Welcome to Dungeonborne!

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 Dungeonborne (the “Game”) and its official website (the “Website”) and the Dungeonborne Team up Challenge (the “Team Up Event”), and the Dungeonborne Streamer Challenge (the “Streamer Event”) (the Game, the Website, the Team Up Event and the Streamer Event together comprise the “Game Services”), and sets out your choices and rights in relation to that information. Please read it carefully – it will allow you to understand how we collect and use your information, and how you can control it.

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

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Game Services. 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 Game Services is Proxima Beta Pte. Ltd. (“we”, “us”, “our”).

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

1. Cookies

We use cookies and other similar technologies (“Cookies”) to enhance your experience using the Game Services. 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.

2. Children

Children must not use the Game Services for any purpose.

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
Algeria	19
Argentina	13
Australia	18
Bangladesh	18
Brazil	18
Cambodia	18
Canada	13
Colombia	18
Egypt	18
European Economic Area	16
Hong Kong	18
Indonesia	18
Japan	18
Kazakhstan	18
Kuwait	21
Macau	18
Malaysia	18
Mexico	18
Morocco	18
Myanmar	18
New Zealand	16
Nigeria	13
Philippines	18
Qatar	18
Republic of Korea	14
Saudi Arabia	18
Serbia	15
Singapore	13
South Africa	18
Sri Lanka	18
Switzerland	14
Taiwan	20
Thailand	20
Tunisia	18
Türkiye	18
United Arab Emirates	21
United Kingdom	13
United States	13
Vietnam	16

3. 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 Brazil, the European Economic Area, Indonesia, Switzerland, Thailand, Türkiye or the United Kingdom, it also identifies the legal basis under which we process your data.

