Delta Force

Privacy Policy

Last Updated: 2024.11.22 ]

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 Delta Force (“Game”) and website for the Game (“Website”) and its related interactive activities and events (“Events”) (together, the “Service”). 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 Service is Proxima Beta Pte. Limited.

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 Service?

In relation to the Game:

· If you choose to set up your profile using a social media account, we collect information provided by your social media account service provider to automatically generate your profile, including user ID, name, profile picture and user token. We will generate an Open ID. If you choose to set up your profile using a guest login, we collect your guest ID and Open ID.

· To maintain the smooth operation of the Service (which includes activities such from addressing bugs or malicious activity through to improving functionality), we will process customary device and network information (such as IP address, connection speed, device specifications, as well as app- and OS-generated identifiers).

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

In relation to the Website:

· If you sign up to receive updates of the Game, we will collect your email address to send you such updates.

· We use your IP address to understand our Website traffic and how visitors use the Website.

· We use your Open ID, email, region, game mode, server ID and role ID to provide a subscription function, to allow you to redeem Game items and register for a pre-launch event. The Service also allows players to communicate directly with each other via the text chat and audio chat functions. Player communication is a key part of players’ experience on the Service. Note that the audio chat function is OFF by default unless specifically enabled.

· To provide you with Events, we process various information, such as identifying information, device and network information, financial information, gameplay and interaction data, media and additional data, and survey information.

More Information.

How will we use your information?

In relation to the Game:

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

In relation to the Website:

· We use your information to provide you with game updates if requested, to understand how visitors use the Website, and to comply with our legal obligations and enforce our legal rights.

More Information.

Who do we share your information with?

· We use third parties and work with our affiliates to help us deliver the best possible experience (such as needed to back up your progress as well as for customer support).

· 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., 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? 

 

· 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 Singapore. We also have support, engineering and other teams who may support the Service, including from Singapore and China.

· 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 maintain an account for the Service, 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.

 

Events

Our Service offers a dynamic and engaging experience through a variety of interactive and frequently updated activities, collectively known as "Events." These Events come in different forms, including:

· Seasonal and themed events: Themed around real-world holidays or seasons, offering limited-time game modes, exclusive skins, or other rewards.

· Tournaments, Contests, and eSports events: Featuring high-stakes competition with cash prizes, in-game rewards, and bragging rights.

· New content releases: Introducing new characters, maps, or game modes, available for a limited time or unlocked through specific challenges.

· Community challenges: Collaborative goals requiring players to work together, such as defeating a certain number of enemies or completing a specific number of matches.

· Crossover events: Offering exclusive content based on collaborations with other franchises or brands.

· Battle passes or season passes: Providing access to exclusive content and rewards over a set period.

· In-game sales or promotions: Limited-time offers on in-game items like skins, characters, or currency.

· Lore events: Special missions, quests, or game modes that reveal more about the game's world and characters.

· Limited Time Modes (LTM): Unique game modes available for a short period of time.

· Anniversary and milestone events: Celebrating service anniversaries or other significant achievements.

· Player Milestone Events: Recognizing player achievements such as reaching certain levels or ranks.

· Community Vote/Comment Events: Allowing players to vote on new features, characters, skins, or other game elements.

· Login events: Rewarding players for logging in during the event period.

· Leaderboard events: Competitive events where players earn points through gameplay and top players receive exclusive rewards.

· Livestreaming events: Live broadcasts featuring influencers, or pro players playing the game.

· Surprise events: Unpredictable activities like flash sales or sudden boss fights.

· Surveys

· Other events: sweepstakes, giveaways, lucky draws, and more.

By participating in these Events, you may receive various prizes and rewards, such as in-game currency, exclusive skins, special items, titles, experience boosts, cash prizes, gaming hardware, game codes, merchandise, event tickets, recognition, exposure, or other event-specific rewards.


Welcome to Delta Force!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with Delta Force (“Game”) and website for the Game (“Website”) and its related interactive activities and events (“Events”) (together, the Service”), 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 Service. 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 Service. By using the Service, 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 Service is Proxima Beta Pte. Limited (“we”, “us”, “our”). 

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here. You can also reach out to our data protection officer at dpo_deltaforce@proximabeta.com. We have representatives for data protection purposes listed here.

1. Cookies

We use cookies and other similar technologies (“Cookies”) to enhance your experience using the Service. 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 Service 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. 

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, 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

European Economic Area

16

Hong Kong

18

India

18

Indonesia

18

Japan

18

Kazakhstan

18

Kuwait

21

Macau

18

Malaysia

18

Mexico

18

Morocco

18

Myanmar

18

New Zealand

16

Nigeria

13

Philippines

18

Qatar

18

Saudi Arabia

18

Serbia

15

Singapore

13

South Africa

18

Sri Lanka

18

Switzerland

14

Thailand

20

Tunisia

18

Türkiye

18

United Arab Emirates

21

United Kingdom

13

United States

13

 

3. How We Process Your Personal Information

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

It also identifies the legal basis under which we process your data, where applicable under applicable data protection laws.

Personal Information

Use

Legal Basis (where applicable)

For the Website

 

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

Subscription information: Open ID, email address, country or region, game mode (if you choose to receive game updates)

We use this information to send you games update as per your request and to allow you to accept and embark on game missions.

We use this information with your consent.

IP address (collected via Google Analytics)

We use this information to understand our Website traffic and how visitors use the Website, for marketing analytics purposes.

It is our legitimate interest to use this information to monitor the performance of, and to improve, our services.

Game item redemption information: Open ID, server ID, role ID

We use this information to allow you to redeem in-Game items.

