Exoborne

Privacy Policy

Last Updated: 10 October 2024

Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Please note that this privacy policy (“Privacy Policy”) applies to the game Exoborne (“Game”) and the main website for the Game (“Website”, which together comprise 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 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.

For the purpose of data protection laws, the data controller of your personal information in relation to the Game Services is Proxima Beta Pte. Ltd.

SUMMARY

Here is a summary of the information contained in this Privacy Policy. You can find more detail by clicking ‘More Information’.

What information do we need to be able to provide the Game Services?

In relation to the Website:

· If you register to receive updates on the development of the Game, then you will need to provide your email address, among other information.

· To monitor the performance of the Website and perform statistics on page view and user view of the Website, we will process customary device and network information (such as IP address).

· If you register for our Game playtests, then we may process your region, date of birth, Discord ID or Steam ID, email address, and other information you provide on our survey questionnaire (such as your gaming habits, gaming preferences and device specifications).

In relation to the Game:

· If you register an account for or log in to use the Game  (via LEVEL INFINITE PASS), we will need some information from you to set this up. This includes your email address, password, user ID, nickname, user token, and country. We will generate an Open ID, which is an internal ID for your account. Depending on your use of the Service 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, such as user ID, nickname, profile picture, user token and Open ID.

· To maintain the smooth operation of the Game Services (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 as well as app- and OS-generated identifiers).

· If you choose to answer a survey, we collect survey response content that you choose to provide in the survey, such as email, country or region of residency, and gaming habits and preferences.

· If you need to get in touch with us, we will retain some information (such as your email and any screenshots you send us) so that we can review and respond to your concerns.  

More Information.

How will we use your information?

· In relation to the Website: We use your information to enable you to optimise and improve the Website, provide you with news and updates to the Game, and consider your eligibility to participate in Game testing events and contact you regarding the same.

· In relation to the Game: We use your information to set up your account, enable you to use the Game, localise the Game experience, enable interaction between users of the Game, save your progress, ensure the safe and secure operation of the Game, address bugs, optimise and improve the Game, protect users, monitor our marketing initiatives, resolve user queries, and to comply with our legal obligations and enforce our legal rights.

More Information.

Who do we share your information with?

· We may from time to time use third parties and work with our affiliates to help us deliver the best possible experience.

· All third party service providers providing services for us (if any) 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, the United States, Germany, Belgium, and the Netherlands. We also have support, engineering and other teams who may support the Game Services, including from Singapore, the United States, Germany, the PRC, Finland, Portugal, and Sweden.

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

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 use a LI Account to register 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.


Welcome to Exoborne!

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

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found dpo_exoborne@levelinfinite.com. You can also reach out to our data protection officer at dpo_exoborne@levelinfinite.com 

1. Cookies

We use cookies, webhooks 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). Except with such consent, children must not use the Game Services for any purpose.

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

Region in which the user is located

Minimum age of the user

Canada

13

European Economic Area

16

Serbia

15

Switzerland

16

United Kingdom

13

United States

13

 

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.

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 the European Economic Area, Switzerland 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 Website

Subscription information: email address, IP address, country and language.

We use this information to send you notifications and updates about the development, progress and launch of the Game, as well as for recruitment for customer engagements and user testing of the Game.

We use this information only with your consent.

IP Address

We use this information to perform statistics on page view and user view on the Website.

It is in our legitimate interests to use this information to monitor the page view and user view of the Website.

Technical information such as IP address, device operating system (Android or iOS) and CPU information. 

Please note that this is supported by a Tencent Cloud module, Real User Monitoring.

We use this information for monitoring the performance of the Website and for troubleshooting, such as addressing and remediating technical issues and bugs.

Website monitoring: It is in our legitimate interests to use this information to monitor the performance of the Website.

Troubleshooting: Necessary to perform our contract with you to provide the Website.

