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TBH: Task Bar Hero
Terms of Service & Privacy Policy
Applies to
This version of the Terms applies to Users who have consented to this version through the in-client consent process. This version corresponds to the server-based client (Ver 1.3.0 and later). Users who have not consented to this version remain governed by the version of the Terms to which they last consented, until they consent to this version. Users with no recorded consent to any version must consent to the then-current version in order to use the Game.
Developer: Nugem Studio
Contact: https://nugemstudio.zendesk.com/hc
IMPORTANT NOTICE
Please read these Terms carefully before playing TBH: Task Bar Hero. When you first launch a client that requires this version, you will be asked to review and consent to these Terms. Consent is required to use the online (server-based) features. The version you consent to is recorded on your account. If you do not consent, you may continue to use offline features or previous-version features under the terms to which you last consented, but you may not use online features that require the current version.
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TERMS OF SERVICE
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Article 1 (Purpose)
These Terms of Service (hereinafter "Terms") govern the rights, obligations, responsibilities, and personal data processing between Nugem Studio (hereinafter "Company") and users in connection with the use of TBH: Task Bar Hero (hereinafter "Game").
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Article 2 (Definitions)
The terms used in these Terms are defined as follows.
1. "Game" refers to TBH: Task Bar Hero and all related services provided by the Company.
2. "User" refers to any person who explicitly agrees to these Terms via the consent process and uses the Game.
3. "Minor" refers to any person under the age of 19 under the laws of the Republic of Korea. For users in the European Union, "Minor" additionally refers to any person under the age of 16 (or such lower age as permitted by the applicable EU Member State law, but no lower than 13). For users in other jurisdictions, the age threshold defined by applicable local law shall apply.
4. "Legal Guardian" refers to a parent or legal guardian of a Minor.
5. "Game Item" refers to digital content generated or acquired through the in-game network features.
6. "Marketplace" refers to the Steam Community Market, where users may trade Game Items using Steam Wallet funds.
7. "Game Data" refers to all data generated during gameplay, including play logs, item holdings, and transaction history.
8. "License" refers to the limited, non-exclusive, revocable right to use the Game.
9. "Personal Information" refers to information that identifies or can identify an individual.
10. "Platform" refers to the Steam service operated by Valve Corporation.
11. "In-App Purchase" refers to any purchase of digital content, virtual items, or other paid features made within the Game through the Platform.
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Article 3 (Effectiveness and Amendment of Terms)
1. These Terms become effective when the User explicitly consents by checking the consent checkbox and clicking the confirmation button upon launching the Game. Users who do not consent may not proceed to use the online (server-based) features of the Game.
2. These Terms become effective immediately upon first publication. The Company may amend these Terms within the scope permitted by applicable laws. Any subsequent amendments will be announced at least 7 days prior to the effective date via in-game notices or Steam announcements.
3. If a User does not agree to the amended Terms, the User may discontinue use of the Game. Continued use after the announcement of amendments shall be deemed as consent to the amended Terms.
4. Consent-version-based application: This version of the Terms applies to Users who have consented to this version through the in-client consent process. The version a User consents to is recorded on the User's account. Use of the online (server-based) features requires consent to the then-current version. A User whose recorded consent version is not the current version will be asked to review and consent to the current version at the next online login, before using online features. A User who does not consent may continue to use offline features or previous-version features under the terms to which the User previously consented, but may not use online features that require the current version. A User with no recorded consent to any version must consent to the then-current version in order to use the Game. References to a specific client version (Ver 1.3.0 and later) are informational only, indicating the client to which this version of the Terms corresponds, and do not by themselves determine which version of the Terms applies to a User.
5. Relationship to the notice period: The advance-notice period in Article 3(2) applies only to amendments that the Company implements without renewed consent. Where a new version is applied through the User's active in-client consent, that version takes effect for that User at the moment of consent, and the notice period in Article 3(2) does not apply to, and does not delay, such consent-based changes.
6. Effect of declining consent: Online features — including server-stored inventory, item generation, and Marketplace-related features — are provided only to Users who have consented to the then-current version of the Terms. A User who declines may use only offline features or previous-version features, and cannot access server-stored items or online features. Before declining, a User may request a copy of their personal data held by the Company in accordance with Article 6 of the Privacy Policy.
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Article 4 (Use by Minors)
1. Minors must obtain consent from their Legal Guardian prior to using the Game. For EU/EEA users, the applicable age thresholds defined in Article 2(3) above apply.
2. If a Minor uses the Game without the consent of their Legal Guardian, the Legal Guardian may cancel such use. However, cancellation may be restricted if the Minor misrepresented themselves as an adult.
3. Legal Guardians may request the Company to review a Minor's game usage history and impose usage restrictions.
4. The Company implements measures to protect Minors in accordance with applicable laws, including youth protection regulations and, where applicable, the GDPR (for EU/EEA users).
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Article 5 (License and Intellectual Property)
1. The Company grants Users a limited, non-exclusive, non-transferable license to use the Game for personal, non-commercial purposes. This license may not be assigned, sold, leased, or sublicensed.
2. Users may not modify, reverse engineer, reproduce, or distribute the Game.
3. All copyrights and intellectual property rights to content within the Game (including graphics, music, sound, code, characters, story, and UI) belong to the Company.
4. Users are permitted to share content created in relation to the Game (such as screenshots and videos) for non-commercial purposes. Commercial use requires prior written consent from the Company.
5. The Company may terminate the License after notifying the User in the event of a Terms violation.
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Article 6 (Service Provision and Changes)
1. The Company may modify game content, systems, and item structures as operationally required.
2. Updates may change the performance or value of existing items, and no separate compensation will be provided for such changes. However, the Company will provide advance notice of significant changes. Rights guaranteed to Users under applicable mandatory laws (such as consumer protection laws) are not limited by this paragraph.
3. Some features of the Game require a network (internet) connection.
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Article 7 (Steam Account and Platform)
1. This Game is provided through the Steam platform operated by Valve Corporation.
2. Users are responsible for the security of their Steam accounts. The Company is not responsible for damages resulting from account theft or hacking, unless caused by the Company's own fault.
3. Valve Corporation's terms of service take precedence with respect to Steam platform policies.
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Article 8 (Network Features and Game Item Generation)
1. The Game uses a network (internet) connection for online features. Online features — including account login, inventory, item generation, and item transactions — are processed and stored on the Company's dedicated game server, which is operated through a processor (see Privacy Policy Article 3). In-game activity logs are also recorded on this server as described in Article 1(5) of the Privacy Policy.
2. Game Items generated through the network are digital content within the Game and do not represent real-world assets or investment instruments.
3. The Company is not responsible for item generation failures caused by unstable network connections, server maintenance, or force majeure events.
4. Users must not use unauthorized methods (such as hacks, macros, or third-party programs) during item generation.
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Article 9 (Marketplace Transactions)
1. Game Items may be traded on the Steam Marketplace (Steam Community Market) using Steam Wallet funds.
2. Marketplace transactions are governed by Valve Corporation's Steam Terms of Service and Marketplace policies. The Company does not directly intervene in Steam platform trading policies.
3. The Company is not responsible for profits, losses, or disputes arising from transactions, which are handled under Steam platform policies.
4. Abnormal transactions, deliberate price manipulation, and fraudulent activities are strictly prohibited and may result in usage restrictions upon detection.
5. The Company may modify item attributes for economic balance purposes and is not responsible for changes in trading value resulting from such modifications. Rights guaranteed to Users under applicable mandatory laws are not limited by this paragraph.
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Article 10 (Refund Policy)
1. The Game is provided free of charge, and refunds do not apply to the Game itself.
2. DLC (Downloadable Content) and In-App Purchases are purchased through the Platform. The Company does not provide separate refunds for DLC or In-App Purchases. Refunds are handled entirely in accordance with Valve Corporation's Steam Refund Policy, and the Company has no authority to process such refunds directly.