Necessary to perform our contract with you to provide in-Game- items.

Verification and reporting information:

Player name, reporting time, reporting results, penalty type, penalty duration, start time, end time

We use this information for verification of identity, distribution of rewards and reporting of player bans and violations.

For player contact details and distribution of rewards, it is necessary to perform our contract with you to verify your identity and distribute in-Game rewards.

For player bans, it is in our legitimate interest to ensure the security of our services and to maintain a fair gaming environment within the Website.

Pre-launch data: Open ID, email address, country/region, IP address, player avatar, player nickname, team name

We use this information to allow you to register for and participate in a web event during the pre-launch of the Game.

Necessary to perform our contract with you to provide the pre-launch web event during the open beta period as per your request.

For the Game

 

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

 

Guest login information: guest ID, Open ID

We use this information to create your guest account for the Game in accordance with your request.

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

Account registration information:

· Steam: userID, nickname, user token, Open ID

· Twitter: userID, nickname, user token, Open ID, GAID (not stored on our servers but on Twitter’s servers)

· Apple: userID, nickname, user token, Open ID

· Discord: userID, nickname, user token, Open ID

· Line: userID, nickname, user token, Open ID

· Google: userID, nickname, user token, Open ID

· Level Infinite Account: UID, token, email address, password

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.

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

Account deletion information: email address, region, Open ID, user token

We use this information to facilitate your request to delete your account and to determine the language to be shown to you during this process.

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

 

Announcement information: Open ID, device ID

We use this information to send you in-game notifications related to the Game.

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

 

Customer Support (in-app, email and website):

 

· Via app: Name, Open ID, account information (nickname, game level, account balance, game community if provided by user), device model, application version, battery level, Wifi strength, free space on phone, network type, iOS version, platform, carrier, country code;

· Via website: Name, Open ID, device  model, email address (optional),

· Via email: Name, email address

· Details of ticket, complaint and handling or information (e.g. photos) that you choose to provide in communications with our support team

 

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

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

 

 

 

 

IP address (not stored)

We use this information to:

· allow you to connect to the Game server; and

· suggest your country/region when you seek to change your location setting.

 

N/A

Survey response data (IMUR): Your responses to the survey questionnaire, which may include email address ,country or region of residency, gaming habits and preferences (including recently played games, gameplay frequency, favourite game categories and experience, language preference, evaluation and comments towards the Game),  and other survey responses content that you may choose to provide.

We use this information to provide you with the survey if you choose to participate in a survey in-game or on the Website.

We collect this information with your consent.

Survey device data (IMUR): browser information and user agent information such as IP address ,browser, browser version, device settings and operating system version.

If you choose to participate in a survey, we use this information to optimise the survey and the Service, including to identify the suggested location based on your country / region.  

We collect this information with your consent.

Information generated as part of the Game

 

Compliance information: Open ID, token, region, username, email address

We use this information to verify your eligibility to use the Game and to comply with applicable laws.

It is in our legitimate interest to ensure compliance with applicable age-gating rules.

XWID: Your XWID, which is generated by us.

We use this information to perform general/overall game analytics (not confined to error fixing or debugging), and to enable you to play the Game as a guest user.

It is in our legitimate interest to ensure the functioning of our Game and to allow users to use the Service as a guest user.

Game resources and version update information: Open ID, device name, device model, login channel ID.

 

We use this information to provide you with Game updates, game maintenance and configuration, to allow you to download in-game resources and to ensure the game performs smoothly.

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

SDK performance information: Information about the interactions between the SDKs,  error code, error message, SDK name, SDK version, request URL, response body, sequence ID, stage, log

We use this information to analyse the performance of the SDKs within the Game in order to ensure the smooth operation of the Service.

It is in our legitimate interest to ensure the smooth operation of the Game.

 

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, RAM total, ROM total, system language, uaid, device IDs

We use this information to conduct general game analytics to improve our Game.

 

It is in our legitimate interest to ensure the smooth operation of the Game and improve the Game.

Crash reporting information: userID, device IDs, CPU, storage, network status

We use this information to locate and resolve crash issues, identify and address bugs.

It is in our legitimate interest to improve the Game.

Chat filter information: Account ID, username, user ID, IP address, chat text content,

We use this information to review chat content to detect and prevent cheating behaviours to ensure the safety of the Game environment.

It is in our legitimate interest to use this information to ensure the safety and integrity of the Game.

Anti-cheating information: 

· Account information: account ID, game ID

· Device information: MAC address (only for PC version) OS version

· Other data: in-game screenshots (which may contain nicknames and chats between you and your teammates, though such information will be obfuscated, and game scenes)  

We use this information for anti-cheating purposes, including to detect and observe cheating behaviours and monitor the presence and operation of suspected cheating activity or anomalies.

It is in our legitimate interest to ensure the security of our services and to maintain a fair gaming environment within the Game.

 

Penalty information: user game ID, account penalty status and information, crash report

We use this information to implement the penalty system for players within the Game for illegal or restricted activities.

It is in our legitimate interest to ensure the security of our services and to maintain a fair gaming environment within the Game.

 

Gameplay analytics data: Open ID, nickname, character ID, account level/rank, match record, game behaviour information, account active days, penalty record, login record, gameplay recording

We use this information to:

· help us understand user behaviour;

· detect illegal activities;

· train our model; and

· deal with user complaints.

It is in our legitimate interest to ensure the security of our services and to improve the Game.

Anti-fraud information: device IDs, device model, operation system, application activities, system performance data

We use this information to implement anti-cheat and fraud prevention strategies.

It is in our legitimate interest to ensure the security of our services and to improve the Game.

