phone number, etc.
When you make purchases on our platform, we will ask for your payment-related information such as credit card number and expiration date.
We will also process information you voluntarily provide, such as when you use our social features to send a message or share a photo or sign up for/or attend an event.

Examples of information you directly provide to us include:

When you create and manage an account, we will process the registration and account information you provide such as your nickname, date of birth (though date of birth is not stored), email address, mobile phone number, password and similar.

If you make a purchase or transact on our platform, we will process payment and billing information such as your credit card number, expiry date, CVC, first name and family name, email address, billing address and similar.

If you use social features within our Services, such as finding your friends that use the same Service and sending, uploading or publishing text, audio, visual and/or other electronic communications information to us, to another user or to a wider group or forum, we will process the information you provide.

If you respond to our surveys and other enquiries in relation to our Services, we will process your feedback (in particular, your user ID, age, gender, contact information, other responses you choose to provide and similar).

If you interact with us, such as seeking customer support (either through chatting with our staff or interacting with an AI-powered chatbot) or submitting a data request, we will process the information you provide such as user ID, email, any evidence you submit for investigation and similar.

If you sign up for our communications or email alerts, for example, about our Services updates and exciting upcoming games, events or activities, we will process the information you voluntarily provide to us.

If you sign up and participate in events we organise (such as e-sports events or community events), we will process the information you provide such as your user ID, your team’s name, team’s logo, date of birth, country, contact information, name on your passport, postal/zip code and address and similar.

If you engage with certain functions of our Services, for example, sending text, audio or images to our AI-driven functions for creative output or granting us access to specific content such as a selected photo album on your device, we will process the information you provide.

B. Information we process when you interact with us

ⓘ Information we process when you interact with us (e.g. when you play games or participate in relevant activities and events) includes:

Depending on the game you play, we will generally process information about your in-game profile, your gameplay data and your other interactions with us and other players.
If you sign up to participate in certain tournaments or events, we may take photos, video record and/or livestream these tournaments or events, in which case certain data relating to you or your team (such as your game performance) will be processed, captured and displayed on public platforms for a broader audience to enjoy.

Information we process includes:

Player’s identity, role and appearance: user ID, role name, role ID, skin and similar.

Gameplay data: your in-game actions (e.g., movement, hit and kill), weapons, level, scores, in-game currency, gameplay performance, start and end times, task completion records, achievements and other relevant behaviour and performance information about your interaction with the game.

Team and social: information such as your performance with friends and other players, rankings, leaderboards and similar.

Gameplay time: for users in certain regions, we will process gameplay time data such as your daily cumulative gameplay time and your daily rest time to prevent gaming addiction.

Photos, video clips and livestreams: in some cases, such as when you enable our replay function (if applicable) or when we capture in-game video clips for anti-cheating and security review, we will collect and process game photos, screenshots, video clips and similar. If you choose to participate in the events and tournaments, we may also take photos, video and/or livestream these events and tournaments.

C. Other information we automatically process when you use our Services

ⓘ We also process some information automatically when you use our Services, such as:

Your usage information reflecting how you interact with us.
Information about your device and hardware.
Your transaction information.
Approximate and precise geolocation data.
Data that allows us to prevent cheating and verify compliance with our terms with you.

Information we automatically process when you use our Services includes:

Usage information and statistics about how you interact with our Services, including your website/application usage, saved preferences, crash reports, the URLs of websites that you have visited, time spent on a page, last active time, session count, your clicks on certain pages, your interaction with ads such as any ads you click and the type of ad you view and similar.

Technical information about your device, hardware, software and network, such as your hardware identifiers, hardware-related information, device brand and manufacturer, screen resolution, recharge and consumption record, WiFi-related data such as strength and speed and other network information.

Browser information, including your browser type, browser version, language preference and similar.

Limited approximate geolocation data that is derived from your IP address, internet connection or device (if applicable) in Services with enabled features including finding your friends or locating players near you, etc.

Precise geolocation data that is derived from your GPS in Services with enabled features, including finding your friends or matches, etc.

Transaction information such as purchase history, details of transaction (such as transaction time, items purchased, cost and currency) and similar.

Anti-cheating and security- related information including your hardware information, data relating to the presence of restricted files and emulators or restricted modifications to files and other data revealed by anti-cheat testing.

Information used for checking your compliance with terms you agreed with us, including the end-user licence agreement (EULA) and other similar agreements.

