Undawn Website

www.undawn.game/en

Privacy Policy

Last Updated: 1 September 2021

Thank you for visiting the Undawn Website(www.undawn.game/en) (together with the sub-pages thereof and other webpages of Undawn linked therein, the “Site”)! We respect your concerns about privacy and appreciate your trust and confidence in us.

Here is a summary of the information contained in this privacy policy (“Privacy Policy”). This summary is to help you navigate the Privacy Policy and it is not a substitute for reading everything! You can use the hyperlinks below to jump directly to particular sections.

What information do we collect?

If you contact us or subscribe for our newsletters, we will collect your name and e-mail address and other information you decide to provide us as part of your communication. More Information.

How will we use your information?

If you contact us, we use your e-mail address to get in touch with you.  If you register for our newsletters, they are sent to the e-mail address you provide. More Information.

Who do we share your information with?

We use some third parties to help us deliver the best possible experience. When we use a third party, we only do this to process or store your information for the purposes described in this Privacy Policy. We also have affiliates around the world who help us operate and maintain the Site.  We may be required by a court or legal obligation to disclose certain information in some circumstances. More Information.

Where do we process your information?

Our servers are located in United States and Singapore. Your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including in Singapore and the United States. More Information.

How long do we keep hold of your information?

We only retain your personal information (i) for so long as you are a subscriber of our newsletter; and (ii) for two years on AIHelp’s servers, unless we are otherwise required to retain information to fulfil the purpose for which it was collected or in accordance with legal or regulatory obligations. More Information.

How can I exercise my rights over my information?

Depending on where you are, you may have certain rights with respect to your information, such as rights of access, to receive a copy of your data, or to delete your data or restrict or object to our processing of your data. More Information.

How to get in touch with us

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, please contact us here.

How will we notify you of changes?

Changes to this Privacy Policy will be posted here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy. More Information.

Contact Information

Data Controller: Proxima Beta Pte. Limited | Email: dpo_undawn@proximabeta.com 


Welcome to the Undawn Website!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with your access to the Undawn Website (www.undawn.game/en) (together with the sub-pages thereof and other webpages of Undawn linked therein, the “Site”), and sets out your choices and rights in relation to that information. Please read it carefully – it is important for you to understand how we collect and use your information, and how you can control it.

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 accessing the Site. By accessing the Site you are acknowledging the rules regarding your personal information as described in this Privacy Policy.

 

This Site has been developed by Proxima Beta Pte. Limited (“we”, “us”, “our”).

For the purpose of data protection laws, the data controller of your personal information in relation to the Site is Proxima Beta Pte. Limited, which is a Singaporean company within our corporate group. The registered address of Proxima Beta Pte. Limited is 10 Anson Road, #21-07 International Plaza Singapore (079903). Our data protection officer can be contacted at dpo_undawn@proximabeta.com.

Please reach out to us if you have any questions or concerns regarding the processing of your personal information. You can contact us anytime at dpo_undawn@proximabeta.com.

1. The Types of Personal Information We Use

This section describes the different types of personal information we collect from you and how we collect it. If you would like to know more about specific types of data and how we use that data, please see the section entitled How We Use Your Personal Information” below. 

The following is a high-level summary of the types of personal information we use:

· Newsletter information (via SDK): If you subscribe for our newsletters, we will collect your e-mail address.

· Contact information: If you contact us, we will collect your e-mail address and other information you decide to provide us as part of your communication.

2. Cookies

We use cookies and other similar technologies (e.g. web beacons, log files, scripts and eTags) (“Cookies”) to enhance your experience on the Site. 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.

3. Children

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

By children, we mean users under the age of 18 years old; or in the case of a country where the minimum age for processing personal information differs, such different age.  For users located in certain countries we have listed the relevant minimum age in the table below.

Country in which the user is located

Minimum age of the user

Australia

18

Canada

13

New Zealand

16

United States

13

 

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 parental/guardian consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us at dpo_undawn@proximabeta.com and we will delete such information.

4. How We Use Your Personal Information

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

Personal Information

Use

Newsletter information (via SDK): E-mail address

If you subscribe to our newsletters, we use this information with your consent to send our newsletters and promotion information to you.

Contact information:

· E-mail address

· Any other information you decide to provide us as part of your communication

If you contact us, we use this information to get in touch with you and to respond to your question, issue or request, as applicable.

AIHelp, a third party service provider, will access our mailbox to address any questions, issues or requests you send to us and store a copy of the emails received.

5. How We Store and Share Your Personal Information

Our corporate group operates around the world. Your personal information will be processed on servers that may not be located where you live. No matter where our servers are located, we take appropriate measures to safeguard your rights in accordance with this Privacy Policy. Our servers are located in the United States and Singapore. In addition, your information can be accessed from outside of where you live by our support, engineering and other teams around the world, including the United States and Singapore.

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

· Third parties such as AIHelp that provide services in support of the Site or its features. All companies providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose other than providing us with their services.

· Companies within our corporate group who process your personal information in order to operate the Site or its features. All related group companies may only use your personal information in accordance with this Privacy Policy.

· Regulators, judicial authorities and law enforcement agencies, and other third parties for safety, security, or compliance with the law. There are circumstances in which we are legally required to disclose information about you to authorities, such as to comply with a legal obligation or processes, enforce our terms, address issues relating to security or fraud, or protect our users. These disclosures may be made with or without your consent, and with or without notice, in compliance with the terms of valid legal process such as a subpoena, court order, or search warrant. We are usually prohibited from notifying you of any such disclosures by the terms of the legal process. We may seek your consent to disclose information in response to a governmental entity’s request when that governmental entity has not provided the required subpoena, court order, or search warrant. We may also disclose your information to:

o enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;

o detect, prevent or otherwise address security, fraud or technical issues; or

o protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (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.