3. Users wishing to request a refund for DLC or an In-App Purchase should do so directly through Steam Customer Support at store.steampowered.com/support. Whether a refund is granted, and within what period, is determined in accordance with Valve Corporation's policies.
4. Steam Wallet transactions on the Steam Marketplace are also subject to Valve Corporation's policies, and the Company has no authority to process refunds for such transactions.
5. Consumer rights guaranteed by applicable mandatory laws (such as consumer protection laws and EU Consumer Rights Directive) are preserved regardless of these Terms.
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Article 11 (User Obligations)
1. Users must not engage in the following activities:
- Using unauthorized methods such as hacks, macros, or auto programs
- Exploiting in-game bugs or vulnerabilities
- Price manipulation, fraud, or abnormal transactions in the Marketplace
- Infringing upon the Company's intellectual property rights
- Using Game content for unauthorized commercial purposes
- Violating applicable laws and regulations
2. The Company may operate automated systems to detect fraudulent activities.
3. Upon confirmation of a violation, the Company may take the following actions:
- Warning and prior notice
- Temporary suspension of game access
- Item recovery
- Permanent ban from the Game
4. Users may appeal the Company's sanctions by submitting a request through the Help Center (https://nugemstudio.zendesk.com/hc). The Company will notify the User of the outcome within 30 days of receipt.
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Article 12 (Service Changes and Suspension)
1. The Company may modify or suspend service content as operationally or technically required.
2. In the event of a service suspension, the Company will provide at least 30 days' advance notice via Steam announcements. However, post-hoc notice may be given in cases of force majeure.
3. Upon service termination, the Company will provide at least 30 days' prior notice via in-game announcements and Steam. During this notice period, users may request a copy of their personal data held directly by the Company by contacting the Help Center (https://nugemstudio.zendesk.com/hc).
4. Game Items and Game Data will be deleted upon service termination. The Company bears no obligation to compensate for such deletion unless otherwise required by applicable mandatory law.
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Article 13 (Disclaimer)
1. The Company is not liable for service interruptions caused by force majeure events such as natural disasters, war, hacking, or server failures.
2. The Company is not liable for damages caused by the User's own fault.
3. The Company is not liable for service changes resulting from policy changes by Steam or Valve Corporation.
4. The Company's liability for damages is limited to the maximum extent permitted by applicable laws.
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Article 14 (Governing Law and Dispute Resolution)
1. These Terms shall be interpreted and applied in accordance with the laws of the Republic of Korea.
2. In the event of a dispute arising from the use of the Game, the Company and the User shall in principle resolve it through mutual consultation.
3. If no agreement is reached, the competent court shall be determined in accordance with the Civil Procedure Act.
4. For international users, applicable mandatory local laws — including EU consumer protection laws — may take precedence over these Terms.
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Article 15 (Miscellaneous)
1. Matters not specified in these Terms shall be governed by applicable laws and the Steam platform's terms of service.
2. If any provision of these Terms is found to be invalid under applicable law, the remaining provisions shall remain in full force and effect.
3. The Company does not use advertising cookies or third-party behavioral-analytics SDKs within the Game. Technical data necessary for the operation and security of the online service, and in-game activity logs recorded by the Company on its own game server, are processed as described in the Privacy Policy. Steam's built-in platform telemetry is governed by Valve Corporation's Privacy Policy.
4. Language: These Terms are provided in multiple languages. In the event of any discrepancy in interpretation between the translated versions, the English version shall prevail.
5. Previous versions: Previous versions of these Terms and the Privacy Policy are archived and remain available to Users at:
https://docs.google.com/document/d/1b9wt29PHDeek6lXvZSwF0wjZZs2LY1xXMMa6w8q2ZxQ/edit?usp=sharing
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PRIVACY POLICY
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Applies to: Users who have consented to this version through the in-client consent process. This version corresponds to the server-based client (Ver 1.3.0 and later). Users who have not consented to this version remain governed by the version of the Privacy Policy to which they last consented, until they consent to this version.
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Article 1 (Information We Collect and Legal Basis)
TBH: Task Bar Hero follows a data minimization policy: the Company collects only the data necessary to operate the game's online features, secure user accounts, prevent abuse, and maintain and improve the Game. The Company does not use advertising cookies or third-party behavioral-analytics SDKs; technical data necessary for the operation and security of the online service, and in-game activity logs recorded by the Company on its own game server, are processed as described in this Privacy Policy.
With the introduction of a dedicated game server (operated through a processor; see Article 3), online features such as account login, inventory, and item transactions are processed and stored on the server. The data below is collected accordingly.
[1. Collected on account login / first access — applies to all online users]
Items : - Steam ID
- App ID
- Steam authentication session ticket (one-time login token)
Purpose : Account identification and login authentication.
Legal Basis : Contract performance (GDPR Art. 6(1)(b))
[2. Automatically collected by the game server when using online features]
The following is automatically recorded by the game server (via the processor's SDK) each time the Game connects to the server.
Items : - IP address and IP-based country information
- Device information and device-based language
- OS information
- Nickname
- Access (call) date and time, including login
Purpose : Operation and stability of the online service; account security; prevention of abuse and unauthorized access.
Legal Basis : Contract performance (GDPR Art. 6(1)(b)) and legitimate interests in security and abuse prevention (GDPR Art. 6(1)(f))
[3. Game data — collected to provide online features]
Items : - Inventory data (item IDs, item instance keys, chest cooldown)
- Item acquisition, consumption, and exchange (synthesis / opening)
request records
- Game client version (for compatibility verification)
- Game progress data: data constituting the User's saved game state (e.g., character level, in-game currency balances, stage progress). Items within this category may be added or changed as game content evolves, and data in this category is processed only within the scope of storing and validating game progress. If the Company begins to collect a new category of data of a different nature, this will be announced through an amendment to this Privacy Policy.
Purpose : Server-side storage of game progress; server-side validation of item grants and exchanges; client version compatibility.
Legal Basis : Contract performance (GDPR Art. 6(1)(b))
[4. Collected only upon cheat detection]
Collected ONLY when the anti-cheat system detects the potential use of cheat software or other abnormal activity. It is NOT collected during normal play.
Items : - Steam ID and game version
- Current and highest stage progress
- Cumulative playtime
- Game progress data at the time of detection (e.g., character level, in-game currency balances)
- Detection rule ID and related detection parameters
Purpose : Detection of cheating and maintaining a fair play environment.
Legal Basis : Legitimate interests — fraud prevention and fair play (GDPR Art. 6(1)(f))
[5. In-game activity logs — recorded during normal play]
While the User plays online, the Game records in-game actions and their results on the Company's game server. These logs are linked to the User's game account.
Items : - In-game currency (gold) changes, including the amount and the balance before and after the change
- Item acquisition, consumption, crafting, synthesis, opening, and item-option changes, including item keys, quantities before and after, and related item identifiers
- Growth records (e.g., hero, cube, and rune level-ups and experience changes)
- Stage and combat summaries (e.g., stage, monster, number of monsters defeated, offline rewards)
- In-game market and mailbox records (item registration, removal, and receipt)
- Game authentication and game entry events
- Exposure of and clicks on in-game event banners and notices, together with country information (country code only)
- Log time and log identifiers used to link related records
Purpose : Analysis of how the Game and its economy are used; game balance and usability improvement; measuring the effectiveness of in-game events and notices; investigating item or currency discrepancies and responding to User inquiries; detection of abnormal activity.
Legal Basis : Legitimate interests in operating, improving, and securing the Game and its economy (GDPR Art. 6(1)(f)). Users may object to this processing under Article 6.
[6. Help Center inquiries — only if you submit an inquiry]
Collected only when a User submits an inquiry, a sanction appeal, or a data-subject rights request through the Help Center
(https://nugemstudio.zendesk.com/hc).