IDIP Information: nickname, open ID, game level, game area, game coins, partition ID, region and country, server ID, game log data

This information is used to provide our internal customer service and business analysis teams with a better understanding of user data to improve our customer service  and improve the Game.

It is in our legitimate interest to allow IDIP to collect this information to improve the Game.

AMS information: Open ID, area, platform ID, game area, region and country

We use this information to facilitate your participation in marketing events, e.g. CDKey redemption for gift packages.

We collect this information with your consent.

Real time voice chat data: Open ID, device model, device brand, system time, SDK version, network type

Other than the data above, we also process real time voice data, which is processed momentarily by us but not stored on our servers.

 

We process this information to facilitate your real-time voice chat with users. 

We collect this information with your consent.

Voice message data: Open ID, device model, system time, operating system, SDK version, network type, voice file, region ID

We process this information to allow you to upload and send voice messages to other users.

We collect this information with your consent.

Text chat data (lobby chat and message chat): Open ID, text chat

We process this information to provide you with the functions of lobby chat (public text chat) and message chat (private text chat).

Necessary to perform our contract with you to provide the Service and enable communication between users.

Game performance information: Open ID, phone memory, GPU information, CPU model, CPU usage rate, device brand, network traffic, device system version, screen resolution, ROM, RAM, device manufacturer, CPU architecture, remaining memory, device model, system time, UUID, root status

We use this information to monitor your game performance and improve game performance.

It is in our legitimate interest to ensure the smooth operation of the Game and improve the Game.

Data analysis and reporting information: 

· Account information: Nickname, username, user ID, email address;

· Social media account information: Login channel, profile picture, username, friend list;

· Device information: Device identifiers, device model, operation system, network, screen, system performance data;

· Location information: IP address, country/region;

· Gameplay data: In-game activities log and gameplay statistics.

We use this information to conduct general game analytics to improve our Game.

It is in our legitimate interest to improve the Game.

Game configuration data: OpenID, device name, device model, login channel ID

We use this information to configure the Game settings such as distribution capabilities.

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

Device performance data: system time, device system version, SDK version, IP address

We use this information to conduct analysis on device performance and to improve user experience.

It is in our legitimate interest to improve the Game.

Transaction Information

 Identity information: Open ID, country, role ID, Steam ID (for payments via Steam Pay only)

 Device information: CPU model, device model

 Other information:  Country currency, SDK version, application version, network type, IDFV, purchase amount

We will also allow you to make in-app purchases via Google Play and the Apple Store.

We use this information to:

· facilitate your transactions as part of the Service and to maintain transaction records;

· enable you to use the payment function in the Service via Google Play or iOS Apple Store.

Necessary to perform our contract with you to facilitate your transactions as part of the Game, to maintain transaction records, and to provide you with information about your purchase history and to restore purchased items. 

In-Game Events Data: Open ID, role ID, partition area, platform ID, language, region, device model, operating system, system memory size, network type, processor type

We use this information to:

· provide you with in-game events; and

Necessary to perform our contract with you to provide the in-game event.

· track user activity and monitor participation rate within the game and for service monitoring.

It is in our legitimate interest to monitor user participation and improve the Game.

For Events

We will provide you with additional notice if the information collected for a specific event exceeds the scope below.

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

Identifying Information (e.g. name,  address and post code (if applicable), contact information (email address, telephone number), date of birth, country of residence, game ID and character information, UUID, open ID, UID, team name, username, social media IDs and information, event-specific identifiers, government-issued document identifiers, and similar identifiers)

We use this information for one or more of the following purposes:

· to facilitate access to the Event;

· we use identifying information like date of birth, country of residence, and government-issued document identifiers for: (i) offline tournaments registration (e.g. relating to hotel bookings); (ii) delivery of physical prizes or cash prizes; and

· to provide an engaging experience.

Necessary to perform our contract with you in connection with the Event.

 

It is in our legitimate interest to use this information to provide an engaging experience.

 

Financial Information (e.g. payment information, bank account details, and similar financial data)

We use this information for one or more of the following purposes:

· to facilitate access to the Event, maintain records;

· to send and administer Event-related physical and cash prizes; and

· to optimize game performance, server management, ensure smooth gaming experience.

Necessary to perform our contract with you in connection with the Event.

 

It is in our legitimate interest to use this information to optimize our game performance and experience.

Survey Information: Any information requested as part of the survey (e.g. email, country or region of residence, gaming habits and preferences, gameplay frequency, favourite game categories, language preference, and any other responses you choose to provide as part of the survey response)

To allow you to participate in surveys about an Event, to improve the Service, and for registration purposes.

 

· To send you news, events and promotions relating to the Event.

We collect this information with your consent.

Information generated as part of Events

Device and Network Information (e.g. device ID, operating system, IP address, device specifications, and similar technical data)

To facilitate access to the Event, maintain records, optimize game performance, server management, ensure smooth gaming experience

Necessary to perform our contract with you in connection with the Event.

 

 

Gameplay and Interaction Data (e.g. in-game performance data, items and prices, game profile, usernames or nicknames, behavioural data, communication data, feedback or survey responses, likes and dislikes, interests and habits, lifestyle information, preferences, leaderboard and ranking information, streamer-related information, and similar gameplay and interaction data)

We use this information for one or more of the following purposes:

· to track progress, maintain records, and provide Event-related rewards;

· to identify and rank users in the game or on leaderboards, improve game balance and design, facilitate in-game chat or communication, collect feedback, improve game design, Event-related rewards; and

· to provide an engaging experience.

Necessary to perform our contract with you in connection with the Event.

 

It is in our legitimate interest to provide an engaging gaming experience for our users.

