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The Callisto Protocol Privacy Policy
Effective and Last Updated Date: 2022.12.02
1. Introduction
KRAFTON, Inc., and its affiliates (“we”, “our”, “Company” or “us”) collect and process information about you (“you”, “user”, or “player”). We provide the video game (“Game”), official sites (“Site(s)”) and services related to the Game (i.e., events, surveys, or customer service) (“Service(s)”) to players. This Privacy Policy (“Policy”) describes how we collect, use, and share personal information about you during and after your relationship with us in accordance with applicable data protection laws.
It is important that you read this Policy, together with any other notice we provide on occasion when we are collecting or processing personal information about you, so that you are aware of how and why we are using such personal information and what are your rights.
2. Information We Collect
We collect information about you when you play our Games and use our Services. This Information may be required to enter into a contractual relationship with you or to perform a contract with you (such as to provide the Game or a Service at your request), and the failure to provide us with any information may result in our inability to provide you with the requested Game or Service. The information we collect falls into two different categories:
1) Information collected directly from you
You may provide us with the following information when playing our Game and/or using our Services. The information you provide to us may differ depending on the circumstances. For example, these include:
- SteamID64(*), purchase history, etc. to provide and operate the Game;
- Email address, purchase history, device information, and records of the issues you experience to provide customer service, and
- Email address, gender, age, country of residence, language, and information to deliver goods (i.e., name, postal address, and phone number), in response to surveys, and for other events (sending newsletters, etc.).
(*) We collect certain information from your third-party platform’s profile/account as permitted by the terms of the third-party platform and your privacy settings thereon.
2) Information collected automatically
We automatically collect certain information when you are playing our Game online and/or use our Services. The type of information that we automatically collect may vary, but generally includes:
- Device information (including but not limited to, IP address, device ID, device model, network type, OS version, time zone settings, battery status, screen resolution, etc.),
- Device event information, including crash reports and system activity details (e.g., whether you encountered an error using our services or lost internet access, etc.), and
- Your browsing behavior while using our Site and/or Services.
3. Cookie and Related Technologies
We use cookies and related technologies to recognize your browser or device, learn more about your interests, and provide you with essential features and services and for additional purposes. Approved third parties may also set cookies and related technologies when you use our Site or Game.
1) Cookies
Cookies are small files downloaded to your computer (if your browser is enabled to accept cookies) to track movements within websites and to customize your experience within the website. Most Internet browsers will allow you to erase cookies from your computer hard drive, block cookies, or receive a warning before a cookie is stored. You should refer to your browser instructions or “Help” screen to learn more about how to manage cookies. Please note, however, that if you block cookies, some portions of the Site may not function properly.
We do not control cookies in third-party ads, and you are encouraged to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technology. The ads appearing on the Site may be delivered to you by third-party advertising companies. These companies may use information about your visits to this and other websites in order to provide advertisements on the Site and other sites about goods and services that may be of interest to you.
2) Website Analytics
We use analytics services on the Site to allow us to record information on the use of the Site and to constantly improve our offering.
The Site uses Google® Analytics, a web analytics services offered by Google Inc. (“Google”). We may use the following advertising functions of Google® Analytics and collect personal information as provided by Google, and you may withdraw your consent by deactivating such functions in Google’s advertising settings: Remarketing by using Google® Analytics; Google® Display Network Exposure Report; Google® Analytics Demographics and Interests Report; and Integrated service allowing the collection of data through Google® Analytics by using advertising cookies and anonymous IDs.
More information about Google’s own privacy policy can be found at https://www.google.com/policies/privacy.
If you wish to opt-out from your information or data being used by Google Analytics, you may download the Google Analytics Opt-out Browser Add-on available here: https://tools.google.com/dlpage/gaoptout.
4. How We Use Your Information
We use the collected information for a variety of purposes, primarily to provide the Game and the Services to players and to improve the quality of the Game and Services. These include:
- Operating and providing the Game and Services,
- Providing opportunities to participate in events or surveys relating to the game (e.g., to deliver goods to players),
- Providing customer service by collecting and responding to inquiries,
- Sending newsletters about our Game or Services (e.g., notice of new games or relevant updates, etc.),
- Providing advertising information and other information on marketing and promotional events and surveys,
- Solving technical problems and improving the quality of the game,
- Technical protection against usage of unauthorized programs, hacks and cheating software, and
- Prevent, detect, identify, investigate, and respond to potential or actual claims, liabilities, prohibited behavior, and criminal activity.