Items : - Email address
- Inquiry subject, message content, and any files you attach
- Information you choose to provide in the course of the inquiry (e.g., Steam ID, nickname, client version)
Purpose : Receiving and handling inquiries, appeals, and rights requests; identity verification; replying with the outcome.
Legal Basis : Contract performance (GDPR Art. 6(1)(b)) and legitimate interests in responding to inquiries (GDPR Art. 6(1)(f))
Note : Using the Help Center is optional; however, the Company cannot reply to an inquiry without an email address.
Note: Providing the data in Section 1 is required to use the online service. Without a Steam ID and login authentication, server login is not possible and online features cannot be provided.
Note: Steam Marketplace transactions are processed on the Steam platform; the related transaction records are held by Valve Corporation, not by the Company. (See Article 5.)
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Article 2 (Purpose of Collection)
Collected information is used solely for the following purposes:
- Account identification and login authentication
- Provision and stable operation of online features (inventory, item transactions, game progress storage)
- Server-side validation of item grants and exchanges
- Account security and prevention of abuse / unauthorized access
- Detection of cheating and maintaining a fair play environment
- Client version compatibility verification
- Analysis of game and in-game economy usage, and improvement of game balance and usability
- Measuring the effectiveness of in-game events and notices
- Investigating item or currency discrepancies and responding to User inquiries
- Receiving and handling inquiries, appeals, and data-subject rights requests
- Responding to sanction-related appeals and legal disputes
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Article 3 (Processing Entrustment)
To operate the online service, the Company entrusts the processing of personal data to the processors below. The Company enters into a data processing agreement with each processor as required under GDPR Art. 28.
[Processor 1]
Entrusted to : AFI Inc. (Backnd, thebackend.io) — Republic of Korea
Tasks : Game account authentication; storage of inventory and game data; storage of in-game activity logs; server-side computation.
[Processor 2]
Entrusted to : Google LLC (Google Apps Script) — United States
Tasks : Operation of the Company's data-collection endpoint for user statistics and cheat-detection logging.
[Processor 3]
Entrusted to : Zendesk, Inc. — United States
Tasks : Operation of the Help Center; receipt, management, and reply to customer inquiries.
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Article 4 (Retention Period and Destruction)
Personal information is retained only for the period necessary, in accordance with the data minimization principle (GDPR Art. 5(1)(e)), and is destroyed as follows.
[Account and game data]
Retention : Retained while the account is active. When a User withdraws (resets) their account, game / user data is deleted immediately, and personal information is deleted within 7 days of withdrawal.
[Residual withdrawal records]
Items : UUID, sign-up date, last access date, and OS / device information at last access.
Retention : Retained after withdrawal only until deleted during the Company's periodic deletion process, which is carried out at least once every 90 days.
[Server request logs]
Retention : Automatically deleted 30 days after the date of the request.
[Cheat-detection data]
Retention : Collected only upon cheat detection. Retained for up to 1 year from the date of detection, solely to process the resulting sanction and any related appeal, after which it is deleted without delay.
Note : During this retention period, the right to erasure (GDPR Art. 17) may be restricted under GDPR Art. 17(3)(e) and the Company's legitimate interests (GDPR Art. 6(1)(f)) in establishing, exercising, or defending sanctions and related legal claims. Other rights — including access, restriction of processing, and objection — remain available. (See Article 6.)
[Help Center inquiry data]
Retention : Retained for 3 years from the date the inquiry is resolved, in line with the retention period for records of consumer complaints and dispute handling under the Enforcement Decree of the Korean Act on the Consumer Protection in Electronic Commerce, etc. (Art. 6), and then deleted without delay. Where applicable law requires a different retention period, that period applies.
[Steam ID (account identifier)]
Retention : Retained for the duration of active service use; deleted within 30 days of service termination.
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Article 5 (Third-Party Disclosure and International Transfers)
1. The Company does not provide personal information to third parties without the User's consent, except as required by applicable law. (Entrustment of processing under Article 3 is distinct from third-party provision.)
2. For Steam platform integration, Steam ID and game session authentication data are shared with Valve Corporation (acting as an independent data controller under its own Privacy Policy). No additional personal data is transferred to Valve beyond what is technically required for platform operation.
3. Steam Marketplace transactions are processed on the Steam platform; the related transaction records are collected and held by Valve Corporation under its own Privacy Policy, not by the Company.
4. International transfers:
- Data processed by AFI Inc. (Backnd) is stored in the Republic of Korea. For EU/EEA users, transfers to the Republic of Korea are covered by the European Commission's adequacy decision (2021), which recognizes Korea as ensuring an adequate level of data protection.
- Data processed by Google LLC is transferred to the United States under the EU-U.S. Data Privacy Framework and/or Standard Contractual Clauses, as permitted under GDPR Chapter V.
- Data processed by Zendesk, Inc. (Help Center inquiry data) may be transferred to the United States under the EU-U.S. Data Privacy Framework and/or Standard Contractual Clauses, as permitted under GDPR Chapter V.
- Transfers to Valve Corporation (US) are conducted under Valve's Standard Contractual Clauses or equivalent mechanism.
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Article 6 (User Rights)
[6-1. Rights regarding data held directly by the Company]
For personal data held directly by the Company (including your Steam ID, account and game data, in-game activity logs, and any data collected upon cheat detection), Users may exercise the following rights by contacting the Help Center (https://nugemstudio.zendesk.com/hc):
- Right of Access (GDPR Art. 15)
Request a copy of your personal data held by the Company.
- Right to Rectification (GDPR Art. 16)
Request correction of inaccurate personal data.
- Right to Erasure / "Right to be Forgotten" (GDPR Art. 17)
Request deletion of your personal data. Users may also delete their account directly through the in-game account withdrawal (reset) feature.
Exception: Where cheat-detection data has been collected, erasure of that data may be restricted for up to 1 year from the date of detection, pursuant to GDPR Art. 17(3)(e) and the Company's legitimate interests in enforcing and defending sanctions. The data is deleted once this purpose no longer applies.
- Right to Restriction of Processing (GDPR Art. 18)
Request restriction of processing in certain circumstances.
- Right to Data Portability (GDPR Art. 20)
Request your data in a machine-readable format.
- Right to Object (GDPR Art. 21)
Object to processing based on legitimate interests, including the processing of in-game activity logs.
The Company will respond within 30 days of receipt of a valid request.
[6-2. Rights regarding data held by Valve Corporation (Steam platform)]
Steam Inventory data and Steam account data are stored and managed by Valve Corporation as an independent data controller. For these data, Users should submit requests directly to: store.steampowered.com/contact
[6-3. Right to lodge a complaint]
EU/EEA Users have the right to lodge a complaint with their local Data Protection Authority (DPA) if they believe their data protection rights have been violated. A list of EU DPAs is available at:
edpb.europa.eu/about-edpb/about-edpb/members_en
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Article 7 (International Users)
1. EU/EEA Users: All rights under the GDPR (Regulation (EU) 2016/679) are guaranteed. Legal bases for each category of data processing are specified in Article 1 above. International transfers are conducted only where an adequacy decision or appropriate safeguards are in place, as described in Article 5.
2. California (US) Users: Rights under the CCPA are guaranteed, including the right to know, right to delete, and right to opt out of the sale of personal information. The Company does not sell Users' personal information to third parties.
3. Users in Other Regions: Applicable local personal data protection laws may apply.
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Article 8 (Controller and Privacy Officer)
[8-1. Controller]
The controller that determines the purposes and means of the processing of personal data under this Privacy Policy is Nugem Studio. Nugem Studio is responsible for the development, distribution, and operation of the Game, serves as the contact point for Users, and handles data subject rights requests.
Tesseract Studio, which was listed as a joint controller (GDPR Art. 26) in v1.5 and earlier, has merged into Nugem Studio. As a result, the joint-controller arrangement has ended, and Nugem Studio succeeds to the relevant rights and obligations as the sole controller.