Playtest Registration Survey Information: information you provide when registrating for our Game playtests, including IP address, selected region, date of birth, Discord ID or Steam ID, email address, and other information you provide on our survey questionnaire (including your gaming habits, gaming preferences and device specifications).

We use this information to determine if you are eligible to participate in existing and/or future Game testing events, and to contact you if you are selected to participate in a Game testing event and to further improve our Services and/or develop new services based on survey responses.

We use this information only with your consent.

In relation to the Game

Information you provide to us (either directly or through a third party) 

Account log-in information:

Social Media Information (if you choose to log in via your account with these networks) that such social media companies provide:

· Steam: User ID, nickname, profile picture, user token, Open ID (see https://store.steampowered.com/privacy_agreement/)

· LEVEL INFINITE PASS: email address, password, user token, Open ID, country, date of birth (we do not store your date of birth on our servers) (see https://account.levelinfinite.com/privacypolicy.html)

We use this information to allow you to register and create your account for the Game (including by linking your game account to another account of an eligible platform) in accordance with your request, log in to the Game and participate in game activities and receive notifications of the Game.

Necessary to perform our contract with you to provide the Game.

Data interface platform (IDIP) data: Open ID, player game behaviour and attribute information, game level, virtual currency (Game gold coins), game area, guild information, country

We use this information to provide a unified standard interface service for our games products, and provide support for our operating systems.

It is in our legitimate interest to use this information to provide a unified standard interface service for our games products, and support our operating systems.

 

Survey information (via IMUR) (aggregated data): game experience feedback, gender, age range, game username, discord ID, work industry , and any other personal information you provide in your survey responses

 

To the extent you choose to participate in an in-game survey regarding the Game Service, 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 only receive aggregated survey data from IMUR.

We use this information to better understand our users and to improve the Service with your consent.

We collect this information with your consent.

Information generated as part of the Game

Databrain information:

· Country, login online time, overall Game performance information (new and active users, revenue, register retention users, device information, gameplay data);

· Event time, zone area ID, platform ID, user ID, client IP, login channel, system language, country;

· Gameplay data (such as user level, currency, activity, map)

We use this information to receive insights related to the Game and our users, in order to monitor the performance of the Game and improve the Game Services.

It is in our legitimate interests to use this information to monitor the performance of the Game and improve the Game Services.

XWIDYour XWID, which is generated by us

We use this information for guest login and debugging.

It is in our legitimate interest to use this identifier for guest login and debugging.

SDK data monitoring information:

· Error code, error message, SDK name, SDK version, request URL, response body, sequeqnce ID, stage, common data reporting 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, login channel ID, device model, device brand, screen width, screen height, CPU name, CPU core,  CPU frequency, GPU name, total ROM, system language, UAID)

We use this information to fix bugs, and to understand the performance and interaction of our SDKs.

It is in our legitimate interest to use this information to fix bugs and monitor the performance of our SDKs.  

Email Segmentation Data: email address, Open ID, subscription status, subscription preferences, language, region, tags, source, add date, when subscription status was last changed date

We use this data to send you information that may be of interest to you if you sign up for marketing messages.

We use this information with your consent.

Customer Support Information:

· Game account and contact information (including your nickname, profile picture, Open ID, country selected by you during registration, login channel, social media account, mobile phone, email address, registration time);

· Login status verification information;

· Device information;

· Game data: Game character information (including your role name and role ID, game data and records, frequency of playtime, game history), and in-game data (including items, penalties, activities, game match data, in-game friends);

· Customer service log data: including Open ID, ticket date, type of request;

· Feedback on app store;

· Any other details/information (including any documents/media) that you choose to provide to us as part of your ticket, query or review

 

We use this information to provide troubleshooting, such as addressing and remediating technical issues and bugs, to improve our services, and for account recovery.

Necessary to perform our contract with you to provide and support the Game Service.

IP address

We use this information to allow you to use the Game Service.

We do not store this data on our servers.

Necessary to perform our contract with you to provide the Game Service.