ⓘ Cookies and other technologies

We use a variety of technologies such as cookies, software development kits (SDKs), log files and analytics tools to automatically process types of information listed above. If the Services you use that have cookies:

You can control the use of cookies at the individual browser level.
If you reject some or all cookies, you will usually still be able to use our websites and Services, but your ability to use or enjoy features or areas of our websites may be limited or deactivated.

For further information, please refer to our Cookies Policy here.

D. Information we receive from third parties

ⓘ In some cases, we will process information about you received from third parties, including:

Information we receive from third parties in connection with your use of our Services, for example, when you login through your account from a third-party platform (such as QQ, WeChat, Meta, Vkontakte, X, Google Play, Line, Apple, Steam, XBOX, etc.), we will process information such as your user ID, nickname, profile picture, user token and email address associated with that account.
Information we receive when other players share their friend/contact list from a third-party platform with us.
Selected partners who are permitted to share additional information or insights about or similar to you (specifically, to help our understanding what you are enjoying about our Services or advertisements you may enjoy). If you interact with an advertisement on an external website, the company that operates that website may share some information with us in accordance with its own privacy practices.

5. How do we use your information?

We use your information to help us provide, improve, customise, analyse and promote our Services, including:

providing the experiences, products and services you request and engage with, such as enabling and facilitating your participation in games and events and fulfilling orders you request.

providing customer support, such as addressing a complaint and handling a data request.

operating, developing and improving our Services and enhancing user experience.

managing alpha, beta, early access and patch tests and collecting feedback from players who seek to participate in tests.

personalising your experience, including presenting content or features better tailored to your interests and leveraging AI tools to generate content (e.g. personalised gaming content).

identifying, fixing and troubleshooting bugs or functionality errors.

assessing and improving the quality of our Services and products, such as using your device and network information to analyse gaming performance quality on different device models and networks to optimise your experience.

undertaking data analysis and research to better understand our players and market and further develop and update our Services.

securing our Services by detecting security incidents and protecting against cheating, malicious, deceptive, fraudulent or illegal actions.

communicating our new products, services, enhancement, offers, promotions or other information to you.

marketing and showcasing our Services, such as promoting our Services in our platform as well as third-party platforms, managing and measuring the effectiveness of our advertisements and sending you information about our products, services and events tailored to your interests.
performing or providing information in connection with audits, transactions and other compliance activities as well as complying with our legal or contractual obligations.

other purposes that are set out in the Additional Information section or are otherwise disclosed to you on or prior to processing your personal information.

We also handle information that does not personally identify you, such as aggregated or de-identified data that we generate. This data helps us gain insights into larger user groups. Our Privacy Policy does not limit our ability to process data that does not personally identify you, and we may use and share aggregated or de-identified data for any legally permissible purpose.

6. Legal basis for processing

The legal bases we rely on to process your personal information vary and depend on multiple factors, including: (i) the Services you use; (ii) the type of personal information involved; (iii) the context within which we process your information; and (iv) your country of residence.

The following table provides you an overview of legal bases we rely on, the corresponding purposes for processing, and the types of processed information.

If the legal bases below are not applicable in your jurisdiction, by using the Service you consent to the collection, use, disclosure, transfer, processing, export (to the extent permitted by applicable laws) and storage of your personal information as described in this Privacy Policy.