Personal Information	Use	Legal Basis (where applicable)
The Game
Information you provide to us (either directly or through a third party)
Nickname	We use this information to create your profile for the Game in accordance with your request.	Necessary to perform our contract with you to provide the Game.
Account information as provided by Steam: Steam ID, Steam name, user token and open ID.	We use this information to create your profile for the Game in accordance with your request.	Necessary to perform our contract with you to provide the Game.
Friends List (Steam)	If a user logs in using Steam, we will import the Steam name of the friends from your Steam profile so that you can connect with your friends.	Necessary to perform our contract with you to provide the Game and connect you with your friends.
Text chat data: Open ID, chat data (inputted by users)	If you enable text chat services, we process this data in order to deliver your messages to other users.	Necessary to perform our contract with you to facilitate communication between users where you seek to use chat services.
Real time voice chat data: Open ID, device information (device model, device brand, system time), and other technical information (SDK version, network type and region ID). We also momentarily process real time voice data, but such data is not stored on our servers.	If you enable audio chat services, we process this data in order to 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.
Survey information: gender, age or age range, and any other content you choose to provide as part of the survey response. To the extent you choose to participate in an in-game survey regarding the Game, we will redirect you to Google Forms to take the survey and the Google’s Privacy & Terms will apply to certain data processed in connection with your participation in the survey. For more details, please refer to: https://policies.google.com/privacy?hl=en-US.	We use this information with your consent to better understand our users and to improve the Game.	We collect this information with your consent.
Information generated as part of the Game
XWID: your XWID, which is generated by us.	We use this information for login and debugging.	It is in our legitimate interest to use this identifier for login and debugging.
Common information for data reporting: game ID, client source, session ID, event time, client IP, country, province, city, carrier ID, Open ID, event name, operating system, operating system version, SDK version, network type, bundle ID, app version, log in channel ID, device model, device brand, screen width, screen height, CPU name, CPU core, CPU frequency, GPU name, RAM, ROM, system language, UAID, specific device ID, XWID, virtual machine determination information.	We use this information for data analytics purposes.	It is in our legitimate interest to use this information for game analytics purposes to monitor the operation of the Game.
Data monitoring information: error code, error message, SDK name, SDK version, request URL, response body, sequence ID, stage, logs, and common information for data reporting.	We use this information to fix bugs, and to understand the performance and interaction of our SDKs.	It is in our legitimate interest to use this information to fix bugs and monitor the performance of our SDKs.
In-game notifications / announcements information: Open ID	We use this information to send you in-game notifications and announcements relating to the Game.	Necessary to perform our contract with you to provide the Game.
IP address	We use this information to allow you to use the Game and connect to our servers.	Necessary to perform our contract with you to provide the Game.
Data analytics to analyse user acquisition statistics: user agent (e.g. safari or chrome or mozille or IE), PC UUID, timezone, resolution, IP address, language, and common information for data reporting.	We use this information to analyse the user acquisition process and understand where the users who downloaded the Game originated from (Facebook, Google, Steam, Epic, etc.).	It is in our legitimate interest to use this information to understand the user acquisition process.
Advertising and marketing analytics data: User acquisition touchpoint data (ID, type, Game ID, team ID, network, campaign, influencer, ad group, ad, ad type, placement, keyword, creative, site ID, sub site ID, UTM source, UTM campaign, UTM term, UTM content, UTM medium, sub1, sub2, sub3, sub4, sub5, sub6, sub7, sub8, sub9, sub10, country, region, city, browser family, user agent, referer, requested at, unique, clicks, clicks unique, impressions, impressions unique, cost model, cost currency, cost amount, record updated at); and Game server data (XWID, Steam account identification number, device information (e.g., operating system, operating system version, installed fonts, screen resolution, user agent, web browser information), IP address, event name and timestamp that relates to the clicking of ad).	We use this information to conduct user acquisition analysis, analysis on advertising costs and impact, and analysis on return on ad spend.	It is in our legitimate interest to use this information to monitor the success of our advertising and marketing programs.
GCloud SDK data – Maple: Device name, device model and login channel ID.	We use the GCloud SDKs data to provide Game maintenance and communications between servers.	Necessary to perform our contract with you to provide the Game.
TDM Data Master data: System time, device system version, SDK version, IP address.	We use this information to collect and report, analyze device performance and improve user experience.	Necessary to perform our contract with you to provide the Game.
Crash-related information: Device name, device model, memory, CPU usage rate, CPU model, device system version, device brand, ROM, RAM, CPU architecture, Whether Root, remaining memory, whether it is running in the simulator, running process information, system time, resolution, dump file, operation system, process name, Network Type, Application version, Application package name, SDK version, SDK version number / application name and version number.	We use this information to locate and resolve crash issues.	It is in our legitimate interest to improve the Game.
Game performance monitoring information: Open ID, Operation System, GPU information, CPU model, CPU usage rate, Device brand, Network traffic, device system version, screen resolution, ROM, RAM, device manufacturer, CPU architecture, remaining memory, device model, system time, UUID, Whether Root, system startup time, battery status.	We use this information to monitor client performance, Cloud control device level, and perform custom data statistical analysis.	Necessary to perform our contract with you to provide the Game.
Customer support information (in app): · General information (received from Game): Zone name, zone ID, platform ID, role name, role icon, language type, open ID, secure position of notch screen of mobile device, scene ID, area ID, app ID, country ID, channel ID; · Device information (automatically collected): Device ID, IP address; · Information collected via International SDK: Encode parameters, game ID, channel ID, OS, timestamp, SDK version, sequence no.; and · Information collected via user’s game data query: Game account information, including registered user name, social media account, registration time; Game character information, including role name, role ID, game duration, historical record; In-game data, including information in relation to items, currency, penalties, logins, activities, top-up, purchase history, in-game friend relationships, in-game match data; any information users provide to customer service, including chat data.	We use this information to: · to improve our services; · to respond to your communications; and · to provide troubleshooting, such as addressing and remediating technical issues and bugs.	Necessary to perform our contract with you to provide and support the Game.
CROS Data Interface Platform data: Open ID, region ID, platform ID, partition ID.	We use this information to provide unified standard interface service to the Game, and real-time data access support for our operating system.	It is in our legitimate interest to improve our services.
CROS Product Technical Operations Platform: Open ID, region ID, partition ID, server ID, game log data Please note that the data collected for the processing of this is not directly collected from users, but from CROS Data Interface platform.	We use this information to provide operations and necessary maintenance of the Game.	Necessary to perform our contract with you to provide the Game.
Data analysis and reporting information: · Account information: nickname, username, user IDs, email address; · Steam account information: login channel, profile pictures, username, friend list; · Device information: device identifiers, device model, operation system, network, screen, system performance data; · Location information: IP address, country/region; and · Game data (Tlog): Open ID, Region ID, Partition ID, Role ID, rolename, level, client IP, online time, and gameplay statistics (player friends number, item ID, item number, battle modes).	We use this information to analyze existing data in database, visualize data in tables/report formats and assist user to customize MySQL data search task.	Necessary to perform our contract with you to provide the Game.
Player penalty system information: Open ID, Game ID, device identifiers (e.g. UUID).	We use this information to perform risk control on penalty system and to distribute feature file for anti-cheating)	It is in our legitimate interest to use this information to run the player penalty system.
User-generated content moderation information: Open ID, Game ID, IP address, user generated text chat message data.	We use this information to detect if your text, pictures, and other forms of user-generated content includes content in breach of our End User Licence Agreement (such as advertising, violence, abusive text, hate, and sexual / vulgar content).	It is in our legitimate interest to ensure the integrity of the Game and protect users from prohibited conduct.
Anti-cheating information: Information retrieved from game logs, such as Open ID, Game ID, device information (e.g. MAC address, operating system, model of main board, model and capacity of hard disk, model and capacity of RAM, and device identifiers like UUID), gameplay data.	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.
Game data (Tlog): Open ID, region ID, partition ID, role ID, rolename, level, client IP, online time, number of player friends, item ID, item number, battle modes.	We use this information to: · to ensure the smooth operation of the Game; · to improve the Game and its functionality (including to provide version updates); · to maintain records of log-in and user account actions; · store your game account information; · for security and verification purposes; and · for feedback and information about gameplay and progress.	Necessary to perform our contract with you to provide the Game.