Profanity filtering information: User account information (account ID, username, user ID, profile picture), IP address, user generated content (text chat)

We use this information to filter profanity, abusive language or other uses of chat in violation of our End-user License Agreement.

It is in our legitimate interest to ensure the integrity of the Game and protect users from prohibited conduct.

Chat data: real-time voice chat data and text chat messages

We use this information to facilitate your communication with other users in the Game.

Necessary to perform our contract with you to provide the chat services in-Game.

 

Log data: log consisting of submitted content (e.g., user ID, operation type (e.g. gift, query), volume and reason), and whether successful or failed

We use this information (i) to distribute in-Game props to users, (ii) for troubleshooting, such as addressing and remediating technical issues and bugs, and (iii) to improve the Game Services.

 

Distributing props: Necessary to perform our contract with you to provide the Game.

Troubleshooting: Necessary to perform our contract with you to provide the Game.

Improve the Game: It is in our legitimate interest to improve the Game Services.

Sharkmob data: Open ID, nickname, game statistics on game play (such as hours played, hardware specs, usage of game features and ingame items)

We use this information to ensure that the game servers and backend is operating as required.

Necessary to perform our contract with you to provide the Game Service

Anti-cheating information: Open ID, nickname

We use this information to prevent and detect cheating or other conduct that may compromise the integrity of the Game or otherwise violate our terms.

It is in our legitimate interests to use this information to protect the fairness and integrity of the Game.

4. How We Store and Share Your Personal Information

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

We have servers for the Game Services in Singapore, the United States, Germany, Belgium, and the Netherlands. The servers applicable to your use of the Game Services will depend upon your choice of server and/or location. We also have support, engineering and other teams who may support the Game Services, including from Singapore, the United States, Germany, the PRC, Finland, Portugal, and Sweden.

 

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

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

· Third parties that provide services in support of the Game Services, including providers of services that process information identified in this policy, for the purpose of providing the Game Services, providing cloud storage services (such as Google Cloud Platform and Amazon Web Services), and providing anti-cheating functionalities. All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Game Services (i.e., for the purpose(s) described above).

· Companies within our corporate group who process your personal information solely for the purpose of providing the Game Services to you, e.g. Tencent Cloud.  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:

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 (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 Website

Subscription Information

 

 

Stored for as long as you subscribe to receive our notifications and updates and deleted within 7 days from receipt of your unsubscription request.

IP Address 

 

Stored for the lifetime of the Website or deleted within 30 days from a data deletion request (or a shorter time period as required by the relevant jurisdiction’s data protection law).

Technical Information

 

Stored in accordance with the retention periods stated in the Tencent Cloud Privacy Policy and Data Processing and Security Addendum for Real User Monitoring.

Playtest Registration Survey Information

Stored for 30 days after completion of the Game playtests (closed beta test), or deleted within 30 days of your deletion request, whichever is earlier.

In relation to the Game

Databrain information

Stored for 2 years (unless the Game is terminated or user requests account or data deletion, in which case such data would be deleted within 30 days thereafter).

XWID

SDK data monitoring information

 

Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with user's reques) and then deleted within 30 days thereafter.

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.

Account log-in information

Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with user's request) and then deleted within 30 days thereafter, other than user token and adult status which stored for 30 days after the last log-in.

Email Segmentation Data

Stored for the lifetime of your use of the Service and deleted within 7 business days if you request for deletion, unless otherwise required to ensure compliance with terms, conditions, policies and legal obligations.  

Data interface platform (IDIP) data

Stored for 7 days.

Customer Support Information

Stored for the duration of the relevant Game playtest and deleted within 30 days thereafter.

Profanity filtering information

Stored for up to 7 days, unless violation has been detected (in which case evidence of violation will be stored for the lifetime of ht euser’s use of the Game).

Chat data

Real-time voice chat data: We do not store this on our servers. This is only processed momentarily by us to deliver your chat communications.

Text chat messages: Stored until the end of the relevant Game playtest.

Sharkmob data

User data is stored for the lifetime fo the user.

