Welcome to Undawn!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with Undawn (the “Game”) and the website for the Game (“Website”) (the Game and the Website and 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 Game Services, 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. Limited (“we”, “us”, “our”).

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here. You can also reach out to our data protection officer at dpo_undawn@proximabeta.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, except where their parent or guardian has provided lawful consent (to the extent this option is available in your jurisdiction).

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

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

Region in which the user is located	Minimum age of the user
Algeria	19
Argentina	13
Australia	18
Brazil	18
Colombia	18
Canada	13
Egypt	18
European Economic Area	16
India	18
Japan	18
Kazakhstan	18
Kuwait	21
Mexico	18
Morocco	18
New Zealand	16
Nigeria	13
Qatar	18
Saudi Arabia	18
Serbia	15
South Africa	18
South Korea	14
Sri Lanka	18
Switzerland	16
Tunisia	18
Türkiye	18
United Arab Emirates	21
United Kingdom	13
United States	13

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, Switzerland, Türkiye or the United Kingdom, it also identifies the legal basis under which we process your data.

Personal Information	Use	Legal Basis (where applicable)
In relation to the Game
Information you provide to us (either directly or through a third party).
Account registration information: Twitter account login: user ID, nickname, profile picture, user token and open ID Google Play account login: user ID, nickname, profile picture, user token and open ID Apple account login: user ID, nickname, profile picture, user token and open ID Facebook account login: user ID, nickname, profile picture, user token and open ID Guest account login: guest ID	We use this information to create your account for the Game in accordance with your request.	Necessary to perform our contract with you to provide the Game.
Level Infinite Account log-in information (if you choose to log-in via Level Infinite Account): email address, password, user_ID, nickname, user token, open ID, country, date of birth (we do not store this on our servers)	We use this information to link your Game account to your Level Infinite Account in accordance with your request.	Necessary to perform our contract with you to provide the Game.
Survey information: gender, age or age range, date of birth, email, address, geographic (country or region) location, income information, education data, phone number, nickname, 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 IMUR Survey to take the survey and the IMUR Survey privacy policy will apply to certain data processed in connection with your participation in the survey.	We 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
Crash-related information: For mobile version: Device name, device model, phone memory, CPU usage rate, CPU model, device system version, device brand, ROM, RAM, CPU architecture, remaining memory, system time, XWID, app data (version, package), SDK version, running process information, root status, network type, whether Game is running in a simulator. For PC version: PC Mac Address, Display Card, GPU, CPU, physical memory, virtual memory, system API random-generated GUID, process name, application version, SDK version, SDK information, buried data reporting, resolution, dump file	We use this information to locate and resolve crash issues.	It is in our legitimate interest to improve the Game.
Advertising Information (collected via and shared with Appsflyer, a third party SDK): Technical information: technical information related to your mobile device or computer, such as browser type, device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier. Technical identifiers: various unique identifiers that generally identify your computer, device, browser or application, for example, IP address (which may also provide general location information), user agent, IDFA, Google advertising ID, your user ID issued by us and other similar unique identifiers. Engagement information: your interactions with our advertisement campaigns, such as: your clicks on our ads, ad impressions viewed, audiences or segments to which an ad campaign is attributed, the type of ads and Game from which such ads were displayed, the webpages that you visit from our Game, the URL from the referring app, downloads and installations of the Game and other interactions, events and actions we measure and analyse within the Game (e.g. add to cart, in-app purchases made, clicks, engagement time etc.).	We use this information to monitor the success of our marketing campaigns and to monitor marketing conversion rates.	It is in our legitimate interests to use this information to monitor the success of our advertising and marketing programs.
Survey device data: IP address, browser version, device settings and operating system version.	We use this information to allow you to complete the survey (if you wish to participate) in-app.	We collect this information with your consent.
Game data: player ID, Open ID, device information, player game behavior data (such as player level, in-game performance, purchased items, virtual currency, etc.), location of the player's choice, Android ID, phone memory, device brand, device system version, device manufacturer, ROM, screen resolution, RAM, system time, device model, device ID, device name, CPU model, CPU architecture, app list.	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); monitor network quality and performance; and store your game account information.	Necessary to perform our contract with you to provide the Game.