In the majority of cases, our processing of your personal information is necessary to provide the Game or Service, respond to you, or process your request. We may also process your information to comply with a relevant legal obligation. From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal by contacting us at the address provided in this Policy.
5. Sharing Your Information
We give permission to third parties, including service providers that process personal information, to do various things such as provide customer support or manage our communities. Examples of these third parties include:
- third-party game platforms (when playing online),
– cloud computing service providers,
– payment service providers to assist with payment for transactions,
– marketing platforms and providers of analytics services relating to player behavior, in order to tailor the Game or Service and to conduct marketing activities,
– online survey service providers in order to improve the Game or Service,
- anti-cheat service providers,
- customer service providers to answer user inquiries.
We may also share your information where such disclosure is essential to comply with a legal obligation or a lawful data access request, pursuant to a merger or acquisition, with our affiliates for the purposes described in this Policy, or where you have otherwise provided your consent or at your direction.
6. International Data Transfers
We operate globally and to provide our Services may transfer your data to countries and other regions outside of where you are located. If your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. Depending on where you are located, we may process your data only in certain regions (as set out in more detail below).
7. Retaining and Deleting Personal Information
Generally, we will remove your personal information without delay after the purpose of collecting personal information is achieved. Personal information stored in physical form will be shredded or incinerated, and personal information stored electronically will be removed using technical measures in a way that the information cannot be reproduced. However, we may retain your personal information even after you have closed your account with us or we have ceased providing the Game or Services to you, if retention of your personal information is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud, cheating or abuse, or enforce this Policy or any other agreement we may have with a player.
8. Our Policy Concerning Children
We do not knowingly collect, use or share any information about children (age of majority depends on the country where you reside) without verifiable parental consent or as permitted by law. If you are a parent or guardian and you believe your child has provided us with information, you can contact us and request your child’s information to be deleted from our system.
9. Links and Third-Party Services
If you click on a link to a third-party website, including, without limitation, an advertisement, you will leave the Game or Site and go to the website you selected. Because we cannot control the activities of third parties, we do not have responsibility for any use of your personal information by such third parties, and we cannot guarantee that they will adhere to the same privacy and security practices as we do. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third-party website that is linked to our Games or Services, you should consult that site’s privacy policy before providing any personal information.
10. Security of Your Information
We venture to put in place appropriate security measures, including encryption and de-identification, to prevent your personal information from being accidentally leaked, used or accessed in an unauthorized way, altered or disclosed. In addition, we put in place controls that seek to limit access to your personal information to those employees, agents, etc. who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. We have also put in place safety procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. Please note, however, that no data transmission over the internet is 100% secure, and that complete security of any information we collect and use cannot be guaranteed.
11. Other Agreements That Govern Your Use of The Site
In addition to this Privacy Policy, your rights and obligations concerning the use of the Game, Site and Services are governed by our Terms of Service, any other supplemental agreements, and other applicable policies, guidelines, and requirements. When you sign up to use the Site, please review each of the aforementioned agreements carefully, as you must agree to be bound by each of the agreements before you may use the Service.
12. Your Privacy Rights
Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your personal information, and to request access to, rectification, erasure, and portability of your own personal information. To make a request concerning your rights or if you have any questions, please contact us by sending an email to the address specified in the “Contact Us” section. We will respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
13. Amendments
We may amend, at our discretion, any portion of this Policy at any time by posting or displaying the amended Policy on our Site. You can see when this Policy was last updated by checking the “Effective and Last Updated Date” date displayed at the top of this Policy.
14. Contact Us
If you have any questions about this Policy, or your dealings with this Game, Site or Services, please contact us by sending an email at privacy@krafton.com.
This Privacy Policy has been translated into other languages for your convenience. In case of any discrepancies between the English version and the other versions, the English version shall prevail. However, the Korean Privacy Policy shall prevail for Korean players.
[SUPPLEMENTAL TERMS – JURISDICTION SPECIFIC]
In the event the following sections apply and there is a conflict between them and the rest of the Policy, the following sections will supersede and control.