6. The Security of Your Personal Information

We are committed to maintaining the privacy and integrity of your personal information no matter where it is stored. 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 via the Internet; any transmission is at your own risk.

7. Data Retention

We do not keep your data for longer than is necessary unless we are required to do so under law. For further details on how long we keep your data, please refer to the time periods set out below.

Personal Information

Retention Policy

Newsletter information (via Tencent Cloud SDK):

Retained for the duration you remain subscribed to our newsletter and deleted within 14 days from receipt of your request to unsubscribe or until the Undawn server is shut down (whichever is earlier).

Contact information

Stored for 2 years on AIHelp’s servers and deleted within 30 days from receipt of your request. AIHelp will access our mailbox to address any questions, issues or requests you send to us and store a copy of the emails received.

 

If we are required to retain your information beyond the retention periods set out above, for example to comply with applicable laws, we will store it separately from other types of personal information. 

8. Your Rights

Some jurisdictions’ laws grant specific rights to users of the Site, which are set out in this section.

Certain rights are set out in the section Supplemental Terms – Jurisdiction-Specific below.

The sub-sections entitled “Access”, “Correction”, and “Erasure” also apply to users that are located in Canada.

The sub-section entitled “Advertising” also apply to users that are located in the United States, Canada, Australia, and New Zealand.

You have certain rights in relation to the personal information we hold about you, depending on where you are located. Some of these only apply in certain circumstances (as set out in more detail below). To exercise any of your rights, please contact us at dpo_undawn@proximabeta.com.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at dpo_undawn@proximabeta.com.

Correction

You have the right to correct any of your personal information we hold that is inaccurate. If you believe we hold any personal information about you and that information is inaccurate, please contact us at dpo_undawn@proximabeta.com

Erasure

You can request that we delete your personal information by contacting us at dpo_undawn@proximabeta.com.

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.

Announcements

We may from time to time send you announcements when we consider it necessary to do so. You may not opt-out of these service-related announcements, which are not promotional in nature.

Advertising

You may choose to stop receiving personalised advertising or marketing promotions from us when using the Site by contacting us at dpo_undawn@proximabeta.com. 

9. Contact & Complaints 

Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to dpo_undawn@proximabeta.com.

In the event that you wish to make a complaint about how we process your personal information, please contact us in the first instance at dpo_undawn@proximabeta.com and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with the data protection authority in the country in which you live or work where you think we have infringed data protection laws.

10. Changes

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here. Please check this page frequently to see if there are any updates or changes to this Privacy Policy.

11. 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 visitors of the Site, 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.

Australia

Overseas Recipients

 

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.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at dpo_undawn@proximabeta.com.

Correction

 

You have the right to correct any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your Site account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at dpo_undawn@proximabeta.com.

 

Children

 

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

Transacting Anonymously

 

Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the Site. 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 Site, including social media integration and in-Site purchases.

 

Your Rights

 

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).

 

Data Transfers

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.

California

This section applies to California residents covered by the California Consumer Privacy Act of 2018 (“CCPA”).

 

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you:

· Identifiers, such as your name and e-mail address.

· If you contact us, any information you decide to provide us as part of your communication.

 

We collect your personal information for the following purposes:

· To provide you with services on the Site, such as:

o sending you our newsletters; and

o getting in touch with you if you contact us and responding to your question, issue or request, as applicable.

· To improve our services, including the functionality of the Site.

 

For additional information about what each type of personal information is used for, see this chart in the main portion of the Privacy Policy.

 

We disclose personal information to the following types of entities:

· Other companies within our corporate group who process your personal information in order to operate the Site.

· Other companies that provide services on our behalf in support of the Site and who are prohibited by contract from retaining, using, or disclosing personal information for any purpose other than for providing their services to us.

· Regulators,  judicial authorities and law enforcement agencies

· Entities that acquire all or substantially all of our business.

 

In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” in the CCPA.

 

Rights under the CCPA:

 

If you are a California resident, you have the right to:

· Request we disclose to you free of charge the following information covering the 12 months preceding your request:

o the categories of personal information about you that we collected;

o the categories of sources from which the personal information was collected;

o the purpose for collecting personal information about you;

o 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

o the specific pieces of personal information we collected about you;

· Request we delete personal information we collected from you, unless CCPA recognises an exception; and

· 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 CCPA.   

 

We aim to fulfil all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

 

How to Exercise Your Rights

 

First, you may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may also exercise your rights, if any, regarding other data by contacting us at dpo_undawn@proximabeta.com.

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 at dpo_undawn@proximabeta.com. Our privacy experts who monitor this email address are also able to answer any questions users may have about the collection, use, disclosure or storage of personal information by our service providers. 

 

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.

 

New Zealand

This section applies to users located in New Zealand:

Overseas Recipients

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.

Access

You have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account. If you believe we hold any other personal information about you, please contact us at dpo_undawn@proximabeta.com. 

Correction

You have the right to request the correction of any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at dpo_undawn@proximabeta.com. 

Children

If you are under the age of 16, you undertake that you have the consent of your parent or legal guardian to register an account on and use the Site.

Your Rights

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).

Data Transfers

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.