Text chat data: Technical / log data (open ID, device information (device manufacturer, client exports IP, Universally Unique ID, system time, device model) and other technical information (SDK version, IP address, network type, mobile network code, network monitoring data message)). Chat data (inputted by users) Subject to this feature’s availability in your jurisdiction and to certain users.	We facilitate the posting of your text chat communications with 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: Technical / log data (open ID, device name, device model, device brand, system time and other technical information (SDK version, network type and region ID). Other than the data above, we also process real time voice data, which is processed momentarily by us but not stored on our servers. Subject to this feature’s availability in your jurisdiction and to certain users.	We facilitate your real time voice chat with other users.	Necessary to perform our contract with you to facilitate communication between users where you seek to use chat services.
Voice message data: Technical / log data (open ID, device name, device model, device brand, system time and other technical information (SDK version, network type, region ID), voice message data (recorded by users) Subject to this feature’s availability in your jurisdiction and to certain users.	We facilitate your recording of voice messages for other users to listen to.	Necessary to perform our contract with you to facilitate communication between users where you seek to use voice message services.
Security-related information: your open ID, chat data, Android device information (root status, simulator status, apps installed, running process information, file name list under SD card application cache directory, apppackage name, process name, app version, start-up time, host file, in-game screen), device information (system version, network type, brand, CPU architecture, RAM space size, ROM space size, system startup time, system boot time, jailbreak status, whether external file for cheating purposes has been detected, application package name, application version, start-up time, in-game screen, process name, screen recording status, presence of dylib files and plug-ins), country code, language, the Client IP, avatar, game space photo.	We use this information for anti-cheating purposes, including to detect and observe cheating behaviours and monitor the presence and operation of suspected cheating activity and to filter out profane language or pictures detected on the Game.	It is in our legitimate interest to ensure the security of our Game, to provide a fair environment for players and to improve the Game.
Security-related language filter: open ID, platform ID, area, zone ID, Role ID, role name, VIP level, role rank, Client IP	We use this information for real-time and post-event language filtering for security purposes.	It is in our legitimate interest to ensure the security of our Game, to provide a fair environment for players and to improve the Game.
Log data: open ID, log in channel and information such as time stamps, relevant chat text including receiving and sending packet records of SDK, including IP information of server	We use this information for debugging purposes and to facilitate the profanity filter feature within the Game.	It is in our legitimate interest to ensure the security and functionality of the Game, to provide a fair and secure environment for players and to improve the Game.
Notification Information: System notification: device token, Firebase Cloud Message token In-app notification: open ID, device ID Game server navigation: Open ID Newsletter notifications (collected via and shared with Firebase, a third party SDK): device model and device name (we do not store this on our servers) Email notifications: email	We use this information to send you in-game notifications and newsletter notifications.	Necessary to perform our contract with you to support the Game.
Analytics and profiling data (collected via and shared with Firebase, a third party SDK): user dimensions, device dimensions (age, app store, app version, country, device brand, device category, device model) and in-app events (such as number of users and sessions, advertising analytics like ad clicks, ad exposure, ad impression, ad query, ad exposure, application analytics like app usage, app clearance, app crashes, app removal, app payment analytics, app update and use analytics, website usage analytics like web clicks, browser downloads, notification, video progress, search analytics), session duration, operating systems, geography, time, gender, language, first launches, app opens, app updates, in-app purchases, advertising analytics, website usage analytics, application analytics, search analytics, Google advertising ID, ADID and IDFA, Firebase Installation ID.	We use this information to carry out data analytics, app performance analytics and profiling for ad attribution purposes to understand how our users interact with advertisements. We also use this information to monitor and analyse in-game purchase rates of new users.	It is in our legitimate interests to use this information to monitor the success of our advertising and marketing programs.
