Exoborne

Privacy Policy

Last Updated: December 1, 2023

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).

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 and provide you with news and updates to the Game.

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 and the United States. We also have support, engineering and other teams who may support the Game Services, including from Singapore an the United States.

·         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 For the following jurisdictions specifically, our representative for data protection purposes is as set out below:

Jurisdiction

Representative

Address

Contact details

EU

Proxima Beta Europe B.V.

Buitenveldertselaan 1-5

1082 VA Amsterdam, the Netherlands

dpo_exoborne@levelinfinite.com

UK

Image Frame Investment (UK) Limited

4th Floor 80 Strand London WC2R 0RL

dpo_exoborne@levelinfinite.com

 

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). 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

European Economic Area

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.]

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 and the United States. 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 and the United States.

 

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. 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.

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

 

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

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.


 

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.

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:

 

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

 

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. 

 

California Users Under 18

 

Any California residents under the age of eighteen (18) who have registered to use the Game Services and who have posted content or information on the Game Services can request that such information be removed from the Game Services by contacting us as specified in Section 8 (Contact). Such request must state that they personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post from prospective public view or anonymize it so the resident cannot be individually identified. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished the post, and archived copies of it may be stored by search engines and other parties that we do not control.

 

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:

 

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).