1. EEA, Switzerland and UK
If you are in the European Economic Area (EEA), Switzerland or the UK, you may lodge a complaint with an EU/UK/EEA data protection authority for your country or region where an alleged infringement of applicable data protection law occurs.
Our representative in the EU is VeraSafe Netherlands BV, located at Keizersgracht 391 A, 1016 EJ Amsterdam, The Netherlands. To contact them, please use the form available here: https://verasafe.com/public-resources/contact-data-protection-representative.
Our representative in the UK is VeraSafe United Kingdom Ltd., located at 37 Albert Embankment, London SE1 7TL, United Kingdom. To contact them, please use the form available here: https://verasafe.com/public-resources/contact-data-protection-representative.
A) International Data Transfer
If we transfer your data outside of the EEA to a country that is not recognized by the European Commission as ensuring an adequate level of data protection, we endeavor to apply suitable measures to safeguard your personal data in accordance with applicable data protection and privacy laws. These safeguards may include data transfer agreements implementing the latest standard contractual clauses (a form of data transfer agreement pre-approved by the European Commission as providing adequate safeguards for personal data). You may ask for a copy of such appropriate measures by contacting us as set out in this Policy. We otherwise transfer personal data with consent; to perform a contract with you; or to fulfill a compelling legitimate interest in a manner that does not outweigh your rights and freedoms.
B) Your Privacy Rights
You have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work, or where we are established.
2. United States
A) Nevada
If you are a Nevada resident, we do not sell your personal information. Nonetheless, if you are Nevada residents who purchased our Game or any Services from us, you may submit a request to record your preference to opt out for the future.
B) California
If you are a California resident, you have additional rights. For more information concerning your privacy rights, please review our Privacy Notice for California Residents below or visit our website.
- Privacy Notice for California Residents
This Privacy Notice (“Notice”) for California residents provided pursuant to the California Consumer Privacy Act (“CCPA”) supplements our Policy and provides additional information on how your personal information is collected, used, disclosed and processed online or offline. Unless otherwise specified, all terms used within this Notice shall carry the same meaning as they are defined in our Policy above. This Notice and the Policy together constitutes our “California Privacy Policy”.
We will collect the following categories of information that may directly or indirectly identify or describe you or your device, or information that may be reasonably capable of being associated with or reasonably linked to you or your device (“personal information”). We have collected these same categories of personal information from consumers over the past 12 months. Please refer to our Policy concerning the categories of sources from which this personal information is collected.
Also, we may provide service providers or third parties with certain personal information to provide or improve our services. Within the past 12 months, we disclosed or shared each of the following categories of personal information with the following categories of third parties. We have not “sold” personal information to third parties as that term is defined by the CCPA within the past 12 months.
- Categories of Personal Information Collected and Disclosed
1) Identifiers
- Categories: IP address(*), email address, SteamID64(*), contact information (such as postal address, phone numbers).
- Categories of third parties to whom personal information was disclosed: payment service providers, online survey service providers, customer service providers, program restriction providers, cloud computing service providers, delivery service providers.
2) Internet or other similar network activity information(*)
- Categories: website, application or advertisement browsing history, device model, OS version, device storage, and information about your device.
- Categories of third parties to whom personal information was disclosed: payment service providers, online survey service providers, customer service providers, program restriction providers, cloud computing service providers.
(*) We collect certain categories only when playing the Game online or when visiting our Sites.
- Your California Privacy Rights
You may exercise the following rights at any point in time in connection with your personal information. To exercise such rights, please email us at privacy@krafton.com.
Please note that at least your email address will be required to submit a request, and additional information may be required so we can verify you. If you exercise your rights via email, you must specify the right(s) you wish to exercise.
We will verify your identity and respond to your request within 45 calendar days. If necessary, we can take up to an additional 45 days to respond, for a maximum total of 90 days from the day the request is received, provided that we notify you to explain the reason for the delay.
1) Right to Access
You have the right to request the following information from us up to two times within a 12-month period:
- the categories of personal information that we have collected from you over the past 12 months, and the specific pieces of personal information we have collected from you;
- Categories of the sources from which personal information was collected
- Business or commercial purposes for which personal information is collected
- the categories of personal information that we have disclosed for a business purpose or sold during the past 12 months, and categories of third parties to whom the information was disclosed or sold (if applicable).