Basis	Why	Examples of data categories
Contract	It is necessary to perform our contract with you to: provide the experiences, products and services you request and engage with, such as enabling and facilitating your participation in games and events (including using the social features therein) and fulfilling orders you request.	Registration and account information (e.g., nickname, date of birth (though date of birth is not stored), age, email address, mobile phone number and other registration info when you sign up for activities and tournaments) Account linking (e.g. if you log in using Meta, we import information such as user ID, nickname, profile picture, email address associated with that account) Information we process when you use social features within our Services (e.g., text, audio, visual communications) Payment and billing information (e.g., credit card number, expiry date, CVC, email address, billing address)
Legitimate Interests	For our legitimate interests or those of a third party (such as a transaction counterparty or lender) to: provide you with customer support.	Information we process when you seek customer service (e.g., user ID, email, any evidence you submit for investigation)
	identify, fix and troubleshoot bugs or functionality errors.	Information we process for data analytics to fix bugs and monitor quality (e.g., device and network information)
	undertake data analysis and research to better understand our players and market, personalise your experience and further develop our Services.	Gameplay information (e.g. in-game actions and behaviours, in-game currency, gameplay time) Transaction information (e.g. purchase history)
	assess and improve the quality of our Services and products, such as analyse gaming performance quality on different device models and networks to optimise your experience.	Technical information about your device, hardware, software and network (e.g., hardware-related information, device brand and manufacturer, WiFi-related data)
	secure our Services by detecting and preventing security incidents and protecting against cheating, malicious and deceptive actions and to maintain a fair environment for our games and Services.	Anti-cheating and security- related information (e.g., hardware information, cheat tool detection information (e.g. device data), data relating to the presence of restricted files and emulators, reported chat messages or screenshots, player reports, data of players suspected of cheating, malicious content information (e.g. nicknames, profile photos, chat histories, audio self-introductions))
	monitor compliance with our terms.	Information used for checking your compliance with terms you agreed with us (e.g., the end-user licence agreement (EULA))
	engage in commercial transactions (for example, if a third party acquires our business)	Registration and account information
	manage and measure the effectiveness of our advertisements.	Advertising engagement and interaction information (e.g., information about your interaction with ads)
Legal Obligations	It is necessary to fulfil an applicable legal or regulatory obligation to which we are subject, in order to: comply with requests from regulatory, governmental, tax and law enforcement authorities. carry out audit checks. prevent and detect fraud.	Information we process to identify abuse, harassment or illegal actions (e.g., user ID, nickname, profile picture, reported chat messages or screenshots) Information we provide in response to requests from law enforcement or other government authorities
	meet the legal obligations we have to you, such as handling a data access request.	Information we process when you initiate a data subject request (e.g., user ID, email address)
Consent	We also process your information based on your consent (where such consent is required by law) to: send you email or in-game notifications about our new promotions, products and activities.	Email address and user ID
	participate in our surveys or tests.	Information we process when you respond to our surveys and other enquiries (e.g., user ID, age, gender, nickname, location, contact information)
	participate in our events and activities that may capture and showcase your performance.	Information we process when you participate in tournaments or events (e.g., user ID, gameplay data, game photos, screenshots, video clips)

7. Where do we store your information?

Data storage: Our corporate group operates around the world and we have servers in different locations including (but not limited to) Hong Kong, Singapore, Japan, Korea, Malaysia, the United States of America and Germany. Depending on your location, your personal information will be processed on servers that may not be located where you live. The servers applicable to your use of our Services will also depend upon your location.

Data transfers:

Where? We may transfer your information outside the location in which you are based for the purposes described in this Privacy Policy. Additionally, your information can be accessed from places outside where you live by our supporting, engineering and other teams around the world, and may be transferred to our affiliates, group members, service providers and business partners in accordance with this Privacy Policy. Furthermore, if we undergo a business transition such as merger or acquisition by another company, or sale of all or part of our business or assets, your information may be among the assets transferred (and handled in accordance with applicable law). Those countries may not have the same data protection laws as the country in which you initially provided the information.
How? Some countries impose restrictions on data transfers outside their territories. This includes, for example, transfers outside the UK and the European Economic Area (“EEA”). Where we transfer personal information across borders, we will ensure we implement appropriate safeguards to protect your information as required under applicable data protection law. Specifically: (i) for transfer between our group companies, we have put in place intragroup data transfer agreements that incorporate applicable standard contractual clauses (“SCCs”) approved by relevant authorities; (ii) for transfers not covered by point (i) or to third parties and vendors located outside of the UK, EEA or other territories with data transfer restrictions, we rely on various legally recognized transfer mechanisms including your explicit consent, agreements incorporating SCCs, adequacy decisions issued by relevant authorities and other appropriate safeguards. The specific transfer mechanism used depends on the recipient party, their location and the applicable legal requirements.

Please refer to the Additional Information section for more information regarding where the data is stored and may be further transferred for that specific game. Some of these countries benefit from adequacy decisions, which can be found here for transfers from the EEA, and here for transfers from the UK. The SCCs for transfers from the EEA are available here and from the UK are available here (we generally rely on Modules 1 and 2).

8. Who do we share your information with?

Only where necessary, we may disclose your personal information to the following recipients. Please refer to Additional Information section for specific disclosure (if applicable).