[8-2. Privacy Officer]
For inquiries regarding personal data processing, please contact us below.
Privacy Officer : Data Protection Division, Nugem Studio
Contact : Help Center, https://nugemstudio.zendesk.com/hc
Response Hours : Weekdays 10:00 AM - 6:00 PM (KST)
Response Time : Within 30 days of receipt of a valid request
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Article 9 (Amendments to Privacy Policy)
This Privacy Policy may be revised in accordance with changes in applicable law or service. Revisions implemented without renewed consent will be announced at least 7 days prior to the effective date via in-game notices or Steam announcements.
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DOCUMENT CHANGE LOG
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v1.6 — Announced October 22, 2026 / Effective October 22, 2026 (KST); corresponds to client Ver 1.3.0 and later Disclosure of in-game activity logs:
- Added a new collection category "In-game activity logs", recorded on the Company's game server during normal online play: currency and item changes, growth records, stage and combat summaries, in-game market and mailbox records, authentication and entry events, and event banner / notice exposure and clicks with country information (Privacy Art. 1(5))
- Added the corresponding purposes: usage and in-game economy analysis, balance and usability improvement, event and notice effectiveness measurement, and investigation of item / currency discrepancies; legal basis set to legitimate interests (GDPR Art. 6(1)(f)) (Privacy Art. 1(5), Art. 2)
- Added storage of in-game activity logs to the tasks of Processor 1 (AFI Inc., Backnd) (Privacy Art. 3)
- Listed in-game activity logs among the data subject to user rights, and clarified that the right to object applies to them (Privacy Art. 6-1)
- Clarified that the "no behavioral-analytics SDKs" statement refers to third-party SDKs, and that first-party in-game activity logs are processed under the Privacy Policy (ToS Art. 8(1), 15(3); Privacy Art. 1)
Company information, contact channel, and Help Center updates:
- Changed the definition of "Minor" under Korean law from under 18 to under 19 (ToS Art. 2(3))
- Following the merger of Tesseract Studio into Nugem Studio, consolidated the party to the Terms and the developer designation as Nugem Studio (ToS Art. 1; document header), and removed the GDPR Art. 26 joint-controller clause, designating Nugem Studio as the sole controller (Privacy Art. 8)
- Changed the customer-support channel from email (help@nugemstudio.com) to the Help Center (https://nugemstudio.zendesk.com/hc) (ToS Art. 11(4), 12(3); Privacy Art. 6-1, 8-2; document header)
- Added collection of personal data when contacting the Help Center (email address, inquiry content and attachments, information provided by the User), with items, purposes, legal basis, and retention (Privacy Art. 1(6), Art. 2, Art. 4)
- Added Zendesk, Inc. (US) as the Help Center processor and the related international-transfer basis (Privacy Art. 3, Art. 5)
Refund policy and response time updates:
- Added an "In-App Purchase" definition (ToS Art. 2(11)) and extended the refund clause to DLC and In-App Purchases: the Company provides no separate refunds, and refunds are handled through Steam Customer Support under Valve Corporation's Steam Refund Policy (ToS Art. 10(2), 10(3))
- Unified the response time for sanction appeals to 30 days (previously 14 days), consistent with the response time for other requests (ToS Art. 11(4))
v1.5 — Announced June 13, 2026 / Corresponds to server-based client Ver 1.00.12 and later Correction of v1.4 and move to consent-version-based application:
- Reverted the amendment notice period from 3 days back to 7 days, and clarified that it applies only to amendments implemented without renewed consent and does not delay consent-based version changes (ToS Art. 3(2), 3(5); Privacy Art. 9)
- Switched the application basis from the client build to the version the User has consented to (recorded on the account); client version references are informational only. Users who have not consented to this version remain governed by the version to which they last consented; Users with no recorded consent must consent to the then-current version to use the Game (ToS Art. 3(4))
- Added an explicit "Effect of declining consent" clause: declining limits use to offline / previous-version features, with server-stored items and online features unavailable; includes guidance on requesting a copy of personal data before declining (ToS Art. 3(6))
- Corrected the Marketplace definition and transaction medium to Steam Wallet funds on the Steam Community Market (ToS Art. 2(6), 9(1), 10(4))
- Added a joint controllers clause under GDPR Art. 26: Nugem Studio (distribution, operation, contact point) and Tesseract Studio (co-development), with roles set out (Privacy Art. 8)
- Aligned SDK statements with actual practice: limited to "no advertising cookies or behavioral-analytics SDKs" and disclosed technical automatic collection necessary for operation and security (Privacy Art. 1; ToS Art. 15(3))
- Defined a purpose-bounded "game progress data" category among game-data and cheat-detection collection items, with representative examples (character level, in-game currency balances, stage progress); new categories of a different nature will be announced via policy amendment (Privacy Art. 1)
- Added consumer-rights preservation language to the item-value-change clauses (ToS Art. 6(2), 9(5))
- Added governing-language clause (English prevails) and a link to archived previous versions (ToS Art. 15)
v1.4 — Announced June 11, 2026 / Effective June 15, 2026 (superseded by v1.5) Dedicated game server migration (Backnd) — data processing update:
- Added processors: AFI Inc. (Backnd, Korea) and Google LLC (Apps Script, US)
(Privacy Art. 3)
- Disclosed data newly processed by the game server: Steam ID / App ID / auth ticket; IP & country, device & language, OS, nickname, access datetime; inventory & item-transaction data; client version (Privacy Art. 1)
- Expanded cheat-detection data items to match actual logging (Privacy Art. 1)
- Added retention & destruction rules incl. account withdrawal (immediate data deletion, personal info within 7 days), residual-record periodic deletion, and 30-day server request logs (Privacy Art. 4)
- Clarified that the right to erasure (GDPR Art. 17) may be restricted for cheat-detection data for up to 1 year from detection, under Art. 17(3)(e) and legitimate interests, while access / restriction / objection rights remain available (Privacy Art. 4, Art. 6)
- Added international transfer bases: Korea adequacy decision; EU-U.S. DPF / SCCs (Privacy Art. 5)
- Updated ToS Art. 8 to reflect dedicated server processing of online features
- Added mandatory-collection notice for online service login (Privacy Art. 1)
- Shortened amendment notice period from 7 days to 3 days (reverted in v1.5)
v1.3 — Announced May 29, 2026 / Effective June 6, 2026 Data collection disclosure corrected to reflect actual data minimization practice:
- Rewrote "Information We Collect" to a two-tier model: only Steam ID is collected on first access; additional data is collected solely upon cheat detection (Privacy Art. 1)
- Removed data categories that are not actually collected: marketplace transaction records, device/access information, bug reports & error logs (Privacy Art. 1, 3)
- Narrowed processing purposes accordingly (Privacy Art. 2)
- Updated retention periods to match (Privacy Art. 3)
- Clarified that Steam Marketplace records are held by Valve, not the Company (Privacy Art. 4)
v1.2 — Announced May 28, 2026 / Effective June 5, 2026
- Changed contact email to help@nugemstudio.com
- Terms effective immediately upon first publication; subsequent amendments effective 7 days after announcement (ToS Art. 3; Privacy Art. 8)
v1.1 — May 28, 2026
GDPR compliance update:
- Added per-data-type legal bases (Privacy Art. 1)
- Clarified consent mechanism as checkbox + confirm button (ToS Art. 3)
- Revised data retention by data type (Privacy Art. 3)
- Added data subject rights with GDPR article references (Privacy Art. 5)
- Clarified Valve data-sharing scope and SCCs (Privacy Art. 4)
- Added EU DPA complaint right (Privacy Art. 5-3)
- Updated Minor definition for EU age thresholds (ToS Art. 2)
- Added service termination data export notice (ToS Art. 12)
- Added tracking/analytics SDK disclaimer (ToS Art. 15)
v1.0 — May 27, 2026
Initial release.