Media and Additional Data (e.g. pictures, videos, other personal information or gameplay data related to cheating prevention, health-related information, video footage of gameplay, recorded images, and similar media and additional data)

We use this information for one or more of the following purposes:

· to allow social and traditional media promotion;

· to prevent cheating, and protect other players; and

· to provide an engaging experience

It is in our legitimate interest to promote the Event, ensure a safe gaming environment, and to provide an engaging experience.

 

4. How We Store and Share Your Personal Information

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 Singapore. We also have support, engineering and other teams who may support the Service, including from Singapore and China.

 

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 occur 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, for the purpose of processing support ticket ID and support communication. 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 you.  All such group companies may only use your personal information in accordance with this Privacy Policy.

· Regulators, judicial authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you, such as to comply with legal obligations or processes. In complying  with the terms of valid legal processes, such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in advance of such disclosure.

· Third parties to ensure safety, security, or compliance with laws. We may disclose your information to:

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 Service 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

For the Website

Subscription information

Game item redemption information

Verification and reporting information

Pre-launch data

Stored for the duration of your use of the Service and removed within 30 days if you request for deletion.

IP address

We do not store this data. This data is stored by Google Analytics for 3 months.

For the Game

Account registration information

Guest login information

Open ID will be stored for the lifetime of your use of the Service or until account deletion in accordance with your request, upon which it will be deleted within 30 days.

Other information other than OpenID will be stored for 30 days from the date of your last login.

Account deletion information

Stored for 30 days (cool down period). If you do not login to the Service or email us to change your mind during the cool down period, your information will be permanently deleted.  

Announcement information

Stored for 30 days.

Compliance information

 

Stored for 1 year after the termination of the Service.

Survey response data (IMUR)

Anti-fraud information

Stored for the duration of your use of the Service. If you request for account deletion, data will be deleted within 30 days after your request. 

 XWID

Data reporting information

SDK performance information

Transaction information

Stored for the duration of your use of the Service and one year thereafter. If you request for account deletion, data will be deleted within 30 days after your request. 

 

Game resources and version update information

Customer support data

 

Stored for 90 days. If you request for account deletion, data will be deleted within 30 days after your request. 

 

Game performance information

Stored for 30 days. If you request for account deletion, data will be deleted within 15 days after your request.

Survey device data (IMUR)

Stored for 30 days. If you request for account deletion, data will be deleted within 30 days after your request.

Penalty information

Crash reporting information

Device performance data

Text chat information

Stored for 90 days.

Anti-cheating information

Account information and other data: Stored for a maximum of 7 days.

Device information: Stored for the duration of your use of the Service. If you request for account deletion, data will be deleted within 30 days after your request. 

Game safety information

Game configuration data

 

Stored for a maximum of 7 days.

 

Gameplay analytics data

Stored for 90 days, unless the user was detected to have violated the Service’s terms and rules, in which case we store the violating user’s information for the duration of their use of the Service or until account deletion request, whichever is earlier

IDIP information

We store two sets of the same data on different databases within our server: (1) stored for 7 days (to provide the Service); and (2) stored for 3 months (to make available for subsequent investigation of records).

AMS information

30 days after the marketing event ends

Data analysis and reporting information

In-Game Events Data

Stored for 6 months.

Real time voice chat data

Real time voice chat data is not stored by us.

Voice message data

Stored for 7 days unless user requests for deletion, upon which it will be deleted within 30 days.

IP address

We do not store this.

For Events

Identifying Information

Stored for one year after the end of the Event, or deleted within 30 days from the receipt of your deletion request.

 

In case those information are necessary to maintain the record of the participation to the Event, such will be kept until Service is shut down.

 

Device and Network Information

 

Gameplay and Interaction Data

 

Stored for one year after your last interaction with the Event, or deleted within 30 days from the receipt of your deletion request.

 

In case those information are necessary to maintain the record of the participation to the Event, such will be kept until Service is shut down.

 

Financial Information

Stored for seven years after the completion of the transaction, or deleted within 30 days from the receipt of your deletion request.

 

Media and Additional Data

 

Stored until the Service is shut down, or deleted within 30 days from the receipt of your deletion request.

 

Survey Information

Stored for up to 1 year.

 

7. Your Rights

Some jurisdictions’ laws grant specific rights to users of the Service. 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 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 Service account.

Erasure

You may be able to delete your account, or remove certain personal information, by logging into your Service account. We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Service and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.

Restriction of Processing to Storage Only

You may have a right to require that we stop processing the personal information we hold about you (other than for storage purposes in certain circumstances). Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). Where we agree to stop processing the personal information, we will take steps to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You may have the right to object to our processing of your personal information. If you wish to do so, please contact us at dpo_deltaforce@proximabeta.com or using the contact details set out below,  and we will consider your request.

Consent Withdrawal

To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us at dpo_deltaforce@proximabeta.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.

Announcements

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

Advertising

You may choose to stop receiving personalised advertising or marketing promotions from us by following the unsubscribe instructions included in these emails or by contacting us at dpo_deltaforce@proximabeta.com.

8. Contact

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

Email: dpo_deltaforce@proximabeta.com

Mailing Address:

International Privacy & Data Protection Centre

79 Robinson Rd #07-01, Capitasky, 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.


INFORMATION FOR PARENTS

Before your child can use the Service, you will need to provide your consent to approve your child’s account set-up and the processing of their personal information.

What personal information does the Game process?

The Game is a PC and mobile  game.