Analytics and reporting data (collected via and shared with Appsflyer, a third party SDK): Report Instance ID generated by Firebase and your open ID.	We use this information to monitor the success of our marketing campaigns and to monitor marketing conversion rates.	It is in our legitimate interests to use this information to monitor the success of our advertising and marketing programs.
Analytics and profiling data (collected via and shared with Appsflyer, a third party SDK): Technical information: browser type, device type and model, CPU, system language, memory, OS version, Wi-Fi status, time stamp and zone, device motion parameters and carrier Technical identifiers: IP address, user agent, identifiers for advertisers, Google Advertising ID, open ID, Android ID Engagement information: ad clicks/impressions, audiences or segments to which an ad campaign is attributed, the type of ads and the webpage or application from which such ads were displayed, URL from the referring website, downloads and installations, other interactions, events and actions customers choose to measure and analyse.	We use this information to carry out data analytics, app performance analytics and profiling for ad attribution purposes to understand how our users interact with advertisements.	It is in our legitimate interests to use this information to monitor the success of our advertising and marketing programs.
Analytics and profiling data (collected via and shared with Facebook, a third party SDK): Contact information: name, email address, and phone number Event data: information you share about others and the actions they take on your websites, apps, or stores, such as visits to sites, installations of apps, and purchases of products Hashed data: email address and phone numbers	We use this information to carry out data analytics and profiling for app performance analytics and ad attribution purposes to understand how our users interact with advertisements.	It is in our legitimate interests to use this information to monitor the success of our advertising and marketing programs.
Data analytics (report key statistics): Common information for data reporting including event name, stage number, stage name, stage status, stage error code, extra json, stage time	We use this information to report key statistics from the processes of log-in and Game update.	It is in our legitimate interests to use this information to monitor the success of our advertising and marketing programs.
Data analytics (user acquisition): Data relating to user registering (e.g. the stage at which user’s drop out, how long do users remain at a particular stage), logging in, game update; and browser data, PC Universally Unique ID, time zone, resolution, IP address, language and technical information (Game ID, client source, session ID, event time, client IP, country, province, city, carrier ID, Open ID, event name, OS, OS 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)	We use this information to analyze the user acquisition process, to better understand where all users who downloaded the Game originated from.	It is in our legitimate interests to use this information to improve the user acquisition process.
Log statistics information: client IP address	We use this information to analyze regional distribution of user requests to accelerate bandwidth resources in the region	Necessary to perform our contract with you to provide the Game.
Compliance information: open ID, token, region, username and email address.	We use this information to facilitate our compliance with applicable laws.	Necessary to perform our contract with you to provide the Game.
Data monitoring information: information about the interactions between the SDKs, such as error codes, error messages, SDK name, SDK version, request URL, response body, stage, log, common information for data reporting.	We use this information to analyse the performance of the SDKs within the Game and interaction of our SDKs in order to ensure the smooth operation of the Game.	It is in our legitimate interest to improve the Game.
XWID: Your XWID, which is generated by us	We us this information to perform general/overall game analytics (not confined to error fixing or debugging), and to enable you to use the Game as a guest user.	It is in our legitimate interest to improve the Game.
Account deletion data: email, region, Open ID, user token	We use this information to allow you to delete your account.	Necessary to perform our contract with you to allow you to delete your account
Character customization: image uploaded by you (from device gallery or device camera - not stored locally in device but uploaded), dimension and resolution; face ID (ID for the chosen avatar, including gender and skin colour chosen by player for in-Game avatar), timestamp, version number of feature, channel ID, device operating system, Open ID, Role ID. We do not store the original photo.	We use this information to allow you to customize your game character with photos uploaded from your device or gallery, or photos taken from your device’s camera.	We process this information with your consent.
In-game photo space: in-game photos uploaded by you, likes and comments from users, Role ID, blue ID, comment ID, picture ID	We use this information to allow you to share and comment on photos about the Game, and to create avatars. We use this information to detect if the text comments is in breach of our End User Licence Agreement.	We process this information with your consent. It is in our legitimate interests to ensure the integrity of the Game and protect users from prohibited conduct.