The Website
Information you provide to us (either directly or through a third party)
Email Address to receive updates on the Game	We use this information to send you notifications and updates about the development, progress and subsequent beta tests and launch of the Game.	We use this information only with your consent.
The Team Up Event
Information you provide to us (either directly or through a third party)
Account information as provided by Steam: Steam ID, Steam name, Open ID	We use this information to create your profile for the Team Up Event in accordance with your request.	Necessary to perform our contract with you to provide the Team Up Event.
Information generated as part of the Team Up Event
Event log data: Open ID, Region ID, Platform ID, Partition ID (Server ID), Role ID	We use this information to: · forward user requests when user participate in in-game events; · record reward logs when users participate in in-game events; · record user qualification logs when users participate in in-game events; · record reporting logs; and · monitor the quantity and frequency of rewards given out.	Necessary to perform our contract with you to provide the Team Up Event.
The Streamer Event
Information you provide to us (either directly or through a third party)
Account information as provided by Steam: Steam ID, Steam name, Open ID.	We use this information to create your profile for the Streamer Event in accordance with your request.	Necessary to perform our contract with you to provide the Streamer Event.
Account information as provided by Twitch when you bind your Twitch account: Twitch user name, email address, email verification status.	We use this information to bind your Twitch account with your Steam account in accordance with your request.	Necessary to perform our contract with you to provide the Streamer Event.
Information generated as part of the Streamer Event
Reward determination information: Twitch user name, play game length.	We use this information to determine users to be rewarded in the Streamer Event.	Necessary to perform our contract with you to provide the Streamer Event.
Streamer Event profile information: Twitch user name, score, ranking, and gameplay statistics including number of kills, number of bosses killed, number of successful escape.	We use this information to provide you with your Streamer Event profile and score.	Necessary to perform our contract with you to provide the Streamer Event.
Leaderboard highlights information: Region ID, ranking, Twitch user name, total score, and gameplay statistics including number of kills, number of bosses killed, number of successful escape, number of gold coins.	We use this information to ensure the integrity of the rankings and high scoring players, and to display the leaderboard information.	It is in our legitimate interest to ensure the integrity of the rankings and high-scoring players is supported by appropriate evidence in-Game.
Rewards distribution information: Discord ID.	We use this information to distribute rewards to users.	Necessary to perform our contract with you to provide the Streamer Event.

4. How We Store and Share Your Personal Information

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

We have servers for the Game Services in Singapore. The servers applicable to your use of the Game Services will depend upon your location. We also have support, engineering and other teams who may support the Game Services, including from Singapore, the Netherlands, and the People’s Republic of China.

For EEA/UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses, or taking into account adequacy assessments.

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

· Third parties that provide services in support of the Game, including providers of services that process information identified in this policy for the purpose of providing the Game Services, for the purpose of processing support ticket ID and support communication, for the purpose of processing gameplay and game rendering data to provide game analytics to improve gameplay, for the purpose of providing marketing and advertisements and monitor the success of our marketing and advertising programs and for the purpose of conducting surveys. 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 Services (i.e., for the purpose(s) described above).

· Companies within our corporate group who process your personal information solely for the purpose of providing the Game Services to you, which may include for customer support purposes. 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.

5. The Security of Your Personal Information

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

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

6. 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
The Game
Nickname XWID Common information for data reporting Data monitoring information Friends List (Steam) Data analytics to analyse user acquisition statistics Advertising and marketing analytics data Text chat data Customer support information (in app) Game data (Tlog)	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days, or deleted manually within 10 days from our receipt of your account deletion request (whichever is earlier).
Account information as provided by Steam In-game notifications / announcements information Player penalty system information Survey information	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days.
IP address	Data is processed momentarily by us but not stored on our servers.
Real time voice chat data	Real time voice data is processed momentarily by us but not stored on our servers. All other data is stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days, or deleted manually within 10 days from our receipt of your account deletion request (whichever is earlier).
GCloud SDK data – Maple TDM Data Master data	Stored for 90 days (unless you request deletion of such data or your account, in which case we will delete such data within 30 days after your request).
Crash-related information Game performance monitoring information	Stored for 30 days (unless you request deletion of such data or your account, in which case we will delete such data within 15 days after your request).
CROS Data Interface Platform data	Data instructed to be stored on Cloud Log Service is deleted automatically after 7 days. Data stored on TBDS Big Data Suite is deleted after 3 months.
CROS Product Technical Operations Platform data	Game log data is stored for 6 months. All other data will only be processed momentarily (query via IDIP or Tlog).
Data analysis and reporting information	Stored for 6 months from collection, after which it will be deleted.
User-generated content moderation information	Stored for 7 days. Open ID and Game ID are stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days.
Anti-cheating information	Open ID, Game ID, device information are stored for 14 days. All other data is stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days.
The Website
Email Address to receive updates on the Game	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days.
The Team Up Event
Account information as provided by Steam	Stored for duration of the Team Up Event and then deleted within 30 days thereafter or deleted manually within 15 days from our receipt of your account deletion request (whichever is earlier).
Event log data	Stored for duration of the Game and then deleted within 30 days thereafter or deleted manually within 10 days from our receipt of your account deletion request (whichever is earlier).
The Streamer Event
Account information as provided by Steam Account information as provided by Twitch when you bind your Twitch account Reward determination information Streamer Event profile information Leaderboard highlights information Rewards distribution information	Stored for duration of the Streamer Event and then deleted within 30 days thereafter or deleted manually within 15 days from our receipt of your account deletion request (whichever is earlier).

7. Your Rights

Some jurisdictions’ laws grant specific rights to users of the Game Services. 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 that we hold about. We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Game Services and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only

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

Objection

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

Consent Withdrawal

To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us at dpo@dungeonborne.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.

Announcements

8. We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the Game Services 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. Contact

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

Email: dpo@dungeonborne.com

Mailing Address:

International Privacy & Data Protection Centre

30 Raffles Place #18-01

Singapore

048622

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.