If your child successfully signs up to the Game, this will result in the collection and sharing of certain personal information:

· Social media account information (if your chid chooses to login via social media)

· Phone number and email

· Account deletion information (email address, region, Open ID, user token)

· Gameplay information (e.g. gaming activity log, performance, statistics, crash and analytics information)

· Customary device and network information: such as IP address, connection speed, device specifications, as well as app- and OS-generated identifiers.

· Text chat and voice chat (to the extent this is enabled)

· Customer support information: such as details of ticket, complaint and handling, email address, name, open ID, device and network information.

· Transaction records and identifiers (if a payment is made)

· Security related information (such as device information and operating system model)

· Survey responses, if they choose to participate in a survey

You can review our Privacy Policy for more details on what personal information we collect and how we use and process the information.

Does the Game process personal information differently for children?

Children will not be able to access the free chat functions unless specifically approved by you.

Why is my consent required? 

Certain jurisdictions require or recommend the consent of a parent or legal guardian before their child can sign up to a game such as the Game, where personal information will be processed. If you do not consent, or withdraw your consent, we will immediately delete any personal information collected up to that point.

What method(s) can I use to verify my child’s account?

In some jurisdictions, including the United States, we ask for date of birth at registration. We will not allow a child to sign-up without first obtaining verifiable consent from that child’s parent or legal guardian. As part of this, we need to verify that you are an adult capable of providing such consent. To do this, we charge or authorize a small amount to a credit card. This process is handled by Ayden. We do not process your credit card information – only the third party payment processor collects credit card information. The credit card information is not retained for any reason, including future purchases or connected to in-app payment functions (if any) in the game.

What if there are changes to the Game in the future?

If we make any changes to the way their personal information is processed, we will notify you of those changes. You must consent to those changes before your child’s personal information will be processed for that new purpose.

Will you retain my personal information?

We will keep a record of your email address so that we can notify you of any changes to the processing of your child’s personal information, and so that we know you are a parent or legal guardian of a player when you contact us. As mentioned above, your credit card information is not processed by us, but instead only processed by a third party payment processor. We do not have access to your credit card information.

What if I do not consent?

If you do not consent (including by providing your credit card details for verification) then your contact information will be deleted.

How do I withdraw my consent or delete my child’s account?

You can withdraw your consent or delete your child’s account by emailing us at dpo_deltaforce@proximabeta.com. You can also request a copy of your child’s personal information at any time.

 

Our Representatives in Certain Jurisdictions

Jurisdiction

Representative

Address

Contact details

EU

Proxima Beta Europe B.V.

Buitenveldertselaan 1-5, 1082 VA, Amsterdam, the Netherlands

 

dpo_deltaforce@proximabeta.com

UK

Image Frame Investment (UK) Limited

Suite 1, 4th Floor 80 Strand, London, United Kingdom WC2R 0RL

dpo_deltaforce@proximabeta.com

Serbia

Karanovic & Partners o.a.d. Beograd

Resavska 23, Belgrade, 11000, Serbia

local.representative@karanovicpartners.com 

 

Thailand

Tencent (Thailand) Company Limited

8 T-One Building, Floor 10th, 11th & 12th (Unit 3-5), Soi Sukhumvit 40, Sukhumvit Road,  Khwaeng Phra Khanong, Khet Khlong Toei, Bangkok 10110, Thailand

dpo_deltaforce@proximabeta.com

Türkiye

Özdağıstanli Ekici Avukatlık Ortaklığı.

Nidakule Ataşehir Kuzey Begonya Sok. No:3 Kat. 17 D: 162 34746 Ataşehir / İstanbul, Türkiye

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-Service 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 using 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 Service, in each case location in the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information).

Argentina

If you are dissatisfied with our response to your request for access to, correction, or erasure of your personal information or your privacy complaint in respect of your personal information, you may contact the Agency for Access to Public Information at: Av. Pte. Gral. Julio A. Roca 710, Piso 2°, Ciudad de Buenos Aires (Telephone: +5411 3988-3968 or email: datospersonales@aaip.gob.ar). While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, by providing your personal information and by using the 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

We take reasonable steps to ensure that third party recipients of your personal information located outside Australia handle your personal information in a manner that is consistent with Australian privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients. You have the right to access personal information we hold about you, how we use it, and who we share it with. You have the right to correct any of your personal information we hold that is inaccurate.

If you are under the age of 18, you must not use the Service.

Where practicable, we will give you the option of not identifying yourself or using a pseudonym when registering an account on or using the Service. You acknowledge that if you do not provide us with your personal information, we may be unable to provide you with access to certain features or sections of the Service, including social media integration and in-Service purchases.

 

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the Australian Information Commissioner (Telephone: +61 1300 363 992 or email: enquiries@oaic.gov.au).

Bangladesh

By acknowledging the Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data, including disclosing to third parties, to the extent provided by the Privacy Policy. You also consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information).

Brazil

Whenever we use your personal information based on your consent, you may revoke the consent that you have previously given for the collection, use and disclosure of your personal information, subject to contractual or legal limitations. To revoke such consent, you may terminate your account or you can contact us as set out in Section 8 (Contact). This may affect our provision of the Service to you.

 

BY ACCEPTING THIS PRIVACY POLICY, YOU EXPRESSLY STATE THAT YOU AUTHORISE US TO COLLECT, USE, STORE, AND PROCESS YOUR PERSONAL INFORMATION, INCLUDING, DISCLOSING TO THIRD PARTIES, TO THE EXTENT PROVIDED BY THIS PRIVACY POLICY.

Canada

If you are located in Canada and wish to obtain written information about our policies and practices with respect to our service providers located outside Canada, you may contact us as specified in Section 8 (Contact). Where we use service providers who might have access to your personal information, we require them to have privacy and security standards that are comparable to ours. We use contracts and other measures with our service providers to maintain the confidentiality and security of your personal information and to prevent it from being used for any purpose other than as provided in this Privacy Policy.

