Privacy Policy
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”) only applies to the PGOS Platform and the PGOS SDK feature(“Service”). If you use any other products or services, please refer to the privacy policy for that particular product or service.
For the purpose of data protection laws,
For any personal information of which we are the data controller, the relevant data controller of your personal information in relation to the Service is Proxima Beta Pte. Limited; and
For any personal information that we process on behalf of another party, the data controller is the party that utilizes the Service in providing its product/service to you (the “Game”).
Please note that if you are a user of a Game that utilizes our Service, you should direct any queries regarding the processing of your personal information to that Game.
If you have any questions about anything in this Privacy Policy or want to exercise any rights you may have, in situations where we act as data controllers, our contact information can be found here.
1. Children
Children must not use or participate in this Service 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. 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. For any personal information that we are the data controller of, if you believe that we have personal information of a child under these ages without lawful consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us.
| Region in which the user is located | Minimum age of the user |
|---|---|
| Algeria | 19 |
| Argentina | 13 |
| Australia | 18 |
| Bangladesh | 18 |
| Brazil | 18 |
| Cambodia | 18 |
| Canada | 13 |
| Colombia | 18 |
| Egypt | 18 |
2. How We Process Your Personal Information
This section provides more detail on the types of personal information we collect from you, and why.
| Personal Information | Use | Legal Basis (where applicable) |
|---|---|---|
| Information you provide to us (either through a third party or directly) | ||
| Player Profile (Backend): OpenID, Player ID, Player Display Name, Avatar, IP Address (only kept in aggregated format for server improvement), Gender, account_platform, account_id, OS, account_provider, language, first_login_time, last_login_time, last_logout_time, country_code | On behalf of the Game, we use this information to allow you to customize your in-game player profile (through selection of the character gender, and their avatars). | Necessary to perform the Game’s contract with you to provide the Service. |
| Player Profile (Overlay): AccountChannel, PlayerCustomStatus (only specified by Developer) | On behalf of the Game, we use this information to allow you to customize your in-game player profile (through the selection of the character gender, and their avatars). | Necessary to perform the Game’s contract with you to provide the Service. |
| Social Feature Information: friends list, chat groups list, offline personal message cache (Please note that no online messages are stored in PGOS, and offline messages will be deleted after 7 days.) | On behalf of the Game, we use this information to enable you to interact with other in-game players and facilitate in-game chat or communication. | Necessary to perform the Game’s contract with you to provide the Service, including but not limited to in-game communication services. We collect this information with your consent. |
| In-Game Orders: Steam ID, country/region code, currency code, in-game language code, order date and time, order ID, IP address, price, and item information (Only time, order ID, price and item information will be stored) | On behalf of the Game, we use this information to enable you to make in-game purchases and query purchase records. | Necessary to perform the Game’s contract with you to provide the Service. |
| In-Game Inventory: In-game Items history, item ID, and Count | On behalf of the Game, we use this information to enable you to make and maintain in-game purchases. | Necessary to perform the Game’s contract with you to provide the Service. We collect this information with your consent. |
| Goals: player goals | On behalf of the Game, we use this information to allow you to set in-game goals for players and then package these goals into a variety of game features (eg. Achievement, Quests, Battle Passes, etc.) | Necessary to perform the Game’s contract with you to provide the Service. |
| In-Game Mail: mail list, attachment list | On behalf of the Game, we use this information to facilitate in-game chat or communication, where you choose to use such mailing service. | Necessary to perform the Game’s contract with you to provide the Service where you seek to use in-game communication services. We collect this information with your consent. |
| Analytics Information: OpenID, Player ID, Player Display Name, Avatar, IP Address (only kept in aggregated format for server improvement), Gender, account_platform, account_id, OS, account_provider, language, first_login_time, last_login_time, last_logout_time, country_code, AccountChannel, PlayerCustomStatus (only specified by Developer), friends list, chat groups list, offline personal message cache, Steam ID, country/region code, currency code, in-game language code, order date and time, order ID, IP address, price and item information, In-game Items history, item Id and Count, player goals, mail list, attachment list (Please note that no online messages are stored in PGOS, and offline messages will be deleted after 7 days.) (Only time, order ID, price and item information will be stored) | On behalf of the Game, we may process this information to facilitate the Game’s data analysis of your in-game data to optimize your Game experience. | We collect this information with your consent. |
3. How We Store and Share Your Personal Information
Pursuant to your contract with the Game that provides you with the Game Services,, 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 Service in Germany, North America, Singapore, and Japan. The servers applicable to your use of the Service will depend upon your location. We also have support, engineering, and other teams who may support the Service, including globally (save from China).