Image content moderation: media uploaded by you, open ID	We use this information to detect if the in-game photos you upload includes content in breach of our End User Licence Agreement (such as violence, hate or sexual content).	It is in our legitimate interests to ensure the integrity of the Game and protect users from prohibited conduct.
Security-related profanity filter: Open ID, platform ID, area, zone ID, role ID, role name, VIP level, role rank, client IP, chat text	We use this information to detect if your text includes content in breach of our End User Licence Agreement (such as advertising, violence, abusive text, hate, sexual / vulgar content).	It is in our legitimate interests to ensure the integrity of the Game and protect users from prohibited conduct.
Customer Service Data: Identity information: Open ID, role ID; Device information: Device brand, device system version, device manufacturer, device model, device name Social platform information: Social platform nickname (of the platform you use to log in to the Game); Login channel ID, SDK version, application version, IP address, network type, client language, buried data reporting, Data relating to your questions and our communications (including any images sent by you) Click actions and view duration	We use this information to: provide you customer support, including to: provide a Q&A function and customer service, and respond to your communications; provide troubleshooting, such as addressing and remediating technical issues and bugs; send you in-app push notifications on updates and reminders; operate, and carry out analytics to improve our services.	Necessary to perform our contract with you to provide and support the Game services. It is in our legitimate interest to improve our services.
GCloud SDK data – Dolphin, Puffer and Maple: Open ID, device name, device model and login channel ID	We use the GCloud SDKs data to provide connection stability, manage Game resources and version updates, as well as Game maintenance and communications between servers.	Necessary to perform our contract with you to provide the Game.
CROS Data Interface Platform data: Open ID, nickname, game level, gold coins, game area, community, and country	We use this information to provide unified standard interface service to the Game, and real-time data access support for our OS.	It is in our legitimate interest to improve our services.
CROS Game experience management information: device name, device model and Open ID	We use this information to request permissions from control servers, monitor network quality and performance, and monitor user’s access to the game lobby.	Necessary to perform our contract with you to provide the Game.
Tencent Data Master data: Android ID, phone memory, device brand, device system version, device manufacturer, ROM, screen resolution, RAM, system time, device model, Device ID, device name, CPU model, CPU architecture, SDK version, IP address, mobile network code, network type, IDFV, application package name, application version, IDFA	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.
In-game events information: Open ID, Role ID	We use this information to store user game account information, send in-game props to users, and search logs.	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. Information collected via user’s game data query: Game account information, including registered user name, social media account, mobile phone number, registration time, VIP level; 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 Information provided by users for guest finding account function: Log-in channel (iOS or Android), role name, device model, friends names, time of registration, time of last log-in, time of last top-up, nickname, email address, email verification code, purchase history, ranking and playtime record	We use this information: to improve our services; to respond to your communications; to provide troubleshooting, such as addressing and remediating technical issues and bugs; and to allow users logged in via guest login who have lost their accounts to find their lost Game accounts.	Necessary to perform our contract with you to provide and support the Game.
Payment information (Midas SDK): Open ID, country, role ID, screen resolution, client exports IP, CPU model, remaining memory, remaining SD card space, screen orientation, device model, Android ID, currency, SDK version, application version, IP address, network type, buried data reporting, network monitoring data, IDFV	We use this information to enable you to use the payment function in the Game.	Necessary to perform our contract with you to provide the Game.
Payment information (Midasbuy): Purchased items and their costs, time, date and currency of the purchase, order ID, Open ID, player ID, country, game account balance and purchase history	We use this information to enable you to use the payment function in the Game.	Necessary to perform our contract with you to provide the Game.
In relation to the Website
Contact information: Name 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.	Necessary to perform our contract with you to provide the Contact Us feature.
Newsletter registration information (via Amazon Simple Email Service (“Amazon SES”)): E-mail address and email transactional information (transactional email delivery history, IP address, delivery status and timestamp for emails sent via Amazon SES)	If you subscribe to our emails, we use this information with your consent to send our emails related to the Game.	We process this information with your consent.