Colombia

Your authorization to process personal information for the 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 8 (Contact)

Egypt

By clicking “accept” or by proceeding with the sign up process, you acknowledge that you have read, understood, and consented to this Privacy Policy. You are acknowledging your consent to the processing, storage, and cross-border transfer of your personal data. The cross border transfer may be to any country in which we have databases or affiliates, in particular to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information).

 

You also acknowledge your consent to receiving marketing messages from us, whether through e-mails or pop-ups or other such means.

 

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, the 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).

Hong Kong

As a Hong Kong data subject you have legal rights in relation to the personal information we hold about you (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to receive a copy of the data we process about you, a data correction request as well as a right to reject to the use of your personal data for direct marketing purposes. A fee may be chargeable by us for complying with a data access request.

India

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

 

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

Indonesia

By accepting and consenting to this Privacy Policy, you agree that we may collect, use and share your personal information in accordance with this Privacy Policy, as revised from time to time. If you do not agree to this Privacy Policy, you must not access or use our services and we have the right to not provide you with access to our services.

If you are under the age of 18, you must not use the Service.

In the event we fail to maintain the confidentiality of your personal information in the Service, we will notify you through the contact information provided by you or via the Service, to the extent required by local laws and regulations.

You are responsible for making sure that any personal details which you provide to us are accurate and current. In order to confirm the accuracy of the information, we may also verify the information provided to us, at any time. You hereby represent that you have secured all necessary consent(s) before providing us with any other person’s personal information (for example, for referral promotions), in which case we will always assume that you have already obtained prior consent, and as such, you will be responsible for any claims whatsoever from any party arising as a result of the absence of such consent(s).

Japan

If you are under the age of 18, you must not use 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 4 (How We Store and Share Your Personal Information).

 

The categories of personal information specified in to the jurisdictions specified in Section 4 (How We Store and Share Your Personal Information) may include "special care-required personal information" (i.e., sensitive information as detailed under applicable law), and you consent to the collection of such information.

 

You may request us to notify you about the purposes of use of, to disclose, to make any correction to, to discontinue the use or provision of, and/or to delete any and all of your personal information which is stored by us, to the extent provided by the Act on the Protection of Personal Information of Japan. When you wish to make such requests, please contact us as set out in Section 8 (Contact).

Kazakhstan

If you are under the age of 18, you must not use 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 and China.

 

In the event of any discrepancy or inconsistency between the English version and the Kazakh version of this Privacy Policy, the Kazakh version shall prevail.

Your Rights

 

· Right of access: You have the right to request access to and obtain a copy of the personal information we have process about you or that is being processed on behalf of us. We reserve the right to impose a fee for providing access to your personal information in the amounts as permitted under law. 

When handling a data access request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data access request.

· Right to correction: You may request for the correction of your personal information or delete such personal information if it is impossible to correct it. When handling a data correction request, we are permitted to request for certain information to verify the identity of the requester to ensure that he/she is the person legally entitled to make the data correction request.

· Right to blocking / de-blocking: You have the right to request the blocking of personal information related you, if you become aware of a violation regarding the collection and processing your data. If the violation has not been proved, you may request to de-block your data.

· Right to deletion: You have the right to request deletion of your personal data if the collection and processing of your data has been conducted in violation of Kazakh laws.

· Processing of your personal information in public sources of personal data: You may request to limit or provide your consent on the processing of your personal information in public sources of personal data.

Kingdom of Saudi Arabia

You consent to the collection, use, disclosure, transfer, export (to the extent permitted by applicable laws) and storage of your personal information as described in this Privacy Policy including (without limitation) for the purposes of showing you personalised advertising when you use the services.

Kuwait

By accepting this Privacy Policy, you expressly state that you authorise us to collect, use, store, and process your personal data and to disclose this data to third parties whether inside or outside of Kuwait, in line with the provisions of this Privacy Policy.

Macau

You have the right not to provide your personal information. However, as a result, we may not be able to provide the Service to you. As a Macau data subject you have legal rights in relation to your personal information (to the extent permitted under applicable laws and regulations). You are entitled to make a subject access request to request a copy of the data we process about you, to make a data correction request, and have the right to oppose the use of your personal information for marketing or any other form of commercial prospecting, or on any grounds of personal nature. A fee may be chargeable by us for complying with a data access request.

Malaysia

Minors are not permitted to use the Service.

Right of access: You have the right to request access to and obtain a copy of your personal information that we have collected and is being processed by or 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 of correction: You may request for the correction of your personal information. 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 limit processing of your personal information: You may request to limit the processing of your personal information by using the contact details provided above. However, this may affect our provision of the Service to you.

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.

· Our data protection officer, responsible for the management and safety of your personal information

o Telephone: +603-22872388

o Email: as set out in Section 8 (Contact)

 

Mexico

Some of the purposes of processing specified in Section 3 (How We Process Your Personal Information) are voluntary, which may include to show you personalised recommendations or advertising. We may also use your personal data for the voluntary purpose of sending information to your email or via SMS that we may consider relevant to you.

In general, we do not require your consent to carry out the transfers detailed in Section 4 (How We Store and Share Your Personal Information). In any case, by using the 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 to “Access”, “Correction”, “Erasure”, “Objection”, “Restriction of Processing to Storage Only “, which includes the limitation to the use and disclosure of your personal data, and “Advertising” as well as the applicable means, procedures and requirements to exercise any of your rights, please contact us as specified in Section 8 (Contact).