Logs are only retained for up to 30 days.

Anti-cheating information

 Stored for the lifetime of your use of the Game (i.e. until account deletion in accordance with user's reques) and then deleted within 30 days thereafter.

Survey information (via IMUR)

Stored for 1 year (unless you request deletion of this data, in which case such data would be deleted within 30 days thereafter).

 

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 account.

Erasure

You may be able to delete your account, or remove certain personal information that we hold about you. 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 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_exoborne@levelinfinite.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_exoborne@levelinfinite.com

Mailing Address:

Tencent International Privacy & Data Protection Centre

79 Robinson Rd #07-01

Singapore 068897

We will endeavour to deal with your request as soon as possible. This is without prejudice to any right you may have to launch a claim with a data protection authority in the region in which you live or work where you think we have infringed data protection laws.

9. Changes

If we make any changes to this Privacy Policy we will post the updated Privacy Policy here and notify you in accordance with relevant legal requirements.

10. Language

Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this Privacy Policy, the English version shall prevail.


SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Game Services, which are set out in this section. If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.

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.

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).

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

Ukraine

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

United States

For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”), and respectively include the terms “personal data” and “sensitive data” as defined in the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”),  (collectively, “US State Laws”).

 

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed for a business purpose the following categories of personal information from or about you or your device:

· Identifiers, such as your Open ID / user ID, your user ID on third party platforms (including LEVEL INFINITE PASS username or Steam ID), IP address and email address and nickname. This information is collected directly from you and your device and from social media platforms if you choose to sign up using a social media account.

· Characteristics of protected classifications under California or federal law such as age. This information is collected directly from you in the context of being our consumer.

· Internet or other electronic network activity information, such as your information regarding your use of the Game Services, including level, score, date and time stamps of actions, log-in and clickstream data, page views 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 country 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, and audio messages. This information is collected directly from you and from social media platforms if you choose to sign up using a social media account.

· Professional or employment-related information such as your profession if you choose to provide it in a survey. This information is collected directly from you.

· Account log-in information, including the username and password used to access your Game account.*

· Contents of your chat messages sent on the Game*. This information is collected from your device, is only stored on your device, and is not retained by our servers.

 

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

· To enable you to register for an account with the Game Services.

· To provide you with the Game Services.

· To process surveys.

· To improve our services, including the functionality of the Game Services.

· To monitor the performance of the Game Services.

· For security and verification purposes, including to prevent and detect fraudulent or cheating activity.

· To address and remediate technical issues and bugs.

· To allow you to participate in our surveys and assess your eligibility for game testing event, to further improve our services and develop new services based on survey responses.

 

For additional information about what each type of personal information is used for, see Section 3 (How We Process Your Personal Information).

 

We disclose each of the categories of personal information that we collect to the following types of entities as described in Section 4 (How We Store and Share Your Personal Information).

 

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

 

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

 

Retention of Your Personal Information

 

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

 

Rights under US State Laws

 

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

· Right to Access/Know. Request we confirm whether we process information about you and give you access to that information. You may also request to receive that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment. If you are a California resident, you may request the following information about our collection, use and disclosure of your information:

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 business or commercial purposes 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 to Delete. Request we delete personal information we collected from you;

· Request to Correct. Request we correct inaccurate personal information that we maintain about you; and

· Right to Non-Discrimination. Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the US State Laws.   

 

How to Exercise Your Rights

 

First, you may wish to log into your account and manage your data from there. Depending on where you live, you may also exercise your rights, you may also exercise your rights, if any, regarding other data by contacting us as specified in Section 8 (Contact). We may take steps to verify your identity before complying with your request to protect your privacy and security, and may decline your request if we are unable to verify your identity.  To verify your identity, we may need the following information from you: your first name, last name, address, phone number, date of birth and email address.   

 

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

 

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

 

Questions

 

If you have questions or concerns regarding this Privacy Policy, please contact us as set out in Section 8 (Contact).