9. 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.

10. 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 Game Services, 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.

Algeria

By using the Game Services, you give your consent to the collection, storage, treatment and use of your personal information, and transfer of your personal information to third parties or our affiliates to help us deliver the Game Services, in each case location in the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information).

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 Game Services, 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.

Australia

We take reasonable steps to ensure that third party recipients of your personal information located outside Australia handle your personal information in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients. You have the right to access personal information we hold about you, how we use it, and who we share it with. You have the right to correct any of your personal information we hold that is inaccurate.

If you are under the age of 18, you must not use the Game Services for any purpose.

Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the Game Services. You acknowledge that if you do not provide us with your personal information, we may be unable to provide you with access to certain features or sections of the Game Services , including social media integration and in- Game Services purchases.

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the Australian Information Commissioner (Telephone: +61 1300 363 992 or email: enquiries@oaic.gov.au).

Bangladesh

By acknowledging the Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data, including disclosing to third parties, to the extent provided by the Privacy Policy. You also consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information).

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 8 (Contact). This may affect our provision of the Game Services 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 as specified in Section 8 (Contact). 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.

Colombia

Your authorization to process personal information for the Game Services may be expressed (i) in writing, (ii) orally or (iii) through unequivocal conduct that allows us to reasonably conclude that your authorization has been granted, such as the act of accepting the Privacy Policy. We may keep evidence of said authorizations, while respecting the principles of confidentiality and privacy of information.

As a data subject you have certain rights, including (i) to access, update and rectify your personal data; (ii) to request a copy of the consent you have given us; (iii) to be informed about how we have processed your personal data; (iv) to file claims before your country’s data protection authority; (v) to revoke the consent you have given us to process your personal data, unless the processing is based on compelling legitimate grounds or is needed for legal reasons; (vi) to ask for the suppression of your personal data (right to erasure); and (vii) to freely access your information. You can contact us to exercise any of these rights, using the information specified in Section 8 (Contact)

Egypt

By clicking “accept” or by proceeding with the sign up process, you acknowledge that you have read, understood, and consented to this Privacy Policy. You are acknowledging your consent to the processing, storage, and cross-border transfer of your personal data. The cross border transfer may be to any country in which we have databases or affiliates, in particular to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information).

If you are a new user, you have seven days to inform us of any objection you may have to this Privacy Policy.

As an Egyptian data subject, you have certain rights under the Egyptian Personal Data Protection Law.

France

Instructions for the processing of your personal data after your death. You 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 as set out in Section 8 (Contact).

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 must not use the Game Services for any purpose.

In the event we fail to maintain the confidentiality of your personal information in the Game Services, we will notify you through the contact information provided by you or via the Game Services, 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 not use the Game Services for any purpose.

By clicking “accept”, 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 where we have databases or affiliates and, in particular, to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information).

The categories of personal information specified in to the jurisdictions specified in Section 4 (How We Store and Share 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 as set out in Section 8 (Contact).

Kazakhstan

If you are under the age of 18, you must not use the Game Services for any purpose.

By clicking “accept”, you consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws), sharing and storage of your personal information as described in this Privacy Policy. The transfer of your personal information to third parties, which may include the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to Singapore.

In the event of any discrepancy or inconsistency between the English version and the Kazakh version of this Privacy Policy, the Kazakh version shall prevail.

Your Rights

· Right of access: You have the right to request access to and obtain a copy of the personal information we have process about you or that is being processed 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 to correction: You may request for the correction of your personal information or delete such personal information if it is impossible to correct it. 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 blocking / de-blocking: You have the right to request the blocking of personal information related you, if you become aware of a violation regarding the collection and processing your data. If the violation has not been proved, you may request to de-block your data.

· Right to deletion: You have the right to request deletion of your personal data if the collection and processing of your data has been conducted in violation of Kazakh laws.

· Processing of your personal information in public sources of personal data: You may request to limit or provide your consent on the processing of your personal information in public sources of personal data.

Kingdom of Saudi Arabia

You consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws) and storage of your personal information as described in this Privacy Policy.

Kuwait

By accepting this Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data and to disclose this data to third parties whether inside or outside of Kuwait, in line with the provisions of this Privacy Policy.

Macau

You have the right not to provide your personal information. However, as a result, we may not be able to provide the Game Services to you. As a Macau data subject you have legal rights in relation to your personal information (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to request a copy of the data we process about you, to make a data correction request, and have the right to oppose the use of your personal information for marketing or any other form of commercial prospecting, or on any grounds of personal nature. A fee may be chargeable by us for complying with a data access request.

Malaysia

In the event you are agreeing to this Privacy Policy in order for a minor to access and use the Game Services, 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 using the contact details provided above. However, this may affect our provision of the Game Services 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 8 (Contact)

Mexico

Some of the purposes of processing specified in Section 3 (How We Process Your Personal Information) are voluntary.

In general, we do not require your consent to carry out the transfers detailed in Section 4 (How We Store and Share Your Personal Information). In any case, by using the Game Services and providing us with your personal data, you agree to the data transfers detailed therein that require your consent.

To understand more about and exercise your rights to “Access”, “Correction”, “Erasure”, “Objection”, “Restriction of Processing to Storage Only “, which includes the limitation to the use and disclosure of your personal data, as well as the applicable means, procedures and requirements to exercise any of your rights, please contact us as specified in Section 8 (Contact).