2) Right to Request Deletion
You have the right to request that the personal information collected from you be deleted.
3) Right to Opt-Out of Selling
You have the right to “opt out” of the “selling” of your personal information as defined by California law by requesting that your personal information not be sold in any form. However, we do not sell personal information.
4) Right to Non-Discrimination
You have the right not to be discriminated against for exercising these privacy rights.
5) Rights for California Minors
Minors under the age of 18 have the right to request the deletion of and/or obtain information posted on websites such as forums or bulletin boards.
6) Shine the Light
You have the right to request the categories of the personal information that we disclosed to third parties for their direct marketing purposes during the past 12 months and information on the relevant third parties. Furthermore, you may also request that your personal information not be disclosed to third parties for their direct marketing purposes.
- Authorized Agent
You may designate another person or entity (“authorized agent”) to act on your behalf in connection with your request for rights that are guaranteed by the CCPA. An authorized agent is a natural person or business entity registered with the Secretary of State to conduct business in California that you have authorized to act of your behalf to make a request to know or to delete.
In order to use an authorized agent for your request, we require that you provide signed permission to your agent. Your authorized agent can submit a request to know or delete by sending an email to privacy@krafton.com. If you contact us, we can offer you an authorized form for your agent to submit.
The above requirement does not apply should your agent have power of attorney pursuant to Probate Code sections 4000 to 4465. Please note that we may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf. Under the CCPA, your agent is responsible for implementing and maintaining reasonable security procedures and practices to protect your information and use your personal information only for the purpose of fulfilling your request.
If you have any questions about this California Privacy Policy, or about exercising your rights described above, you can contact us by email at privacy@krafton.com.
Effective and Last Updated Date: 2022.12.02
1. Introduction
KRAFTON, Inc., and its affiliates (“we”, “our”, “Company” or “us”) collect and process information about you (“you”, “user”, or “player”). We provide the video game (“Game”), official sites (“Site(s)”) and services related to the Game (i.e., events, surveys, or customer service) (“Service(s)”) to players. This Privacy Policy (“Policy”) describes how we collect, use, and share personal information about you during and after your relationship with us in accordance with applicable data protection laws.
It is important that you read this Policy, together with any other notice we provide on occasion when we are collecting or processing personal information about you, so that you are aware of how and why we are using such personal information and what are your rights.
2. Information We Collect
We collect information about you when you play our Games and use our Services. This Information may be required to enter into a contractual relationship with you or to perform a contract with you (such as to provide the Game or a Service at your request), and the failure to provide us with any information may result in our inability to provide you with the requested Game or Service. The information we collect falls into two different categories:
1) Information collected directly from you
You may provide us with the following information when playing our Game and/or using our Services. The information you provide to us may differ depending on the circumstances. For example, these include:
- SteamID64(*), purchase history, etc. to provide and operate the Game;
- Email address, purchase history, device information, and records of the issues you experience to provide customer service, and
- Email address, gender, age, country of residence, language, and information to deliver goods (i.e., name, postal address, and phone number), in response to surveys, and for other events (sending newsletters, etc.).
(*) We collect certain information from your third-party platform’s profile/account as permitted by the terms of the third-party platform and your privacy settings thereon.
2) Information collected automatically
We automatically collect certain information when you are playing our Game online and/or use our Services. The type of information that we automatically collect may vary, but generally includes:
- Device information (including but not limited to, IP address, device ID, device model, network type, OS version, time zone settings, battery status, screen resolution, etc.),
- Device event information, including crash reports and system activity details (e.g., whether you encountered an error using our services or lost internet access, etc.), and
- Your browsing behavior while using our Site and/or Services.
3. Cookie and Related Technologies
We use cookies and related technologies to recognize your browser or device, learn more about your interests, and provide you with essential features and services and for additional purposes. Approved third parties may also set cookies and related technologies when you use our Site or Game.
1) Cookies
Cookies are small files downloaded to your computer (if your browser is enabled to accept cookies) to track movements within websites and to customize your experience within the website. Most Internet browsers will allow you to erase cookies from your computer hard drive, block cookies, or receive a warning before a cookie is stored. You should refer to your browser instructions or “Help” screen to learn more about how to manage cookies. Please note, however, that if you block cookies, some portions of the Site may not function properly.