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, Germany, Korea, Japan, and the United States. 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 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.

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 Services, including providers of cloud services that process information identified in this policy on their servers for the purpose of providing the Game; third party SDKs (e.g. from Appsflyer, Firebase) for the purpose of monitoring the success of our marketing and advertising programs and profiling, monitoring and analysing views, clicks and engagement with the advertisements displayed in the Game, which process the relevant data analytics, profiling and user acquisition data identified in the policy in the United States, Belgium and Ireland; our partners for the purposes if promoting the Game; and service providers in support of the Website (such as Google Analytics, AIHelp and Amazon SES). 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 solely for the purpose of providing the Game Services to you. All such group companies may only use your personal information in accordance with this Privacy Policy.

Regulators, judicial authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you, such as to comply with legal obligations or processes. In complying with the terms of valid legal processes, such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in advance of such disclosure.
Third parties to ensure safety, security, or compliance with laws. We may disclose your information to:
- enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
- detect, prevent or otherwise address security, fraud or technical issues; or
- protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (such as exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

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
In relation to the Game
Account registration 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.
Security-related information Log data GCloud SDK data Tencent Data Master data Image content moderation Security-related profanity filter	Stored for 90 days or deleted manually upon your request within 30 days from receipt of the request (whichever is earlier).
Survey information Survey device data	Deleted automatically after 1 year or deleted manually upon your request within 30 days from receipt of the request (which is earlier).
Analytics and profiling data (Firebase) Analytics and profiling data (AppsFlyer) Analytics and profiling data (Facebook) Analytics and reporting data (AppsFlyer) Advertising information (AppsFlyer) Customer support information (in-app)	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. Where you do not request for account deletion, such data will be retained for 30 days after the Game is shut down, before it is deleted.
Data analytics (report key statistics) Data analytics (user acquisition) Data monitoring information In-game events information XWID	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. Where you do not request for account deletion, such data will be retained for 1 year after the Game is shut down, before it is deleted.
Game data CROS Game experience management information	Stored for 30 days or deleted manually upon your request within 30 days from receipt of the request (whichever is earlier).
Level Infinite Account log-in 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. Date of birth is processed momentarily by us but not stored on our servers.
Log statistics information	Stored for 180 days.
Crash-related information	Stored for 3 months or deleted manually upon your request within 30 days from receipt of the request (whichever is earlier).
Security-related language filter	Not stored.
Text chat data	In terms of your chat data, up to 50 messages will be stored on a rolling basis. If you are a minor and using the quick chat service with parental consent, up to 100 messages will be stored on a rolling basis. Stored for 7 days on our servers and deleted automatically upon expiry of such period.
Real time voice chat data	Real time voice data is processed momentarily by us but not stored on our servers.
Voice message data	Stored for 7 days on our servers and deleted automatically upon expiry of such period.
Notification information	Information other than email: 30 days. Email: Stored until 1 year after the Game is shut down.
CROS Data Interface Platform data	Data instructed to be stored on Tencent Cloud CLS is deleted automatically after 7 days. Data stored on Tencent Cloud TBDS is deleted after 3 months.
Character customization In-game photo space	The original photo (uploaded from user's device) is not stored. The customized character image and in-game photo space data will be 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. Where you do not request for account deletion, such data will be retained for 90 days after the Game is shut down, before it is deleted.
Account deletion information	Retained for the cool-down period (i.e. 30 days).
Customer Service Data	OpenID, in-game purchase history and in-game log-in data: 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. Where you do not request for account deletion, such data will be retained for 30 days after the Game is shut down, before it is deleted. Chat messages: Stored for 90 days (unless you request deletion of such data or your account, in which case we will delete such data within 7 days after your request).
Payment information (Midas SDK) Payment information (Midasbuy)	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. Where you do not request for account deletion, such data will be retained for 3 months after the Game is shut down, before it is deleted.
Compliance information	Stored for 1 year after the Game is shut down.
In relation to the Website
Contact information	Stored for 2 years on AIHelp’s servers and deleted within 30 days from receipt of your request.
Newsletter registration information (via Amazon SES)	Emails: Stored for 14 days and be deleted. Email address (of sender and recipient): Stored for 14 days and be deleted. Transactional information: Passing state in email actions is stored for 30 days and email program metrics is stored for 90 days.

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. You can access the personal information you have made available as part of your account by logging into your account.

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. You can access the personal information we hold about you by logging into your Game account.

Erasure

You may be able to delete your account, or remove certain personal information, by logging into your Game account. We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Game 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_undawn@proximabeta.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_undawn@proximabeta.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.

Announcements

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

8. Contact

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

Email: dpo_undawn@proximabeta.com

Mailing Address:

Tencent International Privacy & Data Protection Centre

30 Raffles Place #19-01

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.

Our Representatives in Certain Jurisdictions

Jurisdiction	Representative	Address	Contact details
EU	Proxima Beta Europe B.V.	Buitenveldertselaan 3-5 1082 VA Amsterdam	dpo_undawn@proximabeta.com
UK	Image Frame Investment (UK) Limited	Suite 1, 3rd Floor 11 - 12 St. James's Square, London, United Kingdom, SW1Y 4LB	dpo_undawn@proximabeta.com
Korea	Kite Bird Korea Yuhan Hoesa	25F, 55, Sejong-daero, Jung-gu, Seoul (Taepyeongro 2-ga), Korea	dpo_undawn@proximabeta.com
Serbia	Karanovic & Partners o.a.d. Beograd	Resavska 23, Belgrade, 11000, Serbia	local.representative@karanovicpartners.com
Türkiye	Özdağıstanli Ekici Avukatlık Ortaklığı.	Nidakule Ataşehir Kuzey, Begonya Sok. No:3 Kat. 17 D: 162 / 34746 Ataşehir Istanbul Turkey 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-Game conduct, bans, investigations, civil or criminal complaints.	turkeydatarep_proximabeta@iptech-legal.com

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, 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 undertake that you have the consent of your parent or legal guardian to register an account on and use the Game Services.