Morocco

We collect information for purposes strictly necessary for the proper use of the Game Services. By accepting this Privacy Policy, you explicitly accept that your personal data may be subject to processing by the Game Services.

Kindly note:

the identity of the Data Controller is set out at the beginning of this Privacy Policy
the purposes of processing personal data are set out in Section 3 (How We Process Your Personal Information)
recipients or categories of recipients are set out in Section 4 (How We Store and Share Your Personal Information)
whether the answer to the questions is compulsory or optional, as well as the possible consequences of a lack of answer: please refer to Section 3 (How We Process Your Personal Information) and Section 7 (Your Rights)

New Zealand

We take reasonable steps to ensure that third party recipients of your personal information located outside New Zealand handle your personal information in a manner that is consistent with New Zealand privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.

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

If you are under the age of 16, you must not use the Game Services for any purpose.

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the New Zealand Privacy Commissioner (www.privacy.org.nz).

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, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.

Peru

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, pursuant to the Personal Data Protection Law (the “Law”). You may also exercise these rights through your legal guardian or someone who has been authorised by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Law.

You can also withdraw your consent or demand a suspension of the personal information processing at any time.

If you consider that your request has not been met you may file a claim with the Peruvian National Authority of Personal Data Protection.

Data Protection Team, responsible for the management and safety of your personal information
Contact: as set out in Section 8 (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 3 (How We Process Your Personal Information);
sharing your personal information with third parties, companies within our corporate group, and a third party that acquires substantially all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and
transferring or storing your personal information in destinations outside the Philippines as described in Section 4 (How We Store and Share Your Personal Information)

Qatar

If you are using the Game Services in Qatar, you consent (for the purposes of Law No. 13 of 2016 on the Protection of Personal Data, as may amended from time to time) to the processing of your information in accordance with this Privacy Policy.

Republic of Korea

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:

Delegatee

Description of Delegated Services

Google LLC

Process survey information

Tencent Cloud

(cloudlegalnotices@tencent.com)

Storage of personal information

Overseas Transfer of Personal Information

We transfer personal information to third parties overseas as follows:

Recipient (Contact Information of Information Manager)

Country 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

Google

(https://policies.google.com/privacy?hl=en-US)

United States

Transmitted through private network/ encrypted transmission etc from time to time

Survey information

Processing of survey information

For the data retention period specified under “How We Store and Share Your Personal Information”.

Tencent Cloud

(cloudlegalnotices@tencent.com)

Singapore

Transmitted through private network/ encrypted transmission etc from time to time

All personal information collected

Storage of personal information

For the data retention period specified under “How We Store and Share Your Personal Information”.

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)

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, 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. Specific considerations are as follows:

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.

Domestic Privacy Representative

Pursuant to the Article 32-5 of Network Act and Article 39-11 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: specified in Section 8 (Contact)

Contact

Data Protection Department, responsible for the management and safety of your personal information
Telephone: +82-2-2185-0926
Email: specified in Section 8 (Contact)

Mandatory Consent Language

Mandatory Consents

You have the right to refuse consent to the collection and use of your personal information. In case of refusal, you will not be able to use the relevant services.

Please consult this Privacy Policy for more detailed information.