We do not control cookies in third-party ads, and you are encouraged to check the privacy policies of advertisers and/or ad services to learn about their use of cookies and other technology. The ads appearing on the Site may be delivered to you by third-party advertising companies. These companies may use information about your visits to this and other websites in order to provide advertisements on the Site and other sites about goods and services that may be of interest to you.
2) Website Analytics
We use analytics services on the Site to allow us to record information on the use of the Site and to constantly improve our offering.
The Site uses Google® Analytics, a web analytics services offered by Google Inc. (“Google”). We may use the following advertising functions of Google® Analytics and collect personal information as provided by Google, and you may withdraw your consent by deactivating such functions in Google’s advertising settings: Remarketing by using Google® Analytics; Google® Display Network Exposure Report; Google® Analytics Demographics and Interests Report; and Integrated service allowing the collection of data through Google® Analytics by using advertising cookies and anonymous IDs.
More information about Google’s own privacy policy can be found at https://www.google.com/policies/privacy.
If you wish to opt-out from your information or data being used by Google Analytics, you may download the Google Analytics Opt-out Browser Add-on available here: https://tools.google.com/dlpage/gaoptout.
4. How We Use Your Information
We use the collected information for a variety of purposes, primarily to provide the Game and the Services to players and to improve the quality of the Game and Services. These include:
- Operating and providing the Game and Services,
- Providing opportunities to participate in events or surveys relating to the game (e.g., to deliver goods to players),
- Providing customer service by collecting and responding to inquiries,
- Sending newsletters about our Game or Services (e.g., notice of new games or relevant updates, etc.),
- Providing advertising information and other information on marketing and promotional events and surveys,
- Solving technical problems and improving the quality of the game,
- Technical protection against usage of unauthorized programs, hacks and cheating software, and
- Prevent, detect, identify, investigate, and respond to potential or actual claims, liabilities, prohibited behavior, and criminal activity.
In the majority of cases, our processing of your personal information is necessary to provide the Game or Service, respond to you, or process your request. We may also process your information to comply with a relevant legal obligation. From time to time, we may ask for your consent to use your information for certain specific reasons. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal by contacting us at the address provided in this Policy.
5. Sharing Your Information
We give permission to third parties, including service providers that process personal information, to do various things such as provide customer support or manage our communities. Examples of these third parties include:
- third-party game platforms (when playing online),
– cloud computing service providers,
– payment service providers to assist with payment for transactions,
– marketing platforms and providers of analytics services relating to player behavior, in order to tailor the Game or Service and to conduct marketing activities,
– online survey service providers in order to improve the Game or Service,
- anti-cheat service providers,
- customer service providers to answer user inquiries.
We may also share your information where such disclosure is essential to comply with a legal obligation or a lawful data access request, pursuant to a merger or acquisition, with our affiliates for the purposes described in this Policy, or where you have otherwise provided your consent or at your direction.
6. International Data Transfers
We operate globally and to provide our Services may transfer your data to countries and other regions outside of where you are located. If your personal information is transferred, stored or processed by us, we will take reasonable steps to safeguard the privacy of your personal information. Depending on where you are located, we may process your data only in certain regions (as set out in more detail below).
7. Retaining and Deleting Personal Information
Generally, we will remove your personal information without delay after the purpose of collecting personal information is achieved. Personal information stored in physical form will be shredded or incinerated, and personal information stored electronically will be removed using technical measures in a way that the information cannot be reproduced. However, we may retain your personal information even after you have closed your account with us or we have ceased providing the Game or Services to you, if retention of your personal information is reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, prevent fraud, cheating or abuse, or enforce this Policy or any other agreement we may have with a player.
8. Our Policy Concerning Children
We do not knowingly collect, use or share any information about children (age of majority depends on the country where you reside) without verifiable parental consent or as permitted by law. If you are a parent or guardian and you believe your child has provided us with information, you can contact us and request your child’s information to be deleted from our system.