=================
Terms of Service & Privacy Policy
Applies to
This version of the Terms applies to Users who have consented to this version through the in-client consent process. This version corresponds to the server-based client (Ver 1.3.0 and later). Users who have not consented to this version remain governed by the version of the Terms to which they last consented, until they consent to this version. Users with no recorded consent to any version must consent to the then-current version in order to use the Game.
Developer: Nugem Studio
Contact: https://nugemstudio.zendesk.com/hc
IMPORTANT NOTICE
Please read these Terms carefully before playing TBH: Task Bar Hero. When you first launch a client that requires this version, you will be asked to review and consent to these Terms. Consent is required to use the online (server-based) features. The version you consent to is recorded on your account. If you do not consent, you may continue to use offline features or previous-version features under the terms to which you last consented, but you may not use online features that require the current version.
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TERMS OF SERVICE
=================
Article 1 (Purpose)
These Terms of Service (hereinafter "Terms") govern the rights, obligations, responsibilities, and personal data processing between Nugem Studio (hereinafter "Company") and users in connection with the use of TBH: Task Bar Hero (hereinafter "Game").
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Article 2 (Definitions)
The terms used in these Terms are defined as follows.
1. "Game" refers to TBH: Task Bar Hero and all related services provided by the Company.
2. "User" refers to any person who explicitly agrees to these Terms via the consent process and uses the Game.
3. "Minor" refers to any person under the age of 19 under the laws of the Republic of Korea. For users in the European Union, "Minor" additionally refers to any person under the age of 16 (or such lower age as permitted by the applicable EU Member State law, but no lower than 13). For users in other jurisdictions, the age threshold defined by applicable local law shall apply.
4. "Legal Guardian" refers to a parent or legal guardian of a Minor.
5. "Game Item" refers to digital content generated or acquired through the in-game network features.
6. "Marketplace" refers to the Steam Community Market, where users may trade Game Items using Steam Wallet funds.
7. "Game Data" refers to all data generated during gameplay, including play logs, item holdings, and transaction history.
8. "License" refers to the limited, non-exclusive, revocable right to use the Game.
9. "Personal Information" refers to information that identifies or can identify an individual.
10. "Platform" refers to the Steam service operated by Valve Corporation.
11. "In-App Purchase" refers to any purchase of digital content, virtual items, or other paid features made within the Game through the Platform.
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Article 3 (Effectiveness and Amendment of Terms)
1. These Terms become effective when the User explicitly consents by checking the consent checkbox and clicking the confirmation button upon launching the Game. Users who do not consent may not proceed to use the online (server-based) features of the Game.
2. These Terms become effective immediately upon first publication. The Company may amend these Terms within the scope permitted by applicable laws. Any subsequent amendments will be announced at least 7 days prior to the effective date via in-game notices or Steam announcements.
3. If a User does not agree to the amended Terms, the User may discontinue use of the Game. Continued use after the announcement of amendments shall be deemed as consent to the amended Terms.
4. Consent-version-based application: This version of the Terms applies to Users who have consented to this version through the in-client consent process. The version a User consents to is recorded on the User's account. Use of the online (server-based) features requires consent to the then-current version. A User whose recorded consent version is not the current version will be asked to review and consent to the current version at the next online login, before using online features. A User who does not consent may continue to use offline features or previous-version features under the terms to which the User previously consented, but may not use online features that require the current version. A User with no recorded consent to any version must consent to the then-current version in order to use the Game. References to a specific client version (Ver 1.3.0 and later) are informational only, indicating the client to which this version of the Terms corresponds, and do not by themselves determine which version of the Terms applies to a User.
5. Relationship to the notice period: The advance-notice period in Article 3(2) applies only to amendments that the Company implements without renewed consent. Where a new version is applied through the User's active in-client consent, that version takes effect for that User at the moment of consent, and the notice period in Article 3(2) does not apply to, and does not delay, such consent-based changes.
6. Effect of declining consent: Online features — including server-stored inventory, item generation, and Marketplace-related features — are provided only to Users who have consented to the then-current version of the Terms. A User who declines may use only offline features or previous-version features, and cannot access server-stored items or online features. Before declining, a User may request a copy of their personal data held by the Company in accordance with Article 6 of the Privacy Policy.
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Article 4 (Use by Minors)
1. Minors must obtain consent from their Legal Guardian prior to using the Game. For EU/EEA users, the applicable age thresholds defined in Article 2(3) above apply.
2. If a Minor uses the Game without the consent of their Legal Guardian, the Legal Guardian may cancel such use. However, cancellation may be restricted if the Minor misrepresented themselves as an adult.
3. Legal Guardians may request the Company to review a Minor's game usage history and impose usage restrictions.
4. The Company implements measures to protect Minors in accordance with applicable laws, including youth protection regulations and, where applicable, the GDPR (for EU/EEA users).
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Article 5 (License and Intellectual Property)
1. The Company grants Users a limited, non-exclusive, non-transferable license to use the Game for personal, non-commercial purposes. This license may not be assigned, sold, leased, or sublicensed.
2. Users may not modify, reverse engineer, reproduce, or distribute the Game.
3. All copyrights and intellectual property rights to content within the Game (including graphics, music, sound, code, characters, story, and UI) belong to the Company.
4. Users are permitted to share content created in relation to the Game (such as screenshots and videos) for non-commercial purposes. Commercial use requires prior written consent from the Company.
5. The Company may terminate the License after notifying the User in the event of a Terms violation.
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Article 6 (Service Provision and Changes)
1. The Company may modify game content, systems, and item structures as operationally required.
2. Updates may change the performance or value of existing items, and no separate compensation will be provided for such changes. However, the Company will provide advance notice of significant changes. Rights guaranteed to Users under applicable mandatory laws (such as consumer protection laws) are not limited by this paragraph.
3. Some features of the Game require a network (internet) connection.
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Article 7 (Steam Account and Platform)
1. This Game is provided through the Steam platform operated by Valve Corporation.
2. Users are responsible for the security of their Steam accounts. The Company is not responsible for damages resulting from account theft or hacking, unless caused by the Company's own fault.
3. Valve Corporation's terms of service take precedence with respect to Steam platform policies.
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Article 8 (Network Features and Game Item Generation)
1. The Game uses a network (internet) connection for online features. Online features — including account login, inventory, item generation, and item transactions — are processed and stored on the Company's dedicated game server, which is operated through a processor (see Privacy Policy Article 3). In-game activity logs are also recorded on this server as described in Article 1(5) of the Privacy Policy.
2. Game Items generated through the network are digital content within the Game and do not represent real-world assets or investment instruments.
3. The Company is not responsible for item generation failures caused by unstable network connections, server maintenance, or force majeure events.
4. Users must not use unauthorized methods (such as hacks, macros, or third-party programs) during item generation.
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Article 9 (Marketplace Transactions)
1. Game Items may be traded on the Steam Marketplace (Steam Community Market) using Steam Wallet funds.
2. Marketplace transactions are governed by Valve Corporation's Steam Terms of Service and Marketplace policies. The Company does not directly intervene in Steam platform trading policies.
3. The Company is not responsible for profits, losses, or disputes arising from transactions, which are handled under Steam platform policies.
4. Abnormal transactions, deliberate price manipulation, and fraudulent activities are strictly prohibited and may result in usage restrictions upon detection.
5. The Company may modify item attributes for economic balance purposes and is not responsible for changes in trading value resulting from such modifications. Rights guaranteed to Users under applicable mandatory laws are not limited by this paragraph.
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Article 10 (Refund Policy)
1. The Game is provided free of charge, and refunds do not apply to the Game itself.
2. DLC (Downloadable Content) and In-App Purchases are purchased through the Platform. The Company does not provide separate refunds for DLC or In-App Purchases. Refunds are handled entirely in accordance with Valve Corporation's Steam Refund Policy, and the Company has no authority to process such refunds directly.