Only where necessary will we share your personal information with third parties. Situations where this occurs are:
Third parties that provide services in support of the Service, including providers of services that process information identified in this policy for the purpose of providing the Service (eg. Proxima Beta Technology (Shenzhen) Ltd. for handling your purchases). 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 Service (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 Service to the Game. 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 organizations 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-organize 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.
4. 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 Service or otherwise via the Internet; any transmission is at your own risk.
5. Data Retention
We do not keep your data for longer than is necessary to fulfill 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 |
|---|---|
| All Personal Data as set out in Section 2 (“How We Process Your Personal Information”) | Stored for the lifetime of the Service and deleted immediately upon request. Offline messages will be deleted after 7 days. |
6. Your Rights
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. For any personal information that we are the data controller of, 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 the Game’s contract with you (e.g., account name), as described above in the section “How We Use Your Personal Information”. We will provide further information to you about transferring this data if you make such a request.*Correction*
You may have the right to correct personal information we hold that is inaccurate.
Erasure
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 defense 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 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 defense 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. For any personal information which we are the data controller of, if you wish to do so, please contact us at PGOS@tencent.comor using the contact details set out below, and we will consider your request.
Consent Withdrawal
To the extent provided by applicable laws and regulations, for any personal information of which we are the data controller of, you may withdraw consent you previously provided to us for certain processing activities by contacting us at PGOS@tencent.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.
7. Contact
Please get in touch with us if you have any questions. You can reach us in the first instance at:
Email: PGOS@tencent.com
Mailing Address:
International Privacy & Data Protection Centre
30 Raffles Place #18-01
Singapore 048622
We will endeavour to deal with your request as soon as possible. This is without prejudice to any right you may have to launch a claim with a data protection authority in the region in which you live or work where you think we have infringed data protection laws.
8. 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.
Our Representatives in Certain Jurisdictions
| Jurisdiction | Representative | Address | Contact details |
|---|---|---|---|
| EU | Proxima Beta Europe B.V. | Buitenveldertselaan 3-5 1082 VA Amsterdam | PGOS@tencent.com |
| UK | Image Frame Investment (UK) Limited | Suite 1, 3rd Floor 11 - 12 St. James's Square, London, United Kingdom, SW1Y 4LB | PGOS@tencent.com |
| Korea | Kite Bird Korea Yuhan Hoesa | 25F, 55, Sejong-daero, Jung-gu, Seoul (Taepyeongro 2-ga), Korea | PGOS@tencent.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, suspensions, investigations, civil or criminal complaints. | turkeydatarep_proximabeta@iptech-legal.com |
SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC
Some jurisdictions’ laws contain additional terms for users of the Service, 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 utilizing the Service, 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 survey, in each case location in the jurisdictions specified in *Section 3 (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 utilizing the Service, 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
Overseas Recipients
We take reasonable steps to ensure that third-party recipients of your personal information located outside Australia handle your personal information in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.
Children
If you are under the age of 18, you undertake that you have the consent of your parent or legal guardian to utilize the Service.
Your Rights
If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the Australian Information Commissioner (Telephone: +61 1300 363 992 or email: enquiries@oaic.gov.au).