9. Links and Third-Party Services
If you click on a link to a third-party website, including, without limitation, an advertisement, you will leave the Game or Site and go to the website you selected. Because we cannot control the activities of third parties, we do not have responsibility for any use of your personal information by such third parties, and we cannot guarantee that they will adhere to the same privacy and security practices as we do. We encourage you to review the privacy policies of any other service provider from whom you request services. If you visit a third-party website that is linked to our Games or Services, you should consult that site’s privacy policy before providing any personal information.
10. Security of Your Information
We venture to put in place appropriate security measures, including encryption and de-identification, to prevent your personal information from being accidentally leaked, used or accessed in an unauthorized way, altered or disclosed. In addition, we put in place controls that seek to limit access to your personal information to those employees, agents, etc. who have a business need to know. They will only process your personal information on our instructions, and they are subject to a duty of confidentiality. We have also put in place safety procedures to deal with any suspected data security breach and will notify you and any applicable regulator of a suspected breach where we are legally required to do so. Please note, however, that no data transmission over the internet is 100% secure, and that complete security of any information we collect and use cannot be guaranteed.
11. Other Agreements That Govern Your Use of The Site
In addition to this Privacy Policy, your rights and obligations concerning the use of the Game, Site and Services are governed by our Terms of Service, any other supplemental agreements, and other applicable policies, guidelines, and requirements. When you sign up to use the Site, please review each of the aforementioned agreements carefully, as you must agree to be bound by each of the agreements before you may use the Service.
12. Your Privacy Rights
Subject to limitations in applicable law, you are entitled to object to or request the restriction of processing of your personal information, and to request access to, rectification, erasure, and portability of your own personal information. To make a request concerning your rights or if you have any questions, please contact us by sending an email to the address specified in the “Contact Us” section. We will respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
13. Amendments
We may amend, at our discretion, any portion of this Policy at any time by posting or displaying the amended Policy on our Site. You can see when this Policy was last updated by checking the “Effective and Last Updated Date” date displayed at the top of this Policy.
14. Contact Us
If you have any questions about this Policy, or your dealings with this Game, Site or Services, please contact us by sending an email at privacy@krafton.com.
This Privacy Policy has been translated into other languages for your convenience. In case of any discrepancies between the English version and the other versions, the English version shall prevail. However, the Korean Privacy Policy shall prevail for Korean players.
[SUPPLEMENTAL TERMS – JURISDICTION SPECIFIC]
In the event the following sections apply and there is a conflict between them and the rest of the Policy, the following sections will supersede and control.
1. EEA, Switzerland and UK
If you are in the European Economic Area (EEA), Switzerland or the UK, you may lodge a complaint with an EU/UK/EEA data protection authority for your country or region where an alleged infringement of applicable data protection law occurs.
Our representative in the EU is VeraSafe Netherlands BV, located at Keizersgracht 391 A, 1016 EJ Amsterdam, The Netherlands. To contact them, please use the form available here: https://verasafe.com/public-resources/contact-data-protection-representative.
Our representative in the UK is VeraSafe United Kingdom Ltd., located at 37 Albert Embankment, London SE1 7TL, United Kingdom. To contact them, please use the form available here: https://verasafe.com/public-resources/contact-data-protection-representative.
A) International Data Transfer
If we transfer your data outside of the EEA to a country that is not recognized by the European Commission as ensuring an adequate level of data protection, we endeavor to apply suitable measures to safeguard your personal data in accordance with applicable data protection and privacy laws. These safeguards may include data transfer agreements implementing the latest standard contractual clauses (a form of data transfer agreement pre-approved by the European Commission as providing adequate safeguards for personal data). You may ask for a copy of such appropriate measures by contacting us as set out in this Policy. We otherwise transfer personal data with consent; to perform a contract with you; or to fulfill a compelling legitimate interest in a manner that does not outweigh your rights and freedoms.
B) Your Privacy Rights
You have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work, or where we are established.
2. United States
A) Nevada
If you are a Nevada resident, we do not sell your personal information. Nonetheless, if you are Nevada residents who purchased our Game or any Services from us, you may submit a request to record your preference to opt out for the future.
B) California
If you are a California resident, you have additional rights. For more information concerning your privacy rights, please review our Privacy Notice for California Residents below or visit our website.