3. Users wishing to request a refund for DLC or an In-App Purchase should do so directly through Steam Customer Support at store.steampowered.com/support. Whether a refund is granted, and within what period, is determined in accordance with Valve Corporation's policies.
4. Steam Wallet transactions on the Steam Marketplace are also subject to Valve Corporation's policies, and the Company has no authority to process refunds for such transactions.
5. Consumer rights guaranteed by applicable mandatory laws (such as consumer protection laws and EU Consumer Rights Directive) are preserved regardless of these Terms.
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Article 11 (User Obligations)
1. Users must not engage in the following activities:
- Using unauthorized methods such as hacks, macros, or auto programs
- Exploiting in-game bugs or vulnerabilities
- Price manipulation, fraud, or abnormal transactions in the Marketplace
- Infringing upon the Company's intellectual property rights
- Using Game content for unauthorized commercial purposes
- Violating applicable laws and regulations
2. The Company may operate automated systems to detect fraudulent activities.
3. Upon confirmation of a violation, the Company may take the following actions:
- Warning and prior notice
- Temporary suspension of game access
- Item recovery
- Permanent ban from the Game
4. Users may appeal the Company's sanctions by submitting a request through the Help Center (https://nugemstudio.zendesk.com/hc). The Company will notify the User of the outcome within 30 days of receipt.
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Article 12 (Service Changes and Suspension)
1. The Company may modify or suspend service content as operationally or technically required.
2. In the event of a service suspension, the Company will provide at least 30 days' advance notice via Steam announcements. However, post-hoc notice may be given in cases of force majeure.
3. Upon service termination, the Company will provide at least 30 days' prior notice via in-game announcements and Steam. During this notice period, users may request a copy of their personal data held directly by the Company by contacting the Help Center (https://nugemstudio.zendesk.com/hc).
4. Game Items and Game Data will be deleted upon service termination. The Company bears no obligation to compensate for such deletion unless otherwise required by applicable mandatory law.
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Article 13 (Disclaimer)
1. The Company is not liable for service interruptions caused by force majeure events such as natural disasters, war, hacking, or server failures.
2. The Company is not liable for damages caused by the User's own fault.
3. The Company is not liable for service changes resulting from policy changes by Steam or Valve Corporation.
4. The Company's liability for damages is limited to the maximum extent permitted by applicable laws.
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Article 14 (Governing Law and Dispute Resolution)
1. These Terms shall be interpreted and applied in accordance with the laws of the Republic of Korea.
2. In the event of a dispute arising from the use of the Game, the Company and the User shall in principle resolve it through mutual consultation.
3. If no agreement is reached, the competent court shall be determined in accordance with the Civil Procedure Act.
4. For international users, applicable mandatory local laws — including EU consumer protection laws — may take precedence over these Terms.
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Article 15 (Miscellaneous)
1. Matters not specified in these Terms shall be governed by applicable laws and the Steam platform's terms of service.
2. If any provision of these Terms is found to be invalid under applicable law, the remaining provisions shall remain in full force and effect.
3. The Company does not use advertising cookies or third-party behavioral-analytics SDKs within the Game. Technical data necessary for the operation and security of the online service, and in-game activity logs recorded by the Company on its own game server, are processed as described in the Privacy Policy. Steam's built-in platform telemetry is governed by Valve Corporation's Privacy Policy.
4. Language: These Terms are provided in multiple languages. In the event of any discrepancy in interpretation between the translated versions, the English version shall prevail.
5. Previous versions: Previous versions of these Terms and the Privacy Policy are archived and remain available to Users at:
https://docs.google.com/document/d/1b9wt29PHDeek6lXvZSwF0wjZZs2LY1xXMMa6w8q2ZxQ/edit?usp=sharing
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PRIVACY POLICY
=================
Applies to: Users who have consented to this version through the in-client consent process. This version corresponds to the server-based client (Ver 1.3.0 and later). Users who have not consented to this version remain governed by the version of the Privacy Policy to which they last consented, until they consent to this version.
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Article 1 (Information We Collect and Legal Basis)
TBH: Task Bar Hero follows a data minimization policy: the Company collects only the data necessary to operate the game's online features, secure user accounts, prevent abuse, and maintain and improve the Game. The Company does not use advertising cookies or third-party behavioral-analytics SDKs; technical data necessary for the operation and security of the online service, and in-game activity logs recorded by the Company on its own game server, are processed as described in this Privacy Policy.
With the introduction of a dedicated game server (operated through a processor; see Article 3), online features such as account login, inventory, and item transactions are processed and stored on the server. The data below is collected accordingly.
[1. Collected on account login / first access — applies to all online users]
Items : - Steam ID
- App ID
- Steam authentication session ticket (one-time login token)
Purpose : Account identification and login authentication.
Legal Basis : Contract performance (GDPR Art. 6(1)(b))
[2. Automatically collected by the game server when using online features]
The following is automatically recorded by the game server (via the processor's SDK) each time the Game connects to the server.
Items : - IP address and IP-based country information
- Device information and device-based language
- OS information
- Nickname
- Access (call) date and time, including login
Purpose : Operation and stability of the online service; account security; prevention of abuse and unauthorized access.
Legal Basis : Contract performance (GDPR Art. 6(1)(b)) and legitimate interests in security and abuse prevention (GDPR Art. 6(1)(f))
[3. Game data — collected to provide online features]
Items : - Inventory data (item IDs, item instance keys, chest cooldown)
- Item acquisition, consumption, and exchange (synthesis / opening)
request records
- Game client version (for compatibility verification)
- Game progress data: data constituting the User's saved game state (e.g., character level, in-game currency balances, stage progress). Items within this category may be added or changed as game content evolves, and data in this category is processed only within the scope of storing and validating game progress. If the Company begins to collect a new category of data of a different nature, this will be announced through an amendment to this Privacy Policy.
Purpose : Server-side storage of game progress; server-side validation of item grants and exchanges; client version compatibility.
Legal Basis : Contract performance (GDPR Art. 6(1)(b))
[4. Collected only upon cheat detection]
Collected ONLY when the anti-cheat system detects the potential use of cheat software or other abnormal activity. It is NOT collected during normal play.
Items : - Steam ID and game version
- Current and highest stage progress
- Cumulative playtime
- Game progress data at the time of detection (e.g., character level, in-game currency balances)
- Detection rule ID and related detection parameters
Purpose : Detection of cheating and maintaining a fair play environment.
Legal Basis : Legitimate interests — fraud prevention and fair play (GDPR Art. 6(1)(f))
[5. In-game activity logs — recorded during normal play]
While the User plays online, the Game records in-game actions and their results on the Company's game server. These logs are linked to the User's game account.
Items : - In-game currency (gold) changes, including the amount and the balance before and after the change
- Item acquisition, consumption, crafting, synthesis, opening, and item-option changes, including item keys, quantities before and after, and related item identifiers
- Growth records (e.g., hero, cube, and rune level-ups and experience changes)
- Stage and combat summaries (e.g., stage, monster, number of monsters defeated, offline rewards)
- In-game market and mailbox records (item registration, removal, and receipt)
- Game authentication and game entry events
- Exposure of and clicks on in-game event banners and notices, together with country information (country code only)
- Log time and log identifiers used to link related records
Purpose : Analysis of how the Game and its economy are used; game balance and usability improvement; measuring the effectiveness of in-game events and notices; investigating item or currency discrepancies and responding to User inquiries; detection of abnormal activity.
Legal Basis : Legitimate interests in operating, improving, and securing the Game and its economy (GDPR Art. 6(1)(f)). Users may object to this processing under Article 6.
[6. Help Center inquiries — only if you submit an inquiry]
Collected only when a User submits an inquiry, a sanction appeal, or a data-subject rights request through the Help Center
(https://nugemstudio.zendesk.com/hc).