Third-party providers that provide services in support of our Services, including providers of cloud services, ad attribution providers, providers that carry out surveys, providers and carriers who send authentication messages, service providers that conduct data analytics, push notifications and payment and marketing services. 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 supporting our Services.
Third-party partners that we collaborate with in providing and delivering our Services, including app stores where you download our applications, social media platforms if you select to login through your account on those platforms or otherwise choose to share certain information on social media platforms linked through our Services, and analytics and marketing companies. These companies will process your personal information and govern your use of their services and products in accordance with their terms and privacy policies.
Companies within our corporate group who process your personal information where necessary for purposes set out in this Privacy Policy, including delivering and securing our Services and conducting data analytics to improve and promote our Services or the products and services of our corporate group.
Regulators, judicial authorities and law enforcement agencies: there are circumstances where we are legally required to disclose information about you, such as to comply with legal obligations or processes or where we have determined that it is necessary to share your personal data to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries. In complying with the terms of valid legal processes, such as a subpoena or search warrant, 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 also disclose your information to:
- enforce our terms and conditions and other agreements, including investigation of any potential violation;
- detect, prevent or otherwise address security, fraud or technical issues; and
- 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.

9. How do we protect your personal information?

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. We use a range of technical and organisational measures designed to protect your personal information from accidental, unlawful or unauthorised destruction, loss, alteration and access. In addition, we request vendors who process personal information on our behalf to take reasonable measures designed to help protect your personal information.

However, the transmission of information via the internet is never completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted as part of our Services or otherwise via the internet; any transmission is at your own risk. You also play an important role in the security of your account, and we encourage you to set a reasonably complex password and change your password periodically.

10. How long do we retain your information?

The retention period for your information varies depending on the categories of personal information we process and how you interact with our Services. We retain your personal information for as long as necessary to fulfil the purposes outlined in this Privacy Policy unless a longer retention period is required by applicable laws.

We will retain your information in line with our retention policies, and the main criteria we consider in determining specific retention periods includes relevant legal requirements and industry standards, the types and nature of information involved and relevance to potential dispute.

Data Categories

Retention Periods

Registration and account information (e.g., email address, mobile phone number, password for account creation or log-in)

Stored for the duration of your use of our Services (i.e. until you delete your account/information, request us to delete your information or we decide to shut down the relevant Services)

Gameplay data (e.g., in-game actions and behaviours, in-game currency, gameplay time)

Information we process when you use social features within our Services (e.g., text, audio, visual and/or other electronic communications)

Information we process when you respond to our surveys and other enquiries (e.g., user ID, age, gender, contact information)

Payment and billing information (e.g., credit card number, expiry date, CVC, email address, billing address)

Stored for the duration of your use of our Services (i.e. until you delete your account/information or request us to delete your information) and then for the duration of any retention periods for which such data must be retained in order to comply with legal obligations.

Information we process when you seek customer service (e.g., user ID, email, any evidence you submit for investigation)

If the customer support is processed by us, data will be stored for the duration of your use of the Services (i.e. until you delete your account/information, request us to delete your information or we decide to shut down the relevant Services)

For information relating to relevant events or activities (e.g., tournament registration information, your address for us to deliver prizes to you)

Stored for the duration of the event plus a limited duration (e.g., 30 days or 1 year, depending on the Service/event). However, we may retain event-related photos and videos for a longer period for promotion and analytical purposes until we find they no longer serve our purposes.

Anti-cheating and security-related information (e.g., video clips of suspected cheating activity and device information)

Stored for a short period of time such as 30 days depending on specific data unless any violation or suspected violation is found, in which case we will store relevant evidence for the lifetime of your use of our Services plus a reasonable period thereafter (in particular, for the purpose of managing a potential future dispute).

Kindly note that there will be a gap between the time you request us to delete your information and the day we execute your instructions. For further information, please see section ‎11 (What are your rights and how to exercise your rights?).

We conduct periodic review of our retention policy to ensure it aligns with our commitment to protecting your privacy and best practices.

11. What are your rights and how to exercise your rights?

You have certain rights in relation to the personal information we hold about you. We respect and uphold your rights and, depending on where you are located, your rights to your personal information vary and may include the following rights:

A. Access

The right to access personal information we hold about you, how we use it and who we share it with.

B. Portability

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 section ‎5 (How do we use your information?). We will provide further information to you about transferring this data if you make such a request.

C. Correction

The right to correct personal information we hold that is inaccurate.