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 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).

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.

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 or your device:

Identifiers, such as your name as it appears on your social media 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.
Internet or other electronic network activity information, such as your information regarding your use of the Game Services, such as date and time stamps of actions and log-in data and other device information as described in the main Privacy Policy. This information is collected directly from you and your device.
Geolocation data 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, 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 income if you choose to provide it in a survey. This information is collected directly from you.
Other information described in subdivision (e) of Section 1798.80, including information about your gender, nationality, or age. This information is collected directly from you in the context of being our consumer.

We collect your personal information for the following purposes:

To provide you with the Game, maintain your account, provide customer service, and deliver audio and text messages.
To process surveys
To improve our services, including the functionality of the Game Services.
To provide you with newsletter and contact us features of the Website
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 personal information to the following types of entities:

Other companies within our corporate group who process your personal information in order to operate the Game Services.
Other companies that provide services on our behalf in support of the Game Services 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:
- the categories of personal information about you that we collected;
- the categories of sources from which the personal information was collected;
- the purpose 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 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 as specified in Section 8 (Contact).

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).

India

Where we permit any third parties to collect and use sensitive personal information, we shall use reasonable measures to ensure that the third parties do not further disclose such information to the extent required by applicable laws.

To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us for certain processing activities by contacting us as set out in Section 8 (Contact). Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent, we may not be able to deliver the expected service.

Japan

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

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 obtain your parent’s or legal guardian’s consent to register an account on and use the Game Services.

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, Germany, Korea, Japan, and the United States.

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.

Mexico

Some of the purposes of processing specified in Section 3 (How We Process Your Personal Information) are voluntary, which may include to show you personalised recommendations or advertising.

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, as well as the applicable means, procedures and requirements to exercise any of your rights as specified in Section 8 (Contact).

You can register with the Public Registry to Avoid Advertising (‘REPEP’) (REPEP (profeco.gob.mx) ) to refuse to receive advertising to your phone number.

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 undertake that you have the consent of your parent or legal guardian to register an account on and use the Game Services.

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.

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.

Data Protection Team, responsible for the management and safety of your personal information
Contact: as set out in Section 8 (Contact)

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

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

Name of Recipient (and contact information)	Types of Personal Information provided	Purpose of Use by Recipient	Period of Retention and Use by Recipient
Appsflyer Limited (privacy@appsflyer.com)	Advertising information	User acquisition purposes and to monitor the effectiveness of our advertisements	For the data retention period specified under “How We Store and Share Your Personal Information”.
Facebook Analytics	Contact information, event data and hashed data	User acquisition purposes and to monitor the effectiveness of our advertisements	For the data retention period specified under “How We Store and Share Your Personal Information”.
Google Analytics (Firebase)	Analytics data	Data analytics	For the data retention period specified under “How We Store and Share Your Personal Information”.

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

Delegatee	Description of Delegated Services
Aceville Pte Ltd (cloudlegalnotices@tencent.com)	Data processor: Processes and stores data on behalf of the data controller
Midas	Provide payment function
AIHelp (privacy@aihelp.net)	Process information to provide customer service to users
Tencent Cloud LLC (cloudlegalnotices@tencent.com)	Storage of personal information
Microsoft Cloud	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
Aceville Pte Ltd (cloudlegalnotices@tencent.com)	Singapore	Transmitted 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”.
Appsflyer Limited (privacy@appsflyer.com)	Belgium and Ireland	Transmitted from time to time	Data analytics and profiling information	User acquisition purposes and to monitor the effectiveness of our advertisements	For the data retention period specified under “How We Store and Share Your Personal Information”.
Facebook Analytics	United States	Transmitted from time to time	Data analytics and profiling information	User acquisition purposes and to monitor the effectiveness of our advertisements	For the data retention period specified under “How We Store and Share Your Personal Information”.
Google Analytics (Firebase)	United States	Transmitted from time to time	Data analytics and profiling information	Data analytics	For the data retention period specified under “How We Store and Share Your Personal Information”.
Midas	Singapore and United States	Transmitted from time to time	Payment information	Payment	For the data retention period specified under “How We Store and Share Your Personal Information”.
AIHelp (privacy@aihelp.net)	United States	Transmitted from time to time	Contact information	Process information to provide customer service to users	For the data retention period specified under “How We Store and Share Your Personal Information”.
Tencent Cloud LLC (cloudlegalnotices@tencent.com)	Germany, Korea, Japan	Transmitted 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”.
Microsoft Cloud	United States	Transmitted 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), Korea
Telephone Number: +82-2-2185-0902
Email: specified in Section 8 (Contact)

Contact

Data Protection Department, responsible for the management and safety of your personal information
Telephone: +82-2-2185-0902
Email: specified in Section 8 (Contact)

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

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 undertake that you have the consent of your parent or legal guardian to register an account on and use the Game Services.