Morocco

We collect information for purposes strictly necessary for the proper use 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 3 (How We Process Your Personal Information)

· recipients or categories of recipients are set out in Section 4 (How We Store and Share Your Personal Information)

· whether the answer to the questions is compulsory or optional, as well as the possible consequences of a lack of answer: please refer to Section 3 (How We Process Your Personal Information) and Section 7 (Your Rights)

New Zealand

We take reasonable steps to ensure that third party recipients of your personal information located outside New Zealand handle your personal information in a manner that is consistent with New Zealand privacy laws. However, you acknowledge that we do not control, or accept liability for, the acts and omissions of these third party recipients.

You have the right to access personal information we hold about you, how we use it, and who we share it with. You have the right to request the correction of any of your personal information we hold that is inaccurate.

If you are under the age of 16, you must not use the Service.

If you are dissatisfied with our response to your request for access to, or correction of, your personal information or your privacy complaint in respect of your personal information, you may contact the Office of the New Zealand Privacy Commissioner (www.privacy.org.nz).

While we take reasonable steps to ensure that third party recipients of your personal information comply with privacy laws that are similar to those of your jurisdiction, you acknowledge and agree that we cannot control the actions of third party recipients and so cannot guarantee that they will comply with those privacy laws.

Peru

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, pursuant to the Personal Data Protection Law (the “Law”). You may also exercise these rights through your legal guardian or someone who has been authorised by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Law.

You can also withdraw your consent or demand a suspension of the personal information processing at any time.

If you consider that your request has not been met you may file a claim with the Peruvian National Authority of Personal Data Protection.

To protect your personal information and handle complaints relating to your personal information, we have appointed the following department responsible for managing and protecting your personal information.

· Data Protection Team, responsible for the management and safety of your personal information

· Contact: as set out in Section 8 (Contact)

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 consenting to this Privacy Policy, you consent to us:

· collecting and processing your personal information as described in Section 3 (How We Process Your Personal Information);

· sharing your personal information with third parties, companies within our corporate group, and a third party that acquires substantially 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 4 (How We Store and Share Your Personal Information)

Qatar

If you are using 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.

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

Singapore

By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, the locations specified in Section 4 (How We Store and Share Your Personal Information).

You have the right to access your personal information, how we use it, and who we share it with. You have the right to correct any of your personal information that is inaccurate.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted as set out in Section 8 (Contact).

South Africa

You have the right to lodge a complaint with the Information Regulator (South Africa) by emailing it at inforeg@justice.gov.za. The Information Regulator (South Africa)’s physical address is 33 Hoofd Street Forum III, 3rd Floor Braampark, Braamfontein, Johannesburg, South Africa.

Republic of Korea

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

Midas; Google Play; Apple Store

Processes transaction information

Tencent Cloud 

(cloudlegalnotices@tencent.com)

 

Processes and stores personal information on behalf of the data controller

Shenzhen Tencent Computer Systems Co Ltd.

Access of personal information to provide technical support on behalf of the data controller

 

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

Tencent Cloud LLC 

(cloudlegalnotices@tencent.com)

Singapore

Transmitted through from time to time

All personal information

Processing and storage of personal information on behalf of the data controller

For the data retention period specified under How We Store and Share Your Personal Information

Shenzhen Tencent Computer System Co Ltd.

PRC

Transmitted through from time to time

Survey Response Data

Survey Device Data

Technical support

For the data retention period specified under How We Store and Share Your Personal Information

Midas

Singapore

Transmitted through from time to time

Transaction Information

Payment

For the data retention period specified under How We Store and Share Your Personal Information

Google Play

 

(https://policies.google.com/privacy?hl=en#intro)

 

In accordance with Google’s privacy policy

Transmitted through from time to time

Transaction Information

Payment

For the data retention period specified under How We Store and Share Your Personal Information

Apple Store

 

(https://www.apple.com/legal/privacy/en-ww/)

In accordance with Apple’s privacy policy

Transmitted through from time to time

Transaction Information

Payment

For the data retention period specified under How We Store and Share Your Personal Information

 

Data Destruction

Personal information is retained in accordance with the data retention periods as detailed in section “Data Retention”. With the exception of the personal information set out below, personal information, which has fulfilled the purpose for which it was collected or used, and has reached the period of time during which personal information was to be possessed, will be destroyed in an irreversible way. Personal information stored in electronic files will be deleted safely in an irreversible way by using technical methods, and printed information will be destroyed by shredding or incinerating such information.

The personal information detailed in section “Data Retention” are required to be retained pursuant to the following laws:

 

Act on the Consumer Protection in Electronic Commerce, Etc.

Article 6 of the Act on the Consumer Protection in Electronic Commerce

In an electronic commerce or a mail-order sale:

· Records regarding labelling and advertising (6 months)

· Records regarding execution or withdrawal of a contract (5 years)

· Records regarding the payment of a price and the supply of goods and services (5 years)

· Records regarding customer services or dispute resolution (3 years)

Protection of Communications Secrets Act

Article 41 of the Decree of the Act, Article 15-2 of the Protection of Communications Secrets Act

· Log records, IP address (3 months)

· The date of telecommunications by users, the time that the telecommunications start and end, the frequency of use (12 months)

You may exercise rights related to the protection of personal information by requesting access to your personal information or the correction, deletion or suspension of processing of your personal information, etc. pursuant to applicable laws such as the Personal Information Protection Act (“PIPA”). You may also exercise these rights through your legal guardian or someone who has been authorized by you to exercise the right. However, in this case, you must submit a power of attorney to us in accordance with the Enforcement Regulations of the PIPA. You can also withdraw your consent or demand a suspension of the personal information processing at any time.