D. Erasure

The right to delete your account or remove certain personal information. We may need to retain personal information if there are valid grounds under data protection laws.

E. Restriction of processing to storage only

The 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).

F. Objection

The right to object to our processing of your personal information. If you wish to do so, please contact us (see section 2 (Data controller and how to contact us)) and we will review your request.

G. Consent withdrawal

To the extent provided by applicable laws and regulations, you can withdraw consent you previously provided to us for certain processing activities by contacting us. 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.

H. Advertising

We will only send marketing messages to you if we have your consent. You may can choose to stop receiving marketing messages from us by using the unsubscribe option in our messages or reach out to us via Contact Us section in the Privacy Portal.

I. 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 any game for maintenance or security reasons). There are essential system and service-related announcements (which are not promotional in nature) that you cannot opt out of as we believe they are important to your interests.

J. Complain

The right to make a complaint to the data protection regulator in your country. However, we always hope that we can resolve any questions or concerns directly – and you can always contact us through the details included in the Contact Us section.

Not all of the rights described above are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request because a right is not granted by the laws that apply. Individuals in certain jurisdictions may have other rights. You can exercise some of these rights directly by accessing and updating the information in your account. To help you better understand your rights, see the applicable Additional Information section.

If you wish to exercise any of your rights, or you believe we hold any other personal information about you, please contact us through the details included in the Contact Us section.

12. Changes

If we make any changes to this Privacy Policy, we will post the updated Privacy Policy here and notify you in accordance with applicable legal requirements. We encourage you to check this page frequently to stay tuned and informed.

13. 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.

14. Contact Us

You can reach us using our online form for submitting data subject rights requests and questions here. The DSAR Form also allows you to contact our Data Protection Officer regarding your privacy-related inquiries.

Mailing Address:

International Privacy & Data Protection Centre

79 Robinson Road, #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.

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.

15. Our Representatives in Certain Jurisdictions

Jurisdiction	Representative	Address	Contact details
EU	Proxima Beta Europe B.V.	Buitenveldertselaan 1-5, 1082 VA, Amsterdam, the Netherlands	DSAR link here
UK	Image Frame Investment (UK) Limited	Suite 1, 4th Floor 80 Strand, London, United Kingdom WC2R 0RL	DSAR link here
Korea	Kite Bird Korea Yuhan Hoesa	25F, 55, Sejong-daero, Jung-gu, Seoul (Taepyeongro 2-ga), Korea	DSAR link here
Serbia	Karanovic & Partners o.a.d. Beograd	Resavska 23, Belgrade, 11000, Serbia	local.representative@karanovicpartners.com
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	DSAR link here
Türkiye	Özdağıstanli Ekici Avukatlık Ortaklığı.	Nidakule Ataşehir Kuzey Begonya Sok. No:3 Kat. 17 D: 162 34746 Ataşehir / İstanbul, Türkiye Özdağıstanli Ekici Avukatlık Ortaklığı is our data controller representative and its authority is limited to the authorities stipulated under the Law on Protection of Personal Data w. no 6698. Özdağıstanli Ekici Avukatlık Ortaklığı is not authorised for any other matters such as in-Service conduct, suspensions, investigations, civil or criminal complaints.	turkeydatarep_proximabeta@iptech-legal.com

Additional Information

Jurisdiction Specific Disclosures

For residents of the Republic of Korea, Türkiye and the United States please visit your corresponding country specific section for more information.

Region in which the user is located

European Economic Area Additional Disclosures

Instructions for the processing of your personal data after your death. You may have the right to provide us with general or specific instructions for the retention, deletion, and communication of your personal data after your death. The specific instructions are only valid for the processing activities mentioned therein and the processing of these instructions is subject to your specific consent. You may amend or revoke your instructions at any time.

You may designate a person responsible for the implementation of your instructions. This person will be informed of your instructions in the event of your death, and be entitled to request their implementation from us. In the absence of designation or, unless otherwise provided for, in the event of the death of the designated person, their heirs will have the right to be informed of your instructions and to request their implementation from us.

When you wish to make such instructions, please contact us at the information provided in the Contact Us Section.

Indonesia

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

If you fail to explicitly express your objection to any amended version of this Privacy Policy within fourteen (14) days of the date the relevant amended version of this Privacy Policy is made available, you will be considered as having accepted the changes and agreed to the new Privacy Policy. However, you may stop using or accessing our Website and Service by unsubscribing or ceasing your use of the Website and Service at any time, if you cease to agree with the amended Privacy Policy.