Items : - Email address
- Inquiry subject, message content, and any files you attach
- Information you choose to provide in the course of the inquiry (e.g., Steam ID, nickname, client version)
Purpose : Receiving and handling inquiries, appeals, and rights requests; identity verification; replying with the outcome.
Legal Basis : Contract performance (GDPR Art. 6(1)(b)) and legitimate interests in responding to inquiries (GDPR Art. 6(1)(f))
Note : Using the Help Center is optional; however, the Company cannot reply to an inquiry without an email address.
Note: Providing the data in Section 1 is required to use the online service. Without a Steam ID and login authentication, server login is not possible and online features cannot be provided.
Note: Steam Marketplace transactions are processed on the Steam platform; the related transaction records are held by Valve Corporation, not by the Company. (See Article 5.)
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Article 2 (Purpose of Collection)
Collected information is used solely for the following purposes:
- Account identification and login authentication
- Provision and stable operation of online features (inventory, item transactions, game progress storage)
- Server-side validation of item grants and exchanges
- Account security and prevention of abuse / unauthorized access
- Detection of cheating and maintaining a fair play environment
- Client version compatibility verification
- Analysis of game and in-game economy usage, and improvement of game balance and usability
- Measuring the effectiveness of in-game events and notices
- Investigating item or currency discrepancies and responding to User inquiries
- Receiving and handling inquiries, appeals, and data-subject rights requests
- Responding to sanction-related appeals and legal disputes
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Article 3 (Processing Entrustment)
To operate the online service, the Company entrusts the processing of personal data to the processors below. The Company enters into a data processing agreement with each processor as required under GDPR Art. 28.
[Processor 1]
Entrusted to : AFI Inc. (Backnd, thebackend.io) — Republic of Korea
Tasks : Game account authentication; storage of inventory and game data; storage of in-game activity logs; server-side computation.
[Processor 2]
Entrusted to : Google LLC (Google Apps Script) — United States
Tasks : Operation of the Company's data-collection endpoint for user statistics and cheat-detection logging.
[Processor 3]
Entrusted to : Zendesk, Inc. — United States
Tasks : Operation of the Help Center; receipt, management, and reply to customer inquiries.
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Article 4 (Retention Period and Destruction)
Personal information is retained only for the period necessary, in accordance with the data minimization principle (GDPR Art. 5(1)(e)), and is destroyed as follows.
[Account and game data]
Retention : Retained while the account is active. When a User withdraws (resets) their account, game / user data is deleted immediately, and personal information is deleted within 7 days of withdrawal.
[Residual withdrawal records]
Items : UUID, sign-up date, last access date, and OS / device information at last access.
Retention : Retained after withdrawal only until deleted during the Company's periodic deletion process, which is carried out at least once every 90 days.
[Server request logs]
Retention : Automatically deleted 30 days after the date of the request.
[Cheat-detection data]
Retention : Collected only upon cheat detection. Retained for up to 1 year from the date of detection, solely to process the resulting sanction and any related appeal, after which it is deleted without delay.
Note : During this retention period, the right to erasure (GDPR Art. 17) may be restricted under GDPR Art. 17(3)(e) and the Company's legitimate interests (GDPR Art. 6(1)(f)) in establishing, exercising, or defending sanctions and related legal claims. Other rights — including access, restriction of processing, and objection — remain available. (See Article 6.)
[Help Center inquiry data]
Retention : Retained for 3 years from the date the inquiry is resolved, in line with the retention period for records of consumer complaints and dispute handling under the Enforcement Decree of the Korean Act on the Consumer Protection in Electronic Commerce, etc. (Art. 6), and then deleted without delay. Where applicable law requires a different retention period, that period applies.
[Steam ID (account identifier)]
Retention : Retained for the duration of active service use; deleted within 30 days of service termination.
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Article 5 (Third-Party Disclosure and International Transfers)
1. The Company does not provide personal information to third parties without the User's consent, except as required by applicable law. (Entrustment of processing under Article 3 is distinct from third-party provision.)
2. For Steam platform integration, Steam ID and game session authentication data are shared with Valve Corporation (acting as an independent data controller under its own Privacy Policy). No additional personal data is transferred to Valve beyond what is technically required for platform operation.
3. Steam Marketplace transactions are processed on the Steam platform; the related transaction records are collected and held by Valve Corporation under its own Privacy Policy, not by the Company.
4. International transfers:
- Data processed by AFI Inc. (Backnd) is stored in the Republic of Korea. For EU/EEA users, transfers to the Republic of Korea are covered by the European Commission's adequacy decision (2021), which recognizes Korea as ensuring an adequate level of data protection.
- Data processed by Google LLC is transferred to the United States under the EU-U.S. Data Privacy Framework and/or Standard Contractual Clauses, as permitted under GDPR Chapter V.
- Data processed by Zendesk, Inc. (Help Center inquiry data) may be transferred to the United States under the EU-U.S. Data Privacy Framework and/or Standard Contractual Clauses, as permitted under GDPR Chapter V.
- Transfers to Valve Corporation (US) are conducted under Valve's Standard Contractual Clauses or equivalent mechanism.
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Article 6 (User Rights)
[6-1. Rights regarding data held directly by the Company]
For personal data held directly by the Company (including your Steam ID, account and game data, in-game activity logs, and any data collected upon cheat detection), Users may exercise the following rights by contacting the Help Center (https://nugemstudio.zendesk.com/hc):
- Right of Access (GDPR Art. 15)
Request a copy of your personal data held by the Company.
- Right to Rectification (GDPR Art. 16)
Request correction of inaccurate personal data.
- Right to Erasure / "Right to be Forgotten" (GDPR Art. 17)
Request deletion of your personal data. Users may also delete their account directly through the in-game account withdrawal (reset) feature.
Exception: Where cheat-detection data has been collected, erasure of that data may be restricted for up to 1 year from the date of detection, pursuant to GDPR Art. 17(3)(e) and the Company's legitimate interests in enforcing and defending sanctions. The data is deleted once this purpose no longer applies.
- Right to Restriction of Processing (GDPR Art. 18)
Request restriction of processing in certain circumstances.
- Right to Data Portability (GDPR Art. 20)
Request your data in a machine-readable format.
- Right to Object (GDPR Art. 21)
Object to processing based on legitimate interests, including the processing of in-game activity logs.
The Company will respond within 30 days of receipt of a valid request.
[6-2. Rights regarding data held by Valve Corporation (Steam platform)]
Steam Inventory data and Steam account data are stored and managed by Valve Corporation as an independent data controller. For these data, Users should submit requests directly to: store.steampowered.com/contact
[6-3. Right to lodge a complaint]
EU/EEA Users have the right to lodge a complaint with their local Data Protection Authority (DPA) if they believe their data protection rights have been violated. A list of EU DPAs is available at:
edpb.europa.eu/about-edpb/about-edpb/members_en
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Article 7 (International Users)
1. EU/EEA Users: All rights under the GDPR (Regulation (EU) 2016/679) are guaranteed. Legal bases for each category of data processing are specified in Article 1 above. International transfers are conducted only where an adequacy decision or appropriate safeguards are in place, as described in Article 5.
2. California (US) Users: Rights under the CCPA are guaranteed, including the right to know, right to delete, and right to opt out of the sale of personal information. The Company does not sell Users' personal information to third parties.
3. Users in Other Regions: Applicable local personal data protection laws may apply.
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Article 8 (Controller and Privacy Officer)
[8-1. Controller]
The controller that determines the purposes and means of the processing of personal data under this Privacy Policy is Nugem Studio. Nugem Studio is responsible for the development, distribution, and operation of the Game, serves as the contact point for Users, and handles data subject rights requests.
Tesseract Studio, which was listed as a joint controller (GDPR Art. 26) in v1.5 and earlier, has merged into Nugem Studio. As a result, the joint-controller arrangement has ended, and Nugem Studio succeeds to the relevant rights and obligations as the sole controller.