Additional Use and Provision of Personal Information

In accordance with the PIPA, we may use or provide personal information within the scope of reasonably related to the initial purpose of the collection, in consideration of whether disadvantages have been caused to data subjects and whether necessary measures have been taken to secure such as encryption, etc.  We will determine with due care whether to use or provide personal information in consideration of general circumstances including relevant laws and regulations such as the PIPA, purpose of use or provision of personal information, how personal information will be used or provided, items of personal information to be used or provided, matters to which data subjects provided consent or which were notified/disclosed to data subjects, impact on data subjects upon the use or provision, and measures taken to protect subject information.  Specific considerations are as follows:

 

· whether the additional use/provision is related to the initial purpose of the collection;

· whether the additional use/provision is foreseeable in light of the circumstances under which personal information was collected and practices regarding processing;

· whether the additional use/provision unfairly infringe on the interests of the data subject; and

· whether the necessary security measures such as pseudonymization or encryption were taken.

Domestic Privacy Representative

Pursuant to the Article 32-5 of Network Act and Article 39-11 of the amended PIPA, the information regarding the domestic agent is as follows:

· Name: Tencent Korea Yuhan Hoesa

· Address: 152 Taeheran-ro, Gangnam-gu (Gangnam Finance Center, Yeoksam-dong), Seoul, Korea 

· Telephone: +82-2-2185-0926

· Email: specified in Section 8 (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: +82-2-2185-0926

· Email: specified in Section 8 (Contact)

 

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 must not use the Service.

Personalised Marketing

By clicking “accept”, you hereby consent to being shown personalised advertisements. You may choose to stop receiving personalised advertising from us by following the opt out instructions included in the Settings section of the Service or by contacting us at Section 8 (Contact).

Thailand

By clicking "accept", you acknowledge that you have read, understood, and agree to the Privacy Policy. If you do not agree with the Privacy Policy, you must not use the Service.

 

If you are under the age of 20, you undertake that you have obtained your parent or legal guardian’s consent to register an account on and use the Service.

 

To the extent provided for by the Thai Personal Data Protection Act (“PDPA”), you may:

· withdraw your consent to the processing of your personal data (only where the legal basis for our processing is consent); however, please note that where consent is required to process your personal data, we may not be able to deliver the expected service without it;

· request us to provide you access to, make any correction to, cease any automated processing or profiling (if applicable), discontinue, restrict the use or provision of and/or erase your personal data;

· request us to provide you or a third party with your personal data which is stored by us in a machine readable format; and/or

· lodge a complaint to a relevant authority.

 

Where you wish to make such requests, please contact us as set out in Section 8 (Contact).

 

The contact details of our designated local representative in Thailand for the purposes of compliance with the PDPA is as set out in Section 8 (Contact) and can be contacted via email. Please include the word “Thailand” in the subject line of your email.

Türkiye

You have legal rights, which are set forth in Article 11 of the DPL, in relation to the personal information data we hold about you. As a Turkish data subject, you may have the right to apply to the data controller and (to the extent permitted under applicable laws and regulations):

· learn whether or not your personal data has been processed;

· request information about processing if your personal data has been processed;

· learn the purpose of processing of your personal data and whether they have been used accordingly;

· know the third parties in the country or abroad to whom personal data has been transferred;

· request rectification in the event personal data is incomplete or inaccurate and to demand the operations in this regard be reported to third parties your personal data has been transferred to;

· request deletion or destruction of personal data within the framework of the conditions set forth under Article 7 of the DPL and to demand the operations in this regard be reported to third parties your personal data has been transferred to;

· object the occurrence of any consequence that is to your detriment by means of analysis of personal data solely through automated systems; and

· demand compensation for the damages that you have suffered as a result of unlawful processing of your personal data.

 

In accordance with Article 9 of the DPL, your personal data may be transferred abroad as follows:

 

Identity of the overseas recipient

Location of the recipient (or as otherwise stated in the recipient’s privacy policy)

Purposes of use of Personal Information by the recipient

Items of Personal Information to be provided

Tencent Cloud

Singapore

Processing and storage of personal information on behalf of the data controller

 

All personal information

Shenzhen Tencent Computer System Co Ltd.

PRC

Technical support

Survey response data

Survey device data

Midas

Singapore

Payment

Transaction Information

Google Play

 

In accordance with Google’s privacy policy

 

Payment

Transaction Information

Apple Store

 

In accordance with Apple’s privacy policy

 

Payment

Transaction Information

 

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”). 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, including sensitive personal information (denoted by *), from or about you or your device:

· Identifiers, such as your name, Open ID / user ID, IP address, device ID, device token, email address, and nickname. This information is collected directly from you and your device.

· Characteristics of protected classifications under California or federal law such as national origin, gender, or 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 Service, including level, score, date and time stamps of actions, log-in and clickstream data and other Device Information as described in the main Privacy Policy. This information is collected directly from you and your device.

· Geolocation information such as your region location when you set up your profile and choose to provide this information for the Service. This information is collected directly from you.

· Audio and visual information such as audio messages. This information is collected directly from you.

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

 

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

· To provide you with the Service, maintain your account, provide customer service, process payments, and deliver audio and text messages.

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

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

· To address and remediate technical issues and bugs.

 

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

 

We disclose each of the categories of personal information that we collect as described in Section 3 (How We Process 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 about you;

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

· Right to Opt out of Targeted Advertising or Profiling. Request to opt-out of the processing of your information for the purposes of targeted advertising or the profiling of your information in furtherance of decisions that produce legal or similarly significant effects; 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, 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).

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, including (without limitation) for the purposes of showing you personalised advertising when you use the Service.

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.