Category of Personal Information	Purpose	Retention Period
The Game
Nickname	We use this information to create your profile for the Game in accordance with your request.	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days, or deleted manually within 10 days from our receipt of your account deletion request (whichever is earlier).
Friends List (Steam)	If a user logs in using Steam, we will import the Steam name of the friends from your Steam profile so that you can connect with your friends.
Text chat data: Open ID, Chat data (inputted by users)	If you enable text chat services, we process this data in order to deliver your messages to other users.
XWID: your XWID, which is generated by us.	We use this information for login and debugging.
Customer support information (in app): · General information (received from Game): Zone name, zone ID, platform ID, role name, role icon, language type, open ID, secure position of notch screen of mobile device, scene ID, area ID, app ID, country ID, channel ID; · Device information (automatically collected): Device ID, IP address; · Information collected via International SDK: Encode parameters, game ID, channel ID, OS, timestamp, SDK version, sequence no.; and · Information collected via user’s game data query: Game account information, including registered user name, social media account, registration time; Game character information, including role name, role ID, game duration, historical record; In-game data, including information in relation to items, currency, penalties, logins, activities, top-up, purchase history, in-game friend relationships, in-game match data; any information users provide to customer service, including chat data.	We use this information to: · to improve our services; · to respond to your communications; and to provide troubleshooting, such as addressing and remediating technical issues and bugs.
Common information for data reporting: game ID, client source, session ID, event time, client IP, country, province, city, carrier ID, Open ID, event name, operating system, operating system version, SDK version, network type, bundle ID, app version, log in channel ID, device model, device brand, screen width, screen height, CPU name, CPU core, CPU frequency, GPU name, RAM, ROM, system language, UAID, specific device ID, XWID, virtual machine determination information.	We use this information for data analytics purposes.
Data monitoring information: error code, error message, SDK name, SDK version, request URL, response body, sequence ID, stage, logs, and common information for data reporting.	We use this information to fix bugs, and to understand the performance and interaction of our SDKs.
Data analytics to analyse user acquisition statistics: user agent (e.g. safari or chrome or mozille or IE), PC UUID, timezone, resolution, IP address, language, and common information for data reporting.	We use this information to analyse the user acquisition process and understand where the users who downloaded the Game originated from (Facebook, Google, Steam, Epic, etc.).
Advertising and marketing analytics data: User acquisition touchpoint data (ID, type, Game ID, team ID, network, campaign, influencer, ad group, ad, ad type, placement, keyword, creative, site ID, sub site ID, UTM source, UTM campaign, UTM term, UTM content, UTM medium, sub1, sub2, sub3, sub4, sub5, sub6, sub7, sub8, sub9, sub10, country, region, city, browser family, user agent, referer, requested at, unique, clicks, clicks unique, impressions, impressions unique, cost model, cost currency, cost amount, record updated at); and Game server data (XWID, Steam account identification number, device information (e.g., operating system, operating system version, installed fonts, screen resolution, user agent, web browser information), IP address, event name and timestamp that relates to the clicking of ad).	We use this information to conduct user acquisition analysis, analysis on advertising costs and impact, and analysis on return on ad spend.
Game data (Tlog): Open ID, region ID, partition ID, role ID, rolename, level, client IP, online time, number of player friends, item ID, item number, battle modes.	We use this information to: · to ensure the smooth operation of the Game; · to improve the Game and its functionality (including to provide version updates); · to maintain records of log-in and user account actions; · store your game account information; · for security and verification purposes; and · for feedback and information about gameplay and progress.
Real time voice chat data: Open ID, device information (device model, device brand, system time), and other technical information (SDK version, network type and region ID). We also momentarily process real time voice data, but such data is not stored on our servers.	If you enable audio chat services, we process this data in order to facilitate your real time voice chat with other users.	Real time voice data is processed momentarily by us but not stored on our servers. All other data is stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days, or deleted manually within 10 days from our receipt of your account deletion request (whichever is earlier).
Survey information: gender, age or age range, and any other content you choose to provide as part of the survey response. To the extent you choose to participate in an in-game survey regarding the Game, we will redirect you to Google Forms to take the survey and the Google’s Privacy & Terms will apply to certain data processed in connection with your participation in the survey. For more details, please refer to: https://policies.google.com/privacy?hl=en-US.	We use this information with your consent to better understand our users and to improve the Game.	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days.
Account information as provided by Steam: Steam ID, Steam name, user token and open ID.	We use this information to create your profile for the Game in accordance with your request.
In-game notifications / announcements information: Open ID	We use this information to send you in-game notifications and announcements relating to the Game.
Player penalty system information: Open ID, Game ID, device identifiers (e.g. UUID).	We use this information to perform risk control on penalty system and to distribute feature file for anti-cheating)
IP address	We use this information to allow you to use the Game and connect to our servers.	Data is processed momentarily by us but not stored on our servers.
GCloud SDK data – Maple: Device name, device model and login channel ID.	We use the GCloud SDKs data to provide Game maintenance and communications between servers.	Stored for 90 days (unless you request deletion of such data or your account, in which case we will delete such data within 30 days after your request).
TDM Data Master data: System time, device system version, SDK version, IP address.	We use this information to collect and report, analyze device performance and improve user experience.
Crash-related information: Device name, device model, memory, CPU usage rate, CPU model, device system version, device brand, ROM, RAM, CPU architecture, Whether Root, remaining memory, whether it is running in the simulator, running process information, system time, resolution, dump file, operation system, process name, Network Type, Application version, Application package name, SDK version, SDK version number / application name and version number.	We use this information to locate and resolve crash issues.	Stored for 30 days (unless you request deletion of such data or your account, in which case we will delete such data within 15 days after your request).
Game performance monitoring information: Open ID, Operation System, GPU information, CPU model, CPU usage rate, Device brand, Network traffic, device system version, screen resolution, ROM, RAM, device manufacturer, CPU architecture, remaining memory, device model, system time, UUID, Whether Root, system startup time, battery status.	We use this information to monitor client performance, Cloud control device level, and perform custom data statistical analysis.
CROS Data Interface Platform data: Open ID, region ID, platform ID, partition ID.	We use this information to provide unified standard interface service to the Game, and real-time data access support for our operating system.	Data instructed to be stored on Cloud Log Service is deleted automatically after 7 days. Data stored on TBDS Big Data Suite is deleted after 3 months.
CROS Product Technical Operations Platform: Open ID, region ID, partition ID, server ID, game log data Please note that the data collected for the processing of this is not directly collected from users, but from CROS Data Interface platform.	We use this information to provide operations and necessary maintenance of the Game.	Game log data is stored for 6 months. All other data will only be processed momentarily (query via IDIP or Tlog).
Data analysis and reporting information: · Account information: nickname, username, user IDs, email address; · Steam account information: login channel, profile pictures, username, friend list; · Device information: device identifiers, device model, operation system, network, screen, system performance data; · Location information: IP address, country/region; and · Game data (Tlog): Open ID, Region ID, Partition ID, Role ID, rolename, level, client IP, online time, and gameplay statistics (player friends number, item ID, item number, battle modes).	We use this information to analyze existing data in database, visualize data in tables/report formats and assist user to customize MySQL data search task.	Stored for 6 months from collection, after which it will be deleted.
User-generated content moderation information: Open ID, Game ID, IP address, user generated text chat message data.	We use this information to detect if your text, pictures, and other forms of user-generated content includes content in breach of our End User Licence Agreement (such as advertising, violence, abusive text, hate, and sexual / vulgar content).	Stored for 7 days. Open ID and Game ID are stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days.
Anti-cheating information: Information retrieved from game logs, such as Open ID, Game ID, device information (e.g. MAC address, operating system, model of main board, model and capacity of hard disk, model and capacity of RAM, and device identifiers like UUID), gameplay data.	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).	Open ID, Game ID, device information are stored for 14 days. All other data is stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days.
Website
Email Address to receive updates on the Game	We use this information to send you notifications and updates about the development, progress and subsequent beta tests and launch of the Game.	Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with your request) and then deleted within 30 days.
Team Up Event
Account information as provided by Steam: Steam ID, Steam name, Open ID	We use this information to create your profile for the Team Up Event in accordance with your request.	Stored for duration of the Team Up Event and then deleted within 30 days thereafter or deleted manually within 15 days from our receipt of your account deletion request (whichever is earlier).
Event log data: Open ID, Region ID, Platform ID, Partition ID (Server ID), Role ID	We use this information to: · forward user requests when user participate in in-game events; · record reward logs when users participate in in-game events; · record user qualification logs when users participate in in-game events; · record reporting logs; and · monitor the quantity and frequency of rewards given out.	Stored for duration of the Game and then deleted within 30 days thereafter or deleted manually within 10 days from our receipt of your account deletion request (whichever is earlier).
Streamer Event
Account information as provided by Steam: Steam ID, Steam name, Open ID.	We use this information to create your profile for the Streamer Event in accordance with your request.	Stored for duration of the Streamer Event and then deleted within 30 days thereafter or deleted manually within 15 days from our receipt of your account deletion request (whichever is earlier).
Account information as provided by Twitch when you bind your Twitch account: Twitch user name, email address, email verification status.	We use this information to bind your Twitch account with your Steam account in accordance with your request.
Reward determination information: Twitch user name, play game length.	We use this information to determine users to be rewarded in the Streamer Event.
Streamer Event profile information: Twitch user name, score, ranking, and gameplay statistics including number of kills, number of bosses killed, number of successful escape.	We use this information to provide you with your Streamer Event profile and score.
Leaderboard highlights information: Region ID, ranking, Twitch user name, total score, and gameplay statistics including number of kills, number of bosses killed, number of successful escape, number of gold coins.	We use this information to ensure the integrity of the rankings and high scoring players, and to display the leaderboard information.
Rewards distribution information: Discord ID.	We use this information to distribute rewards to users.