- Privacy Notice for California Residents
This Privacy Notice (“Notice”) for California residents provided pursuant to the California Consumer Privacy Act (“CCPA”) supplements our Policy and provides additional information on how your personal information is collected, used, disclosed and processed online or offline. Unless otherwise specified, all terms used within this Notice shall carry the same meaning as they are defined in our Policy above. This Notice and the Policy together constitutes our “California Privacy Policy”.
We will collect the following categories of information that may directly or indirectly identify or describe you or your device, or information that may be reasonably capable of being associated with or reasonably linked to you or your device (“personal information”). We have collected these same categories of personal information from consumers over the past 12 months. Please refer to our Policy concerning the categories of sources from which this personal information is collected.
Also, we may provide service providers or third parties with certain personal information to provide or improve our services. Within the past 12 months, we disclosed or shared each of the following categories of personal information with the following categories of third parties. We have not “sold” personal information to third parties as that term is defined by the CCPA within the past 12 months.
- Categories of Personal Information Collected and Disclosed
1) Identifiers
- Categories: IP address(*), email address, SteamID64(*), contact information (such as postal address, phone numbers).
- Categories of third parties to whom personal information was disclosed: payment service providers, online survey service providers, customer service providers, program restriction providers, cloud computing service providers, delivery service providers.
2) Internet or other similar network activity information(*)
- Categories: website, application or advertisement browsing history, device model, OS version, device storage, and information about your device.
- Categories of third parties to whom personal information was disclosed: payment service providers, online survey service providers, customer service providers, program restriction providers, cloud computing service providers.
(*) We collect certain categories only when playing the Game online or when visiting our Sites.
- Your California Privacy Rights
You may exercise the following rights at any point in time in connection with your personal information. To exercise such rights, please email us at privacy@krafton.com.
Please note that at least your email address will be required to submit a request, and additional information may be required so we can verify you. If you exercise your rights via email, you must specify the right(s) you wish to exercise.
We will verify your identity and respond to your request within 45 calendar days. If necessary, we can take up to an additional 45 days to respond, for a maximum total of 90 days from the day the request is received, provided that we notify you to explain the reason for the delay.
1) Right to Access
You have the right to request the following information from us up to two times within a 12-month period:
- the categories of personal information that we have collected from you over the past 12 months, and the specific pieces of personal information we have collected from you;
- Categories of the sources from which personal information was collected
- Business or commercial purposes for which personal information is collected
- the categories of personal information that we have disclosed for a business purpose or sold during the past 12 months, and categories of third parties to whom the information was disclosed or sold (if applicable).
2) Right to Request Deletion
You have the right to request that the personal information collected from you be deleted.
3) Right to Opt-Out of Selling
You have the right to “opt out” of the “selling” of your personal information as defined by California law by requesting that your personal information not be sold in any form. However, we do not sell personal information.
4) Right to Non-Discrimination
You have the right not to be discriminated against for exercising these privacy rights.
5) Rights for California Minors
Minors under the age of 18 have the right to request the deletion of and/or obtain information posted on websites such as forums or bulletin boards.
6) Shine the Light
You have the right to request the categories of the personal information that we disclosed to third parties for their direct marketing purposes during the past 12 months and information on the relevant third parties. Furthermore, you may also request that your personal information not be disclosed to third parties for their direct marketing purposes.
- Authorized Agent
You may designate another person or entity (“authorized agent”) to act on your behalf in connection with your request for rights that are guaranteed by the CCPA. An authorized agent is a natural person or business entity registered with the Secretary of State to conduct business in California that you have authorized to act of your behalf to make a request to know or to delete.
In order to use an authorized agent for your request, we require that you provide signed permission to your agent. Your authorized agent can submit a request to know or delete by sending an email to privacy@krafton.com. If you contact us, we can offer you an authorized form for your agent to submit.
The above requirement does not apply should your agent have power of attorney pursuant to Probate Code sections 4000 to 4465. Please note that we may deny a request from an agent that does not submit proof that they have been authorized by you to act on your behalf. Under the CCPA, your agent is responsible for implementing and maintaining reasonable security procedures and practices to protect your information and use your personal information only for the purpose of fulfilling your request.
If you have any questions about this California Privacy Policy, or about exercising your rights described above, you can contact us by email at privacy@krafton.com.