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
Aceville Pte Ltd (cloudlegalnotices@tencent.com)	Singapore	Storage of personal information	All personal information collected
Appsflyer Limited (privacy@appsflyer.com)	Dublin, Ireland hosted by AWS and in St. Ghislain, Belgium hosted by Google Cloud, United States	User acquisition purposes and to monitor the effectiveness of our advertisements	Advertising information and data analytics/profiling information
Facebook Analytics	United States unless otherwise described in the service provider’s privacy policy	User acquisition purposes and to monitor the effectiveness of our advertisements	Contact information, event data and hashed data
Google Analytics (Firebase)	United States unless otherwise described in the service provider’s privacy policy	Data analytics	Analytics data
Midas	Singapore and United States	Payment	Payment information
AIHelp	United States	Customer service	Contact information
Tencent Cloud LLC	Germany, South Korea, Singapore	Storage of personal information	All personal information collected
Microsoft Cloud	United States	Storage of personal information	All personal information collected

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 other than Ukraine, to the extent and for the purpose provided by 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.

Virginia

This section applies to Virginia residents covered by the Virginia Consumer Data Protection Act (“VCDPA”). For purposes of this section, “personal data” and “sensitive personal data” have the meanings given in the VCDPA and do not include information excluded from the VCDPA’s scope.

If you are a Virginia resident and the law does not recognize an exception that applies to you or your personal data, you have the right to:

request that we disclose to you the personal data that we collect, use, or disclose, and information about our data practices.
request we delete personal data we collected from you, unless the law recognises an exception;
request we correct inaccurate personal data that we maintain about you;
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 law.

We do not collect sensitive personal data about you. We also do not process personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

How to Exercise Your Rights

First, you may wish to log into your account and manage your data from there. If you are a Virginia resident to whom the VCDPA applies, you may also exercise your rights, if any, regarding other data by contacting us as specified in Section 8 (Contact)

How to Appeal Decision on Your Request

If you would like to appeal a decision on your request to exercise any right you have under the VCDPA, you may contact us as set out in Section 8 (Contact).

What information do we need to be able to provide the Game Services?	In relation to the Game: If you register an account to use the Game, then we will need some information from you to set this up. This includes a user ID, nickname, profile picture and user token. We will generate an Open ID, which is an internal ID for your account. 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. If you choose to set up your profile using a social media account, we collect information provided by your social media account service provider to automatically generate your profile, including user ID, name, profile picture and user token. We will generate an Open ID. 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, connection information, device specifications, as well as app- and OS-generated identifiers). If you wish to participate in our surveys, we will process survey information and survey device data, such as email, address, geographic (country or region) location, IP address and browser version, with your consent to better understand our users and to improve the Game. If you need to get in touch with us, we will retain some information (such as your player identity information, device information and interactions with our help services) so that we can review and respond to your concerns. In relation to the Website: If you register to receive newsletter or contact us then we will collect your email address.	More Information.
How will we use your information?	We use your information to set up your account, 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, resolve user queries, provide you with newsletter, allow us to get in touch with you, and to comply with our legal obligations and enforce our legal rights.	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, Germany, Korea, Japan, and the United States. The servers applicable to your use of the Game will depend upon your location. We also have support, engineering and other teams who may support the Game Services, including from Singapore 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 an account for the Game, or for so long as the information is needed to fulfil the purpose for which it was collected (as further described in this Privacy Policy). We then delete or anonymise such data, in accordance with applicable laws.	More Information.
How can I exercise my rights over my information?	Certain jurisdictions offer users specific rights with respect to their information, so you may have a right to access or receive a copy of your data, or to delete your data or restrict or object to our processing of your data.	More Information.
How will we notify you of changes?	Changes to this Privacy Policy will be posted here. We will also notify you of changes in accordance with relevant legal requirements.	More Information.