[8-2. Privacy Officer]
For inquiries regarding personal data processing, please contact us below.
Privacy Officer : Data Protection Division, Nugem Studio
Contact : Help Center, https://nugemstudio.zendesk.com/hc
Response Hours : Weekdays 10:00 AM - 6:00 PM (KST)
Response Time : Within 30 days of receipt of a valid request
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Article 9 (Amendments to Privacy Policy)
This Privacy Policy may be revised in accordance with changes in applicable law or service. Revisions implemented without renewed consent will be announced at least 7 days prior to the effective date via in-game notices or Steam announcements.
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DOCUMENT CHANGE LOG
=================
v1.6 — Announced October 22, 2026 / Effective October 22, 2026 (KST); corresponds to client Ver 1.3.0 and later Disclosure of in-game activity logs:
- Added a new collection category "In-game activity logs", recorded on the Company's game server during normal online play: currency and item changes, growth records, stage and combat summaries, in-game market and mailbox records, authentication and entry events, and event banner / notice exposure and clicks with country information (Privacy Art. 1(5))
- Added the corresponding purposes: usage and in-game economy analysis, balance and usability improvement, event and notice effectiveness measurement, and investigation of item / currency discrepancies; legal basis set to legitimate interests (GDPR Art. 6(1)(f)) (Privacy Art. 1(5), Art. 2)
- Added storage of in-game activity logs to the tasks of Processor 1 (AFI Inc., Backnd) (Privacy Art. 3)
- Listed in-game activity logs among the data subject to user rights, and clarified that the right to object applies to them (Privacy Art. 6-1)
- Clarified that the "no behavioral-analytics SDKs" statement refers to third-party SDKs, and that first-party in-game activity logs are processed under the Privacy Policy (ToS Art. 8(1), 15(3); Privacy Art. 1)
Company information, contact channel, and Help Center updates:
- Changed the definition of "Minor" under Korean law from under 18 to under 19 (ToS Art. 2(3))
- Following the merger of Tesseract Studio into Nugem Studio, consolidated the party to the Terms and the developer designation as Nugem Studio (ToS Art. 1; document header), and removed the GDPR Art. 26 joint-controller clause, designating Nugem Studio as the sole controller (Privacy Art. 8)
- Changed the customer-support channel from email (help@nugemstudio.com) to the Help Center (https://nugemstudio.zendesk.com/hc) (ToS Art. 11(4), 12(3); Privacy Art. 6-1, 8-2; document header)
- Added collection of personal data when contacting the Help Center (email address, inquiry content and attachments, information provided by the User), with items, purposes, legal basis, and retention (Privacy Art. 1(6), Art. 2, Art. 4)
- Added Zendesk, Inc. (US) as the Help Center processor and the related international-transfer basis (Privacy Art. 3, Art. 5)
Refund policy and response time updates:
- Added an "In-App Purchase" definition (ToS Art. 2(11)) and extended the refund clause to DLC and In-App Purchases: the Company provides no separate refunds, and refunds are handled through Steam Customer Support under Valve Corporation's Steam Refund Policy (ToS Art. 10(2), 10(3))
- Unified the response time for sanction appeals to 30 days (previously 14 days), consistent with the response time for other requests (ToS Art. 11(4))
v1.5 — Announced June 13, 2026 / Corresponds to server-based client Ver 1.00.12 and later Correction of v1.4 and move to consent-version-based application:
- Reverted the amendment notice period from 3 days back to 7 days, and clarified that it applies only to amendments implemented without renewed consent and does not delay consent-based version changes (ToS Art. 3(2), 3(5); Privacy Art. 9)
- Switched the application basis from the client build to the version the User has consented to (recorded on the account); client version references are informational only. Users who have not consented to this version remain governed by the version to which they last consented; Users with no recorded consent must consent to the then-current version to use the Game (ToS Art. 3(4))
- Added an explicit "Effect of declining consent" clause: declining limits use to offline / previous-version features, with server-stored items and online features unavailable; includes guidance on requesting a copy of personal data before declining (ToS Art. 3(6))
- Corrected the Marketplace definition and transaction medium to Steam Wallet funds on the Steam Community Market (ToS Art. 2(6), 9(1), 10(4))
- Added a joint controllers clause under GDPR Art. 26: Nugem Studio (distribution, operation, contact point) and Tesseract Studio (co-development), with roles set out (Privacy Art. 8)
- Aligned SDK statements with actual practice: limited to "no advertising cookies or behavioral-analytics SDKs" and disclosed technical automatic collection necessary for operation and security (Privacy Art. 1; ToS Art. 15(3))
- Defined a purpose-bounded "game progress data" category among game-data and cheat-detection collection items, with representative examples (character level, in-game currency balances, stage progress); new categories of a different nature will be announced via policy amendment (Privacy Art. 1)
- Added consumer-rights preservation language to the item-value-change clauses (ToS Art. 6(2), 9(5))
- Added governing-language clause (English prevails) and a link to archived previous versions (ToS Art. 15)
v1.4 — Announced June 11, 2026 / Effective June 15, 2026 (superseded by v1.5) Dedicated game server migration (Backnd) — data processing update:
- Added processors: AFI Inc. (Backnd, Korea) and Google LLC (Apps Script, US)
(Privacy Art. 3)
- Disclosed data newly processed by the game server: Steam ID / App ID / auth ticket; IP & country, device & language, OS, nickname, access datetime; inventory & item-transaction data; client version (Privacy Art. 1)
- Expanded cheat-detection data items to match actual logging (Privacy Art. 1)
- Added retention & destruction rules incl. account withdrawal (immediate data deletion, personal info within 7 days), residual-record periodic deletion, and 30-day server request logs (Privacy Art. 4)
- Clarified that the right to erasure (GDPR Art. 17) may be restricted for cheat-detection data for up to 1 year from detection, under Art. 17(3)(e) and legitimate interests, while access / restriction / objection rights remain available (Privacy Art. 4, Art. 6)
- Added international transfer bases: Korea adequacy decision; EU-U.S. DPF / SCCs (Privacy Art. 5)
- Updated ToS Art. 8 to reflect dedicated server processing of online features
- Added mandatory-collection notice for online service login (Privacy Art. 1)
- Shortened amendment notice period from 7 days to 3 days (reverted in v1.5)
v1.3 — Announced May 29, 2026 / Effective June 6, 2026 Data collection disclosure corrected to reflect actual data minimization practice:
- Rewrote "Information We Collect" to a two-tier model: only Steam ID is collected on first access; additional data is collected solely upon cheat detection (Privacy Art. 1)
- Removed data categories that are not actually collected: marketplace transaction records, device/access information, bug reports & error logs (Privacy Art. 1, 3)
- Narrowed processing purposes accordingly (Privacy Art. 2)
- Updated retention periods to match (Privacy Art. 3)
- Clarified that Steam Marketplace records are held by Valve, not the Company (Privacy Art. 4)
v1.2 — Announced May 28, 2026 / Effective June 5, 2026
- Changed contact email to help@nugemstudio.com
- Terms effective immediately upon first publication; subsequent amendments effective 7 days after announcement (ToS Art. 3; Privacy Art. 8)
v1.1 — May 28, 2026
GDPR compliance update:
- Added per-data-type legal bases (Privacy Art. 1)
- Clarified consent mechanism as checkbox + confirm button (ToS Art. 3)
- Revised data retention by data type (Privacy Art. 3)
- Added data subject rights with GDPR article references (Privacy Art. 5)
- Clarified Valve data-sharing scope and SCCs (Privacy Art. 4)
- Added EU DPA complaint right (Privacy Art. 5-3)
- Updated Minor definition for EU age thresholds (ToS Art. 2)
- Added service termination data export notice (ToS Art. 12)
- Added tracking/analytics SDK disclaimer (ToS Art. 15)
v1.0 — May 27, 2026
Initial release.
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