Serbia

Our designated local representative in Serbia is Karanovic & Partners for the purposes of compliance with the Law on Personal Data Protection, and can be contacted at local.representative@karanovicpartners.com. Please include the word “Serbia” in the subject line of your email.

Name: Karanovic & Partners o.a.d. Beograd
Address: Resavska 23, Belgrade, 11000, Serbia
Telephone Number: +381 11 3094 200

E-mail: local.representative@karanovicpartners.com

Singapore

By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, the locations specified in Section 4 (How We Store and Share Your Personal Information).

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 as set out in Section 8 (Contact).

South Africa

You have the right to lodge a complaint with the Information Regulator (South Africa) by emailing it at inforeg@justice.gov.za. The Information Regulator (South Africa)’s physical address is 33 Hoofd Street Forum III, 3rd Floor Braampark, Braamfontein, Johannesburg, South Africa.

Sri Lanka

By clicking “accept”, you consent to the Privacy Policy and permit the collection, use and disclosure of your personal information. However, if you are under the age of 18, you must not use the Game Services for any purpose.

Taiwan

We do not knowingly collect or solicit personal information from anyone under the age of 20 or knowingly allow such persons to register on the Game Services platform. If you are under 20 years of age, please do not attempt to use or register for our Game Services or send any personal information about yourself to us.

Thailand

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

If you are under the age of 20, you must not use the Game Services for any purpose.

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

· withdraw your consent to the processing of your personal data (only where the legal basis for our processing is consent); however, please note that where consent is required to process your personal data, we may not be able to deliver the expected service without it;

· request us to provide you access to, make any correction to, cease any automated processing or profiling (if applicable), discontinue, restrict the use or provision of and/or erase your personal data;

· request us to provide you or a third party with your personal data which is stored by us in a machine readable format; and/or

· lodge a complaint to a relevant authority.

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

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

Türkiye

You have legal rights, which are set forth in Article 11 of the 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.

In accordance with Article 9 of the DPL, your personal data may be transferred abroad as follows:

Identity of the overseas recipient

Location of the recipient (or as otherwise stated in the recipient’s privacy policy)

Purposes of use of Personal Information by the recipient

Items of Personal Information to be provided

Google LLC

United States

Processing of survey information

Survey information

Tencent Cloud (cloudlegalnotices

@tencent.com)

Singapore

Storage of personal information

All personal information as set out in the section “How We Process Your Personal Information”

Ukraine

By accepting this Privacy Policy, you expressly authorize us to collect, use, store, and process your personal data, including disclosing to third parties and transferring to countries or regions other than Ukraine, to the extent and for the purposes provided in this Privacy Policy.

United Arab Emirates

You consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws), sharing and storage of your personal information, as described in the Privacy Policy.