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).

Malaysia

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
- Other Contact: see Contact Us Section.

Taiwan

We do not knowingly collect or solicit personal information from anyone under the age of 7 or

knowingly allow such persons to register on the Service platform. If you are under 7 years of age, please do not attempt to use or register for our Service or send any personal information about yourself to us. No one under the age of 7 may provide any personal information to us while using the Service. In the case of users located in Taiwan, persons under the age of 20 are required to obtain parental/guardian consent prior to using the Service.

Thailand

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

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.

If you have questions about this section, would like to exercise any of your rights, or if you would like to contact our Data Protection Officer (who is responsible for managing the protection of your personal data), you can contact us at the information provided in the Contact Us Section.

Game Specific Jurisdictional Disclosures

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 Hong Kong.

With regards to the legal basis of processing personal information included in Section ‎6 “Legal basis for processing,” the following legal provisions under the PIPA applies:

(consent): we use this information pursuant with your consent, pursuant to Article 15(1)(1) of the PIPA.
(compliance with legal obligations): we use this information where necessary to comply with a legal obligation pursuant to Article 15(1)(2) of the PIPA.
(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 of the data subject - PIPA Art. 17(1)(1)

Facebook

https://www.facebook.com/privacy/policy/

Facebook nickname and avatar

To enable users to login using their Facebook account

In accordance with the Facebook privacy policy

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

PIPA Art. 28-8(1)(3) Delegation and Retention for Contract Performance

Facebook

https://www.facebook.com/privacy/policy/

United States, Ireland, Denmark, and Sweden

Transferred via information and communications network at the time of service use

Facebook nickname and avatar

To enable users to login using their Facebook account

In accordance with the Facebook 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 (Representative: Wang Si Min)
Address: 25F, 55, Sejong-daero, Jung-gu, Seoul (Taepyeongro 2-ga), Republic of Korea
Telephone: +82-2-2185-0926
Email: specified in the Contact Us section

Contact

Data Protection Department, responsible for the management and safety of your personal information
Telephone: +82-2-2185-0926
Email: specified in the Contact Us section

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)

Türkiye

You have legal rights, which are set forth in Article 11 of the Turkish Law on Personal Data Protection Law (“DPL”), in relation to the personal information data we hold about you. As a Turkish data subject, you may have the right to apply to the data controller and (to the extent permitted under applicable laws and regulations):

learn whether or not your personal data has been processed;
request information about processing if your personal data has been processed;
learn the purpose of processing of your personal data and whether they have been used accordingly;
know the third parties in the country or abroad to whom personal data has been transferred;
request rectification in the event personal data is incomplete or inaccurate and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the DPL and to demand the operations in this regard be reported to third parties your personal data has been transferred to;
object the occurrence of any consequence that is to your detriment by means of analysis of personal data solely through automated systems; and
demand compensation for the damages that you have suffered as a result of unlawful processing of your personal data.

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.

Your 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;
Right to Opt out of Targeted Advertising or Profiling. Request to opt-out of the processing of your information for the purposes of targeted advertising or the profiling of your information in furtherance of decisions that produce legal or similarly significant effects; 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.

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 name as it appears on your social media profile, Open ID, in-game ID, 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.
Internet or other electronic network activity information, such as your information regarding your use of the Service, such as level, score, date and time stamps of actions, log-in and clickstream data and other device information as described in the main Privacy Policy. This information is collected directly from you and your device.
Commercial information about any transactions within the Service such as what products were purchased and how much they cost. This information is collected directly from you and your device and the Midasbuy platform.
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.
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, is only stored on your device, and is not retained by our servers.

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 process payments.
To improve our services, including the functionality of the Service;
To enable you to communicate directly with other users on the Service;
To resolve customer support queries;
For security and verification purposes, including to prevent and detect fraudulent activity;
To address and remediate technical issues and bugs; and]
To comply with our legal obligations and enforce our legal rights.

We disclose each of the categories of personal information that we collect as described in Section ‎‎4 (What information do we process).

For additional information about what each type of personal information is used for, see Section ‎5 (How do we use your 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, please refer to Section ‎10 (How long do we retain your information) in the main portion of the Privacy Policy.

Watchdog disclosure

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 Submit a Report – Watchdog.

Questions

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