Data Transfers
While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.
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 7 (Contact)*. This may affect our provision of the Service.
BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORISE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.
Canada
If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us at PGOS@tencent.com. Our privacy experts who monitor this email address are also able to answer any questions users may have about the collection, use, disclosure or storage of personal information by our service providers.
Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this privacy policy.
Colombia
Your authorization to process personal information for the Service 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 7 (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 3 (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 7 (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 7 (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 utilize the Service.
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 3 (How We Store and Share Your Personal Information)*.
The categories of personal information specified in to the jurisdictions specified in *Section 3 (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 7 (Contact)*.
Kazakhstan
If you are under the age of 18, you must obtain your parent’s or legal guardian’s consent to utilize the Service.
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 processed 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 to you if you become aware of a violation regarding the collection and processing of your data. If the violation has not been proven, 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 authorize 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 2 (How We Process Your Personal Information)* are voluntary, which may include to show you personalized recommendations or advertising.
In general, we do not require your consent to carry out the transfers detailed in *Section 3 (How We Store and Share Your Personal Information)*. In any case, by utilizing the Service 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 7 (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 provision of the Service. By accepting this Privacy Policy, you explicitly accept that your personal data may be subject to processing by the Service.
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 2 (How We Process Your Personal Information)*
- Recipients or categories of recipients are set out in *Section 3 (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 2 (How We Process Your Personal Information)* and *Section 6 (Your Rights)*
New Zealand
This section applies to users located in New Zealand:
Overseas Recipients
We take reasonable steps to ensure that third-party recipients of your personal information located outside New Zealand handle your personal information in a manner that is consistent with New Zealand privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third-party recipients.
Access
You have the right to access personal information we hold about you, how we use it, and who we share it with. If you believe we hold any other personal information about you, please contact us at PGOS@tencent.com.
Correction
You have the right to request the correction of any of your personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your account. If you believe we hold any other personal information about you and that information is inaccurate, please contact us at PGOS@tencent.com.
Children
If you are under the age of 16, you undertake that you have the consent of your parent or legal guardian to utilize the Service.
Your Rights
If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the New Zealand Privacy Commissioner (www.privacy.org.nz).
Data Transfers
While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.
Philippines
You are entitled to the following rights:
- Right to be informed. You may in certain circumstances have the right to be informed whether personal data pertaining to you is being, or has been processed, including the existence of automated decision-making and profiling.
- Right to object. You may in certain circumstances have the right to object to the processing of your personal information, including processing for direct marketing, automated processing, or profiling.
- Right to access. You may in certain circumstances have the right to seek reasonable access to, upon request, your personal information.
- Right to rectification. You may in certain circumstances have the right to dispute an inaccuracy or error in your personal information and have us correct it, unless the request is vexatious or otherwise unreasonable.
- Right to erasure or blocking. You may in certain circumstances have the right to suspend, withdraw, or seek the blocking, removal, or destruction of your personal information.
By acknowledging this Privacy Policy, you acknowledge:
- Collecting and processing your personal information as described in *Section 2 (How We Process Your Personal Information)*;
- Sharing your personal information with third parties, companies within our corporate group, and a third party that acquires all or substantially all of us or our business, as described in this Privacy Policy and for the purposes stated herein; and
- Transferring or storing your personal information in destinations outside the Philippines as described in *Section 3 (How We Store and Share Your Personal Information)*
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 7 (Contact)*
Qatar
If you are utilizing the Service 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* |
|---|---|---|---|
| Proxima Beta Technology (Shenzhen) Ltd. | In-Game Orders: Steam ID, country/region code, currency code, in-game language code, order date and time, order ID, IP address, price and item information (Only time, order ID, price and item information will be stored) | We use this information to enable you to make in-game purchases and query purchase records. | Stored for the lifetime of the Service and deleted immediately upon request. |
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 |
|---|---|
| Proxima Beta Technology (Shenzhen) Ltd. | We use this information to enable you to make in-game purchases and query purchase records. |
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* |
|---|---|---|---|---|---|
| Proxima Beta Technology (Shenzhen) Ltd. | Singapore and/or North America | Continuous | In-Game Orders: Steam ID, country/region code, currency code, in-game language code, order date and time, order ID, IP address, price, and item information (Only time, order ID, price and item information will be stored) | We use this information to enable you to make in-game purchases and query purchase records. | Stored for the lifetime of the Service and deleted immediately upon request. |
You may refuse the overseas transfer of your personal information by contacting our Data Protection Department. If you refuse the overseas transfer of your personal information, your personal information will not be transferred overseas. However, you may not be able to use our services for which overseas transfer of personal information is necessary.