We may voluntarily report a cyber-security incident where it constitutes a crime under UAE law (e.g. under the UAE Cybercrime Law). The incident can be reported to the relevant authorities for the purpose of investigations. Please note that voluntary reporting of a cyber-security incident can also be made to the UAE Computer Emergency Response Team (“CERT”). CERT is a security awareness organisation that provides a process for logging incidents and advising on known cyber security threats in the UAE.

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 name as it appears on your Steam profile, Open ID / user ID, IP address, device ID, device token, phone number, mailing address, 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.
Personal information categories listed in the California Customer Records statute, including information covered by other categories such as your address and phone number. This information is collected directly from you.
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.
Internet or other electronic network activity information, such as your information regarding your use of the Game Services, including 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 Game Services such as what products were purchased and how much they cost. 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 Game Services. This information is collected directly from you.
Audio and visual information such as your social media profile picture, photos shared in the Game Services, 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.
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 Game Services account.*
Contents of your chat messages sent on Game Services*. 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 Game Services, maintain your account, provide customer service, process payments, and deliver audio and text messages.
To process surveys.
To improve our services, including the functionality of the Game Services.
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 3 (How We Process Your Personal Information).

We disclose each of the categories of personal information that we collect as described in Section 4 (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;
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 as specified in Section 8 (Contact). 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 as set out in Section 8 (Contact).

Vietnam

By accepting this Privacy Policy, you expressly agree and authorise us to collect, use, store, and process your personal information, including, lawfully disclosing and transferring it to third parties, as described in this Privacy Policy.

Where we permit any third parties to collect and use your personal information, we shall take reasonable measures to ensure that the third parties do not further disclose the personal information.

You have the right to access, correct, and erase the personal information we hold about you. You also have the right to withdraw your earlier provided consent to collect, store, process, use and disclose your personal information and to request us to stop providing your personal information to a third party.

*What information do we need to be able to provide the Game Services?*	In relation to the Game: · If you use the Game, then we will collect information provided by Steam to automatically generate your profile, including Steam ID, Steam name, and user token. We will generate an Open ID, which is an internal ID for your profile. Depending on your use of the Game and the jurisdiction where you are based, you may also need to provide some additional information to help us set up 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 app- and OS-generated identifiers). · 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. In relation to the Website: · If you register to receive updates on the development of the Game including any subsequent beta tests, then you will need to provide your email address. In relation to the Team Up Event: · If you join the Team Up Event, we collect information provided by Steam, including Steam ID, Steam name and Open ID, to connect to your profile. · We will process your Open ID, Region ID, Platform ID, Partition ID, Role ID in relation to the Team Up Event after you log in to your Steam account, to provide your rewards to you. In relation to the Streamer Event: · If you join the Streamer Event, we collect information provided by Steam, including Steam ID, Steam name, and Open ID, to connect to your profile. We will also collect information provided by Twitch, including Twitch user name, email address, email verification status, to bind your profile with your Twitch account. · To maintain operation of the Streamer Event, we will process your profile information, play game length, leaderboard highlights, game statistics, performance data (such as your score and ranking within the Game), region ID and discord ID.	More Information.
*How will we use your information?*	· In relation to the Game: We use your information to set up your profile, enable you to use the Game, 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, enable transactions, and resolve user queries. · In relation to the Website: We use your information to enable you to use the Website, resolve user queries, provide you with updates of the Game. · In relation to the Team Up Event: We use your information to enable you to participate in the Team Up Event to claim rewards. · In relation to the Streamer Event: We use your information to enable you to use the Streamer Event, provide you and other players with your score and profile, your in-Game battle records based on gameplay statistics, and performance rankings as well as to enable reward distribution. ·	More Information.
*Who do we share your information with?*	· We use third parties and work with our affiliates to help us deliver the best possible experience (such as needed to back up your progress as well as for customer support, and surveys and our marketing). · 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 Services (i.e., to fulfil the purpose(s) described above). · In some cases we may be required by a court or be under a legal obligation (such as a valid search warrant or subpoena) to disclose certain information.	More Information.
*Where do we process your information?*	· Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy. · We have servers for the Game Services in Singapore. We also have support, engineering and other teams who may support the Game Services, including from Singapore and the Netherlands and the People’s Republic of China. · For EEA/UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses, obtaining your consent first or taking into account adequacy assessments.	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 a profile for the Game Services, 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.

Jurisdiction	Representative	Address	Contact details
EU	Proxima Beta Europe B.V.	Buitenveldertselaan 3-5 1082 VA Amsterdam	dpo@dungeonborne.com
UK	Image Frame Investment (UK) Limited	Suite 1, 4th Floor 80 Strand, London, United Kingdom WC2R 0RL	dpo@dungeonborne.com
Republic of Korea	Kite Bird Korea Yuhan Hoesa	25F, 55, Sejong-daero, Jung-gu, Seoul (Taepyeongro 2-ga), Republic of Korea	dpo@dungeonborne.com
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	dpo@dungeonborne.com
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

1. Cookies

2. Children

3. How We Process Your Personal Information

4. 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.

For EEA/UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses, or taking into account adequacy assessments.

5. The Security of Your Personal Information

6. Data Retention

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

7. Your Rights

9. Changes

10. Language

Our Representatives in Certain Jurisdictions