Data Destruction
Personal information is retained in accordance with the data retention periods as detailed in the 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 the section “Data Retention” is 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 infringes 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 7 (Contact)*
Contact
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 Department, responsible for the management and safety of your personal information
- Telephone: +82-2-2185-0902
- Email: specified in *Section 7 (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
South Africa
You have the right to lodge a complaint with the Information Regulator (South Africa) by emailing it to 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 utilize the Service.
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 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 |
|---|---|---|---|
| Proxima Beta Technology (Shenzhen) Ltd. | Singapore and/or North America | We use this information to enable you to make in-game purchases, and query purchase records. | In-Game Orders: Steam ID, country/region code, currency code, in-game language code, order date and time, order ID, IP address, price and item information (Only time, order ID, price and item information will be stored) |
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.
United States
For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”), and respectively include the terms “personal data” and “sensitive data” as defined in the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”), (collectively, “US State Laws”). The terms do not include information excluded from the scope of US State Laws.
Collection and Disclosure of Personal Information
Over the past 12 months, we have collected and disclosed for a business purpose the following categories of personal information from or about you or your device:
- (As mentioned in *Section 2 (How We Process Your Personal Information)*) Player Profile (Backend), Player Profile (Overlay), Social Feature Information, In-Game Orders, In-Game Inventory, Goals, In-Game Mail, Analytics Information.
We collect and disclose your personal information, including sensitive personal information, for the following purposes:
- (As mentioned in *Section 2 (How We Process Your Personal Information)*) Player Profile (Backend), Player Profile (Overlay), Social Feature Information, In-Game Orders, In-Game Inventory, Goals, In-Game Mail, Analytics Information.
For additional information about what each type of personal information is used for, see this chart in the main portion of the privacy policy.
We disclose each of the categories of personal information that we collect as described in *Section 3 (How We Store and Disclose 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. In the past 12 months, we may have collected the following types of sensitive personal information about you:
- Your chat data
Retention of Your Personal Information
The retention period varies among the different categories of data collected. For detailed information about the retention period for any specific category of data, see this chart in the main portion of the Privacy Policy.
Rights under US State Laws:
Depending on where you live, you may have some or all of the rights listed below in relation to information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
- Right to Access/Know. Request we confirm whether we process information about you and give you access to that information. You may also request to receive that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment. If you are a California resident, you may request the following information about our collection, use, and disclosure of your information:
- the categories of personal information about you that we collected;
- the categories of sources from which the personal information was collected;
- the business or commercial purposes for collecting personal information about you;
- the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
- the specific pieces of personal information we collected about you;
- Right to Delete. Request we delete the personal information we collected from you;
- Right to Correct. Request we correct inaccurate personal information that we maintain about you;
- Right to Non-Discrimination. Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the US State Laws.
How to Exercise Your Rights
First, you may wish to log into your account and manage your data from there. Depending on where you live, you may also exercise your rights, if any, regarding other data by contacting us at here. 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 you to provide the Data Subject Request Information set out in the section “*How We Process Your Personal Information*”.
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 fulfill 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 at PGOS@tencent.com.